10 20 12 To 11 17 12 0204 599 607 Emails To SBN

new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest
in SCR 105 Complaint

From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/14/12 6:46 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
(nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org); (fflaherty@dlpfd.com)
(fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org);
(tsusich@nvdetr.org) (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com);
(eifert.nta@att.net) (eifert.nta@att.net); (consult@laketahoelaw.com) (rhrc@laketahoelaw.com); (stuttle@washoecounty.us)
(stuttle@washoecounty.us); (kadlicj@reno.gov) (kadlicj@reno.gov); (wongd@reno.gov) (wongd@reno.gov);
(schornsby@nvdetr.org) (schornsby@nvdetr.org)
Dear Panel and Bar Counsel,
Please find the attach additional discovery the Reno City Attorney's Office gave me today related to the custodial jaywalking
arrest of 1/12/12, at which time Richard Hill applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD
Officer Look took a special trip to the jail to attempt to serve the TPO for Hill). Please see attached the video of the arrest and
interactions prior thereto, and consider the lack of accuracy in Hill and Baker's Second Motion to Show Cause, Judge Flanagans
denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause Hearing (which WCSO Deputy Machen, the same
one who filed a false affidavit incident to the summary eviction order posting and lockout on 11/1/11 in the Richard Hill
eviction cases rev2011-001708 served on Coughlin, by way of violating the "courthouse sanctuary" doctrine, and Caplow holds
attorney of record and efiler on that case Coughlin did not require personal service anyways...this was hazing by Hill and the
RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11 TR 26800, the traffic citation trial that NG12-
0204 stems from, which stems from RPD Sargent Tarter telling Coughlin to leave Hill's office upon going there after being
released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12 resulting in a wrongful arrest for criminal
trespass of Coughlin by RPD Officer Chris Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer
Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee Officer Leedy then proceeds to adopt Hill's
approach nearly verbatim in his arrest report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for
"misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage the "serious offense" dictates of SCR
111, even though he lacks an RPC 3.8 probable cause basis for doing so. Further, both Hill and Officer Leedy substantially
misrepresent what Officer Hollingsworth said. Additionally, should Officer Hollingsworth had indeed told Coughlin that what
he was doing was legal but that the Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve
cooperation, that would violate Soldal v. Cook County, which is essentially what RPD Sargent Tarter did on 11/15/11 in his
three traffic citations outside Hill's office, which les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess
it takes a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky associate Casey Baker, Esq. make
money...One can hardly blame Coughlin for half-way believing RPD Officer Carter's statement on 11/15/11 that "Richard G.
Hill pays me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's merely attributing the statement
that RPD Carter said to Carter is not misconduct. Hill's making up things about a "crack pipe and bag of weed" and "large
quantity of pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see that the "pills" are
vitamins...and Hill's contractor Phil Stewart, signed an affidavit that mentions this "large quantity of pills"). If you knew all the
Thursday nights I spent since 2003 with Coe, and now deceased Judge Bob, and so many others, you would realize how
infinitely tacky Hill's conduct is.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204 25 page discovery northwind ncs krebs reduced size.pdf
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-000018 0204 Leed.pdf
SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
City Attorney Skau, updated discovery in iPhone case, dispatch recordings, don't
seem to reveal basis for "a possible fight" assertions in office testimony and
prosecutors's filings and argument
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder ptthoa 0204.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
bifurcate atty client severe hearing trialotjl.pdf
bifurcate atty client severe hearing trial.pdf
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf
Download all

Sent: Wed 11/14/12 2:09 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com (skent@skentlaw.com);
mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net);
rhrc@laketahoelaw.com (consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us);
kadlicj@reno.gov (kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov); schornsby@nvdetr.org
(schornsby@nvdetr.org); jleslie@washoecounty.us (jleslie@washoecounty.us); jgoodnight@washoecounty.us
(jgoodnight@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us)
Dear DDA Young and Bar Counsel and Panel Members,
The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what started all this off (by "all this" I mean the
46 days in jail, the 10 different trips to jail, the five to six different evictions, all summary, the competency evaluations, and all
the associated grievances. This arrest and prosecution have largely been based on and the office and prosecutor have cited to,
their contention that the information from ECOMM or dispatch told the RPD Officers (and the arresting Officer Nick Duralde
is married to a dispatcher working that night and perhaps whose voice is on these files, finally given to me only today, by Reno
City Attorney's Office Creighton Skau, after he secured my attendance at a hearing that I do not believe was noticed in a legal
since by sending me an email saying Judge Sferrazza authorized service of the notice of the hearing by email...which Judge
Sferrazza denies (in fairness to Mr. Skau...its possible the Judge did say that...Mr. Young could maybe shed some light on that,
as apparently their was a sort of group meeting with he, the Reno City Attorney and the WCPD on or about November 8th,
2012 in rCR2012-063342, that I was not noticed on and, of course did not attend).
Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch reported a "possible fight" and how that
somehow justified the rash approach taken by Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand
Larceny (7 days in jail, the eviction notice in the Richard Hills summary eviction from my former home law office was served
during the interim in RJC Rev2011-001708) for a three year old iphone that the alleged owner, Cory Goble, testified was worth
about $80 at the time....(and the overcharging of a felony enabled Officer Duralde to conduct a search incident to arrest for a
misdemeanor not committed in his presence, after 7 pm...which Nevada law prohibits, particularly where, as here, there was no
citizen's arrest (Coughlin himself called 911 and there is a video of the time prior to arrest where Coughlin is heard imploring
the skater youths to stay peaceful and wait for law enforcement to arrive so a civil resolution of the dispute could be garnered).
I am writing now and providing this new production of ECOMM/911 dispatch recordings that would seem to be the State's last
hope of proving that the Officers were told of, by dispatch, "a possible fight" and therein provide some factual basis for that
which Officer Duralde and DDA Young have testified to, and filed pleadings in that matter arguing that reports of "a possible
fight" justified the subsequent terry stop weapons check pat down, and search incident to arrest (remember, Officer Duralde
announced 20 seconds into arriving on scene that he was going to arrest Coughlin and do a search of Coughlin's pockets prior to
conducting any of the pretexutal "investigation" that he later testified to...its just that Officer Duralde did not realize he was
being recorded when he said that....no matter how he "remixed" things in his Supplementary Declaration (filed within 48 hours
of arrest) or his Narrative (by all indications, the Narrative was only filed some three months after the arrest and apparently after
the RPD and City Attorneys Office became aware that the video of the arrest was publicly available).
I have listened closely to these dispatch recordings and hear nothing about "a possible fight". Does that make the Officer's
Testimony perjury and DDA Young's conduct misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the
SBN's Office on Double R. Blvd. I ask that you attend and explain these matters as this arrest is pled in Bar Counsel Kings SCR
105 Complaint.
Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to subpoena the dispatch recordings until October
3, 2012 (despite the Trial occuring on May 7th, 2012 (in violation of NRS 178.405, no less), and again on July 16th,
2012....and, again on August 29th, and September 5th, 2012....and then please explain why you feigned inability to personally
serve subpoenas as a basis for failing to get Nicole Watson (easily found and or served via a certified mailing under NRS
174.345, at the addresses your investigator refused to turn over to me until November 2012 upon a court order (you guys are
supposed to help defend the accused, not the County or local law enforcement against their potential civil liability for ego
driven foolish arrests) as a student at McQueen High School along with Lucy Byington, both percipient witnesses, and where
Watson was captured on tape admitting to the "man with a six-pack" holding the phone aloft and offering it up, and announcing,
very loudly, that he woud "throw it in the river" if it was not immediately claimed (therein presenting yet another claim of right
defense and further vitiating the legitimacy of DDA Young's retaliatory, deficiently pled, amending of the Complaint on
December 5th, 2012 to included "possessing or receiving stolen property from another".
I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City Attorney's gained an advantage and
prejudiced my ability to defend in both NG12-0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I
will note that at least Joe Goodnight gathered the three 911 calls.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
Download all

SBN and or Panel will be breaking the law by holding a hearing tomorrow in
violation of SCR 105(2)(c) proof attached
Sent: Tue 11/13/12 3:22 PM
To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net
(eifert.nta@att.net); rosec@nvbar.org (rosec@nvbar.org)
You will be criminals as of tomorrow if you hold that hearing.
SCR 105(2)(c), SBN"s Index for Hearing is holding out certificates of mailing and or proofs of service on the most materials
documents incident to a due process analysis (10 9 12 Notice of Intent to Take Default was recieved as returned due to
insufficient postage by the SBN on 11 8 12, I declare under penalty of perjury...nrs 53.045...further, SBN only sent one
envelope of that document, that returned for insufficient postage certified mail mailing on 10 9 12.
Additionally, SBN is holding out 10 12 2012 certified mailing of Notice of Hearing and Designation of Witnesses and
Summary of Evidence as having a date of 10/12/12 for a constructive notice analysis, despite the USPS proof indicating the first
scan in a USPS system occurred on 10/16/12.
Additionaly, the SBN and Peters formally declared that the 8/23/12 mailing was returned to the SBN and that another certified
mailing of the Complaint would immediately be sent out, and that the 8/23/12 certified mailing would never be offered to prove
proof of service under SCR 109 or in any other manner offered as proof of service of the Complaint. Yet that is just what King
has done by his Index putting that forward.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 13 14 attachment proving 0204 sbn and panel fraud scr 105(2)(c).pdf
From: zachcoughlin@hotmail.com
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Subject: FW:
Date: Sun, 11 Nov 2012 07:50:13 -0800
Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR 116 appeal
rights...
Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN Laura
Peters signed a waiver of service or similar
and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law (Response)

Date: Mon, 13 Aug 2012 11:28:12 -0700
From: silverman@silverman-decaria.com
To: zachcoughlin@hotmail.com
Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
SCR Rule 104(3) Complaint filed against Bar Counsel King and Clerk of Court
Peters
I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final judgment in the crim case and point out that your temporary suspension
is akin to a permanent death of your practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now have access to your meds and
are ok. I can't think this pleading is going to help you much...it is too long, repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't
make your case in 3-5 pp, you can't make your case in 35. 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.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Sent: Mon 11/12/12 9:51 PM
To: Frank Flaherty (fflaherty@dyerlawrence.com); rosec@nvbar.org (rosec@nvbar.org); schornsby@nvdetr.org
(schornsby@nvdetr.org); glennm@nvbar.org (glennm@nvbar.org)
President Flaherty,
I have filed my SCR 104(3) Complaint with you already. I reserve my right to supplement it at a later date, but it is filed. Whether you choose to abide by the duties of your Office is
not something I can control. However, I do understand that there is a Constitutional requirement that the Nevada Supreme Court review your determination. Please provide me the
case number for this Complaint, and the case numbers for every grievance I have filed this year. Just want my file stamp and case number, Sir. I understand you may feel my
Complaint is jibberish...but I don't believe Clerk's of Court, under NRCP 5(e) are permitted to refuse to file Complaints (or anything for that matter, so...please just stamp it in and give
'er a case number.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: FFlaherty@dyerlawrence.com
CC: DavidC@nvbar.org; PatrickK@nvbar.org; KimberlyF@nvbar.org
Subject: RE: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
Date: Wed, 31 Oct 2012 21:02:36 +0000
Mr. Coughlin:

Regarding your numerous complaints and allegations below, I have no case numbers, I have no authority over attorneys who are not
employees of the Office of Bar Counsel, and I certainly have no authority over judges.

If you think you really need to file a complaint against an attorney in the Office of Bar Counsel, please review SCR 104(3) and send
me a succinct and organized written document, along with only relevant exhibits, setting forth your allegations that said attorney
has violated the Nevada Rules of Professional Conduct.

Thank you.

Franci s C. Fl aherty
Dyer-Lawrence
2805 Mountai n Street
Carson Ci ty, Nevada 89703
(775) 885-1896
FAX: (775) 885-8728

Thi s e-mai l may contai n l egal l y pri vi l eged and/or confi denti al i nformati on. If you are not the i ntended reci pi ent(s), or the empl oyee or agent responsi bl e for del i very of thi s message to the
i ntended reci pi ent(s), you are hereby noti fi ed that any di ssemi nati on, di stri buti on or copyi ng of thi s e-mai l message i s stri ctl y prohi bi ted. If you have recei ved thi s message i n error, pl ease
i mmedi atel y noti fy the sender and del ete thi s message from your computer.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Wednesday, October 31, 2012 12:57 PM
To: Frank Flaherty
Subject: FW: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman

Dear Presi dent Fl aherty,

Can I get a case number for thi s matter, I have not heard anythi ng about i t i n forever. I al so, I woul d l i ke to fi l e a gri evance or Compl ai nt agai nst Bar Counsel Pat Ki ng and NNDB Chai rman Susi ch
for fai l i ng to fol l ow the June 7th, 2012 Order of the Nevada Supreme Court and SCR 111(7)-(8), i n addi ti on to SCR 102(4)(d). Under the Chi ng or Chang deci si on, the SBN i s the "compl ai nant" and
wi t respect to these matters, wherei n I al l ege mi sconduct by Peter Chri sti ansen, Character and Fi tness Chai rman Kevi n Kel l y, Esq. and others, the SBN has not known about these matters for more
than 4 years. Further, Ki ng refuses to undertake any i nvesti gati on agai nst Ri chard G. Hi l l , Esq., Judge Nash Hol mes, Casey Baker, any of the RMC "court appoi nted defenders" (l i ke Loomi s,
Puentes, Tai tel , Sotel o) or WCPD's Lesl i e, Goodni ght, Dogan, or Bosl er. Now, Ki ng i s tryi ng to jam me i nto a combo heari ng on November 14th, 2012 i n hi s ng12-0205 ng12-0434, and ng12-0434
scr 105 compl ai nt, whi ch i mpermi ssi l by seeks to ski rt scr 111(7)-(8) vi s a vi s Ki ng's SCR 111 peti ti on i n 60838 (pl ease see my fi l i ngs i n that regard).

Furhter, the "courthouse sanctuary" rul e makes the RMC Marshal Harl ey's conduct i n personal l y servi ng me noti ce of an Order to Show Cause Heari ng i n the appeal of the evi cti on matter i n cv11-
03628 (Ri chard HIl l got me evi cted from my former home l aw offi ce) on behal f of WCSO Deputy Machen (whom HIl l hi red to serve i t despi t the Capl ow deci si on maki ng cl ear that i s not even
requi red...basi cal l y, i ts wrong to have the RMC Marshal barge i n to my pl ea bargai ni ng sessi on wi th ci ty attorney ormaas on february 27th, 2012 i nci dent to the traffi c ci tati ons i n 11 tr 26800
that the rpd gave me at hi l l 's offi ce when I went to get my wal l et, key's, dri vers l i cense, and cl i ent's fi l es from hi l l after bei ng rel eased from a fraudul ent custodi al arrest for cri mi nal trespass at
my former home l aw offi ce i n a cri mi nal compl ai nt si gned by hi l l , judge nash hol mes hel d that 11 tr 26800 tri al l ater that day, despi te her apparent admi ssi on that she was made aware by the
wcpd and or wcpd bi ray dogan that an order for competency eval uati on had been entered respecti ng me on 2/27/12 at 1:31 pm and nrs 178.405 and nrs 5.010 shoudl have prevented judge nash
hol mes from hol di ng that tri al , and In re Ol i ver (us supreme court case requi ri ng si xth amendment ri ght to counci l i n cases l i ke 11 tr 26800 where Judge Nash Hol mes convi cted me of "summary
cri mi nal contempt" despi te her order resti ng upon al l eged conduct outsi de her presence, i n a bathroom stal l that she al l eged i n her 3/ 12/12 heari ng i n that matter an RMC Marshal l wi tnessed
by peeri ng through a bathroom stal l I was i n where "di ssassembl i gn a smartphone" or some nonsense l i ke that peepi ng tom crap...RMC Harl ey was servi ng an Order to Show Cause on behal f of
WCSO Deputy Machen (who di dn't want to wai t around to serve me i t....just l i ke on 11/1/11 when machen di dn't want to fol l ow the l aw i n servi ng me the evi cti on order, and i nstead fi l ed a fal se
affi davi t attesti ng to personal servi ce, then conducted a l ockout usi ng a stal e or i nval i d evi cti on order when I was not present, onl y to attest to havi ng "personal l y served" me..

Thi s i s a mess, the SBN doesn't have jack on me (gi ve me my heari ng under the court's 6/7/12 order for the "sol e purpose" of determi ngi n my puni shment over the "wal mart candy bar" petty
l arceny convi cti on, whi ch I compl etel y showed to l ack due process (di smi ssi ng appeal s for fai l ure to ci te to a transcri pt where the rmc i s breaki ng the l aw i n not prepari ng the transcri pt? i
proved perjury by al l the ci ty's wi tnesses, and prosecutori al mi sconduct, cl earl y)....then the cri mi nal trespass convi cti on i s so fl awed i ts unbel i evabl y. the judge was the brother of the fami l y
court judge garnder who got me fi red from washoe l egal servi ces, and the brother passed her sancti on order to judge nash hol mes who passes i t to the sbn, and i t becomes ng12-0435, but sbn
ki ng doesn't want to admi t that that i s how he got i t? and the brother judge gardner refuses to recuse hi msel f from that cri mi nal trespass case rmc 11 cr 26405, despi t my fi l i ng mandamus
agai nst hi s si ster's order i n 54844 and despi te hi s si ster's order bei ng a bar gri evance agai nst me, submi tted by judge hol mes, on behal f of the brother judge gardner and al l the other rmc
judges? and the rmc "l oses" my n oti ce of appeal an i t gets di smi ssed i n cr12-1262 by the same judge el l i ot of d10 whom put me i n jai l between 4/19 and 4/26/12 i mpermi ssi bl y based upon l i es
by the competency eval uators and a moti on by dda young that vi ol ated nrs 178.405's mandatory stay? and duri ng that i ncarcerati on ri chard hi l l 's $40k attorneys fees moti on agai nst me i n the
evi cti on cv11-03628 i s fi l ed, whi ch fl anagan ul ti matel y awarded?

the sbn i s gambl i ng a l arge chunk of yours and i ts reputati on on a bunch of asi ni ne arrest by the rpd, and extremel y suspect co-si gni ng of ri chard hi l l 's bul l shi t thi s year by peopl e who shoul d
know better.

Si ncerel y,

Zach Coughl i n
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

LITIGATION HOLD NOTICE PLEASE RETAIN ALL EVIDENCE
To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
Subject: Character and Fi tness, Kevi n Kel l y, Pete Chri sti ansen, Patri ce Ei chman
Date: Fri , 16 Mar 2012 13:48:17 -0700
Dear Bar Counsel,
I write respectfully asking an inquiry be conducted into whether Kevin Kelly indicated at my June 2002 hearing that
3 pro bono attorney's name would be provided to me, but that only one was, Peter S. Christiansen, and that,
despite Christiansen saying he was doing my case on a pro bono basis, he was paid at least $5,000, and pretty
much the only work he or his office did was attend the June 2002 hearing, and that Christiansen and Kelly are very,
very close, and that they sent me to a psychologist who specializes in gambling addictions (I have never really
even gambled) who cost approximately another $2,000....Then Ms. Eichman failed to submit my application for
admission or my Request For Reconsideration (sent to her and Christiansen's office on September 15th, 2003, as
confirmed by my fax records, in additional to being mailed to them) to the Nevada Supreme Court. There are
numerous other issues that deserve a grievance there, including whether Christiansen supervised the newly
licensed Sanft in any way, whether a writing wherein I addressed alcoholism was forward to the Bar despite the
express dictate that it not be, whether second Consent Agreement sent to the Christiasens on 9/27/04 was ever
forwarded to the Bar. Additionally, Mike Rowe wrote very stern letters to me basically telling me not to follow up
on things, whereupon my attorney's and Ms. Eichman failed to follow up on things, essentially tying my hands in
the matter. I intend to supplement this grievance with additional matters soon, but wish it to begin now.
Sincerely,
Zach Coughlin
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
Sent: Mon 11/12/12 6:52 AM
To: schornsby@nvdetr.org (schornsby@nvdetr.org); patrick@nvbar.org (patrick@nvbar.org); davidc@nvbar.org
(davidc@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
cvellis@bhfs.com (cvellis@bhfs.com); je@eloreno.com (je@eloreno.com); tsusich@nvdetr.org (tsusich@nvdetr.org);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net)
RELATED TO THE MAILING OF, THE CERTIFIED MAILING NUMBER OF, AND THE ENVELOPE AND
DOCUMENTS RETURNED TO THE STATE BAR OF NEVADA, ESPECIALY THE ONLY COPY OF THE NOTICE OF
INTENT TO TAKE DEFAULT THAT COUGHLIN EVER RECEIVED UNTIL GETTING A COPY OF THE FILE ON 11 7
12 FINALLY DELIVERED TO HIS PHYSICAL ADDRESS AT 1471 E. 9TH, ST. Simply put, the SBN only mailed a certified
version of the Notice of Intent To Take Default. That 10/9/12 mailing was not given to Coughlin by "Tim" at the Vassar
Station due to the postage thereon being insufficient. However, the copy of the file provided to Coughlin lacks any indication
of what the certified mail track and confirm number is for that Notice of Intent to take default.
Coughlin requests that the SBN notify the panel of its error, the fact that Coughlin's Notice of Hearing and DowSoE was not
even scanned into the USPS certified mail until 10/16/12, despite the certificate of mailing indicating 10/12/12, and that that
mailing, with purports to have included the DowSoE, was not even available to Coughlin until 10/22/12, at the po box
Coughlin then utilized (3961
Its more than inaccurate for Mr. King to suggest I have dodged service. See my email to Reno Carson below...I know I called
and left at least once voice mail there, etc. Plus, despite still being afraid of local law enforcement and others, and just getting
used to my new place (and I have already received threats), against my better judgment and preferences, on October 23rd, 2012, I
alerted the sbn of my new physical adderss.
The Disciplinary File provided to Coughlin lacks a return of or proof of service of the Complaint and for the Notice of Intent to
take Default. Please proof of service thereof of proof of attempts at service, including the certified mailing numbers. Give the
primacy of such documents to the due process of these matters, it would seem holding the 11/14/12 Hearing would be
reversible error and imprudent.
"The Rhino" is Johnno Lazetich, http://www.facebook.com/public/Johnno-Lazetich-the-Rhino
we were on the Reno High School basketball team together in 1994-=95... Johnno ran the ball for Kansas State.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
9 24 12 10 3 12 10 23 12 physical address service issues ex 0204 rhino.pdf
"From: zachcoughlin@hotmail.com
To: process@renocarson.com
Subject: checking in
Date: Wed, 3 Oct 2012 23:09:50 -0700
Dear Reno Carson,

Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me know what I
can do for you.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com"
my new address
Sent: Tue 10/23/12 11:29 AM
To: patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; complaints@nvbar.org
Dear Bar Counsel,
I am still very afraid of retaliation by local law enforcement, and due to my status as a domestic violence victim. In the past, I have offered to assistn you in getting me served
appropriately, but have received no follow up. Further, the SBN, via Investigator/Clerk Peters and otherwise have made representations that I have relied upon to the extent that
another certified mail SCR 105 Complaint would be sent out shortly after my communications with Peters on September 11th, 2012 or so where she admitted to receiving in the mail
the one she said she sent on August 23rd, 2012. Whatever the SCR 109 implications, the SBN's promises made by Peters are binding in that regard...
Nonetheless, I now feel forced to provide you my address and expose myself to even greater danger, particularly where, some might say, the SBN has a vested interest in
discrediting me now, a motive, a bias, some might say (I take no position in that regard at the current time). Please note my new phone number as well. While Mr. King has referred
to some upcoming SCR 105 hearing (a "combo hearing" akin to the one's, including a Trial that DDA Young and his crew of Washoe County Public Defenders have been trying to run
on me this year, including attempting to hold a Trial on May 7th, 2012 in RCR2011-0063341 where the Order finding me competent and remanding jurisdiction to the Justice Court in
CR12-0376 was only signed, entered, and file stamped on May 9th, 2012...A big no-no under NRS 178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for
given his communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and 12 CR 12420. This could be your Waterloo, so I hope you will investigate this
properly. Especially considering the Order granting Loomis' withdraw in the criminal trespass case Mr. King just filed an SCR 111 petition in occurred during the pendency of such an
evaluation on May 8th, 2011 (lots going on between May 7th-May 9th, 2012, here!) and the fact that Loomis and or the RMC ramrodded a Trial setting of June 18th, 2012 on May
8th, 2012 as well, well before Coughlin's competency was determined...and to the extent King indicates NG12-0204 and NG12-0435 rely on "Orders" entered or rendered during
periods in which NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no good. Please don't make my address public yet or disseminate it in any way.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, 89512
Tel and Fax 949 667 7402
"From: zachcoughlin@hotmail.com
To: process@renocarson.com
Subject: checking in
Date: Wed, 3 Oct 2012 23:09:50 -0700
Dear Reno Carson,

Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me know what I
can do for you.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com"
my physical address
Sent: Wed 10/03/12 9:31 AM
To: patrickk@nvbar.org; laurap@nvbar.org
Dear Bar Counsel King and Court Clerk Peters,

I would prefer not to give my physical address given that I am a victim of domestic violence and have also
been subject to quite a few attacks by law enforcement this year. I will provide it if you write back
demanding it, as I want to cooperate, but could we arrange for me to accept service by certified mail of
anything you wish to serve me? Or I could meet your process server somewhere?
Tribal Police not allowed to arrest for misdemeanors FW: Case No. RCR2011-
063341
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
citation to legal authority?
Sent: Mon 9/24/12 5:13 PM
To: patrickk@nvbar.org
Mr. King, this is the first I have heard of you wanting a physical address for me. Can you indicate, in writing, when, if ever the SBN has requested as much and whether it was in
writing or verbal? Do you have an legal citation for your contentions.

Thanks,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Sun 11/11/12 8:40 AM
To: homerj@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-stevensc@reno.gov (hazlett-
stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
wongd@reno.gov (wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov); bonyr@reno.gov (bonyr@reno.gov);
skauc@reno.gov (skauc@reno.gov); davidc@nvbar.org (davidc@nvbar.org); drakej@reno.gov (drakej@reno.gov);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); skent@skentlaw.com
(skent@skentlaw.com)
How exactly is it that both City Attorney Pamela Roberts, Esq. and Chris Hazlett-Stevens, Esq. did not violate RPC 3.8 or
otherwise prosecute for arrests that were not lawful
in RMC 11 CR 22176 (Indian Tribe police custodial arrest for misdemeanor? Not lawful under NRS 171.1255, and even if
they were RPD, which they are not, its not like they charge Coughlin with something other than petty larceny a la NRS
171.136(2)...
Further, can you provide me an indication of how it was lawful for RSIC Officer's Kameron Crawford or Donnie Braunworth to
arrest me on 9/9/11 (and Wal-Mart's Thomas Frontino made explicitly clear in his testimony at trial on 11/30/11 that neither he
nor any of Wal-Mart's staff in any way effected a custodial arrest of Coughlin on that date) for a misdemeanor given the
following:
NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person employed as a police officer by an Indian tribe may make an
arrest in obedience to a warrant delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public offense, and the officer or agent has reasonable cause to
believe that the person arrested is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery upon that persons spouse and the peace officer finds evidence
of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a person who is reasonably believed by the officer or agent to have
committed a felony within the boundaries of the reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in the presence of
the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
(Added to NRS by 1985, 452)
While Ormaas made sure to get judicial notice taken of jurisdiction in 11 TR 26800, it doesn't seem Pamela Roberts, Esq. did in the Indian Colony Wal-Mart matter...Why is
that, Pam? Tribal land? Never determined if Coughlin had even an ounce of tribal blood? RSIC Officers not entitled to make custodial arrests for misdemeanors, even,
apparently, one's committed right in their presence? So, even if Coughlin did refuse to provide his driver's license (which has been proven to be a lie, and perjury suborned by
Pam Roberts as to the testimony of Wal-Mart's Frontino and the RSIC Officer's Crawford and Braunworth via police reports, dispatch recordings (AND PLEASE BE
ADIVSED, AS ITS WITHIN THE 2 YEARS, THAT THE CITY OF RENO, THE SOUTH DISPATCH CENTER FOR ECOMM OR WASHOE COUNTY, OR
WHOEVER IT IS THAT HANDLES THE RSIC DISPATCH CALLS, IT ON A LITIGATION HOLD NOTICE. COUGHLIN DEMANDS (AND THE
DISPATCH/ECOMM SOUTH DISPATCH CENTER WILL GET ITS NRS 174.345 SUBPOENA IN THE MAIL FOR A MISDEMEANOR SOON ENOUGH) THAT
THE CUSTODIAN OF RECORDS MAINTAIN ANY AND ALL RECORDINGS, LOGS, OR OTHER DOCUMENTATION OR MEDIA IN ANY WAY
CONNECTED TO ZACHARY B. COUGHLIN IN ANY WAY WHATSOEVER, ESPECIALLY WITH REGARD TO THE ARREST OF 9/9/11 AT THE RSIC WAL-
MART IN RENO NEVADA NEAR GLENDALE AND W. 2ND ST.
So, all these arrests by the RSIC police of alleged shoplifters at Wal-Mart...Sling Bla...er, Officer Braunworth testified that there was lots of them (sounds like Wal-Mart and the
RSIC have the whole "find a way to get a search incident to arrest" thing down part, while avoiding any wrongful arrest liability against the deep pocket tenant Wal-Mart by
avoiding any "shopkeeper's privilege" type citizen's arrests (or trying to use just as much intimidation and coercion as Frontino and the gang can muster, while seeking to claim not
to have effected a citizen's arrest later in court, given setting the RSIC up to handle those types of lawsuits is arguably a better long term loss mitigation approach for these long
term business partners, Wal-Mart and their partner/landlord the RSIC.
So, please enlighten me. How is it these RSIC Officers are making all these custodial arrests for simple misdemeanors? And just where in the audio transcript of the Trial (you
might want to have RMC house transcriptionist Pam Longoni finally get around to making a transcript and providing it to Coughlin, as the handouts the RMC itself provides
defendants baring Longoni's and the RMC's "down payment"/transcript hostage rules are tantamount to extortion in violation of NRS 189.030. Then there is the bit about the
RMC and or other discovering over $700K was "missing", and the attempts to chalk it up to "data entry" errors. Please get that transcript to me right away, and transcripts of
every other hearing I have ever had in the RMC, including the one on or around February 2nd, 2012 or so where RMC court appointed defender Roberto Puentes successfully
argued for an Order Granting His Withdrawal (five Withdrawals by court appointed counsel of Coughlin, four via an Order Granting a duly filed Motion (though these guy's
Motions wouldn't pass my 7th grade English Class's bi-weekly writing assignment in my days at Swope Middle School) and Hon. W. Gardner starts to divulge, only after
Coughlin's prompting, bit by bit some of the patent conflicts that should have prevented him from ever ruling on a single motion in that case 11 CR 26405. With such lack of
vigor from the RMC's court appointed defense counsel, could a class action lawsuit agains them, the RMC, and or the City of Reno be a possibility someday? Certainly is a nice
lil side gig $7K a month those guys get...and all these prosecutions and trips to jail this year certainly have afforded an opportunity to see the "operation" up close.
Also, you know, as to lots of these arrests, like say the July 3rd, 2012 arrest by RPD Officer Alan Weaver and now Sargent Brian Dye in 12 CR 12420 (wherein two RMC
court appointed counsel have already sought and obtained Orders Granting Their Withdrawal, one, by Keith Loomis, one by Henry Sotelo, the latter in violation of the stay in
NRS 178.405) the legitimacy of effecting a custodial arrest is completely suspect considering:
ARREST: BY WHOM AND HOW MADE
NRS 171.124 Arrest by peace officer or officer of Drug Enforcement Administration.
1. Except as otherwise provided in subsection 3 and NRS 33.070 and 33.320, a peace officer or an officer of the Drug Enforcement Administration designated by the Attorney
General of the United States for that purpose may make an arrest in obedience to a warrant delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officers presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officers presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public offense, and the officer has reasonable cause to believe that the
person arrested is the person so named or described.
2. A peace officer or an officer of the Drug Enforcement Administration designated by the Attorney General of the United States for that purpose may also, at night, without a
warrant, arrest any person whom the officer has reasonable cause for believing to have committed a felony or gross misdemeanor, and is justified in making the arrest, though it
afterward appears that a felony or gross misdemeanor has not been committed.

So back to the Wal-Mart RSIC arrest...the charge sheet doesn't say Coughlin was arrested for anything other than petty larceny....but:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation or
offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and the arrest is made in the manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued pursuant to NRS 33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
So, on exactly what basis was the July 3rd, 2012 arrest made by the RPD? The police report says the arrest was made for "disturbing the peace", yet the only allegation of
anything remotely in the "officer's presence" relates to the minor traffic citation the City of Reno is clinging to in attempts to mitigate the Sec. 1983 damages here. However, the
RPD admits at least one vehicle was between their's and Coughlin's and Sooudi et al (besides making an incomprehensibly stupid decision to briefly file an amended complaint for
trespassing where even the RPD was smart enough to realize that was a poor choice given Coughlin still had lease at Northwind, and thus a pat claim of right defense to any
trespass allegation absent something like the manufactured protection order that RPD Officer Weaver coerced Milan Krebs into obtaining, just like Weaver attempted to get
Superior Storage's Matt Grant to do, shortly after Weaver, in full view of Welch, Sargent Miller, and other RPD Officer's, on September 21st, 2012, threatened to come up with
yet another fraudulent "failure to secure a load on one's vehicle" arrest of Coughlin). So, even though Weaver and Dye are stuck with their statements in the written reports,
wherein they allege to have arrest Coughlin for "disturbing the peace" only to then tack on "citations" for the two traffic offenses (and the "proof of insurance" citation, even after
Officer Weaver admits to being provided a high definition pdf picture on a 5 inch smart phone screen with a policy number, etc., only to be amplified by the July 5th, 2012 bail
hearing racket tearing (a tennis reference for Jill Drake, Esq.,... for shame, really Jill, really, really unimpressed).
Please remit a certified check for $450,000 in satisfaction of these torts committed upon Coughlin, under color of law.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: homerj@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341
Date: Thu, 8 Nov 2012 20:36:27 -0800
couldn't open them, and I don't accept service of anything form you... See Allison Ormaas comments on 3/12/12 in 11 tr
26800 with respect to your offices violation of the RMC Rules to the extent there is not difference technologically anymore
between an email and a fax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet and exhibits. A document shall not be split into multiple
transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar
number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a governmental agency, an
attorney, or with the consent of the receiving party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for
response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must state the reason therefore and whether or not any
continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a continuance agree to by then court appointed defense counsel
Lew Taitel, whose business partners Coughlin was suing in CV11-03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go
on a six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but then retaliated against Coughlin's pointing
out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional snail mail, usps, or personal
service. And I am not currently included amongst those who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record
about not being served where he has been. Take, for instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from
representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner as
to why Coughlin has a confirmation of delivery of his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the
combination of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please provide to me the grievance number associate with this new grievance
that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
Voxox noreply@voxox.com Jun 27
to me
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 08:54:28 PM on 2012-06-27.
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox? Get
Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox by TelCentris,
Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
to me
Hi zachcoughlin,
to me
Hi zachcoughlin,
Your Fax was delivered @ 08:13:34 AM on 2012-06-28.
to me
Hi zachcoughlin,
to me
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
FW:
Emergency Ex Parte Motion NG12-0204, 0434,0435
Sent: Sun 11/11/12 7:50 AM
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
3 attachments
10 31 12 0204 Pre Hearing Motion to Dismiss and for Summary Judgement and Memorandum of Law (Responsive
Pleading).pdf (10.4 MB) , 10 31 12 subpoena on peters and waiver of service.pdf (541.5 KB) , ex x harris silverman
coughlin garin 0204 11 11 12.pdf (9.8 MB)
Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR 116 appeal
rights...
Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN Laura
Peters signed a waiver of service or similar
and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law (Response)

Date: Mon, 13 Aug 2012 11:28:12 -0700
From: silverman@silverman-decaria.com
Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final judgment in the crim case and point out that your temporary suspension
is akin to a permanent death of your practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now have access to your meds and
are ok. I can't think this pleading is going to help you much...it is too long, repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't
make your case in 3-5 pp, you can't make your case in 35. 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.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Sent: Sun 11/11/12 4:13 AM
(tsusich@nvdetr.org) (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
from:
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
tel and fax 949 667 7402
I do not consent to service or notice of anything electronically in this proceeding, but I do appreciate being copied on such things via email and fax)
Emergency Ex Parte Motion NG12-0204, 0434,0435
please find attached 88 page Emergency Ex Parte Motion to Dismiss or Quash or Otherwise Challenge Sufficiency of Service
and of Process, of Complaint and Notice of Intent to Take Default and DoWSoE; and Preserving for Appeal Objection to All other Due Process Violations; and
UNDER PROTEST...RESPONSE TO COMPLAINT
RE: Case No. RCR2011-063341
submitted for filing with the State Bar of Nevada on November 9th, 2012
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 9 12 response under protest 0204 and various motions and notices 0204 etc.pdf

Sent: Thu 11/08/12 8:36 PM
To: HomerJ@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-stevensc@reno.gov (hazlett-
stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org)
couldn't open them, and I don't accept service of anything form you... See Allison Ormaas comments on 3/12/12 in 11 tr
26800 with respect to your offices violation of the RMC Rules to the extent there is not difference technologically anymore
between an email and a fax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet and exhibits. A document shall not be split into multiple
transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar
number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a governmental agency, an
attorney, or with the consent of the receiving party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for
response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must state the reason therefore and whether or not any
continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a continuance agree to by then court appointed defense counsel
Lew Taitel, whose business partners Coughlin was suing in CV11-03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go
on a six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but then retaliated against Coughlin's pointing
out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional snail mail, usps, or personal
service. And I am not currently included amongst those who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record
about not being served where he has been. Take, for instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from
representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner as
to why Coughlin has a confirmation of delivery of his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the
combination of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please provide to me the grievance number associate with this new grievance
that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
to me
Hi zachcoughlin,
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox? Get
Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox by TelCentris,
Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
to me
Hi zachcoughlin,
to me
Hi zachcoughlin,
to me
Hi zachcoughlin,
"investigator" Peters putting the blindfold on herselfFW: Undeliverable:
to me
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341
Please see attached documents from Creig Skau, Deputy City Attorney:

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

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

Thank you.

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

ATTORNEY-CLIENT PRIVILEGE

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

Sent: Tue 11/06/12 8:25 PM
To: complaints@nvbar.org (complaints@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); patrickk@nvbar.org
(patrickk@nvbar.org)
This is ridiculous that Clerk of Court/Investigator Peters has admitted to adding me to her blocked senders list. Why doesn't she add herself to the "blocked paycheck" list? Please
forward this on to her. Plus, she added me to that least WAY too late to excuse the lack of investigation and due diligence her, considering all the materials I can proved she and the
SBN received.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: postmaster@nvbar.org
Date: Tue, 6 Nov 2012 19:45:32 -0800
Subject: Undeliverable:
Delivery has failed to these recipients or groups:
laurap@nvbar.org (laurap@nvbar.org)
This message was rejected by the recipient e-mail system. Please check the recipient's e-mail address and try resending this message,
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From: Zach Coughlin <zachcoughlin@hotmail.com>
To: "laurap@nvbar.org" <laurap@nvbar.org>, "patrickk@nvbar.org"
<patrickk@nvbar.org>
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
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x-doc-filename1: 11 6 12 0202 Objection and Notice.pdf
x-doc-filename2: supplemental to Coughlin's designation fo witnesses and
summary and production of evidence and notice of objection 0204 CORRECTED
CAPTION.pdf
x-doc-filename3: 0204 notice of non service of purported notice of intent to
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x-doc-filename4: 0204 SUBPOENA WITH DISCLAIMER.pdf
x-doc-filename5: 0204 subpoena all.pdf
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--Forwarded Message Attachment--
To: laurap@nvbar.org; patrickk@nvbar.org
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
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 Jesus" (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 Respondnet 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
(No Subject)
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 dispalyed a clear lack of regard for procedural safeguards in that it was issued prior to the
expiration of five judicials days from the constructive service upon Coughlin, 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? 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 Judge Nash Holmes? What's next, Judges 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 frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John 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:
Rule120.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
11 6 12 0202 Objection and Notice.pdf
supplemental to Coughlin's designation fo 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

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 Jesus" (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. "
(No Subject)
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 Respondnet 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 dispalyed a clear lack of regard for procedural safeguards in that it was issued prior to the
expiration of five judicials days from the constructive service upon Coughlin, 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? 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 Judge Nash Holmes? What's next, Judges 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 frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John 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:
Rule120.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
11 6 12 0202 Objection and Notice.pdf
supplemental to Coughlin's designation fo 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

Sent: Tue 11/06/12 9:46 AM
(tsusich@nvdetr.org) (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
Zach Coughlin has shared a folder with you
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 5 12 SUPPLMENTSAL TO 0204.pdf

Sent: Tue 11/06/12 9:46 AM
To: patrickk@nvbar.org
Exhibit 1 to 11 3 12
Supplement to
Coughlin's List of
Witness, Summary
of and Production
of Evidence for
NG12-0204, 0434,
0435 SBN v
Coughlin SCR 105
View photos
You are invited to view Zach's album. This album has
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
Share your files with
Sent: Tue 11/06/12 9:46 AM
To: davidc@nvbar.org
Supplement to
Coughlin's List of
Witness, Summary
of and Production
of Evidence for
NG12-0204, 0434,
0435 SBN v
Coughlin SCR 105
View photos
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
FW: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena
Duces Tecum: CV10-01341
Sent: Tue 11/06/12 9:46 AM
To: complaints@nvbar.org
Supplement to
Coughlin's List of
Witness, Summary
of and Production
of Evidence for
NG12-0204, 0434,
0435 SBN v
Coughlin SCR 105
View photos
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
Sent: Mon 11/05/12 3:31 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com)
5 attachments
12 8 11 email to eflex regarding Gessin's efiler status and withdrawals 0204.htm (12.7 KB) , 11 25 11 email to John
Gessin jd.gman@yahoo.com explaining ghostwriting taboos and Notice of Appearance 0204.htm (12.7 KB) , 9 6 11 11-
05078 Gessin 0204 26405 1708 03628 proof that Coughlin was commercial tenant 40.253 prohibits summary evict no
cause.pdf (39.5 KB) , 9 6 11 11-05078 NVB Gessin Coughlin not ghostwriting 0204.pdf (558.4 KB) , 9 7 11 Adversary
Proceeding 11-05077-btb rissone gessin 0204.pdf (36.2 KB)
Dear Mr. King and Chairman Echeverria,
Is this ghostwriting allegation by Hill in 0204 still an issue? I am pretty sure Gessin paid for his own electronic filing account at
about the time we parted ways...and that Hill, Baker, and I were all listed as his attorney at that time....Shelly O'Neill, Esq. (of the
NNDB) is now or recently was Gessin's attorney in various matters...Can we narrow down what is at issue in the hearing? I
didn't do any ghostwriting and in fact kind of went out of my way to prevent anything of the sort...I think I was halfway
concerned about the appearance of ghostwriting when I sent Gessin the 11/25/11 email and filing Notices of Appearances were,
to some extent (not soley) done to guard against anything like that... In the eflex notification below...I did not filed such a
Subpoena Duces Tecum and I am almost sure I didn't have anything to do with a subpoena and Gessin during the entire time I
worked on his matters. I believe I filed a few documents in the NVB on an "unbundled services" type of arrangement, from
which I learned that it is not really possible to do so, to the extent that one will still need get an Order granting their Withdrawal
as "counsel of record", even if the attorney notates "unbundled services" on the information above the caption....
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 9 Dec 2011 10:22:05 -0800
From: eflex@washoecourts.us
Subject: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena Duces Tecum: CV10-01341
****** IMPORTANT NOTICE - READ THIS INFORMATION *****
PROOF OF SERVICE OF ELECTRONIC FILING
A filing has been submitted to the court RE: CV10-01341
Judge: PATRICK FLANAGAN
Official File Stamp: 12-09-2011:09:26:55
Clerk Accepted: 12-09-2011:10:17:49
Court: Second Judicial District Court - State of Nevada
Case Title: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB)
Document(s) Submitted: Subpoena Duces Tecum
- **Continuation
Filed By: JOHN GESSIN
You may review this filing by clicking on the following link to take you to your cases.
This notice was automatically generated by the courts auto-notification system.
If service is not required for this document (e.g., Minutes), please disregard the below language.
The following people were served electronically:
RICHARD HILL, ESQ. for JOHN GESSIN
ZACHARY COUGHLIN, ESQ. for JOHN GESSIN
CASEY BAKER, ESQ. for JOHN GESSIN
The following people have not been served electronically and must be served by traditional means (see Nevada electronic filing rules):
GLADE HALL, ESQ.
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John Gessin wishing to be able to file without rejections
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 12/08/11 3:08 PM
To: eflex@washoecourts.us; filing@washoecourts.us; cfranden@mail.co.washoe.nv.us; courttech@washoecourts.us
3 attachments
alternatively errate withdraw etc CV09-00710 - ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , alternatively errate withdraw etc ARB09-00710
- ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , ERRATA TO NOTICE OF APPEARANCE OR ALTERNATIVELY MTN TO WITHDRAWCV10-
01341 - STACEY RISSONE VS. JOHN DAVID GESSIN (ARB) notice of appearance hill baker.pdf (81.0 KB)
I am writing (I just filed the attached motions as well) due to exigent circumstances. Basically, John Gessin (jd.gman@yahoo.com
775 376 3650), who is apparently an efiler pro se, wishes to be able to file things, but is being told my attorney of record
status is preventing that. In order to attempt to avoid prejudicing Mr. Gessin's interests, I am writing to ask that you allow
him to file what he wants, on his own behalf right away, given that time may be of the essence.

Sincerely,
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended
for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential,
intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not
the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is
prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and
destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
Print
NOTICES OF APPEARANCES
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 11/25/11 12:24 AM
To: jd.gman@yahoo.com
4 attachments
CV10-01341 RISSONE ARB BAKER HILL NOTICE OF APPEARANCE.pdf (60.4 KB) , CV09-00710 TAITANO MOORE STP NOTICE OF APPEARANCE.pdf (60.6 KB) , CV10-03675
STACEY RISSONE ET VS JOHN DAVID GESSIN ET (D3) NOTICE OF APPEARANCE.pdf (60.4 KB) , ARB09-00710 taitano moore arb notice of appearance.pdf (61.1 KB)
John, Let me know whats going on, i got a new temporary address and phone number. theres is some ghostwriting taboos,
so...if you want me to withdraw thats fine, whatever, its all good
Zach Coughlin, Esq.
817 N. Virginia st. #2
Reno, NV 89501
775 229 6737
Licensed in Nevada
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended
for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential,
intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not
the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is
prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and
RE: convicting attorney of summary criminal contempt during pendency of Order
for Competency Evaluation
RE: Mr. King's assertion in his 3/16/12 letter
destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
Sent: Sun 11/04/12 12:34 AM
To: togninim@reno.gov (togninim@reno.gov); joey.hastings@washoecounty.us (joey.hastings@washoecounty.us);
joey.orduna@washoecounty.us (joey.orduna@washoecounty.us); david.hardy@washoecounty.us
(david.hardy@washoecounty.us); patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org
(complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
(cvellis@bhfs.com)
Dear SBN,
I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me in response to
your antiquated email system having any sort of file size limitations resulting in a rejection of a transmission that pretty much an
old free gmail or hotmail account could accept. So, your on notice of that and your apparent purposeful Luddite stance (reminds
me of "Investigator" Peters mentioning how reluctant she is to investigate anything) is not something I will be receiving any
notice of so you might want to adjust your email system accordingly.
I have an idea, how about you implement a "salary size limitation" on your paychecks until you cease pursuing outdated and
dubious plausible deniability constructs?
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org; skent@skentlaw.com;
mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Subject: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
Date: Sat, 3 Nov 2012 03:13:58 -0700
togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us;
patrickk@nvbar.org; skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com;
davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Sun 11/04/12 12:33 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org
(complaints@nvbar.org)
Dear SBN,
I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me in response to
your antiquated email system having any sort of file size limitations resulting in a rejection of a transmission that pretty much an
old free gmail or hotmail account could accept. So, your on notice of that and your apparent purposeful Luddite stance (reminds
me of "Investigator" Peters mentioning how reluctant she is to investigate anything) is not something I will be receiving any
notice of so you might want to adjust your email system accordingly.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org; skent@skentlaw.com;
mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Subject: FW: Mr. King's assertion in his 3/16/12 letter
Date: Sat, 3 Nov 2012 03:00:11 -0700
Dear Judge Hardy, Chairman Susich, Clerk of Court Orduna Hastings, Bar Counsel, and Ms. Tognini, and
Members of the Panel,

It is plain from my interactions with Patrick King that the irony of Richard G. Hill, Esq's allegations of my
"ghostwriting" are richest when considering the apparent "ghost-grievancing" going on here, especially with
respect to the genesis of NG12-0435, the grievance consisting of Family Court Judge Linda Gardner's April
2009 Order sanctioning a domestic violence attorney $1,000, personally, where failed to follow Judge Linda
Gardner's orders to seek to intimidate his battered spouse immigrant client into accepting the marital
settlement agreement offer of one John Springgate, Esq. (a chimera of sorts where Mr. Springgate's client
would agree to be responsilbe for a collection of third party credit card debt for which he was the sole
signatory and for which even under and extremely unlikely "doctrine of the neccessaires, assuing my client
lost on a "waste of marital assets", approach, my client, Ms. Joshi, would be very unlikely to ever face
judgment or execution in connection with such third party credits card debts. I failed to cave to Judge Linda
Gardner's bullying demands, and even where she yelled at me and my client in the impromptu "settlement
conference" she decided to hold 10 minutes before the Trial (Judge Linda Gardner yelled at me to "shut up" in
front of my client, then proceeded to tell Ms. Joshi "don't listen to your attorney!" in an angry, hostile, and
belligerent tone), and instead cited to an ALR article that presents the position I took as the majority viewpoint
in American jurisprudence with respect to the duty of a domestic obligation not being permissibly set off with
a mere debt, particularly a third party unsecured credit card debt, such as those for which Mr. Joshi was the
sole signatory. Apparently Judge Gardner agreed with John Springgate's whining about how he "needed to be
able to know how much to charge for his time" or something along those lines (Mr. Springgate indicated that
Coughlin's failing to immediately accept Springgate's settlement offer was screwing up Springgate's whole
profit margin, and therefore contrary to the orderly administration of justice, or something along those lines, at
which point Springgate moved for sanctions (despite not having served a 21 day safe harbor filing ready NRCP
11 motion), which, in John's words was tantamount to "sending a shot across your bow", a bloodsport sort of
analogy one might expect from a semi-professional fencer like Mr. Springgate. I was fired from Washoe
Legal Services and told by its Executive Director that the decision was based solely on Judge Linda Gardner's
Order....which was odd given she and Master Edmondson and at least one other judge had given Elcano
positive reviews of my work less than two months prior to that. Elcano, though, did, at the time of reporting
those positive reviews mention that he goes "way back" with Linda Gardner, and that "she owes" him because
"he did her a big favor a long time ago", etc., etc.

Anyways, Bar Counsel King has recently indicated that he was completely unaware that Linda Gardner is the
sister of the RMC Judge William Gardner who refused to recuse himself from the criminal trespass conviction
I sustained incident to a custodial arrest at my former home law office, wherein the opposing counsel Richard
G. Hill, Esq., has been caught lying on tape regarding whether any warning was given to me to leave, and
whether the RPD identified themselves as law enforcement and issued a lawful order to leave the premises
prior to the landlord kicking down a door to a "basement" that was, according to Hill's associate, not even a
part of the property (or included in the part of the property contained within any exterior doors to the
premises.

Despite the statements of RMC Judge Gardner in the audio cds that King himself finally admitted to me to
possessing and receiving from RMC Judge Nash Holmes (after several instances of King lying about his
willingness to allowing me to review the materials Judge Nash Holmes and others slipped to the SBN, King
finally was forced to turn over at least a few of those items. Included amongst them were the hearings before
Judge William Gardner on 4/10/12 and 5/8/12 wherein RMC Judge William Gardner admits that his sister is
none other than Family Court Judge Linda Gardner, and that his sister passed him her April 2009 Order
sanctioning Coughlin (which Coughlin filed a Petition for Writ of Mandamus challenging in 54844,):
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746

Washoe Legal Services fired Coughlin, citing Judge Linda Gardner's Order sanctioning Coughlin as the sole
reason for its doign so. Couglin sued WLS for wrongful termination, and Judge Elliot dismissed Coughlin's
lawsuit without reaching the merits of the Complaint, but then decided to sanction Coughlin for his lawsuit
allegedly lacking "merit" anyways...go figure. Judge Elliot also incarcerated Coughlin from April 19th, 2012-
April 26th, 2012 based upon some fraudulent letter by Lake's Crossing, and some Motion for Revocation of
Bail made by DDA Zach Young at a time when NRS 178.405 forbid his making any motions given that all
proceedings must be stayed during the pendency of an Order for Competency Evaluation. Amazingly, in her
3/16/12 letter to the SBN, Judge Nash Holmes is still mentioning how she and the RMC are furiosly trying to
set for Trial the case stemming from teh custodial "jaywalking" arrest of Coughlin on January 12th, 2012
incidnet to the lies by Richard G. Hill, Esq. to the RPD on that date. It is curious that that matter 11 CR
00696 was all of the sudden transferred to Judge Nash Holmes on February 27th, 2012, the same day Judge
Nash Holmes was purportedly made aware of the 2/27/12 Order for Competency Evaluation of Coughlin in
RCR2011-063341 (relative, at the very least, to the communications between Tognini and the WCPD, at the
very least). Additionally, Second Judicial District Chief Appeals Clerk denied Coughlin's 2/27/12 filing of a
Motion for Extension of Time to effectuate service in the wrongful termination lawsuit by Coughlin against
Elcano (whom Judge Linda Garnder "owes a big favor", according to Elcano) in CV11-01955 (before Judge
Elliot).

Further, to the extent Judge Elliot's remanding Coughlin into custody to coerce his consent to divulging
extremely private medical information is somehow a contempt Order, then the "letter" or "evaluation under
seal" of 4/18/12 by Lakes Crossing Dr. Bill Davis and Dr. Sally Farmer must be in the form of an affidavit. It
was not. Further, Coughlin called Dr. Davis from the booking room at the jail and Dr. Davis attempted to
weasel out of the consequences of his professional misconduct, done under color of law, by alleging that he
"didn't write the 4/18/12 letter filed with the Court" but merely signed it and was not responsible for it being
filed with the court. To the extent the assertions in that 4/18/12 letter are outright lies (they are...the letter
indicates Coughlin outright refused to provide basic medical information, which is not true, Coughlin indicated
he would "need to check his records" in response to one initial question, and then mentioned that some
professional, particularly physicians, face an inability to obtain malpractice insurance if word gets out that they
take anti-depressants. Somehow Dr. Davis and Dr. Farmer interpreted such a statement to allow themselves to
file a letter with the Court alleging that Coughlin "threatened one of the evaluators with legal action". No
wonder Lake's Crossing insists on doing a Terry Stop style "pat down" search on each and everyone forced to
go there by the Courts to get a Competency Evaluation (the RJC and WCPD have it set up so that one must
utilize the services of Lake's Crossing for any such evaluation) and maintain a strick ban on any sort of smart
phones or cellular phones within their evaluation rooms (how difficult it would be for Dr. Davis and Dr.
Farmer to lie with seeming impunity, as they did in their 4/18/12 "evaluation" filed with the Court in CR12-
0376, should their subjects be readily able to reveal the dishonesty of these evaluators via some recording
impeachign their credibility. To the extent Judge Elliot found Coughlin in contempt of court (which he
apparently did in response to Coughlin inquiring into the scope and extent of such a Competency Evaluation
rather than submitting to a blank check inquest into his mental health and medical records incident to a
retaliatory Motion for Competency Evaluation on 2/27/12 by a public defender upset that Coughlin had
criticized his failing to show up to a court date even after that attorney, Biray Dogan had filed a Notice of
Appearance and met with the client to discuss the case RCR2012-065630, for over an hour and a half just one
week previous to that missed court appearance, and where DDA Young was clearly retaliating against
Coughlin for Coughlin filing a Motion for Sanctions against Young just days previous to that in a different
case.

Regardkess. Marilyn Tognini is now being listed as a witness Coughlin intends to call at his November 14th,
2012 NNDB hearing at the State Bar of Nevada Offices at 9 am, and any other person whom Judge Nash
Holmes may be referring to in her attached grievance against Coughlin (wherein she manages to allude to
some hearsay about Coughlin living in his car despite the fact that Coughlin was clearly still living at 1422 E.
9th St. at the time Judge Nash Holmes letter to the SBN was written, 3/14/12, even where Judge Nash Holmes
feigns an inability to readily make contact with Coughlin, depsite neither she nor the RMC calling, emailing or
faxing Coughlin, or managing to mail the 2/28/12 Order to the address all other RMC Departments then had
for Coughlin. Regardless, that 3/14/12 grievance goes on to demonstrate Judge Nash Holmes profound lack of
respect for or knowledge of the dictates of NRS 178.405, or the legal principles, in general, related to
refraining from proceeding with prosecutions where the competency of the accused is in doubt in the mind of
the trier of fact. Further, the SBN's Bar Counsel Patrick King (whom, again, managed to just in the last couple
weeks indicate that he was unaware that Judge William Gardner and Judge Linda Gardner are brother and
sister, or even related, despite King receiving from the RMC's Judge Nash Holmes a box of materials that
included multiple hearings in the criminal trespass proseuction of Coughlin that Judge William Gardner (then
RMC Administrative Judge, whom admitted to "at least one meeting" wherein he and the other RMC Judges
discussed Coughlin, along with Chief Marshal Roper, only for Judge Gardner to then attempt to say with a
straight face that he "was not sure whether he was" aware of this or that, or had any knowledge of the
grievance Judge Nash Holmes filed against Coughlin with the SBN (despite that 3/14/12 letter to the SBN by
Judge Nash Holmes expressly purporting to be written on behalf of herself and ALL the other RMC Judges,
whose "full cooperation" she assures she can deliver to the SBN in seeking to discredit Coughlin and in so
doing assist the City of Reno in addressing the multiple wrongful arrests of Coughlin in the preceding months.

Regardless, the communications between the Washoe County Public Defender and the RMC, including Ms.
Tongini and Judge Nash Holmes, and what exactly Judge William Gardner was made aware of, and what he
passed from his sister, Judge Linda Gardner, on to Judge Nash Holmes, and what Judge Nash Holmes passed
onto Bar Counsel King is now of material relevance, and brings into play the issue of the level of candor with
opposing counsel King exhibits in his 4/19/12 correspondenc with Coughlin when he purports to only have
recieved Judge Linda Gardner's April 2009 Order for Sanctions on 3/15/12 (and that "5" in the "15" looks
shaky, Pat), wherin King wrote: "It was sent to me by the clerk of the court at my request, pursuant to my
investigation." Which Clerk of Court, Mr. King? Clerk of Court Orduna Hastings? Then there is Judge Elliot dismissing
Coughlin's lawsuit against Washoe Legal Services, then incarcerating Coughlin between April 19th and April 26th, 2012 (during
which time Richard G. Hill and Casey Baker filed their Motion for Attorney's Fees of $40,050 incident to the appeal of a
summary eviction in CV11-03628, which Coughlin's former co-worker Judge Flanagan awarded Baker and Hill, after Judge
Flanagan refused to recuse himself even where Coughlin pointed out the necessity of his so doing. Then Judge Elliot denied
Coughlin's appeal of RMC Judge Howard's conviction of Coughlin for "petty larceny of a candy bar and some cough drops" in 11
CR 22176 (the sole basis for the current temporary suspension of Coughlin's law license, incident to a trial where the Reno City
Attorney Pamela Roberts offered perjured testimony from Wal-Mart's Thomas Frontino and RSIC Officer Kameron Crawford
that Crawford was justified in conducting a custodial arrest and search incident thereto for an alleged misdemeanor offense,
occurring after 7 pm, outside the presence of the officer, in light of Coughlin failure to provide the officer his driver's license.
City Attorney Roberts had been provided by the RSIC a video tape showing Coughlin providing Crawford his driver's license,
and Coughlin's booking inventory sheet lists his drivers license (despite Officer Crawfords sworn testimony that Coughlin did
not have one on his person at the time, even where Wal-Mart's video shows Crawford copying down Coughlin's information
off the driver's license Coughlin provided to Offier Crawford, and where Wal-Mart admits that it did not effect a citizen's arrest
of Coughlin, and therefore NRS 178.1255 required an application of the exclusionary rule to any partial package of "cough
drops" found in Coughlin's pockets upon a search incident to arrest (and even that is not all that necessary to prove Coughlin's
innocence given that the RSIC Officer and Wal-Mart's Frontino testified incorrectly that the receipt for the $83.82 worth of
groceries that Coughlin selected and paid after his allegely consuming a "candy bar and some cough drops" while shopping,
did, in fact have an entry for that exact UPC of Duract Cough Melts ("cough drops"), contrary to the sworn testimony of both
Wal-Mart's Frontino and the RSIC's Crawford). But none ofthat mattered much to Judge Elliot, as he denied Coughlin's appeal
based on some civil statute related to a litigant being required to pay for a transcript up front, even where, in criminal
matters, the RMC is required to transmit the record on appeal and order the production fo the transcripts within 10 days of
the filing of a Notice of Appeal, pursuant to NRS 189.010-030, regardless of whether the criminal defendant pays for the
transcript up front. See CR12-1018 for other instances of teh RMC and its "exclusive trancriptionist" Pam Longoni perpetuating
a fraud on the public (the RMC indicates Longoni is the only transcriptionist they will allow, and demand that she be paid up
front....Longoni hung up on Coughlin multiple times and otherwise prejudiced Coughlin's appeal by refusing to prepare his
transcript even where Coughlin would pay up front for the transcripts, in CR11-2064. Judge Elliot then dismissed Coughlin's
appeal of the criminal trespass conviction by Judge William Gardner in CR12-1262 where the RMC and Lisa Wagner failed to
file the 6/28/12 Notice of Appeal Coughlin has confirmation that the RMC and City Attorney Hazlett-Stevens recieved, though
both maintain a dubious position counter to such irrefutable proof.

Additionally, one of the aspects of Richard G. Hill's grievance with the SBN against Coughlin, memorialized in NG12-0204 (one of the three greivances forming Mr. Kings SCR 105 SBN
v. Couglin Petition) alleges some sort of "ghostwriting" on Coughlin's part for a former client of Coughlin's John Gessin. This is plainly not true, though some confusion may have
arisen given the fact that at about the time Gessin and Couglin parted ways, Gessin apparently paid for and signed up for an E-flex account (apparently non-attorneys may do so?).
Hill's allegations respecting Gessin are baseless and ironic given the fact that Coughlin filed Notice of Appearance as Gessin's attorney in various matters, and even sent Gessin a
correspondence wherein he warns Gessin that he will not tolerate any appearance of ghostwriting (what can an attorney do when a client pays him money, drafts of NRCP 60(b)
Motions are worked up extensively over a period of time, then the client decides he wants to part ways, and takes with him those drafts? File a Notice of Appearance so there is at
least some paper trial?). It would be helpful to addressing Hill's allegations vis a vis "ghostwriting" for Gessin if the Second Judicial District Court would present or allow for
inspection anything it may have tending to shed light on such allegations.

Here is one correspondence Coughlin sent then client John Gessin refuting the allegations that Hill made to the SBN in his attached 1/14/12 grievance against Coughlin (attached to
the SBN King's 2/14/12 letter to Coughlin):

"Subject: NOTICES OF APPEARANCES

John, Let me know whats going on, i got a new temporary address and phone number. theres is some ghostwriting taboos, so...if
you want me to withdraw thats fine, whatever, its all good
Zach Coughlin, Esq."

Further, in her 10 4 12 order in 11 TR 26800, Judge Nash Holmes continues to refuse to allow Coughlin to appeal a final appealable order convicting him of "summary
criminal contempt", even though Judge Holme's Order specifically relies upon alleged conduct, and an essential element thereof, not occuring in here "immediate
presence", and where there is no Affidavit by her Marshal (Judge Nash Holmes states on the record in 11 TR 26800 that an RMC Marshal (apparently Marshal Harley)
followed Coughlin into the restroom during a break in the Trial Judge Nash Holmes begrudingly granted Coughlin (though she ordered him to leave his yellow note pad in
the courtroom?) whereupon Marshal Harley played Peeping Tom through a bathroom stall and alleges to have spied Coughlin "dissassembling a smartphone", which
Judge Nash Holmes took as an opportunity to find "by clear and convicing" evidence that Coughlin "lied" "under oath" in response to her impromptu, sua sponte,
interrogation of Coughlin immediately following that bathroom break (and soon after RMC Marshal Harley (who violated the "courthouse sanctuary" dictates against
serving Coughlin Judge Flanagan's Order to Show Cause for a 3/23/12 Hearing on Richard G. Hill's Motion in the eviction appeal in CV11-03628 while Coughlin and City
Attorney Ormaas where haggling over plea details immediately prior to the traffic citation trial in 11 TR 26800 (incident to Coughlin being told to leave Hill's office upon
arriving their to retrieve his keys, wallet, and driver's license, and client's file upon being released from three days in jail incident to a criminal trespass complaint Hill
signed against Coughlin, which the RPD committed misconduct in subjecting Coughlin to a custodial arrest for, especially in light of the video taped admission of Sargent
Lopez and the matrials presented in Coughlin's recent filings in 61901 and 11 CR 26405). RMC Marshal Harley took it upon himself to aid WCSO Deputy Machen in filing a
false Affidavit of Service in Harley's handing Coughlin, on behalf of Hill, a document Hill paid the WCSO to serve on Coughlin (an how unseemly and bullying to attempt
to serve it at the traffic citation trial, appearance of impartiality and impropriety be damned, Caplow, regardless.). And City Attorney Ormaas may have been whispering
in Harley's ears given her apparent concern or her responses to Coughlin asking her, shortly before the trial commenced, if she planned to follow up on or in any way
document the admissions to accepting bribes from Richard Hill made by the officer effecting the custodial criminal trespass arrest, RPD Officer Chris Carter, Jr. (whom will
apparently attest that he was jesting, though its not clear what is funny about arresting an attorney for trespass at his former home law office where the WCSO admits it
lied in filing an Affidavit of Service attesting to having "personally served" Coughlin such an Eviction Order.

I appreciate this opportunity to clarify my subpoena.

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

From: PatrickK@nvbar.org
Subject: RE: Mr. King's assertion in his 3/16/12 letter
Date: Thu, 19 Apr 2012 21:29:10 +0000
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,

A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the grievances filed against you. The panel directed me to
proceed to a formal disciplinary hearing. As such, I will be preparing a formal Complaint.

I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at Wal-Mart and that you should not have been found in
contempt of Court. However, it must concern you that you were found in contempt of Court by more than one Judge in two different trials. You wanted to know how I
learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at my request, pursuant to my
investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were held in contempt of Court. You may be
well served to explain what remedial measures you are taking to make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can
suggest you cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to
the office of Bar Counsel.

Patrick King
Sent: Monday, April 16, 2012 5:41 PM
To: Patrick King; David Clark; Glenn Machado
Subject: Mr. King's assertion in his 3/16/12 letter

Dear Bar Counsel,
One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months worth of my portion of our rent from me (our arrangement
was I would give her the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed a great deal and paid lots of her tuition, and she broke up
with me and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her graduation from UNR. I did not know about her stealing my portion of the
rent or failing to pay her own portion until August 2011, as the landlord was on an extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the
eviction in RJC REV2011-001708 from my former home law office ensued within less than a week of his communicating this deficiency. He and his counsel, Richard G. Hill, Esq. and
Casey Baker pursued a No Cause Notice of Eviction because there was a wealth of support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in
addition to personal property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such, indicated it would "be the path of least
resistance" to simply seek a No Cause Eviction. The only problem in their attempt to circumvent the law (even though they still threatened to seek back rent in another forum after
getting their No Cause, summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a commercial law office there, and NRS 40.253 makes
impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice, which, of course Baker and Hill chose not to do....and it was about the time that
Hill started to understand that his "wrong site surgery" for his neurosurgeon landlord client might subject Hill and his firm to some malpractice liability, that Hill started writing letters to
bar counsel attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable when Gessin was Hill's client and Hill was milking over $20K from Gessin) for
"ghostwriting" even though I was listed as Attorney of Record on several different Gessin cases, etc., etc.
Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has filed a grievance or complaint and also with respect to any criminal
charge against me, including that which resulted in a conviction in 11 CR 22176, which, I think will ultimately reveal was replete with prosecutorial misconduct, lying by the Wal-Mart loss
prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other errors by Judge Howard.
I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on that 3/16/12 letter from Assistant Bar Counsel King
(please see attached picture of the letter and envelope) indicates it was mailed 3/16/12, and the letter indicates it was not faxed to me (despite my numerous written requests that such
a practice be done in consideration of the problems I have encountered in the USPS violations of the Federal Torts Claims Act and incident to the domestic violence I have been subjected
to, in FV12-00188 and FV12-00187, which included interference with my mail).
I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden Valley USPS Station and the Downtown Reno Post Office in
and attempt to make every diligent effort to receive my mail. I have been threatened by and lied to by the supervisors of the Golden Valley Station USPS Station. I had a hearing
related to a landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12 letter that I was living in my car at that time rather suspect, given my home
law office was located at the property which was the subject of that hearing and which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no attribution for such
hearsay in her extremely reckless assertion) in RJC REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked even a law license to litigate on her behalf, or
on that of the HOA which Kern has now decided to appear for, despite her being listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in
RJC Rev2012-000374.
convicting attorney of summary criminal contempt during pendency of Order for
Competency Evaluation
My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to respond to it. Additionally, I note that Mr. King, in that
3/16/12 letter, writes "I am enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order from District court....I will make available for your
review and inspection the supporting documents and audio recordings."
However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting documents and audio recordings". I wish to have a copy of all
such "supporting documents and audio recordings", and failing a copy being provided, I wish to be allowed the access to conduct a "review and inspection" of "the supporting documents
and audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such access. In addition, Mr. King now informs me that he has opened a grievance
on behalf of Judge Linda M. Gardner, incident to a Order for Sanctions she entered in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or
otherwise provided it to Bar Counsel as a Complaint or Grievance or otherwise. I believe someone necessarily must file the complaint or grievance. Further, I believe I am entitled to
know whom that is, and when such was filed. Additionally, Mr. King has, so failed to provide a copy or any access to any purported complaint by the City of Reno Marshal's division
incident to my accessing justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord tenant hearing set for March 15th, 2012, and further, in
response to hostility, retaliation, lies, and threats made by the USPS Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12
letter to me, was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other, on it by the USPS), however, some mail, like several Orders of
the Reno Municipal Court, were not forwarded on to me, but rather, apparently, returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for Judge
Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what Judge Nash Holmes is referring to when she describes difficulty contacting me (the attempts by Judge Nash Holmes
and the RMC apparently did not included either email or fax or a phone call, however....).
There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the RMC dated 3/14/12) and which mailings it ultimately
forwarded on to me (at my then PO BOX 60952, please note, I have a new PO BOX, that I intened to keep for a substantial period of time, it is PO BOX 3961, Reno 89505...), such as a
3/13/12 mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope has 3 yellow stickers stacked atop each other as well, the farthest
one down indicating a forwarding date of 3/21/12, then next sticker indicating a hold, and the final sticker atop the stack indicating a forwarding date of 3/28/12....).
I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former home law office, and there was difficulties in filing a Change of
Address incident to that given that the Address being changed from was permanently assigned to a business, a motor lodge. Further, some problem cause Bank of America to
temporarily deny my attempts to change my address on file online, and rather require that I mail Bank of America a signed letter requesting as much, all the way to Florida. That
resulted in delays in filing an online Change of Address with the USPS, given the USPS demands the online changes be made with one's own debit card, and that they debit card bare the
same billing address as the location one is filing a change of address from, or else, the USPS, will process such a request, but it will add 7-10 days to tohe processing time. I chose that
option given mailign a letter to Bank of America in Florida would have taken just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and
the supervisor, beyond calling me a "squatter" in advance of the hearing in RJC REv2011-000374 (and refusing to divulge whom had been providing information to them resulting in such
a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my Change of Address to my then PO Box 60952 was being processed, my mail would be
held at the Golden Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the following days, a supervisor named Buck Hyde literally assaulted me,
and he and two other supervisors there, Terri James and "Ms. Passot" informed me they were "Feds" and didn't have to put up with any crap from an attorney related to state laws like
NRS 118A.190, though they couldn't cite specifically to any section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former home law office at 1422 E. 9th
St. #2.
Sincerely,
Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
Sent: Sat 11/03/12 3:14 AM
(cvellis@bhfs.com)
5 attachments
11TR26800 RMC 031412_20120312-1033_01cd003b8f0851d0.wmv (10.3 MB) , 10 25 12 61901 opposition (1)
FILESTAMPED 61901 SCR 111(4) In Re Coughlin.pdf (225.1 KB) , 61901 10 29 12 amendedemmental.pdf (230.2 KB) ,
Patrick King sbn grievance letter of 3 16 12 and Judge Nash Holmes greivance of 3 14 12 rmc 11 TR 26800.pdf (575.8
KB) , exhibit 1 with cover page part 1 of 3 61901 10 25 12 filing.pdf (8.0 MB)
togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us;
patrickk@nvbar.org; skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com;
davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
FW: Mr. King's assertion in his 3/16/12 letter
Tel and Fax: 949 667 7402
Sent: Sat 11/03/12 3:00 AM
(cvellis@bhfs.com)
4 attachments
11cr26405 puentes 041012_20120410-0903_01cd16f8c3aa49b0.mp3 (5.1 MB) , 11CR26405 050812 Loomis_20120508-
1104_01cd2d0a627f5f90.mp3 (15.1 MB) , 5 11 09 wls elcano washoe legal services dismissal letter citing Judge Linda
Gardner's Order sole cause 26405 26800 00696.pdf (902.5 KB) , 5 6 09 email from wls ed elcano 26405 60302 garnder
01955 10896 60302 26800 60317 54844 dd.pdf (15.3 KB)
Dear Judge Hardy, Chairman Susich, Clerk of Court Orduna Hastings, Bar Counsel, and Ms. Tognini, and
Members of the Panel,

It is plain from my interactions with Patrick King that the irony of Richard G. Hill, Esq's allegations of my
"ghostwriting" are richest when considering the apparent "ghost-grievancing" going on here, especially with
respect to the genesis of NG12-0435, the grievance consisting of Family Court Judge Linda Gardner's April
2009 Order sanctioning a domestic violence attorney $1,000, personally, where failed to follow Judge Linda
Gardner's orders to seek to intimidate his battered spouse immigrant client into accepting the marital
settlement agreement offer of one John Springgate, Esq. (a chimera of sorts where Mr. Springgate's client
would agree to be responsilbe for a collection of third party credit card debt for which he was the sole
signatory and for which even under and extremely unlikely "doctrine of the neccessaires, assuing my client
lost on a "waste of marital assets", approach, my client, Ms. Joshi, would be very unlikely to ever face
judgment or execution in connection with such third party credits card debts. I failed to cave to Judge Linda
Gardner's bullying demands, and even where she yelled at me and my client in the impromptu "settlement
conference" she decided to hold 10 minutes before the Trial (Judge Linda Gardner yelled at me to "shut up" in
front of my client, then proceeded to tell Ms. Joshi "don't listen to your attorney!" in an angry, hostile, and
belligerent tone), and instead cited to an ALR article that presents the position I took as the majority viewpoint
in American jurisprudence with respect to the duty of a domestic obligation not being permissibly set off with
a mere debt, particularly a third party unsecured credit card debt, such as those for which Mr. Joshi was the
sole signatory. Apparently Judge Gardner agreed with John Springgate's whining about how he "needed to be
able to know how much to charge for his time" or something along those lines (Mr. Springgate indicated that
Coughlin's failing to immediately accept Springgate's settlement offer was screwing up Springgate's whole
profit margin, and therefore contrary to the orderly administration of justice, or something along those lines, at
which point Springgate moved for sanctions (despite not having served a 21 day safe harbor filing ready NRCP
11 motion), which, in John's words was tantamount to "sending a shot across your bow", a bloodsport sort of
analogy one might expect from a semi-professional fencer like Mr. Springgate. I was fired from Washoe
Legal Services and told by its Executive Director that the decision was based solely on Judge Linda Gardner's
Order....which was odd given she and Master Edmondson and at least one other judge had given Elcano
positive reviews of my work less than two months prior to that. Elcano, though, did, at the time of reporting
those positive reviews mention that he goes "way back" with Linda Gardner, and that "she owes" him because
"he did her a big favor a long time ago", etc., etc.

Anyways, Bar Counsel King has recently indicated that he was completely unaware that Linda Gardner is the
sister of the RMC Judge William Gardner who refused to recuse himself from the criminal trespass conviction
I sustained incident to a custodial arrest at my former home law office, wherein the opposing counsel Richard
G. Hill, Esq., has been caught lying on tape regarding whether any warning was given to me to leave, and
whether the RPD identified themselves as law enforcement and issued a lawful order to leave the premises
prior to the landlord kicking down a door to a "basement" that was, according to Hill's associate, not even a
part of the property (or included in the part of the property contained within any exterior doors to the
premises.

Despite the statements of RMC Judge Gardner in the audio cds that King himself finally admitted to me to
possessing and receiving from RMC Judge Nash Holmes (after several instances of King lying about his
willingness to allowing me to review the materials Judge Nash Holmes and others slipped to the SBN, King
finally was forced to turn over at least a few of those items. Included amongst them were the hearings before
Judge William Gardner on 4/10/12 and 5/8/12 wherein RMC Judge William Gardner admits that his sister is
none other than Family Court Judge Linda Gardner, and that his sister passed him her April 2009 Order
sanctioning Coughlin (which Coughlin filed a Petition for Writ of Mandamus challenging in 54844,):
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746

Washoe Legal Services fired Coughlin, citing Judge Linda Gardner's Order sanctioning Coughlin as the sole
reason for its doign so. Couglin sued WLS for wrongful termination, and Judge Elliot dismissed Coughlin's
lawsuit without reaching the merits of the Complaint, but then decided to sanction Coughlin for his lawsuit
allegedly lacking "merit" anyways...go figure. Judge Elliot also incarcerated Coughlin from April 19th, 2012-
April 26th, 2012 based upon some fraudulent letter by Lake's Crossing, and some Motion for Revocation of
Bail made by DDA Zach Young at a time when NRS 178.405 forbid his making any motions given that all
proceedings must be stayed during the pendency of an Order for Competency Evaluation. Amazingly, in her
3/16/12 letter to the SBN, Judge Nash Holmes is still mentioning how she and the RMC are furiosly trying to
set for Trial the case stemming from teh custodial "jaywalking" arrest of Coughlin on January 12th, 2012
incidnet to the lies by Richard G. Hill, Esq. to the RPD on that date. It is curious that that matter 11 CR
00696 was all of the sudden transferred to Judge Nash Holmes on February 27th, 2012, the same day Judge
Nash Holmes was purportedly made aware of the 2/27/12 Order for Competency Evaluation of Coughlin in
RCR2011-063341 (relative, at the very least, to the communications between Tognini and the WCPD, at the
very least). Additionally, Second Judicial District Chief Appeals Clerk denied Coughlin's 2/27/12 filing of a
Motion for Extension of Time to effectuate service in the wrongful termination lawsuit by Coughlin against
Elcano (whom Judge Linda Garnder "owes a big favor", according to Elcano) in CV11-01955 (before Judge
Elliot).

Further, to the extent Judge Elliot's remanding Coughlin into custody to coerce his consent to divulging
extremely private medical information is somehow a contempt Order, then the "letter" or "evaluation under
seal" of 4/18/12 by Lakes Crossing Dr. Bill Davis and Dr. Sally Farmer must be in the form of an affidavit. It
was not. Further, Coughlin called Dr. Davis from the booking room at the jail and Dr. Davis attempted to
weasel out of the consequences of his professional misconduct, done under color of law, by alleging that he
"didn't write the 4/18/12 letter filed with the Court" but merely signed it and was not responsible for it being
filed with the court. To the extent the assertions in that 4/18/12 letter are outright lies (they are...the letter
indicates Coughlin outright refused to provide basic medical information, which is not true, Coughlin indicated
he would "need to check his records" in response to one initial question, and then mentioned that some
professional, particularly physicians, face an inability to obtain malpractice insurance if word gets out that they
take anti-depressants. Somehow Dr. Davis and Dr. Farmer interpreted such a statement to allow themselves to
file a letter with the Court alleging that Coughlin "threatened one of the evaluators with legal action". No
wonder Lake's Crossing insists on doing a Terry Stop style "pat down" search on each and everyone forced to
go there by the Courts to get a Competency Evaluation (the RJC and WCPD have it set up so that one must
utilize the services of Lake's Crossing for any such evaluation) and maintain a strick ban on any sort of smart
phones or cellular phones within their evaluation rooms (how difficult it would be for Dr. Davis and Dr.
Farmer to lie with seeming impunity, as they did in their 4/18/12 "evaluation" filed with the Court in CR12-
0376, should their subjects be readily able to reveal the dishonesty of these evaluators via some recording
impeachign their credibility. To the extent Judge Elliot found Coughlin in contempt of court (which he
apparently did in response to Coughlin inquiring into the scope and extent of such a Competency Evaluation
rather than submitting to a blank check inquest into his mental health and medical records incident to a
retaliatory Motion for Competency Evaluation on 2/27/12 by a public defender upset that Coughlin had
criticized his failing to show up to a court date even after that attorney, Biray Dogan had filed a Notice of
Appearance and met with the client to discuss the case RCR2012-065630, for over an hour and a half just one
week previous to that missed court appearance, and where DDA Young was clearly retaliating against
Coughlin for Coughlin filing a Motion for Sanctions against Young just days previous to that in a different
case.

Regardkess. Marilyn Tognini is now being listed as a witness Coughlin intends to call at his November 14th,
2012 NNDB hearing at the State Bar of Nevada Offices at 9 am, and any other person whom Judge Nash
Holmes may be referring to in her attached grievance against Coughlin (wherein she manages to allude to
some hearsay about Coughlin living in his car despite the fact that Coughlin was clearly still living at 1422 E.
9th St. at the time Judge Nash Holmes letter to the SBN was written, 3/14/12, even where Judge Nash Holmes
feigns an inability to readily make contact with Coughlin, depsite neither she nor the RMC calling, emailing or
faxing Coughlin, or managing to mail the 2/28/12 Order to the address all other RMC Departments then had
for Coughlin. Regardless, that 3/14/12 grievance goes on to demonstrate Judge Nash Holmes profound lack of
respect for or knowledge of the dictates of NRS 178.405, or the legal principles, in general, related to
refraining from proceeding with prosecutions where the competency of the accused is in doubt in the mind of
the trier of fact. Further, the SBN's Bar Counsel Patrick King (whom, again, managed to just in the last couple
weeks indicate that he was unaware that Judge William Gardner and Judge Linda Gardner are brother and
sister, or even related, despite King receiving from the RMC's Judge Nash Holmes a box of materials that
included multiple hearings in the criminal trespass proseuction of Coughlin that Judge William Gardner (then
RMC Administrative Judge, whom admitted to "at least one meeting" wherein he and the other RMC Judges
discussed Coughlin, along with Chief Marshal Roper, only for Judge Gardner to then attempt to say with a
straight face that he "was not sure whether he was" aware of this or that, or had any knowledge of the
grievance Judge Nash Holmes filed against Coughlin with the SBN (despite that 3/14/12 letter to the SBN by
Judge Nash Holmes expressly purporting to be written on behalf of herself and ALL the other RMC Judges,
whose "full cooperation" she assures she can deliver to the SBN in seeking to discredit Coughlin and in so
doing assist the City of Reno in addressing the multiple wrongful arrests of Coughlin in the preceding months.

Regardless, the communications between the Washoe County Public Defender and the RMC, including Ms.
Tongini and Judge Nash Holmes, and what exactly Judge William Gardner was made aware of, and what he
passed from his sister, Judge Linda Gardner, on to Judge Nash Holmes, and what Judge Nash Holmes passed
onto Bar Counsel King is now of material relevance, and brings into play the issue of the level of candor with
opposing counsel King exhibits in his 4/19/12 correspondenc with Coughlin when he purports to only have
recieved Judge Linda Gardner's April 2009 Order for Sanctions on 3/15/12 (and that "5" in the "15" looks
shaky, Pat), wherin King wrote: "It was sent to me by the clerk of the court at my request, pursuant to my
investigation." Which Clerk of Court, Mr. King? Clerk of Court Orduna Hastings? Then there is Judge Elliot dismissing
Coughlin's lawsuit against Washoe Legal Services, then incarcerating Coughlin between April 19th and April 26th, 2012 (during
which time Richard G. Hill and Casey Baker filed their Motion for Attorney's Fees of $40,050 incident to the appeal of a
summary eviction in CV11-03628, which Coughlin's former co-worker Judge Flanagan awarded Baker and Hill, after Judge
Flanagan refused to recuse himself even where Coughlin pointed out the necessity of his so doing. Then Judge Elliot denied
Coughlin's appeal of RMC Judge Howard's conviction of Coughlin for "petty larceny of a candy bar and some cough drops" in 11
CR 22176 (the sole basis for the current temporary suspension of Coughlin's law license, incident to a trial where the Reno City
Attorney Pamela Roberts offered perjured testimony from Wal-Mart's Thomas Frontino and RSIC Officer Kameron Crawford
that Crawford was justified in conducting a custodial arrest and search incident thereto for an alleged misdemeanor offense,
occurring after 7 pm, outside the presence of the officer, in light of Coughlin failure to provide the officer his driver's license.
City Attorney Roberts had been provided by the RSIC a video tape showing Coughlin providing Crawford his driver's license,
and Coughlin's booking inventory sheet lists his drivers license (despite Officer Crawfords sworn testimony that Coughlin did
not have one on his person at the time, even where Wal-Mart's video shows Crawford copying down Coughlin's information
off the driver's license Coughlin provided to Offier Crawford, and where Wal-Mart admits that it did not effect a citizen's arrest
of Coughlin, and therefore NRS 178.1255 required an application of the exclusionary rule to any partial package of "cough
drops" found in Coughlin's pockets upon a search incident to arrest (and even that is not all that necessary to prove Coughlin's
innocence given that the RSIC Officer and Wal-Mart's Frontino testified incorrectly that the receipt for the $83.82 worth of
groceries that Coughlin selected and paid after his allegely consuming a "candy bar and some cough drops" while shopping,
did, in fact have an entry for that exact UPC of Duract Cough Melts ("cough drops"), contrary to the sworn testimony of both
Wal-Mart's Frontino and the RSIC's Crawford). But none ofthat mattered much to Judge Elliot, as he denied Coughlin's appeal
based on some civil statute related to a litigant being required to pay for a transcript up front, even where, in criminal
matters, the RMC is required to transmit the record on appeal and order the production fo the transcripts within 10 days of
the filing of a Notice of Appeal, pursuant to NRS 189.010-030, regardless of whether the criminal defendant pays for the
transcript up front. See CR12-1018 for other instances of teh RMC and its "exclusive trancriptionist" Pam Longoni perpetuating
a fraud on the public (the RMC indicates Longoni is the only transcriptionist they will allow, and demand that she be paid up
front....Longoni hung up on Coughlin multiple times and otherwise prejudiced Coughlin's appeal by refusing to prepare his
transcript even where Coughlin would pay up front for the transcripts, in CR11-2064. Judge Elliot then dismissed Coughlin's
appeal of the criminal trespass conviction by Judge William Gardner in CR12-1262 where the RMC and Lisa Wagner failed to
file the 6/28/12 Notice of Appeal Coughlin has confirmation that the RMC and City Attorney Hazlett-Stevens recieved, though
both maintain a dubious position counter to such irrefutable proof.

Additionally, one of the aspects of Richard G. Hill's grievance with the SBN against Coughlin, memorialized in NG12-0204 (one of the three greivances forming Mr. Kings SCR 105 SBN
v. Couglin Petition) alleges some sort of "ghostwriting" on Coughlin's part for a former client of Coughlin's John Gessin. This is plainly not true, though some confusion may have
arisen given the fact that at about the time Gessin and Couglin parted ways, Gessin apparently paid for and signed up for an E-flex account (apparently non-attorneys may do so?).
Hill's allegations respecting Gessin are baseless and ironic given the fact that Coughlin filed Notice of Appearance as Gessin's attorney in various matters, and even sent Gessin a
correspondence wherein he warns Gessin that he will not tolerate any appearance of ghostwriting (what can an attorney do when a client pays him money, drafts of NRCP 60(b)
Motions are worked up extensively over a period of time, then the client decides he wants to part ways, and takes with him those drafts? File a Notice of Appearance so there is at
least some paper trial?). It would be helpful to addressing Hill's allegations vis a vis "ghostwriting" for Gessin if the Second Judicial District Court would present or allow for
inspection anything it may have tending to shed light on such allegations.

Here is one correspondence Coughlin sent then client John Gessin refuting the allegations that Hill made to the SBN in his attached 1/14/12 grievance against Coughlin (attached to
the SBN King's 2/14/12 letter to Coughlin):

"Subject: NOTICES OF APPEARANCES

John, Let me know whats going on, i got a new temporary address and phone number. theres is some ghostwriting taboos, so...if
you want me to withdraw thats fine, whatever, its all good
Zach Coughlin, Esq."

Further, in her 10 4 12 order in 11 TR 26800, Judge Nash Holmes continues to refuse to allow Coughlin to appeal a final appealable order convicting him of "summary
criminal contempt", even though Judge Holme's Order specifically relies upon alleged conduct, and an essential element thereof, not occuring in here "immediate
presence", and where there is no Affidavit by her Marshal (Judge Nash Holmes states on the record in 11 TR 26800 that an RMC Marshal (apparently Marshal Harley)
followed Coughlin into the restroom during a break in the Trial Judge Nash Holmes begrudingly granted Coughlin (though she ordered him to leave his yellow note pad in
the courtroom?) whereupon Marshal Harley played Peeping Tom through a bathroom stall and alleges to have spied Coughlin "dissassembling a smartphone", which
Judge Nash Holmes took as an opportunity to find "by clear and convicing" evidence that Coughlin "lied" "under oath" in response to her impromptu, sua sponte,
interrogation of Coughlin immediately following that bathroom break (and soon after RMC Marshal Harley (who violated the "courthouse sanctuary" dictates against
serving Coughlin Judge Flanagan's Order to Show Cause for a 3/23/12 Hearing on Richard G. Hill's Motion in the eviction appeal in CV11-03628 while Coughlin and City
Attorney Ormaas where haggling over plea details immediately prior to the traffic citation trial in 11 TR 26800 (incident to Coughlin being told to leave Hill's office upon
arriving their to retrieve his keys, wallet, and driver's license, and client's file upon being released from three days in jail incident to a criminal trespass complaint Hill
signed against Coughlin, which the RPD committed misconduct in subjecting Coughlin to a custodial arrest for, especially in light of the video taped admission of Sargent
Lopez and the matrials presented in Coughlin's recent filings in 61901 and 11 CR 26405). RMC Marshal Harley took it upon himself to aid WCSO Deputy Machen in filing a
false Affidavit of Service in Harley's handing Coughlin, on behalf of Hill, a document Hill paid the WCSO to serve on Coughlin (an how unseemly and bullying to attempt
to serve it at the traffic citation trial, appearance of impartiality and impropriety be damned, Caplow, regardless.). And City Attorney Ormaas may have been whispering
in Harley's ears given her apparent concern or her responses to Coughlin asking her, shortly before the trial commenced, if she planned to follow up on or in any way
document the admissions to accepting bribes from Richard Hill made by the officer effecting the custodial criminal trespass arrest, RPD Officer Chris Carter, Jr. (whom will
apparently attest that he was jesting, though its not clear what is funny about arresting an attorney for trespass at his former home law office where the WCSO admits it
lied in filing an Affidavit of Service attesting to having "personally served" Coughlin such an Eviction Order.

I appreciate this opportunity to clarify my subpoena.

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Subject: RE: Mr. King's assertion in his 3/16/12 letter
Date: Thu, 19 Apr 2012 21:29:10 +0000
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,


contempt of Court. However, it must concern you that you were found in contempt of Court by more than one Judge in two different trials. You wanted to know how I
learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at my request, pursuant to my
investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were held in contempt of Court. You may be
well served to explain what remedial measures you are taking to make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can
suggest you cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to
the office of Bar Counsel.

Patrick King
Sent: Monday, April 16, 2012 5:41 PM
To: Patrick King; David Clark; Glenn Machado
Subject: Mr. King's assertion in his 3/16/12 letter

Dear Bar Counsel,
One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months worth of my portion of our rent from me (our arrangement
was I would give her the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed a great deal and paid lots of her tuition, and she broke up
with me and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her graduation from UNR. I did not know about her stealing my portion of the
rent or failing to pay her own portion until August 2011, as the landlord was on an extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the
eviction in RJC REV2011-001708 from my former home law office ensued within less than a week of his communicating this deficiency. He and his counsel, Richard G. Hill, Esq. and
Casey Baker pursued a No Cause Notice of Eviction because there was a wealth of support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in
addition to personal property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such, indicated it would "be the path of least
resistance" to simply seek a No Cause Eviction. The only problem in their attempt to circumvent the law (even though they still threatened to seek back rent in another forum after
getting their No Cause, summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a commercial law office there, and NRS 40.253 makes
impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice, which, of course Baker and Hill chose not to do....and it was about the time that
Hill started to understand that his "wrong site surgery" for his neurosurgeon landlord client might subject Hill and his firm to some malpractice liability, that Hill started writing letters to
bar counsel attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable when Gessin was Hill's client and Hill was milking over $20K from Gessin) for
"ghostwriting" even though I was listed as Attorney of Record on several different Gessin cases, etc., etc.
Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has filed a grievance or complaint and also with respect to any criminal
charge against me, including that which resulted in a conviction in 11 CR 22176, which, I think will ultimately reveal was replete with prosecutorial misconduct, lying by the Wal-Mart loss
prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other errors by Judge Howard.
I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on that 3/16/12 letter from Assistant Bar Counsel King
RE: SBN still has not provided Coughlin access to the materials he is entitled to to
prepare for 11/14/12 Hearing
(please see attached picture of the letter and envelope) indicates it was mailed 3/16/12, and the letter indicates it was not faxed to me (despite my numerous written requests that such
a practice be done in consideration of the problems I have encountered in the USPS violations of the Federal Torts Claims Act and incident to the domestic violence I have been subjected
to, in FV12-00188 and FV12-00187, which included interference with my mail).
I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden Valley USPS Station and the Downtown Reno Post Office in
and attempt to make every diligent effort to receive my mail. I have been threatened by and lied to by the supervisors of the Golden Valley Station USPS Station. I had a hearing
related to a landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12 letter that I was living in my car at that time rather suspect, given my home
law office was located at the property which was the subject of that hearing and which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no attribution for such
hearsay in her extremely reckless assertion) in RJC REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked even a law license to litigate on her behalf, or
on that of the HOA which Kern has now decided to appear for, despite her being listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in
RJC Rev2012-000374.
My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to respond to it. Additionally, I note that Mr. King, in that
3/16/12 letter, writes "I am enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order from District court....I will make available for your
review and inspection the supporting documents and audio recordings."
However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting documents and audio recordings". I wish to have a copy of all
such "supporting documents and audio recordings", and failing a copy being provided, I wish to be allowed the access to conduct a "review and inspection" of "the supporting documents
and audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such access. In addition, Mr. King now informs me that he has opened a grievance
on behalf of Judge Linda M. Gardner, incident to a Order for Sanctions she entered in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or
otherwise provided it to Bar Counsel as a Complaint or Grievance or otherwise. I believe someone necessarily must file the complaint or grievance. Further, I believe I am entitled to
know whom that is, and when such was filed. Additionally, Mr. King has, so failed to provide a copy or any access to any purported complaint by the City of Reno Marshal's division
incident to my accessing justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord tenant hearing set for March 15th, 2012, and further, in
response to hostility, retaliation, lies, and threats made by the USPS Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12
letter to me, was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other, on it by the USPS), however, some mail, like several Orders of
the Reno Municipal Court, were not forwarded on to me, but rather, apparently, returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for Judge
Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what Judge Nash Holmes is referring to when she describes difficulty contacting me (the attempts by Judge Nash Holmes
and the RMC apparently did not included either email or fax or a phone call, however....).
There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the RMC dated 3/14/12) and which mailings it ultimately
forwarded on to me (at my then PO BOX 60952, please note, I have a new PO BOX, that I intened to keep for a substantial period of time, it is PO BOX 3961, Reno 89505...), such as a
3/13/12 mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope has 3 yellow stickers stacked atop each other as well, the farthest
one down indicating a forwarding date of 3/21/12, then next sticker indicating a hold, and the final sticker atop the stack indicating a forwarding date of 3/28/12....).
I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former home law office, and there was difficulties in filing a Change of
Address incident to that given that the Address being changed from was permanently assigned to a business, a motor lodge. Further, some problem cause Bank of America to
temporarily deny my attempts to change my address on file online, and rather require that I mail Bank of America a signed letter requesting as much, all the way to Florida. That
resulted in delays in filing an online Change of Address with the USPS, given the USPS demands the online changes be made with one's own debit card, and that they debit card bare the
same billing address as the location one is filing a change of address from, or else, the USPS, will process such a request, but it will add 7-10 days to tohe processing time. I chose that
option given mailign a letter to Bank of America in Florida would have taken just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and
the supervisor, beyond calling me a "squatter" in advance of the hearing in RJC REv2011-000374 (and refusing to divulge whom had been providing information to them resulting in such
a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my Change of Address to my then PO Box 60952 was being processed, my mail would be
held at the Golden Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the following days, a supervisor named Buck Hyde literally assaulted me,
and he and two other supervisors there, Terri James and "Ms. Passot" informed me they were "Feds" and didn't have to put up with any crap from an attorney related to state laws like
NRS 118A.190, though they couldn't cite specifically to any section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former home law office at 1422 E. 9th
St. #2.
Sincerely,
Sent: Fri 11/02/12 11:45 PM
To: patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org
(complaints@nvbar.org)
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org;
je@eloreno.com; cvellis@bhfs.com
Subject: SBN still has not provided Coughlin access to the materials he is entitled to to prepare for 11/14/12 Hearing
Date: Fri, 2 Nov 2012 22:36:46 -0700
Dear Panel Members and Bar Counsel,

I called Mr. King (he directed me to call Panel Chair Echeverria) today to seek clarification regarding an
earlier approval he relayed to me from Chief Bar Counsel David Clark, wherein Mr. Clark advised me that I,
even though I am a temporarily suspended attorney, have been given permission by the Office of Bar Counsel
to issue subpoenas in connection with this disciplinary matter (ng12-0204, ng12-0434, ng12-0435...odd, can't
recall a single other "case" in all my legal research that had three case numbers....especially where an Order
Denying a Motion to Bifurcate was issued, even before the 5 days for me to file a Reply to the Opposition
(given NRCP is expressly applicable to these matters under the SCR's)...Am I going to find out that my filings
are "too long" under a view that assumes this is "one case" even though there are "three grievance case
numbers" in the caption, and where each "grievance" is fairly rambling? And where the SBN's King purports
this hearing to involve that which the N. S. Ct. Ordered to occur in response to its temporary suspension Order
incident to the SCR 111 Petition for the petty larceny of a "candy bar and some cough drops" (ie, the Court
order that matter, 60838, referred to the Board for a "hearing at which the sole issue to be determined" would
be my punishment for that which was noticed and adjudicated in the 60838 SCR 111 Petition. I believe you
are all now violating Nevada Law in persisting in your denial of my right to such a hearing wherein the "sole
issue" is such, but rather trying to jam me up with this "combo hearing" that seeks to encompass a great deal of
disparate claims (many of which are pending criminal charges, and therefore, entirely outside of your
jursisiction at this point, and your deigning to address them interferes with the orderly administration of justice
in those pending criminal prosecutions, as evinced by Judge Sferrazza's refusal to testify at the November
14th, 2012 Hearing...which is problematic considering Judge Sferrazza presided over the civil summary
eviction matter in RJC Rev2011-001708 that is intimately connect to ALL THREE of the grievances included
in King's reckless, negligent, compromised SCR 105 "Complaint". For instance:
NG12-0204: Richard G. Hill's January 14th, 2012 letter to Bar Counsel King (whom he had just worked on the
Milsner v. Carstarphen matter with (http://law.justia.com/cases/nevada/supreme-court/2012/51631.html)

Today, King admitted to being unaware of who Casey Baker, Esq. is. King also admitted to not having read
any of my filings in any of these connected matters, only to then suggest an analogy along the lines of if a
woman is raped a lot, she is probably a whore and deserves it or wanted it, given the sheer mathematical
improbability of any one woman getting raped over and over, and how King just doesn't get paid enough to
stick his nose into some gangbang, what with the chances of getting himself involved in doing the right thing
where it is just so much easier to sit back and pretend that the Claiborne decision (explicated extensively in my
attached August 13th, 2012 Petition) does not permit Bar Counsel to just throw its hands up and suggest that a
Muni Court conviction (even, in RMC 11 CR 26405, presided over by the brother of the judge whose
sanctions Orders is before you in NG12-0435, and where the brother refused to recuse himself from that
criminal trespass conviction incident to the lies and or attempts to mislead a tribunal by Casey Baker, Esq. and
Richard G. Hill at the June 18th, 2012 criminal trespass trial incident to the civil eviction from Coughlin's
former law office in RJC Rev2011-001708. Asst. Bar Counsel King also admitted that he had failed to even
view the video taped admission by RPD Sargent Lopez that she, Hill, Merliss, and RPD Officer Carter lied in
order to effectuate the wrongful arrest leading to Couglin's conviction by the brother of the sister whose 2009
sanctions Order against Coughlin only became a grievance on March 14th, 2012 (apparently King adopts
Ching as to whom can be an SCR 105 complainant, and therefore within the statute of limitations, when it
comes to Gardner's April 2009 Order, but not when it involves misconduct by a Chairman of the Character
and Fitness Committee of the SBN, Spearmint Rhino owner Kevin Kelly, Esq., whom also owns a Las Vegas
Strip Club that gives cabbies $10 million dollars a year to funnel tourists to it's doors from the airport, and the
misconduct of Peter Christiansen, Jr. and Mike Sanft, and others incident to Coughlin's application for
admission in Nevada, including that of then Director of Admissions Patrice Eichmann, made all the more
feasible by the conduct of Mike Smiley Rowe, Esq. and the fraudulent conduct of Mark Tratos and Mary
LaFrance) when RMC Judge Nash Holmes (in response to prompting by the SBN) passed that three year old
Order (attorneys get sanctioned all the time, such orders do not become grievances as a matter of course, and
the SBN has admitted it keeps no central record of any such grievances) on to Bar Counsel after receiving it
from her co-RMC Judge, and the brother of the family court judge issuing the sanction order...at right about
the time that Coughlin filed that March 7th, 2012 Notice of Appeal (and there is plenty of case law to establish
that a "summary criminal conviction" is a final appealable Order, and the RMC is fraudulently conspiring with
transcriptionist Pam Longoni to violate NRS 189.010-030 by demanding payment up front for such transcripts
by indigent criminal defendants, and Longoni and the RMC's fraud in that regard resulted in Judge Elliot
denying Coughlin's appeal of the Wal-Mart candy bar petty larceny conviction in cr11-2064, wherein Judge
Elliot actually cites to a civil statute related to transcript preparation to justify the RMC's fraud, seen
elsewhere in CR12-1018, further the RMC "lost' Coughlin's Notice of Appeal of the 11 cr26405 criminal
trespass conviction appeal (despite Coughlin having digitial confirmation of the receipt of that fax by the
RMC, and where RMC Rules allows service thereof via that means upon both the Court and the City Attorney
(and Hazlett-Stevens lied about that as well, in addition to the lies he told respecting whether the City Attorney
had received anything from the RSIC following Coughlin's Wal-Mart arrest) in the "summary criminal
contempt" Order stemming from the traffic citation (California roll) trial connected to Coughlin reporting the
admissions of bribery by Richard Hill (RPD Officer Carter stated as much during the November 13th, 2011
criminal trespass arrest, now part of the SCR 105 Complaint, incorporated by reference, one must suppose, by
Hill's NG12-0204 grievance) to the Sargent who retaliated against Coughlin by issuing three traffic citations,
for Coughlin so reporting such admissions by the arresting officer in the trespass matter to the Sargent who
issued the traffic citations to Coughlin incident to Coughlin going to Hill's office to retrieve his keys, wallet,
client's files, and goverment issued identification after being release from 3 days in jail incident to the wrongful
criminal trespass arrest.

Mr. King is beyond incorrect is stating that he will be able to simply point to a criminal conviction and declare
that no inquiry into the legitimacy of that conviction may be made. There is a wealth of case law and
precedent that holds otherwise, and Mr. King has previously been made aware of that. This is true especially
where the convictions at issue completely fail to evince even baseline level of regard for traditional notions of
due process. Simply put, some might say the members of this Panel ought think rather hard before tying their
reputations to the mast that is the extremely low bar required to get a conviction in the Reno Municipal Court
these days....and further, the Panel would be well advised to avoid letting Mr. King lead it down that primrose
path wherein one believes they will be entitled to merely accept a municipal court conviction as conclusive
proof of misconduct or otherwise rule irrelevant any inquiry into the circumstances attendant to such a
matter. This will be particularly true where Mr. King seeks to, in his SCR 105 Complaint, allege matters not
even charged in that Municipal Court criminal trespass proseuction. How Mr. King will be able to allege his
RPC 3.8 violating allegations respecting "breaking and entering" or "broken locks" are relevant or admissible
where Coughlin's dissection of the illegitimacy of the Walmart candy bar petty larceny conviction (supposedly
part of the SCR 105 Compalint....and mentioned in Hill's NG12-0204 grievance...which brings to mind the
question...what of matters not mentioned in any of the three grievance numbers? How are they eligible for
inclusion in some SCR 105 "Complaint' that lacks a unique case number of its own?) Regardless, it is
November 2nd, 2012 and my defense has been irreversibly prejudiced by the refusal of Bar Counsel to allow
me to access the materials at the SBN that are my right to under the SCR, thus bringing the legitimacy of the
entire November 14th, 2012 hearing into doubt, to which any argument that I should be made to fit the bill for
Bar Counsel's bungling and fraudulent failure to follow the rules applicable to this matter, in addition to its
own written attestations, is entirely unsupportable.

Regardless, Richard G. Hill, Esq.'s hench man, Casey Baker, Esq., now that the heat is on and he and Hill's
avarice driven misdeeds are finally facing the oversight they deserve, has now suddenly fled back to
Kentucky:
http://www.nvbar.org/lawyer-detail/11271

It was Baker whom Hill used to file the November 21st, 2011 and January 20th, 2012 filings in RJC Rev2011-001708 and the appeal thereof in CV11-03628 to make the allegatons that
Hill himself knew unwise to make in his own regard within a sworn Declaration...So, despite Hill, not Baker, having the eye witness knowledge of such events (like whether the RPD
identified themselves as law enforcement and issued to Coughlin a lawful warning to leave at the risk of a criminal trespass citation or arrest prior to the landlord kicking down the
door to a quasi "basement" under the property that Baker's own testimony at the June 18th, 2012 trespass trail admits lacked any sort of exterior lock, and thus would require no
"breaking of any sort" of the type both Susich and King suddenly felt the need to allege when considering how terribly compromised their 60975 Petiton and the instant SCR 105
"combo-grievances" (kind of like a "due process value meal" that Pat King is serving up, and asking this Board to co-sign...which, apparently the Chairman finds fitting....what's next,
are you going to have lawyers dress up in Hot Dog on a Stick employee uniforms (you know, rainbow colors, the spinning thing atop the hat, etc.) too? Is that how little the property
right of a law license (case law declares it as much under the Fourteenth Amendment, and any willful deprivation thereof by this Board, including a deprivation of the due process
required to impinge thereupon, can subject the members of this Board the 42 USC Sec. 1983 liability, especially where, as her, what appears to be a coordinated effort to obstruct
justice and proceed impermissibly under color of law for the self interested aims of those leveraging such positions is apparent. RICO.

I am writing to request confirmation of what I believe Mr. Clark has previously rule, ie, that I, as an indigent respondent herein, am not required to pay witnesses any sort of "witness
fee" in issuing and or serving subpoenas and subpoens duces tecums upon them in connection with the November 14th, 2011 Hearing in this matter. I feel Hill's then associate Casey
Baker, Esq's testimony will be particular necessary to this hearing (especially where Hill admits himself that he was not present at the purported November 1st, 2011 "lockout" in the
eviction matter (and the service of an receipt by the WCSO with respect to any such lockout Order is of material relevance, as NRS 40.253 requires such an Order be carried out
"within 24 hours of receipt" thereof...and Baker's testimony at the June 18th, 2012 criminal trespass trial, in combination with previous statements by the Washoe County Sheriff's Office
(and please add these individuals and matters to my designation fo witnesses and summary of evidence to be presented) Supervisor Liz Stuchell, Roxy Silve, Deputy Machen, and
administrators, supervisors, and clerks at the Reno Justice Court (RJC) add up to the fact that it was Hill, Baker, and the WCSO, and RPD that were trespassing, not Coughlin, at
Coughlin's former home law office. Attached it the video taped admission by RPD Sargent Lopez respecting the lies by her, RPD Officer Carter, Hill, Merliss, and Baker leading to
Coughlin's arrest and conviction for criminal trespass. Keith Loomis will need to answer for his failure to fulfill the Sixth Amendment in that regard, in addition to the content of the
unapproved and impermissible "meeting" with RMC Judge Gardner and City of Reno Prosecutor wherein, upon information and belief, an "approach" to handling the criminal
trespass trial of Coughlin was "developed" shortly before the April 10th, 2012 Trial date in that criminal trespass matter (a Trial date which violated Nevada law, anyways, in that it was
set and held during the pendency of an Order for Competency Evaluation of Coughlin in violation of NRS 178.405 and NRS 5.010). Any trier of fact that wishes to attempt to pull the
wool over Coughlin's eyes, make incongruous and patently compromised, often sua sponte relevancy rulings, or otherwise cook up a due process value meal may wish to ask RMC
Judge Gardner how the recent filings by Coughlin in 61901 and the RMC 11 CR 26405 are tasting right about now. Or get Judge Howard's inpute with respect to the analysis of his
work in 60838. And Judge Nash Holmes may be able to provide some insight as to how that approach served her, particularly where her "criminal summary contempt" order was
made during the pendency of an Order for Competency Evaluation, and cites to alleged conduct committed outside her immediate presence (and that's the thing about "summary
adjudications"....the are so arbitary and devoid of due process that the requirements attendant thereto must be stricly adhered to....so when Judge Nash Holmes in here Orders in 11
TR 26800 of 2/28/12 and 3/12 3/13, and 3/13/12 refers to some RMC Marshal allegedly peering, Peeping Tom style, through a bathroom stall wherein Coughlin was during a
restroom break within that trial, her Order fails to adhere to the dictate that each element of any conduct she deigns to summarily rule upon be committed in her "immediate
presence"...otherwise, someone would have to sign an Affidavit like a grown up, and Coughlin would be entitled to a hearing, and likely appointed counsel under the Sixth Amendment
before some Bar Counsel like King could attempt to prop up any such "conviction" in an attempt to lend it an air of respectiability, especially where that Marshal Harley (whom King
conveniently has failed to subpoena) had his own self interested reasons for seeking to discredit Coughlin (RMC Marshal Harley violated the "courthouse sanctuary" rule and
contributed to an appearance of impropriety where he served Coughlin an Order to Show Cause incident to one of Hill's fraudulent Motions seeking to abuse process in hopes of
remaining competitive with an actual attorney like Coughlin (rather than a known hack like HIll whom inherited a law practice from his father and who legion of local attorneys accuse
of unneccesarily running up fees on his clients by purposefully overcomplicating litigations and engendering an adversarial stance amongst litigants designed to line Hill's pockets,
and those of, apparently, even his legal assistans, whom drive $130,000 Mercedes v12 SL-600 sport coupe convertibles to crack inspections of law offices incident to impermissible
summary evictions of commercial tenants where Hill chose to proceed under a No Cause Eviction Notice (along with Baker) rather than a Non Payment Notice, and therein committed
a "wrong site surgery" (in a litigation sense, to borrow some of the parlance of the landlord, Dr. Merliss's field, wherein he is a Neurosurgeon/Neurologist in Chico, CA, apparently
armed with enough money to choose to run up $60,000, as of April 2012 in fees ot HIll and Baker in these matters rather than settle with Coughlin for the $1,500 Coughlin offered
him).

Please add to the witness list all the individuals mentioned in the various filings I have provided you, including, but not limited to RPD Officers Duralde, Rosa, Alaksa, Weaver,
Look, Travis Warren, and Leedy, RPD Sargent Tarter,Lopez, Sifre, Oliver Miller, Dye, and Bradshaw, Hill's Associate Casey Baker, Sheri Hill, and to be deterimined members of HIll's
staff (particulary those with knowledge of any matters connected to the receipt of either of the Eviction Orders by the WCSO in the eviction matter, WCPD Jim Leslie, Biray Dogan, Joe
Goodnight, Walmart Thomas Frontino and ASM John Ellis, and a yet to be determined AP Associate whom, along with Ellis, made express threats to retaliate against Coughlin with
abuse of process similar to the petty larceny candy bar conviction in 60838 that currently forms the only basis for the suspension of Coughlin's law license and for which this Panel and
the SBN are violating Nevada law in persisting in refusing to follow the dicates of both the Supreme Court Rules of Nevada and the Court's June 7th, 2012 Order in 60838, but rather,
like Clerk/"reluctant" Investigator Peters, are allowing themselves to be led down that primrose path that Pat King finds to pleasurable to take the unwitting along in his social climbing
and life of ease and comfort, devoid of honor or intergrity, approach to life...Also, to the extent then Panel considers a pending criminal prosecution up for inquiry in a disciplinary
proceeding, included in potential witness call may call are Nicole Watson, Lucy Byington, Nate Zarate, Cory Goble, the individual whose phone number is 7753786673, Colton
Templeton, Robert Dawson, Nick Duralde, Ron Rosa, Thomas Alaksa, Savannah Montgomery, Linda Gray, Kelly Odom, Kariann Beechlker, RPD Officer Schaur and any others present
at arrest of 1/14/12 for "misuse of emergency communications", and of the 5-6 officers whom, along with RPD Duralde pulled Coughlin over upon his release from jail on 1/13/12 for
the 1/12/12 "jaywalking" arrest made upon the fraudulent assertions of Richard HIll, RJC Judge Jack Schroeder (whom evicted Coughlin from Park Terrace and granted Hill the
protection order incident to the jaywalking arrest and who yelled "do you want to go to jail" at Coughlin at the extension hearing when Coughlin broached the topic of Hill's abuse of
process, and whom wrongfully granted the 6/27/12 Eviction Order in RJC Rev2012-001048 despite the deficient 5 day notice listing the wrong court to file a tenan'ts affidavit (a
requirement under NRS 40.253, and despite Coughlin's numerous calls and 6/26/12 email to the RJC, SJC, RPD and WCSO, also Jeff Nichols and Peter Eastman and Paul Freitag, Esq.
(involved in SBN King's impermissilbe disclosures and slanderous statements concerning Coughlin and the NVB (which King also made to his boss in front of Coughlin, David Clark,
and which have proven to be baseless, despite King ticking such off amongst the top 2 reasons for the SCR 105 Complaint he alleged he would hurriedly throw together upon
Coughlin serving King, the SBN, Clark and Peters the August 13th, 2012 filing in 60838 and 61426, now before the N. S. Ct.). Also, Richard Cornell, Tom Hall, Geof Giles, and Michael
Lehrners, Judge Joe Van Walraven and others all whom have indicated, to one degree or another, that Hill's conduct incident to this eviction matter and concomitant appeal is
deplorable and entirely consistent with the way Hill has comported himself throughout his 33 year career, which began with is inheriting a large scale law practice from his father, and
continued on with Hill effecting the manner of a 10 year old boy entrusted with flying a 747 full of people, to this day. Add to the witness List Paul Elcano of WLS, Judge Steven Elliot,
Judge Patrick Flanagan, Hale Lane/Holland and Hart's Anthony Hall and Tim Lukas, Richard Elmore, Judge Scott Pearson, Judge Peter J. Sferrazza (though he indicated on 10/22/12
that he declined the SBN's request that he testify, citing his sitting on the pending criminal prosecution in RCR2011-063341), the RJC's Bonnie Cooper and "Nevi", Chief Bailiff Michael
Sexton, RMC Chief Marshal Roper and Marshal Deighton, Marshal Thompson, Marshal Coppa, WCDC Van der Wal, Beatson, Hoekstra, Cheung, unnamed deputies. Further, please
add Western Nevada Management's Sue King, Jared Scalise, and Park Terrace Townhomes Association attorney Gayle Kern, Esq., Roberto Puentes, Lew Taitel, the RMC's Matthew Fisk
and Cassandra Jackson, Donna Ballard, Judge Howards past legal assistant, Judge Nash Holmess legal and administrative assistant, Martin Crowley or Martin Weiner or whichever
attorney is was Judge Nash Holmes was sued for wiretapping in the past, the RMC counter clerk "Daniel" and "Thom", WDC Chief Appeals Clerk Matheus, Joey Orduna Hastings, Chief
Judge David Hardy, Justice Hardesty (whom was one of only three Justices signing the June 7th, 2012 temporary suspension Order, but whom recused himself from 60302 and 60317,
the wrongful termination suit against Washoe Legal Services (see attached letters from WLS's Executive Director citing Judge Linda Gardner's April 2009 Order sanctioning Coughlin as
the "sole reason" for Coughlin's firing (her brother, RMC Judge William Gardner refused to recuse himself from the criminal trespass conviction mentioned in in King's SCR 105
Complaint, and King admitted two weeks ago that he was unaware that the two Judge Gardners were brother and sister or related whatsoever, or that Judge Nash Holmes was a
prison warden or something similar for ten years, and a lifelong prosecutor besides that (in addition to all other RMC Judges and all RMC court appointed defenders).

Also, I never received any Notice of Intent to Take Default from the SBN, and herein lodge my objection to any Order by this Panel that cites thereto. Additionally, SBN's Peters has
indicated no other respondents have ever been made to pay witness subpoena fees, and further Peters and the SBN have repeatedly failed to adhere to agreements they have made
with Coughlin (including the failure of the SBN to resend a certified mail copy of the SCR 105 Complaint incident to the agreement between Peters and Coughlin on or about
September 11th, 2012.

Sincerely,

Sincerley,
skent@skentlaw.com, mike@tahoelawyer.com, nevtelassn@sbcglobal.net, patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
Close
Subject: RE: Records
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Print
Your Online Police Report T11005956 Has Been Submitted
From:
NvRenoPd@coplogic.com
Sent: Wed 9/07/11 9:36 PM
****DO NOT RESPOND TO THIS E-MAIL****
Your online report has been successfully received and the
temporary report number is T11005956.
You will be notified via email of any problems with your
report. Once your report is approved, it will be issued
a case number and you will receive a PDF copy as an attachment
in your email within approximately five business days.
Thank you for using our online reporting system and please
contact us with any suggestions you have for improving our
system.
Online Officer
Reno Police Department
Your Online Police Report T11005956 Has Been Rejected
From:
Sent: Wed 9/07/11 10:51 PM
We're sorry the following problem was found during review
of your submitted report T11005956:
THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT
WILL BE ADDRESSED.
Thank you,
Officer WOZNIAK,
From:
Sent: Sun 1/08/12 1:35 AM
tracking number is T12000219.
system.
Online Officer
From:
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From:
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To: ZACHCOUGHLIN@HOTMAIL.COM
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From:
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From:
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Your Online Police Report 120100300 Has Been Approved
From:
Sent: Wed 1/11/12 3:09 PM
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Your report has been approved report and the permanent number of the case is
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the delicate information in his report has been replaced for *** to support isolation in this email.
Thank you for using our online reporting system and please contact us with any suggestions you have for improving our system.
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From:
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Your report has been approved supplemental report and the permanent number of the case is
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From:
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****THIS IS AN UN-MONITORED MAIL BOX****
in your email within approximately ten business days.
system.
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system.
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Print
RE: release of information to my attorney
From:Goodnight, Joseph W (JGoodnight@washoecounty.us)This sender is in your safe list.
Sent: Wed 5/02/12 4:45 PM
Mr. Coughlin,
MHC has received your referral and diagnosis from Ascent NBI. The MHC coordinator indicated that your case will be added to Friday's staffing and your application "looks fine." I
take that to indicate that you'll likely be accepted. I have a call in to DDA Young to re-open negotiations. This is what I intend to present for a global resolution:

Parties will agree to transfer jurisdiction of RCR11-063341 (RJC Misdemeanors) to MHC. DDA Young will defer prosecution of RCR12-065630 (misuse of 911) and upon successful
completion of MHC, will dismiss with prejudice. City prosecutor in Reno Municipal Court case (Trespass) will defer prosecution and upon successful completion of MHC, will
dismiss with prejudice (your attorney, Mr. Loomis, should advise you regarding this case).

Is that acceptable to you? If not, please let me know immediately.
Sincerely,
Joe Goodnight

**********************************************************
Joseph W. Goodnight
Deputy Public Defender
(775) 337-4839
jgoodnight@washoecounty.us
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521,
and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent
responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review,
dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited.
Sent: Wednesday, May 02, 2012 2:28 PM
To: Goodnight, Joseph W
Subject: FW: release of information to my attorney
Joe,

Here is Yassars assistants update. I am in favor of a global resolution. regarding mental health court, do
they attemt to take over ones medical care or second guess ones doctor on health care matters? what is the
worst case scenario with mental health court? lets say one does not do well in it, does that defendnat then
get tried in justice court as they would have before entering mental health court? can the mental health
court sentence one to jail?

thanks,

> From: megan@ascentreno.com
> To: ZachCoughlin@hotmail.com
> Subject: RE: release of information to my attorney
> Date: Wed, 2 May 2012 14:22:06 -0700
>
> Zach,
> I have not had time to type up the letter due to the high volume of patients and calls in the office. I will get to the letter as soon as I get a chance . The attorneys office did call
prior to you showing up in the office and due to that I did not have a release to talk with them regarding your diagnosis or treatment I told them I would have to get that first.
>
> Megan Sredy
>
> Megan Sredy
> Patient Coordinator
> Ascent NBI & TMS Center
> 540 West Plumb Lane, Suite 1A
> Reno, NV 89509
> Phone (775) 322-4666; Fax (775) 322-4747
>
>
> IMPORTANT:
> This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the
individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately, and delete the message and any attachments.
Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited.
>
>
>
> -----Original Message-----
> From: zach coughlin [mailto:ZachCoughlin@hotmail.com]
> Sent: Wednesday, May 02, 2012 2:06 PM
> To: ecek@ascentreno.com; megan@ascentreno.com
> Subject: release of information to my attorney
>
> From: zach coughlin <ZachCoughlin@hotmail.com>
> Phone: 7753388118
>
> Message Body:
> ----------------------
>
> My attorney sent me the following earlier today
>
> > Mr. Coughlin,
> > I have not received anything from Dr. Yassar's office. I called again and left a message with them to contact me regarding the release. I'd like confirmation of the diagnosis
today so I can submit your MHC application (again, due on Wednesday for staffing/acceptance meeting on Friday). Would you like me to try submitting your application without
the diagnosis? Perhaps this would achieve a conditional acceptance pending receipt of the diagnosis. Let me know.
> > Sincerely,
> > Joe Goodnight
Close
> >
> > PS - I don't know about your second question regarding RMC contact.
> >
> > **********************************************************
> > Joseph W. Goodnight
> > Deputy Public Defender
> > (775) 337-4839
> > jgoodnight@washoecounty.us
>
>
>
>
>
> Note, above is Joe Goodnights telephone number and email.
>
>
>
> --
> This mail is sent via quick contact form on Ascent Reno Psychiatry http://ascentrenopsychiatry.com
>
Print
RE: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?
From:Keith Loomis (keithloomis@earthlink.net)
Sent: Mon 2/27/12 3:27 PM
To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
Mr. Coughlin:

E-mail works well for me.

Keith Loomis

Sent: Monday, February 27, 2012 7:56 AM
To: keithloomis@earthlink.net
Subject: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?

hi, i guess Mr. Loomis was appointed as my 3rd defense attorney in RMC case 11 cr 26405. I have not heard anything about this case, and the RMC indicated they had
nothing scheduled. Please communicate with me only via email or fax please, having issues with my mail incident to domestic violence committed against me my fax is
949 667 7402. thanks,
Zach Coughlin
court date
Sent: Mon 3/05/12 4:09 PM
Mr. Coughlin:

I have requested that court set your trespass case for trial in about 30 days. I will let you know the date and time as soon as I know.

Keith Loomis
RE: court date
Sent: Wed 3/07/12 4:36 PM
Mr. Coughlin:

On what grounds, other than those already set forth in your existing motion, do you believe a motion to dismiss should be filed?

Keith Loomis

Sent: Wednesday, March 07, 2012 12:45 AM
Subject: RE: court date

Mr. Loomis,
Please copy me on any and all correspondences, filing, or other documentation or verbal requests,
correspondences, etc. that you submit to the Court, including the one you reference below. Please do not
follow Taitel's tact of agreeing to requests or failing to oppose motions without even attempting to obtain my
permission to in advance thereof.
I would like for you to draft a Motion to Dismiss in this case for me review.
Thanks,
From: keithloomis@earthlink.net
Subject: court date
Date: Mon, 5 Mar 2012 16:09:19 -0800
Mr. Coughlin:


Keith Loomis
RE: court date
Sent: Fri 3/09/12 10:14 AM
No worries. Made me laugh.

Couple of questions:

Did you file an appeal from Justice of the Peace Sferrazzas eviction order?
If yes, has it been resolved?

Did Sferrazza announce at the close of the hearing on the 25
th
that he was granting the eviction and ask Hill/Baker to provide a written order?

Did you ever see the eviction order posted by WCSO
If yes, when?

What is relevance of personnel files of Carter or Lopez?

How is Dr. Merliss testimony material to the defense of this case?

Keith Loomis

Sent: Thursday, March 08, 2012 12:46 AM

Dear Mr. Loomis,
I apologize Sir for what I am sure comes across as rudeness on my part. You seem like a good guy, and you
have great hair. I simply don't have time, money or energy to do any of this the polite way given the
"uniqueness" of this situation....Please just know I mean you no disrespect.
Would you please file a request or Motion for the Personnel File of RPD Officer Chris Carter and Sargent Monica
Lopez as well as supboena from the RPD all the volumns of crap Richard Hill has given them on this in addition
to noticing the court and City Atty as to Richard HIll being a witness, subpoena him (though the earlier
continuance would appear to imply he already is) AND SUBPOENA THE OLD CALIFORNIA NEUROSURGEON
WHO CAN GET HIS OUT DOWN HERE FOR THE TRIAL AND A DEPOSITION PRIOR THERETO, ETSPECIALLY
CONSIDERING THAT THE VARIOUS POLICE REPORTS AND MOTIONS FOR ORDERS TO SHOW CAUSE QUOTE
MERLISS AS SAYING HE WAS AT THE PROPERTY IN THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE
STUFF BOBBY PUENTES GOT YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT
CLEARLY). iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON ME, THEN
THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND HAVE THEIR RENT-A-
LYCAN rICHARD HILL DO IT.
ALSO PLEASE FILE A MOTION TO dismiss based upon denial of right to a speedy trial, spoliation of evidence,
etc....
PEACE

Trial Date
Sent: Fri 3/09/12 10:44 AM
1 attachment
Coughlin Trial Setting.pdf (771.8 KB)
See attached
RE: Trial Date
From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
Sent: Mon 3/12/12 9:26 AM
I can do that if there is a good reason to vacate the date. What is the reason?

Keith
Sent: Friday, March 09, 2012 6:28 PM
Subject: RE: Trial Date

Please file something with the court seeking to vacate that trial date and explaining that you failed to even once
consult with your client prior to setting it.
Subject: Trial Date
Date: Fri, 9 Mar 2012 10:44:17 -0800
See attached
RE: court date
Sent: Mon 3/12/12 10:02 AM
This e-mail is sent to address the grounds you identified as forming the basis of a motion to dismiss. As you know there is both a constitutional right and a statutory right to a
speedy trial. This case is nowhere close to a violation of the constitutional right to a speedy trial. The statute does provide for a right to trial within 60 days of arraignment in
municipal court. NRS 178.556(2). In this circumstance the court may dismiss the complaint. The statute requires, however, that the trial not have been postponed at the request
of the defendant. It is my understanding that the January 10, 2012, trial date, was postponed at your request. If that is true then there are not grounds to dismiss on the basis of
a violation of a right to speedy trial.

Dismissal based on spoliation is a civil concept. It has not been applied to criminal cases in Nevada as of yet. See Higgs v. State, 126 Nev. Adv. Opn 1 (2010). Rather defendants
in criminal cases are protected from the loss of evidence in the hands of the prosecution by the doctrine of due process. Consequently you might have a basis to request
dismissal if the City Attorneys Office lost evidence, in its possession material to the case. In such case if the City acted in bad faith or with connivance or if you were prejudiced by
the loss then there may be grounds on which to base a dismissal. Please advise as to what evidence was lost and how it was lost.

You have not identified any other grounds as a basis for dismissal. If you believe there are other grounds, let me know.

Thanks

Keith Loomis


Dear Mr. Loomis,
etc....
PEACE

RE: Trial Date
From:Keith Loomis (keithloomis@earthlink.net)You moved this message to its current location.
Sent: Wed 3/14/12 2:35 PM
Dear Mr. Coughlin:

My obligation under Nevada Rule of Professional Conduct 1.2 is to abide by a clients decision concerning the objectives of representation and, as required by Rule 1.4 to consult
with the client as to the means by which the objectives of representation are to be pursued. In a criminal case the lawyer shall abide by the clients decision, after consultation
with the lawyer, as to plea to be entered, whether to waive jury trial whether the client will testify.

Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any relevant limitations on the lawyers conduct when the lawyer knows that the client expects assistance not
permitted by the Rules of Professional Conduct or other law.

Under Rule 2.1. In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In rendering advice, a lawyer may refer not
only to law but to other considerations such as moral economic, social and political factors, that may be relevant to the clients situation.

Under Rule 3.1. A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not
frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for a defendant in a criminal proceeding that could result in
incarceration, may nevertheless so defend the proceeding as to require that every element of the case be established.

Under Rule 3.2(a) and (b). A lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.
The duty stated in paragraph (a) does not preclude a lawyer from granting a reasonable request from opposing counsel for an accommodation, such as an extension of time, or
from disagreeing with a clients wishes on administrative and tactical matters, such as scheduling depositions, the number of depositions to be taken, and the frequency and use
of written discovery requests.

Under Rule 8.4(d) It is misconduct for a lawyer to engage in conduct which is prejudicial to the administration of justice.

These, and others, are the professional rules I operate under in providing legal representation to you in case number 11 CR 26405, a case in which you are charged with the crime
of trespass. It is my understanding that your objective in this criminal case is that you be acquitted of the crime of trespass. That is my purpose in representing you. I am happy
to work towards that outcome to the best of my ability. It is my opinion, however, that much of what you ask to be done is not in compliance with the above rules. Accordingly, I
will not be filing a motion to dismiss based upon NRCP 6(a) and (b), I see that argument as frivolous. I will not be proceeding with the summoning of an out-of-state witness
(Merliss) unless you can establish his materiality to the defense. Nor will I be subpoenaing the personnel records of law enforcement personnel unless you can establish to my
satisfaction why they are relevant to this case. I have no intention at this time of conducting any depositions in the case or sending requests for production of documents or
interrogatories in the case. I see these actions as unduly burdensome on the judicial system, and unwarranted by anything you have provided to this point. I also see them as
frivolous and an attempt to utilize the criminal justice system to accomplish objectives not relevant to my purpose in representing you.

If you are dissatisfied with the limitations I perceive to exist regarding my representation of you, you are welcome to terminate my representation of you. You may then ask the
Court to appoint a new lawyer to represent you.

It is my understanding that Deputy Machem will be testifying in the case along with Richard Hill and Casey Baker.

I do think that there are some interesting angles to the case upon which a defense can be based and I will be pursuing those angles. I have asked you in previous e-mails to
provide information which I believe will be helpful to the defense of your case.

I advise you that the City has offered to recommend time-served as a sentence if you enter a no-contest plea to trespass. It is also my understanding that you have other criminal
cases pending in both Reno Justice Court and in the Second Judicial District Court of the State of Nevada. It is my understanding further that all of the criminal cases can be
resolved in a single plea to a misdemeanor offense if you will obtain psychological counseling. It is my obligation to inform you of the availability of these resolutions to the
present criminal case in which I provide representation. I will, of course, abide by your decision as to whether to accept these resolutions or not.

I note that there is a psychiatric evaluation scheduled for you in 2
nd
Judicial District Court Case No. CR12-0376 on April 3, 2012. The outcome of that evaluation could have an
important impact on this case. I am asking that you authorize a release of the information contained in the evaluation to me so that I may determine what impact it could have on
your behalf in this case.

I remain prepared to represent you in the trespass case. I think that a trial of the case will be interesting. My representation, however, is circumscribed by the Nevada Rules of
Professional Conduct.

Keith Loomis

Sent: Tuesday, March 13, 2012 4:29 PM

Dear Mr. Loomis,

In your motion to dismiss, I would like you to really focus on and set forth to the court the fact that the eviction order needed to
be served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of
Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with the provisions of NRS 40.220 to 40.420, inclusive, apply to the
proceedings mentioned in those sections.

The language about "removing the tenant with in 24 hours of receipt of the order" is only applicable to those situations where the tenant does not file a Tenant's Answer
or Tenant's Affidavit. I did file such a Tenan'ts Affidavit, and litigated the matter thoroughly. In those situations, NRS 40.400 requires NRCP to apply, specifically NRCP
6(a) and 6(e), and clearly WCSO Machem (please subpoena and identify as witnesses Mary Kandaras, Esq. of the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO
Civil Division supervisor Liz Stuchell for the trial in this matter, and further send out a request for production and subpoena duces tecum to the WCDA and the WCSO
askign them to specify, in writing and in detail, the exact procedures and policies in place with respect to the service and conducting of such lockouts (ie, not default
lockouts where there is not a summary eviction hearing, but one's like the present one, where there was a Tenant's Answer and hearing held, etc....). Be sure to ask
whether the are aware of what "personally served" means, and whether they mail the Orders on top of merely posting them to the door. Further, I have been told that
the WCSO has a policy or penatly system in place whereby the deputies must get these lockouts performed "within 24 hours of receipt of the order" the receipt being
the WCSO's receipt, and not the tenant's receipt. I don't ncessarily read the statute that way, but....the WCSO policy and punishment system would be at least some
indication of what the legislature meant (I guess, but I dont' really think so, though, you will note that Hill was left with nothing but citing to the "usual and customary
practice of the WCSO" in serving the Eviction ORders and performign lockouts, I believe, because the law does not contain much to support Hill's contention and
therefore he wishes to see the WCSO "customary practices" being given the weight of law.

Please see some specific selections attached from the eviction matter. I know, I know, you want to curtail the scope of your representation to an immaculate
degree....but Hill can clearly be seen in his various Motion to Show Cause, State Bar Grievances, Temproary Protection Order Applications, etc., etc., to be a punk who
doesn't much like competing on an even playing field, like any good private schooler, he would rather sick an attack dog on somebody than get in the octogon and go toe
to toe mentally. Regardless, Hill shows a continual desire to subvert NRCP 6(e), which applies to service of documents filed elecronically in the Second Judicial District
Court. He would rather withhold opposing counsels computers, laptops, client files, driver's license, etc. The last thing he wants is to go argument for argument,
research for research, writing for writing. Private school and daddy's pleading bank. Hill files a Motion to Show caue allegeing Coughlin subvreted an Order that was
filed on January 11th, 2012 with Couglin's action of January 12th, 2012. Under NRCP 6(e), the Order Denying the TRO had not even been served yet, and there has been
no indidcation that Hill gave the Order at the town dump to anyone other than an RPD Officer.

Further, it is not all that clear why Hills Motion for ORder to Show Cause deserves a full blown hearing when D7 does not indicate a hearing will be accorded to the
appeal. This is particularly suspect given that Anvui sets forth that appeals in summary eviction matters are done on a trial de novo basis.
There are a number, but how about your complete lack of communication with me prior to so setting that date. How about Mr.
Taitel and Mr. Puentes's failure in this matter and the prejudice to my case so created? How about your failing to identify yourself
as the public defender to a room full of defendants in jail at the arraignment?
There are other reasons as well, including, but not limited to, your resistance to subpoena the materials I have and am requesting.

I wish for you to subpoena the personnel files of both RPD Sargent Monica Lopez and Officer Chris Carter. I wish for you to list Dr.
Merliss as a witness and subpoena his appearance and appropriately notice the City of Reno in that regard, same goes for Richard
Hill and Casey Baker (Baker, by letter dated November 10th, 2011 demands the full rental value for the property as "storage" under
NRS 40.253, while also asserting he will go after moving and inventory costs, in addition to Hill's contractor Phil Stewarts later
ridiculous charges and perjury. Please subpoena Stewart as well.

Most importantly subpoena Washoe County Sheriff's Office Deputy Machem to testify and serve a subpoena dueces tecum,
requests for production, and interrogatories seeking records and responses from the WCSO as set forth in the letter I sent Liz
Stuchell (see attached) on or about February 10th, 2012. You see, the WCSO and Deputy Machem may be committing a fraud
upon the public by repeatedly filing affidavits of service that attest to personal service where Liz Stuchell, of the WCSO admits that
they clearly do not know, or choose to "remix" the legal meaning of "personally serve".

Further, please inform the City of Reno and appropriately notice the same as to the existence and intent to offer into evidence a
video of Richard Hill, Esq., admitting that he and his firm, on behalf of Dr. Merliss, were withholding the accused personal property,
in addition to the client's files from the former commercial lease home law office of the accused and asserting a lien, under NRS
40.253 for "storage", however, as the video tape shows, Hill admits to charging the undersigned the same $900 per month rent as
was charged for the "full use and occupancy" of the premises at 121 River Rock St., Reno, NV 89512. Hill further demands that
property be removed in a certain order, regardless of whether his articifically inflated lien was paid or not. Additionally, Hill
committed fraud upon the court in a number of instances and filed false police reports wherein he alleges that he agreed to or
otherwise made available to the accused items such as the accused's clients files (and for a time wallet and state issued driver's
license) where, clearly, without requiring any payment by the accused, however, clearly, the facts show that Hill never actually lived
up to those assertions and repeatedly failed to show provide such items absent payment of his artifically inflated lien.

Further, I wish for you to divulge and provide notice that it is available for pickup and that we intent to introduce into evidence a
video of RPD Sargent Monica Lopez admitting that she and RPD Officer Carter did not identify themselves as police officers or
otherwise ask the accused to leave 121 River Rock St. on the date of the arrest prior to Merliss opening the door to the basement.
This is apparently in direct contradiction to the sworn filings made by Richard Hill, Esq. in his affidavits attached to his various
Motions to Show Cause, the Reply to Opposition thereto, Opposition to TRO, etc., etc. (in RJC Rev2011-001708 and the appeal in
CV11-03628). For that reason alone Merliss' presence is required. He was a precipient witness and you are asking me why he
should be there? You have a duty to zealously advocate on my behalf, Mr. Loomis. You are paid, by the public, to do so. Please
divulge any prior associations you have with anyone employed by or workign as an independent contractor with the RMC and or
the Reno City Attorney, including anyone you went to law school with or attended the same law school as, within a 5 year period.

Further, I wish for you to file a motion seeking a mistrial or otherwise requiring the recusal of the RMC and further disclosing why it
is that Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth recuse Judge Dilworth?) in one case,
without detailing why exactly, while Judge Gardner apparently is intent on remaining on in 11 CR 26405, despite the fact that an
apparent conflict exists, one which he only disclosed upon prompting from the accused, with respect to Judge Gardner's very
recent employment with the Reno City Attorney's office and the existing and or brewing litigation (or, at least, possible litigation)
between the accused and the City of Reno, Reno City Attorney, and possibly, the RMC.


Date: Mon, 12 Mar 2012 09:26:35 -0700

Keith

Subject: Trial Date
Date: Fri, 9 Mar 2012 10:44:17 -0800
See attached
RE: i was evicted 3 15 12, i need a continuance
Sent: Wed 3/28/12 2:03 PM
Dear Mr. Coughlin:

This message is sent to address issues raised in the e-mail you sent on 3-26-12.

1. Please note that you are free to send the communications you send to me, to anyone else you desire. You should be aware that sending your communications to other
parties will cause your communications to me to lose their attorney-client confidentiality.
2. For what specific purposes do you need a continuance? A continuance purely for the purpose of delay is not a proper reason for a continuance.
3. Whether you are entitled to e-mail the Reno Municipal Court is not my concern. That is a problem to be addressed between you and the Court.
4. Ms. Drake is no longer the attorney handling your case for the Reno City Attorneys Office. Your case is now being handled by Christopher Hazlett-Stevens, Esq.
5. In response to your question regarding the weaknesses of the trespassing case I offer the following:
a. The complaint is deficient in that if fails to set forth the elements of the crime of trespass. It fails to identify whether your presence on the premises was for the
purpose to vex or annoy the owner or occupant of the premises or whether it was an entry onto the premises after a warning not to so trespass. This is probably easily
remedied by an amendment at the time of trial. Nevertheless these are alternative theories on which a trespass case can be pursued and the defendant is entitled to
know on which theory or theories a case is being prosecuted in advance of showing up for trial.
b. You filed an appeal on October 19, 2011, apparently, of the order made by Justice of the Peace Sferrazza on October 13, 2011. That order denied your request for a
continuance and granted summary eviction unless you filed a deposit with the court. Typically the courts lose jurisdiction to rule on other matters in the case once an
appeal is taken. It is clear from the court records that this appeal was pending before the Second Judicial District Court at the time the court held a hearing on the
unlawful detainer on October 25, 2011. It may well be that the Justice Court lost jurisdiction to hold the eviction hearing while the appeal was pending.
c. I am working on some other thoughts.
6. If you are dissatisfied with the way I am representing you, you remain free to seek a new attorney.
7. Another chuckle regarding my ownership of strip clubs. I dont own or have any ownership interest in any strip clubs, brothels, adult book stores or movie houses. I
guess that leaves me free to moralize.
8. I still dont see the importance of Dr. Merliss. The request for payment of an amount equal to rent, was for storage of your personal property. You are entitled to
contest the amount of the storage fee, which you did. There is no credible evidence anywhere which suggests that anyone intended to reopen or create a new tenancy
allowing you to retain possession of the premises.
9. Dr. Merliss is an out of state witness. In order to compel his appearance, his testimony must be material. NRS 174.425(1). It does not appear that his testimony is material
under the information you have provided Further, under NRS 174.425(2) he is entitled to be paid his subsistence and travel expenses incurred in coming to Nevada. Are
you prepared to pay those expenses in advance of his coming to Nevada?
10. I dont intend to fax or e-mail to you, your full file in this case. You already have everything with the exception of a couple of items which I mailed to your old address. I
will send them again to your new address. If you want to review the file you are welcome to do so at my office. If you want copies of anything in the file you may mark
the items. After giving you a cost estimate, for which I require payment in advance, we will provide you with copies of the marked items.

Keith Loomis

Sent: Monday, March 26, 2012 10:33 PM
To: keithloomis@earthlink.net; stermitz@sbcglobal.net; jmd@randazza.com; jboles@callatg.com; kristiemanning@yahoo.com; kadlicj@reno.gov
Subject: i was evicted 3 15 12, i need a continuance

Dear Mr. Loomis,
I was wrongfully evicted on 3 15 12, and I need a continuance in the criminal trespass matter that you set overly
quickly against my express wishes anyway. My ability to collect evidence necessary to my defense and
otherwise prepare has been adversely affected. Additionally, I don't feel as though you are performing in an
appropriate manner as defense counsel, but rather you seem stuck in your prosecutorial ways, too quick to look
for any excuse whatsoever to bury one's case, so I think you have forced a split here, which further prejudices
my case and augers towards a continuance. Please move for one immediately and copy me on my entire file
by email and fax please. Additionally, please seek clarification from the RMC as to whether I am allowed to ever
send an email to renomunicrecords@reno.gov. Please note, today, Judge Flanagan denied Richard Hill's latest
frivolous motion.
Did you know that Kevin Kelly, of the State Bar of Nevada's Character and Fitness Committee for at least the last
decade owns and runs the Spearmint Rhino strip club in Las Vegas:
http://www.reviewjournal.com/lvrj_home/2002/Mar-06-Wed-2002/news/18241452.html
I know I always like my three hour tours of heavy handed moralizing from someone who runs a monolithic strip
club in Las Vegas.
You are on the State Bar of Nevada's fee dispute committee, aren't you Mr. Loomis? Do you own any strip
clubs?
Mr. Loomis, which of the elements of the trespass charge RMC 8.10.040 do you feel are weakest for Deputy
City Attorney Jill Drake, whom I informed about the admission by Reno PD Officer Chris Carter that Richard G.
Hill, Esq. bribes him, but for which Ms. Drake indicated a complete lack of interest and expressed that she
would not be following up on that report of bribery of a RPD Officer. Mr. Kadlic, please place a copy of this
correspondence in Jill Drake's personnel file. Additionally please place one in Allison Ormaa's personnel and
employment file too, in addition to Deputy City Attorney Dan Wong's employment file, as all three of those
Deputy City Attorney's were provided that report and all three indicated they did not care and had no
intention of following up or otherwise investigating the admission by RPD Officer Chris Carter that Richard G.
Hill, Esq. bribed him. I think the failure to follow up by any of these 3 Deputy City Attorney's relates to any
future negligent hiring, training, and supervision claims that the Reno City Attorney may need to defend
against when representing the Reno PD like it did in the Eeof v. Pitsnogle case:
http://www.lvrj.com/news/reno-official-accused-of-witness-tampering-116586528.html
You know, Deputy City Attorney Ormaas's decision to push on for that $70 traffic ticket
is looking more and more interesting. \\
Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his understanding of the
extent to which his attorney, Richard G. Hill, Esq. had effectively rescinded any eviction
Order by sending a bill for the same amount as full use and occupany of the location at
121 River Rock St. goes to the substance of the elements found in RMC 8.10.040 as well
as the credibility of both Merliss and Hill.
Sincerely,
Sent: Thu 3/29/12 4:59 PM
Mr. Coughlin:

I previously sent you the setting slip for your trial in this matter by e-mail on March 9, 2012. That setting slip set your trial for April 10, 2012 at 8:00 a.m. in Dept 2 of the
Reno Municipal Court.

I am available to meet. Best times for me next week are Monday afternoon, Thursday afternoon or Friday morning. Let me know which is best for you and I will set
aside time for an appointment.

No I am not going to send you my case plan in writing with reference to citations and copies of legal research etc. (You might take cognizance of the fact you sent my last
discussion of your case to the Reno City Attorneys Office-notoriously poor strategic and tactical move on your part).

No skin in the game.

Keith Loomis

Sent: Thursday, March 29, 2012 12:04 PM
Subject: RE: i was evicted 3 15 12, i need a continuance

Mr. Loomis,
Can you please indicate to me, via email, if there is a Trial Date or any other court date set in this matter, and, if
so, provide the Date and Time. I would like to meet with you, when are you available to do so? Also, please
indicate in writing what your plan is for this case and what you have done to zealously advocate on my behalf,
including specifics regarding any legal research you have culled (and please provide citations and copies of the
research gathered to me, preferably by email). In your duties on the State Bar of Nevada's Fee Dispute
Committee, have you ever had a fee dispute from a client of a public defender? Do public defenders have any
skin in the game?
Sincerely,
RE: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno
Attorney's smart phone and cell phone etc. in court after cross examing RPD on bribery and
retaliation
Sent: Thu 3/29/12 5:05 PM
Dear Mr. Coughlin:

There has not been, as of yet, a trial as to which a mistrial could be declared in this case. A motion for mistrial is consequently premature.

I am only representing you as to your trespass case over which Judge Gardner is presiding. I am not representing you in regards to any other criminal case over which any
other Reno Municipal Court Judge is presiding. If you believe there are grounds to seek the recusal of Judge Gardner in regards to your trespass case, please identify
what those grounds might be.

Keith Loomis

Subject: FW: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD
on bribery and retaliation
Importance: Low

Dear Mr. Loomis,
Please file a motion for a mistrial and a motion to conflict out any RMC Judge from hearing any criminal case where I am a defendant.
Thanks,
To: dgentile@gordonandsilver.com; renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com;
ed@npri.org; mkandaras@da.washoecounty.us; mark@markmausertlaw.com
Subject: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD on
bribery and retaliation
Date: Thu, 29 Mar 2012 14:39:17 -0700
Dear City of Reno,
Please place a copy of this in Marshal Coppa's and the other Marshal who transported me to jail on 2/27/12's
employment/personnel file as he was the one who went into a backroom of the "Sally Bay" at the jail after
whispering in the WCSO Deputy Cheung's ear. Please ask him about the bag with the micro sd card, the various
contradictory statements made by RMC staff, Reno Marshals, and WCSO staff with respect to the chain of
custody of the seized property, with particular attention focused on Marshal Harley's statements concerning any
micro sd card, Debi Campbell's assertions in that regard, what Pam Willmore heard WCSO Deputy Hodge admit
with respect to the WCSO retention of the micro sd and other property, comparing that with any recordigns of
that conversation that may exist, and further referencing the statements of Ms. Campbell, Cummings, and
Beckman, while also reviewing any recordings made of telephone conversations with WCSO Detention Facility
Staff shortly after Coughlin was released from jail on
Please find new attachments herein including the emailed responses of WCSO agents Cummings, Debi
Campbell, and Trish Beckman.
To: renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com
Subject: City of Reno Marshal Division hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD on bribery and
retaliation
Date: Thu, 29 Mar 2012 14:05:54 -0700
Dear City of Reno and Mr. Jeanney,
I was told by the Washoe County Sheriff's Office to call the City of Reno Marshal's division to inquire about the
return of the personal property that was seized from me incident to a 2/27/12 arrest for summar contempt
during the traffic trial in 11 tr 26800 before Judge Nash Holmes. I called the number held out as the Marshals
Division contact number http://reno.gov/index.aspx?page=223
And a "Bill" answered the phone, was evasive, indicated he did not work for the Marshal's division, would not
give me any contact information for a Marshal, any Marshal, told me he wasn't going to answer me stupid
questions, and hung up on me.
I called back and I believe it was Marshal Harley who answered (though I am not sure) and he answere the
phone in an unprofessional manner, guessing as to my identity in some show of menace. Rather than tjust
answer the phone like a professional and provide me the number for Marshal Dayton, as I was requesting, this
individual refused to provide the number, answered the phone on a "gotcha" type way where there was nothing
to "gotcha", then hung up the phone on purpose after declaring that he would not give me Marshal Dayton's
number or take a message. Please place a copy of this correspondence/complaints in "Bill" of court security for
the Reno Munic Court, and Marshal Harley's file and follow up this grievance. I am available to comment on
this unprofessional conduct further. Please also find attached other recent complaints I have submitted
regarding the Marshal Division and place them in the individual's complained of employment/personnel files.
There will be no ability to allege a lack of knowledge of this conduct in any future negligent hiring, training, and
supervision lawsuit incident to any misconduct alleged. I a requesting that a full scale investigation/inquiry be
conducted pursuant to the various conflicting, and inconsistent statement made with respect to the seized
personal property (inlcuding my phones, etc.). You might want to consider whether any Washoe County
Sheriff's Deputies have made statements that will conflict with anything the City of Reno may say from hear on
out. Given problems associated with my recently being adjudge a victim of domestic violence (my vulnerability
in that regard made moreso by Judge Nash Holmes seizing my cell phones and attempt to have my incomed
reduced through jeopardizing my law license, etc.) please correspond with my in writing only and only by email
and or fax.
Sincerely,
Zach Coughlin, Esq.
Detail page for JAMES MENZEL
Name JAMES MENZEL
Position
Marshal
Reno
Notice
The City of Reno failed to report the cost of employee health care benefits. Only the cost of retirement benefits is included within the
"Benefits" category for this jurisdiction.
Year 2009
Base Pay $60,609.42
Overtime and
Callback
Collected
$622.67
Total Pay $63,750.96
Benefits
Accumulated
$22,425.49
Total Pay &
Benefits
$86,176.45
State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
Education: CCSD Warrants, NSHE Budgets
Politicians: 2010 Transparency Survey, Congressional Disbursements
Connect: Facebook, Twitter
About Us: Contact Us, FAQ, Disclaimer
TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
Detail page for JOEL HARLEY
Name JOEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Benefits Accumulated N/A
Total Pay & Benefits $124,126.82
Detail page for JUSTINROPER
Name JUSTIN ROPER
Position
7819 Marshal Commander
Reno
Year 2010
Base Pay $107,914.00
Overtime and
Callback Collected
$0.00
Other Pay ($2,697.89)
Total Pay $105,216.11
Name JAMES MENZEL
Position
Marshal
Reno
Notice
Year 2009
Base Pay $60,609.42
Overtime and
Callback
Collected
$622.67
Benefits
Accumulated
$22,425.49
Total Pay &
Benefits
$86,176.45
Name JOEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Name JUSTIN ROPER
Position
Reno
Year 2010
Base Pay $107,914.00
Overtime and
Callback Collected
$0.00
Other Pay ($2,697.89)
Total Pay $105,216.11
RE: request for a pre trial motion and bail motion
Sent: Tue 8/07/12 9:55 AM
Zach

Why dont you move to represent yourself. That way you will be completely satisfied with the services you provide yourself and can do all of the things you believe are
necessary.

If you want me to continue to represent you, what I asked you to provide to me was a description of the events which lead to the charge of disturbing the peace. I still
need that description.

Keith Loomis

Sent: Monday, August 06, 2012 3:54 PM
To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
Subject: request for a pre trial motion and bail motion

Dear Mr. Loomis and City Attorney Kadlic and Deputy City Attorney Drake,

I am writing to request that you file some motion to alter, amend, reconsider, set aside, or modify my bail in the case stemming from my JUly 3, 2012 arrest for distrubing the peace,
failure to provide proof of insurance, and failure to secure a load. I am writing to request that you file a pre trial motion (Motion to Dismiss, request for a pre trial motion and bail
motion, and motion to supress police report based upon the DTP arrest occuring for alleged conduct outside the officer's presence). If you will not file these motion (and please
provide me a draft of such motions for my review prior to filing them as well as prior to making any communication on my behalf to either the RMC or the City of Reno Prosecutor),
please provide me a written indication of your rationale for so refusing, and then please file a Motion to Withdrawal as soon as practicable. I ask this respectfully.

The police showed up to the hearing, yet I was not noticed of that fact in advance, or of the hearing itself. Further, Judge Gardner explicilty indicated he was basing his decision to
raise the bail based upon "public safety" and "concern for the defendant's safety", which are impermissible rationale for so increasin one's bail.

NRS
178.498. Many courts use a bail schedule to determine the amount, but note the
initial amount can be increased if good cause is shown. NRS 178.499. Additionally, in
determining the amount of bail, the judge should look at the following factors (NRS
178.498):
The nature and circumstances of the offense charged
The defendants financial ability to post bail
The defendants character; and
The factors listed in NRS 178.4853.
Bail can not be excessive. U.S. Const. Amend. VIII. It should be limited to a
reasonable amount designed to ensure the defendants presence in court. It should not
be a corrective or preventative detention device.

NRS 178.484. The Court should take care in imposing any restrictions on a defendants constitutional rights (i.e.,
search and seizure) and only imply such restrictions if warranted by the underlying facts
of the alleged crime. Section 11 of NRS 178.484 describes the document that must
be signed by the defendant before he/she can be released on bail.

My bail hearing contained what seems to be an impermissible coercive attempt to condition my release or the possibility thereof upon my providing confidential medical records
(Lake's Crossing etc) to the Reno Municipal Court, even where the same judge presiding over the bail hearing found me competent enough to face a criminal trepass trial less than
two weeks before teh bail hearing in 11 CR 26405.

The friend of mine who posted my bail, Jared Swanson, has a serious form of cancer and a one year old baby. I request a reduction of the bail for his benefit and for the proof of
insurance charge to be dismissed, as (and I am trying to avoid this in any way I can), if I am rearrested, such a proof of insurance charge may present another basis for imposing an
unduly burdensome bail upon me, as it did on July 5th, 2012 where, despite my having produced a legible pdf copy of my proof of insurance card on my large screened zoomable
smart phone, Officers Weaver and Dye still charged me with that violation, and the bail was subsequently increase. Further, none of the events or accusations forming the basis of
the distrubing the police charge occurred in the officer's presence, and the police report contains no indication whatsoever that the arrest was made based upon NRS 171.1771. I
provided Officer Weaver my driver's license prior to the arrest. I did not
refuses to give a written promise to appear in court as provided in NRS 171.1773.

When a person is believed to have committed a misdemeanor offense, the peace officer has the discretion to
either issue a citation or arrest and detain the person. NRS 171.1771 states that a person can be arrested if
his identity is questionable or if the peace officer does not believe the person will appear in court. A person
can also be arrested for a misdemeanor offense if a warrant has been issued.

Additionally, I am requesting that you file a Motion to Dismiss the Disturbing the Peace charge based upon a lack of evidence and or insufficiency of pleading in that the allegations do
not amount to a prima facie case of a DTP violation. Further, please subpoena and or collect the Protection Order application filed by Milan Krebs on July 5th, 2012, and interview
Krebs as to why he mentions Coughlin often carrying around a large knife in a menacing manner in that protection order application, yet completely failed to mention that in his July
3rd, 2012 police report. Additionally, please determine why Kreb's TPO appliication has a different style of handwriting on the caption compared to the descriptive sections, indicating
someone pushed the filing of the TPO on Krebs, perhaps his employer, Northwind Apartments or the RPD, which has in the days preceding the arrest threatend to arrest Coughlin for
criminal trespass if he returned to any part of the premises of Northwind Apartments, in consideration of Coughlin's eviction from unit 29, despite the fact Coughlin still had a valid
right to go to his other two rentals, units 45 and 71, in addition to the fact that Northwinds essentially withdrew or rescinded its June 28th, 2012 eviction of Coughlin by posting an
Amended 5 Day Unlawful Detainer Notice on unit 29 on June 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada Courts Services that the July 14th, 2012 5 Day
notice was not "personally served" (NCS's R. Wray lied about effecting personal service, as he could not possibly have verified someone of "suitable age and discretion" was within
the windowless room with a metal door closed and locked and where no Wray admits that he received no verbal response from the unit or anyone therein upon his knocking on the
door and or attempting to break into the unit, please see Soldal v. Cook County in that regard, a US S. Ct case) and therefore Coughlin would have had until at least noon on July
28th, 2012 to file a Tenant's Answer, whereas the eviction/lockout/arrest of June 28th, 2012 took place two hours before noon at 10 am).

Additionally, RPD Officer Weaver had previously attempted to break into one of my rentals at Northwind at a time when he lacked a warrant and or an exigent rationale for doing so,
much less an eviction Order. I just want this case to be dismissed and to try to move on in life, and difuse the tensions incident to this case.

I did not disturb the peace at Northwinds as alleged, nor did I make the threats Kreb's accuses me of or stalk him or follow him in a threatening manner at any time. Additionaly, I
never broke into nor did I ever attempt to break into Krebs' truck, and in fact, I filed a police report in June 2012 reporting extortionate threats by another maintenance man at
Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne Jakob, wherein they threatened to make such a spurious allegation, but subsuquently refrained from
doign so when it apparently occurred to them that I may have excuplatory video evidence disproving such an allegation as well as capturing their baseless and extortionate threats
and accusations. Additionally, please subpoene the police reports I filed with the RPD and any emails I sent to any officers (including Weaver, Barnes, Sargent MIiller, LIeutenant
Brown) and any reports of or recording of phone conversations I had with any of those RPD personnel. Further, please see the attached june 26th, 2012 email to the RPD, WCSO,
RJC, Sparks Justice Court and others pointing out the insufficiency of the 5 day Notice drafted and posted by non-lawyers Nevada Court Services, in that under NRS 40.253 it listed
the wrong forum for the tenant to file a Tenant's Answer, and under the Aiken decision of the Nevada Supreme Court and NRCP 60(b)(4), any lockout order stemming therefrom is
void for lack of jurisdiction.


(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:...
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;...

Krebs did not immediately arrest me under NRS 171.136(2)(d), nor was the DTP arrest for an offense alleged to have occurred in the officer's presence.

the attached videos are of the incident on June 5th, 2012, not from July 3rd, 2012, but they support my contentions and the relevancy of subpoening the police incident reports and
other documentation should this case not be dismissed, nolle prosequi, de minimis, etc....

I will forward to you my emails to the RPD et all from June 26th, and July 2nd, 2012. I realize their tone was not a smart one to take or appropriate and am only sending them in
hopes of having this matter dismissed. I do not have any interest in pursuing anything like Wheeler v Cross 344 Fed Apps 420 (2008) .

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
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From:NvRenoPd@coplogic.com
Sent: Fri 6/08/12 4:39 PM

system.

Online Officer

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system.

Online Officer

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report-120103420-0.pdf (71.4 KB)

120103420.



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120103420.



Online Officer
Sent: Tue 8/07/12 4:25 PM
You have already had two bail hearings. You are out on bail now. I decline to file a new request for a bail hearing.
I will be out of town on vacation from Friday August 10 and will return on Monday Aug. 20. That makes attendance at a bail hearing problematic and unlikely to be heard
before your trial.
I do think the complaint fails to allege the charge of disturbing the peace. I will make the motion to dismiss it at the time of trial.
The fact that the officer did not observe you committing a misdemeanor means he was not entitled to arrest you. You have a civil claim against RPD and the
officer. That does not mean the charge of DTP is subject to dismissal.
I will review the case involving Mr. Krebs and his request for a temporary protective order.
I need your description of what happened on the 3
rd
of July. Will you provide it?

Sent: Tuesday, August 07, 2012 3:38 PM
To: Keith Loomis
Subject: RE: request for a pre trial motion and bail motion

Are you refusing to file the motions o requested?
-----Original Message-----
From: Keith Loomis
Sent: 7 Aug 2012 16:55:44 GMT
To: 'Zach Coughlin'
Zach

necessary.


Keith Loomis





NRS
178.498):













Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
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120103420.



Online Officer
RE: respectfully submitted
Sent: Wed 8/08/12 2:43 PM
Zach:
I reviewed the file in the Krebs protective order application. It is interesting in that there is not one reference by Mr. Krebs to a belief that you were trying to provoke
him to engage in violence or a violation of law. Those appear to be solely the words of Office Weaver.
I subsequently received your 100 page e-mail and do not intend to review it at length as most of the material appears irrelevant. What I gather from it is that
you are once again not happy with my representation and want me to withdraw. I think there is merit to that request. It appears that our relationship has broken down
and that you are asking me to engage in conduct that will result in violations of the rules of professional conduct. Those include Rules 3.1, 3.2 , 4.4 and possibly others. I
also fundamentally disagree with some of your requested actions in that so far you have refused to provide your description of what happened on July 3, 2012 with Mr.
Krebs. It also appears that your repeated demands are making my representation unreasonably difficult. It would be helpful; if I can represent in the motion to
withdraw that you are willing to waive the 60 day rule for trial, so that a new attorney can be appointed to represent you and have enough time to prepare your case.
Please respond whether you will agree to that waiver. If not I will simply file the motion without the representation and hope for the best.

Keith Loomis

To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
Subject: FW: respectfully submitted

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: weavera@reno.gov; barnesm@reno.gov
Subject: respectfully submitted
Date: Fri, 8 Jun 2012 16:41:49 -0700
Dear Officer Weaver and Officer Barnes,
I am respectfully submitting this supplementary material to the police report I submitted to you in person on
June 6, 2012 regarding the assault I was the victim of at the hands of maintenance staff member Luke of
Northwind Apartments on June 5th, 2012, and the attempts at unlawful entry committed by Northwind
Manager Dwayne Jakob on or about June 4, 2012.
I am attaching an article you may find of interest regarding the intersection of landlord tenant law and police
work, vis a vis criminal/civil matters and the fine distinctions that sometimes arise. I didn't see anything in there
on Officer Weavers fine hypothetical regarding entry without permission when a burglary may be occurring.
That situation probably does not come up that often because hardly anybody but the police would be brave
enough to enter such a dangerous situation.
I appreciate the brave service both of you provide. I am attaching this materials just because they are
interesting to me and may be to you and in no way wish for so attachign these to be interpreted as a criticism
of either of your police work.
Sincerely,
Zach Coughlin
Motion to Withdraw
Sent: Fri 8/10/12 11:07 AM
To: Zach Coughlin (ZachCoughlin@hotmail.com)
1 attachment
SKMBT_C35312081011000.pdf (164.4 KB)
Motion to Withdraw is attached

Keith Loomis

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Print
RE: motion for continuance
From:Pamela Roberts (robertsp@reno.gov)
Sent: Wed 11/16/11 5:12 PM
To: Zach Coughlin (zachcoughlin@hotmail.com)
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for reciprocal discovery. You just need to call ahead at 334-2050 and
arrange to pick it up. You are entitled to copies of all the reports and witness statements and video we may have on this case. Since I am not calling any additional witnesses that
are not already mentioned in the reports/statements, I am not obligated to send you an additional list of witnesses. I am also not obligated to do any further investigation or
interviews. Pam Roberts.
To: <robertsp@reno.gov>
Date: Wed, 16 Nov 2011 15:35:48 -0800
Subject: RE: motion for continuance
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any Walmart employees had, previous to this
incident, made any threats respecting maliciously having the accused banned from Walmart's incident to a
disagreement over Walmart staff and managers curious practice of "forgetting" their return policy, despite some
individuals having worked there over 10 years....Further, I believe it relevant and part of your duty to provide
exculpatory information to ascertain whether the RSIC police officer made statements wherein he attempted to
coerce a consent to an impermissible search and further buttressed his probable cause finding to conduct a search
incident to arrest, expressly, in words, to the accused, upon the accused's failure to consent to such a search.

Please provide a list of any witnesses you intend to call at trial, including a summation of the matters the will
testify to, in addition to producing a copy or making available for reproduction any documentation, audio, video,
or other materials intended to be used in any way at trial.
Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
From: robertsp@reno.gov
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation from the Court that your trial date has been
continued, you will need to appear this afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are
unable to resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the Court is not required to appoint you an attorney. In
addition, you have no right to a jury trial in a misdemeanor case.

I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.

Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
Dear Counselor Roberts,
I believe you are the prosecutor for the case against me, State v. Coughlin, which I believe is still set for
trial on November 14th, I think at 1pm. I am not totally sure that there is a duty to serve you on such a
thing, but I filed a Motion for Continuance and a Motion for Appointment of Counsel sometime within
about the last 10 days, I would say. I believe I attempted to copy you on it, but have recently been
evicted and its been a very difficult time in terms of coordinating paperwork, etc., etc. I apologize for
any inconvenience this may have cause you. I am unsure of whether the November 14th trial is still set
to take place. I believe fairness dictates that it be continued to a later date. I have request counsel but
have yet to receive any, or wait, I was denied a request to receive counsel because Judge Howard said
there is not a 6th amendment right to counsel where, even though jail time is technically a possibility, the
state does not anticipate seeking jail time...or something like that, however, I found some cases that say I
should still get counsel appointed, especially where I show I am indigent, and I believe I qualify as
indigent rather easily. Can and would you agree to a continuance? I believe I tried to contact about this
prior to filing my Request for a Continuance. I maintain my innocence in this case and feel any sort of
conviction, especially one involving any sort of theft based charge, would work a terrible injustice and
greatly damage my reputation and employment prospects. I want a jury trial, too.
SBN still has not provided Coughlin access to the materials he is entitled to to
prepare for 11/14/12 Hearing
Close
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
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Print
WLS
From:Paul Elcano (pelcano@washoelegalservices.org)You moved this message to its current location.
Sent: Wed 5/06/09 9:38 AM
Dear Zach,

You are correct about the letter being delivered on April 20
th
, I misread my timeline. My decision is limited to the hearing conduct. You have proffered nothing that indicates
that the way you acted in court is in any way related to any outside event. Your 50 page motion for reconsideration before Judge Gardner has not linked your conduct in any way to
an outside event. You have refused to give me a time and date to meet once again, and I will issue my determination tomorrow morning at 9:00 am.

Access to your computer materials, will be made at a convenient time and place with our office manager, executive director or designee and our computer specialist
present. This is a business computer, and without further research I will not give you access to it privately. You have been given a tape of the two Joshi hearings. To date, you have
not agreed to meet at any time and place to discuss these hearings; and you have not specifically requested any identified items, documents etc. that were related to your conduct
in this hearing. Your series of questions about the Board is irrelevant. The Board delegated this matter to me to handle as a personnel matter.

-Paul
Sent: Fri 11/02/12 10:36 PM
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
33 attachments
all emails to loomis 26405 12420 26800 00696 065630 063341.pdf (779.8 KB) , 2 28 12 Contempt Order Nash 26800
26405 065630 00696 063341 bf size reduced.pdf (449.9 KB) , 11cr26405 puentes 041012_20120410-
0903_01cd16f8c3aa49b0.mp3 (5.1 MB) , NvRenoPd@coplogic.com rpd police reports by coughlin 063341 duralde carter
lopez sifre 1708 26405 26800.htm (145.0 KB) , rpd carter police report 11 cr 26405 puentes loomis 1708 merliss rmc
gardner cr12-0376 mh12-0032 650630 063341 rpd lopez carter police report 11 13 12-2.pdf (6.3 MB) , 3 3 12 attached to
loomis email and filed in rmc final motion to dismiss 11 cr 26405 26800 065630 063341.pdf (442.6 KB) , goodnight
jgoodnight@washoecounty.us 5 2 12 email regarding hazlett loomis mhc 178.405 063341 26405.htm (16.3 KB) , all emails
from keith loomis keithloomis@earthlink.net between 2 27 12 and 8 10 12 26405 26800 00696 063341 065630.htm (322.8
KB) , 3 7 12 rmc 11 cr 26405 loomis gardner 178.405 Coughlin Trial Setting 26800 00696 063341 065630.pdf (321.4
KB) , 8 9 12 Loomis second Motion to withdraw 12 cr 12420 rmc see also 26405.pdf (229.2 KB) , State Bar Of Nevada
nvbar casey baker 1708 26405.htm (42.7 KB) , 5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302
26800 60317 54844 dd.pdf (15.3 KB) , 11 16 2011 email from reno city attorney roberts.htm (16.3 KB) , WCSO Beckman,
Debi Campbell, Cummings, Hodge Statements on property sezied from Reno Attorney by Reno Munic Court Judge Nash
Holmes.pdf (150.3 KB) , ZachCoughlin@hotmail.com emails to puentes@aol.com.pdf (222.1 KB) , pam roberts on her
duty.pdf (812.0 KB) , Patrick King sbn grievance letter of 3 16 12 and Judge Nash Holmes greivance of 3 14 12 rmc 11 TR
26800.pdf (575.8 KB) , proof of clandestine status conference on 2 27 12 dogan young nash holmes schroeder rcr2012-
065630 rjc rmc rpd wcso wcpd wcda - Copy.pdf (1644.4 KB) , proof of faxing notice of appeal to both rmc gardner and
reno city attorney hazlett-stevens.pdf (14.5 KB) , proof picture of personally delivering notice of appeal to city of reno
hazlett 6 27 12 in cr12-1262 11 cr 26405.pdf (43.9 KB) , records request and subpoena to RSIC.pdf (71.2 KB) , records
request to rsic police.pdf (65.8 KB) , rmc 12 cr 12420 Loomis motion to withdraw as counsel 8 9 12 City of Reno v
Coughlin.pdf (926.9 KB) , Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB) , ORDER
RELEASING PROPERTY 11 TR 26800 3 30 12 nash rmc rjc rpd wcso king clark marked as recd back by rmc 4 13 12
return to sender pthoa hy.pdf (287.1 KB) , letter to bar counsel regarding rmc and reno city attorney complaints with loomis
emails.pdf (329.3 KB) , ex 1 to motion to set aside dismissal cr12-1262.pdf (2.5 MB) , CR12-1262-3093668 (Opposition
to Mtn ...).pdf (92.5 KB) , CR12-1262-3117150 (Ord Dismiss Appeal Remand).pdf (73.9 KB) , CR12-1262-3119416
(Exhibit 1).pdf (2.7 MB) , 6 28 12 email to hazlett stevens showing what was served notice of appeal 11 cr 26405 cr12-
1262.pdf (12.8 KB) , 12 14 11 fax to Puentes re WCSO Affidavit of Service REV2011-001708.pdf (24.9 KB) , 5 6 09
email from elcano wls stating his decision is limited to hearing conduct before judge linda gardner rmc 26405 26800
60302.htm (10.3 KB)
Dear Panel Members and Bar Counsel,

I called Mr. King (he directed me to call Panel Chair Echeverria) today to seek clarification regarding an
earlier approval he relayed to me from Chief Bar Counsel David Clark, wherein Mr. Clark advised me that I,
even though I am a temporarily suspended attorney, have been given permission by the Office of Bar Counsel
to issue subpoenas in connection with this disciplinary matter (ng12-0204, ng12-0434, ng12-0435...odd, can't
recall a single other "case" in all my legal research that had three case numbers....especially where an Order
Denying a Motion to Bifurcate was issued, even before the 5 days for me to file a Reply to the Opposition
(given NRCP is expressly applicable to these matters under the SCR's)...Am I going to find out that my filings
are "too long" under a view that assumes this is "one case" even though there are "three grievance case
numbers" in the caption, and where each "grievance" is fairly rambling? And where the SBN's King purports
this hearing to involve that which the N. S. Ct. Ordered to occur in response to its temporary suspension Order
incident to the SCR 111 Petition for the petty larceny of a "candy bar and some cough drops" (ie, the Court
order that matter, 60838, referred to the Board for a "hearing at which the sole issue to be determined" would
be my punishment for that which was noticed and adjudicated in the 60838 SCR 111 Petition. I believe you
are all now violating Nevada Law in persisting in your denial of my right to such a hearing wherein the "sole
issue" is such, but rather trying to jam me up with this "combo hearing" that seeks to encompass a great deal of
disparate claims (many of which are pending criminal charges, and therefore, entirely outside of your
jursisiction at this point, and your deigning to address them interferes with the orderly administration of justice
in those pending criminal prosecutions, as evinced by Judge Sferrazza's refusal to testify at the November
14th, 2012 Hearing...which is problematic considering Judge Sferrazza presided over the civil summary
eviction matter in RJC Rev2011-001708 that is intimately connect to ALL THREE of the grievances included
in King's reckless, negligent, compromised SCR 105 "Complaint". For instance:
NG12-0204: Richard G. Hill's January 14th, 2012 letter to Bar Counsel King (whom he had just worked on the
Milsner v. Carstarphen matter with (http://law.justia.com/cases/nevada/supreme-court/2012/51631.html)

Today, King admitted to being unaware of who Casey Baker, Esq. is. King also admitted to not having read
any of my filings in any of these connected matters, only to then suggest an analogy along the lines of if a
woman is raped a lot, she is probably a whore and deserves it or wanted it, given the sheer mathematical
improbability of any one woman getting raped over and over, and how King just doesn't get paid enough to
stick his nose into some gangbang, what with the chances of getting himself involved in doing the right thing
where it is just so much easier to sit back and pretend that the Claiborne decision (explicated extensively in my
attached August 13th, 2012 Petition) does not permit Bar Counsel to just throw its hands up and suggest that a
Muni Court conviction (even, in RMC 11 CR 26405, presided over by the brother of the judge whose
sanctions Orders is before you in NG12-0435, and where the brother refused to recuse himself from that
criminal trespass conviction incident to the lies and or attempts to mislead a tribunal by Casey Baker, Esq. and
Richard G. Hill at the June 18th, 2012 criminal trespass trial incident to the civil eviction from Coughlin's
former law office in RJC Rev2011-001708. Asst. Bar Counsel King also admitted that he had failed to even
view the video taped admission by RPD Sargent Lopez that she, Hill, Merliss, and RPD Officer Carter lied in
order to effectuate the wrongful arrest leading to Couglin's conviction by the brother of the sister whose 2009
sanctions Order against Coughlin only became a grievance on March 14th, 2012 (apparently King adopts
Ching as to whom can be an SCR 105 complainant, and therefore within the statute of limitations, when it
comes to Gardner's April 2009 Order, but not when it involves misconduct by a Chairman of the Character
and Fitness Committee of the SBN, Spearmint Rhino owner Kevin Kelly, Esq., whom also owns a Las Vegas
Strip Club that gives cabbies $10 million dollars a year to funnel tourists to it's doors from the airport, and the
misconduct of Peter Christiansen, Jr. and Mike Sanft, and others incident to Coughlin's application for
admission in Nevada, including that of then Director of Admissions Patrice Eichmann, made all the more
feasible by the conduct of Mike Smiley Rowe, Esq. and the fraudulent conduct of Mark Tratos and Mary
LaFrance) when RMC Judge Nash Holmes (in response to prompting by the SBN) passed that three year old
Order (attorneys get sanctioned all the time, such orders do not become grievances as a matter of course, and
the SBN has admitted it keeps no central record of any such grievances) on to Bar Counsel after receiving it
from her co-RMC Judge, and the brother of the family court judge issuing the sanction order...at right about
the time that Coughlin filed that March 7th, 2012 Notice of Appeal (and there is plenty of case law to establish
that a "summary criminal conviction" is a final appealable Order, and the RMC is fraudulently conspiring with
transcriptionist Pam Longoni to violate NRS 189.010-030 by demanding payment up front for such transcripts
by indigent criminal defendants, and Longoni and the RMC's fraud in that regard resulted in Judge Elliot
denying Coughlin's appeal of the Wal-Mart candy bar petty larceny conviction in cr11-2064, wherein Judge
Elliot actually cites to a civil statute related to transcript preparation to justify the RMC's fraud, seen
elsewhere in CR12-1018, further the RMC "lost' Coughlin's Notice of Appeal of the 11 cr26405 criminal
trespass conviction appeal (despite Coughlin having digitial confirmation of the receipt of that fax by the
RMC, and where RMC Rules allows service thereof via that means upon both the Court and the City Attorney
(and Hazlett-Stevens lied about that as well, in addition to the lies he told respecting whether the City Attorney
had received anything from the RSIC following Coughlin's Wal-Mart arrest) in the "summary criminal
contempt" Order stemming from the traffic citation (California roll) trial connected to Coughlin reporting the
admissions of bribery by Richard Hill (RPD Officer Carter stated as much during the November 13th, 2011
criminal trespass arrest, now part of the SCR 105 Complaint, incorporated by reference, one must suppose, by
Hill's NG12-0204 grievance) to the Sargent who retaliated against Coughlin by issuing three traffic citations,
for Coughlin so reporting such admissions by the arresting officer in the trespass matter to the Sargent who
issued the traffic citations to Coughlin incident to Coughlin going to Hill's office to retrieve his keys, wallet,
client's files, and goverment issued identification after being release from 3 days in jail incident to the wrongful
criminal trespass arrest.

Mr. King is beyond incorrect is stating that he will be able to simply point to a criminal conviction and declare
that no inquiry into the legitimacy of that conviction may be made. There is a wealth of case law and
precedent that holds otherwise, and Mr. King has previously been made aware of that. This is true especially
where the convictions at issue completely fail to evince even baseline level of regard for traditional notions of
due process. Simply put, some might say the members of this Panel ought think rather hard before tying their
reputations to the mast that is the extremely low bar required to get a conviction in the Reno Municipal Court
these days....and further, the Panel would be well advised to avoid letting Mr. King lead it down that primrose
path wherein one believes they will be entitled to merely accept a municipal court conviction as conclusive
proof of misconduct or otherwise rule irrelevant any inquiry into the circumstances attendant to such a
matter. This will be particularly true where Mr. King seeks to, in his SCR 105 Complaint, allege matters not
even charged in that Municipal Court criminal trespass proseuction. How Mr. King will be able to allege his
RPC 3.8 violating allegations respecting "breaking and entering" or "broken locks" are relevant or admissible
where Coughlin's dissection of the illegitimacy of the Walmart candy bar petty larceny conviction (supposedly
part of the SCR 105 Compalint....and mentioned in Hill's NG12-0204 grievance...which brings to mind the
question...what of matters not mentioned in any of the three grievance numbers? How are they eligible for
inclusion in some SCR 105 "Complaint' that lacks a unique case number of its own?) Regardless, it is
November 2nd, 2012 and my defense has been irreversibly prejudiced by the refusal of Bar Counsel to allow
me to access the materials at the SBN that are my right to under the SCR, thus bringing the legitimacy of the
entire November 14th, 2012 hearing into doubt, to which any argument that I should be made to fit the bill for
Bar Counsel's bungling and fraudulent failure to follow the rules applicable to this matter, in addition to its
own written attestations, is entirely unsupportable.

Regardless, Richard G. Hill, Esq.'s hench man, Casey Baker, Esq., now that the heat is on and he and Hill's
avarice driven misdeeds are finally facing the oversight they deserve, has now suddenly fled back to
Kentucky:
http://www.nvbar.org/lawyer-detail/11271

It was Baker whom Hill used to file the November 21st, 2011 and January 20th, 2012 filings in RJC Rev2011-001708 and the appeal thereof in CV11-03628 to make the allegatons that
Hill himself knew unwise to make in his own regard within a sworn Declaration...So, despite Hill, not Baker, having the eye witness knowledge of such events (like whether the RPD
identified themselves as law enforcement and issued to Coughlin a lawful warning to leave at the risk of a criminal trespass citation or arrest prior to the landlord kicking down the
door to a quasi "basement" under the property that Baker's own testimony at the June 18th, 2012 trespass trail admits lacked any sort of exterior lock, and thus would require no
"breaking of any sort" of the type both Susich and King suddenly felt the need to allege when considering how terribly compromised their 60975 Petiton and the instant SCR 105
"combo-grievances" (kind of like a "due process value meal" that Pat King is serving up, and asking this Board to co-sign...which, apparently the Chairman finds fitting....what's next,
are you going to have lawyers dress up in Hot Dog on a Stick employee uniforms (you know, rainbow colors, the spinning thing atop the hat, etc.) too? Is that how little the property
right of a law license (case law declares it as much under the Fourteenth Amendment, and any willful deprivation thereof by this Board, including a deprivation of the due process
required to impinge thereupon, can subject the members of this Board the 42 USC Sec. 1983 liability, especially where, as her, what appears to be a coordinated effort to obstruct
justice and proceed impermissibly under color of law for the self interested aims of those leveraging such positions is apparent. RICO.

I am writing to request confirmation of what I believe Mr. Clark has previously rule, ie, that I, as an indigent respondent herein, am not required to pay witnesses any sort of "witness
fee" in issuing and or serving subpoenas and subpoens duces tecums upon them in connection with the November 14th, 2011 Hearing in this matter. I feel Hill's then associate Casey
Baker, Esq's testimony will be particular necessary to this hearing (especially where Hill admits himself that he was not present at the purported November 1st, 2011 "lockout" in the
eviction matter (and the service of an receipt by the WCSO with respect to any such lockout Order is of material relevance, as NRS 40.253 requires such an Order be carried out
"within 24 hours of receipt" thereof...and Baker's testimony at the June 18th, 2012 criminal trespass trial, in combination with previous statements by the Washoe County Sheriff's Office
(and please add these individuals and matters to my designation fo witnesses and summary of evidence to be presented) Supervisor Liz Stuchell, Roxy Silve, Deputy Machen, and
administrators, supervisors, and clerks at the Reno Justice Court (RJC) add up to the fact that it was Hill, Baker, and the WCSO, and RPD that were trespassing, not Coughlin, at
Coughlin's former home law office. Attached it the video taped admission by RPD Sargent Lopez respecting the lies by her, RPD Officer Carter, Hill, Merliss, and Baker leading to
Coughlin's arrest and conviction for criminal trespass. Keith Loomis will need to answer for his failure to fulfill the Sixth Amendment in that regard, in addition to the content of the
unapproved and impermissible "meeting" with RMC Judge Gardner and City of Reno Prosecutor wherein, upon information and belief, an "approach" to handling the criminal
trespass trial of Coughlin was "developed" shortly before the April 10th, 2012 Trial date in that criminal trespass matter (a Trial date which violated Nevada law, anyways, in that it was
set and held during the pendency of an Order for Competency Evaluation of Coughlin in violation of NRS 178.405 and NRS 5.010). Any trier of fact that wishes to attempt to pull the
wool over Coughlin's eyes, make incongruous and patently compromised, often sua sponte relevancy rulings, or otherwise cook up a due process value meal may wish to ask RMC
Judge Gardner how the recent filings by Coughlin in 61901 and the RMC 11 CR 26405 are tasting right about now. Or get Judge Howard's inpute with respect to the analysis of his
work in 60838. And Judge Nash Holmes may be able to provide some insight as to how that approach served her, particularly where her "criminal summary contempt" order was
made during the pendency of an Order for Competency Evaluation, and cites to alleged conduct committed outside her immediate presence (and that's the thing about "summary
adjudications"....the are so arbitary and devoid of due process that the requirements attendant thereto must be stricly adhered to....so when Judge Nash Holmes in here Orders in 11
TR 26800 of 2/28/12 and 3/12 3/13, and 3/13/12 refers to some RMC Marshal allegedly peering, Peeping Tom style, through a bathroom stall wherein Coughlin was during a
restroom break within that trial, her Order fails to adhere to the dictate that each element of any conduct she deigns to summarily rule upon be committed in her "immediate
presence"...otherwise, someone would have to sign an Affidavit like a grown up, and Coughlin would be entitled to a hearing, and likely appointed counsel under the Sixth Amendment
before some Bar Counsel like King could attempt to prop up any such "conviction" in an attempt to lend it an air of respectiability, especially where that Marshal Harley (whom King
conveniently has failed to subpoena) had his own self interested reasons for seeking to discredit Coughlin (RMC Marshal Harley violated the "courthouse sanctuary" rule and
contributed to an appearance of impropriety where he served Coughlin an Order to Show Cause incident to one of Hill's fraudulent Motions seeking to abuse process in hopes of
remaining competitive with an actual attorney like Coughlin (rather than a known hack like HIll whom inherited a law practice from his father and who legion of local attorneys accuse
of unneccesarily running up fees on his clients by purposefully overcomplicating litigations and engendering an adversarial stance amongst litigants designed to line Hill's pockets,
and those of, apparently, even his legal assistans, whom drive $130,000 Mercedes v12 SL-600 sport coupe convertibles to crack inspections of law offices incident to impermissible
summary evictions of commercial tenants where Hill chose to proceed under a No Cause Eviction Notice (along with Baker) rather than a Non Payment Notice, and therein committed
a "wrong site surgery" (in a litigation sense, to borrow some of the parlance of the landlord, Dr. Merliss's field, wherein he is a Neurosurgeon/Neurologist in Chico, CA, apparently
armed with enough money to choose to run up $60,000, as of April 2012 in fees ot HIll and Baker in these matters rather than settle with Coughlin for the $1,500 Coughlin offered
him).

Please add to the witness list all the individuals mentioned in the various filings I have provided you, including, but not limited to RPD Officers Duralde, Rosa, Alaksa, Weaver,
Look, Travis Warren, and Leedy, RPD Sargent Tarter,Lopez, Sifre, Oliver Miller, Dye, and Bradshaw, Hill's Associate Casey Baker, Sheri Hill, and to be deterimined members of HIll's
staff (particulary those with knowledge of any matters connected to the receipt of either of the Eviction Orders by the WCSO in the eviction matter, WCPD Jim Leslie, Biray Dogan, Joe
Goodnight, Walmart Thomas Frontino and ASM John Ellis, and a yet to be determined AP Associate whom, along with Ellis, made express threats to retaliate against Coughlin with
abuse of process similar to the petty larceny candy bar conviction in 60838 that currently forms the only basis for the suspension of Coughlin's law license and for which this Panel and
the SBN are violating Nevada law in persisting in refusing to follow the dicates of both the Supreme Court Rules of Nevada and the Court's June 7th, 2012 Order in 60838, but rather,
like Clerk/"reluctant" Investigator Peters, are allowing themselves to be led down that primrose path that Pat King finds to pleasurable to take the unwitting along in his social climbing
and life of ease and comfort, devoid of honor or intergrity, approach to life...Also, to the extent then Panel considers a pending criminal prosecution up for inquiry in a disciplinary
proceeding, included in potential witness call may call are Nicole Watson, Lucy Byington, Nate Zarate, Cory Goble, the individual whose phone number is 7753786673, Colton
Templeton, Robert Dawson, Nick Duralde, Ron Rosa, Thomas Alaksa, Savannah Montgomery, Linda Gray, Kelly Odom, Kariann Beechlker, RPD Officer Schaur and any others present
at arrest of 1/14/12 for "misuse of emergency communications", and of the 5-6 officers whom, along with RPD Duralde pulled Coughlin over upon his release from jail on 1/13/12 for
the 1/12/12 "jaywalking" arrest made upon the fraudulent assertions of Richard HIll, RJC Judge Jack Schroeder (whom evicted Coughlin from Park Terrace and granted Hill the
protection order incident to the jaywalking arrest and who yelled "do you want to go to jail" at Coughlin at the extension hearing when Coughlin broached the topic of Hill's abuse of
process, and whom wrongfully granted the 6/27/12 Eviction Order in RJC Rev2012-001048 despite the deficient 5 day notice listing the wrong court to file a tenan'ts affidavit (a
requirement under NRS 40.253, and despite Coughlin's numerous calls and 6/26/12 email to the RJC, SJC, RPD and WCSO, also Jeff Nichols and Peter Eastman and Paul Freitag, Esq.
(involved in SBN King's impermissilbe disclosures and slanderous statements concerning Coughlin and the NVB (which King also made to his boss in front of Coughlin, David Clark,
and which have proven to be baseless, despite King ticking such off amongst the top 2 reasons for the SCR 105 Complaint he alleged he would hurriedly throw together upon
Coughlin serving King, the SBN, Clark and Peters the August 13th, 2012 filing in 60838 and 61426, now before the N. S. Ct.). Also, Richard Cornell, Tom Hall, Geof Giles, and Michael
Lehrners, Judge Joe Van Walraven and others all whom have indicated, to one degree or another, that Hill's conduct incident to this eviction matter and concomitant appeal is
Close
deplorable and entirely consistent with the way Hill has comported himself throughout his 33 year career, which began with is inheriting a large scale law practice from his father, and
continued on with Hill effecting the manner of a 10 year old boy entrusted with flying a 747 full of people, to this day. Add to the witness List Paul Elcano of WLS, Judge Steven Elliot,
Judge Patrick Flanagan, Hale Lane/Holland and Hart's Anthony Hall and Tim Lukas, Richard Elmore, Judge Scott Pearson, Judge Peter J. Sferrazza (though he indicated on 10/22/12
that he declined the SBN's request that he testify, citing his sitting on the pending criminal prosecution in RCR2011-063341), the RJC's Bonnie Cooper and "Nevi", Chief Bailiff Michael
Sexton, RMC Chief Marshal Roper and Marshal Deighton, Marshal Thompson, Marshal Coppa, WCDC Van der Wal, Beatson, Hoekstra, Cheung, unnamed deputies. Further, please
add Western Nevada Management's Sue King, Jared Scalise, and Park Terrace Townhomes Association attorney Gayle Kern, Esq., Roberto Puentes, Lew Taitel, the RMC's Matthew Fisk
and Cassandra Jackson, Donna Ballard, Judge Howards past legal assistant, Judge Nash Holmess legal and administrative assistant, Martin Crowley or Martin Weiner or whichever
attorney is was Judge Nash Holmes was sued for wiretapping in the past, the RMC counter clerk "Daniel" and "Thom", WDC Chief Appeals Clerk Matheus, Joey Orduna Hastings, Chief
Judge David Hardy, Justice Hardesty (whom was one of only three Justices signing the June 7th, 2012 temporary suspension Order, but whom recused himself from 60302 and 60317,
the wrongful termination suit against Washoe Legal Services (see attached letters from WLS's Executive Director citing Judge Linda Gardner's April 2009 Order sanctioning Coughlin as
the "sole reason" for Coughlin's firing (her brother, RMC Judge William Gardner refused to recuse himself from the criminal trespass conviction mentioned in in King's SCR 105
Complaint, and King admitted two weeks ago that he was unaware that the two Judge Gardners were brother and sister or related whatsoever, or that Judge Nash Holmes was a
prison warden or something similar for ten years, and a lifelong prosecutor besides that (in addition to all other RMC Judges and all RMC court appointed defenders).

Also, I never received any Notice of Intent to Take Default from the SBN, and herein lodge my objection to any Order by this Panel that cites thereto. Additionally, SBN's Peters has
indicated no other respondents have ever been made to pay witness subpoena fees, and further Peters and the SBN have repeatedly failed to adhere to agreements they have made
with Coughlin (including the failure of the SBN to resend a certified mail copy of the SCR 105 Complaint incident to the agreement between Peters and Coughlin on or about
September 11th, 2012.

Sincerely,

Sincerley,
skent@skentlaw.com, mike@tahoelawyer.com, nevtelassn@sbcglobal.net, patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
Subject: RE: Records
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Print
From:
Sent: Wed 9/07/11 9:36 PM
temporary report number is T11005956.
system.
Online Officer
Your Online Police Report T11005956 Has Been Rejected
From:
Sent: Wed 9/07/11 10:51 PM
We're sorry the following problem was found during review
of your submitted report T11005956:
THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT
WILL BE ADDRESSED.
Thank you,
Officer WOZNIAK,
From:
Sent: Sun 1/08/12 1:35 AM
system.
Online Officer
From:
Sent: Sun 1/08/12 2:25 AM
system.
Online Officer
From:
Sent: Sun 1/08/12 2:47 AM
system.
Online Officer
From:
Sent: Tue 1/10/12 12:29 AM
system.
Online Officer
From:
Sent: Tue 1/10/12 1:04 AM
system.
Online Officer
From:
Sent: Wed 1/11/12 3:09 PM
1 attachment
report-120100300-0.pdf (76.4 KB)
120100300.
Online Officer
From:
Sent: Wed 1/11/12 3:29 PM
1 attachment
report-120100300-1.pdf (76.4 KB)
120100300.
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From:
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1 attachment
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120100300.
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From:
Sent: Wed 1/11/12 3:32 PM
1 attachment
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120100300.
Online Officer
From:
Sent: Wed 1/11/12 3:35 PM
1 attachment
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120100302.
Online Officer
From:
Sent: Fri 6/08/12 4:39 PM
system.
Online Officer
From:
Sent: Fri 6/08/12 4:45 PM
system.
Online Officer
From:
Sent: Mon 6/11/12 4:10 PM
1 attachment
report-120103420-0.pdf (71.4 KB)
120103420.
Online Officer
From:
Sent: Mon 6/11/12 4:11 PM
1 attachment
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120103420.
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From:
Sent: Fri 9/21/12 8:09 PM
system.
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From:
Sent: Fri 9/21/12 8:49 PM
system.
Online Officer
From:
Sent: Thu 10/04/12 3:42 PM
1 attachment
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120105605.
Online Officer
From:
Sent: Thu 10/04/12 3:54 PM
1 attachment
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Close
120105605.
Online Officer
Print
RE: release of information to my attorney
From:Goodnight, Joseph W (JGoodnight@washoecounty.us)This sender is in your safe list.
Sent: Wed 5/02/12 4:45 PM
Mr. Coughlin,
MHC has received your referral and diagnosis from Ascent NBI. The MHC coordinator indicated that your case will be added to Friday's staffing and your application "looks fine." I
take that to indicate that you'll likely be accepted. I have a call in to DDA Young to re-open negotiations. This is what I intend to present for a global resolution:

Parties will agree to transfer jurisdiction of RCR11-063341 (RJC Misdemeanors) to MHC. DDA Young will defer prosecution of RCR12-065630 (misuse of 911) and upon successful
completion of MHC, will dismiss with prejudice. City prosecutor in Reno Municipal Court case (Trespass) will defer prosecution and upon successful completion of MHC, will
dismiss with prejudice (your attorney, Mr. Loomis, should advise you regarding this case).

Is that acceptable to you? If not, please let me know immediately.
Sincerely,
Joe Goodnight

**********************************************************
Joseph W. Goodnight
Deputy Public Defender
(775) 337-4839
jgoodnight@washoecounty.us
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521,
and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent
responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review,
dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited.
Sent: Wednesday, May 02, 2012 2:28 PM
To: Goodnight, Joseph W
Subject: FW: release of information to my attorney
Joe,

Here is Yassars assistants update. I am in favor of a global resolution. regarding mental health court, do
they attemt to take over ones medical care or second guess ones doctor on health care matters? what is the
worst case scenario with mental health court? lets say one does not do well in it, does that defendnat then
get tried in justice court as they would have before entering mental health court? can the mental health
court sentence one to jail?

thanks,

> From: megan@ascentreno.com
> To: ZachCoughlin@hotmail.com
> Subject: RE: release of information to my attorney
> Date: Wed, 2 May 2012 14:22:06 -0700
>
> Zach,
> I have not had time to type up the letter due to the high volume of patients and calls in the office. I will get to the letter as soon as I get a chance . The attorneys office did call
prior to you showing up in the office and due to that I did not have a release to talk with them regarding your diagnosis or treatment I told them I would have to get that first.
>
> Megan Sredy
Close
>
> Megan Sredy
> Patient Coordinator
> Ascent NBI & TMS Center
> 540 West Plumb Lane, Suite 1A
> Reno, NV 89509
> Phone (775) 322-4666; Fax (775) 322-4747
>
>
> IMPORTANT:
> This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the
individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately, and delete the message and any attachments.
Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited.
>
>
>
> -----Original Message-----
> From: zach coughlin [mailto:ZachCoughlin@hotmail.com]
> Sent: Wednesday, May 02, 2012 2:06 PM
> To: ecek@ascentreno.com; megan@ascentreno.com
>
> From: zach coughlin <ZachCoughlin@hotmail.com>
> Phone: 7753388118
>
> Message Body:
> ----------------------
>
> My attorney sent me the following earlier today
>
> > Mr. Coughlin,
> > I have not received anything from Dr. Yassar's office. I called again and left a message with them to contact me regarding the release. I'd like confirmation of the diagnosis
today so I can submit your MHC application (again, due on Wednesday for staffing/acceptance meeting on Friday). Would you like me to try submitting your application without
the diagnosis? Perhaps this would achieve a conditional acceptance pending receipt of the diagnosis. Let me know.
> > Sincerely,
> > Joe Goodnight
> >
> > PS - I don't know about your second question regarding RMC contact.
> >
> > **********************************************************
> > Joseph W. Goodnight
> > Deputy Public Defender
> > (775) 337-4839
> > jgoodnight@washoecounty.us
>
>
>
>
>
> Note, above is Joe Goodnights telephone number and email.
>
>
>
> --
> This mail is sent via quick contact form on Ascent Reno Psychiatry http://ascentrenopsychiatry.com
>
Print
RE: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?
Sent: Mon 2/27/12 3:27 PM
Mr. Coughlin:

E-mail works well for me.

Keith Loomis

Sent: Monday, February 27, 2012 7:56 AM
Subject: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?

hi, i guess Mr. Loomis was appointed as my 3rd defense attorney in RMC case 11 cr 26405. I have not heard anything about this case, and the RMC indicated they had
nothing scheduled. Please communicate with me only via email or fax please, having issues with my mail incident to domestic violence committed against me my fax is
949 667 7402. thanks,
Zach Coughlin
court date
Sent: Mon 3/05/12 4:09 PM
Mr. Coughlin:


Keith Loomis
RE: court date
Sent: Wed 3/07/12 4:36 PM
Mr. Coughlin:

On what grounds, other than those already set forth in your existing motion, do you believe a motion to dismiss should be filed?

Keith Loomis

Sent: Wednesday, March 07, 2012 12:45 AM

Mr. Loomis,
Please copy me on any and all correspondences, filing, or other documentation or verbal requests,
correspondences, etc. that you submit to the Court, including the one you reference below. Please do not
follow Taitel's tact of agreeing to requests or failing to oppose motions without even attempting to obtain my
permission to in advance thereof.
I would like for you to draft a Motion to Dismiss in this case for me review.
Thanks,
Subject: court date
Date: Mon, 5 Mar 2012 16:09:19 -0800
Mr. Coughlin:


Keith Loomis
RE: court date
Sent: Fri 3/09/12 10:14 AM
No worries. Made me laugh.

Couple of questions:

Did you file an appeal from Justice of the Peace Sferrazzas eviction order?
If yes, has it been resolved?

Did Sferrazza announce at the close of the hearing on the 25
th
that he was granting the eviction and ask Hill/Baker to provide a written order?

Did you ever see the eviction order posted by WCSO
If yes, when?

What is relevance of personnel files of Carter or Lopez?

How is Dr. Merliss testimony material to the defense of this case?

Keith Loomis


Dear Mr. Loomis,
etc....
PEACE

Trial Date
Sent: Fri 3/09/12 10:44 AM
1 attachment
Coughlin Trial Setting.pdf (771.8 KB)
See attached
RE: Trial Date
Sent: Mon 3/12/12 9:26 AM

Keith

Subject: Trial Date
Date: Fri, 9 Mar 2012 10:44:17 -0800
See attached
RE: court date
Sent: Mon 3/12/12 10:02 AM
This e-mail is sent to address the grounds you identified as forming the basis of a motion to dismiss. As you know there is both a constitutional right and a statutory right to a
speedy trial. This case is nowhere close to a violation of the constitutional right to a speedy trial. The statute does provide for a right to trial within 60 days of arraignment in
municipal court. NRS 178.556(2). In this circumstance the court may dismiss the complaint. The statute requires, however, that the trial not have been postponed at the request
of the defendant. It is my understanding that the January 10, 2012, trial date, was postponed at your request. If that is true then there are not grounds to dismiss on the basis of
a violation of a right to speedy trial.

Dismissal based on spoliation is a civil concept. It has not been applied to criminal cases in Nevada as of yet. See Higgs v. State, 126 Nev. Adv. Opn 1 (2010). Rather defendants
in criminal cases are protected from the loss of evidence in the hands of the prosecution by the doctrine of due process. Consequently you might have a basis to request
dismissal if the City Attorneys Office lost evidence, in its possession material to the case. In such case if the City acted in bad faith or with connivance or if you were prejudiced by
the loss then there may be grounds on which to base a dismissal. Please advise as to what evidence was lost and how it was lost.

You have not identified any other grounds as a basis for dismissal. If you believe there are other grounds, let me know.

Thanks

Keith Loomis


Dear Mr. Loomis,
etc....
PEACE

RE: Trial Date
From:Keith Loomis (keithloomis@earthlink.net)You moved this message to its current location.
Sent: Wed 3/14/12 2:35 PM
Dear Mr. Coughlin:

My obligation under Nevada Rule of Professional Conduct 1.2 is to abide by a clients decision concerning the objectives of representation and, as required by Rule 1.4 to consult
with the client as to the means by which the objectives of representation are to be pursued. In a criminal case the lawyer shall abide by the clients decision, after consultation
with the lawyer, as to plea to be entered, whether to waive jury trial whether the client will testify.

Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any relevant limitations on the lawyers conduct when the lawyer knows that the client expects assistance not
permitted by the Rules of Professional Conduct or other law.

Under Rule 2.1. In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In rendering advice, a lawyer may refer not
only to law but to other considerations such as moral economic, social and political factors, that may be relevant to the clients situation.

Under Rule 3.1. A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not
frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for a defendant in a criminal proceeding that could result in
incarceration, may nevertheless so defend the proceeding as to require that every element of the case be established.

Under Rule 3.2(a) and (b). A lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.
The duty stated in paragraph (a) does not preclude a lawyer from granting a reasonable request from opposing counsel for an accommodation, such as an extension of time, or
from disagreeing with a clients wishes on administrative and tactical matters, such as scheduling depositions, the number of depositions to be taken, and the frequency and use
of written discovery requests.

Under Rule 8.4(d) It is misconduct for a lawyer to engage in conduct which is prejudicial to the administration of justice.

These, and others, are the professional rules I operate under in providing legal representation to you in case number 11 CR 26405, a case in which you are charged with the crime
of trespass. It is my understanding that your objective in this criminal case is that you be acquitted of the crime of trespass. That is my purpose in representing you. I am happy
to work towards that outcome to the best of my ability. It is my opinion, however, that much of what you ask to be done is not in compliance with the above rules. Accordingly, I
will not be filing a motion to dismiss based upon NRCP 6(a) and (b), I see that argument as frivolous. I will not be proceeding with the summoning of an out-of-state witness
(Merliss) unless you can establish his materiality to the defense. Nor will I be subpoenaing the personnel records of law enforcement personnel unless you can establish to my
satisfaction why they are relevant to this case. I have no intention at this time of conducting any depositions in the case or sending requests for production of documents or
interrogatories in the case. I see these actions as unduly burdensome on the judicial system, and unwarranted by anything you have provided to this point. I also see them as
frivolous and an attempt to utilize the criminal justice system to accomplish objectives not relevant to my purpose in representing you.

If you are dissatisfied with the limitations I perceive to exist regarding my representation of you, you are welcome to terminate my representation of you. You may then ask the
Court to appoint a new lawyer to represent you.

It is my understanding that Deputy Machem will be testifying in the case along with Richard Hill and Casey Baker.

I do think that there are some interesting angles to the case upon which a defense can be based and I will be pursuing those angles. I have asked you in previous e-mails to
provide information which I believe will be helpful to the defense of your case.

I advise you that the City has offered to recommend time-served as a sentence if you enter a no-contest plea to trespass. It is also my understanding that you have other criminal
cases pending in both Reno Justice Court and in the Second Judicial District Court of the State of Nevada. It is my understanding further that all of the criminal cases can be
resolved in a single plea to a misdemeanor offense if you will obtain psychological counseling. It is my obligation to inform you of the availability of these resolutions to the
present criminal case in which I provide representation. I will, of course, abide by your decision as to whether to accept these resolutions or not.

I note that there is a psychiatric evaluation scheduled for you in 2
nd
Judicial District Court Case No. CR12-0376 on April 3, 2012. The outcome of that evaluation could have an
important impact on this case. I am asking that you authorize a release of the information contained in the evaluation to me so that I may determine what impact it could have on
your behalf in this case.

I remain prepared to represent you in the trespass case. I think that a trial of the case will be interesting. My representation, however, is circumscribed by the Nevada Rules of
Professional Conduct.

Keith Loomis

Sent: Tuesday, March 13, 2012 4:29 PM

Dear Mr. Loomis,

In your motion to dismiss, I would like you to really focus on and set forth to the court the fact that the eviction order needed to
be served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of
Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with the provisions of NRS 40.220 to 40.420, inclusive, apply to the
proceedings mentioned in those sections.

The language about "removing the tenant with in 24 hours of receipt of the order" is only applicable to those situations where the tenant does not file a Tenant's Answer
or Tenant's Affidavit. I did file such a Tenan'ts Affidavit, and litigated the matter thoroughly. In those situations, NRS 40.400 requires NRCP to apply, specifically NRCP
6(a) and 6(e), and clearly WCSO Machem (please subpoena and identify as witnesses Mary Kandaras, Esq. of the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO
Civil Division supervisor Liz Stuchell for the trial in this matter, and further send out a request for production and subpoena duces tecum to the WCDA and the WCSO
askign them to specify, in writing and in detail, the exact procedures and policies in place with respect to the service and conducting of such lockouts (ie, not default
lockouts where there is not a summary eviction hearing, but one's like the present one, where there was a Tenant's Answer and hearing held, etc....). Be sure to ask
whether the are aware of what "personally served" means, and whether they mail the Orders on top of merely posting them to the door. Further, I have been told that
the WCSO has a policy or penatly system in place whereby the deputies must get these lockouts performed "within 24 hours of receipt of the order" the receipt being
the WCSO's receipt, and not the tenant's receipt. I don't ncessarily read the statute that way, but....the WCSO policy and punishment system would be at least some
indication of what the legislature meant (I guess, but I dont' really think so, though, you will note that Hill was left with nothing but citing to the "usual and customary
practice of the WCSO" in serving the Eviction ORders and performign lockouts, I believe, because the law does not contain much to support Hill's contention and
therefore he wishes to see the WCSO "customary practices" being given the weight of law.

Please see some specific selections attached from the eviction matter. I know, I know, you want to curtail the scope of your representation to an immaculate
degree....but Hill can clearly be seen in his various Motion to Show Cause, State Bar Grievances, Temproary Protection Order Applications, etc., etc., to be a punk who
doesn't much like competing on an even playing field, like any good private schooler, he would rather sick an attack dog on somebody than get in the octogon and go toe
to toe mentally. Regardless, Hill shows a continual desire to subvert NRCP 6(e), which applies to service of documents filed elecronically in the Second Judicial District
Court. He would rather withhold opposing counsels computers, laptops, client files, driver's license, etc. The last thing he wants is to go argument for argument,
research for research, writing for writing. Private school and daddy's pleading bank. Hill files a Motion to Show caue allegeing Coughlin subvreted an Order that was
filed on January 11th, 2012 with Couglin's action of January 12th, 2012. Under NRCP 6(e), the Order Denying the TRO had not even been served yet, and there has been
no indidcation that Hill gave the Order at the town dump to anyone other than an RPD Officer.

Further, it is not all that clear why Hills Motion for ORder to Show Cause deserves a full blown hearing when D7 does not indicate a hearing will be accorded to the
appeal. This is particularly suspect given that Anvui sets forth that appeals in summary eviction matters are done on a trial de novo basis.
There are a number, but how about your complete lack of communication with me prior to so setting that date. How about Mr.
Taitel and Mr. Puentes's failure in this matter and the prejudice to my case so created? How about your failing to identify yourself
as the public defender to a room full of defendants in jail at the arraignment?
There are other reasons as well, including, but not limited to, your resistance to subpoena the materials I have and am requesting.

I wish for you to subpoena the personnel files of both RPD Sargent Monica Lopez and Officer Chris Carter. I wish for you to list Dr.
Merliss as a witness and subpoena his appearance and appropriately notice the City of Reno in that regard, same goes for Richard
Hill and Casey Baker (Baker, by letter dated November 10th, 2011 demands the full rental value for the property as "storage" under
NRS 40.253, while also asserting he will go after moving and inventory costs, in addition to Hill's contractor Phil Stewarts later
ridiculous charges and perjury. Please subpoena Stewart as well.

Most importantly subpoena Washoe County Sheriff's Office Deputy Machem to testify and serve a subpoena dueces tecum,
requests for production, and interrogatories seeking records and responses from the WCSO as set forth in the letter I sent Liz
Stuchell (see attached) on or about February 10th, 2012. You see, the WCSO and Deputy Machem may be committing a fraud
upon the public by repeatedly filing affidavits of service that attest to personal service where Liz Stuchell, of the WCSO admits that
they clearly do not know, or choose to "remix" the legal meaning of "personally serve".

Further, please inform the City of Reno and appropriately notice the same as to the existence and intent to offer into evidence a
video of Richard Hill, Esq., admitting that he and his firm, on behalf of Dr. Merliss, were withholding the accused personal property,
in addition to the client's files from the former commercial lease home law office of the accused and asserting a lien, under NRS
40.253 for "storage", however, as the video tape shows, Hill admits to charging the undersigned the same $900 per month rent as
was charged for the "full use and occupancy" of the premises at 121 River Rock St., Reno, NV 89512. Hill further demands that
property be removed in a certain order, regardless of whether his articifically inflated lien was paid or not. Additionally, Hill
committed fraud upon the court in a number of instances and filed false police reports wherein he alleges that he agreed to or
otherwise made available to the accused items such as the accused's clients files (and for a time wallet and state issued driver's
license) where, clearly, without requiring any payment by the accused, however, clearly, the facts show that Hill never actually lived
up to those assertions and repeatedly failed to show provide such items absent payment of his artifically inflated lien.

Further, I wish for you to divulge and provide notice that it is available for pickup and that we intent to introduce into evidence a
video of RPD Sargent Monica Lopez admitting that she and RPD Officer Carter did not identify themselves as police officers or
otherwise ask the accused to leave 121 River Rock St. on the date of the arrest prior to Merliss opening the door to the basement.
This is apparently in direct contradiction to the sworn filings made by Richard Hill, Esq. in his affidavits attached to his various
Motions to Show Cause, the Reply to Opposition thereto, Opposition to TRO, etc., etc. (in RJC Rev2011-001708 and the appeal in
CV11-03628). For that reason alone Merliss' presence is required. He was a precipient witness and you are asking me why he
should be there? You have a duty to zealously advocate on my behalf, Mr. Loomis. You are paid, by the public, to do so. Please
divulge any prior associations you have with anyone employed by or workign as an independent contractor with the RMC and or
the Reno City Attorney, including anyone you went to law school with or attended the same law school as, within a 5 year period.

Further, I wish for you to file a motion seeking a mistrial or otherwise requiring the recusal of the RMC and further disclosing why it
is that Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth recuse Judge Dilworth?) in one case,
without detailing why exactly, while Judge Gardner apparently is intent on remaining on in 11 CR 26405, despite the fact that an
apparent conflict exists, one which he only disclosed upon prompting from the accused, with respect to Judge Gardner's very
recent employment with the Reno City Attorney's office and the existing and or brewing litigation (or, at least, possible litigation)
between the accused and the City of Reno, Reno City Attorney, and possibly, the RMC.


Date: Mon, 12 Mar 2012 09:26:35 -0700

Keith

Subject: Trial Date
Date: Fri, 9 Mar 2012 10:44:17 -0800
See attached
Sent: Wed 3/28/12 2:03 PM
Dear Mr. Coughlin:

This message is sent to address issues raised in the e-mail you sent on 3-26-12.

1. Please note that you are free to send the communications you send to me, to anyone else you desire. You should be aware that sending your communications to other
parties will cause your communications to me to lose their attorney-client confidentiality.
2. For what specific purposes do you need a continuance? A continuance purely for the purpose of delay is not a proper reason for a continuance.
3. Whether you are entitled to e-mail the Reno Municipal Court is not my concern. That is a problem to be addressed between you and the Court.
4. Ms. Drake is no longer the attorney handling your case for the Reno City Attorneys Office. Your case is now being handled by Christopher Hazlett-Stevens, Esq.
5. In response to your question regarding the weaknesses of the trespassing case I offer the following:
a. The complaint is deficient in that if fails to set forth the elements of the crime of trespass. It fails to identify whether your presence on the premises was for the
purpose to vex or annoy the owner or occupant of the premises or whether it was an entry onto the premises after a warning not to so trespass. This is probably easily
remedied by an amendment at the time of trial. Nevertheless these are alternative theories on which a trespass case can be pursued and the defendant is entitled to
know on which theory or theories a case is being prosecuted in advance of showing up for trial.
b. You filed an appeal on October 19, 2011, apparently, of the order made by Justice of the Peace Sferrazza on October 13, 2011. That order denied your request for a
continuance and granted summary eviction unless you filed a deposit with the court. Typically the courts lose jurisdiction to rule on other matters in the case once an
appeal is taken. It is clear from the court records that this appeal was pending before the Second Judicial District Court at the time the court held a hearing on the
unlawful detainer on October 25, 2011. It may well be that the Justice Court lost jurisdiction to hold the eviction hearing while the appeal was pending.
c. I am working on some other thoughts.
6. If you are dissatisfied with the way I am representing you, you remain free to seek a new attorney.
7. Another chuckle regarding my ownership of strip clubs. I dont own or have any ownership interest in any strip clubs, brothels, adult book stores or movie houses. I
guess that leaves me free to moralize.
8. I still dont see the importance of Dr. Merliss. The request for payment of an amount equal to rent, was for storage of your personal property. You are entitled to
contest the amount of the storage fee, which you did. There is no credible evidence anywhere which suggests that anyone intended to reopen or create a new tenancy
allowing you to retain possession of the premises.
9. Dr. Merliss is an out of state witness. In order to compel his appearance, his testimony must be material. NRS 174.425(1). It does not appear that his testimony is material
under the information you have provided Further, under NRS 174.425(2) he is entitled to be paid his subsistence and travel expenses incurred in coming to Nevada. Are
you prepared to pay those expenses in advance of his coming to Nevada?
10. I dont intend to fax or e-mail to you, your full file in this case. You already have everything with the exception of a couple of items which I mailed to your old address. I
will send them again to your new address. If you want to review the file you are welcome to do so at my office. If you want copies of anything in the file you may mark
the items. After giving you a cost estimate, for which I require payment in advance, we will provide you with copies of the marked items.

Keith Loomis

Sent: Monday, March 26, 2012 10:33 PM
To: keithloomis@earthlink.net; stermitz@sbcglobal.net; jmd@randazza.com; jboles@callatg.com; kristiemanning@yahoo.com; kadlicj@reno.gov
Subject: i was evicted 3 15 12, i need a continuance

Dear Mr. Loomis,
I was wrongfully evicted on 3 15 12, and I need a continuance in the criminal trespass matter that you set overly
quickly against my express wishes anyway. My ability to collect evidence necessary to my defense and
otherwise prepare has been adversely affected. Additionally, I don't feel as though you are performing in an
appropriate manner as defense counsel, but rather you seem stuck in your prosecutorial ways, too quick to look
for any excuse whatsoever to bury one's case, so I think you have forced a split here, which further prejudices
my case and augers towards a continuance. Please move for one immediately and copy me on my entire file
by email and fax please. Additionally, please seek clarification from the RMC as to whether I am allowed to ever
send an email to renomunicrecords@reno.gov. Please note, today, Judge Flanagan denied Richard Hill's latest
frivolous motion.
Did you know that Kevin Kelly, of the State Bar of Nevada's Character and Fitness Committee for at least the last
decade owns and runs the Spearmint Rhino strip club in Las Vegas:
http://www.reviewjournal.com/lvrj_home/2002/Mar-06-Wed-2002/news/18241452.html
I know I always like my three hour tours of heavy handed moralizing from someone who runs a monolithic strip
club in Las Vegas.
You are on the State Bar of Nevada's fee dispute committee, aren't you Mr. Loomis? Do you own any strip
clubs?
Mr. Loomis, which of the elements of the trespass charge RMC 8.10.040 do you feel are weakest for Deputy
City Attorney Jill Drake, whom I informed about the admission by Reno PD Officer Chris Carter that Richard G.
Hill, Esq. bribes him, but for which Ms. Drake indicated a complete lack of interest and expressed that she
would not be following up on that report of bribery of a RPD Officer. Mr. Kadlic, please place a copy of this
correspondence in Jill Drake's personnel file. Additionally please place one in Allison Ormaa's personnel and
employment file too, in addition to Deputy City Attorney Dan Wong's employment file, as all three of those
Deputy City Attorney's were provided that report and all three indicated they did not care and had no
intention of following up or otherwise investigating the admission by RPD Officer Chris Carter that Richard G.
Hill, Esq. bribed him. I think the failure to follow up by any of these 3 Deputy City Attorney's relates to any
future negligent hiring, training, and supervision claims that the Reno City Attorney may need to defend
against when representing the Reno PD like it did in the Eeof v. Pitsnogle case:
http://www.lvrj.com/news/reno-official-accused-of-witness-tampering-116586528.html
You know, Deputy City Attorney Ormaas's decision to push on for that $70 traffic ticket
is looking more and more interesting. \\
Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his understanding of the
extent to which his attorney, Richard G. Hill, Esq. had effectively rescinded any eviction
Order by sending a bill for the same amount as full use and occupany of the location at
121 River Rock St. goes to the substance of the elements found in RMC 8.10.040 as well
as the credibility of both Merliss and Hill.
Sincerely,
Sent: Thu 3/29/12 4:59 PM
Mr. Coughlin:

I previously sent you the setting slip for your trial in this matter by e-mail on March 9, 2012. That setting slip set your trial for April 10, 2012 at 8:00 a.m. in Dept 2 of the
Reno Municipal Court.

I am available to meet. Best times for me next week are Monday afternoon, Thursday afternoon or Friday morning. Let me know which is best for you and I will set
aside time for an appointment.

No I am not going to send you my case plan in writing with reference to citations and copies of legal research etc. (You might take cognizance of the fact you sent my last
discussion of your case to the Reno City Attorneys Office-notoriously poor strategic and tactical move on your part).

No skin in the game.

Keith Loomis

Subject: RE: i was evicted 3 15 12, i need a continuance

Mr. Loomis,
Can you please indicate to me, via email, if there is a Trial Date or any other court date set in this matter, and, if
so, provide the Date and Time. I would like to meet with you, when are you available to do so? Also, please
indicate in writing what your plan is for this case and what you have done to zealously advocate on my behalf,
including specifics regarding any legal research you have culled (and please provide citations and copies of the
research gathered to me, preferably by email). In your duties on the State Bar of Nevada's Fee Dispute
Committee, have you ever had a fee dispute from a client of a public defender? Do public defenders have any
skin in the game?
Sincerely,
RE: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno
Attorney's smart phone and cell phone etc. in court after cross examing RPD on bribery and
retaliation
Sent: Thu 3/29/12 5:05 PM
Dear Mr. Coughlin:

There has not been, as of yet, a trial as to which a mistrial could be declared in this case. A motion for mistrial is consequently premature.

I am only representing you as to your trespass case over which Judge Gardner is presiding. I am not representing you in regards to any other criminal case over which any
other Reno Municipal Court Judge is presiding. If you believe there are grounds to seek the recusal of Judge Gardner in regards to your trespass case, please identify
what those grounds might be.

Keith Loomis

Subject: FW: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD
on bribery and retaliation
Importance: Low

Dear Mr. Loomis,
Please file a motion for a mistrial and a motion to conflict out any RMC Judge from hearing any criminal case where I am a defendant.
Thanks,
To: dgentile@gordonandsilver.com; renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com;
ed@npri.org; mkandaras@da.washoecounty.us; mark@markmausertlaw.com
Subject: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD on
bribery and retaliation
Date: Thu, 29 Mar 2012 14:39:17 -0700
Dear City of Reno,
Please place a copy of this in Marshal Coppa's and the other Marshal who transported me to jail on 2/27/12's
employment/personnel file as he was the one who went into a backroom of the "Sally Bay" at the jail after
whispering in the WCSO Deputy Cheung's ear. Please ask him about the bag with the micro sd card, the various
contradictory statements made by RMC staff, Reno Marshals, and WCSO staff with respect to the chain of
custody of the seized property, with particular attention focused on Marshal Harley's statements concerning any
micro sd card, Debi Campbell's assertions in that regard, what Pam Willmore heard WCSO Deputy Hodge admit
with respect to the WCSO retention of the micro sd and other property, comparing that with any recordigns of
that conversation that may exist, and further referencing the statements of Ms. Campbell, Cummings, and
Beckman, while also reviewing any recordings made of telephone conversations with WCSO Detention Facility
Staff shortly after Coughlin was released from jail on
Please find new attachments herein including the emailed responses of WCSO agents Cummings, Debi
Campbell, and Trish Beckman.
To: renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com
Subject: City of Reno Marshal Division hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing RPD on bribery and
retaliation
Date: Thu, 29 Mar 2012 14:05:54 -0700
Dear City of Reno and Mr. Jeanney,
I was told by the Washoe County Sheriff's Office to call the City of Reno Marshal's division to inquire about the
return of the personal property that was seized from me incident to a 2/27/12 arrest for summar contempt
during the traffic trial in 11 tr 26800 before Judge Nash Holmes. I called the number held out as the Marshals
Division contact number http://reno.gov/index.aspx?page=223
And a "Bill" answered the phone, was evasive, indicated he did not work for the Marshal's division, would not
give me any contact information for a Marshal, any Marshal, told me he wasn't going to answer me stupid
questions, and hung up on me.
I called back and I believe it was Marshal Harley who answered (though I am not sure) and he answere the
phone in an unprofessional manner, guessing as to my identity in some show of menace. Rather than tjust
answer the phone like a professional and provide me the number for Marshal Dayton, as I was requesting, this
individual refused to provide the number, answered the phone on a "gotcha" type way where there was nothing
to "gotcha", then hung up the phone on purpose after declaring that he would not give me Marshal Dayton's
number or take a message. Please place a copy of this correspondence/complaints in "Bill" of court security for
the Reno Munic Court, and Marshal Harley's file and follow up this grievance. I am available to comment on
this unprofessional conduct further. Please also find attached other recent complaints I have submitted
regarding the Marshal Division and place them in the individual's complained of employment/personnel files.
There will be no ability to allege a lack of knowledge of this conduct in any future negligent hiring, training, and
supervision lawsuit incident to any misconduct alleged. I a requesting that a full scale investigation/inquiry be
conducted pursuant to the various conflicting, and inconsistent statement made with respect to the seized
personal property (inlcuding my phones, etc.). You might want to consider whether any Washoe County
Sheriff's Deputies have made statements that will conflict with anything the City of Reno may say from hear on
out. Given problems associated with my recently being adjudge a victim of domestic violence (my vulnerability
in that regard made moreso by Judge Nash Holmes seizing my cell phones and attempt to have my incomed
reduced through jeopardizing my law license, etc.) please correspond with my in writing only and only by email
and or fax.
Sincerely,
Zach Coughlin, Esq.
Name JAMES MENZEL
Position
Marshal
Reno
Notice
Year 2009
Base Pay $60,609.42
Overtime and
Callback
Collected
$622.67
Benefits
Accumulated
$22,425.49
Total Pay &
Benefits
$86,176.45
Name JOEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Name JUSTIN ROPER
Position
Reno
Year 2010
Base Pay $107,914.00
Overtime and
Callback Collected
$0.00
Other Pay ($2,697.89)
Total Pay $105,216.11
Name JAMES MENZEL
Position
Marshal
Reno
Notice
Year 2009
Base Pay $60,609.42
Overtime and
Callback Collected
$622.67
Benefits Accumulated $22,425.49
Name JOEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Name JUSTIN ROPER
Position
Reno
Year 2010
Base Pay $107,914.00
Overtime and
Callback Collected
$0.00
Other Pay ($2,697.89)
Total Pay $105,216.11
Sent: Tue 8/07/12 9:55 AM
Zach

necessary.


Keith Loomis





NRS
178.498):













Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
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6/08/12
Sent: Fri 6/08/12 4:39 PM

system.

Online Officer

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6/08/12
Sent: Fri 6/08/12 4:45 PM

system.

Online Officer

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6/11/12
Sent: Mon 6/11/12 4:10 PM
1 attachment
report-120103420-0.pdf (71.4 KB)

120103420.



Online Officer
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Sent: Mon 6/11/12 4:11 PM
1 attachment
report-120103420-1.pdf (70.9 KB)

120103420.



Online Officer
Sent: Tue 8/07/12 4:25 PM
You have already had two bail hearings. You are out on bail now. I decline to file a new request for a bail hearing.
I will be out of town on vacation from Friday August 10 and will return on Monday Aug. 20. That makes attendance at a bail hearing problematic and unlikely to be heard
before your trial.
I do think the complaint fails to allege the charge of disturbing the peace. I will make the motion to dismiss it at the time of trial.
The fact that the officer did not observe you committing a misdemeanor means he was not entitled to arrest you. You have a civil claim against RPD and the
officer. That does not mean the charge of DTP is subject to dismissal.
I will review the case involving Mr. Krebs and his request for a temporary protective order.
I need your description of what happened on the 3
rd
of July. Will you provide it?

To: Keith Loomis

Are you refusing to file the motions o requested?
From: Keith Loomis
Sent: 7 Aug 2012 16:55:44 GMT
To: 'Zach Coughlin'
Zach

necessary.


Keith Loomis





NRS
178.498):













Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
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From:
Sent: Fri 6/08/12 4:45 PM

system.

Online Officer

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From:
Sent: Mon 6/11/12 4:10 PM
1 attachment
report-120103420-0.pdf (71.4 KB)

120103420.



Online Officer
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From:
Sent: Mon 6/11/12 4:11 PM
1 attachment
report-120103420-1.pdf (70.9 KB)

120103420.



Online Officer
RE: respectfully submitted
Sent: Wed 8/08/12 2:43 PM
Zach:
I reviewed the file in the Krebs protective order application. It is interesting in that there is not one reference by Mr. Krebs to a belief that you were trying to provoke
him to engage in violence or a violation of law. Those appear to be solely the words of Office Weaver.
I subsequently received your 100 page e-mail and do not intend to review it at length as most of the material appears irrelevant. What I gather from it is that
you are once again not happy with my representation and want me to withdraw. I think there is merit to that request. It appears that our relationship has broken down
and that you are asking me to engage in conduct that will result in violations of the rules of professional conduct. Those include Rules 3.1, 3.2 , 4.4 and possibly others. I
also fundamentally disagree with some of your requested actions in that so far you have refused to provide your description of what happened on July 3, 2012 with Mr.
Krebs. It also appears that your repeated demands are making my representation unreasonably difficult. It would be helpful; if I can represent in the motion to
withdraw that you are willing to waive the 60 day rule for trial, so that a new attorney can be appointed to represent you and have enough time to prepare your case.
Please respond whether you will agree to that waiver. If not I will simply file the motion without the representation and hope for the best.

Keith Loomis

To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
Subject: FW: respectfully submitted

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: weavera@reno.gov; barnesm@reno.gov
Subject: respectfully submitted
Date: Fri, 8 Jun 2012 16:41:49 -0700
Dear Officer Weaver and Officer Barnes,
I am respectfully submitting this supplementary material to the police report I submitted to you in person on
June 6, 2012 regarding the assault I was the victim of at the hands of maintenance staff member Luke of
Northwind Apartments on June 5th, 2012, and the attempts at unlawful entry committed by Northwind
Manager Dwayne Jakob on or about June 4, 2012.
I am attaching an article you may find of interest regarding the intersection of landlord tenant law and police
work, vis a vis criminal/civil matters and the fine distinctions that sometimes arise. I didn't see anything in there
on Officer Weavers fine hypothetical regarding entry without permission when a burglary may be occurring.
That situation probably does not come up that often because hardly anybody but the police would be brave
enough to enter such a dangerous situation.
I appreciate the brave service both of you provide. I am attaching this materials just because they are
interesting to me and may be to you and in no way wish for so attachign these to be interpreted as a criticism
of either of your police work.
Sincerely,
Zach Coughlin
Motion to Withdraw
Sent: Fri 8/10/12 11:07 AM
To: Zach Coughlin (ZachCoughlin@hotmail.com)
1 attachment
SKMBT_C35312081011000.pdf (164.4 KB)
Motion to Withdraw is attached

Keith Loomis

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RE: motion for continuance
From:Pamela Roberts (robertsp@reno.gov)
Sent: Wed 11/16/11 5:12 PM
To: Zach Coughlin (zachcoughlin@hotmail.com)
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for reciprocal discovery. You just need to call ahead at 334-2050 and
arrange to pick it up. You are entitled to copies of all the reports and witness statements and video we may have on this case. Since I am not calling any additional witnesses that
are not already mentioned in the reports/statements, I am not obligated to send you an additional list of witnesses. I am also not obligated to do any further investigation or
interviews. Pam Roberts.
Date: Wed, 16 Nov 2011 15:35:48 -0800
Subject: RE: motion for continuance
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any Walmart employees had, previous to this incident, made
any threats respecting maliciously having the accused banned from Walmart's incident to a disagreement over Walmart staff
and managers curious practice of "forgetting" their return policy, despite some individuals having worked there over 10
years....Further, I believe it relevant and part of your duty to provide exculpatory information to ascertain whether the RSIC
police officer made statements wherein he attempted to coerce a consent to an impermissible search and further buttressed
his probable cause finding to conduct a search incident to arrest, expressly, in words, to the accused, upon the accused's
failure to consent to such a search.

Please provide a list of any witnesses you intend to call at trial, including a summation of the matters the will testify to, in
addition to producing a copy or making available for reproduction any documentation, audio, video, or other materials
intended to be used in any way at trial.
Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
From: robertsp@reno.gov
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation from the Court that your trial date has been continued, you will
need to appear this afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to resolve the
case, you can ask the Court again for a continuance and I won't object. However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the Court is not required to appoint you an attorney. In addition, you
have no right to a jury trial in a misdemeanor case.

I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.

Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
Dear Counselor Roberts,
I believe you are the prosecutor for the case against me, State v. Coughlin, which I believe is still set for trial on November
14th, I think at 1pm. I am not totally sure that there is a duty to serve you on such a thing, but I filed a Motion for
Continuance and a Motion for Appointment of Counsel sometime within about the last 10 days, I would say. I believe I
attempted to copy you on it, but have recently been evicted and its been a very difficult time in terms of coordinating
paperwork, etc., etc. I apologize for any inconvenience this may have cause you. I am unsure of whether the November
14th trial is still set to take place. I believe fairness dictates that it be continued to a later date. I have request counsel but
have yet to receive any, or wait, I was denied a request to receive counsel because Judge Howard said there is not a 6th
amendment right to counsel where, even though jail time is technically a possibility, the state does not anticipate seeking
jail time...or something like that, however, I found some cases that say I should still get counsel appointed, especially
where I show I am indigent, and I believe I qualify as indigent rather easily. Can and would you agree to a continuance? I
believe I tried to contact about this prior to filing my Request for a Continuance. I maintain my innocence in this case and
feel any sort of conviction, especially one involving any sort of theft based charge, would work a terrible injustice and
greatly damage my reputation and employment prospects. I want a jury trial, too.
Why no Casey Baker, Esq., Allison Ormaas, Esq., WCSO Deputy Machen, or RMC
Marshal Harley, WCPD Biray Dogan, DDA Zach Young
Close
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information
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or other applicable privilege.

Print
WLS
From:Paul Elcano (pelcano@washoelegalservices.org)You moved this message to its current location.
Sent: Wed 5/06/09 9:38 AM
Dear Zach,

You are correct about the letter being delivered on April 20
th
, I misread my timeline. My decision is limited to the hearing conduct. You have proffered nothing that indicates
that the way you acted in court is in any way related to any outside event. Your 50 page motion for reconsideration before Judge Gardner has not linked your conduct in any way to
an outside event. You have refused to give me a time and date to meet once again, and I will issue my determination tomorrow morning at 9:00 am.

Access to your computer materials, will be made at a convenient time and place with our office manager, executive director or designee and our computer specialist
present. This is a business computer, and without further research I will not give you access to it privately. You have been given a tape of the two Joshi hearings. To date, you have
not agreed to meet at any time and place to discuss these hearings; and you have not specifically requested any identified items, documents etc. that were related to your conduct
in this hearing. Your series of questions about the Board is irrelevant. The Board delegated this matter to me to handle as a personnel matter.

-Paul
Sent: Thu 11/01/12 5:39 PM
To: patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com);
mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net)
Dear Mr. King,
I am writing to formally complaint about your, once again, reneging on an offer you have made to allow me
access to certain materials.
Please explain your repeated misrepresentations to me regarding the "access" you will allow me to the materials I am entitled to
view, and those you have made offers in writing to me to allow me to view and or review.
I think you might find that the attached video of Sargent Lopez pretty much vitiates the criminal trespass conviction (and that
conviction, and all of Judge Nash Holmes orders are void in light of there violation of NRS 178.405 vis a vis NRS 5.010 and
the admission in Judge Nash Holmes March 14th, 2012 letter to the SBN, and beyond that In re Oliver and the fact that Judge
Nash Holmes admits on the record to be basing her Order's upon conduct not committed in her "immediate presence" (an
allegation of having a RMC Marshals look "Peeping Tom" style through a bathroom stall doesn't cut it)... Interesting that you
have chosen to subpoena your former Attorney General's coworke Dan Wong rather than City Attorney Ormaas (given her
presence at the 2/27/12 11 TR26800 Trial from which the "summary criminal contempt" order stems, and the allegations of her
and that RMC Marshal Harley (whom violated the "courthouse sanctuary" doctrine in one of the worst ways imaginable with his
barging in on a plea bargain session to "personally serve" a Notice of Order to Show Cause on behalf of Richard G. Hill (and the
11 tr 26800 case involved traffic citations immediately after RPD Tarter told Coughlin to leave Hill's office, albeit without his
wallet, keys, client's files, or state issued identification....) then to have the same
WCSO Deputy Machen who lied about personally serving the lockout order on Coughlin (in the eviction involving Hill) again
lie in his 3 7 2012 Affidavit attesting to have served the notice of the 3 23 12 ORder to Show Cause hearing (the one RMC
Marshal Harley served for him, then got all jumpy and whispering in Ormaas's, and, apparently while Coughlin was in the
restroom, made allegations to Judge Nash Holmes (and afterwards incident to the SITA) seeking to cover up his misconduct and
that of Ormaas. Claiborne is not going to allow you to feign ignorance, Mr. King, nor is the proof of receipt of all my emails
and writings and media. Have fun reviewing it all.
Regardless, its not "summary contempt" if all essential elements of the allegation, under any iteration of NRS 22 are not alleged
to have occurred in the "immediate presence" of the Judge...where, as here, that is not the case, those RMC Marshal are going to
have to sign their names to affidavits like the big boys they strut around acting like they are, behaving in a menacing and
intimidating manner that is wholly inconsistent with traditional notions of the type of comportment required of officers of the
court.
Again, today, you have reverted to your old tricks. I want everything, not just that which you or Clerk/Investigator Peters deem
"related' to the SCR 105 "Complaint" (which has three case numbers on it ng12-0204, ng12-0434, and ng12-0435). Both you
and Peters get real evasive when it comes times to answer for who submitted or filed the ng12-0435 grievance consisting of a
three year old Order by Family Court Judge Linda Garnder, yet which bares a file stamp of March 15th, 2012 by the SBN...then
there is Judge Linda Gardner's brother, RMC Judge William Gardner refusing to recuse himself from the criminal trespass case,
resulting in a conviction. I would think the attached videos pretty much demonstrate perjury by Richard G. Hill considering the
various Declarations and Application for a TPO, bar grievances, police reports, and Motions for Orders to Show Cause he filed
or signed on to....Mr. King, is this what the SBN needs right now? A SCR 105 Complaint by you coyly including this January
12th, 2012 "jaywalking" arrest, yet refusing to utter Hill's name in connection with it?
Some selected past correspondences with Mr. King detailing his reneging on offers:
Mr. King, one of of our recent discusson you promised to send me something in writing informing me as to who exactly was on the
screening panel. You have failed to uphold that promise as well. Further, you and Clerk/Investigator Peters have remained evasive
and contradictory respecting who filed NG12-0435, when, and under what circumstances it came to be a grievance. I think you will
find that a review of the hearings you finally provided in 11 CR 26405 (April 10th and May 8th, 2012) will yield some really
intersting statements on the record by Keith Loomis, Esq. (your Minden associate) and Judge William Gardner of the RMC (brother to
Family Court Judge Linda Garnder, whose 2009 sanctions order was file stamped by the SBN on March 15th, 2012 and is now called
NG12-0435, though neither you nor Peters will say anything all that sensible about the genesis of that grievance, etc. Judge Gardner
makes some pretty curious statements respecting the competency analysis, the decision to plow ahead with a Trial Setting on March
7th, 2012 for April 10th, 2012 (interesting considering Coughlin filed the Notice of Appeal of the final, appealable "summary criminal
contempt" conviction on that same date, March 7th, 2012 that now forms part of the asis for Judge Nash Holmes ng12-0434
"decompensating" grievance, incident to her March 14th, 2012 letter to the SBN....you might want to have Judge Gardner's statements
on the record from 4/10/12 and 5/8/12 and Loomis's transcribed, as your possession of the audio thereof arguably puts a Claiborne-
esque duty upon you to inquire as to the candor and veracity of some of those statements, especially vis a vis the "meetings" Gardners
being the RMC's "Administrative Judge", etc., etc. Further, you have refused to allow me access to a number of materials that neither
you nor Peters deem "part of the complaint" (the SCR SBN v Coughlin complaint...though to the extent one or more of ng12-0204,
ng12-0434, 0435 mention the RMC, arguably, I am entitled to anything at all related to me, whether submitted by the WCSO, RMC,
City of Reno, City of Reno Marshals, etc.
There are grievances against Dogan, Loomis, Young, Ormaas, Roberts, Hazlett, etc., etc., and given the SBN's and NNDB's known predilection against bifurcating hearings,
why not have those individuals show up on November 14th, 2011 in the name of adminitrative economy? I am to financially strapped to arrange for all of their appearances, but
I believe my requesting a waiver herein, or that the SBN or NNDB so arrange for these barristers to appear, combined with the duties attendant to Mr. King being a prosecutor
(Brady Rule RPC 3.8, simple duty of fairness to opposing counsel, etc., etc.) might dictate that they so be obliged to appear. Certainly Dogan and Young could shed some light
on the communications to the RMC and Judge Nash Holmes that made her holding the Trial on 2/27/12, hours after Dogan and Young successfully obtained an Order for
Competency Evaluation of Coughlin in RCR2012-065630, appear to be plainly violative of NRS 178.405 and NRS 5.010 (as was Young's filing an Opposition later that day,
baring a file stamp time over 90 minutes after that found on the Order for Competency Evaluation. As for WCSO Machen, why, he is practically indispensable here. You got
him and Baker doing the November 1, 2011 eviction lockout, you got him with the phony Affidavit of Service he failed thereto on 11/7/11, you got Machen having RMC
Marshal Harley serving the Notice of Order to Show Cause Hearing on Couglin on 2/27/12 while Coughlin and Ormaas haggled over the fines for the Richard Hill traffic citation
trial before Judge Nash Holmes (I would think getting the audio of the other cases on Judge Holmes' docket at 1:00 pm on 2/27/12 will reveal what I heard her administrative
assistant say...something along the lines of "I am going to start the record now so I don't forget to later...followed by a substantial period of no one being able to find Judge Nash
Holmes, comments directed to how odd that was, etc., etc.) all occurring at the exact same time that Dogan and Young were holding their clandestine status conference on
2/27/12 at 1:30 pm...which didn't stop Judge Nash Holmes from continuing on to hold the 11 TR 26800 traffic citation trial, at which she suspended the proceedings at 4 pm or
so, and had Coughlin cuffed and taken straight to a 5 day jail stay (and despite her protestations of concern for Coughlin's client's welfare, she gave the idea of a stay extremely
short shrift, indeed). Funny how that Order immediatly follow Coughlin saying "RPD Sargent Tarter lied when...." BOOM. STOP. Summary criminal contempt conviction....5
day jail stay. Judge Nash Holmes even kept the $100 Coughlin's Mother paid to get him out a day early, despite the jail not releasing Coughlin. Wow, indeed.
Patrick King (PatrickK@nvbar.org) Add to contacts 3/27/12 To: zachcoughlin@hotmail.com From: Patrick King
(PatrickK@nvbar.org)This sender is in your safe list. Sent: Tue 3/27/12 9:24 AM To: zachcoughlin@hotmail.com
(zachcoughlin@hotmail.com) March 27, 2012 Dear Mr. Coughlin, Perhaps you are not fully aware of your behavior. At our brief
meeting yesterday I perceived you as very hostile and even threatening. Under those circumstances I felt it better to terminate the
meeting. If it was not your intent to appear hostile or to attempt to intimidate me then you might consider how I perceived your
conduct. I had intended to try to listen to you and determine how my office could best help you address the grievances that I have
received. You said you did not have time and simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not
care if you received the information I sent to you, I said I did not care how your received it, so long as you received it. I do care that
you receive the information that I send to you. As I attempted to explain, I will be meeting with a panel to have them make a
determination about the grievances that have been made against you by Mr. Hill and the Judge from Department 3 that you read at my
office. I have asked for a written response to those grievances. In response I received many e-mails with attachments. I will soon be
sharing the grievances with a disciplinary panel and will advise them of your responses to date. I will keep you advised of the panels
determination. Sincerely, Patrick King Actions Zach Coughlin (zachcoughlin@hotmail.com) 3/26/12 To: patrickk@nvbar.org,
glennm@nvbar.org, davidc@nvbar.org Dear Mr. King, This correspondence is sent to confirm that I visited the Double R Blvd.
offices of the State Bar of Nevada today and attempted to be provided access the the various "other different judges" grievances that I,
prior to last Friday, was completely unaware of. I have sent you several written correspondences detailing the tampering and other
problems with my USPS mail incident to the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask
that you copy my on all correspondences or document production via email and fax. Today, you showed me a two page letter from
Judge Nash Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of
any other judges from whom you have received any other similar such materials and further refused to allow me to view and such
items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told me you
didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters, grievances, or other
materials, prior to being questioned by you and before any such meeting. I informed you that I am considering different attorneys to
represent me right now, and indicated I need these materials to prepare for any future meeting with you. My records incidate that your
letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know if you
received any sort of "return to sender" letter for that mailing. Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel:
775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473 2012 Microsoft Terms Privacy Developers
English (United States)
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Mon 4/02/12 3:57 PM To:
zachcoughlin@hotmail.com Dear Mr. Coughlin, I have opened 3 disciplinary files against you. They are identified by number below:
NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005)
Judge Holmes NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner You have received the grievance from Mr.
Hill and also the grievance from Judge Holmes. The Grievance from Judge Gardner relates to her Order After Trial in the case of
Ashwin Joshi v Barti Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13. I have received
certified copies of the contempt orders, a certified copy of the conviction at Wal-Mart, and an incident report from Marshals
Thompson and Coppa regarding your conduct on March 22, 2012. I also have the recordings of the court proceedings at issue. At this
time, I do not expect to be providing you with any additional information. If you have additional information that you want me to be
made aware of in response to the grievances identified above please feel free to mail them to me. Sincerely, Patrick King, Assistant
Bar Counsel
\
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Thu 4/19/12 2:28 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,


contempt of Court. However, it must concern you that you were found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of or
obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at my request, pursuant to my investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were held in contempt of Court. You may be well
served to explain what remedial measures you are taking to make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest you
cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the office of Bar
Counsel.

Patrick King
011412 RJC RCR2012-065630 RCR2011-063341 RCR2012-067980 Reno Police Department Sargent Paul Sifre arrests Reno Attorney for misuse of 911 second arr.3gp
zach's arrest 009 26405 1708 26800 03628.flv
zach's arrest 011 26405 1708 26800 03628.flv
zach's arrest 010 26405 1708 26800 03628.flv
10 4 12 ORDER STRIKING document filed in error on 10 2 12 and returning document 26800 0204 0434 nash 00696 26405.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
Download all
CC: DavidC@nvbar.org
Subject: Records
Date: Thu, 1 Nov 2012 16:04:21 +0000
Good Morning Mr. Coughlin,

RE: Records
Your disciplinary file is being sent to the printer to be copied. I am having the documents bate stamped and the printing company will mail them to you.

Formal proceeding are taking place at the state bar office so you will not be permitted in the building.

Sent: Thu 11/01/12 4:43 PM
To: Patrick King (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org);
complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); JE@ELORENO.com
(je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
Dear Mr. King,
I am writing to formally complaint about your, once again, reneging on an offer you have made to allow me
access to certain materials.
Please explain your repeated misrepresentations to me regarding the "access" you will allow me to the materials I am entitled to
view, and those you have made offers in writing to me to allow me to view and or review.
I think you might find that the attached video of Sargent Lopez pretty much vitiates the criminal trespass conviction (and that
conviction, and all of Judge Nash Holmes orders are void in light of there violation of NRS 178.405 vis a vis NRS 5.010 and
the admission in Judge Nash Holmes March 14th, 2012 letter to the SBN, and beyond that In re Oliver and the fact that Judge
Nash Holmes admits on the record to be basing her Order's upon conduct not committed in her "immediate presence" (an
allegation of having a RMC Marshals look "Peeping Tom" style through a bathroom stall doesn't cut it)... Interesting that you
have chosen to subpoena your former Attorney General's coworke Dan Wong rather than City Attorney Ormaas (given her
presence at the 2/27/12 11 TR26800 Trial from which the "summary criminal contempt" order stems, and the allegations of her
and that RMC Marshal Harley (whom violated the "courthouse sanctuary" doctrine in one of the worst ways imaginable with his
barging in on a plea bargain session to "personally serve" a Notice of Order to Show Cause on behalf of Richard G. Hill (and the
11 tr 26800 case involved traffic citations immediately after RPD Tarter told Coughlin to leave Hill's office, albeit without his
wallet, keys, client's files, or state issued identification....) then to have the same
WCSO Deputy Machen who lied about personally serving the lockout order on Coughlin (in the eviction involving Hill) again
lie in his 3 7 2012 Affidavit attesting to have served the notice of the 3 23 12 ORder to Show Cause hearing (the one RMC
Marshal Harley served for him, then got all jumpy and whispering in Ormaas's, and, apparently while Coughlin was in the
restroom, made allegations to Judge Nash Holmes (and afterwards incident to the SITA) seeking to cover up his misconduct and
that of Ormaas. Claiborne is not going to allow you to feign ignorance, Mr. King, nor is the proof of receipt of all my emails
and writings and media. Have fun reviewing it all.
Regardless, its not "summary contempt" if all essential elements of the allegation, under any iteration of NRS 22 are not alleged
to have occurred in the "immediate presence" of the Judge...where, as here, that is not the case, those RMC Marshal are going to
have to sign their names to affidavits like the big boys they strut around acting like they are, behaving in a menacing and
intimidating manner that is wholly inconsistent with traditional notions of the type of comportment required of officers of the
court.
Again, today, you have reverted to your old tricks. I want everything, not just that which you or Clerk/Investigator Peters deem
"related' to the SCR 105 "Complaint" (which has three case numbers on it ng12-0204, ng12-0434, and ng12-0435). Both you
and Peters get real evasive when it comes times to answer for who submitted or filed the ng12-0435 grievance consisting of a
three year old Order by Family Court Judge Linda Garnder, yet which bares a file stamp of March 15th, 2012 by the SBN...then
there is Judge Linda Gardner's brother, RMC Judge William Gardner refusing to recuse himself from the criminal trespass case,
resulting in a conviction
Mr. King, one of of our recent discusson you promised to send me something in writing informing me as to who exactly was on the
screening panel. You have failed to uphold that promise as well. Further, you and Clerk/Investigator Peters have remained evasive
and contradictory respecting who filed NG12-0435, when, and under what circumstances it came to be a grievance. I think you will
find that a review of the hearings you finally provided in 11 CR 26405 (April 10th and May 8th, 2012) will yield some really
intersting statements on the record by Keith Loomis, Esq. (your Minden associate) and Judge William Gardner of the RMC (brother to
Family Court Judge Linda Garnder, whose 2009 sanctions order was file stamped by the SBN on March 15th, 2012 and is now called
NG12-0435, though neither you nor Peters will say anything all that sensible about the genesis of that grievance, etc. Judge Gardner
makes some pretty curious statements respecting the competency analysis, the decision to plow ahead with a Trial Setting on March
7th, 2012 for April 10th, 2012 (intersesting considering Coughlin filed the Notice of Appeal of the final, appealable "summary
criminal contempt" conviction on that same date, March 7th, 2012 that now forms part of the asis for Judge Nash Holmes ng12-0434
"decompensating" grievance, incident to her March 14th, 2012 letter to the SBN....you might want to have Judge Gardner's statements
on the record from 4/10/12 and 5/8/12 and Loomis's transcribed, as your possession of the audio thereof arguably puts a Claiborne-
esque duty upon you to inquire as to the candor and veracity of some of those statements, especially vis a vis the "meetings" Gardners
being the RMC's "Administrative Judge", etc., etc. Further, you have refused to allow me access to a number of materials that neither
you nor Peters deem "part of the complaint" (the SCR SBN v Coughlin complaint...though to the extent one or more of ng12-0204,
ng12-0434, 0435 mention the RMC, arguably, I am entitled to anything at all related to me, whether submitted by the WCSO, RMC,
City of Reno, City of Reno Marshals, etc.
Patrick King (PatrickK@nvbar.org) Add to contacts 3/27/12 To: zachcoughlin@hotmail.com From: Patrick King
(PatrickK@nvbar.org)This sender is in your safe list. Sent: Tue 3/27/12 9:24 AM To: zachcoughlin@hotmail.com
(zachcoughlin@hotmail.com) March 27, 2012 Dear Mr. Coughlin, Perhaps you are not fully aware of your behavior. At our brief
meeting yesterday I perceived you as very hostile and even threatening. Under those circumstances I felt it better to terminate the
meeting. If it was not your intent to appear hostile or to attempt to intimidate me then you might consider how I perceived your
conduct. I had intended to try to listen to you and determine how my office could best help you address the grievances that I have
received. You said you did not have time and simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not
care if you received the information I sent to you, I said I did not care how your received it, so long as you received it. I do care that
you receive the information that I send to you. As I attempted to explain, I will be meeting with a panel to have them make a
determination about the grievances that have been made against you by Mr. Hill and the Judge from Department 3 that you read at my
office. I have asked for a written response to those grievances. In response I received many e-mails with attachments. I will soon be
sharing the grievances with a disciplinary panel and will advise them of your responses to date. I will keep you advised of the panels
determination. Sincerely, Patrick King Actions Zach Coughlin (zachcoughlin@hotmail.com) 3/26/12 To: patrickk@nvbar.org,
glennm@nvbar.org, davidc@nvbar.org Dear Mr. King, This correspondence is sent to confirm that I visited the Double R Blvd.
offices of the State Bar of Nevada today and attempted to be provided access the the various "other different judges" grievances that I,
prior to last Friday, was completely unaware of. I have sent you several written correspondences detailing the tampering and other
problems with my USPS mail incident to the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask
that you copy my on all correspondences or document production via email and fax. Today, you showed me a two page letter from
Judge Nash Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of
any other judges from whom you have received any other similar such materials and further refused to allow me to view and such
items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told me you
didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters, grievances, or other
materials, prior to being questioned by you and before any such meeting. I informed you that I am considering different attorneys to
represent me right now, and indicated I need these materials to prepare for any future meeting with you. My records incidate that your
letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know if you
received any sort of "return to sender" letter for that mailing. Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel:
775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473 2012 Microsoft Terms Privacy Developers
English (United States)
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Mon 4/02/12 3:57 PM To:
zachcoughlin@hotmail.com Dear Mr. Coughlin, I have opened 3 disciplinary files against you. They are identified by number below:
NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005)
Judge Holmes NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner You have received the grievance from Mr.
Hill and also the grievance from Judge Holmes. The Grievance from Judge Gardner relates to her Order After Trial in the case of
Ashwin Joshi v Barti Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13. I have received
certified copies of the contempt orders, a certified copy of the conviction at Wal-Mart, and an incident report from Marshals
Thompson and Coppa regarding your conduct on March 22, 2012. I also have the recordings of the court proceedings at issue. At this
time, I do not expect to be providing you with any additional information. If you have additional information that you want me to be
made aware of in response to the grievances identified above please feel free to mail them to me. Sincerely, Patrick King, Assistant
Bar Counsel
\
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Thu 4/19/12 2:28 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,


contempt of Court. However, it must concern you that you were found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of or
obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at my request, pursuant to my investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were held in contempt of Court. You may be well
served to explain what remedial measures you are taking to make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest you
cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the office of Bar
Counsel.

Patrick King
EMAILS TO PATRICKK@NVBAR.ORG PATRICK KING BAR COUNSEL.pdf
emails from ZachCoughlin@hotmail.com to Patrick King patrickk@nvbar.org since 3 23 12.pdf
emails since 3 23 12 from patrickk@nvbar.org Patrick King Bar Counsel State Bar of Nevada.pdf
5 4 09 attachment to wlc elcano email gardner 26405 01955 60302 ltrCoughlin2ndDraft.pdf
5 7 09 termination letter from wls elcano linda gardner zachcoughlin040709.pdf
5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844.pdf
11TR26800 RMC 022712 031412_20120312-1033_01cd003b8f0851d0.mp3
11CR26405 050812 Loomis_20120508-1104_01cd2d0a627f5f90.mp3
11TR26800 RMC 022712 031412_20120227-1507_01ccf5618f76c460.mp3
3 16 12 ng12-0434 SBN King letter containing RMC Judge Nash Homes 3 14 12 grievance against Coughlin and ng12-0435 linda gardner sanction from 4 10 09 26800 00696
54844.pdf
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf
11cr26405 puentes 041012_20120410-0903_01cd16f8c3aa49b0.mp3
rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv
2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal harley.pdf
RE: Coughlin: Petit larceny case
rerevised exhibit 1 26405 61901 WITH BATES NUMBERING.pdf
12-32685 10 15 12 scr 111(4) in re coughlin petition criminal trespass conviction 61901 26405 1708 26800 12420 hill sbn.pdf
Download all
CC: DavidC@nvbar.org
Subject: Records
Date: Thu, 1 Nov 2012 16:04:21 +0000
Good Morning Mr. Coughlin,

Your disciplinary file is being sent to the printer to be copied. I am having the documents bate stamped and the printing company will mail them to you.

Formal proceeding are taking place at the state bar office so you will not be permitted in the building.

Sent: Thu 11/01/12 1:10 PM
To: Leslie, Jim (jleslie@washoecounty.us); odomk@reno.gov (odomk@reno.gov); complaints@nvbar.org
(complaints@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com)
Dear Jim,
Have no idea what you mean about a "riding your butt" comment...Jim, you understand that files that are on a cd/dvd, are digital
in nature, you get that, right? Please send me those files in accordance with Judge Sferrazza's October 22nd, 2012 Order,
already. Also, Jim, you have a duty to maintain a copy of a former client's file, and here you admit to seeking to shirk that duty, I
believe, for the even more impermissible purposes I have detailed previously.
From: Jleslie@washoecounty.us
Subject: Coughlin: Petit larceny case
Date: Thu, 1 Nov 2012 19:38:03 +0000
Mr. Coughlin:

In response to your several argumentative phone calls today in which you stated at least once I am riding your butt and in which you keep demanding that we digitally
transmit materials that are in hard form, if you have a dispute about the discovery/file materials or my conduct, set a hearing with the court and I will hand them to you in
the presence of the judge since you are refusing to take receipt of them or sign an inventory.

If you set a hearing, please note that I generally am not available Tuesday or Thursday mornings but will make all reasonable effort. Otherwise, I typically have RJC cases in
the afternoons.

I noticed you copied the State Bar on one or more of the emails. I wonder if you would prefer to have the Bar involved in monitoring the hand-off of materials?

James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defenders Office
RE: Coughlin: Petit Larceny case -- Hand-Off Transmittal
350 South Center Street
Fifth Floor
Reno, NV 89509
1-800-762-8031
Direct Dial: 775-337-4828
Fax: 775-337-4856
Email: jleslie@washoecounty.us

The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL INFORMATION, are legally privileged, and are intended for use and review only by the party sending same and the intended recipient. If
you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly prohibited. If you received this communication in error, please
immediately notify us at 775-337-4800 to arrange return of the original transmittal. Thank you.

Sent: Thu 11/01/12 3:14 AM
To: Leslie, Jim (jleslie@washoecounty.us); davidc@nvbar.org (davidc@nvbar.org); patrickk@nvbar.org (patrickk@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); complaints@nvbar.org (complaints@nvbar.org)
1 attachment
filed 10 18 12 MOtion and Memorandum in RCR2011-063341.pdf (1500.4 KB)
Jim,
I will give you an opportunity to retract or fully explain your statement in your last correspondence to me, wherein
you wrote:
"Gi ven your past statements to me, I bel i eve I shoul d al so warn you of the possi bi l i ty of appl i cabi l i ty of Nevada Rul e of Professi onal Conduct 3.3. In that regard, pl ease recal l that duri ng a
meeti ng between you and I i n one of the i ntervi ew rooms at Reno Justi ce Court duri ng tri al on 9/5/12, you suggested to me that I al ter the vi deo recordi ng of your i nteracti on wi th the pol i ce
offi cers i n the peti t l arceny case. I tol d you I cannot do that. You became i rate and argumentati ve and asked why I coul d not do i t, and I tol d you i t woul d be unethi cal . I rai se thi s i ssue i n thi s
emai l transmi ttal to rei terate what I have had to tel l you more than once i n thi s case, that i s, I cannot and wi l l not assi st you i n al terati on of evi dence or other commi ssi on or attempted
commi ssi on of fraud upon the court. Shoul d I observe you attempti ng to do so duri ng the resumed tri al , currentl y set for November 19, 2012, as noted above, I bel i eve I woul d be requi red under
Nevada Rul e of Professi onal Conduct 3.3 to advi se the Court."
I don't know what i s funni er, Ji m, the accusati on that I woul d somehow vi ew you as tech savvy enough to whi p up some vi deo edi ti ng on the spot wi th "the county l aptop" whi ch "takes a l i ttl e
whi l e to boot up", or the suggesti on that I woul d be stupi d and reckl ess enough to attempt to encourage you to commi t some vague mi sconduct, you whom I cannot stand and whom cl earl y wants
nothi ng but the worst for me. Sure, Ji m, sure. I get i t Ji m, you have had a chance to read the Memorandum I submi tted, whi ch pai nstaki ngl y di ssects your mi sconduct, and you are pani cki ng,
doi ng damage control , reverti ng to your tri ed and true threateni ng of your i ndi gent cri mi nal cl i ent's routi ne....next, you wi l l attempt to have a bai l i ff l ean on your cl i ent wi th some i nti mi dati on
tacti cs, probabl y have hi m threaten to "put my foot up your ass" as you di d wi th Bai l i ff Reyes on October 8th, 2011 at the RJC.
I consi der your above wri ti ng to be an i nappropri ate threat, and beyond i naccurate. Ji m, i f there was a transcri pt of these conversati ons you refer to, and one compared them to your above
statements, woul d your conduct be ethi cal or even l egal ? By "al ter", what exactl y do you mean, Ji m? Are you referri ng to the "10 mi nute break" where you need to "boot up the county l aptop" 10
mi nutes before l unch, whi ch Judge Sferrazza granted you so you coul d "do some tri al prep" (mi d-way through the tri al , whereupon you were goi ng to vi ew, for the fi rst ti me, apparentl y, the vi deo
of the arrest, especi al l y gi ven your earl y foul ups on the record wherei n you fai l ed to recogni ze the di fference between the extorti onate threats made by Offi cer Rosa from those made by Offi cer
Dural de...then, duri ng that "10 mi nute break" you proceed to do somethi ng other than what you tol d Judge Sferrazza the break was for...i nstead of revi ewi ng the excul patory vi deo, you tal ked to
the State Bar of Nevada on the phone and recei ved confi denti al i nformati on rel ated to Kei th Loomi s's representati on or l ack thereof of mysel f...I asked you whether you had any authori ty for your
posi ti on that the vi deos of the arrest, and other i nvesti gatory vi deos I capture had to be submi tted or presented to the court i n thei r enti rety (some of the vi deos are qui te l ong...you woul dn't know
Ji m, because you have not vi ewed them....). You, of course, because you never have any ci tati on for anythi ng, i nstead proceeded to attempt to make some l ame threat accusi ng me of some
gi bberi sh, i n that cl assi c Ji m Lesl i e, CYA, faux si ncere, hyperpretenti ous del i very of yours that i s so very grati ng....
Don't have ti me to go i nto al l the mi srepresentati ons you make i n your emai l bel ow. Ji m, why don't you just emai l me the di spatch tapes, you know, as that i s a very materi al i ssue i n thi s matter.
Thi s i s especi al l y true where the RPD and DDA Young have seemi ngl y come up wi th thi s "di spatch reported to the offi cers a possi bl e fi ght" despi te the fact that the di spatch l ogs menti on onl y a
"di sturbance" at fi rst, then
Further, Dural de's Suppl emental Decl arati on (the one he fi l ed the day after the arrest, not the Narrati ve he fi l ed 3 months l ater when the RPD found out the arrest had been captured on tape by
Coughl i n...i ts a great vi deo, Ji m, you shoul d watch i t someti me....):
"report of a l arceny of a cel l phone at that l ocati on. Di spatch rel ayed i nformati on that the vi cti m had set hi s phone down and that he was now cal l i ng the phone and It was l i ghti ng up In the
suspecfs pocket. The suspect was descri bed as a whi te mal e adul t, 35 years of age, 6'02",210 Iba, weari ng a red Chi cago hat and a whi te or yel l ow shi rt and pl ai d shorts. Di spatch al so rel ayed
that the suspect was sti l l on scene."
Then, on page two of DDA Young Opposi ti on to the Moti on to Suppress (the one where you guys fai l ed to preserve arguments rel ated to the i mpermi ssi bl i ty of a search i nci dent to arrest based
upon what remai ned of the facts shoul d your suppressi on moti on be granted as i t rel ated to the pat-down al one), DDA Young seems to come out of nowhere wi th thi s "report of a possi bl e fi ght"
stuff, whi ch, conveni entl y, real l y hel ps i n the whol e "need for arti cul abl e facts supporti ng a reasonabl e suspi ci on/pat down or probabl e cause/search i nci dent to arrest anal ysi s...On page 5 of
hi s Opposi ti on, DDA Young dri ves the poi nt home: "In the i nstant case, the pat-down search of the Defendant was proper under the total i ty of the ci rcumstances. 3 Pri or to arri vi ng, Offi cer
Dural de l earned that the scene i nvol ved a l oud di sturbance wi th possi bl e fi ght, thereby i mmedi atel y rai si ng the concern of weapons and the safety of al l those present . Thi s i s just one factor for
thi s Court to consi der. Upon contacti ng the Defendant, he became uncooperati ve and chal l enged Offi cer Dural de that there was not enough i nformati on for a detenti on. Thi s i s just one factor for
thi s Court to consi der. Upon contacti ng the Defendant, he became uncooperati ve and chal l enged Offi cer Dural de that there was not enough i nformati on for a detenti on . Thereafter , i n response
to Offi cer Dural de's i nqui ry whether the Defendant had Mr. Gobl e's phone, the Defendant asked i f he had the ri ght not to answer the questi on. Whi l e the Defendant arguabl y can choose not to
answer such a questi on, thi s response, al ong wi th hi s general atti tude, demeanor, and reacti on, certai nl y can be consi dered by thi s Court when addressi ng the reasonabl eness of Offi cer Dural de
1s concern for hi s and others l safety . It i s i mportant to note that there were mul ti pl e peopl e on 2 scene, any of whi ch coul d be subjected to i njury or death i f the 3 Defendant had a weapon .
Upon arri val , the Defendant and a group of 4 peopl e (i ncl udi ng Mr. Gobl e) were on scene, and wi th the al l egati on that the Defendant had stol en a phone bel ongi ng to a person of sai d 6 group,
emoti ons were hi gh and a physi cal fi ght coul d have erupted. Agai n, such factors shoul d be consi dered by thi s Court when 8 determi ni ng the reasonabl eness of the pat-down search."
But where i s the support for thi s "a possi bl e fi ght" suggesti on? Its not i n the di scovery produced to me. So, how about those di spatch tapes, huh, Ji m. Kel l y Odom? Pl ease emai l them to me, I
don't want you tryi ng to jam me up so cl ose to tri al wi th some non-sense about how some bl ank or scratched cd you gave me was the "onl y copy" your offi ce had. I know you wel l , Ji m. So, seei ng
as how you fi nal l y served a subpoena duces tecum on Kel l y Odom/Ecomm/ 911 di spatchers, so we can fi nal l y hear the di spatch tapes, and see i f any "possi bl e fi ght" was menti oned, why don't
you go ahead and emai l me those audi o fi l es (and audi o fi l es are merci ful l y smal l compared to vi deo fi l es, Ji m, yet I have managed to send you reams of vi deo fi l es vi a emai l ...). Al so, I need the
audi o of the aborted Tri al i n thi s matter that was hel d on May 7th, 2012 (despi te the fact that Judge El l i ot di d not si gn the Order fi ndi ng Coughl i n Competent, and therefore endi ng the peri od i n
whi ch "al l proceedi ngs must be stayed" requi red by NRS 178.405, unti l two days l ater, on May 9th, 2012. So you guys were goi ng to jam me i nto a Tri al whi l e there was a pendi ng Order for
Competency Eval uati on, just days after my getti ng out of jai l , where my medi cati on was wrongful l y wi thhel d from me (and some medi cati ons shoul d not be ceased or started to abruptl y), where I
spent 8 days due to the l i es of the Lakes Crossi ng eval uators and the mi sconduct and mal prati ce of your protege, Bi ray Dogan, whom proceeded to read my confi denti al medi cal i nformati on i nto
the open, publ i c record, i n front of 40 or so members of the publ i c....a transgressi on whi ch Mr. Bosl er saw no need to attempt to have stri cken or corrected.
BUT TO ME CLEAR, JIM...I know Goodni ght orderd a copy of the May 7th, 2012 aborted Tri al , that occurred duri ng the pendency of an Order for Competency Eval uati on. I do not have a copy of that
JAVS audi o, nor do I have a copy of my arrai gnment i n rcr2011-063341. You guys don't even get bi l l ed for these and yet you have deni ed them to me, unti l you got wi nd of the fact that I went and
got my own, then you come up wi th you faux offers to provi de me copi es....Very cl ever.
Ji m, the RJC severel y l i mi ts my access to the fi l es, so you are not enti tl ed to make any assumpti ons that al l evi ate your duty to provi de me copi es of fi l i ngs, access to my fi l e, etc.
Further, I see that Li nda Gray fi l ed a request for the audi o of the October 22nd, 2012 Heari ng, and I want a copy of i t, so pl ease emai l i t to me, and al so provi de a hard copy. Its not rocket sci ence
copyi ng a CD, Ji m, and i t doesn't take ages, ei ther. You remember the October 22nd, 2012 Heari ng, ri ght, Ji m...the one where you can be heard on the record tel l i ng me "you are goi ng to fai l " and
"your're di si ntegrati ng" and maki ng more of your threats about how I attempt to advocate on my own behal f the Judge wi l l put me i n jai l , etc.,etc.? Yeah, I need a copy of the copy your offi ce got
of that heari ng. Wi th the bi ts where you tel l the Judge "he (Coughl i n) doesn't get to di p i nto our money, no one cent" i n your expl ai ni ng your refusal to subpoena materi al wi tnesses or send out
subpoena duces tecums (odd, because the RPD doesn't seem to charge you guys for those....yet you never sent one to ECOMM unti l wel l over mi dway through the tri al , why i s that, Ji m?).
See, Ji m, i t was professi onal mi sconduct for you to spend your enti re cross-exami nati on of Cory Gobl e tryi ng to establ i sh a ci ti zen's arrest was effectuated, and therefore hel p the pol i ce and the
State overcome the fact that Offi cer Dural de cl eary overcharged the cri me as a fel ony i n an attempt to game the system and get around the whol e statutory di ctate agai nst offi cer's maki ng
custodi al arrest (and therefore bei ng permi tted to conduct searches i nci dent thereto) for mi sdemeanors, al l egedl y commi tted after 7 pm and outsi de the offi cer's presence (unl ess a ci ti zen's
arrest i s i mmedi atel y effected). Your cross was pretty good work for a prosecutor, but you get pai d to ful fi l l the Si xth Amendment Ji m, not throw retal i atory ti zzy fi ts. Your fai l ure to i n any way
uti l i ze the 911 cal l tapes and vi deos Coughl i n took of the moments pri or to arrest (where the youths admi t they are tryi ng to steal Coughl i n's bi ke and hi s dog, to teach hi m a l esson...not to
"detai n" hi m or effect a "ci ti zens arrest" (i t al most seemed l i ke DDA Young had you make the arguments he wanted to make, but knew woul d be unethi cal for hi m to make, or woul d expose other
gl ari ng weaknesses i n hi s case, and i n that way, you two real l y make beauti ful musi c together, Ji m). Then there i s the fact that Coughl i n hi msel f cal l ed 911, and that Coughl i n i s heard on the
vi deo's pri or to the pol i ce arri vi ng encouragi ng the hosti l e gang of l ate teens, earl y twenti es skateboarders to remai n peaceful , and wai t for the pol i ce to arri ve, so the matter coul d be handl ed
ci vi l y (and not l ead to anyone dyi ng, as Coughl i n referenced the tragi c death of a 25 year ol d man i nterveni ng i n a purse snatchi ng of that was i n the news just months pri or to the August 20th,
2011 arrest i n thi s matter RCR2011-063341...real l y, Ji m, you shoul d joi n us at the November 14th,2 011 bar heari ng i n NG12-0204, as the SCR 105 Compl ai nt saw fi t to make thi s pendi ng
cri mi nal charge a basi s for a professi onal mi sconduct heari ng.
In the meanti me, why don't you send me the di gi tal transmi ssi ons that Judge Sferrazza ordered, and not hi de behi nd some "there's not enough ti me to make copi es" non-sense. Ri ght, Ji m, you are
real l y goi ng to gi ve me your onl y copi es of thi ngs. Uh-huh. You? Ji m, you? Ji m, you spend al l day coveri ng your ass, so pl ease. Besi des, the Judge di d not rul e that I have to pi ck up some box of
stuff, and si gn some document whi l e bei ng harassed by you, attesti ng to the contents of l ong pi eces of di gi tal medi a (whi ch I am sure you wi l l object to me watchi ng ri ght there i n your offi ce).
That i s the beauty of the di gi tal transmi ssi on, Ji m. Maybe the WCPD wi l l need to get i tsel f a Skydri ve, they are free, who knows? Al l I know i s I have made far l ess money than you thi s year Ji m,
and done the l i on's share of work on thi s case (wi th l ots of extra work added by your mi sconduct), and I have found your work on thi s matter to be amongst the most di stasteful I have ever seen
by an attorney.
So, now that I know that your offi ce di d subpoena Kel l y Odom (she showed up to Tri al , yet you kept that secret from me, i n addi ti on to the subpoena duces tecum you sent her, real l y l ate i n the
game, on October 3, 2012. Al so, you do real i ze that RPD Offi cer Dural de's wi fe was on duty that ni ght worki ng as a di spatcher for ECOMM, ri ght? Jessi ca Dural de, and what di spatch tol d the
RPD that ni ght has become a materi al i ssue i n thi s case. Yet, the WCPD was sati sfi ed wi th was the RPD gave them and di dn't send a subpoena duces tecume out to ECOMM unti l after the Tri al
woul d have been over al ready, had i t not been for how tenaci ous that Coughl i n i s.
Fi nal l y, Ji m, you mi ght want to reconsi der your anal ysi s respecti ng your purported fai l ure to subpoena wi tnesses after revi ewi ng the attached, as you wrote:
"I have not subpoenaed witnesses to the November 19, 2012, resumption of trial because (1) contrary to your assertions, no witnesses appear to have credible and
persuasive prospective testimony to help your case, in fact most of the witnesses you have insisted on calling at trial appear to have prospective testimony
harmful, not helpful, to your defense, (2) the witnesses you have demanded we subpoena and have testify appear to actually have prospective testimony contra to
a finding of not-guilty, and (3) I already obtained several points through cross examination of Zurate, Duralde, and Goble that you requested and that are credible
and potentially persuasive points in favor of your defense (please recall your comments to me during the first day of trial, I like where you are going with this . . . .
)."
From: Jleslie@washoecounty.us
Subject: FW: Coughlin: Petit Larceny case -- Hand-Off Transmittal
Date: Wed, 31 Oct 2012 23:56:26 +0000
Mr. Coughlin:

I understand from staff that you came in today demanding your documents. I also received your email asking for them and saying your email was now working again.

Below is the original transmittal I tried to send Monday of this week.

You have asked for proof of the transmittals bouncing back. I will print those, PDF them, and send them to you via email attachment tomorrow when I have time. In the meantime,
now that you say your email is again working, I wanted to get the below transmittal to you today without further delay.

Please note that, as noted in the below email, there are disks and photos as well. Please email me as to your availability to come in and take receipt of those.

Thank you.

Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856


From: Leslie, Jim
Sent: Monday, October 29, 2012 2:17 PM
Subject: Coughlin: Petit Larceny case -- Hand-Off Transmittal
Importance: High

Mr. Coughlin:

This transmittal is protected by Attorney-Client Confidentiality. However, dissemination of any kind of the contents hereof or of any of the attachments hereto may effect a
waiver of such Confidentiality, as you have been previously advised in prior emails and as you know from your legal training.

Transmitted herewith as attachments are file materials which are transmitted as courtesy hand-off transmittal from us as assigned counsel of record to you as court-
permitted self-representing defendant, for purpose of assisting you in your preparation for resumption of trial in the Petit Larceny case currently scheduled for November
19, 2012, at 8:30 a.m., and as to which date you have been previously advised via US Mail, email notice, verbal notice, and as you have previously acknowledged being
advised of in prior proceedings in open Court.

The attachments themselves shall serve as inventory of the materials transmitted herewith. Additionally, as courtesy and as memorialization of various issues, please note
the following:

Please note that there are also several computer discs/DVDs containing video and/or audio on them, as well as a set of color-printed photographs which we had prepared in
response to your September 20, 2012, email to us, that we will produce in tangible form separate and apart and in addition to this email transmittal. You will need to pick
those items up from our office and sign a receipt. A copy of that receipt is attached hereto as a PDF attachment, titled Receipt of Documents. Please email me whether you
are available 10/29/12 or 10/30/12 for pick-up of the additional documents and I will arrange to be present with an executable receipt for your signature. Said receipt is
necessary in part because the materials listed in the Receipt of Documents cannot be reproduced on short notice, in an effort to ensure you receive them well before the
resumption of trial, and to avoid dispute as to what materials were handed over to you.

I note that you and the Court confirmed at the last hearing that you have already directly received copies of the JAVS audio recordings of proceedings from the Court, so we
are not producing those in duplicate.

Included in the attached PDF transmittals are copies of clean, unredacted discovery materials from the State, copies of those materials with redactions, and our transmittal
letter to you including redacted copies of the discovery materials dated December 1, 2011. We have also provided you via email other copies of those same discovery
materials on prior occasions. Additionally, I recall personally trying to provide you additional courtesy copy of those materials on at least one occasion when you came to
the office without an appointment and made loud verbal demands for another copy of your discovery because you had lost your previously provided copies, however, you
then left the office when we tried to provide you that additional copy.

Although we are hereby producing various pleadings as PDF attachments to this email, as listed herein, my understanding from you is that you already have copies of all
filed pleadings, orders, etc., from your direct contacts with the Reno Justice Court. Nevertheless, the pleadings listed herein are produced as PDF attachments as a courtesy.

We are not producing you copies of the voluminous emails and email attachments you have previously sent us, since by being the transmitting party of those emails and
attachments you obviously have them yourself.

Please also note that you are now operating as your own self-representing counsel, by way of the self-representation granted you by the Court on 10/22/12, in the petit
larceny case. If you represent to anyone that you are operating in that case in conjunction with or as co-counsel with our office or any attorney therein, other than in our
capacity as Stand-By Counsel, we will have to consider reporting you to the State Bar for fraudulent misrepresentation. Additionally, as you were warned by the Court on
10/22/12, you cannot use any of the materials we are transmitting or the information contained in those materials to harass any person or otherwise put the materials or
information therein to any other improper use. These cautionary notes include but are not limited to information contained in the cell phone records of Mr. Goble and the
addresses, phone numbers, and other contact information of any persons identified in the transmitted materials, including those attached to this email transmittal and
those contained in the Receipt of Documents.

Given your past statements to me, I believe I should also warn you of the possibility of applicability of Nevada Rule of Professional Conduct 3.3. In that regard, please recall
that during a meeting between you and I in one of the interview rooms at Reno Justice Court during trial on 9/5/12, you suggested to me that I alter the video recording of
your interaction with the police officers in the petit larceny case. I told you I cannot do that. You became irate and argumentative and asked why I could not do it, and I told
you it would be unethical. I raise this issue in this email transmittal to reiterate what I have had to tell you more than once in this case, that is, I cannot and will not assist
you in alteration of evidence or other commission or attempted commission of fraud upon the court. Should I observe you attempting to do so during the resumed trial,
currently set for November 19, 2012, as noted above, I believe I would be required under Nevada Rule of Professional Conduct 3.3 to advise the Court.

I have not subpoenaed witnesses to the November 19, 2012, resumption of trial because (1) contrary to your assertions, no witnesses appear to have credible and persuasive
prospective testimony to help your case, in fact most of the witnesses you have insisted on calling at trial appear to have prospective testimony harmful, not helpful, to your
defense, (2) the witnesses you have demanded we subpoena and have testify appear to actually have prospective testimony contra to a finding of not-guilty, and (3) I
already obtained several points through cross examination of Zurate, Duralde, and Goble that you requested and that are credible and potentially persuasive points in favor
of your defense (please recall your comments to me during the first day of trial, I like where you are going with this . . . . ). Additionally, the Court advised you on 10/22/12
that if you believe you require subpoenas, you may contact the Court directly and obtain subpoenas with waiver of fees.

As directly by the Court on 10/22/12, I will be present at the trial on November 19, 2012, at 8:30 a.m. as Stand-By Counsel. If during the resumed trial you believe you are
unable, after all, to adequately handle the trial proceedings yourself, I will be available to take over representation, at which point I would do my best to correct any errors
or tactical mistakes you might have committed as well as otherwise try to win the case for you.

Thank you,

Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856

my new address
grievance against Keith Loomis, Esq. and Christopher Hazlett-Stevens, Esq., Lew
Taitel, Esq., and Henry Sotelo, Esq., and WCPD Biray Dogan and Jim Leslie

Sent: Tue 10/23/12 11:29 AM
To: patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; complaints@nvbar.org
Dear Bar Counsel,
I am still very afraid of retaliation by local law enforcement, and due to my status as a domestic violence victim. In the past, I have offered to assistn you in getting me served
appropriately, but have received no follow up. Further, the SBN, via Investigator/Clerk Peters and otherwise have made representations that I have relied upon to the extent that
another certified mail SCR 105 Complaint would be sent out shortly after my communications with Peters on September 11th, 2012 or so where she admitted to receiving in the mail
the one she said she sent on August 23rd, 2012. Whatever the SCR 109 implications, the SBN's promises made by Peters are binding in that regard...
Nonetheless, I now feel forced to provide you my address and expose myself to even greater danger, particularly where, some might say, the SBN has a vested interest in discrediting
me now, a motive, a bias, some might say (I take no position in that regard at the current time). Please note my new phone number as well. While Mr. King has referred to some
upcoming SCR 105 hearing (a "combo hearing" akin to the one's, including a Trial that DDA Young and his crew of Washoe County Public Defenders have been trying to run on me
this year, including attempting to hold a Trial on May 7th, 2012 in RCR2011-0063341 where the Order finding me competent and remanding jurisdiction to the Justice Court in CR12-
0376 was only signed, entered, and file stamped on May 9th, 2012...A big no-no under NRS 178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for given his
communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and 12 CR 12420. This could be your Waterloo, so I hope you will investigate this properly.
Especially considering the Order granting Loomis' withdraw in the criminal trespass case Mr. King just filed an SCR 111 petition in occurred during the pendency of such an
evaluation on May 8th, 2011 (lots going on between May 7th-May 9th, 2012, here!) and the fact that Loomis and or the RMC ramrodded a Trial setting of June 18th, 2012 on May 8th,
2012 as well, well before Coughlin's competency was determined...and to the extent King indicates NG12-0204 and NG12-0435 rely on "Orders" entered or rendered during periods
in which NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no good. Please don't make my address public yet or disseminate it in any way.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, 89512
Tel and Fax 949 667 7402
Sent: Mon 10/22/12 12:33 AM
To: complaints@nvbar.org; complaint@nvbar.org; rosec@nvbar.org; davidc@nvbar.org; patrickk@nvbar.org;
glennm@nvbar.org
Dear Bar Counsel,

Please accept this filing of a formal grievance against the attorneys listed and mentioned herein. The basic import of this
grievance is that these public defenders and prosecutors seek to leverage the benefits of Order for Comptency Evaluations (buy
them some time to do research once they get cornered or exposed) while avoiding any of the dictates of NRS 178.405 and NRS
5.010 requiring "all proceedings" be stayed.

There was an Order For Competency Evaluation by Judge Clifton in RCR2012-065630 entered February 27th, 2012, and the
Order in CR12--0376 adjudging Coughlin competent and remanding jurisdiction back to the lower court was not entered until
May 9th, 2012, yet Loomis and Hazlett-Stevens persisted in seeking to ramrod the criminal trespass case in RMC 11 CR 26405
through...and both were well aware of the February 27th, 2012 Order for Competency Evaluation and the import of NRS
178.405, requiring the suspension of all proceedings during the pendency of such an Order. Further, the RMC failed to file the
timely Notice of Appeal I submitted for filing on June 28th, 2012, and which was served by delivering to the City Attorney's
Office on June 27th, 2012 (timely within 10 days under NRS 189.010) resulting in the dismissal of the appeal.

Further, Loomis and Puentes deprived me of my right to supboena witnesses to defend myself in RMC 11 CR 26405, a criminal trespass matter resulting in a criminal trespass conviction on June 18th,
2012, which I reported to Bar Counsel in compliance with SCR 111. SBN Bar Counsel King has the audio from two of the pre-trial hearings and I am attaching the audio of the trial or linking to it herein.
It demonstrates the fact that Dr. Merliss was a percipient, material eye witness (in fact Dr. Merliss lied to the RPD in effectuating this wrongful arrest, and Sargent Marcia Lopez has admitted to me,
contrary to RPD Officer Chris Carter's police report and Richard Hill's June 18th, 2012 sworn testimony and Casey Baker, Esq's (whom was not even there on November 13th, 2011) NRCP Rule 11
violating (given he possessed the video's taken by Dr. Merliss and his supervisory attorney, Richard G. Hill, Esq, which were propounded to the Reno City Attorney's Office and which both Loomis
and Puentes had, which further demonstrate their culpability. There is a suggestion that these "contract" court appointed defenders put their own profit motive above their client's rights to subpoena
witnesses and gather evidence to defende their cases (similar to the refusals by WCPD Jim Leslie, Loomis refused to procure and provide the audio of two extremely relevant court proceedings in the
RJC, necessary to the defense of RMC case, which led to 18 days wrongful incarceration of me from July 3, 2012 to July 21st, 2012 in RMC 12 CR 12420. The two RJC matters are the Milan Krebs TPO
hearing in RJC RCP2012-000287 (particularly necessary to the defense of that matter, in addition to the matter Leslie represent me on incident to a wrongful June 28th, 2012 arrest by the WCSO in
RCR2012-067980, incident to a fraudulently procurred Summary Eviction Order (stemming from the fraudulent Declaration of Personal Service by license process server Robert Wray for Nevada Court
Services, which was committing the unauthorized practice of law (deeming themselves an "eviction consulting and process service company" in RJC rev2012-001048, where Wray lied about
"personally serving" me a June 14th, 2012 5 day unlawful detainer notice (he tried to break and enter my rental #29, which had not windows and which had a locked front door at the time that he and
Northwind Apartments Manager Duane Jakob attempted to break and enter and committ another trespass (as they had done previously, when they failed to get the City of Reno Code Enforcement to
do their bidding in seeking to subvert the summary eviction process, and where the RPD, though making threats to arrest me for criminal trespass violative of Soldal v. Cook County, was taking too
long to "help" Northwind out. WCPD Leslie failed to inform me or notify me in any way as to the fact that the WCDA filed, on August 23rd, 2012, a document listing Jakob as a witness it intends to
call in its prosecution of me in RCR2012-067980. Further, WCPD Biray Dogan failed to inform me in any way of the fact that, on July 31st, 2012, DDA Young filed a Motion to Amend Criminal Complaint
wherein he, lacking a RPC 3.8 probable cause basis to do so, seeks to amend his charge in RCR2012-065630 to a charge that would invoke, upon a conviction, the reporting requirements of SCR 111(6),
rather than maintain the difficult task of prosecuting one for "misue of 911" where 911 was allegedly utilized to report police misconduct, whereupon 911 operators purportedly efused to document such
a complaint or report in any way. Additionally, Henry Sotelo, similar to Loomis, refused to procure and provide to his client, Coughlin (once Loomis received his second Order granting his withdrawal
as court appointed counsel for Coughlin, once in RMC 11 CR 26405 (now a SCR 111(4) petition, filed by Bar Counsel against Coughlin on October 15th, 2012) and again in RMC 12 CR 12420 (Loomis
also refused to send a request for discovery or subpoena duces tecum to the City of Reno or RPD for the various police reports Sargent Dye and Officer Weaver reference during an impermissible,
unnotice, impromptu bail hearing (wherein Jill Drake, Esq. committed professional misconduct) on July 5th, 2012 (at which RMC Judge Gardner again failed to recuse himself despite the pending
grievances filed on his behalf by Judge Nash Holmes, NG12-0434 and NG12-0435, the latter of which resulted from Judge W. Gardner's sister passing to him, her brother, her April 2009 Order After trial
sanction Coughlin, to RMC Judge Nash Holmes, whom filed it on March 14th, 2012 with Bar Counsel, along with her admission to to communications with the WCPD's Office, which the WCPD'S
Office, including Bosler, Dogan, and Leslie, have refused to comment on to Coughlin in any way, aside from Leslie's dubious assertion that he is completely unaware of such.

Regardless, given the import of NRS 178.405 and NRS 5.010, the June 18th, 2012 Trial in RMC 11 CR 26405 should have never taken place, should have never been set on May 8th, 2012 (particularly
where the 2/27/12 Order for Competency Evaluation in RCR2012-065630, to which Loomis admits to have been aware of, was not ruled upon by D10 ("Tiburon" prinout sua sponte gathered by Judge
Gardner aside, where Loomis didn't manage to get one, though he did argue that an unofficial online "docket" was somehow capable of providing judicial notice of an Order Finding Coughlin
competent on May 8th, 2012, which is clearly violative of NRS 178.405 and NRS 5.010). Additionally, it is preposterous to find that Coughlin was able to make the decision to proceed without Loomis
or other court appointed, Sixth Amendment satisfying representation, on May 8th, 2012, given the Order by D10 in CR12-0376 finding Coughlin competent did not get signed and entered until May 9th,
2012. This is reminiscent of DDA Young filing an Opposition to Coughlin's Motion to Appear as Co-Counsel in RCR2011-063341 after the entry of the 2/27/12 Order for Competency Evaluation by
Judge Clifton in RCR2012-065630 (though the docket lists Judge Schroeder as presiding over that "clandestine" status conference, so deemed in light of Coughlin being notice in writing that it had
been vacated to March 29th, 2012, in light of the scheduling conflict presented by the RMC 11 TR 26800 traffic citation trial set for 1:00 pm on 2/27/12 before Judge Nash Holmes, which she held
anyways, despite the dictates of NRS 178.405 and NRS 5.010 and the communicatiosn Judge Nash Holmes admits to in the March 14th, 2012 grievance she filed on behalf of all RMC Judges
(including pro tempore ones) on March 14th, 2012, and for which Judge William Gardner admits to being aware of, as does City Attorney Hazlett-Stevens, whom makes ridiculously mincing arguments
respecting the difference in being "competent" to practice law versus being "competent" to stand trial, even where he was aware of RCR2012-065630 and CR12-0376. Further, upon information and
belief, Hazlett-Stevens demonstrates a lack of candor to tribunals where he argues he was not "served" documents that he recieved via email and or faxwhere the RMC Rules allow for such
transmissions to constitute service upon "governmental attorneys". I reserve my right to supplement this grievance further at a later date. Additionally, Mr. Sotelo violated NRS 178.405 and NRS 5.010
on September 30th, 2012 where he filed a Motion to Withdraw as Coughlin's Counsel of Record in 12 CR 12420 during a period in which a September 5th, 2012 (though it might be file stamped
September 7th, 2012) Order for Competency Evaluation of Coughlin in RCR2011-063341 was entered (and which the RMC, City Attorney Sooudi, and RMC defender Sotelo recognized as requiring a
stay of a Motion Hearing in 12 CR 12420 on September 18th, 2012...). Sotelo compounds his misconduct by making spurious and vague allegations against his then client Coughlin in that Motion
alluding to some "repugnant" course he alleges Coughlin wishes to maintain, though, predictably, Sotelo fails to provide any support for his egregiously prejudicial statement, damaging of his client's
interests and defense, all while violating NRS 178.405 and NRS 5.010.

Further, given the correspondences admitted to between Puentes and Loomis with the Washoe County Public Defender's Office, and in light of the fact that both Loomis and Puentes are employed by
the RMC, the various Orders for Competency Evaluation filed since the first one of September 8th, 2011 regarding Coughlin, in RCR2011-063341, vitiate the import of all subsequently void Orders
predicated upon any part of any proceeding not stayed during the pendency of such an Order for Competency Evaluation. That means, the conviction in RMC 11 CR 22176 underpinning the SCR
111(6) petition in 60838 resulting in Coughlin's current temporary suspension of his law license, is necessarily void, particularly where the arraignment took place at a time (October 10th, 2011) when
Coughlin's competency was put into question, particularly where RMC defender Lew Taitel, appointed at Coughlin's court ordered defense counsel beginning on November 19th, 2011, was aware of
the pending Order for Competency Evaluation in RJC RCR2011-063341 at the time of the November 30th, 2011 Trial in RMC 11 CR 22176. resulting in Coughlin's conviction for petty larceny. Please add
Pamela Robert, Esq., City of Reno prosecutor on that matter to this grievance in that regard as well, in addition to her coworker Allison Ormaas, particularly where she appeared and offered argument
both at the 2/27/12 Trial in 11 TR 26800 in the RMC, but as well as the February 12th, 2012 continuation of that Trial. In that regard, all of Judge Nash Holmes purported Orders, including those finding
Coughlin "by clear and convincing evidence" to be guilty of "summary criminal contempt" and other violations of the Rules of Professional Conduct incident to the traffic citation trial in 11 TR 26800
on 2/27/12 that Judge Nash Holmes, despite the mandates of NRS 178.405 and NRS 5.010, transmogrified into a disciplinary proceeding against a pro se attorney indigent criminal defendant denied his
Sixth Amendment Right To Counsel in a proceeding wherein jail time was ultimately ordered, are also void, to the extent they are not already void given the divesting of her jurisdiction incident to
Coughlin filing, on March 7th, 2012, a Notice of Appeal of that summary contempt order as rendered (especially where the March 28th,2 2012 written Order by Judge Nash Holmes was mailed to an
address for Coughlin that the RMC knew was no longer good). Most recenlty, WCPD Dogan and Goodnight, in a stipulation with DDA Young sought to swap an October 15th, 2012 hearing date in
RCR2012-063341 with Dogan (though Dogan has not communicated with me at all in what seems like months, and Leslie appears to be taking ownership of that case, in RCR2012-065630, though Leslie
does not communicate with me much at all either...and most of the information I glean from this matters is culled from repeated trips to the filing office, where bailiffs have implemented rules limiting my
access to justice to 15 minute installments...). The public defenders (including Sotelo, whom only sent me a copy of his Motion to Withdraw after the Order granting it was signed...) repeatedly fail to
adhere to the RPC concerning their duty to communicate with clients., particularly where I have put them on written notice respecting my demands to be copied on any and all filings and
correspondence in any way connected to any of my cases.

To wit:
"CERTIFIED COPY OF DOCKET
13 November 2011: Criminal Complaint issued upon the oath of Reno Police
Department Officer Carter.
Charge I: Trespass, a violation ofR.M.C 08.10.0lD.
14 November 2011: Defendant appeared while in custody before Judge William Gardner
for arraignment. The defendant was represented by Keith Loomis Esq. and on behalf of the City
was Christopher Hazlett-Stevens. The defendant was advised of his Constitutional rights. The
Defendant entered a plea of Not Guilty and a trial date was set for December 13, 2011. Lewis
Taitel Esq. was appointed to represent defendant. Defendant's request for release on O.R. was
denied.
15 November 2011: Cash bail in the amount of$3 1 0.00 wa.s posted and the defendant was
released from the Washoe County Jail.
23 November 2011: Motion To Continue With Supporting Declaration filed by
Deputy City Attorney Christopher Hazlett-Stevens.
28 November 2011: Order Continuing Trial signed by Judge William Gardner.
30 November 2011: Trial date of January 10,2012 set by the court. Legal Defender
Roberto Puentes was appointed as Attorney for defendant for new trial date.
14 December 2011: Motion To Proceed Inforrna Pauperis filed by defendant.
03 January 2012: Motion for New Trial Date filed by Legal Defender Roberto
Puentes.
04 January 2012: Motion for New Trial Date granted by Judge William Gardner.
18 January 2012: Motion For Withdrawal Of Attorney filed by Legal Defender
Roberto Puentes. A motion hearing was set for February 2,2012.
02 February 2012: Motion hearing held before Judge William Gardner. Present at
the hearing on behalf of the City was Deputy City Attorney Jill Drake, for the defense Roberto
Puentes and defendant Zachary Couglin. Motion To Withdraw was granted. Legal Defender
Keith Loomis was appointed to represent defendant.
13 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication Of
Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
16 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication Of
Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
22 February 2012: Opposition to Defendant's Motion filed February 13,2012, filed
by Deputy City Attorney Jill Drake.
05 March 2012: Trial date set for April 10, 2012 by Court.
05 March 2012: Notice Of Appearace As Co-Counsel And Motion To Dismiss filed
defendant.
20 March 2012: Order #1 denying defendant's motion filed 13, February 2012 signed
by
Judge William Gardner.
21 March 2012: Order #2 denying defendant's motion filed 5, March 2012 signed by
Judge William Gardner.
21 March 2012: Motion To Strike Defendant's Motion To Dismiss Complaint filed by
Deputy City Attorney Christopher Hazlett- Stevens.
10 April 2012: Defendant appeared for trial with counsel Keith Loomis, Judge William
Gardner presiding. Present on behalf of the City was Christopher Hazlett-Stevens. Several
pre-trial motions were heard. An Order Suspending Proceedings was signed. All
proceedings suspended until the question of competence is determined. Case Status Hearing
scheduled for 8, May 2012.
08 May 2012: Case Status hearing held before Judge William Gardner. Present on
behalf of the City was Deputy City Attorney Christopher Hazlett-Stevens, for the defense
Keith Loomis and defendant Zachary Coughlin. Defendant was found to be competent.
Defendant's motion to remove Keith Loomis as counsel granted. Trial date set by the court
for June 18,2012.
OS June 2012: Notice Of Appearance As Counsel ; Motion To Dismiss; Motion To
Suppress; Motion For A Continuance Of Trial And Transfer To Mental Health Court filed by
defendant.
18 June 2012: Defendant appeared for trial pro-per, Judge William Gardner presiding.
Present on behalf of the City was Christopher Hazlett-Stevens. Several pre-trial motions
were heard. Motion to Continue filed by defendant denied. Motion to Dismiss filed by
defendant denied. Motion to Suppress denied. Motion to Recuse denied. Motion to Transfer
to Mental Health Court denied. Case tried on its merits and the Defendant was found guilty of the
charge of Trespass, a violation of R.M.C 08.10.010.
The Defendant was sentenced as follows:
Trespass, a violation of R.M.C 08.10.0 10. : Time Served and a $310.00 fine.
26 June 2012: Motion for New Trial filed by defendant.
11 July 2012: Order Denying Motion For New Trial & For Other Relief signed by Judge
William Gardner.
18 July 2012: Notice Of Appeal filed by defendant.
19 July 2012: Notice Of Appeal filed by defendant.
2 3 July 2012: Notice Of Appeal filed by defendant.
25 July 2012: Notice of Appeal, motion to Vacate and or Set Aside, JCRCP 59, JCRCP 60,
Motion for Reconsideration; Motion for Recusal; Motion For Publication Of Transcript at
Public Expense, Petition for In Forma Pauperis Status filed by defendant.
Municipal Judge.
Department Two
CERTIFICATE OF TRANSMITTAL OF COMPLETE RECORD ON APPEAL
1, Cassandra Jackson, Court Administrator of the Reno Municipal Court, do hereby
certifY that the attached documents include full, true and correct copies of all papers relating
to Case Number II CR 26405 21, including a Certified Copy of Docket, Plaintiff's exhibits 1-
3. Further, said documents have been transmitted to and filed with the clerk of the Washoe
County District Court. Transcript to follow."
Further, Taitel took on my representation despite a clear conflict existing, ie, I was suing his business partners, Nevada Court
Services (with whom he shares a fax number, mailing and physical address, receptionist, is listed as "associated with" and "Staff
Attorney" on the Nevada Court Services official web site, etc....all while NCS was trespassing against me at my former home
law office, while being hired by Richard G. Hill and Casey Baker, Esq.. I submitted an IFP and propsed Complaint in the
District Court on October 19th, 2011 CV11-
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402

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