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1N THE JUSTICE COLIT OF TOWNSHIP


4 COUNTY OF C ,STATE OF NEVADA
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APPLICATION FOR TEMPORARY
ORER FOR PROTECTION AGAINST
HARASSMENT IN THE WORKPLACE
vs (NRS 33.250)

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Adverse Part*
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(NUTI:1fIAO 0al}br0urAd1rr\r Par,)
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HASMENT L THE WKKAL\- 'uder lS JJ.74. harassmfnt in the
workplace 0\when:
\. Aperson knowingly tbreatens to cause or commits an act that rauses:
(a) Bodily Injury to himself or anotber person;
(b) Damage to tbe property of auotber person; 0`
(t)Substautlal harm to tb . pbyslral or mental health or safely of a puson;
7. The tllreat Is made or tbe act Is committed against an employer, an employee of tbe
employer wblle tbe employee performs bls dnties of employment or a person present
at the workplace of tbe employer; and
J. Tbe threat would rans. a reasonable person to fear tbat tbe tbreat be carried
out or the act would cause a reasonable person to feel terrol'lzed, fI'Igbtened,
lutimidated or harassed.
PLEASE TYPE OR PRINT CLEARLY.
COMPLETE THE APPLICATION TO THE BEST OF YOUR K;OWLEDGE,
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!reasonably believe that the Adverse Palty has threatened or committed an act or act( s) of
harassment ill the workplace as delucd above, !\c evcnt(s) OCCUlTed as follows:

NOTE: 8E SPEC/C AS WHO l14TENED OR COMMlTTED rr1TACT OR


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ACTS AND AGA1NST WHOM. lIC. 4TE APPROXMATE DATE(S) AND
LOCATION(S) .. 4LSO LIST SPECIFC EMPLOYEE(S)IPERSON(S) PRENT AT THE
' WORKPLACE WHO ARE THE FOCUS OF THE HARASSMT OR WHOM THE
ADVERSE PARTY SHOULD BE DIECTED NOT TO CON1AC1:
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`J. PLEASE DO NOT HKON THE BACKS OF ANY PAGES;
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:utn:r=tcn
(Complete H, both)

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NOTICE REQUIREMENTS
( either A or nol
A_ Application to the Adverse Party by the Collowing
methodes):
uPerson
\have received confnnation that the Adverse Party has received my ApplicatIOn for
a Temporar Order for Protection Against Harassment in the Workplace. Conftion
of receipt is attached (ie + fax, e-mail, postal mail, etc.).
!have not received continuation,
B. I HAVE NOT given notice of this Application to the Adverse Pnty because
immediate and lneparable inJluy, loss, or damage will result to the employer, an employee of te
employer while the employee perfomlS the duties of his employment, or a person who \5 present
at the worklace of the employer, before te matter can be heard on notice. TIle ineparable
injmy, loss, or damage that may ie5ult is:
~+,, ,,,-,-,--------.~=
It is ineparabJe becaue of:
Possible economic or property damage which uuy i1kludC the following: __
Continuols tlueat of stalking!llarassment
Asslultiatter (persoualuIJu)
Possible death !O specifed individuals Hamed in the Appiicatioll
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GENERAL INfORlfATION
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(a) u !|d0|!0I I0Ic0IlOuylu8I0U0>Ii< ~l00uCc (PK5 Jo.0Z0)
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Please Lbrcktbe Appropriate BOI Below:
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0Iu8I00 Pd\0|0uIIyunywhre Iuue:!atoI^eVada,mdt0cAdvcr>cmhasIL
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Case # Court PlaL0of Appro!. Outcome (TPO
(if known) Filing Date Flie
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granted, denied, (JusticefFamily)
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Employee( s) also work at Ih0d
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I!|0u spccIHclocations Ih!need !Ohe enUlnerared
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`. PUAS: CHECK THE iPPROPRATE BOX(ES) BELOW, IF APPLICABLE.
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(If you wish to designate more specifc addresses, please list them in tbis Cormat on a
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protection is Ileeded: .__ _____ _ _ _ ___ ___
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REQUESTED
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Have there been any other Cour dCtion5 or any otlier relationships between Ie employer
and the Adverse Party?
RELIEF
I THEREFORE REQUEST Ihat a Temporary Oder for Plotection Against Harassent in
te Worklace be Issued aganst the Adverse Pa so uI8l the Adverse Parry will be !uIu0t|cd um
contaclmg, intimdating, |uiG|tut0g.or otherwise imerering wth the employer's business ndor !!
Hl0{ceu0!ayCr'on prescm at the worklace, and that the Adverse Party will be ordered to stay
away from Ihe employer's workplace, |> request U8Ith! C0mrmbIt the Adverse Par fom
violatmg this !dc!V8 e-maiL corespondence, !c!cphu0c. C! by auagen|
I FURTHER REQUEST the following other t000!II0h1.
FURTHER REQUEST that this Cout 8uI abeaing date for an Extended Order
5 soon 5possible.
es No
I!c8. complete the Application for Extended Order for Protection Against
Harassment in the Worklace NOTE: TIDS HARING WaL BE HLD WITHIN
TEN (10) .JUDICIAL DAYS PURSUANT TO NRS 33.270(6)(c), UNLESS
COMPELLING REASONS REQUIRE OTHERWISE,
(NRS 53(045)
DECU,RE UNDER PENALTY OF PER,lRY UNDER 1'E LAW QF IIE STATE OF NEVAA
'AT: (I) I AM 'HE EMnOYER OR AlTHORIZED AGENT HEREIN, I HAVE READ TU
STATU1ENTS CONTA1ED HEREIN OR HA Vi HAD THEM READ TO ME, lEL! VE THESE
D OR
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XHD1
Exbibit Am>iicltion Tcmporar Against in tbe
W(rkplace
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"I" to for Order for Protection Harassment
Zachary Coughlin is a LlienIof the Washoe County Public Defender, and I have been
assigned to one or more of his criminal cases, It is anticipated that by Tuesday, December 18,
2012, our omce will be relieved as counsel on Mr, Coughlin's single |0mainI ng case wit this
olIee. Me Coughlin is an attcrey on suspended status with the Nevada State Bar arising HOIIa
conviction IO!misdemeanor shoplifing which has been publiciz;; d in the press. Mr. Coughlin
represented himself in that criminal proceeding,
On December 12,2012, I received a email frm Zachary Coughlin, a copy of which i s
attached hereto as Exhibit" IA . The email pertains to a misdemeUnor ptit larceny case of Mr.
Coughlin's involving thef or unlawful retention of an iPhone, on which I and other attoreys in
our ofce previously represented him, During the course of the bench trial, our ofce was
relieve as counsel upon ML Coughlin's request to represent himself Throughout the email.Mr.
Coughlin makes various derogatory complaints about and references to me and uther attoreys in
our ofcc.
At the end of the first paragraph of the emailMr Coughlin complains that his various
attoreys and others in the local criminal justice system have ruined his life and he W1ie8HI
remember when my life featured happy moments like the birth of twInS , . but that was before
your leviathan legal system vvrecked shop on my existence. What, sir, shall be my
compensation ? The email then references the website http//tinyurl.comlbgmlfdr. When that
address is eut and pasted into a web browser, it directs the reader to a website containing a video
segment fro1 lhe movie "Cape Fear which te website summarizes as a film that "tells the
stor of a convicted rapist who seeks vengeance against a former public defender whom he
blames for his 14-year imprisonment .... " In the movie, the dient, played by Robert Di Nero,
carries out that vengeance by stalking and trying to kill his forler public defender, played by
Nick Nolte. A copy of the print out of the website is attached hereto as Exhibit ., IB", The
video segment on te website is a scene in the movie where the client of the public defender has
just beaten two men. The client is wering a shirt bloodied with his blood and the blood of the
men he just beat and he is holding a bluntinstrumcnt weapon or a chain in his hand. He vows to
continue his harassment of his former public defender, who is hiding nearby behind d garbage
dumpster.
The email from Mr. Coughlin is addIeSSeu to severl attoreys in te ofce of the
Washoe COUnty Public Defnder, including attoreys Jim Leslie, Jeremy Bo Se Biray Dogan,
Joseph Goodnight, and Mr, Coughlin has
" Tiilen
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Based on Mr. Coughlin having included the various recipients to the email who are not
his attomeys, Mr. Coughlin has waived attomey-c1ient confidentiality. Additionally, based upon
the nature of the references made in the first paragraph of the email to Mr. Coughlin's legal
problems and reference to the "Cape Fear" regarding violence and harassment against former
puhlic defender, Mr, Coughlin has waived attorey-client confidentiality as per Nevada Rule of
Professional Conduct 1 .6(c).
Later te same day as the email. December I 2. 20 1 2. Mr. Coughlin showed up at the
otces ofthe \Vashoe County Public Defender without an appointment I and an investigator
went to the lobby to see him, since we had decided based on previous encounters with Mr.
Coughlin that i t is best not to meet with him alone, With the investigator present i n the lobby, I
asked Mr. Coughlin what he needed. He said he wated his discovery documents. Since we
have had prior incidents where Mr. Coughlin received documents from us and later claimed we
di d not prvide them, I asked him to email me with hi s request and that I would respond the
emaiL During our discussion I infrmed him that I would be aking that our oficc be relieved
from his pending mi sdemeanor Obstructing and Resisting criminal case. He became agitated and
upset and I asked him to leave and to schedule an appointment i f he thought he needed one and
to send me his email request. He refused to leave, stating he was writi ng a note. I asked what
the note was and he became loud and verbally aggressive and said "None of your goddamncd
business . , , ." His demeanor was visibly belligerent I asked him again several times to leave
and he rose to his feet (he i s approximately 6'3" and I am 5' 4") and went on a verbal rant agaiust
me. I continued to tell hi m to leave while I ted to the front desk staf and asked them to call
the police, He tried handing me the note, and in response I held out my hand to receive it from
him, but then he pulled the note back from me several times in a taunting manner while smiling.
As we waited for the elevator, he kept saying he was "chipping" at me. As he lef i n the
elevator, he kept saying " chip, chip, chip . . . . , in a taunting manner.
I asked my investigator to summarize the encounter in writing. A copy of that written
summary is hereto attached as Exhibit "] -C".
Given Mr. Coughl i n' s demeanor and behavior, and given the "Cape Fear" refrence in
the email earlier that day, [ felt it appropriate to call the police o o result of!lr. Coughl in'S
refusal to leave, aggressive and hostile demeanor and statements, and the concer that he might
get physically violent. He l ef the building before the police arrived.
As a result of te email and the encounter with Mr. Coughlin in \U il1hhy, we have
;)c\(ifcd him via email that he is not to come to our ofices without prior confirmation of
an appointment with his asigned attorey Exhibit " I -D"
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post it clifton 11 28 12 don't file this in stays w case file however 1 of 69 pages. pdf; 12 6
12 26405 Notice of Deficiency of Record on Appeal and Filing OJudicial Discipline
Commission Complaint 0204 - Copy, pdf; 12 6 12 samped 065630 emergency Motion
for Mistrial and Continuance Given state's failure timely provide discover exculpator
Copy,pdf; 12 4 12 Afidavit of Service RJC Bailif John Reyes lacks a lack number, lacks a
notary 065630 03341 067980 has no Order attached to it or incorporated by
reference, pdf; paes 1 to 17 from first fax judicial discipline commission complaints 0204
gardner elliot howard nash holmes sferrazza clifon final-2-2,pdf Paul-D-Elcano
Jr--1070555-8 stanford 0204 elliot echeverria.pdf; 01955 docket coughlin elliot gardner
elcano.pdf; cr12-0376 coughlin judge steven elliot 0204 docket ccwashoe.pdf
er11-2064 docket coughlin Y city of reno judge elliot city attorey roberts 0204,pdf; paul
ekano suing rutherform chirpracice and dr ross and nichols 0204 60317,pdf; 2 3 12
22176 60838 0204 robers Gmail - couresy copy of audio of trail exhibit 1 to
Supplement to Opposition to Motion to Dismiss pdf; 11 10 11 063341 nrs 174,345
sbupoena on Duralde Rosa Alaksa and Othel|0O|!|0d 105 skau 020.pdf; !!26 12
: tu00naIlsGJ: GJ!7Ga||n GUr0-0^::Ib'J3J0bJ:^l
775 325 671 5 1 1 : 40: 32 a, m, 1 2-21 -201 2
leslie, Jim
from:
Set:
1
Subje:
AUachmnM:
Zach Coughlin <zichcoughl i n@hotmaiLcom>
Wednesday, December 12, 2012 2:35 PM
Leslie, Jim; Bosler, jeremy; Dogan, Biray Goodnight, Joseph W; Fortier, Chris; Tuttle,
Steve; Kandaras, Mary; Young, Zach; skauc@reno,gov; wongd@reno,gov
kadli cj@reno.gov; complaints@nvbar,org; cvellis@bhfs,com; je@eloreno.com;
patrickk@nvbar,org; davidc@nvbarorg; rosec@nvbar,org; laurap@nvbar,org;
skent@skentlaw,com; mlke@tahoelawyer.com; elfert.nta@att.net;
nevtelassn@sbcglobal,net fflaher@dlpfd.com; fiaherty@dyerlawrence,com
The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17,
2012 to Coughlin in rcr2012-065630
12 7 12 declaration of zach coughlin 0204,pdf; 2 6 12 email from Fortier regarding
Dogan 065630.pdf; 10 11 12 email mmisue of 911 case 065630 fortier at al.htm;
transparent nevada Veronica Lopez Marda Lopez 26405 22176 0696 065630 0204,pdf;
1 12 12 rpd police report 12 (r 00696 sifre leedy look nash young kandaras bradshaw
0204 065630 redacted ocrd,pdf; BecketCR211004 0204 065630.pdf Beckett and
Tanner examples special treatemen! for prosecutor and tanner pet thef involve s16K
0204 Bar_.Counsel_Reporune_2011,pdf; 11 22 12 26405 Motion for Continuance
because Hill on vacation Hazlett Declaration 0204 065630.pdf; 12 6 12 not authorized
by Clifon Custodian of Recors WCPD 065630,pdf; 12 6 12 subpoenas 065630 Thew
Silre Schaur Lopez Foreshee ECOMM,pdf; coughlin nsct docket search as of 12 7 12
0204 065630,pdf; 8 20 11 unredacted dispatch logs 063341 back from tiff.P9.pdf; 9 7 12
063341 Order for Competency Evaluation 0204 065630 12420,pdf; 12 19 11 063341
GOODNIGHT'S REQUEST FOR DISCOVERY 0204 065630,pdf; nsct docket 54844
coughlin v dist ct josh! 01168 0204 26405 61901.pdf; 1 1 27 12 065630 fax cover page
jremer whn my
legal system wrecke op my existene. xir
http://tinyLcomlbglfd

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and multiple trips to the WCPD personally by Coughlin to pick such materials up,
and despite more flip fopping on their stor by Leslie and Doga regarding
whether they ever gave Coughlin some package of materials responsive to
Coughlin's request for his " fleH ... But, Jim Leslie is stuck with the 7/27/1 2 date he
mentions i n his email, then he is stuck with what his recent email wherein he
purports to have therein digitally transmitted Coughlin his "fle", which obviously
does not include the cd's of 91 1 calls (the one's DDA Young took up an enormous
amount of court time playing, over and over (well, Young only played over and
over the particula cal l s he felt were strongest for his case and most prejudicial.
claiming some "cutting room floor mishap" for the reoccurrence of certain calls,
arguing that such a "happy accident" justifed playing them again and again, at ever
increasing volumes, etc. , etc. ). Apparently, I am here to subsidize Young's baby
making, just like I was with Ms. Goran, as a continuance of prejudicial length of
afforded to te State where none was forthcoming to Coughlin. despite Leslie and
Dogan's obstuctionist tantrums, ones of a quality that would.
life featured happy moments like the birth of twins . . . but that was before our
eviathan s on hhct xhcuhem
ccmpcnacticn Dc)cuminJj/I putm)cmcrcunJ.. #
This is a fonnal grievance against Dogan, Leslie, Bosler, Young ... etc.
Svengalifiann Ross Diva Jim Leslie is going to micromanage Dogan and Goodight's cases, and gag order
them, he better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of
9 1 1 calls DDA Young gave the wcpd on 8/1 3 and 8/171 1 2 in Ic rev201 1 065630, and clearly. any packet from
7/27/1 2 wouldn't have them (nol to even get into the flip flopping contradictory accounts by Leslie ad Doga
as to who gave Coughlin the packet. or who didn't or blah blah blah) . . . and certaily Leslie email below only
contained a 57 page pdL.way to close to the 1 211 1 11 2 trial date, and containing materials Coughlin had never
been given before . . . . so much easier. Jimmy Sleazy to email the client a "digital transmittal" proving what you
gave and when .. . ... but. l!O. that would make i t so hard to fudge the accounts of what was contained therein, or
who handed what to whom. or who failed to pick up this or that. or Dogal's slippery nonsense:
"From: Jleslie@ washoecQunty,us
To: zachcoughl in@hotmai l.com
CC: BDogan@ washoecouty.u8
Sub,lcC:: ! I
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Since we have been removed from the 9 1 1 case, we are closing our file. The attached materials were sitting at
our front desk. Since you licto retrieve tem, we provide the attached courtesy copy before final closure of
our flIe.
No response to this transmittal is required fom you.
Iac1 bl<>lr.Lq"
So, while Dogan states on 7/2711 2 in 65630 "Your Honor, I have never even spoken
with Judge Dorothy Nash Holmes" .. ,he coyly fails to indicate whether he spoke
with ayone with the RMC, Marilyn Tognoni, included, or why hi s 2/28/1 2 fa to
Coughlin was so insistent that it was "Lake's Crossing's Bi l l Davis, Ph. D. " who
must conduct the "Competency Evaluation", or how it was Judge Cl ifon's 2/2711 2
Order for Competency Evaluation could have possibly known and included Judge
Elliott as the "randomly assigned judge" to that Competency Case in CR1 2-0376
(Judge El liott on Committee to Aid Abused Women's Board, (CAAW) .. .Judge
Elliott presiding over Coughlin's wrongful termination lawsuit against WCDA's
Office ECR Partner, Washoe Legal Services, its Executive Director Paul E1cano.
and CA, in CVl l -01 955 .. ,Judge Elliott fails to disclose confict or recuse
himself, Judge El liott manages to "randomly" be assigned Coughlin's two criminal
appeals from RMC convictions (the Wal-Mart "candy bar" petty larceny leading to
a 6 months, so far, temporary suspension of Coughlin's law license in 1 1 cr 221 76
i n the RMC. then crl l - 2064 in the appal Judge El liott canned based upon a civil
statute requiring a down payment for the preparation of tanscripts and El l iott's
contention that he need not address the merits of Coughlin's appeal given the lack of
a written transcript (Coughlin paid the audio cd. and that the
cnrnal CU!t01U!
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no continuance from Judge Howad in that 1 1 cr 221 76 (even where he was
wrongful ly evicted in Rev20 1 1 -0 1 708 (now on appeal in 6033 1 and 6 1 383) on
1 1/ 1 1 1 1 , then wrongful l y arrested on 1 1/ 1 3/ 1 2 in I I cr 26405 (now feature in
61 901 , 621 04, 54844, 60302, 603 1 7, etc . . ) and incarcerated between 1 1/ 1 3/ 1 2 and
1 11 1 51 1 2, no continuance for the 1 1130/1 2 Trial in 1 1 cr 221 76, despite an
agreement in writing with City Attorey Pamela Roberts (whom put on perjured
testimony by three witnesses where she possess a video and other evidence
conclusively proving that Coughlin did provide his driver's license to RSIC Ofcer
Crawford ... and where Robert's prosecuted based on an arrest for a misdemeanor by
tibal officers where NRS 1 78. 1 255 bars such an arrest, and where Wal-Mart's
Thomas Frontino and Roberts herself admit no citizen's arrest was effectuated . . . . so,
about that RC 3. 8 violation . . . ). Then there is the appeal in cr 1 2- 1 262 that Judge
Elliott, cgcin, was "randoml y" assigned from the conviction by RMC Judge
William Gardner in I I cr 26405 based upon the criminal trespass complaint signed
by Richard G. Hill, Esq. (opposing counsel in the summar eviction from
Coughlin's former home l aw office in rjc rev20 1 1 -00 1 708, presided over by Judge
Sferazza, though Hill and his associate Casey D. Baker, Esq. fax, on October 1 7th,
201 1 to Judge Clifon (who was not Chief Judge at the time, or anything) a
Emergency Ex Parte Motion for Inspection of Coughlin's Law Ofice, and where i n
his October 1 9th, 201 1 Order in that matter 001 708, Judge Cl i fton ruled as "moot"
Coughlin' 1 11 1 711 2 Motion to Set Aside the 1 1 1 1 3/ 1 2 Order following Summary
Eviction Proceeding by Judge Sferrazza setting the matter for "Trial " on 1 0/25/1 2,
on the condition that Coughlin deposit a rent escrow of $2,275 with the RIC
(though Judge Sferrazza admitted later on the record on 1 1 17/1 2 that the RIC Judges
had a meeting wherein they all had to agree that Coughlin was absolutely corect
that the RIC was violating Nevada law in having an unpublished "house rule"
corollary to JCRL V 44 requiring such rent escrow deposits in landlord tenants
matter here JCRCP 83 had not been followed in that the RIC had not published and
had approved by the N. S. Ct. any such deviation from the statutory remedies set
forh in NRS 40 and 1 1 8A. Judge Elliott managed to torpedo that appeal of the
trespass stemming the criminul and
required by SCR 1 1 1 (8) and the Court's 6nl1 2 Order got particularly short shift in
the 8123/ 1 2 triple grievance numbered SCR 1 05 Complaint by Bar Counsel Pat
"Patty lee" King, aka Pat Sal ierit whom wants no part of explaining his statements
2 5B^
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while Judge Gardner maageed to push through his 7/1 l / 1 2 Order Denying
Coughlin's Motion for New Trial, is all the more reason to apply consteration to
Judge El liott's work on the appeal on CR1 2-01 262. . Then there is Judge Linda
Gardner being Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out
of the Mental Health Court based upon Sharon Dolarhid, Rene Biondo, and Breen
and the MHC's own breach of contract (i f they provide program materials,
acceptance, ad a contract that l ist certain medications as disallowed, how i s it they
can claim non-compliance or "failure to abide" by the rules for taking a medication
not l i sted therein? Don't ask WCPD Joe Goodnight or Jetifer Rains . . . they know
what side their bread is buttered on . . . . MHl 2-032 ... so DDA Young tries to jam
through a trial in 063341 on May 7t, 201 2, despite the mandatory stay in NRS
1 78.405 and the then still pending Order for Competency Evaluation in rjc 201 2-
065630 from the clandestine status conference Dogan and Young never quite seem
to refute happening on 2127/1 2 # .B 0h, and Judge Clifton, then DA Dorothy Nash
Holmes, and Judge Linda Gardner were all co-workers onee upon a time, working
closely with then Sparks City Attorey/prosecutor Steven El liott, whom worked for
the law firm of the father of the Panel Chair for Coughlin's 1 1 11 4/ 1 2 SBN v.
Coughlin formal Discipl inary Hearing in NG 1 2-0204, 0434, 0435 (the last two
being grievances against Coughlin filed, in part, by RMC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal trespass case against
Coughlin before him in 1 1 CR 26405 B B =even where Judge Gardner's aialcrJudge
Linda Gardner's April 2009 Order sanctioning Coughlin was cited by WLS's Eleano
as the sole basis for fing Coughlin, and where Coughlin filed a Mandamus Petition
in 54844 challenging those sanctions, and where ng 1 2-0435 was one of three
grievances forming the 8/23/1 2 SCR 1 05 Complaint against Coughlin
(strangely ... the Wal-Mar "candy bar" ptty larceny conviction and the formal
hearing for the "sole purpose" of determining Coughlin's punishment for such
1 1 :46:44 a, m, 1 2-21 -2012 1 0 /32
775 325 671 5
plenary civil criminal contempts SlaMs that Judge Nash Holmes whipped
up. . . though she avoid NRS 22.030 and detlnitely there wasn't no afidavit signin' by
01' RMC Marshal Harley for alleged conduct i n a restroom or restroom stall, which
assuredly was not "under the watchful eye of the court" or " in the immediate
presence" of the court . . . . so much easier for Bar Counsel to feed Judge Nash Holmes
the "clear and convicing evidence" standard from Schaefer required to prove an
ethical violation, have here copy and paste some RPC's into a second bite at the
apple and more than 1 0 days later (civi l statute, NRS 22.01 0, NRCP and JCRCP 59
allow sua sponte amending within 1 0 days, no 1 2 days4 . 4 2/27/1 2 to 3/1 2/ 1 2 . . R^void
Order of 3/1 2/ 1 2 by Judge Nash Holmes, so, sorry Patty Ice, nice ty, no SCR
1 1 1 (5) "an Order or conviction is conclusive proof of gUilt and I don't recognize
Claibore as binding authority because it makes my job harder . . . . " Y A . .
Tank You Ji m for continuing to prevaricate i n writing, your recent email combined
with some, uh, other materials that have been culled, wi l l surely be helpful i n
exposing you for the fraud that you ae. And Biray Dogan too . . . Oh, by the way,
that 1 117/1 2 fax confinnation page or proof of faxing? How is that coming along,
because I need to see it from you. My records show absolutely no receipt of any
fax of that sort, not on that day, not on any day ... which means the ball is in your
court to show how Dogan's representations to Judge Sferrazza on 1 11 1 9/ 1 2 in court
were not displaying a lack of candor to the tribunal and How Leslie Tibbals'
certificate on service therein is not faud.
Oh, attached is Goodnight's 1 2 1 9 I I Request for Discovery, which includes:
"REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and
through his attorey of record, Joseph W. Goodnight, Deputy Public Defender, and
hereby requests the following discovery pursuant to NRS 1 74, 235 to NRS 1 74.295,
1 . and V\ !lphotograph
1 1 : 47: 58 a, m, 1 2-21 -2012 1 1 132
775 325 671 5
Ji m, then there is you chi ming in, in your role as "standby counsel ", attempting to
aid the Court and DDA Young in coercing from me my Fifth Amendment rights at
the 9:06 am mark on the transcript from 1 1 120/1 2 ("Your Honor, I' ll remind the
Court that I J |etete]am|a|amyre|ed5 staacbyccaase|aayt|methe Cour's
feel s he is dragging his feet. . . .He is wasting County assets! " . . . very Atticus Finch,
Jim).
So, then there is Jim's 1 0131l 2 subpona to EcommlKelley \ood ... and given he was
counsel of record until 1 012211 2, yet completely failed to tum over anything
(responsive or not) in relation to that subpoena, and the fact that the entire
Suppression Motion tured on "what information the RPD received from dispatch",
and the fact that the audio of the "radio trafic" between the RPD and Di spatch on
that night (or at least the portions of it I have been able to extract from the powers
that be) reveal, one, no repor of a possible fight was received by RPD (they were
on the scene by the time the 1 1 :27: 1 1 pm text was sent to the displays i n their
vehicles, and the one audible "radio trafc" recording contains no mention of
anything beyond "check for possible larceny of a cell phone that just occurred,
suspect still on the scene, also reports of a loud verbal disturbance . .. ". Then there is
Jim and Goodnight completely whifing on the detaining argument, i n addition to
the whole "assuming we wi n on the pat down, make sure to oppose the notation that
there was sufficient probable cause for an arrest ad search incident thereto . . . . ", not
to mention that it was Coughlin (whose filings Ji m managed to cheerfl l y announce
"The Public Defender's Ofce is not joining in on those fugitive documents ... ",
despite the 2121 / 1 2 Filings by Goodnight that do just that. . . . ) that pointed out the
whole NRS 1 7 1 .360 basis for throwing out the search (which Ji m managed to not
cite to or quote from in his closing argument as the Suppression Hearing . . . where
Jim did manage to ask Cory Goble questions on cross that were designed to do
nothing more than establish a citizen's arrest suficient to rebut the NRS 1 7 1 . 360
basis for throwing out the arrest and fruits culled therefrom . . . ).
1 1 : 49: 1 6 a, m, 1 2-21 -2012 1 2 /32
775 325 671 5
experience", "detained" , "I don't remember who made the cal l ", "I can' t remember
which one of my friends it was who was with me" , etc. , etc.) Also, the WCPD
practice of blacking out locations ad addresses sure makes it difficul t to establish
inconsistencies between testimony and the reportslWitness Statements or otherwise
utilize them for impeachment purposes.
So, now today, we get this Jim Leslie email with al l it's revisionist history . . . whkh
only contradicts the position Leslie and Dogan have taken that Coughlin already
picked up this 7/2711 2 packet (at frst Dogan claimed to have personally handed it
to Coughlin, then changed his story 2 minutes later and said he saw Leslie
personal l y hand it to Coughlin . . . . and Dogan asserts to the Court at the 1 1127/1 2
Hearing in rcr201 2-065630 that he has never spoken with Judge Dorothy Nash
Holmes (see materials regarding clandestine status conference of 2/2711 2 and
subsequent fallout with Judge Nash Holmes of 2/271l 2 a couple hours after Dogan
secured his 2/27/1 2 1 : 3 1 pm Order for Competeny Evaluation in 065630 from
Judge Cl i fton).
The SBN v. Coughlin Complaint of 8/23/1 2 specifically mentions the arrest of
1 11 4/ 1 2 that theis 065630 case is based on, i n addition to the 063341 iPhone arest,
and RCJudicial Secretary Lori Townsend sent Cougl in's 2121 1 1 2 in 065630 to the
SBN, and offered to send Coughlin's 2/1 5/ 1 2 filing in 063341 to the SBN ... and
Judge Nash Holme's 3/1 2/ 1 2 Order in 1 1 TR 26800 mentions Coughlin quoting
"rock lyrics" in a filing as a basis for her tansmogrifying a "si mple traffic citation"
to a "formal disciplinary heaing on an ethics violation" wherein she quotes the
Schaefer standard for an ethical violation that Bar Counsel had fed her earlier in the
day. . . ad that window between the 1 : 0 pm noticed start time of the traffic citation
trial in 1 1 tr 26800 and the 3: 30 pm eventual stat time includes the 1 : 25 pm
courthouse sanctuary doctrine violating service upon Coughlin (by RMC Marshal
Joel Harley, on behalf of WCSO Deputy Machen, hired by Richard G. Hill, Esq. , at
whose ofice Coughlin was retaliated against by RPD Sargent Tarter with the three
side their bread is buttered on and indicated "there just isn't a basis for seeking
reconsideration of Judge Breen's Order". Judge Peter Breen, MD.
Funny how Dogan did not state to Judge Cl ifon that he never spoke with anyone
else at the Reno Municipal Court about Coughlin . . . . including Marilyn
Tognoni . . . but, rater Dogan just indicated he never spoke with Judge Nash
Holmes, in his best innocent little boy voice that he cops when he isn't busy tittering
away wi th Jim Leslie in the spectator area during the 1 1 1 1 9 and 1 1 120 Trial in
063341 (where he failed to apprise Judge Sferrazza of the fraud attendant to his
earlier attestations regarding proof of service (by fax no less) of his ll // l ?Motion
775 325 671 5 1 1 : 50: 36 a. m. 1 2-21 -201 2 1 3 /32
case 065630 (the one where Dogan had appeared as attorey of record then failed to
show up for a heaing on 2/ 1 3/ 1 2, then retaliated against Coughlin for Coughlin's
212 l 1 l 2 filing in 065630 by moving for a Competency Evaluation and basically
doing absolutely noting on te case for the next 9 months besides raping fom
Coughlin his medical privacy rghts along with Judge Steven El liot and DDA Zach
Young at the 4/1 9/ 1 2 heaing in CR1 2-0376 (one of 3 criminal appeals Judge El l iot
was " randomly" assigned in which Coughlin is a party . . . to go along with te
wrongful termination suit by Coughlin that Judge Elliot presided over in CVI I
01 955 wherein Coughlin sued CAA W and WLS, despite Judge El liot sitting on
CAAW' s Board, and where Judge El liot, the Panel Chair at Coughlin's formal
disci plinary hearing of 1 1 1 1 4/ 1 2, and Washoe Legal Service's Paul Elcano all went
to Stanford together, and where Judge Elliot worked for Panel Chair John
Echeverria's father's law firm, Echeverria and Osbore). Then there is Linda
Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from
Mental Health Court i n MH1 2-0032, where the MHC's Rene Biondo and Sharon
Dollarhide lied about what medications were listed as accepted or not in the
materials provided by Goodnight and or the MHC along with the contract entered
into with Coughlin, whom was accepted into the MHC. Then there is WCPD Joe
Goodnight and Jennifer Rains refusal to file anything directed towads enforci ng the
MHC's contract with Coughlin, wherein they both demonstrated they know what
~lr nr
775 325 671 5
1 1 : 5 1 : 54 a. m. 1 2-21 -201 2 1 4 /32
Leslie finally emails me a 56 page pdf purporing it to b my "file". One wonders
where any audio recordings, dispatch recordings, 91 1 call recordings or other medi a
are any why Leslie and Dogan di d not provide them. Coughl in appeared at the
WCPD's Ofce today and asked for the hard copy of his file, yet was told by front
desk receptionist "Paula" (of course, no last name provided) that she "spoke with an
associate" and they told her that Jim Leslie had already provided Coughl i n his fle
and that he, therefore, would not be given the hard copy. "Paula" eventually
seemed to have to admit that the misleading use of the term "associate" actually did
not connote her having spoken with an attorey about the matter . . . hut rather Linda
!y. wumhccucuriollsly si lent al to |cuponu!misconduct attendant to hct
admitting that she did not mail out any written notice to Coughlin of the August 6th,
201 2 "combo-hearing" in rcr20 1 2067980 or rcr20 1 2-065630 (Leslie glossed over
that fact by sending Coughlin a note about how he "saved the day" with his
"advocacy" . . . skipping past the part about how te client. Coughlin, was not noticed
on the hearing in any matter, much less in writing . . . . Leslie later refsed to indicate
with any specificity whatsoever how he "knew" Coughlin had been noticed on the
8/611 2 hearing in writing . . . and RJC Judges are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things . . .
Mr. Leslie, the thing i s, I have a Trial in this case rcr201 2-065630. You have
continued in your way (simila to how you approached the rcr201 1 063341 case
where Joe Goodnight, Esq. was counsel of record until you had him removed on
7/1 6/ 1 2. the moring of Trial . . . afer Mr. Goodnight and I have completed a video
conference final trial preparation at 4: 30 pm on Friday, July 1 3th, 201 2 while I was
in custody (pursuant to an arest on July 3rd, 201 2. ordered by RPD Sargent Kim
Bradshaw, she of the 1 1 1 2/ 1 2 custodial jaywalking arrest along with RPD Sargent
Paul Si fre) . . . . Things fall through the cracks, Mr. Leslie, when you place a gag order
on the associates you claim to supervise, then stubbornly, petulantly, and
retaliatorily refuse to work the cases you have snatched back fom your
associates . . . . Similarly, WCPD Fortier'S email to me of February 6th, 201 2 may have
contributed Mr. Dogan's confsion failing to attend the Hearing on Feburary
2
1
pm that the matter would be rcnJoml)assigned to District Court Judge Steven
Elliot (also a lifelong prosecutor with deep and longstanding ties to the domestic
violence industrial complex. and a member of the Committee to Aid Abused
1 1 : 53 : 1 4a, m, 1 2-21 -2012 1 5 /32
775 325 671 5
However, Mr. Dogan, you are not of the hook just because Jim Leslie places a gag
order on you. Mr. Leslie sent this email today with a 56 page pdf fle purporting to
be my "file". I , as now a former client, have rights to "my file". I have requested
my file in writing from your offce on numerous occasions, and given your removal
as counsel of record on 1 1122/ 1 2 (amazingly Mr. Dogan probably managed to say
200 words on a case that he had been counsel of record on for nearly a year, and
had not managed to fle a single document in that case, RCR201 2-065630, and had
managed to get upset that a client would take issue with his missing the 2/ 1 3/ 1 2
Hearing, even though WCPD Fortier's 2/6/1 2 email makes clear, the matter was
assigned to Mr. Dogan at that point, and he had already sat down and discussed the
case with Coughlin for over one hour on or about Februay 8th, 201 2, where
Coughlin went to check in with Mary Watson, whom was then represented by
WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bai l i ff and
demanded they breathalyze her client. They did, she was taen into custody.
So, after sitting down with Dogan for at least an hour and discussing various things,
some including matters related to the case he was then attorey of record on
1 78.388).
defndant may waive his appearance when certain condtion are met.
RCR201 2-065630, the February 1 3th, 201 2 court date (Dogan and Coughlin have
conflicting views as to what was agreed upon and the applications of NRS
NR 178.388 provides that the defendant must be present at arraignment, trial, and sentencing and provides that the
Its kind of odd how Judge Clifon (whose atached bio indicates he has deep and
longstanding ties to the domestic violence industry infrastructure) knew
instantaneous to signing the Order for Competency Evaluation of 2/27/1 2 at 1 : 3 1
\r:
urlotu:ed,
1 1 : 54: 30a, m, 1 2-21 -2012 1 6 /32
775 325 671 5
before the State Bar of Nevada, John Echeveria in the late 1 960s . . . and Judge Elliot
worked at John Echeverra's father's law firm, Echeveria and Osbore Board of
Directors, in addition to bing a former ass
In CVI I -01 955, Coughlin sued his former employer Washoe Legal Services, whose
Executive Director Paul Elcano went to Stanford in the late 1 9608 with Judge
Steven Elliot and John Eheverria, the Panel Chair of Coughlin's 1 1/ 1411 2 Formal
Disciplinary Hearing before the State Bar of Nevada"and Judge Elliot worked at
John Echeverria's father's law firm, Echeverria ad Osbore, and Judge El l iot
served on the Board for CAA W, and was a prosecutor as te Sparks City Attorey.
Also, Mr. Leslie. while the 56 page pdf you finally sent me (gosh, was it that hard
to cl i ck " attach", load a 2 mb pdf file and hit "send" on a email to me? No
debatin', no arguing about whether Leslie and Dogan left the package at te desk.
whether Dogan already gave i t to Coughlin, or whether Dogan then changed his
story and said Leslie gave it to Coughlin, whether Coughlin already picked it up. no
claims by Jessica the Receptionist of anyone kickin' friture . . . nothing like that,
just a digitally verifiable means of ascertaining what you transmitted and
when . . . was that so hard? Heck, Jim, you could probably just email those ECOMM
recordings too . . . and if attachment size is an issue. sign up for a www.outlook.com
(the new HoTaiL, allowing up to 30 mb attachments via the Sky Drive
functionality, and up to 1 00 mb attachments via plan email, and over 25 free gb of
storage on the Skydrive, etc. , etc . . . ). But its Leslie finally sent the 56 page " cl ient's
fil e" on or about 1 21711 2, yet he failed to include the insipid Motion of 1 1 12611 2 by
DDA Young (wherein, just afer Judge Clifton finishes telling Coughlin at the
1 1127/ 1 2 Hearing that Coughlin i s not allowed to even think about the other two
RC shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just
not relevant to this proceeding"", and anytime Coughlin would point out spcific
basis for undertaking a recusal or conflict analysis vis a vis either Judge Clifton, the
RC, DDA Young, the WCPD, or the WCDA, Judge Clifton would say "your're
losing mCcnyour're losing me,,:' as if Coughlin wa speaking in tongues all the
cases even
ex
ZlchCQghl in@holmai l.com
`:
1 1 : 55: 39 a. m. 1 2-21 -2012 1 7 /32
775 325 671 5
Zach Coughlin
147 1 E. 9th St.
Reno, NV 895 1 2
Tel and Fax: 949 7402
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
CC: BDogan@washoecoullty,us
Subject; 9 1 1 Case
Date: Fri, 7 Dec 2012 1 7:09:08 + 0
Mr. Coughlin:
Attached are the discovery materials in the above-referenced case that you had requested and we had made an
additional copy of for you in response to your request. Please note that the July 27, 201 2, cover letter was for
your pick up and you never picked it up. Note also that the July 27, 201 2, packet encloses a copy of the April
1 7, 201 2, hand delivery transmittal of the very same documents which you received.
Since we have been removed fom the 9 1 1 case, we are closing our fle. The attache materials were sittig at
our front desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of
our file.
No response to tis transmittal is requird from you.
1HcS B. Lslc.
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775 325 671 5 1 1 : 56: 08a, m, 1 2-21 -201 2 1 8 /32
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1 1 : 56: 41 a, m, 1 2-21 -2012 20 /32


775 325 671 5
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1 1 : 58: 1 1 a, m, 1 2-21 -201 2 23 /32
775 325 671 5
Leslie, Jim
From: Novak, |vo
Sent: Wednesday, December l., <0l. 4:51 PM
To: leslie, Jim
Subject: Coughl in office vi sit I.I2I.
Knowing Mr, Coughlin's vol atil e past behavi or I wa 5asked to accompany Ji m leslie to the lobby to assist Coughl i n, He
was seated in a chair writing a note, Ji m lesl ie asked Coughl i n what he needed, Coughl in mentioned he needed some
discovery from a case. Jim Leslie advised him make any commun'leations by way of e'mail, he would handle that way,
Coughl i n asked if I was present as witness, Ji m leslie confirmed that, Jim stated that he was going to ask to be relieved
from the current Coughl i n case, Coughlin's demeanor became belligerent. Jim Leslie asked Coughl in to leave the office,
Coughlin refused cl ai mi ng he was writing a note, Jim Leslie asked what the note was. Coughl i n said " it' > none of your
goddamn business and walked past Jim and left the note at the reception desk, Coughlin was advise several times by Ji m
Leslie to leave the ofce. Jim Lesl i e advised hi m that the police were goi ng to be cal l ed. At that poi nt the elevator
arrived, Prior to the elevator door closing he continued his rant toward Jim Leslie until the door cl osed,
Evo Novak
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775 325 671 5 1 1 : 58: 39 a, m, 1 2-21 -201 2 24 /32
XHH1 I -U
ilIe@washoeco!nty,u5
1 1 : 58: 53 a. m.
1 2-21 -2012
25 /32
775 325 671 5
l05l0, JID
lfOU Lesli-,in
Sent: Wednesday. December !2.`0!`4.Z. PM
To: zachcoughlin@hotrnail.com'
Subject: CQ|ghlin
Mr. Coughlin:
Based on your behavior at our ofces on several past occasions, including today where we had to call the police due to
YU engaging in behavior constituting disturbing the peace, you are hereby directed NOT IO ComEto our ofices without
first having confirmed in writing an appointment with your assigned atlorney.
If you violate this emai l notifcation, we will contact law enforcement.
James Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defender's Office
350 South Center Street
Fifth Floor
Reno, NV dd
!Jb=O^1
Direct Dial: '^oO
8x. J''J7O'O
Email:
`0ton|^n!:olIh>communicatiDll ouaII accompan,ing document dnd aI\achmcnIscon\amCONfIDENTIAL INFORMATION; af legaHy pnvileged, and are n'^nrd
for use and icvcv-only by mzpdft tending Sme un0the intnded recipient If you are not 'he :ntended redpn:mt you are hrb)uI:!'"th:H any disc!oslJrf, copymg,
distribution, use UJ taking ,11,' action reliant on $Id LOUT\ Me CONFlDENTfAL ind strictly prohlblted If you received :hi.communiCaton In !D!, p!tae
immediinely ct(US3\ 77'JJ460to arrnge return of the origHl31 transmitl. Th<H1k YOV
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I
775 325 671 5 1 1 : 59: 20 a, m, 1 2-21 -201 2 26 /32
IXH1l -I
!ilsl ie@washoecoUn
27 /32
1 2-21 -2012
1 1 '. 59:34 a. m.
775 325 671 5
leslie, Jim
From: le>|ie.ih
Sent: Wtdnesday.December 12, 2012 FM
To; Duarte, Julio
Cc: Vaughn, Va|elie
Subject: |W.Coughlin
'ullD
Val lells me she spoke to you briefly about Zachary Coughlin. Below is my emai l to hi m stating he I S NOT to COR0to out
ullice>without o prior written confirmation oIappointment with his assigned attorney. l am hi>only assigned attorney.
We ask that YUU NOT grant him admittance to the buHding Without first |tIIng u know he is hcre I wi |l cal l you I n
advance of any date and time lhat I set an appointment with him, but other than that thero's no reason to pefmit him
irL
Please let me know if you have any questions.
Thank You,
'80cS U |e-'i,tS
Chief Deputy Publ" Defender
Wd5|UL County Public Defend0(s |I
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5n\:Wednesday, Lecember .`I`'.2.ll
TO' !ah.uuh_'OI3i.OU`
'
1 2 : 00: 07 p, m,
1 2-21 -2012
28 /32
775 325 671 5
iDUS. |CS!t, c5{
Chiel leputy Public Defender
Yd5DUt County Public Defender'S Office
S0uthCcnIcrSIreet
|ihh Flocr
Reno,NV 89509
HOO7628031
Direct Dial: 7753374828
3X` 1b.3O>O
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1-ont;nts of this cormunicaton and all accmnpanying dOlmRnt .nd attaChmBnts cofllln CUNFlDENTIAL lNFUl'M^JIUN.arcleiiyprivegd< and arc n:.drd
for U$P 1C revew only t,y te par serding same <nd the intended no!vinIcn0c0 archereby notfied that nyd\sdofi\ire, copying
d!StuutlOR \>P or tling any aCtDn riJi;mt DUsai ccnn:su` $tlCtypronlb1ted_ [(you Li$ mmmuni(tlOri !I vi+r,Ise
nnmediately no!1lyU5 d! 75'71800lU 4rrange rnrn olLh-origHli! tflfSmlrtaL Thank yet
,
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775 325 671 5 1 2 : 00: 27 p, m, 1 2-21 -201 2 29 /32
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AIIJUAVJT OI ATTLNPTLD HLFVJCL


STATE C NEVAA
COUTY OF
, . Watts , be f irst y :\OJD and under
perj ury
l .
l have of lowing s and am
to testi to same .
am employed by Washoe County as a Deputy ll1l.
in the 1 ll\l.lOD the O\D! llG
Attorney' s Off
3 . As part of my j ob duties , represent County i n
workplace and am the of record
this Appl ion .
4 . tVr . Lesl
l
as a f Deputy Public
l
a County
employee who other County employees lD the washoe
County Publ Def ender' s Of f , i s an authorized agent of the
OUD for the purposes of Appl icat
. On ! , . O ., I was provided
in tant At the
rece ! was a reet th another ient at
n.ot conclude unt il
5 : CO unable !.C
th.6
of `.
f
f
J 7
me ;
my
1 2: 01 : 22 p, m, 1 2-21 -2012 31 /32
775 325 671 5
J to a court act Reno Court , at

= 8 : 3 0 a . m .
' . After to
draft the tant af f t , and the Appl
to s f i zationt then for f i l
6
8 . to f iling, my As sis tant , Mendoza,
7 provided a copy of the instant Appl icat ion and 1 attachments
S to the 1 addres s numbers and provided by Mr .
> Coughlin in s correspondence with Mr . Lesl
1' zachcoughlin@hotmail , com, number ( 94 9 ) 667 - 7 4 0 2 .
1 1 9 . Given Mr . Coughlin' s repeated ins tances hara. ssment
`2 and int imidation as described by Mr . Lesl in the Appl ication,
13 it is likely tha.t Hr . Caughlin will react badly to
. to remove !r . Les as counsel for Mr . Caughlin, and
1o engage in further acts of sment and intimidation
16
10 . !r . Lesl i e ' s ion Mr . Coughl in' S his
` unannounced Public Defender' s f
. - tructions that he is to
at a set s threat to
red with Mr . Les i e ' s
fender' s
s of
:
i
`
ercrarv
1 2 : 02: 06 p, m, 1 2-21 -2012
32 /32
775 325 671 5
can be heard to
2
Court is fore ted to t
?
set a hearing near
for as
Further fiant
t

STATE OF NEVADI\

C01NTY OF "SHOE
` SUBSCRIBED and S\10RN to me
`` this 1 8 th day of December, 2 0 1 2
1 1 by David I. Wat t s- Vial .
!`
I
`
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`
`
`
order
and

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