Escolar Documentos
Profissional Documentos
Cultura Documentos
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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:
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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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Please Lbrcktbe Appropriate BOI Below:
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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:
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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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' . After to
draft the tant af f t , and the Appl
to s f i zationt then for f i l
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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
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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
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can be heard to
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Court is fore ted to t
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set a hearing near
for as
Further fiant
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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 .
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order
and