9 8 11 To 1 3 13 Emails To @reno - Gov Addresses 0204 60838 26800 22176 26405 00696 12420

INDEX OF EMAILS FROM COUGHLIN TO @RENO.
GOV ADDRESSES FOR

0204, 22176, 26506, 00696, 26800, 12420
Date Subject
1/03/13 RE: Please email me recording of leedy
1/02/13 Please email me recording of leedy
12/31/12 request for Reno ars!al"s re#ort
12/21/12 $ am %riting to request a fee %ai&er of t!e yearly '300 efle( c!arge
12/20/12 motion for ne% trial) notice of a##eal
12/1*/12 court refusing to file documents and e(!ibits missing
12/1*/12 R+ certifying Second ,udicial filings to S-. e(!ibit 1/ from
11/10/12 %as ne&er #ro&ided to coug!lin
12/13/12 1!e 1!ree E"s2 %c#d failure to #ro&ide essential *11 call cd disco&ery of 3/13 and 3/14) 2012
12/0//12 your office refused %!at $ tried to deli&er it yesterday
12/0//12 DD5 6oung retaliatory #rosecution of domestic &iolence &ictim
12/0//12 -ailiffs detaining me) &iolating court!ouse sanctuary doctrine) #!ysically restraining me)
12/07/12 your email %as unreadable
12/00/12 formal %ritten grie&ance against S8au) 6oung) 9eslie) Dogan) etc: ;<: *11 calls missing f
11/23/12 Please get t!is to t!ese +ity of Reno em#loyees
11/23/12 +!ief ars!al Ro#er and ars!al =arley on setting t!e record straig!t in .>12?0037
11/22/12 ;<: #lease indicate some res#onse to my sub#oena and disco&ery requests
11/22/12 &ideo of RPD arcia 9o#e@ admitting to misconduct on 1/13/12 su##orting inference of retaliation
11/22/12 ,udge =o%ard and +assandra ,ac8son %ant to e(#lain
11/22/12 <as!oe 9egal Ser&ices Paul Elcano and State -ar of .e&ada"s +oe S%obe"s contacts %it! my family
11/1*/12 9$1$>51$A. =A9D .A1$+E 1A 1=E RE.A B.$+$P59 +ABR1 R+ -allard
11/10/12 ne% Disco&ery finally #roduced by Reno +ity attorney on 1/12/12 ,ay%al8ing arrest in S+R 107
11/10/12 +ity 5ttorney S8au) u#dated disco&ery in iP!one case) dis#atc! recordings) don"t seem to
11/11/12 1ribal Police not allo%ed to arrest for misdemeanors ;<: +ase .o: R+R2011?0/3301
11/0*/12 SB-PAE.5 5.D SB-PAE.5 DB+ES 1E+B 5115+=ED
11/03/12 RE: +ase .o: R+R2011?0/3301
11/03/12 RE: 511. Renee -ro%n Reno Postmaster re;<: com#laint by Reno .e&ada 5ttorney
11/03/12 RE: R+R12?0/7/30
11/03/12 C.o SubjectD
11/04/12 C.o SubjectD
11/07/12 +95R$;$+51$A. on +!ange of 5ddress for
11/07/12 ;<: #lease file t!is %it! t!e R+
11/00/12 RE: con&icting attorney of summary criminal contem#t during #endency of Arder for
11/00/12 ;<: con&icting attorney of summary criminal contem#t during #endency of Arder for
11/00/12 ;<: r: Eing"s assertion in !is 3/1//12 letter
11/03/12 ;<: request for audio records
11/07/12 ;<: #lease file t!is %it! t!e R+
11/00/12 RE: con&icting attorney of summary criminal contem#t during #endency of Arder for
11/00/12 ;<: con&icting attorney of summary criminal contem#t during #endency of Arder for
11/00/12 ;<: r: Eing"s assertion in !is 3/1//12 letter
1/0
11/03/12 con&icting attorney of summary criminal contem#t during #endency of Arder for +om#etency
11/02/12 RE: #lease email me t!e materials #roduced by ecomm/E: Adom/ dis#atc! ta#es
11/01/12 RE: +oug!lin: Petit larceny case
10/12/12 you &iolated .RS 143:007
10/11/12 RE: +oug!lin: R+R11?0/3301 CPetit 9arcenyD and R+R12?0/4*30 CResistingD and
10/11/12 ;<: res#ectfully submitted
10/10/12 Arder dissol&ing #rotection order Erebs &: +oug!lin re .ort!%ind 5#artments
10/10/12 $ demand my summary e&iction !earing) before a jury based u#on / 23 12 notice and my fa(ed
10/10/12 9$1$>51$A. =A9D .A1$+E +A.+ER.$.> 5.6 RE+ARDS 6AB =5FE 5DE
10/01/12 my car %as searc!ed incident to a routine traffic citation by Afficer <ea&er) %!o t!reatened to do
*/23/12 9$1$>51$A. =A9D .A1$+E BPD51E RE>5RD$.> SEP1E-ER 21) 2012 RPD
*/23/12 $ .EED 5++ESS 1A 6 PRAPER16 1AD56) $ED$51E96) A1=ER<$SE $ <$99 $.+BR
*/22/12 ;<: Soldal &: +oo8 +ounty ;<: Ferified +om#laint for $llegal 9oc8out attac!ed
*/22/12 Soldal &: +oo8 +ounty ;<: Ferified +om#laint for $llegal 9oc8out attac!ed
*/21/12 9$1$>51$A. =A9D .A1$+E BPD51E RE>5RD$.> SEP1E-ER 21) 2012 RPD
*/21/12 9$1$>51$A. =A9D .A1$+E
*/21/12 C.o SubjectD
*/21/12 9$1$>51$A. =A9D .A1$+E ;<: Reno e&iction noticed for S#ar8s ,ustice +ourt
*/21/12 !ere is t!at citation you as8ed for
*/21/12 9$1$>51$A. =A9D .A1$+E 5.D SB-PAE.5your 11 4 11 res#onse to disco&ery request in rjc
*/13/12 request to meet) confer) and #re#are for trial 9$1$>51$A. =A9D .A1$+E
*/11/12 %rongful arrests) malicious/retaliatory #rosecutions ;<: Reno e&iction noticed for S#ar8s ,ustice
*/03/12 #lease note my ne% address if it !as not already been noted
3/24/12 11 +R 2/007 and a##eal in +R12?12/2: .otice of R+"s failure to file timely filed .otice of 5##eal
3/04/12 motion for #re#aration of transcri#t at #ublic e(#ense etc
3/04/12 ;<: res#ectfully submitted
3/0//12 global resolution
3/0//12 ;<: Reno e&iction noticed for S#ar8s ,ustice +ourt
3/0//12 request for a #re trial motion and bail motion
4/31/12 request for consideration of global resolution
4/27/12 / 2/ 12 %arning to %cso r#d) etc: Reno e&iction noticed for S#ar8s ,ustice +ourt
4/27/12 Reno e&iction noticed for S#ar8s ,ustice +ourt
4/27/12 ;%d: <!eeler & cross 300 fed a##s 020
4/27/12 <!eeler & cross 300 fed a##s 020
4/20/12 #lease #ro&ide to ,udge >ardner) see8ing #ermission to file
4/02/12 ;<: Reno e&iction noticed for S#ar8s ,ustice +ourt
//23/12 motion for ne% trial
//24/12 motion for ne% trial) motion for reconsideration) motion to alter or amend
//2//12 Reno e&iction noticed for S#ar8s ,ustice +ourt
//22/12 .+55 and D%ayne ja8ob
//22/12 .e&ada court ser&ices attac8 and attem#ted brea8 in
//03/12 res#ectfully submitted
//0//12 +ory >oble battery
7/0*/12 ental !ealt! court
7/02/12 ;<: release of information to my attorney
0/1//12 #lease file t!is %it! t!e R+
0/1//12 +=5.>E A; 5DDRESS 511AR.E6 +AB>=9$.
0/1//12 +ARRE+1$A. +=5.>E A; 5DDRESS 511AR.E6 ) ESG:
0/13/12 c!anging my address on #ortal
2/0
0/00/12 ;<: E&idence
0/00/12 RE: E&idence
3/2*/12 r#d sargent sifre loses H coug!lin"s dog ,ac8son is gone &oicemail from C447D 4/2?17*7 at 0:24 P
3/2*/12 +ity of Reno ars!al Di&ision =arrassment) !anging u# #!one on me) R+ sei@ing Reno 5ttorney"s
3/2*/12 +ity of Reno ars!al Di&ision !anging u# #!one on me) R+ sei@ing Reno 5ttorney"s smart #!one
3/23/12 #lease note my ne% address) SA95+E PRA>R5 REGBES1
3/2//12 i %as e&icted 3 17 12) i need a continuance
3/21/12 traffic/#ar8ing citations
3/03/12 ;<: +ity +ler8"s Affice
3/04/12 .otice of 5##eal and Ation for::::
3/03/12 #lease find motion to dismiss attac!ed for 11 cr 2/007
2/22/12 ;<: +ity +ler8"s Affice
2/17/12 .A1$+E A; 5PPE59 A1$A.
2/10/12 E&ictions RE: <+SA De#uty ac!em"s I#ersonally ser&edI 5ffida&it of 11/1/2011
2/03/12 +ity +ler8"s Affice
2/0//12 <+SA De#uty ac!em"s I#ersonally ser&edI 5ffida&it of 11/1/2011
1/30/12 ;<: R+ 11 +R 2214/ #art four E(!ibit 1 #ages /01?401 of otion for .e% trail from 12 12 2011 ey
1/30/12 ;<: R+ 11 +R 2214/ #art four E(!ibit 1 #ages 401?4*0 of otion for .e% trail from 12 12 2011 ey
1/30/12 ;<: R+ 11 +R 2214/ #art four E(!ibit 1 #ages /01?401 of otion for .e% trail from 12 12 2011 ey
1/30/12 ;<: otion for .e% 1rial Etc: in R+ 11 +R 2214/
1/30/12 ;<: otion for .e% 1rial Etc: in R+ 11 +R 2214/
1/30/12 audio of ,udge =o%ard regarding deadline to file .otice of 5##eal ;<: R+ said $ could file t!is
1/2//12 RE: Request for Public $nformation
1/1//12 #lease #ro&ide to RPD $nternal 5ffairs in addition to acce#ting t!is request for your ser&ices
1/10/12 RE: 6our Anline Police Re#ort 112000223 =as -een Submitted
1/0*/12 RE: debt &alidation documentation request and dis#ute letter under ;D+P5 to +ity of Reno et al
1/0*/12 debt &alidation documentation request and dis#ute letter under ;D+P5 to +ity of Reno et al
1/0*/12 #roof of insurance and registration 5ffida&it/Declaration and su##orting documentation
12/20/11 RE: request for audio records
12/21/11 no re#ly from 1ranscri#tionist
12/1*/11 $ %ill fa( t!is to s: Roberts and t!e R+ as %ell) t!is is a courtesy co#y
12/1*/11 ;<: emergency
12/1*/11 emergency
12/14/11 ;<: 121 Ri&er Roc8
12/1//11 emergency filings
12/1//11 ;<: R+ 11 +R 2214/
12/17/11 R+ 11 +R 2214/
12/17/11 rmc 11 cr 2214/
12/10/11 R+ issues
12/10/11 RE: essage left on 12/13/2011
12/10/11 RE: $;P/ ;$.5.+$59 $.GB$R6 5PP9$+51$A.
12/10/11 $;P/ ;$.5.+$59 $.GB$R6 5PP9$+51$A.
12/13/11 ;<: records request
12/13/11 records request
12/13/11 R+ 11 +R 2214/ #art four E(!ibit 1 #ages /01?401 of otion for .e% trail from 12 12 2011 ey
12/12/11 defamation la%suit/%rongful arrest/#erjury under color of state la% arrest:
12/12/11 audio of t!e .o&ember 30t! 1rial in ,udge =o%ards court
12/12/11 =ere is ser&ice of t!e otion
12/12/11 R+ 11 +R 2214/ #art four E(!ibit 1 #ages 401?4*0 of otion for .e% trail from 12 12 2011 ey
3/0
12/12/11 R+ 11 +R 2214/ #art four E(!ibit 1 #ages /01?401 of otion for .e% trail from 12 12 2011 ey
12/12/11 otion for .e% 1rial Etc: in R+ 11 +R 2214/
12/12/11 otion for .e% 1rial Etc: in R+ 11 +R 2214/
12/12/11 ;<: R+ said $ could file t!is by email
12/03/11 signed REGBES1 ;AR RE+ARDS +D/DFD A; 1R$59 5.D A1=ER DA+BE.151$A.
12/03/11 RE: your failure to #ro#ound disco&ery
12/03/11 request of cd of trial in 11 +R 2214/ 2$
12/03/11 RE: your failure to #ro#ound disco&ery
12/04/11 your failure to #ro#ound disco&ery
12/04/11 disco&ery request2
12/00/11 your co# lying) see your &ideo dri&ers license #roduce a# o&er&ie% at /:0* mar8
12/00/11 ;<: your co# lying) see your &ideo dri&ers license #roduce a# o&er&ie% at /:0* mar8
12/00/11 your co# lying) see your &ideo dri&ers license #roduce a# o&er&ie% at /:0* mar8
11/2*/11 RE: 5ttac!ed $mage / Sub#oena
11/2*/11 RE: 5ttac!ed $mage / Sub#oena
11/2*/11 ;<: tem#orary address c!ange and instruction to #ursue a continuance
11/2*/11 RE: motion for continuance
11/23/11 Reno unici#al +ourt a##ointment of counsel
11/22/11 RE: tem#orary address c!ange and instruction to #ursue a continuance
11/21/11 &erint user agreement
11/21/11 RE: motion for continuance
11/21/11 tem#orary address c!ange and instruction to #ursue a continuance
11/1//11 .R+P Rule 11 and duty to ma8e reasonably diligent inquiry/e(cul#atory e&idence/#rosecutors
11/1//11 RE: motion for continuance
11/1//11 RE: motion for continuance
11/11/11 motion for continuance
10/00/11 records request for incident re#ort urgent #lease
*/0*/11 Re: 6our Anline Police Re#ort 111007*7/ =as -een Rejected
*/03/11 Re: 6our Anline Police Re#ort 111007*7/ =as -een Rejected
*/03/11 Re: 6our Anline Police Re#or
0/0
Close Print
RE: Please email me recording of leedy
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 1/03/13 9:07 AM
To: Daniel Wong (wongd@reno.gov); RobisonJ@reno.gov (robisonj@reno.gov)
Thank You Chief Deputy Wong,
Much appreciated. If at all possible, could a copy of the file be emailed? I belive its a very small audio file, and probably in .cda format (which is
what music cd's are typically in, which means one must "rip" the file from the cd to a hard drive...then upload it as an attachment to an email...and be
careful not to merely drag and drop or copy the .cda file, as those aren't really "the file", they are 1kb or so quasi-files...(confused? me too....but wait, don't
you have a sort of blog? You must be fairly computer savvy to do that...http://www.ehow.com/how_5585651_rip-cda-files.html
http://www.ehow.com/how_8717603_rip-cda-wav.html
http://www.youtube.com/watch?v=J_6kO-HrUqM )
I understand if its too big a hassle and appreciate your provided another copy by any method.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
> Date: Thu, 3 Jan 2013 07:16:00 -0800
> From: wongd@reno.gov
> Subject: RE: Please email me recording of leedy
> To: zachcoughlin@hotmail.com
> CC: RobisonJ@reno.gov
>
>
> Another copy will be mailed to you today.
>
>
>
>
> -----Original Message-----
> From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
> Sent: Wednesday, January 02, 2013 4:30 PM
> To: wongd@reno.gov
Please email me recording of leedy
request for Reno Marshal's report
> Subject: Please email me recording of leedy
>
> In 12 CT 00696 the CD you provided was scratched
>
> Zach Coughlin 7753388118 PO Box 3961 89505
Sent: Wed 1/02/13 4:29 PM
To: wongd@reno.gov
In 12 CT 00696 the CD you provided was scratched
Zach Coughlin 7753388118 PO Box 3961 89505
Sent: Mon 12/31/12 4:22 PM
To: roperj@reno.gov (roperj@reno.gov)
Dear Chief Roper,
Hello, Sir.
As far as I know you are not an employee of the Reno Municipal Court.
I am writing to request that you provide me with a copy of any reports or documentation involving me (whether about me, received from me, or in
connection with any of the arrests made by your Marshal's (including the 11/30/11 summary civil contempt arrest in 11 CR 22176 before Judge Howard
in Department 4, or the 2/27/12 summary contempt arrest in 11 TR 26800 before Judge Nash Holmes in Department 3).
I also ask that you provide me with a copy of anything you have sent the State Bar of Nevada about me (including some means of determining what was
included in any such transmissions, ie, so I will know the difference between what you may be providing me in reference to my above request, and this
more specific request regarding materials you (or the RMC after being requested from you) provided to the State Bar of Nevada.
http://www.washoecounty.us/large_files/agendas/072407/4.pdf
At the above link, from
Here in Nevada we love to have Judges, Sheriff's, District Attorney's, Chief of Police, etc., etc., write letters of recommendation for or endorse candidates for judicial office, for the public defender
positions, etc., etc., no matter how tacky and inappropriate that is, or what appearance of impropriety, bias, or conflcit it may exude:
http://www.washoecounty.us/large_files/agendas/062105/7.pdf
Please note that with respect to any subpoenas served on you, your Marshals, etc., that NRCP 45 is not strictly applied, as it is modified in the context of a
formal disciplinary hearing, and the SBN/Panel/Board, waived all subpoena or subpoena duces tecum witness fees and granted me the right to issue my
own supoenas (ie, they do not need to be issued by the SBN Clerk of Court or bare the SBN seal). Therefore, it is my position that the Marshals whom I
had served by a non-party on or about 12/6/12, and any subpoena duces tecum served, must be complied with, lest one risk being in contempt.
Regardless, I believe I am entitled to at least one copy of the City of Reno Marshal's report and probable cause sheet in connection with both of those
contempt arrests.
Please ALSO CONSIDER THIS AN OPEN RECORDS LAW REQUEST FOR DOCUMENTATION/ FREEDOM OF INFORMATION ACT
REQUEST:
http://www.sunshinereview.org/index.php/Nevada_Open_Records_Act
I would greatly appreciate it if you would either email or fax me these materials in addition to any recordings or other media in your control or made by your Marshals (I know Marshals Thompson
and Coppa admitted to recording me in their letter/affidavit to the State Bar of Nevada on or about March 22nd, 2012.
I do not know of you being represented by an attorney. If you are please provide me their contact information, or at least, their name. You may want to consult with an attorney in connection
with this request. I will note again that Marshal Menzel has recently taken to following me around the courthouse, including appearing in the Reno Justice Court filing office when I go there (even
if I had not previously gone to the Reno Municipal Court during such a visit) and up to the District Attorney's Office on the fourth floor of 1 South Sierra St. and back down, staring at me, facing me,
glaring and often making comments about my not having a job. Please note that Marshal Menzel previously worked as a Bailiff at the RJC, and wrote a letter of recommendation for RMC court
appointed defender Lew Taitel, whom is listed as "Staff Attorney" for Nevada Court Services, whom I was suing at the time in November 2011 when Mr. Taitel accepted my case for representation
in the criminal trespass matter before Judge William Gardner in 11 CR 26405 in the RMC. I sued Judge WIlliam Gardner's sister in case 54844 in the Nevada Supreme Court, and she and her
brother, Judge William Gardner, and Judge Nash Holmes filed a grievance against me with the State Bar of Nevada, which has now become a Complaint in NG12-0435 and NG12-0434 seeking to
have me disbarred, which rest largely on an allegation by Judge Nash Holmes that Marshal Harley told her certain things, and Coughlin is entitled to the Marshal Reports related thereto and has
not been provided them.
All sorts of conflicts of interest are detailed at the following link, many involving the actions against me of late and the connections between Judge Nash Holmes, Judge Linda Gardner, Judge
William Gardner, RMC court appointed defender Lewis Taitel (whom never did comply with RMC Rules in putting into writing to reason for his seeking to withdraw as counsel of record in RMC 11
CR 26405), Terri Vaus-Wong, Judge Linda Gardner's former law partner Gayle Kern, Esq. (see RJC rev2012-000374, wherein Judge Schroeder entered a default summary eviction Order against me,
carried out less than 5 hours latter by the Washoe County Sheriff's Office, at gunpoint, without identifying themselves prior to breaking in, similar to WCSO's Deputy Machen's conduct in rcr2012-
067980, and which interferred with Coughlin's representation of his client Keller in the NVB adversary proceeding Cadle Company v. Keller in 10-05104 on 3/15/12, just 5 hours after Coughlin
showed up to the RJC for the summary eviction hearing in rev2012-000374, where the hearing was noticed for 8:30 am, despite the fax header on the Lockout Order to the WCSO and or RJC Filing
Office indicating a time of 8:24 am, and despite Coughlin being accused of a RPC violation that Kern herself her seems to violate in obtaining a default where she clearly knew Coughlin was
contesting the eviction and she saw Coughlin walking into the courtroom as she was walking out of it with her default summary eviction Order being obtained:
http://www.ripoffreport.com/real-estate-services/gayle-kern-esq/gayle-kern-esq-gayle-kern-de-f9bb7.htm ), the Washoe County Sheriff's Office (letter of recommendation for Taitel by
Sheriff Hayley Marshal Mentzel, Department of Alternative Sentencing (where RJC Bailiff's have violated courthouse sanctuary doctrine and rules, in much the same manner RMC Marshal Joel
Harley did on 2/27/12 in attempting to effect personal service upon me of the Order to Show Cause by Judge Flanagan in CV11-03628, the appeal of the summary eviction/"Trial" from my former
home law office, where opposing counsel Richard G. Hill, Esq. hired the Washoe County Sheriff's Office to personally serve me the 2/8/12 Order to Show Cause in 03628 (which I had already been
served by the Eflex system given I was an electronic filer attached to the case, a party, and likely the "attorney of record" therein, which, under Caplow would make Hill's attempt to have me
served at the 2/27/12 11 TR 26800 traffic citation trial stemming from RPD Sargent Tarter retaliating against me by issuing me 3 traffic citations outside of Richard G. Hill's office on 2/15/12, upon
my informing him that RPD Officer Chris Carter, Jr had said to me, upon making a custodial arrest for criminal trespass incident to a complaint signed by Richard G. Hill, Esq., and upon my asking
him if he was "on Richard G. HIll's payroll", Officer Carter said: "yes, Richard G. HIll pays me a lot of money so I arrest who he says to arrest and I do what he ways to do". That seeming
admission seems to be supported by the conduct of the RPD and admissions in the following:
http://www.youtube.com/watch?v=V6I3t7tTlPI
http://www.youtube.com/watch?v=Eh2xyc-9cg0
http://www.youtube.com/watch?v=VcVDVjFK64g Coughlin obtaining admissions from RPD Sargent Monica Lopez regarding the wrongful arrest by she and RPD Officer Chris Carter, Jr. of
Coughlin in RMC 11 CR 26405 on 11/13/12...detailed in Coughlin's 11/2/12 Notice of Errata submitted for filing with the RMC on 11/2/12, though only marked "received", and though mentioned in
Judge William Gardner's 11/13/12 Order denying Coughlin a New Trial, that document was not included by the RMC's Lisa Wagner or RMC Court Administrator Cassandra Jackson (whom writes
emails to the SBN about Coughlin detailing what Coughlin's clothes were like during a visit to the filing office counter (ie, not the "Office of the ClerK") to the State Bar of Nevada, unprompted)
http://www.youtube.com/watch?v=6TAFO6Z0OVo
Also, the RPD arrested Couglin, a custodial arrest, for jaywalking on 1/12/12 in RMC 12 CR 00696 incident to the lies by Richard G. Hill, Esq. to officers (wherein Hill alleges Coughlin had already lost
his appeal of the eviction in CV11-03628, despite a decision not being issued in that appeal until 3/30/12, and further where Hill's Witness Statement and allegations in his TPO, granted by RJC
Judge Schroeder in RCP2012-000018, simply are not supported by the videos of the events:
http://www.youtube.com/watch?v=7vlEI1fJJWc&list=UUJRiA0LTsRYM4Ol9tWU62mg&index=1
HIll sat on the Central District Citizens' Advisory Board of the City of Reno:
http://www.richardhillaw.com/About_Richard_Hill.htm
I would have been able to point out the conflict of having Lew Taitel, Esq. appointed as my attorney, but RMC Judge William Gardner refused to divulge the names of the possible 5 court
appointed defenders here:
http://www.youtube.com/watch?v=9_aApRniyk8
http://www.nevcs.com/attorney.html web page for unauthorized practitioners of law in RJC rev2012-001048 (wherein Judge Schroeder signed a summary eviction Order against me despite
the fraudulent Declaration of Service by NCS's Ryan Wray and the defective 6/14/12 5 day Notice Listing Sparks Justice Court as the forum to file a Tenant's Affidavit, and my so filing such a
Tenant's Affidavit on 6/26/12 with the Sparks Justice Court (which the SJC faxed on 6/28/12 at noon, to the Reno Justice Court, and where the RJC and WCSO and Sparks Justice Court were made
aware in advance of the deficiencies in the 5 day Notice (required by law under NRS 40.253, see AB 226):
http://www.leg.state.nv.us/Session/76th2011/reports/history.cfm?ID=507
https://skydrive.live.com/redir?resid=43084638F32F5F28!5814 7/25/12 filing in 60302 in Nevada Supreme Court detailing NCS's Ryan Wray's malfeasance.
"Subject: Reno eviction noticed for Sparks Justice Court
Sent: Tue 6/26/12 7:58 AM
To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us;
chansen@washoecounty.us; milllerr@reno.gov
Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful detainer?) for rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the notice
indicates that I must file a Tenant's Answer with the Sparks Justice Court.
Am I mistaken in viewing this matter to be outside the jurisdiction of the Sparks Justice Court, and rather, a matter to be handled in Reno Justice Court?
Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court has 4 judicial days a week, the deadline for filing a special appearance (to contest jurisdiction)
and or a Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he indicated theWCSO planned to come effectuate an eviction on this date, June 26, 2012.
I believe that would be premature, as Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit by noon after the fifth full day (judicial days) and Fridays in Sparks Justice
Court are not full days in that sense, and regardless, Sparks Justice Court, I believe, is not the appropriate forum where, as here, the situs is located in Reno (Ward 1-nap?)
Judge Nash Holmes detail what the Reno Marshals alleged regarding Coughlin's actions of 2/27/12, here, in the audio transcript from the continuation of the traffic citation trial for the citations
made outside Richard G. Hill's law office on 11/15/12 (where Coughlin had gone to get his client's files, wallet, state issued driver's license, and keys, which Hill refuse, though RPD Sargent Tarter
"giving Coughlin a break" for not citing him for not having his current driver's license, is mentioned in Judge Nash Holmes 3/12/12 Order...though Judge Holmes ruled irrelevant any inquiry into
why Coughlin did not have his current driver's license with him during that traffic stop).
http://www.youtube.com/watch?v=1uQQdukb3D4
Marshal Harley failed to appear at Coughlin's 11/14/12 formal disciplinary hearing before the State Bar of Nevada despite his being served a subpoena by a non-party and the SCR 105(4)
requirements and other rules and procedures applicable to such subpoenas and . It is time for Marshal Harley and the Reno Marshals to release the reports, recordings, and documentation in its
possession or control respecting Coughlin and to set the record straight, and for Marshal Scott Coppa and WCSO Deputy Cheung to speak to the micro sd card, and their conversations in the back
room of the jail's "sally bay" after Marshall Coppa pulled Deputy Cheung aside and whispered into his ear. Further, the Reno Marshal and Marshal Deighton ought indicate why they retrieved
Coughlin's property on 2/28/12 (after it had been booked into Coughlin's personal property at the jail) and why Coughlin's smart phone and micro sd data card were returned to him with the data
wiped on 4/7/12, and why WCSO Deputy Hodge, Trudy Darlington, Debi Cummings, Brandi Berriman, and Patricia Beckman, and others made the contradictory statements they did about the
chain of custody of Coughlin's property.
Finally, DDA Mary Kandaras and those above need to reveal upon what authority or Order, or warrant, the WCDA and or WCSO released Coughlin's personal property to the RMC Marshals, the
RMC, and Judge Nash Holmes.
Additionaly, the RMC and Judge Nash Holmes, Marilyn Tognoni, and Terri Vaus-Wong and any other assistant to Judge Nash Holmes and the Reno City Attorney and Washoe County Public
Defender's Office and WCDA need to reveal the communciation admitted to between Judge Nash Holmes, the RMC, and the Washoe County Public Defender's Office in Judge Nash Holmes' 3/14/12
written grievance against Coughlin, NG12-0434 to the State Bar of Nevada.
Jim Leslie, Biray Dogan, and the Washoe County Public Defener's Office and RMC court appointed Defenders Keith Loomis, Esq. and Henry Sotelo, Esq. need to divulge their rationale for failing to
procure and provide to Coughlin and utilize in his defense the audio transcripts of the hearings in:
7/31/12 RJC rev2012-001048 Northwinds Apartments v. Coughlin (testimony by Northwinds Manager Duane Jakob, while being represented in court before RJC Judge Pearson (whom allowed it) by
an unlicense unauthorized practictioner of law, Nevada Court Servces CEO Jeff Chandler, whom wrote Lew Taitel, Esq. a letter of recommendation in his attempt to become a Reno Justice Court
Justice of the Peace, and whom Judge Pearson himself filed a Judicial Discipline Commission Complaint against (at that 7/31/12 hearing, Judge Pearson went against NRCP 11's dictate, made
applicable via NRS 40.400, against corporations, such as Northwinds Apartments Associate, Inc. of Bellevue, Washington, appearing pro se without an attorney, which is not allowed under NRS
Chapter 40 or 118A, regardless of what Judge Pearson may have ruled, similar to what Judge Sferrazza ruled in allowing Gayle Kern's client, Park Terrace Townhomes HOA to appear without a
licensed attorney on 2/12/12 in RJC rev2012-074408 , leading to the 6/28/12 arrest and summary eviction lockout of Coughlin in rcr2012-067980.
As a courtesy, here is a link to the materials you were previously provided in the attached emails to you from me:
https://skydrive.live.com/redir?resid=43084638F32F5F28!5822
In her testimony on 11/14/12, Judge Nash Holmes said a lot of hearsay...perhaps Marshal Menzel, a former RJC Bailiff who is known to walk away from his post at the RMC and following Coughlin
around the entire building at 1 South Sierra St., has some input as to whom is telling Judge Nash Holmes what and the unfortunate fallout related thereto? Coughlin filed for a Protection Order
against both RJC Bailiff John Reyes (which was transferred to the Sparks Justice Court and summarily denied without any interview of Coughlin, despite Reyes admitting that he said to Coughlin "I
am going to put my foot in your ass" with Coughlin's public defender Joe Goodnight and Jim Leslie, Esq. sitting next to Coughlin). The RJC recently granted Leslie and the Washoe County Public
Defender and Patrick O. King, Esq. and the State Bar of Nevada TPO's against Coughlin where Leslie and King both lied in their applications in alleging Coughlin linked to a "video" of some violent
scene where the link in question is clearly only an audio sound bite from a movie at www.Hark.com.
The exact transcript of that quotation from an Academy Award nominated motion picture is:
"I ain't no white trash piece of s***. I'm better than you all. I can out learn you. I can out read you. I can outthink you, and I can out philosophize you. And I'm going to outlast you. You think a couple
of whacks to my good old boy gut's gonna get me down? It's going to take a hell of a lot more than that, Counselor, to prove you're better than me!!"
There is no video clip at the link, despite the lies by WCPD Jim Leslie and State Bar of Nevada Bar Counsel Patrick O. King. But, if one were to try to keep track of all the lies WCPD Jim Leslie,
Esq. and State Bar of Nevada Bar Counsel Patrick O. King or Clerk of Court Laura Peter tell, well, one simply would not have time for anything else. Further, the quotation mentions learning,
reading, and philosophizing, hardly threatening subject matters supportive of the TPOs granted by RJC Judge Pearson against Coughlin, in favor of WCPD Jim Leslie and SBN Bar Counsel Patrick
King in RCP2012-000599 and RCP2012-000607. RJC Judge Shroeder actually denied a TPO application Coughlin filed against Leslie, but for some reason that application was not given its own
distinct case number, but rather lumped in with the one Judge Pearson granted WCPD Jim Leslie (who admits he failed to turn over to Coughlin the discovery of 911 calls in RJC rcr2012-065630 (a
case originally "randomly" assigned to Judge Lynch, but for which Judge Clifton, a former WCDA prosecutor for 25 years working in the domestic violence unit with the same former WCDA and now
Second Judicial Family Court Judge Linda Gardner (Coughlin sued her in 54844 after her April 2009 Order was cited by Paul Elcano of Washoe Legal Services as the basis for firing Coughlin as a
domestic violence attorney from legal aid, though Judge Linda Gardner's brother, RMC Judge William Gardner refused to recuse himself from the criminal trespass prosecution of Coughlin in RMC 11
CR 26405, which involved RMC court appointed defender Lew Taitel being assigned the case (at the 11/14/12 arraignment Judge William Gardner refused to identify the potential appointed defense
attorneys to Coughlin...and that's too bad, given that RMC court appointed defense counsel Lew Taitel, Esq. was ultimately appointed by the RMC to defend Coughlin in November 2011 in criminal
trespass complaint where opposing counsel Richard G. Hill, Esq. signed the criminal complaint incident to the custodial arrest of Coughlin on 11/13/11 at Coughlin's former home law office at 121
River Rock St. Reno, NV 89512 (nice and close to the Courthouse and law library, which is used by only two local attorneys...Zach Coughlin (well temporarily suspended attorney Zach Coughlin,
Esq.), and Richard Cornell, Esq.. That's it. Those are the only two you will ever see there, honest. You'll see Keith Loomis, Esq. down at the Supreme Court's library in Carson City on occasion.
Speaking of, Loomis was served a Subpoena for the 11/14/12 formal disciplinary hearing in NG12-0204, 0434, and 0435, but, he, like RMC Marshal Joel Harley, played hooky that day.
Judge Sferrazza allows the unauthorized practice of eviction law by a property manager similar to what Judge Pearson allowed Nevada Court Services to do in RJC Rev2012-001048.
Judge Linda Gardner previously worked for Gayle Kern, Esq. Judge Linda Gardner's April 2009 Order sanctioning a domestic violence legal aid attorney resulted in his firing, and the following
lawsuits:
Her brother, Reno Municipal Court Judge William Gardner, refused to recuse himself from the criminal trespass prosecution of Coughlin incident to the custodial arrest at his former home law office in
RMC 11 CR 26405, which, incidentally involved Lew Taitel, Esq. being appointed as Coughlin's defense counsel despite Coughlin then suing Taitel's business partners incident to that very eviction,
Nevada Court Services and Jeff Chandler. Somehow, RMC Judicial Assistnat Lisa Gardner did not manage to file stamp the Notice of Appeal Coughlin served on the City Attorney Hazlett-Stevens
and submitted for filing with the RMC on 6/28/12 shortly before Nevada Court Services, the Washoe County Sheriff's Office Deputy Machen, and the Reno Police Department arrested Coughlin again
in rcr2012-067980 (incident to the wrongful eviction in rjc rev2012-001048) on 6/28/12, and then again in the 7/2/12 arrest by the RPD Officer Alan Weaver and Sargent Dye in RMC 12 CR 12420
(where, on 7/5/12 court appointed RMC defender Keith Loomis, Esq. conspired against Coughlin during the unnoticed bail increase hearing where, again, Judge Gardner, raised Coughlin's bail 10 times
the original amount, resulting in 20 days in jail for Coughlin, during which a $40K attorney fee award by Judge Flanagn was issued, incident to, you guessed it, that same summary eviction appeal
cv11-03628. Judge Hardy wrote Lew Taitel a letter of recommendation for the RJC job...but denied several of Coughlin's Motions for in forma pauperis status in 2012, including some related to the
eviction from Coughlin's former home law office and lawsuits related thereto.
So, then there is the mother load of conflicts and intrigue...Lew Taitel, Esq.'s application and collection of reference letters in his bid to become a Reno Justice Court Justice of the Peace, including:
a letter by City of Reno prosecutor Pamela Robert, Esq., whose prosecutorial misconduct in RMC 11 CR 22176 and the appeal in CR11-2064 is now memorialized in 60838, the audio of the 11/30/11
Trial before RMC Judge Kenneth Howard and the Wal-Mart interrogation room video that City Attorney Roberts possessed that proves she put on perjured testimony by Reno Sparks Indian Colony
Officer Kameron Crawford, incident to the Trial where Judge Gardner denied Coughlin court appointed counsel in violation of the Sixth Amendment, denied Coughlin a continuance based upon Judge
Howard's mistaken belief that Coughlin had caused the continuance of the 11/14/11 Trial date (in the last 3 minutes of the transcript Judge Howard admits his error, but believes he ameliorates it by
removing a few hours of the community service requirement he order Coughlin to perform, then Judge Howard attempts to mislead Coughlin as to the appeability of his NRS 22.030 civil summary
contempt 3 day immediate incarceration of Coughlin.
http://www.youtube.com/watch?v=FKmLtzgfFxk
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
Taitel's other letters of reference include ones from RJC Judge Clifton (formerly a WCDA prosecutor for 25 years working largely in the domestic violence arena, including at one point with Judge
Linda Gardner:
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746 54844 Mandamus Petition filed by Coughlin against Judge Linda Gardner's April 2009 Order sanctioning Coughlin and
resulting wrongful termination lawsuits:
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=28481 In 60317, the appeal from the trial court matter before D10 Judge Steven P. Elliott, whom went to Stanford University in
the late 1960s with Washoe Legal Services Director Paul Elcano, and the Panel Chair for Coughlin's formal disciplinary hearing on 11/14/12, John Echeverria. Judge Elliott also worked for Chair
Echeverria's father's law firm, Echeverria and Osborne. http://www.washoecourts.com/index.cfm?page=elliott&judge_id=d10
Judge Elliott graduated from Stanford University in 1971. He worked for the law firm of Echeverria and Osborne in Reno and served as an Assistant City Attorney for the City of Sparks. He
completed the Course for Prosecutors sponsored by the National Association of District Attorneys at Northwestern University. He was a founder of the Washoe County Domestic Violence Task Force.
Judge Elliott has been active in community organizations. He has served as a director of the Committee to Aid Abused Women Advisory Board. He is a past president of the Reno Area Stanford Club.
WDCR Rule 2. Organization of the court; chief judge; court administrator. 1. All civil and criminal cases shall be randomly assigned.
Somehow, Judge Elliot managed to be "randomly" assigned four straight criminal appeals wherein Coughlin is a party following his being "randomly" assigned Coughlin's wrongful termination lawsuit
against Paul Elcano, Washoe Legal Services, and the Committee to Aid Abused Women (CAAW). This included the appeal of the Wal-Mart petty larceny conviction at issue in the SCR 111(6)
Petition resulting in Coughlin's current temporary suspension, in 60838, from which the 6/7/12 Order referring the matter to the disciplinary panel for a formal
The announcement that Judge Elliott was retiring came shortly after Coughlin's 11/19/12 filing in 61901.
http://www.nevadajudiciary.us/index.php/supnews/1756-applications-being-accepted-to-succeed-retiring-washoe-district-judge-steven-elliott
Applications being accepted to succeed Retiring
Washoe District Judge Steven Elliott
Wednesday, 19 December 2012 10:25
Judge leaving bench March 12, 2013 after 16 years
CV11-01955 ZACHARY COUGHLIN VS. WASHOE LEGAL SRVC, ET AL(D10) Plaintiff 30-JUN-2011
CR11-2064 ZACH COUGHLIN VS. CITY OF RENO (D10) Appellant 23-DEC-2011
http://www.ccwashoe.com/public/ck_public_qry_doct.cp_dktrpt_frames?backto=P&case_id=CR11-2064&begin_date=&end_date=
CR12-0376 STATE VS ZACHARY BARKER COUGHLIN (D10) Defendant 28-FEB-2012
CR12-1262 ZACHARY COUGHLIN VS. CITY OF RENO (D10) Appellant 25-JUL-2012
R12-2025 ZACHARY COUGHLIN VS STATE (D10) Appellant 06-DEC-2012
In RJC RCR2012-065630, Coughlin filed a Declaration in Lieu of an Affidavit seeking to disqualify Judge Clifton from hearing the "misuse of emergency services" prosecution of Couglin (which was
amended on 7/27/12 to a "obstructing a public officer charge" at the same rushed hearing in which WCPD Biray Dogan, Esq. was "relieved" of all the "work" he had been doing on Coughlin's
defense...and DDA Young was granted an Order barring Coughlin from faxing him or the RJC incident to a Motion for such relief DDA Young had only mailed to Dogan the day before...and despite
claiming to be in a big, big hurry, DDA Clifton, er, Judge Clifton managed to contradict his earlier statement on the record that it was not permissible to file the Amended Complaint in in open court
and arraign Coughlin at that time, when he allowed DDA Young to do just that. Which was convenient given the Trial Setting of December 11th, 2012 insured that Coughlin was prevented from
filing pre-trial motion prior to Dogan being removed as attorney of record, and upon Dogan being removed 14 days prior to Trial, it was too late for Coughlin to file pre-trial motions himself given
the statutory dictate that such motions be filed 15 days prior to trial. And while Judge Clifton insisted Coughlin not refer to any matters outside of that specific case (RCR2012-065630) he allowed
DDA Young to base the lion share of his factual support for his contention that Coughlin was overburdening his fax machine on faxes allegedly sent to him in a different case entirely, RCR2011-
063341. Judge Clifton refused follow Nevada law under NRS 53.045, where Judge Clifton refused to comply with the dicates of NRS 1.235 upon
NRS 1.230 Grounds for disqualifying judges other than Supreme Court justices.
1. A judge shall not act as such in an action or proceeding when the judge entertains actual bias or prejudice for or against one of the parties to the action.
NRS 1.235 Procedure for disqualifying judges other than Supreme Court justices.
1. Any party to an action or proceeding pending in any court other than the Supreme Court, who seeks to disqualify a judge for actual or implied bias or prejudice must file an
affidavit specifying the facts upon which the disqualification is sought. The affidavit of a party represented by an attorney must be accompanied by a certificate of the attorney of
record that the affidavit is filed in good faith and not interposed for delay. Except as provided in subsections 2 and 3, the affidavit must be filed:
(a) Not less than 20 days before the date set for trial or hearing of the case; or
(b) Not less than 3 days before the date set for the hearing of any pretrial matter.
2. Except as otherwise provided in this subsection and subsection 3, if a case is not assigned to a judge before the time required under subsection 1 for filing the affidavit, the
affidavit must be filed:
(a) Within 10 days after the party or the party's attorney is notified that the case has been assigned to a judge;
(b) Before the hearing of any pretrial matter; or
(c) Before the jury is empaneled, evidence taken or any ruling made in the trial or hearing,
whichever occurs first. If the facts upon which disqualification of the judge is sought are not known to the party before the party is notified of the assignment of the judge or before
any pretrial hearing is held, the affidavit may be filed not later than the commencement of the trial or hearing of the case.
3. If a case is reassigned to a new judge and the time for filing the affidavit under subsection 1 and paragraph (a) of subsection 2 has expired, the parties have 10 days after notice
of the new assignment within which to file the affidavit, and the trial or hearing of the case must be rescheduled for a date after the expiration of the 10-day period unless the
parties stipulate to an earlier date.
4. At the time the affidavit is filed, a copy must be served upon the judge sought to be disqualified. Service must be made by delivering the copy to the judge
personally or by leaving it at the judge's chambers with some person of suitable age and discretion employed therein.
5. The judge against whom an affidavit alleging bias or prejudice is filed shall proceed no further with the matter and shall:
(a) Immediately transfer the case to another department of the court, if there is more than one department of the court in the district, or request the judge of another district court
to preside at the trial or hearing of the matter; or
(b) File a written answer with the clerk of the court within 2 days after the affidavit is filed, admitting or denying any or all of the allegations contained in the affidavit and setting
forth any additional facts which bear on the question of the judge's disqualification. The question of the judge's disqualification must thereupon be heard and determined by another
judge agreed upon by the parties or, if they are unable to agree, by a judge appointed:
(1) By the presiding judge of the judicial district in judicial districts having more than one judge, or if the presiding judge of the judicial district is sought to be disqualified, by the
judge having the greatest number of years of service.
(2) By the Supreme Court in judicial districts having only one judge.
RMC Judge Howard held Coughlin in summary contempt in retaliation for Coughlin's moving for Judge Howard to recuse himself based upon evident impartiality and other rationale
during the 11/30/11 petty larceny trial in 11 CR 22176, wherein Coughlin was denied his Sixth Amendment Right To Counsel, denied a continuance, and deprived of his constitutional
right to decide whether or not to testify on his own behalf, and deprived the ability to rebut prejudicial hearsay allowed into evidence by Judge Howard, amongst numerous other due
process deprivations.
Coughlin filed his Motion to disqualify Judge Clifton prior to the start of Trial on December 11th, 2012. Coughlin attempted to have a copy served upon Judge Clifton (out of
respect for Judge Clifton and various doctrines related to judicial immunity from service while on the bench, Coughlin sought to leave the copy at the Judge's chambers, but was not
granted access thereto, so instead Couglin consulted with RJC Chief Bailiff Sexton and the counter clerks at the second floor of the Reno Justice Court and they accepted Coughlin's
Motion to Disqualify Judge Clifton and indicated they would provide it to him soon thereafter, and, in fact, upon the Trial starting over an hour or so later, Judge Clifton not only had
the filign office's copy but the copy Coughlin left with the RJC staff upon Coughlin being denied access to the Judges Chambers. Judge Clifton cited Coughlin's failure to have his
Motion to Disqualify notarize (ie, in an Affidavit form versuse a Declaration made under penalty of perjury in lieu of an Affidavit, as allowable under NRS 53.045, a practice by
Coughlin which the Nevada Supreme has expressly approved in Buckwalter v. Dist. Ct., 126 Nev. ___, ___, 234 P.3d 920, 921 (2010).
"This original writ proceeding asks us to decide whether a medical expert's declaration under penalty of perjury as provided in NRS 53.045 can satisfy the affidavit requirement stated in NRS 41A.071. We agree with the district
court that it can and therefore deny writ relief....The latter provides that [a]ny matter whose existence or truth may be established by an affidavit may be established with the same effect by an unsworn declaration of its
existence or truth signed by the declarant under penalty of perjury, and dated, in substantially the following form: I declare under penalty of perjury that the foregoing is true and correct. NRS 53.045. An affidavit is
a written statement sworn to by the declarant before an officer authorized to administer oaths. Black's Law Dictionary 66 (9th ed.2009). A declaration under NRS 53.045 is not sworn, but instead is dated and signed
under penalty of perjury. Petitioners contend that because NRS 41A.071 expressly requires an affidavit, the complaint must be dismissed. We disagree. Statutes must be construed together so as to avoid rendering any portion
of a statute immaterial or superfluous. Albios v. Horizon Communities, Inc., 122 Nev. 409, 418, 132 P.3d 1022, 1028 (2006). NRS 41A.071 imposes an affidavit requirement, which NRS 53.045 permits a litigant to meet either
by sworn affidavit or unsworn declaration made under penalty of perjury. See State, Dep't Mtr. Veh. v. Bremer, 113 Nev. 805, 813, 942 P.2d 145, 150 (1997) (concluding that a declaration under NRS 53.045 met the affidavit
requirement of the breathalyzer statute, even though the statute's language required an affidavit). To hold otherwise would make NRS 53.045 meaningless because it would require every statute imposing an affidavit
requirement to state when a declaration may be used instead of an affidavit. Interpreting the two statutes so as to give meaning to both, we conclude that a declaration that complies with NRS 53.045 can fulfill NRS 41A.071's
affidavit requirement." Buckwalter v. Dist. Ct., 126 Nev. ___, ___, 234 P.3d 920, 921 (2010).
NRS 53.045 Use of unsworn declaration in lieu of affidavit or other sworn declaration; exception. Any matter whose existence or truth may be established by an affidavit or other sworn declaration may be established with the
same effect by an unsworn declaration of its existence or truth signed by the declarant under penalty of perjury, and dated, in substantially the following form:

1.If executed in this State: I declare under penalty of perjury that the foregoing is true and correct.

(interesting, because the Reno City Attorney is freely given continuances, like the one it received in the criminal trespass prosecution of Coughlin where Richard G. Hill, Esq. needed to go on vacation
for six weeks, in the case where RMC defenders Taitel, then Puentes, then Loomis all refused to subpoena percipient witnesses RPD Officer Carter (how was Coughlin's Sixth Amendment Right to
Confrontation fulfilled where neither RPD Officers showed up?), nor Sargent Marcia Lopez, nor landlord Dr. Matthew J. Merliss, MD. Opposing counsel Hill and Baker billed their neurologist client
$60,000 incident to their counseling him to undertake a summary eviction against a commercial tenant based only upon a No Cause Eviction Notice, which is expressly forbidden under NRS 40.253
(ie, it was, to borrow a medical analogy, a "wrong site surgery"...so how could RMC Judge Gardner find "irrelevant" the witness bias incident to Hill or Baker's testimony elicted by Coughlin
questioning them on the financial arrangement with their client or their own desire to avoid malpractice liability?
Regardless, both the attorneys fee awards against Coughlin by Judge Flanagan in the appeal of the RJC eviction in rev2011-001708 and the criminal trespass conviction against Coughlin incident
thereto in RMC 11 CR 26405 are based upon an Eviction Order and Decision of 10/25/11 and Summary Eviction Order of 10/27/11, both by Judge Sferrazza that are void, stale, or otherwise
inoperative on a number of grounds, such as:
1. Those Orders were made at a time in which the RJC and Judge Sferrazza had been divested of jurisdiction to make any such Orders given Coughlin's filing of a Notice of Appeal on October 19th,
2011 in RJC Rev2011-001708 and, in the District Court:
CV11-03051 ZACH COUGHLIN VS. MATT MERLISS ET AL (D1) Petitioner 19-OCT-2011
http://www.ccwashoe.com/public/ck_public_qry_doct.cp_dktrpt_frames?backto=P&case_id=CV11-03051&begin_date=&end_date=
CV11-03126 ZACH COUGHLIN VS. MATT MERLISS, M.D. et al. Plaintiff 26-OCT-2011
CV11-03628 ZACHARY COUGHLIN VS. MATTHEW MERLISS (D7) Plaintiff 21-DEC-2011
As a general rule, the timely filing of a notice of appeal divests the district court of the jurisdiction to act and vests jurisdiction in the Supreme Court (Mack-Manley v. Manley, 122 Nev. 849) as
to those issues pending on appeal. However, the district court retains jurisdiction over matters that are collateral to and independent from the appealed matters. The court may still entertain
motions and deny them or if inclined to grant may certify such an intent (Foster v. Dingwall citing to Huneycutt v. Huneycutt, 94 Nev. 79). Enforcement actions are not divested.
Rule2. Organization of the court; chief judge; court administrator.
1.All civil and criminal cases shall be randomly assigned.
2.The district judges shall elect from among the general jurisdiction division and family court division judges a chief judge for a term of 2 years. The chief judge is the presiding judge as referred to in NRS 3.025 and the chief
judge referred to in Supreme Court Rule 8.
3.Election of the chief judge shall be by secret ballot at the regular December meeting of judges. Nomination shall likewise be made and closed at the November meeting. The term of the chief judge shall commence the first
Monday of January in even years. Election shall be by majority vote. The chief judge may be removed by motion made at any regular meeting and a two-thirds vote of the judges at the next regular meeting.
4.The chief judge may be, or may appoint, the presiding judge of the division of his or her jurisdiction and shall appoint a presiding judge of the remaining division. The presiding judge or judges shall serve at the pleasure of the
chief judge and shall perform such duties as are delegated by the chief judge.
5.The chief judge shall supervise the court administrator and presiding judge(s). The chief judge shall appoint committees of the court. The chief judge shall preside over all judges meetings and shall speak for the court on matters
therein approved by the judges. The chief judge shall represent the court in its relations with other agencies of the government, the bar, the general public and the news media.
6.The chief judge shall supervise caseflow management, assign overflow trials and other overflow matters from the other judges and shall assist the other judges who request assistance in disposition of their caseload within the
court by obtaining senior judges or other sitting judges in other districts within the state. The chief judge shall be the arbitrator in resolving conflicts between judges on calendaring and case assignment and procedural policy disputes. The caseload of
the chief judge shall be reduced by 20 percent. The chief judge shall be responsible for compilation and distribution of statistics of the court.
7.The chief judge may assign one or more district judges to act temporarily as a judge or judges of the family court, if the caseload of the family court so requires or if for any reason a judge of the family court is unable to act.
8.The district court administrator shall be selected by the court and is responsible for the administration of the rules, policies and directives of the district court. In addition to the duties prescribed below, the district court
administrator shall be denominated the clerk of the court and shall perform all the statutory and other duties assigned to that office. Subject to the direction of the chief judge acting on behalf of the district judges, the district court administrator shall:
(a)Supervise the assistant court administrator, family division administrator, jury commissioner and other officers and employees of or serving the district court, except for the staff of each judge;
(b)Supervise the office of the court clerk and the processing of all pleadings and papers related to court business and the court clerks;
(c)Direct the implementation and operation of a court interpreter program;
(d)Plan, organize and direct the budgetary, and fiscal operations of the district court;
(e)Plan for, organize, hire, train, and supervise all personnel deemed necessary by the district court to adequately conduct the operations of the district court, except for the staff of each judge;
(f)Monitor a system of internal controls which includes payroll, purchasing, accounts payable, accounts receivable, information systems and inventory along with all other fiscal aspects of the district court, including adjudication,
administration, family mediation services, and jury services;
(g)Expedite movement of the court calendars and coordinate and monitor automated case management systems including, but not limited to, the development of integrated data entry systems;
(h)Supervise preparation and submission of reports and activities of the court to state, regional and local authorities as required;
(i)Determine statistics to be gathered for the statewide uniform system of judicial records and manage the flow of information through and about the court;
(j)Direct research, evaluation and monitoring and propose new and revised policies as necessary to improve court operations;
(k)Coordinate the calendars and activities of judges visiting from other jurisdictions and of hearing officers or masters assigned for specific purposes;
(l)Represent the court on regional, statewide, judicial and justice system coordinating councils, conferences, conventions and committees as assigned by the chief judge;
(m)Handle public information and liaison with other government executive, legislative and judicial agencies in the community as assigned by the chief judge;
(n)Perform such other functions and duties as may be assigned by the chief judge.
[As amended; effective February 6, 2002.]
Sincerely,
Zach Coughlin PO BOX 3961 Reno, NV 89505 tel 775 338 8118 fax 949 667 7403"
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Zach has 50 files to share with you on SkyDrive. To view them, click the links below.
2 27 12 Judge Schroeder status conference clifton order rcr2012-065630 26800 wcpd wcso dogan.pdf
2 28 12 fax from Dogan 065630 re bill davis competency order elliot 0204 rmc nash 4873 Clifton Elliot randomly.pdf
3 2 09 assembly minutes Judge Clifton on DV 065630 0204 01955 two per page shortened.pdf
4 22 07 RMC Marshal Menzel Letter for Taitel 26700 26405 0434 0435 0204 62337.pdf
5 15 07 RJC Judge Schroeder letter of rec for Judge Linda Gardner 54844 rev2012-000374 60302 rev2012-001048 62337.pdf
5 22 07 RMC defender Taitel's application to RJC 0204 26405 54844 26800 00696 62337 063341 1048 12420.pdf
6 26 12 0204 067980 12420 60302 NCS Taitlel RMC Machen Harley email to RJC Stancil and WCSO Stuchell Sheriff's Web and Sparks Justice Court Hansen.pdf
7 25 12 60302 0204 067980 12420 0435 stamped Coughlin's motion for extensio nto file brief and exhibit 60302 000374.pdf
10 17 11 Clifton Order Noticing 10 25 11 Trial Date 26405 1708 60331 61383 0204.pdf
10 19 11 baker letter to clifton emergency inspection with 10 20 11 sferrazza note order have p draft order will isgn it 1708 0204.pdf
10 20 98 STANDING COMMITTEE ON JUDICIAL ETHICS 0204 063341 54844 62337.pdf
11 8 11 Motion to Stay and Set Aside eviction order 1708 CV11-03051-2534024 0204 03628 62337.pdf
11 19 12 71 page Notice in 61383 0204 26800 26506 12-36656.pdf
11 27 12 065630 fax cover page post it clifton 11 28 12 don't file this in stays w case file however 1 of 69 pages.pdf
I am writing to request a fee waiver of the yearly $300 eflex charge
12 5 12 065630 refiled from 11 27 12 with new addition to ex 1OPPOSITION TO MOTION TO AMEND, OR ALTERNATIVELY, MOTION FOR RECONSIDERATION OF.pdf
12 6 12 not authorized by Clifton Custodian of Records WCPD 065630.pdf
12 8 11 Order Denyin Motion for Stay Judge Berry Appeal 1708 CV11-03051-2588517 0204 26405 10 19 12 Notice of Appeal 11 8 12 Stay.pdf
12 14 11 0204 26800 email from Chief Marshal Roper roperj@reno.gov regarding Menzel.pdf
0204 mh12-0032 Judge Breen Letter of Recommendation for Judge Linda Gardner 0204 54844 60302 cr12-0376.pdf
2007 resume for Linda Gardner 0204 0435 conflicts elcano echeverria clifton elliott.pdf
Chief Judge Hardy letter for Taitel cr12-2025 Hardy denied all of Coughlin's IFP Applications 26405 0204 62337.pdf
DAS Ingraham 063341 26405 letter Taitel Brown 0204 62337.pdf
DAS Officer Celeste Brown letter for RJC Taitel 063341 26405 0204 26800.pdf
federal court judges Hicks father of wcda chris hicks dismissing rjc judge clifton and rpd from suit while clifton a da 0204 065630 2025.pdf
former WCDA DDA Puentes letter Taitel RMC defenders Gardner HIll trespass 26405 0204 60302 61901 60331 62337 54844.pdf
Gardner, Linda 01.15.10 0204.pdf
Judge Adams letter for Judge Linda Gardner cv11-01986 54844 60302 0204 0435.pdf
Judge Adams letter for Taitel see cv11-01986 and rmc 11 cr 26405 0204 62337.pdf
Judge Hardy's former partner Woodman letter Taitel IFP denied 60302 60317 03126 03051 26405.pdf
Judge Nash Holmes RJC application listing Sarnowski as reference of Judicial Discipline Commission conflict 26800 0204 00696 60302.pdf
LT Judge Clifton (with encl) (10-19-11).pdf
ncs 0204 northern nevada's only eviction agency 26800.pdf
ncs main page with staff attorney link 0204 26405 26800.pdf
Nevada Court Services CEO Jeff Chandler letter for RJC RMC Taitel doesn't mention partnership 0204 26405 03051 03126 03628 62337.pdf
nevada lawyer article on judge linda gardner domestic violence unit wcda clifton 0204 065630 .pdf
NVBAR RJC JUDGE CLIFTON MCGEORGE 1983 065630.pdf
Orth v_ Balaam et al Justia Dockets & Filings clifton hicks rjc 0204.htm
rcr2-12-065630 RJC Judge Clifton 2 27 12 Order for Competency evaluation dogan young nash rmc rjc rpd wcso.pdf
relevant florida judicial discipline case concerning pro se formulaic dv clifton sferrazza howard 063341 0204 065630.pdf
Reno City Attorney Pamela Roberts for Taitel her misconduct in rmc 11 cr 22176 60838 taitel's in 26405 0204 62337 26800 00696 NCS.pdf
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Sent: Fri 12/21/12 5:03 PM
To: CourtTech@washoecourts.us (courttech@washoecourts.us); filing@washoecourts.us (filing@washoecourts.us); judge.hardy@washoecourts.us (judge.hardy@washoecourts.us);
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zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us); stuttle@washoecounty.us (stuttle@washoecounty.us);
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(ncjdinfo@judicial.state.nv.us); ( (renodirect@reno.gov); ( (kadlicj@reno.gov); nvscclerk@nvcourts.nv.gov (nvscclerk@nvcourts.nv.gov); tlindeman@nvcourts.nv.gov
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Dear Second Judicial District Court,

I am writing based on exigent circumstances to request a fee waiver of the yearly $300 Eflex charge as my account is currenly deactivated or disabled. I am not copying the
State Bar of Nevada or President Flaherty or the Panel Members (Chair John Echeverria, Clark Vellis, Karen Pearl, Stephen Kent, or Michael Johnson or Bar Counsel Clark of
King becuase I may have had a TPO served against me recently (I am not entirely sure, and, given the courthouse sanctuary doctrine, I am not sure it is appropriate for the same
RJC Bailiff who threatened to "put my foot up your ass" to WCPD Jim Leslie, Esq.'s delight, to be attempting serve me anything while I am checking in with the Department of
Alternative Sentencing, which Judge Sferrazza mandated I do, and which, I guess, incidentally, allows for the States to search my home, office, or personall effects (including
computers, hard drives, etc. and not sure how that "sentence" is not retaliatory given the standard sentence is $500 or five days in jail, and I had already served 7...but the
sentence sure would seem to help the WCDA's Office, Washoe County, the SBN, and others influence and leverage certain things from hereforth) just about any hour of the day
(despite the fact that the conviction on 11/20/12 violated Shep v. State in addition to pretty much every other constitutional rights criminal defendants have). I think it is
possible I will be murdered soon or incarcerated pretexutally and denied any ability to file legal documents, so I have to send this out in this manner, but I wish to avoid any ex
parte contact allegations. I wish my filings of 11/2/12 in 11 cr 26405 and thos I submitted for filing but have only been held by the Nevada Supreme Clerk's Office as
"received" but not filed in 61901 will someday see the light of day, including the videos submitted. I am afraid I might be violating some TPO if I copy Bar
Counsel/NNDB/Panel, etc. on this...but would not mind if it was forwarded to them if not violative of any TPO, rules, or laws. Additionally, I think it is inappropriate for
60317 to be dismissed, especially given the improperly noticed testimony of WLS's Paul Elcano, Judge L. Gardner's bailiff's attendance at the 11/14/12
Hearing, RMC "official transcriptionist" Pam Longoni's connection to the 11/14/12 formal disciplinary hearing, the multitude willfull violations of my SCR 105(2)(c)
rights (including Judge Beesley's participation and having the 3,000 pages in a box dropped off to my on 11/8/12 for an 11/14/12 Hearing, where the SBN alleges that complies
with the SCR 105(2)(c) dictate that I be afforded access to those materials "at least 30 days" prior to the 11/14/12 Hearing, particulary where that was co-signed by Panel Chair
Echeverria and both Echeverria and Bar Counsel and the Chair (at least according to King) have repeatedly attempted to thwart my attempts to filing anything in that case,
alternatively required me to call ahead with 15 minutes warning before appearing to file anything, then calling the police when I comply with that strange dictate, then,
apparently, applying for a protection order or giving me a trespass notice of some sort whenever I point out their fraudulent conduct, and how easily proven it is.

I need this Eflex access to defend myself in the formal disciplinary proceedings against me before the State Bar of Nevada, Nevada Supreme Court, and anything that may
issue in connection with my license to practice patent law before the United States Patent and Trademark Office. My eflex username is ZachCoughlin. It is disabled. I live in
a rented fifth wheel trailer that I rent for about $75 a month plus incidentals. I get food from food pantries. I have no money in my one bank account (a Bank of America
account) and its been that way for months. I own no real estate or stocks or have any assets beyond simple household furnishings. I am an independent jack of all
trades/research whose law license is suspened currently in Nevada and I have next to no income per month...to the point where I am embarrassed about it and it would probably
be an exaggeration to say I am making even $200 a month. My 65 year old mother occasionally helps me out financially with my rent or some gas money.

As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla. 1994) indicate, unsolicited contact with the adjudicatory or investigative entity
often involves the judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance of impropriety judges must strive to avoid.

I have not been provided (though I believe they are required to) by th RJC a copy of the Record on Appeal in CR12-2025. Certainly, DDA Young and the WCDA have been
provided access via elfex to the 800 page Record on Appeal therein, yet the RJC has failed to mail me my copy. And time is of the essence. I have already been prejudiced
in that regard and I believe NRS 189.030 has been violated in that the RJC has failed to order the transcripts prepared of all hearings in that matter yet. Please see CR12-1018
and the recent IFP and Request for Transcript I filed in CR12-2025. I need eflex access, further, for many of the cases necessary to defending myself in the SBN v. Coughlin
SCR 105 Complaint, and to defending myself against the numerous retaliatory prosecutions and matters related thereto.

I respectfully request that I be given immediate EFlex privileges and that the yearly dues thereto be waived.

Further, I believe it would be entirely in appropriate for Judge Elliot to remain on that case, given the irregularities of his "randomly" being assigned four of my criminal matters,
failure to disclose conflict or recuse himself in cv11-01955 and other matters detailed herein.

As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla. 1994) indicate, unsolicited contact with the adjudicatory or investigative entity
often involves the judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance of impropriety judges must strive to avoid.

I have recently been forced to make numerous trips to law libraries far away given the Washoe County Law Librarie's contention (disputed by me at the meeting of the Board
of Trustess of the WC Law Library when the new law librarian's cv was detailed yearlier this year, wherein Judges Weller, Walker, and Steinheimmer were present, along with
Clerk of Court Orduna Hastings, wherein those Judges all deferred to the Washoe County District Attorney's Office rather than address my contentions that the WCLL asserts to
the public in writing that the "westlaw contract" forbids certain things that the contract simply does not forbid, requiring patrons to expend great amounts of money to print
materials, resulting in collection of revenue by the Court and or Library. I have great respect for the WCLL, and would give them huge donations if I had the means, as its the
most important room in the County, in my opinion). I do have a license to practice before the United States Patent and Trademark Office but have never filed anything there
and have informally represented to USPTO OED Staff Attorney Tom McBride, Esq. that I will not be representing anyone there for the foreseeable future given the extremely
encumbering nature of my recent legal troubles and defending myself incident thereto. I would greatly appreciate this waiver of the $48 I owe pacer and swear under penalty of
perjury subject to NRS 53.045 that the information contained herein is true and correct.

I have previously and will again here complaint in writing that Judge Steven Elliott has "randomly" (in accord with our local rules) been assigned four of my criminal matters in
a row (the appeals of the RMC conviction in 11 cr 22176 for petty larceny of a "candy bar and some cough crops" which I vehemently dispute and which resulted in my current
six month temporary suspension of my law license in 60838 (which the State Bar of Nevada managed to get crammed into an unbifurcated hearing on 11/14/12 that also included
something like 10 copied and pasted alleged violations of the Rules of Professional Conduct (none mentioning any direlection of my duties to clients, other than Judge Nash
Holmes alleging I violating my own duty of competency to myself, etc. where I represented myself in a "simple traffic citation" trial on 2/27/12 (held in violation of NRS
178.405 and NRS 5.071 where Judge Nash Holmes knew of the competency issues, and where Judge Nash Holmes continues to violate NRS 189.030 in refusing to process my
Notice of Appeal of 3/7/12 and those materials submitted thereafter
37 A.L.R.4th 1004 (Originally published in 1985)
American Law Reports ALR4th The ALR databases are made current by the weekly addition of relevant new cases. Disqualification of judge in state proceedings to punish contempt against or involving himself in open court and in his actual
presence

57 A.L.R. 545 (Originally published in 1928)
American Law Reports ALR The ALR databases are made current by the weekly addition of relevant new cases. Necessity that hearing be allowed before imposition of punishment for contempt

The use of summary criminal contempt power is proper only for charges of misconduct, in open court, in the presence of the judge, which disturbs the federal court's business,
where all of the essential elements of the misconduct are under the eye of the court, are actually observed by the court, and where immediate punishment is essential to prevent
demoralization of the court's authority before the public. 18 U.S.C.A. 401; Fed.Rules Cr.Proc.Rule 42(b), 18 U.S.C.A. F.T.C. v. Trudeau, 606 F.3d 382 (7th Cir. 2010).

Judge Nash Holmes sentenced Coughlin to a summary 5 day incarceration for contempt on 2/27/12, signed in an Order stamped 2/28/12 in 11 TR 26800 that, combined with a second bite at the apple
Order of 3/12/12 in that case attempts to both convict coughlin of "the misdemeanor of criminal contempt" in a summary fashion, where there does not seem to be any notice in writing to Coughlin
onf the 3/12/12 continuation of the Trial and where Coughlin filed a Motion for Continuance of any future hearings and Notice of Appeal on 3/7/12 that divested Judge Nash Holmes and the RMC of
jurisdiction to even hold the 3/12/12 continuation of the Trial (and NRS 178.405, NRS 5.071 further prohibited such a proceeding...and its really not at all clear how Judge Nash Holmes feels it is
propert to file a grievance with the State Bar of Nevada against Coughlin on 3/14/12 on behalf of herself an all the other RMC Judges (even the Judges Pro Tem) (which Judge Dilworth vehemently
disputes) including Second Judicial Judge L. Gardner's brother, RMC Judge William Gardner (whom refused to recuse himself from the criminal trespass conviction Trial against Coughlin in 11 cr
26405, despite W. Gardner then himself having a grievance against Coughlin in ng12-0434, and despite his being involved in the filing of the grievance against Coughlin in ng12-0435, which consists
solely of his sister's April 2009 Order sanctioning Coughlin $1,000 (despite Springgate failing to follow NRCP 11's 21 day safe harbor provisions...so basically Springgate and Judge Linda Gardner
(whose 2008 campaign contributions list Springgate as a donor and Judge Peter Breen, as well, whom removed Coughlin from the Mental Health Court in MH12-0032 for Coughlin takign a
medication for ADHD/treatement resistent depression that Coughlin was specifically told was approved and not probibited prior to Coughlin entering into the Mental Health Court contract, and
reviewing the associated written materials provided by the MHC, Reno Biondo, est. whom subsequently fraudulently asserted Coughlin was removed from the MHC for not following program rules (the
alleged violation was that Coughlin was taking a medication that he had specifically been told was no prohibited and that his use of was acceptable. Judge Breen's law clerk at one time was Judge
Linda Gardner, who recused herself from a case wherein Coughlin represent Robert Bell in Bell v. Greer, a case filed on 8/10/11, proving Coughlin was a commercial tenant practicing law at the 121
River Rock St. location from which Coughlin was summarily evicted, in violation of NRS 40.253 (much less where Coughlin was required to deposit a $2,275 rent escrow deposit that violated Nevada
law, in that no corollary to JCRLV 44 had been published and approved by the N. S. Ct, in compliance with Nevada's JCRCP 83...) from his former law office, and subsequently subject to a custodial
arrest and prosecution for trespass, signed by opposing counsel Richard G. Hill (whom lied to the RPD about whether he had been at the office in the weeks prior, in an attempt to avoid the requirement
under the RPC that the lawyer, Hill, withdraw where the likelihood of his becoming a witness in the case was assured, where Hill told the RPD it was his client Merliss who "noticed" things in the
office in the week prior to the criminal trespass arrest, which was fraudulent anyways, as detailed in 61901 and 11 cr 22176, especially the 11/2/12 filing in that matter that the RMC did not included in
the record transmitted on 11/29/12 in cr12-1262 (another 'random" assignement to Judge Elliot...whom failed to disclose and recuse himself from Coughlin's wrongful termination suit against Washoe
Legal Services (who admitted ot fiing Coughlin based solely upon Judge L. Gardner's April 2009 Order sanctioning Coughlin (which was impermissibly summary in nature anyways and failed to follow
the 21 day safe harbor in NRCP 11 required under NRS 7.085) in cv11-01955 even where Coughlin was suing for wrongful termination as a former domestic violence attorney at WLS, and also suing
Committee to Aid Abused Women (CAAW) where Judge Elliott was on CAAW's Executive Board, and started the Nevada Domestic Violence Task Force, and where a 25 year Washoe County District
Attorney turned RJC Judge (David Clifton) who was a longtime domestic violence prosecutor (working with now Judge Linda Gardner in the domestic violence unit of the WCDA, to go along with
their both being from Reno High School's Class of 1975, and WLS's Director Elcano admitting that Judge Linda Gardner and Master Edmondson has given Coughlin "a thumb's up" review in February
2009...shortly before Coughlins' suspension and firing from WLS on 4/20/09...the day after Coughlin submitted a complaint in writing to WLS and Elcano regarding the hostile work environment
there...where Elcano and WLS fired Coughlin "solely" based upon Judge Gardner's April 2009 Order sanctioning Coughlin for his work in the 3/12/09 and 3/17/09 divorce trial in Joshi, DV08-
01168...never mind that Coughlin was encumbered preparing a Nevada Department of Taxation 20 page appeal brief for Elcano by a 3/10/09 deadline to get Elcano and WLS out of the jam where the
Lease Agreement for the property Elcano had just moved WLS to required WLS, a non-profit 503(c) to pay the private landlord's property taxes...and where WLS management failed to timely respond
to Coughlin's request for subpoena fees and other discovery related expenses and where Coughlin emails to his then WLS assistant proves he had culled ALR support for the positions taken, vis a vis
Siragusa, that Judge Gardner had him fired over....Judge L. Gardner's 2008 campaign expense reports lists CAAW as well, in addition to WLS's Todd Torvinen, Esq., whom specifically approved of the
positions Coughlin took in that Joshi divorce Trial upon Coughlin following Elcano's direction to seek mentoring and guidance from Torvinen, whom managed to get the lawsuit against him dismissed
in 60302 and 60317 based upon weasley "legibility" arguments regarding the service of process, which the WCSO messed up in 60302 where Coughlin was an IFP)

That under some circumstances, even where immediate summary contempt proceedings
would be appropriate, it might be necessary for the contemned trial judge to be disqualified
from sitting therein was recognized by the court in Krueger v State (1977, Fla App D3) 351
So 2d 47, in which it appeared that the appellate court's primary emphasis was on the lack of
objective evidence to support the trial judge's finding that a contempt had actually been committed
by a prosecuting attorney whose intent to appeal a prior ruling had been characterized
by the trial judge as not only frivolous but "absurd," and who replied to this characterization
merely by stating that the judge was entitled to his opinion

Judge Berry's Order in CR12-1018 seems to establish that the RMC had a duty to order the transcripts prepared in 11 cr 22176 ("randomly" assigned to Judge Elliot in
Department 10 in cr11-2064, where he dismissed my appeal based upon not citing to a transcript that I attempted to have prepared by the "RMC Official transcriptionist and the
only person the RMC will release your audio transcripts to and whom can prepare a transcript for you, Pam Longoni"...Ms. Longoni refused to prepare my transcript and hung up
on me twice in December 2011. Further RMC Judge Howard seems to have violated NRS.

So, the transcripts from the convictions in RMC 11 CR 22176 should have been ordered prepared by RMC Judge Kenneth Howard, and his failure to prejudiced Coughlin
in the appeal ("randomly" assigned to Judge Elliott in Cr11-2064, dismissed by him citing to a civil statue about down payments on transcripts), and in 11 TR 26800 (which the
RMC and Judge Nash Holmes continue to violate NRS 189.030 in failing to process Coughlin's notice of appeal of 3/7/12 etc. for. Additionally, Judge Elliott was
"randomly" assigned Coughlin's appeal of the criminal trespass conviction that RMC Judge W. Gardner failed to recuse himself from in 11 cr 26405, in cr12-1262, and
dismissed that case where, despite Coughlin showing proof of timely receipt of his Notice of Appeal in compliance with NRS 189.010 by both the City Attorney and the
RMC, properly submitted for filign by Coughlin, RMC assistant Lisa Wagner is mum about why that Notice of Appeal was not filed in by the RMC, as is Judge
W. Gardner...Further RMC Donna Ballard is certifying Orders from the Second Judicial District Court for SBN Bar Counsel Patrick King that she has no right to certify.
Further, King is fraudulently alleging to have certified copies of an admitting as exhibits in the 11/14/12 hearing against Coughlin in the SBN ng12-0204 of Judge Flanagan's
6/28/12 Order awarding against his former co-worker at Hale Lane, Coughlin (Flanagan refused to recuse himself despite obvious conflicts set out by Coughlin in cv11-
03628) a preposterous $42,050 in attorney's fees, against a pro se tenant, whom Flanagan apparently ruled a commercial tenant anyway whose rent was les sthan $1,000, though denied the NRS 118A.385 stay
afforded such litigants.

SBN King similarly fraudulently asserted the April 2009 Order by Judge L. Gardner in dvb08-01168 was certified where he had it admitted as an exhibit (ordered admitted by Panel Chair John Echeverria, who Judge Steven
Elliott worked for Echeverria's father's law firm, Echeverria and Osborne, and where Chair Echeverria, Judge Elliott, and WLS's Paul Elcano all went to Stanford University in the late 1960s together, something none of them
disclosed until Coughlin pointed it out...and Elcano, Echeverria, Norman Beesley and other Judges went to Reno High School together in 1962...along with other former co-workers of Coughlin from Hale Lane (Peek,
Dennisson, Judge Charles McGee, Judge Salcedo, whom Judge Sferrazza mentioned needing to meet with on the record in another retaliatory prosecution against Coughlin in RJC rcr2011-063341, which, again, Judge Elliott
was "randomly" assigned on 12/6/12, allegedly, in cr12-2025 (which Coughlin has not been provided a copy of the 800 page record on appeal, which seems to involved Judge Sferrazza, in conjunction with the fraudulent
conduct of public defendner Jim Leslie, "disenfecting" the record of Coughlin's 2/15/12 Pre-Trial Motions and Coughlin 8/29/12 Memorandum of Law, etc. (Leslie has no ability to "refuse to join in on" such, especially where
Leslie was not even attorney of record untilsometime in August 2011 and where Coughlin filed a Notice of Appearance to represent himself while he was still a license attorney and to subsitute out the WCPD's office or to
at least downgrade their involvement to co-counsel in February 2012.)

Additionally, Coughlin has not received any such "Amended Notice of Appeal" in cr12-1262, despite receiving an email indicating one was filed from Eflex...Coughlin's elfex is currently disabled for non-payment, and
Coughlin hereby request his eflex charges be waived in light of his indigency and the misconduct and irregularities mentioned above and previously by Coughlin.

Coughlin attempted to proved the testimony by RMC Judge Nash Holmes regarding the order of the bathroom break and Holme's other patently false and or incorrect statements in her testimony on 11/14/12 at the formal
disciplinary hearing...however Judge Elliott's former Stanford Classmate (whose father's law firm he worked for), Chair Echeverria (who admits to be "boyhood chums" with fellow wine business owner WLS's Elcano, upon
Coughlin prompting them to divulge further conflicts), Chair John Echeverria refused to allow into evidence the audio transcript Coughlin bought from the RMC (well, Coughlin had to have his mother, Very Special Arts
Nevada's Mary Barker sneak down to the RMC and buy it becuase Coughlin's previous three or four attempts to buy it himself were met with obstuctionist tactics by the RMC) for $35, where Bar Counsel King claimed it
wasn't "certified" and the lack of a written transcript made it "worthless" and "devoid of context" (surely the tape could have shown that the sua sponte interrogation by Judge Nash Holmes regarding her questioning
Coughlin if he was "recording" or had a "recording device" occured AFTER the one and only restroom break in theat 2/27/12 11 tr 26800 "simple traffic trial" and NRS 22.030(3) requirement for an Affidavit for any factual
allegations to support a summary contempt order for any conduct occuring in the "immediate presence" of the Judge would have been useful, as then RMC Marshal Harley could have maybe gotten his story straight (or
Judge Nash Holmes could have had some more "help" with her "memory" about what Harley "told" her to support Judge Holmes "finding" that Coughlin "probably lied" about such matters in her 2/28/12 Order, and that
Coughlin "lied" and therefore "violated the Rules of Professional Conduct" in her "second bite at the apple" Order of 3/12/12 (which violated NRCP 59(a) in that such a sua sponte altering or amending of what was a "civil
contempt" Order must be within 10 days of its entry...where Judge Nash Holmes cites to plenary civil contempt statutes in her ORders (NRS 22.010 and NRS 22.100, curiously avoiding the summary civil contempt statute
setting out the Affidavit requirment that Judge Holmes, the RMC, and Marshal Harley benefitted from avoiding, found in NRS 22.030(3)...

Also, less than 48 hours after Richard G. Hill, Esq. had the RPD arrest Coughlin for jaywalking in RMC 12 CR 00696 (curiously "transferred" to Judge Nash Holmes by Judge W. Gardner on 2/27/12, from RMC Dept. 1), the
RPD again arrested Coughlin on 1/14/12 for "misuse of 911"...but that would be politically awkward for RJC Judge Clifton to convict Coughlin of in rjc rcr2012-065630, plus, so much better leverage for the SBN (whom
received emails from RJC Judicial Secretrary Lori Townsend containing Coughlin's 2/21/12 filign in that matter and where Townsend offered to send Coughlin's 2/15/12 filing in rcr2011-063341 to the SBN, unprompted...and
the RJC and SBN are refusing to prove that such transmission by the RJC were not unprompted. Further RMC Judge Kenneth Howard and RMC Administrator Cassandra Jackson have sent unprompted correspondence to
the SBN seeking to have an effect on Coughlin's formal disciplinary hearing, which is judicial misconduct.

Summary convictions for contempt, during criminal trial, that are unwarranted by the facts will not be invulnerable to appellate review. Codispoti v Pennsylvania, 418 US 506, 41 L Ed 2d 912, 94 S Ct 2687, conformed to
(Pa) 328 A2d 484.
Denying misdemeanant contemnor an appeal and bail pending appeal, right to which all other misdemeanants were absolutely entitled under California law, violated equal protection clause. Bell v Hongisto (DC Cal) 346
F Supp 1392.
Criminal contempt judgments are immediately appealable because they result from a separate and independent proceeding to vindicate the authority of the court and are not a part of the original cause. 28 U.S.C.A.
1291. Cobell v. Norton, 334 F.3d 1128 (D.C. Cir. 2003).

33 A.L.R.3d 448
Appealability of contempt adjudication or conviction
Exercise by trial judge of his summary power to punish for contempt of court committed in his presence is subject to review on appeal. Re Lafferty, 28 Mich App 654, 185 NW2d 189.

RMC Judge Howard attempted to mislead Coughlin as to his right to appeal and seek review of the NRS 22.030 civil summary contempt Order he rendered against Coughlin at the conclusion of the 11/30/12 Wal-Mart
candy bar petty larceny trial in 11 cr 22176 (and now Chair Echeverria is trying to call that one "criminal contempt" too...seeking to utilize Bar Counsel King's oft repeated, Claiborne ignoring claim, that SCR 111(5) makes and
such "conviction" provide "conclusive proof of guilt" and thereby vitiating and Claiborne duty upon Bar Counsel of the Panel to ascertain whether a fundamental lapse of due process occurred (or whether such a "conviction"
was void for lack of jurisdiction or not actually a crime anyways under Schaefer...

Further WCDA's Office David Watts-Vial may not seek to Quash Coughlin's subpoenas served upon Clerk of Court Hastings where Watts-Vial's relation works as a Administrative Assistant to Judge Egan Walker.

In re Eriksson, 36 So. 3d 588 (Fla. 2010) (judge publicly reprimanded for revoking bond for defendant who sought recusal, thereby punishing defendant for exercising legitimate
legal right, and for employing unduly rigid process in dealing with self-represented litigants, so as to impede their ability to obtain relief and protection they sought from court).

http://www.flcourts.org/gen_public/courted/bin/judicialethicsbenchguide.pdf
6. What Contact with Investigative or Adjudicatory Bodies Is Permitted?
The case law and committee opinions advise that a judge may not initiate contact with an investigatory or adjudicatory body determining rights, duties, privileges, or immunities
of a person requesting that the judge contact the body on his or her behalf. Opinion 75-6 (improper to write character letter for attorney who is principal in disbarment
proceeding); Opinion 75-18 (improper to write letter to bar grievance committee or supreme court in disciplinary proceeding or to federal judge in criminal sentencing
without official request); Opinion 82-15 (improper to write letter voluntarily to Board of Bar Examiners); Opinion 89-15 (impermissible to appear before judicial nominating
commission to introduce candidate or express opinion about who is best qualified to serve as judge...See Judge Sferrazza's letter in 2007 on this and Judge Linda Gardner's
submitting numerous letters of recommendation from local judges:
http://www.washoecounty.us/large_files/agendas/071007/35.pdf page 101-104);

Judge Linda Gardner recused herself from Bell v. Greer admitting to a personal bias against Coughlin (maybe stemming from the Mandamus Petition Coughlin file in 54844
agaisnt her, which WLS's Elcano claimed to be unaware of in his improperly notice 11/14/12 testimony at Coughlin formal disciplinary hearing. Panel Chair Echeverria
did not care about SCR 105(2)(c)'s requirement that such a Designation of Witnesses and Summary of Evidence be provided Coughlin "at least" 30 days prior to the
11/14/12 hearing where Bar Counsel King (despite no "newly discovered" evidence justiying such, no argument by King in support of such a stance, and have been aware of
all that either Judge Beelsey or WLS's Elcano (whom both went to McGeorge School of Law in 1977 with another witness that day, RMC's Judge Dorothy Nash Holmes, though
none of divulged that...Judge Beesley also worked with WLS's Karen Sabo at Beesley Peck, and attended at 2008 West Fourth St. Bistro WLS fundraising dinner, RMC Judge
Howard is a 1980 graduate of McGeorge, as is Panel member Stephen Kent, Esq., and Coughlin "court appointed defender" Keith Loomis in the RMC, who received multiple
ORders granting his Withdraw, is a 1982 McGeorge graduate and whom fraudulently refused to assert the claim of right defense to the criminal trespass charge set out to him
in 11 cr 26405, even where Hill admits to having sent writings charging the same $900 per month that was charged for "full use and occupancy" and where Washoe County
Sheriff's Officer Liz Stuchell admitted in her 2/5/12 email to Coughlin that the 11/7/12 Affidavit of Service by Deputy Machen was false in that no personal service was effect,
therby making Hill and the WCSO the trespasses, along with Casey D. Baker, Esq., especially where the "within 24 hours of receipt" language of NRs 40.253(5) made both the
10/25/11 and 10/27/11 Orders in rev2011-001708 void and or stale, especially where WCSO Roxy Silva brazenly brags about the stomping on tenant's rights in open violation
of such law where the WCSO knows it is too late and any such Lockout ORder is stale. Oh, then there is the locksmith from the 11/1/11 lockout at Coughlin former law
office admitting that the lockout was effected outside the "within 24 hours" required in NRS 40.253 (not to mention Sferrazza's Order fails to include that required
language...which in no way amounted to a "trespass warning" anyways).

In re Frank, 753 So. 2d 1228 (Fla. 2000) (retired appellate judge publicly reprimanded for actions while on bench, including making false or misleading statements under oath
concerning his involvement in divorce litigation of his daughter; not recusing himself from appeals based on his friendship with attorney in those appeals; improperly interfering
with Bar grievance proceeding of that attorney; threatening to have son-in-law arrested or committed to psychiatric facility during divorce proceedings involving his other
motion for new trial, notice of appeal
daughter).

Then there is the matter of RJC Clifton on 2/27/12, "somehow" knowing that Judge Elliott would be "randomly" assigned the case created by Judge Clifton's 2/27/12 Order for
Competency Evaluation (the gross misdemeanor of "misuse of emergency services (911)" case rcr2011-065630 necessitated the opening of a District Court case, CR12-0376),
where Judge Clifton specifically lists "Judge Elliott" in that 2/27/12 Order and also list's the evaluator Couglin was required to utilized for the evaluation ("Lake's Crossing Bill
Davis, Ph.D....who just so happened to file and sign a fraudulent lie filled letter in that cr12-0376 case on 4/18/12 resulting in Coughlin being incarcerated from April 19th to
April 26th, 2012, though Judge Elliott has failed to put the "why" of it in writing in an sort of Order...and where DDA Young violated NRS 178.405 in moving for Coughlin to
"be remanded into custody" (as if asking a question about one's HIPAA rights or telling Bill Davis, Ph.D. that Coughlin would need to "check his records" in response to one
question justified such a remanding into custody or was tantamount to "following all laws"...which DDA Young clearly does not follow all laws himself given his horific attempts
to coerce from Coughlin, in conjunction with RJC Judge Sferrazza and "stand by counsel" WCPD Jim Leslie, Coughlin's Fifth Amendment rights on November 19th and 20th,
2012 in rcr2011-063341...see from 4:05 pm to 4:55 pm on 11/19/12 (at which time RJC Bailiff John Reyes attempted to extort from Coughlin permission to for the RJC to keep
(and probably search and or copy under Diaz) Coughlin's laptops and other trial materials overnight while Coughlin was in custody, at a time when Coughlin was handcuffed and
in custody awaiting transport to the Washoe County Jail incident to Judge Sferrazza finding Coughlin in contempt for "making arguement while testifying")
http://www.youtube.com/watch?v=8NsOLy2Unek
http://www.youtube.com/watch?v=w4c7hyhI1RI Witness "standby counsel" WCPD Jim Leslie trying to aid in coercing from Coughlin his Fifth Amendment and other
rights (even more than Leslie is heard doing on the record during the 8/27, 8/29/, and 9/5/12 Trial dates in 063341) at the 9:05 am mark

Then there is....this by RJC Judge Clifton and WCDA DDA Zachary Norman Young, Esq.:
http://www.youtube.com/watch?v=WPYCmDZTSXo

/s/ signed electronically Zach Coughlin
Zach Coughlin

law license temporarily suspended in Nevada
NV Bar No: 9473
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Thu 12/20/12 4:32 PM
To: dilworth@reno.gov (dilworth@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov)
1 attachment
12 20 12 12420 (104.9 KB)
Dear Judge Dilworth,
I am indigent and am requesting this be submitted for filign given some matters preventing me from going to the courthouse and time being of the essence.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
court refusing to file documents and exhibits missing
Tel and Fax: 949 667 7402
Sent: Wed 12/19/12 1:14 PM
To: (patrickk@nvbar.org) (patrickk@nvbar.org); (je@eloreno.com) (je@eloreno.com); (davidc@nvbar.org) (davidc@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com)
(cvellis@bhfs.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com); (fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (skent@skentlaw.com) (skent@skentlaw.com);
(nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (ncjdinfo@judicial.state.nv.us) (ncjdinfo@judicial.state.nv.us); (dballard@reno.gov) (dballard@reno.gov); (ballardd@reno.gov)
(ballardd@reno.gov); (jacksonc@reno.gov) (jacksonc@reno.gov); (renodirect@reno.gov) (renodirect@reno.gov); (kadlicj@reno.gov) (kadlicj@reno.gov); (joey.hastings@washoecourts.us)
(joey.hastings@washoecourts.us); (judge.hardy@washoecourts.us) (judge.hardy@washoecourts.us); (rsweet@nvcourts.nv.gov) (rsweet@nvcourts.nv.gov); (training@nvcourts.nv.gov)
(training@nvcourts.nv.gov); (staffattorney@nvcourts.nv.gov) (staffattorney@nvcourts.nv.gov); (zyoung@da.washoecounty.us) (zyoung@da.washoecounty.us); (jleslie@washoecounty.us)
(jleslie@washoecounty.us); (bdogan@washoecounty.us) (bdogan@washoecounty.us); (mkandaras@da.washoecounty.us) (mkandaras@da.washoecounty.us); (stuttle@washoecounty.us)
(stuttle@washoecounty.us); (info@abanet.org) (info@abanet.org); (katy.englehart@americanbar.org) (katy.englehart@americanbar.org); (bill.pritchard@americanbar.org)
(bill.pritchard@americanbar.org)
3 attachments
12 12 12 rcr2011-063341 notice of rjc refusing defendant access to file since 11 19 12 and refusing to file in documents 0204.pdf (1388.6 KB) , 20121219_113934 rcr2011-063341 robbin
baker cathy wood.jpg (1565.6 KB) , 12 19 12 docket in cr12-2025 from sferrazza's shepp violating 2011-063341 conviction 0204.pdf (254.1 KB)
To Whom it May Concern,
Before I get done away with, I just wanted to try to access justice a little bit more. Been having some real issues with Court's just refusing to file things (the RJC refusing to file the 12/26/11 Notice of Appeal in rjc rev2011-001708 cited in Judge
Flanagan's Order denying my appeal (or he cited my failure to file such a NOA in CV11-03628 as allowing him not to consider matters stemming from Judge Sferrazza's 12/21/11 order "resolving" (no, I did not "agree" to the Order, I made that
very clear on the record...).
Then there is the RJC failing to file my 3/16/12 Notice of Appeal in rjc rev2012-000374, in the other summary eviction by Galye Kern, ESq. (Judge Linda Gardner's former law partner, and I sued Judge Linda Gardner in 54844, and her Order in
dv08-01168 was cited by Washoe Legal Services Elcano as the sole reason for my firing, which led to 60302, and that April 2009 ORder now "mysteriously" became a grievance ng12-0435, which Bar Counsel has fraudulently attempted to assert he
got from "the clerk of court", but which lacks a certification from Clerk of Court Hastings (Bar Counsel King likes dealing with the Reno Municipal Court whenever possible, going so far as to have it certify documents that it lacks authority to certify,
then claiming the audio transcripts from the RMC are "not certified...worthless...lacking context..." when Coughlin tries to offer them to the Panel on 11/14/12 in SBN. V. Coughlin (ng12-0204, 0434, and 0435...which somehow is supposed to
address 60838 despite the "conviction" in 60838 not being addressed at all, which is considering the Court's 6/7/12 ORder and SCR 111(7) mandate that the matter "is referred to the disciplinary panel for the sole purpose of determining the
punishment " for the the conviction the subject of the SCR 111(6) petition in 60838 (ie, not for what the SBN and NNDB/Panel did, which is try to tranmogrify RMC Judge Nash Holmes various Order in a "simple traffic citation trial" into some SCR
111(5) "conclusive proof of a conviction" of a bunch of alleged violations of the Rules of Professional Conduct that Judge Nash Holmes copied and pasted into her second bite at the apple 3/12/12 Order in rmc 11 tr 26800...then there is judge
schroeder ruling that gayle kern doesn't even have to respond to coughlin's recent filings pointing out that she mailed the notice of entry of order to an address coughlin had told her was no good anymore in her may 2012 mailing....then
there is the rjc issuing an eviction order violative of nrs 40.253(5) on 6/28/12, depsite coughlin's filing a tenant's affidavit with the sparks justice court on 6/26/12, which was the forum listed on the notice in which the tenant must file...and
coughlin's writying and callign the wcso, rjc, sparks justice court, etc., etc. and giving them a heads up on the situation...no matter, Judge schroeder signed the eviction order and the wcso office arrested coughlin w here he didn't immediately
open his door and where the wcso refused to identify themselves, and where the lockout order was obtained by an unlicensed "eviction consulting service process firm", Nevada Court services in rjc rev2012-001048, which begat the criminal
prosecution fo coughlin in rcr2012-067980 for "resisting or obstructing a public officer" or "false statement to a public officer....the rjc and the wcda's office criminal and civil division and the wcso goin' together like bread and meat.
Then there is Judge Clifton's "disenfecting" the record from anything I am trying to preserve in rjc rcr2012-065630. Most recently he put a post-it note "Order" telling Robbin Baker and Cathy Wood to finally file in my 11/28/12 filing in that
matter but to file stampe it the day after the trial started...so file stampe it 12/12/12...which makes it far less operative.. I had permission to fax file as of 11/28/12, and given Judge Clifton removed public defender Dogan as counsel of record
substituting in me as a pro se...I was entitled to file that document (I believe it was an Motion for Reconsideration of Order allowing wCDA to Amend Complaint (they didn't want to try a "misuse of 911" charge against this former domestic
violence attorney, where Judge Clifton and Judge Gardner worked together in the domestic violence unit at the Washoe County District Attorney's Office and where Coughlinw as granted two protections orders against domestic violence against
the very peopel he called 911 about, but for which reno pd sargent paul sifre decided to order coughlin arrest for the second time in 2 days (the first arrest, on 1/12/12 was a custodial arrest for jaywalking...and in the interim the same officer
coughlin filed a written complaint against with the rpd on 1/8/12 pulled coughlin over on 1/13/12 with 5 other officers and harrassed him late at night....).
Plus, the wcpd refused to give coughlin the 8/13 and 8/17/12 cd's of discovery containing the 911 calls in question. DDA Young refused to provide Coughlin a copy and Judge Clifton claimed his hands were tied to allow Coughlin access to such
discovery (though he was sure to "help" the DA out by turning the 11/27/12 hearing into an arraignment, despite earlier stating on the record that it was not permissible to do so and how the hearing was for a very limited purpose of hearing
argument on the motion to amend the complaint (which was amended to a scr 111(6) "serious offense" because a conviction there woudl help bar counsel get rid of coughlin, and help the wcda's office out a lot more than a "misue of 911"
charge...the amended charge was "obstructing a public officer"...which is specificaly mnetioned in the scr 111(6) serious offense rule....though Judge Clifton kept a straight face when indicating to Coughlin "I don't see how "misuse of 911" is less
worse for you than "obstructing a public officer" under a SCR 111(6) analysis...I really don't. " Yeah. uh....sure.
Then there is Judge Clifton refusing to file in many other filing by Coughlin in rcr2012-065630.
Then, Coughlin as of 12/19/12, still has not received the record on appeal in cr12-2025 (one of 4 criminal matters involving Couglin that have been "randomly" assigned to Judge Steven Elliot, who worked at Panel Chair Echeverria's father's law
firm, sat on CAAW's board and presided over Coughlin's wrongful termination suit against CAAW and Washoe Legal SErvices, did not disclose the conflict, failed to recuse self, etc...and who went to Stanford in the later 1960s with Elcano (director
of WLS) and Panel Chair Echeverria...Oh, and Judge Gardner's campgain contributions include some from WLS's Torvingen, expense to CAAW, her brother refused recuse self from criminal trespass prosectuion of coughlin in 11 cr 26405...oh, jeez,
its exhausting detailing all this over and over....more copy and pasting necessary..
RMC certifying Second Judicial filings to SBN exhibit 16 from 11/14/12 was never provided to coughlin
then judge linda gardner's brother, rmc jduge william gardner failed to file coughlin's timely notice of appeal of the 6/18/12 conviction of trespass in 11 cr 26405...for cr12-1262...then the rmc failed to order the transcript prepared in the walmart
candy bar case in 11 cr 22176, which became cr11-2064, rmc holds Pam Longoni out as only one who can get the audio to do the transcript, and Longoni refuses to prepare the transcript, even where coughlin offerred to pay for it under protest
(because nrs 4.14(a) applies to civil cases, not criminal appeals by indigents....(rmc Judge HOward refused Coughlin court appointed counsel, even though he failed to rule that jail time was absolutely not a possibility, violation aigersinger...and
refused even one continuance, though they are freely given to richard g. hill/reno city attorney...or stipped to by lew taitel, coughlin's then rmc court appointed defender who is the "staff attoreny" for Nevada Court Services, whom Coughlin as
suing at the time...so, no on the conflicts check by Taitel...
Now Judge Clifton and Judge Sferrazza and RJC Administrator STeve Tuttle (with the help of clerk's Robbin Baker and Cathy Wood) have forbidden Coughlin from fax filing, only allow him 15 minutes a day to be at the counter to review a file (no
matter how much of that 15 minutes is eaten up with "delays"...), etc., etc. lots of special unpublished "house rules" applicable only to Coughlin...kind of like the impermissible rent escrow deposit judge sferrazza order in 10/13/11 in rev2011-
001708 in violation of jcrcp 83 in that the rjc has not published and had approved by the n. s. ct. a corollary to jcrlv 44...though Judge Clifton managed to find "moot" Coughlin's Motion to Set aside that forced rent escrow deposit in light of the
fact that Coughlin did deposit that $2,276 dollars....not exactly moot...kind of like Judge Clifton saying "your here!" when Coughlin contested the improper notice by public defender leslie of the 12/18/12 hearing in rcr2012-067980 that Judge
Clifton curiously presided over despite it being a Judge PEarson case and Judge PEarson being at work that day...the whole jcrrt rule about cases being randomly assigned doesn't seem all that hard and fast...like when Jduge Clifton was assigned
the Coughlin v. Park Terrace illegal lockout case, but rjc bailiff sexton came in and moved Jduge SFerrazza onto the matter minutes before the hearing, whereupon Judge Clifton had "traffic matters" to rule on....
then there is the rmc and judge nash holmes refusing to file in and comply with the dictates of nrs 189.030 in 11 tr 26800 where coughlin appealed the contempt order of 2/27/12 and 2/28/12....and the whole business of the rmc and its
marshall being given coughlin's smart phone and micro sd card after it was book into coughlin's personal property at the jail on 2/27/12, when the rmc marshals came to the jail on 2/28/12...and apparently..without a court order or warrant, were
allowed to take possession of those items and take them back to the rmc....and they were returned to coughlin 37 days later, via a 3/30/12 order by judge nash holmes releasing them to coughlin (curious considering coughlin's 3/30/12 filign in
Judge Beelsey's case in the nvb cadle company v keller 10--05104 exposed that whole confiscating coughlin's property in a manner in no way a search incident to arrest....) and where Judge Beelsey, Judge Nash Holmes, and Washoe Legal SErvices
Elcano all went to McGeorge School of law in 1977....and all three testified at coughlin's 11/14/12 formal disciplinary hearing before the panel and sbn....hhmmmmmn....
and the recent cr12-1262 appeal of the denial of coughlin's motion for new trial did not include the cd/dvds coughlin attached to his 10/24/12 filign and his 11/2/12 filing (and the 11/2/12 filign was not included in what the rmc transmitted to
the district court on 11/29/12? funny..... lots of attached cd/dvds turnin' up missin' or "weren't never there" despite Robbin Baker admitting they were in the rjc in rcr2011-063341 and rcr2012-065630 in the jduge sferrazza and judge clifton
cases...and in Clifton's 065630 City Attorney Bony's letter about the subpoenas in 2011-063341 and the envelope addresssed to judge sferrazza is in the file in Clifton's 065630 case? and Judge Clifton admits that, on the record in 065630 he
"looked at the submission on subpoenas" in the judge sferrazza cases...funny, Judge SFerrazza said there was no cd/dvd's attached to any of Coughlin's pre-trial filings.....and judge sferazza signed the 11/16/12 orders on those "submissions on
subpoenas"...so why would Judge clifton be lookin at them and why are cd/dvd's disappearing?
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Wed 12/19/12 2:22 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); davidc@nvbar.org (davidc@nvbar.org); eifert.nta@att.net (eifert.nta@att.net); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); skent@skentlaw.com (skent@skentlaw.com); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); ncjdinfo@judicial.state.nv.us (ncjdinfo@judicial.state.nv.us); dballard@reno.gov (dballard@reno.gov); ballardd@reno.gov (ballardd@reno.gov);
jacksonc@reno.gov (jacksonc@reno.gov); renodirect@reno.gov (renodirect@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); joey.hastings@washoecourts.us
(joey.hastings@washoecourts.us); judge.hardy@washoecourts.us (judge.hardy@washoecourts.us); rsweet@nvcourts.nv.gov (rsweet@nvcourts.nv.gov); training@nvcourts.nv.gov
(training@nvcourts.nv.gov); staffattorney@nvcourts.nv.gov (staffattorney@nvcourts.nv.gov)
Dear Administrative Office of the Courts,
I apologize for the rushed nature of this, however, the SBN, RMC and RJC have been putting me through the paces of late and I never know when they
will finish the job on me, so I want to send this while I can...
and Chair Echeverria and or SBN Bar Counsel King have a duty of candor and can't sneak it into the file as an "exhibit 16" where Coughlin was not
provided a copy at the hearing on 11/14/12, especially where the 4 exhibits that were included with that filing (exhibit 16 EMERGENCY EX I'ARTE
MOTION TO DISMISS. VACATE. reset or postpone, etc...)
check out the exhibit page on page 32 of the attachment....notice how none of the exhibits were included in what was given to the clerk and court reporter
purporting to be a "rule of completeness" sufficient copy of that filing presented as Exhibit 16? You guys lied enough already (you gave me permission
to file by fax, then didn't file in my faxed filings...you waived subpoena and subpoena duces tecum fees, then lied and said you didn't sufficient to prevent
me from being able to call witness (and you know that attached keith loomis, esq. subpoena was problematic for you...no wonder Pat King disposed of the
grievance against Loomis so quick...and then you lied when you said you didn't give me permission to issue my own subpoenas (ie, you said I would not
be required to have them "issued by the court" or embossed or baring a seal or any of that, but that I could issue my own subpoenas "in the manner an
attorney could" despite my current temporary suspension. You guys are lying overtime....how many of the Panel are in on it? Vellis? How about
you? Its a nice reputation you have Vellis...would be a shame to see it get all associated with this despicable miscarriage of justice. Not sure Mike
Johnson wants the Supreme Court knowing he was texting on his iPhone the whole hearing, or twittering or whatever, because he definately wasn't paying
attention or looking professional. And as for hiding my cd/dvd's attached as exhibits to filings from the Justices of the Nevada Supreme Court, Panel
Member Stephen Kent (McGeorge Class of 1980, interesting that "Chairman Susich" chose the Panel...sure...Pat....Elcano, Beesley (both of whose
testimony was not noticed until a couple days before the hearing despite nothing about it being newly discovered to bar counsel...and why hasn't the
Beesley letter ever been produced to Coughlin? And Elcano is not a "practicing attorney"...check his SCR 79 page on www.nvbar.org....inactive status,
has been for quite some time...that's why "wouldn't he be awfully rusty" comments were made when his name was floated for the ECR deal...
Also, look at the certification by Donna Ballard. She is not authorized to make certifications for documents from the Second Judicial District Court.
Look closely at the language on her certifcations. Her court does not maintain the "originals" in cv11-03628, nor in cr11-2064, nor in cr12-1262.
That is fraud by both she and Bar Counsel King for purporting those documents to be certified. Further, its fraudulent for King to (or have Richard
G. Hill, Esq. do it) read a quote from a passage of Richard G. Hill, Esq.'s associate, Casey Baker, Esq.'s Motion for Attorney's fees and purport it to be
something ordered by Judge Flanagan. Just because Judge Flanagan quotes to something in one of his Order's does not mean he endorses is as a
conclusion of law or finding of fact or even a part of his Order. He has quoted to things I wrote before. He commented on something I wrote being
"poignant" in dismissing on 3/27/12 Hill's Second Motion for Order To Show Cause once Coughlin destroyed Hill's witness, contractor Phil Stewart on
cross examination at both the 3/23/12 hearing (closely following by bar counsel ill advised and cryptic email about "the clerk of court in Department 3"
writing the SBN about Coughlin's clothing choice or some high school gibberish or other. I demand the RMC and Ballard immediately retract those
"certifications".
Please consider this as my resume for the staff attorney position with the Administrative Office of the Courts and review my filings with the Nevada
Supreme Court.
Not sure its appropriate or Panel Chair Echeverria to be sticking his tongue out at me throughout the hearing and grinning demonically like some "Boss
Hog"...Also, kind of funny to apply the Court's scr 111(7) citation in its 6/7/12 Order about the "sole purpose of determining the punishment' to the
hearing...but not just to the walmart candy bar petty larceny conviction, but instead, to a multitude of RPC violations the SBN and or RMC Judge Nash
Holmes copied and pasted into an Order. Chair Echeverria admitted during the "hearing" on 11/14/12 that he and the Panel and SBN were just skippin'
past the whole being accused of something and having a trial on it and going straight to the sentencing phase...despite none of the RPC violations being
"proven" (and Judge Nash Holmes, testifying by telephone over Coughlin's objection, was sure to point out she "wasn't trying to usurp the function of a
formal hearing panel" in her 3/12/12 Order, upon which Bar Counsel is trying awful hard to tack on an SCR 111(5) "conviction is conclusive proof of
guilt" easy day at work....but SCR 111 is for "criminal convictions", Pat King...next time you feed Judges proposed findings and criminal law violation
orders, get the statue right, Pat. That Order from a "simple traffic citation matter", from which Judge Nash Holmes threw in the Schaefer "clear and
convicing evidence" standard bar counsel prompted her to insert, in her attempt to transmogrify the 3/12/12 resumption of the traffic citation trial in rmc
11 tr 26800 into not only a second bit at the apple considering she already issued an order on 2/28/12 (which was attached to the filing in Judge Beesley's
NVB court in the adversary proceeding 10-05104 Cadle Company v Keller...which had to alarm Judge Beesley to see his 1977 classmate at McGeorge,
Judge Nash Holmes and Washoe Legal Services Paul Elcano having such trouble with Coughlin (not to mention Judge Beesley's former partner at
The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in rcr2012-065630
Beesley Peck, Karen Sabo, Esq. was being sued by Coughlin incident to her actions at WLS set forth in the wrongful termination lawsuit on appeal with
the Court in 60302...maybe if Bar Counsel had managed to notice Coughlin on Judge Beesley's testimony more than 2 day prior to the hearing, and not in
violation of SCR 105(2)(c), some of this mess could have been avoided...But another thing is clear...there was no "misdemeanor of criminal contempt
convictions of Coughlin...ever....that would require a citation to NRS 199.340...which is not summary in nature anyways....NRS 22.030 (Judge Howard
cited to the right statute at least), and NRS 22.010 (the one Judge Nash Holmes attempted to characterize as a "misdemeanor of criminal contempt" along
with NRS 22.100, in justifying her summary 5 day incarceration of a pro se attorney in a traffic citation trial seconds after he testified that RPD Sargent
Tarter "lied when he said that..."...and boom....contempt citation, 5 days in jail, no stay...prejudice to Coughlin's client's be damned...and the SBN and
Judge Nash Holmes are goign to try to make hay out of an in forma pauperis application indicating Coughlin employed as a "jack of all trades" filed
after a trial in 11 tr 26800 wherein Coughlin's being an attorney was discussed extensively? And Bar Counsel wants to object to Coughlin entering
into evidence or using for impeachment both the audio transcript the RMC sold him and the disc of the same hearing the RMC purportedly gave to Bar
Counsel, then Bar Counsel gave to the Screening Panel, then gave to Coughlin? Yet Donna Ballard gets to certify Orders by Judge Flanagan and Judge
Elliot (who worked at Chair Echeverria's father's law firm, and who went to Stanford from Reno along with Chair Echeverria and Washoe Legal
Services's Paul Elcano in the later 1960's together....and Echeverria and Elcano went to Reno High School together in 1962, and were forced to admit they
were "boyhood chums"....no mention of the wine business though at the hearing or the Basque Board, or the Orlich and Gardner connection with Elcano
and Coughlin's contention that Elcano admitted to Coughlin in February 2009 that Judge Linda Gardner had approved of Coughlin's work at that time
after Elcano querried her and Elcano citing having done Judge Gardner "a big favor a long time ago" as a basis for establishing his strong rapport with
Judge Gardner, and, apparently, her veracity or something or other.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
0204 Coughlin Disciplinary Hearing File cut up with notations revised.pdf.pdf
12 10 12 065630 final motion recuse conflict continuance with exhibits and cover pages.pdf
Download all

Sent: Thu 12/13/12 9:34 AM
To: jleslie@washoecounty.us (jleslie@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us); bdogan@washoecounty.us (bdogan@washoecounty.us);
jgoodnight@washoecounty.us (jgoodnight@washoecounty.us); cfortier@washoecounty.us (cfortier@washoecounty.us); stuttle@washoecounty.us (stuttle@washoecounty.us);
mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skauc@reno.gov (skauc@reno.gov); wongd@reno.gov
(wongd@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); cvellis@bhfs.com (cvellis@bhfs.com); je@eloreno.com (je@eloreno.com);
patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); rosec@nvbar.org (rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); skent@skentlaw.com
(skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com)
28 attachments
12 7 12 declaration of zach coughlin 0204.pdf (81.2 KB) , 2 6 12 email from Fortier regarding Dogan 065630.pdf (30.3 KB) , 10 11 12 email fw misue of 911 case 065630 fortier et al.htm
(347.1 KB) , transparent nevada Veronica Lopez Marcia Lopez 26405 22176 00696 065630 0204.pdf (104.2 KB) , 1 12 12 rpd police report 12 cr 00696 sifre leedy look nash young
kandaras bradshaw 0204 065630 redacted ocrd.pdf (3.2 MB) , Beckett_RI20110404 0204 065630.pdf (117.7 KB) , Beckett and Tanner examples special treatement for prosecutor and tanner
petty theft involve s16K 0204 Bar_Counsel_Report__June_2011.pdf (284.4 KB) , 11 22 12 26405 Motion for Continuance because Hill on vacation Hazlett Declaration 0204 065630.pdf
(407.6 KB) , 12 6 12 not authorized by Clifton Custodian of Records WCPD 065630.pdf (1791.3 KB) , coughlin nsct docket search as of 12 7 12 0204 065630.pdf (48.6 KB) , 8 20 11
unredacted dispatch logs 063341 back from tiff.jpg.pdf (229.0 KB) , 9 7 12 063341 Order For Competency Evaluation 0204 065630 12420.pdf (1573.5 KB) , 12 19 11 063341
GOODNIGHT'S REQUEST FOR DISCOVERY 0204 065630.pdf (2.4 MB) , nsct docket 54844 coughlin v dist ct joshi 01168 0204 26405 61901.pdf (33.5 KB) , 11 27 12 065630 fax cover
page post it clifton 11 28 12 don't file this in stays w case file however 1 of 69 pages.pdf (265.7 KB) , 12 6 12 26405 Notice of Deficiency of Record on Appeal and Filing of Judicial
Discipline Commission Complaint 0204 - Copy.pdf (777.9 KB) , 12 6 12 stamped 065630 emergency Motion for Mistrial and Continuance Given state's failure timely provide discovery
exculpatory - Copy.pdf (765.2 KB) , 12 4 12 Affidavit of Service RJC Bailiff John Reyes lacks a lack number, lacks a notary 065630 063341 067980 has no Order attached to it or
incorporated by reference.pdf (492.2 KB) , paes 1 to 17 from first fax judicial discipline commission complaints 0204 gardner elliot howard nash holmes sferrazza clifton final-2-2.pdf
(596.6 KB) , Paul-D-Elcano-Jr--1070555-a stanford 0204 elliot echeverria.pdf (67.3 KB) , 01955 docket coughlin elliot gardner elcano.pdf (152.4 KB) , cr12-0376 coughlin judge steven
elliot 0204 docket ccwashoe.pdf (23.9 KB) , cr11-2064 docket coughlin v city of reno judge elliot city attorney roberts 0204.pdf (42.7 KB) , paul elcano suing rutherform chiropractice and
dr ross and nichols 0204 60317.pdf (18.7 KB) , 2 3 12 22176 60838 0204 roberts Gmail - courtesy copy of audio of trail exhibit 1 to Supplement to Opposition to Motion to Dismiss.pdf
(16.8 KB) , 11 10 12 063341 nrs 174.345 sbupoena on Duralde Rosa Alaksa and others rrr certified 1045 skau 0204.pdf (10.5 KB) , 11 26 12 5 big recent emails 60302 60317 Garin WLS
Gardner 0204 60331 61383 063341 etc.pdf (645.8 KB) , 54844 COUGHLIN VS. DIST. CT. and Linda Gardner 0204 0435 26405.pdf (5.1 MB)
The Trial yesterday in RCR2012-065630 featured extended discussions regarding the failure of the WCPD, Dogan, and Leslie, to turn over discovery
propounded by DDA Young in the form of cd's featuring 911 calls DDA Young provided to the WCPD on 8/13/12 and 8/17/12... And the heavy hitters
were there, too (Elliot Sattler).....despite numerous written requests from Coughlin that the WCPD do so, and multiple trips to the WCPD personally by
Coughlin to pick such materials up, and despite more flip flopping on their story by Leslie and Dogan regarding whether they ever gave Coughlin some
package of materials responsive to Coughlin's request for his "file"...But, Jim Leslie is stuck with the 7/27/12 date he mentions in his email, then he is
stuck with what his recent email wherein he purports to have therein digitally transmitted Coughlin his "file", which obviously does not include the cd's of
911 calls (the one's DDA Young took up an enormous amount of court time playing, over and over (well, Young only played over and over the particular
calls he felt were strongest for his case and most prejudicial, claiming some "cutting room floor mishap" for the reoccurrence of certain calls, arguing that
such a "happy accident" justified playing them again and again, at ever increasing volumes, etc., etc.). Apparently, I am here to subsidize Young's baby
making, just like I was with Ms. Gorman, as a continuance of prejudicial length of afforded to the State where none was forthcoming to Coughlin, despite
Leslie and Dogan's obstructionist tantrums, ones of a quality that would. I remember when my life featured happy moments like the birth of twins...but
that was before your leviathan legal system wrecked shop on my existence. What, sir, shall be my compensation? Do you mind if I put my arm
around....http://tinyurl.com/bgmlfdr
This is a formal grievance against Dogan, Leslie, Bosler, Young...etc.
If Svengali/Diann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order them, he better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of
911 calls DDA Young gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-065630, and clearly, any packet from 7/27/12 wouldn't have them (not to even get into the flip flopping contradictory accounts by Leslie and Dogan
as to who gave Coughlin the packet, or who didn't or blah blah blah)...and certainly Leslie email below only contained a 57 page pdf...way to close to the 12/11/12 trial date, and containing materials Coughlin had never
been given before....so much easier, Jimmy Sleazy to email the client a "digital transmittal" proving what you gave and when"....but, no, that would make it so hard to fudge the accounts of what was contained therein, or
who handed what to whom, or who failed to pick up this or that, or Dogan's slippery nonsense:
"From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response to your request. Please note that the July 27,
2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packet encloses a copy of the April 17, 2012, hand delivery transmittal of the very same
documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to retrieve them, we provide the attached courtesy
copy before final closure of our file.

No response to this transmittal is required from you.

James B. Leslie, Esq."
So, while Dogan states on 7/27/12 in 65630 "Your Honor, I have never even spoken with Judge Dorothy Nash Holmes"...he coyly fails to indicate whether
he spoke with anyone with the RMC, Marilyn Tognoni, included, or why his 2/28/12 fax to Coughlin was so insistent that it was "Lake's Crossing's Bill
Davis, Ph.D." who must conduct the "Competency Evaluation", or how it was Judge Clifton's 2/27/12 Order for Competency Evaluation could have
possibly known and included Judge Elliott as the "randomly assigned judge" to that Competency Case in CR12-0376 (Judge Elliott on Committee to Aid
Abused Women's Board, (CAAW)...Judge Elliott presiding over Coughlin's wrongful termination lawsuit against WCDA's Office ECR Partner, Washoe
Legal Services, its Executive Director Paul Elcano, and CAAW, in CV11-01955...Judge Elliott fails to disclose conflict or recuse himself, Judge Elliott
manages to "randomly" be assigned Coughlin's two criminal appeals from RMC convictions (the Wal-Mart "candy bar" petty larceny leading to a 6
months, so far, temporary suspension of Coughlin's law license in 11 cr 22176 in the RMC, then cr11-2064 in the appeal Judge Elliott canned based upon
a civil statute requiring a down payment for the preparation of transcripts and Elliott's contention that he need not address the merits of Coughlin's appeal
given the lack of a written transcript (Coughlin paid for the audio cd, and its not even clear that the RMC is a court of record anyways, and the RMC
distributes to defendants instructions sheets and enforces "house rules" regarding the preparation of transcripts that require one utilizing the services of
RMC "official transcriptionist Pam Longoni (whom hung up on Coughlin twice, and refused to prepare the transcript in 11 cr 22176/cr11-2064, failed to
return emails/faxes, etc.)" and where the RMC refused to even give Coughlin the audio recording for some time, insisting Coughlin could merely have it
made available to Longoni....Oh, Coughlin didn't get no continuance from Judge Howard in that 11 cr 22176 (even where he was wrongfully evicted in
Rev2011-001708 (now on appeal in 60331 and 61383) on 11/1/11, then wrongfully arrested on 11/13/12 in 11 cr 26405 (now feature in 61901, 62104,
54844, 60302, 60317, etc..) and incarcerated between 11/13/12 and 11/15/12, no continuance for the 11/30/12 Trial in 11 cr 22176, despite an agreement
in writing with City Attorney Pamela Roberts (whom put on perjured testimony by three witnesses where she possess a video and other evidence
conclusively proving that Coughlin did provide his driver's license to RSIC Officer Crawford...and where Robert's prosecuted based on an arrest for a
misdemeanor by tribal officers where NRS 178.1255 bars such an arrest, and where Wal-Mart's Thomas Frontino and Roberts herself admit no citizen's
arrest was effectuated....so, about that RPC 3.8 violation...). Then there is the appeal in cr12-1262 that Judge Elliott, again, was "randomly" assigned
from the conviction by RMC Judge William Gardner in 11 cr 26405 based upon the criminal trespass complaint signed by Richard G. Hill, Esq. (opposing
counsel in the summary eviction from Coughlin's former home law office in rjc rev2011-001708, presided over by Judge Sferrazza, though Hill and his
associate Casey D. Baker, Esq. fax, on October 17th, 2011 to Judge Clifton (who was not Chief Judge at the time, or anything) an Emergency Ex Parte
Motion for Inspection of Coughlin's Law Office, and where in his October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as "moot"
Coughlin' 11/17/12 Motion to Set Aside the 11/13/12 Order following Summary Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on
10/25/12, on the condition that Coughlin deposit a rent escrow of $2,275 with the RJC (though Judge Sferrazza admitted later on the record on 11/7/12
that the RJC Judges had a meeting wherein they all had to agree that Coughlin was absolutely correct that the RJC was violating Nevada law in having an
unpublished "house rule" corollary to JCRLV 44 requiring such rent escrow deposits in landlord tenants matter here JCRCP 83 had not been followed in
that the RJC had not published and had approved by the N. S. Ct. any such deviation from the statutory remedies set forth in NRS 40 and 118A. Judge
Elliott managed to torpedo that appeal of the criminal trespass conviction stemming from the criminal complaint and custodial arrest at Coughlin's former
home law office by co-signing RMC Judicial Assistant Lisa Wagner's and the RMC's nonsense about not having received Coughlin's Notice of Appeal
timely under NRS 189.010. The proof of delivery fax confirmation indicates otherwise, Lisa. And regardless. the conveniently timed arrest of
Coughlin on 6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion for New Trial in that matter, and the kited, dated 7/10/12 jailhouse Notice of
Appeal by Coughlin, and the curiously failure to grant Coughlin tier time in the interim while Judge Gardner manageed to push through his 7/11/12 Order
Denying Coughlin's Motion for New Trial, is all the more reason to apply consternation to Judge Elliott's work on the appeal on CR12-01262.. Then
there is Judge Linda Gardner being Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out of the Mental Health Court based upon Sharon
Dollarhid, Rene Biondo, and Breen and the MHC's own breach of contract (if they provide program materials, acceptance, and a contract that list certain
medications as disallowed, how is it they can claim non-compliance or "failure to abide" by the rules for taking a medication not listed therein? Don't
ask WCPD Joe Goodnight or Jennifer Rains...they know what side their bread is buttered on....MH12-0032...so DDA Young tries to jam through a trial in
063341 on May 7th, 2012, despite the mandatory stay in NRS 178.405 and the then still pending Order for Competency Evaluation in rjc 2012-065630
from the clandestine status conference Dogan and Young never quite seem to refute happening on 2/27/12...Oh, and Judge Clifton, then DA Dorothy Nash
Holmes, and Judge Linda Gardner were all co-workers once upon a time, working closely with then Sparks City Attorney/prosecutor Steven Elliott, whom
worked for the law firm of the father of the Panel Chair for Coughlin's 11/14/12 SBN v. Coughlin formal Disciplinary Hearing in NG12-0204, 0434, 0435
(the last two being grievances against Coughlin filed, in part, by RMC Judge William Gardner, prior to Gardner failing to recuse himself from the criminal
trespass case against Coughlin before him in 11 CR 26405...even where Judge Gardner's sister Judge Linda Gardner's April 2009 Order sanctioning
Coughlin was cited by WLS's Elcano as the sole basis for firing Coughlin, and where Coughlin filed a Mandamus Petition in 54844 challenging those
sanctions, and where ng12-0435 was one of three grievances forming the 8/23/12 SCR 105 Complaint against Coughlin (strangely...the Wal-Mar "candy
bar" petty larceny conviction and the formal hearing for the "sole purpose" of determining Coughlin's punishment for such required by SCR 111(8) and the
Court's 6/7/12 Order got particularly short shrift in the 8/23/12 triple grievance numbered SCR 105 Complaint by Bar Counsel Pat "Patty Ice" King, a/k/a
Pat Salieri, whom wants no part of explaining his statements to Coughlin during the 3/26/12 appearance at the SBN by Coughlin, for the sole purpose of
taking King up on his offer to let Coughlin review the materials submitted along with the grievances (therein King claimed to have received grievances
against Coughlin from three different Judges....though, by 3/26/12, it couldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge Nash
Holmes and the WCSO and WCDA impermissibly confiscating Coughlin's smart phone without a warrant or court order and well after the end of the
period to do a search incident to arrest (the arrest was 2/27/12 for some pastiche of summary plenary civil criminal contempts statuts that Judge Nash
Holmes whipped up...though she avoid NRS 22.030 and definitely there wasn't no affidavit signin' by ol' RMC Marshal Harley for alleged conduct in a
restroom or restroom stall, which assuredly was not "under the watchful eye of the court" or "in the immediate presence" of the court....so much easier for
Bar Counsel to feed Judge Nash Holmes the "clear and convicing evidence" standard from Schaefer required to prove an ethical violation, have here
copy and paste some RPC's into a second bite at the apple and more than 10 days later (civil statute, NRS 22.010, NRCP and JCRCP 59 allow sua sponte
amending within 10 days, no 12 days...2/27/12 to 3/12/12....void Order of 3/12/12 by Judge Nash Holmes, so, sorry Patty Ice, nice try, no SCR 111(5)
"an Order or conviction is conclusive proof of guilt and I don't recognize Claiborne as binding authority because it makes my job harder...."....
Thank You Jim for continuing to prevaricate in writing, your recent email combined with some, uh, other materials that have been culled, will surely be
helpful in exposing you for the fraud that you are. And Biray Dogan too...Oh, by the way, that 11/7/12 fax confirmation page or proof of faxing?
How is that coming along, because I need to see it from you. My records show absolutely no receipt of any fax of that sort, not on that day, not on any
day...which means the ball is in your court to show how Dogan's representations to Judge Sferrazza on 11/19/12 in court were not displaying a lack of
candor to the tribunal and How Leslie Tibbals' certificate on service therein is not fraud.
Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
"REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public
Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or photograph
any written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of the
State, the existence of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes
any video and audio recordings, including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded,
generated in connection with this case."
Jim, then there is you chiming in, in your role as "standby counsel", attempting to aid the Court and DDA Young in coercing from me my Fifth
Amendment rights at the 9:06 am mark on the transcript from 11/20/12 ("Your Honor, I'll remind the Court that I am here to jump in in my role as standby
counsel anytime the Court's feels he is dragging his feet....He is wasting County assets!"...very Atticus Finch, Jim).
So, then there is Jim's 10/3/12 subpoena to Ecomm/Kelley Wood...and given he was counsel of record until 10/22/12, yet completely failed to turn over
anything (responsive or not) in relation to that subpoena, and the fact that the entire Suppression Motion turned on "what information the RPD received
from dispatch", and the fact that the audio of the "radio traffic" between the RPD and Dispatch on that night (or at least the portions of it I have been able
to extract from the powers that be) reveal, one, no report of a possible fight was received by RPD (they were on the scene by the time the 11:27:11 pm text
was sent to the displays in their vehicles, and the one audible "radio traffic" recording contains no mention of anything beyond "check for possible larceny
of a cell phone that just occurred, suspect still on the scene, also reports of a loud verbal disturbance...". Then there is Jim and Goodnight completely
whiffing on the detaining argument, in addition to the whole "assuming we win on the pat down, make sure to oppose the notation that there was sufficient
probable cause for an arrest and search incident thereto....", not to mention that it was Coughlin (whose filings Jim managed to cheerfully announce "The
Public Defender's Office is not joining in on those fugitive documents...", despite the 2/21/12 Filings by Goodnight that do just that....) that pointed out the
whole NRS 171.360 basis for throwing out the search (which Jim managed to not cite to or quote from in his closing argument as the Suppression
Hearing...where Jim did manage to ask Cory Goble questions on cross that were designed to do nothing more than establish a citizen's arrest sufficient to
rebut the NRS 171.360 basis for throwing out the arrest and fruits culled therefrom...).
Oh, then there is your office blacking out the numbers of the callers on the dispatch logs and refusing to turn over even a redacted version of the alleged
victim's call records for the time in question, thereby completely obstructing the defendant's ability to impeach the various lies testified to by all the
witnesses. And "Coach" DDA Young can tell you all about his 40 minutes coaching sessions visible through the plexiglass in the Justice Court lobby
with Zarate, Goble, Lichty, and Templeton, and their constant parroting (along with RPD Duralde) of "prosecutor buzzwords" ("willfully withheld",
"report from dispatch of a possible fight", "my training and experience", "detained", "I don't remember who made the call", "I can't remember which one
of my friends it was who was with me", etc., etc.) Also, the WCPD practice of blacking out locations and addresses sure makes it difficult to establish
inconsistencies between testimony and the reports/Witness Statements or otherwise utilize them for impeachment purposes.
So, now today, we get this Jim Leslie email with all it's revisionist history...which only contradicts the position Leslie and Dogan have taken that
Coughlin already picked up this 7/27/12 packet (at first Dogan claimed to have personally handed it to Coughlin, then changed his story 2 minutes later
and said he saw Leslie personally hand it to Coughlin....and Dogan asserts to the Court at the 11/27/12 Hearing in rcr2012-065630 that he has never
spoken with Judge Dorothy Nash Holmes (see materials regarding clandestine status conference of 2/27/12 and subsequent fallout with Judge Nash
Holmes of 2/27/12 a couple hours after Dogan secured his 2/27/12 1:31 pm Order for Competeny Evaluation in 065630 from Judge Clifton).
The SBN v. Coughlin Complaint of 8/23/12 specifically mentions the arrest of 1/14/12 that theis 065630 case is based on, in addition to the 063341
iPhone arrest, and RJC Judicial Secretary Lori Townsend sent Coughlin's 2/21/12 in 065630 to the SBN, and offered to send Coughlin's 2/15/12 filing in
063341 to the SBN...and Judge Nash Holme's 3/12/12 Order in 11 TR 26800 mentions Coughlin quoting "rock lyrics" in a filing as a basis for her
transmogrifying a "simple traffic citation" to a "formal disciplinary hearing on an ethics violation" wherein she quotes the Schaefer standard for an ethical
violation that Bar Counsel had fed her earlier in the day...and that window between the 1:00 pm noticed start time of the traffic citation trial in 11 tr 26800
and the 3:30 pm eventual start time includes the 1:25 pm courthouse sanctuary doctrine violating service upon Coughlin (by RMC Marshal Joel Harley, on
behalf of WCSO Deputy Machen, hired by Richard G. Hill, Esq., at whose office Coughlin was retaliated against by RPD Sargent Tarter with the three
traffic citations shortly after Coughlin reported to Tarter the admissions regarding bribery by Richard G. Hill, Esq. by RPD Officer Chris Carter, Jr....and
Marshal Harley was serving the Order to Show Cause for the 3/23/12 Hearing in the appeal of the summary eviction from Coughlin's former law office
(where RPD Carter made the trespass arrest now detailed in N. S. Ct. case 61901), on behalf of Deputy Machen, in the conference room within the
Courtroom B of the RMC, despite Coughlin, an efiler, having already been served it). However, the only filing by Coughlin that could be said to quote
"rock lyrics" is the 2/21/12 filing in Dogan's case 065630 (the one where Dogan had appeared as attorney of record then failed to show up for a hearing on
2/13/12, then retaliated against Coughlin for Coughlin's 2/21/12 filing in 065630 by moving for a Competency Evaluation and basically doing absolutely
nothing on the case for the next 9 months besides raping from Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach Young
at the 4/19/12 hearing in CR12-0376 (one of 3 criminal appeals Judge Elliot was "randomly" assigned in which Coughlin is a party...to go along with the
wrongful termination suit by Coughlin that Judge Elliot presided over in CV11-01955 wherein Coughlin sued CAAW and WLS, despite Judge Elliot
sitting on CAAW's Board, and where Judge Elliot, the Panel Chair at Coughlin's formal disciplinary hearing of 11/14/12, and Washoe Legal Service's Paul
Elcano all went to Stanford together, and where Judge Elliot worked for Panel Chair John Echeverria's father's law firm, Echeverria and Osborne). Then
there is Linda Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from Mental Health Court in MH12-0032, where the MHC's
Rene Biondo and Sharon Dollarhide lied about what medications were listed as accepted or not in the materials provided by Goodnight and or the MHC
along with the contract entered into with Coughlin, whom was accepted into the MHC. Then there is WCPD Joe Goodnight and Jennifer Rains refusal
to file anything directed towards enforcing the MHC's contract with Coughlin, wherein they both demonstrated they know what side their bread is buttered
on and indicated "there just isn't a basis for seeking reconsideration of Judge Breen's Order". Judge Peter Breen, MD.
Funny how Dogan did not state to Judge Clifton that he never spoke with anyone else at the Reno Municipal Court about
Coughlin....including Marilyn Tognoni...but, rather Dogan just indicated he never spoke with Judge Nash Holmes, in his best innocent little
boy voice that he cops when he isn't busy tittering away with Jim Leslie in the spectator area during the 11/19 and 11/20 Trial in 063341
(where he failed to apprise Judge Sferrazza of the fraud attendant to his earlier attestations regarding proof of service (by fax no less) of his
11/7/12 Motion to Quash Coughlin's Subpoena....
Also, its a bit strange how Dogan and the WCPD redact or black out the names of the RPD Officers and Dispatch Operators beginning on
page 16 of the 56 page file Jim Leslie finally emailed me today titled "Coughlin Discovery 911 Case", which, as is their wont, he and Dogan
have continued to change their stories about whether they had or had not provided to me already until the last possible minute before
trial, whereupon, with a Trial date of December 11th, 2012 in rcr2012-065630, Jim Leslie finally emails me a 56 page pdf purporting it to be
my "file". One wonders where any audio recordings, dispatch recordings, 911 call recordings or other media are any why Leslie and
Dogan did not provide them. Coughlin appeared at the WCPD's Office today and asked for the hard copy of his file, yet was told by front
desk receptionist "Paula" (of course, no last name provided) that she "spoke with an associate" and they told her that Jim Leslie had already
provided Coughlin his file and that he, therefore, would not be given the hard copy. "Paula" eventually seemed to have to admit that the
misleading use of the term "associate" actually did not connote her having spoken with an attorney about the matter...but rather Linda
Gray, whom has been curiously silent as to the apparent misconduct attendant to her admitting that she did not mail out any written notice
to Coughlin of the August 6th, 2012 "combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over that fact by sending
Coughlin a note about how he "saved the day" with his "advocacy"...skipping past the part about how the client, Coughlin, was not noticed
on the hearing in any matter, much less in writing....Leslie later refused to indicate with any specificity whatsoever how he "knew" Coughlin
had been noticed on the 8/6/12 hearing in writing...and RJC Judges are only too willing to "believe" Jim Leslie, Esq. when he explains away
vaguely such things...
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have continued in your way (similar to how you approached the
rcr2011-063341 case where Joe Goodnight, Esq. was counsel of record until you had him removed on 7/16/12, the morning of Trial...after
Mr. Goodnight and I have completed a video conference final trial preparation at 4:30 pm on Friday, July 13th, 2012 while I was in custody
(pursuant to an arrest on July 3rd, 2012, ordered by RPD Sargent Kim Bradshaw, she of the 1/12/12 custodial jaywalking arrest along with
RPD Sargent Paul Sifre)....Things fall through the cracks, Mr. Leslie, when you place a gag order on the associates you claim to supervise,
then stubbornly, petulantly, and retaliatorily refuse to work the cases you have snatched back from your associates....Similarly, WCPD
Fortier's email to me of February 6th, 2012 may have contributed to Mr. Dogan's confusion in failing to attend the Hearing on Feburary
13th, 2012, which begat my filing of February 21st, 2012, which begat Mr. Dogan's procurring the February 27th, 2012 Order for
Competency Evaluation, which begat the 5 day summary incarceration for summary/plenary/criminal/civil/transmogrified disciplinary
hearing on an ethics violation/what is jurisdiction? Order by RMC Judge Nash Holmes on 2/27/12 at 4:40 pm...which begat NG12-0434, and
probably 0435 (the SBN v. Coughlin SCR 105 Complaint of 8/23/12).
However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag order on you. Mr. Leslie sent this email today with a 56
page pdf file purporting to be my "file". I, as now a former client, have rights to "my file". I have requested my file in writing from your
office on numerous occasions, and given your removal as counsel of record on 11/22/12 (amazingly Mr. Dogan probably managed to say
200 words on a case that he had been counsel of record on for nearly a year, and had not managed to file a single document in that case,
RCR2012-065630, and had managed to get upset that a client would take issue with his missing the 2/13/12 Hearing, even though WCPD
Fortier's 2/6/12 email makes clear, the matter was assigned to Mr. Dogan at that point, and he had already sat down and discussed the case
with Coughlin for over one hour on or about February 8th, 2012, where Coughlin went to check in with Mary Watson, whom was then
represented by WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and demanded they breathalyze her client.
They did, she was taken into custody.
So, after sitting down with Dogan for at least an hour and discussing various things, some including matters related to the case he was then
attorney of record on RCR2012-065630, the February 13th, 2012 court date (Dogan and Coughlin have conflicting views as to what was
agreed upon and the applications of NRS 178.388).
NRS 178.388 provides that the defendant must be present at arraignment, trial, and sentencing and provides that the defendant may waive his appearance when certain conditions are met.
Its kind of odd how Judge Clifton (whose attached bio indicates he has deep and longstanding ties to the domestic violence industry
infrastructure) knew instantaneous to signing the Order for Competency Evaluation of 2/27/12 at 1:31 pm that the matter would be
randomly assigned to District Court Judge Steven Elliot (also a lifelong prosecutor with deep and longstanding ties to the domestic
violence industrial complex, and a member of the Committee to Aid Abused Women's (CAAW, one of the named defendants in the
wrongful termination lawsuit Coughlin brought and over which Judge Steven Elliot presided in CV11-01955, where he failed to point out his
per se conflict of interest to plaintiff Coughlin at any time, and where he ultimately pulled out just about every wrinkle in the insufficiency of
service and or process and or service of process (a movie showing a non party over 18 years of age serving a senior paralegal at Washoe
Legal Services, whose Executive Director Paul Elcano went to Stanford with Judge Elliot and the Panel Chair of Coughlin's 11/14/12 Formal
Disciplinary Hearing before the State Bar of Nevada, John Echeverria in the late 1960s...and Judge Elliot worked at John Echeverria's father's
law firm, Echeverria and Osborne Board of Directors, in addition to being a former ass
In CV11-01955, Coughlin sued his former employer Washoe Legal Services, whose Executive Director Paul Elcano went to Stanford in the
late 1960s with Judge Steven Elliot and John Echeverria, the Panel Chair of Coughlin's 11/14/12 Formal Disciplinary Hearing before the State
Bar of Nevada..and Judge Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne, and Judge Elliot served on the Board
for CAAW, and was a prosecutor as the Sparks City Attorney.
Also, Mr. Leslie, while the 56 page pdf you finally sent me (gosh, was it that hard to click "attach", load a 2 mb pdf file and hit "send" on an
email to me? No debatin', no arguing about whether Leslie and Dogan left the package at the desk, whether Dogan already gave it to
Coughlin, or whether Dogan then changed his story and said Leslie gave it to Coughlin, whether Coughlin already picked it up, no claims by
Jessica the Receptionist of anyone kickin' furniture...nothing like that, just a digitally verifiable means of ascertaining what you transmitted
and when...was that so hard? Heck, Jim, you could probably just email those ECOMM recordings too...and if attachment size is an issue,
sign up for a www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive functionality, and up to 100 mb
attachments via plan email, and over 25 free gb of storage on the Skydrive, etc., etc...). But its Leslie finally sent the 56 page "client's file"
on or about 12/7/12, yet he failed to include the insipid Motion of 11/26/12 by DDA Young (wherein, just after Judge Clifton finishes telling
Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even think about the other two RJC shotgunnin' style splatter paint
prosecutions by DDA Young, as "they are just not relevant to this proceeding"...and anytime Coughlin would point out specific basis for
undertaking a recusal or conflict analysis vis a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or the WCDA, Judge Clifton would
say "your're losing me...your're losing me..." as if Coughlin was speaking in tongues all the sudden...
So, while Coughlin is reportedly not even allowed to email DDA Young about cases not even before Judge Clifton, or something like
that...DDA Young is able to get an unnoticed, ex parte, emergency Motion to Prho
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: Jleslie@washoecounty.us
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response to your request. Please note that the July 27,
2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packet encloses a copy of the April 17, 2012, hand delivery transmittal of the very same
documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to retrieve them, we provide the attached courtesy
copy before final closure of our file.

No response to this transmittal is required from you.

James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defenders Office
Close
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.

--Forwarded Message Attachment--
Print
FW: misue of 911 case
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 10/11/12 2:34 PM
To: jrains@washoecounty.us; cfortier@washoecounty.us; jgoodnight@washoecounty.us; ltibbals@washoeconty.us; lgray@washoecounty.us
5 attachments
011412 RJC RCR2012-065630 RCR2011-063341 RCR2012-067980 Reno Police Department Sargent Paul Sifre arrests Reno Attorney for misuse of 911 second arrest in 2 days by Sifre of Attorney.3gp
(11.8 MB) , Mental Health Court mh-0032 contract coughlin rcr2012-065630 rcr2011-065630 5 5 2012.pdf (596.5 KB) , email to bdogan@washoecounty.us 4 11 2012 had the Sifre arrest video.htm
(262.5 KB) , PAUL SIFRE TransparentNevada 185k per year.htm (3.3 KB) , rcr2012-065630 4 19 12 letter from dogan with Complaint and discovery attached and Order for Competency evaluation
from 2 27 12 sifre schaur pthoa misue 911.pdf (3.6 MB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
From: zachcoughlin@hotmail.com
To: bdogan@washoecounty.us; jbosler@washoecounty.us; jleslie@washoecounty.us
Subject: misue of 911 case
Date: Thu, 20 Sep 2012 02:20:22 -0700
Mr. Dogan,

Oh, look at that, there is the MHC contract with Coughlin that fails to exclude the medication Coughlin was taking and which the MHC and Biondo cited as their rationale for
expelling Coughlin, libelling him, in fact. Not that old Jennifer Rains was going to advocate anything about that? I have no idea what the purpose of even having an
attorney there is? And Judge Elliot was really thrown for a loop when Biray mentioned a "social worker" on staff at the WCPD, in that transcript of the April 27th, 2011
Hearing that I finally gots my hands on.

I am curious to hear yoru theory of the case (whether the charge be resisting or obstructing arrest or whatever it was Young sought to amend the Complaint to (something more
in line with a '"erious crime" vis a vis a SCR 111(6) analysis, or if the charge remaisn misue of emergency services. Please provide me with any novel legal research you
culled for this case. Additionally, yoru were already provided these videos, but here they are again, videos of both arrests made or ordered by Sargent Sifre (who gets $185K
a year and about our age, Biray) within a 36 hour period of each other, with an intervening pullover by Officer Duralde and 5 other RPD personnel late at night after Coughlin
bonded out on the custodial arrest for jaywalking on January 12th, 2012.
Biray, some people might say that DDA Young has used you, the WCDA Office has used you, the RMC and Judge Nash Holmes have used you, and perhpas even that Mr.
Bosler and Mr. Leslie are using you. Maybe you like it. Maybe you like being used. Maybe you like being pushed around. Maybe you love it. Maybe that is
what you are good at.

Biray, please tell me how true any of the following strikes you as being:

SCR 111(6): "Definition of serious crime. The term serious crime means (1) a felony and (2) any crime less
than a felony a necessary element of which is, as determined by the statutory or common-law definition of the crime,
improper conduct as an attorney, interference with the administration of justice, false swearing, misrepresentation,
fraud, willful failure to file an income tax return, deceit, bribery, extortion, misappropriation, theft, or an
attempt or a conspiracy or solicitation of another to commit a serious crime.

Coughlin's WCPD, Biray Dogan, Esq. and DDA Young, in the RJC prosecution for "misuse of emergency services" (911
calls), when considering their lack of candor to the tribunal, fairness to opposing counsel (given Coughlin filed a
Notice of Appearance and has the right to represent himself, and is an attorney), DDAYoung's repeated instances of
violating NRS with respect to all matters being stayed upon an Order for Competency Evaluation being entered against
a party, such a Coughlin, and the failure of Dogan to alert Coughlin to, or provide any copy of (depsite Coughlin's
repeated written demands) the July 31st, 2012 Motion to Amend Complaint (that, upon Judge Sferrazza querrying DDA
Young as to whether the DA even needed seek an Order allowing it to so amend such a Complaint, responded that the DA
did not, but that he was just seeking one "for purposes of keeping the record 'clean'", whatever in the world that
means. When viewed with Dogan, Young and Leslie's attempts to shuffle Coughlin on through the MSC process (DDA Young
indicated, to Judge Sferrazza, on the record, while attempting to check of the MSC box minutes before the Start of
the August 29th, 2012 iPhone petty larceny Trial, that he anticipated the MSC "only taking a couple minutes, at most"
and felt it was Coughlin's "obstructionist" and "difficult" attitude of "non-compliance" that was preventing him from
effecting his stated goal. DDA Young clearly subscribes to the RPD Ron Rosa/Nick Duralde school of "How's that
runnin' for ya" style retaliation, intimidation, and misconduct.
Most troubling about Dogan and DDA Young's apparent conspiracy to get an Order for Competency Evaluation against
Coughlin during their clandestine MSC of 2/27/12 (which, again, Coughlin was noticed, in writing, had been continued
out to March 29th, 2012), including impermissible communications to the RMC and Judge Nash Holmes (who arguably
violated NRS by continuing on with the traffic Trial just minutes after being made aware of the 2/27/12 Order for
Competency Evaluation in the RJC by Dogan and, perhaps, by DDA Young as well, is Dogan's failure to inform Coughlin
of DDA Young's RPC 3.8 violating Motion to Amend Criminal Complaint, wherein DDA Young seeks to alter the charge to
one that would invoke a mandatory SCR 111 Petition in light of SCR 111(6)'s definition of a "serious crime" and the
"statutory or common law definition" of the crime for which DDA Young, though lacking "probable cause" sufficient to
satisfy his RPC 3.8 duty, sought to have so amended to an "obstructing or resisting a public officer" charge, which
of course fits squarely in the "serious crime" definition set forth in SCR 111(6). So, no, Judge Sferrazza, Coughlin
was not "over-lawyering it" on August 29th, 2012 during the "only take a minute at most" MSC Dogan and DDA Young (and
Leslie) sought to slip past Judge Sferrazza right before the big iPhone petty larceny trial that may well decide
whether Coughlin can ever practice law again (including as a patent attorney before the USPTO). Coughlin, on the
record, risked going to jail when he indicated that what Dogan has just said with respect to whether Coughlin
objected to the State's so amending the Complaint was not what Coughlin had indicated to his counsel, in RCR2012-
065630 from a gross misdemeanor "misuse of 911" charge to a misdemeanor "obstructing and resisting a public officer
charge". Coughlin responded to Judge Sferrazza's incredulity at his objecting to amending to a lesser charge
(Coughlin indicated doing so, however counter-intuitive, "may somehow inure" to his benefit), then Judge Sferrazza
indicated Coughlin "definitely" was "over-lawyering it"...but then Peter J. went Peter J., likely sensing an attempt
to pull the wool over one's eyes, and because "game recognize game, real recognize real"...Judge Sferrazza decided to
not countenance Dogan and Young attempts to lead the RJC and Coughlin blindly (and in a MSC that "should only last a
minute or two at most" per DDA Young) through their tired, tacky, hackneyed, sordid little plan. There is a reason
Judge Sferrazza is often mentioned as the best of all the fine RJC Judges by long time local attorneys. Dogan and
Young, despite being well aware of the September 5th, 2012 Order for Competency Evaluation still have failed to
vacate the Motion Hearing set for October 2nd, 2012 in that regard.

Maybe old Zach Young gonna give his buddy Biray Dogan a job picking up his dry cleaning or somethin' when Dogan's get
disbarred on account of the primrose path he got led on down by ol' nice ol' Zach Young, whom is the "nice" and
"fair" one compared to Halstead and...remember saying that B-Town? He nicin' you into bar grievances and sticky
wickets a plenty.
Loading video preview from YouTube
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Dear Mr. Bosler,
Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tacky commentary on my suit and tie ("so, are you workin'
construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts at humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after
admittedly muzzling Joe Goodnight, who I respected at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open
Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary regarding Ms. Halstead was especially troubling. I am
formally forbidding anyone with the WCPD from speaking with anyone with the Reno Municipal Court or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open
court under a search incident to arrest following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent attempt to protect
Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions of bribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a
pathetic criminal trespass arrest in the context of a civil eviction proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was
attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of NRS 118A.460.
RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and utter lack of documentation in these files setting forth any
reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever
conducted. Further, Mr. Goodnight, the file int he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date vacated,
and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnight constantly quote me the "basis in fact and law" language in NRCP Rule 11
when explaining their complete failure and refusal to do anything I ask be done in my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is
inapplicable in a criminal setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for continuing to prosecute this pathetic
gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the
arresting RPD Sargent Sifre admitting he was engaging in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations where
they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively rebuked such involvement by Sargent Thew. About six weeks
later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation
by someone other than Coughlin, who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.
The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a retaliatory competency evaluation after Coughlin reported and
criticized Dogan's failure to appear for a court date:
http://www.youtube.com/watch?v=oU3t_kRR0RA
The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:
http://www.youtube.com/watch?v=gBu9zflGALE
Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses. Amazingly, you have disclosed a "Colton Templeton" while
refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer
Kevorkian" approach needs to cease, Mr. Goodnight.
The Arrest:
http://www.youtube.com/watch?v=5PR7q4OI5b0
Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:
http://www.youtube.com/watch?v=to_UOFIccLw
Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.
Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was sought, after a "hearing" for BOTH of the competency evaluations
I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held, however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an
Order for Competency Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's Crossing and the WCPD, and an illegal
tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note
attempting to describe my first trip down to Lake's Crossing. I wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much
your office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so, given how weak Goodnight and Hylin's rationale was for
seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed
out to Goodnight how very intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, then to divulge client confidences in
open court over the remonstrances of the client.
Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's Crossing evaluator if I have a "private attorney". Further, she
indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator if I utilize the services of the WCPD.
Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications in violation of the duty of confidentiality attendant to the
attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practice of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based
upon "hunches" and the DPD's "duty to the court" is rather suspect.
Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff Reyes was attempting to prevent Coughlin from standing
near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions
himself all over the RMC And RJC Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he alternates with a shingle
eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G.
Hill, Esq. was extremely successful in getting a protection order from Judge Schroeder of the RJC, in a scant 40 minutes from the time he filed it no less (and that application contained perjury by Hill that was
subsequently unveiled at the hearing on Hill's Motion for Order to Show Cause before Judge Flanagan on 3/23/12), Coughlin was not so successful in getting a Protection Order against Bailiff Reyes. While Hill's
protection order application contained only unsupported hearsay, and some nonsense about climbing on a truck (which was thoroughly discredited at the 3/23/12 Hearing in D7), Coughlin's TPO application against
Bailiff Reyes actually set forth a threat of sexual assault, yet Coughlin did not even get a hearing on the matter and now Bailiff Reyes has amped up his misbehavior. This, in combination with RJC civil office counter
clerk Christine Erickson brazen refusal to file various exigent Motion's and Notices of Appeal and other landlord tenant based filings submitted by Coughlin, despite Coughlin providing the RJC with support for his
contention that such refusals are clearly in violation of established Nevada law and contribute to substantial losses to Coughlin personally and professionaly. Most ironic of all, Bailiff Reyes, recently, explained to RJC
Court Administrator Tuttle in Coughlin's presence at the RJC civil division filing office that Reyes "does not think it is appropriate" for Coughlin to have any communications with RJC civil division filing office staff of
anything other than the most brief and sterile nature. Apparently Bailiff Reyes finds telling Coughlin, under color of law, and for no legitimate reason, that he will "put my foot up your ass", while, curiously Bailiff
Reyes somehow finds Coughlin's sayign "hello" and "how was your weekend" to filing office staff to be "inappropriate".
Further, Richard G. HIll, Esq. threatened Coughlin at the 12/20/11 Hearing on Coughlin's Motion to Release Personal Property (where Coughlin as charged the outrageous sum of $30 per day "storage" and forced to pay
a lien for the contents of his former law office after Richard G. Hill, Esq.'s negligence cause it to be burglarized on December 12, 2011, something for which Hill now seeks to have Coughlin pay for in his ridiculous
Memorandum of Costs on appeal in D7 in CV11-03628) when Hill exclaimed to Coughlin, in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also made threatening commentary to Coughlin on multiple occasions
seeking to prevent Coughlin from filing documents with the RJC incident to exigent eviction matters) that Hill, too, "would like to stick something up Coughlin's ass". Hill said this in a loud voice approximately 20
feet from Coughlin, with Bailiff Reyes and Chief Bailiff Sexton standing near Hill, all three gentlemen sharing a good laugh, during a recess, but while in the courtroom, in RJC Rev201-001708's 12/20/11 Hearing. Judge
Sferrazza was informed of this on the record. Please place a copy of this formal complaint in both Deputy Reyes and Chief Deputy Sexton's employment and personnel files.
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
There was a problem connecting to YouTube. This video may not exist or it may only play on YouTube. Try going to their website: http://www.youtube.com/watch?v=5PR7q4OI5b0
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Dear Mr. Bosler,
Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tacky commentary on my suit and tie ("so, are you workin'
construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts at humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after
admittedly muzzling Joe Goodnight, who I respected at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open
Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary regarding Ms. Halstead was especially troubling. I am
formally forbidding anyone with the WCPD from speaking with anyone with the Reno Municipal Court or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open
court under a search incident to arrest following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent attempt to protect
Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions of bribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a
pathetic criminal trespass arrest in the context of a civil eviction proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was
attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of NRS 118A.460.
RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and utter lack of documentation in these files setting forth any
reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever
conducted. Further, Mr. Goodnight, the file int he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date vacated,
and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnight constantly quote me the "basis in fact and law" language in NRCP Rule 11
when explaining their complete failure and refusal to do anything I ask be done in my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is
inapplicable in a criminal setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for continuing to prosecute this pathetic
gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the
arresting RPD Sargent Sifre admitting he was engaging in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations where
they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively rebuked such involvement by Sargent Thew. About six weeks
later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation
by someone other than Coughlin, who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.
The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a retaliatory competency evaluation after Coughlin reported and
criticized Dogan's failure to appear for a court date:
http://www.youtube.com/watch?v=oU3t_kRR0RA
The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:
http://www.youtube.com/watch?v=gBu9zflGALE
Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses. Amazingly, you have disclosed a "Colton Templeton" while
refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer
Kevorkian" approach needs to cease, Mr. Goodnight.
The Arrest:
http://www.youtube.com/watch?v=5PR7q4OI5b0
Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:
http://www.youtube.com/watch?v=to_UOFIccLw
Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.
Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was sought, after a "hearing" for BOTH of the competency evaluations
I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held, however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an
Order for Competency Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's Crossing and the WCPD, and an illegal
tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note
attempting to describe my first trip down to Lake's Crossing. I wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much
your office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so, given how weak Goodnight and Hylin's rationale was for
seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed
out to Goodnight how very intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, then to divulge client confidences in
open court over the remonstrances of the client.
Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's Crossing evaluator if I have a "private attorney". Further, she
indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator if I utilize the services of the WCPD.
Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications in violation of the duty of confidentiality attendant to the
attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practice of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based
upon "hunches" and the DPD's "duty to the court" is rather suspect.
Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff Reyes was attempting to prevent Coughlin from standing
near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions
himself all over the RMC And RJC Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he alternates with a shingle
eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G.
Hill, Esq. was extremely successful in getting a protection order from Judge Schroeder of the RJC, in a scant 40 minutes from the time he filed it no less (and that application contained perjury by Hill that was
subsequently unveiled at the hearing on Hill's Motion for Order to Show Cause before Judge Flanagan on 3/23/12), Coughlin was not so successful in getting a Protection Order against Bailiff Reyes. While Hill's
protection order application contained only unsupported hearsay, and some nonsense about climbing on a truck (which was thoroughly discredited at the 3/23/12 Hearing in D7), Coughlin's TPO application against
Bailiff Reyes actually set forth a threat of sexual assault, yet Coughlin did not even get a hearing on the matter and now Bailiff Reyes has amped up his misbehavior. This, in combination with RJC civil office counter
clerk Christine Erickson brazen refusal to file various exigent Motion's and Notices of Appeal and other landlord tenant based filings submitted by Coughlin, despite Coughlin providing the RJC with support for his
contention that such refusals are clearly in violation of established Nevada law and contribute to substantial losses to Coughlin personally and professionaly. Most ironic of all, Bailiff Reyes, recently, explained to RJC
Court Administrator Tuttle in Coughlin's presence at the RJC civil division filing office that Reyes "does not think it is appropriate" for Coughlin to have any communications with RJC civil division filing office staff of
anything other than the most brief and sterile nature. Apparently Bailiff Reyes finds telling Coughlin, under color of law, and for no legitimate reason, that he will "put my foot up your ass", while, curiously Bailiff
Reyes somehow finds Coughlin's sayign "hello" and "how was your weekend" to filing office staff to be "inappropriate".
Further, Richard G. HIll, Esq. threatened Coughlin at the 12/20/11 Hearing on Coughlin's Motion to Release Personal Property (where Coughlin as charged the outrageous sum of $30 per day "storage" and forced to pay
a lien for the contents of his former law office after Richard G. Hill, Esq.'s negligence cause it to be burglarized on December 12, 2011, something for which Hill now seeks to have Coughlin pay for in his ridiculous
Memorandum of Costs on appeal in D7 in CV11-03628) when Hill exclaimed to Coughlin, in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also made threatening commentary to Coughlin on multiple occasions
seeking to prevent Coughlin from filing documents with the RJC incident to exigent eviction matters) that Hill, too, "would like to stick something up Coughlin's ass". Hill said this in a loud voice approximately 20
feet from Coughlin, with Bailiff Reyes and Chief Bailiff Sexton standing near Hill, all three gentlemen sharing a good laugh, during a recess, but while in the courtroom, in RJC Rev201-001708's 12/20/11 Hearing. Judge
Sferrazza was informed of this on the record. Please place a copy of this formal complaint in both Deputy Reyes and Chief Deputy Sexton's employment and personnel files.
Sincerely,
your office refused what I tried to deliver it yesterday
DDA Young retaliatory prosecution of domestic violence victim
Position
Reno
Year 2011
Base Pay $94,927.67
Overtime and
Callback Collected
$11,088.45
Other Pay $19,378.03
Total Pay $125,394.15
Benefits Accumulated $60,068.55
Total Pay & Benefits $185,462.70
State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
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TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
Sent: Thu 12/06/12 1:26 PM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); ramoss@reno.gov (ramoss@reno.gov)
plus i am being hassled by courthouse security, which implies that your "no faxing" ex parte Order (which i still have not been supplied a copy of the
Motion thereto despite express written requests to the wCPd and the RJC filing office) was meant to create just such a situation. I am forced to copy you on the
file stamped 12 5 12 filing given these circumstances.
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.
12 5 12 065630 refiled from 11 27 12 with new addition to ex 1OPPOSITION TO MOTION TO AMEND, OR ALTERNATIVELY, MOTION FOR RECONSIDERATION OF.pdf

Sent: Thu 12/06/12 1:05 PM
To: ramoss@reno.gov (ramoss@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
I need help. DDA Young is support the "blame the victim" approach of the RPD, which conveniently enables their Soldal v. Cook County misconduct as well...
Bailiffs detaining me, violating courthouse sanctuary doctrine, physically restraining me, and preventing access to filing office
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
fv12-00187 allaback tpo application minutes and order and ronjones@nvenergy.com emails.pdf
SAM_0204 RPD SIFRE MISUSE OF 911 ARREST 1 14 12 JACKSON MISSING DOG_00009.mp4
SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
RPD 12-974 065630.WMA
rcr2012-065630 4 19 12 letter from dogan with Complaint and discovery attached and Order for Competency evaluation rpd sifre thew dogan weaver wcso rmc from 2 27 12 sifre schaur pthoa m.pdf
Download all

Sent: Thu 12/06/12 12:39 PM
To: stuttle@washoecounty.us (stuttle@washoecounty.us); roperj@reno.gov (roperj@reno.gov)
Dear Mr. Tuttle and Chief Roper,
This Monday, Bailiff Reyes physically pushed me in my abdomen with his right arm in the DAS office, and purported to be detaining me for the purpose
of violating courthouse sanctuary doctrine (as Bailiff Plamondon did on November 3, 2011 in Rev2011-001708 in purporting to be serving an Order by
you, though it bared nothing more than a rubber stamping of your name...regardless, it doesn't match up with the December 17th, and 18th, unsworn
statements by Jocelyn Jonas and Karen Stancil and Jonas's unnoticed "testimony on December 20th, 2011 respecting my alleged "refusal to allow the RJC
to set" the hearing that I showed up for and checked in with Chief Bailiff Sexton on November 22nd, 2011 in REv2011-001708.)
Regardless, this is a formal Complaint against Bailiff Reyes who continues to harass me constantly, under your negligent hiring, training and
supervision. Bailiff Anthony Enlgish denied me access to the filing office on Tuesday of this week as well when I presented prior to the door closing or
locking, then he indicted he was going into the filing office to seek clarification as to the legitimacy of his doing so (the week prior he made a threatening
statement to me about how I "certainly have a way about (you)" in an indication that I had been upsetting various RJC Judges and Staff in my attempts to
defend myself against the retaliatory prosecutions and landlord tenants matters I am a party to in the RJC and RMC. Please place a copy of this
Complaint in both of their employment files. Yesterday, for the second time this week, RMC Marshal Menzel followed me over to the RJC Filing
Office and then up and down from the WCDA's Office. The Courthouse Security worked who is a brunette female (on approximately July 17th, 2011
she threatened me in the District Court, telling me "you better watch your step" in relation to my attempting to access the filing office).
Courthouse security and the RJC Bailiffs have an obvious system of signalling in place that seeks to have a Bailiff close the RJC FIling office door prior
to 5 pm should I enter the building close in time thereto. This creates and appearance of impropriety.
Please place a copy of this formal written complaint in all four of these individual's personnel files.
your email was unreadable
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Wed 12/05/12 4:05 PM
To: Dilworth@reno.gov (dilworth@reno.gov); ncjdinfo@judicial.state.nv.us (ncjdinfo@judicial.state.nv.us)
Dear Judge Dilworth,
I could not read your email of 3:38 pm. It seems you sent it shortly after this though:
From: Voxox (noreply@voxox.com) This sender is in your safe list.
Sent: Wed 12/05/12 3:24 PM
Hi zachcoughlin,
Your Fax was successfully sent to 3d2eb020-3ed4-44c2-a744-504ffb688076general693298 ( 17756873607).
Your Fax was delivered @ 11:24:52 PM on 2012-12-05.
xoxo,
The Voxox Team
This message was intended for zachcoughlin@hotmail.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.
And the contents of what was sent in that, and the proximity of your response, well..
But if your email was sent at 3:38 pm, and my fax was sent marked "successfully sent" by me at 3:24 pm, and add to that the following:
"
Submission of multiple Judicial Discipline Commission Complaints
Sent: Wed 12/05/12 3:33 PM
To: ncjdinfo@judicial.state.nv.us (ncjdinfo@judicial.state.nv.us)
Dear Commission,
Please see attached. I think "page 16" (the nvbar.org contact page for Panel Chair
Echeverria with my comments) may be missing my comments on the "first fax" version I
actually faxed to the Commission. Out of respect for the Commission, and due to my
indigency and the terrible raping I have sustained this year at the hands of a rogue
collective of Judges, I cannot afford to print or mail the 1,000 attachment or the
cd/dvds/digital media linked to in my complaints, and I am hesistant to burden the
Commission's fax machine without herein first provide warning of an impending fax of
substantial length and opportunity for the Commission to assent to acceptance of service
thereof electronically, by email and links to my Skydrive's and the video that someone
has posted on youtube.com
Respectfully Submitted,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
first fax judicial discipline commission complaints...
judicial discipline commission complaints ...
"...
Well, it just kind of has a certain appearance to it...When viewed in the context of the
RMC and RJC recently claiming to have lost or not received multiple cd/dvd attachments
to filings by myself, and the RMC's failure in 11 cr 26405, to include such materials or the
11/2/12 filing in RMC 11 CR 26405 into what was transmitted on to the District Court on
11/30/12 or so....
Sincerely,
Zach Coughlin
formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing from what was produced by City
Attorney Skau
.
Sent: Tue 12/04/12 2:07 PM
To: HomerJ@reno.gov (homerj@reno.gov); skauc@reno.gov (skauc@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); complaints@nvbar.org (complaints@nvbar.org);
patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); rosec@nvbar.org
(rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); philp@nvbar.org (philp@nvbar.org); glennm@nvbar.org (glennm@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org); bdogan@washoecounty.us
(bdogan@washoecounty.us); jleslie@washoecounty.us (jleslie@washoecounty.us)
12 attachments
CR11-2064-2676094 (Opposition to Motion to Dismiss CR11-2064-2676094.pdf).pdf (167.7 KB) , 11 7 12 subpoenas 063341 gricela alvarez and hassett proof of service or waivers.pdf
(10.4 MB) , CR11-2064 MOTION FOR EXTENSION OF TIME (Mtn for Extension of Time).pdf (132.1 KB) , CR11-2064-2655401 (Mtn to Dismiss ...).pdf (117.4 KB) , CR11-2064-
2676094 (Exhibit 2).pdf (133.6 KB) , CR11-2064-2676094 (Exhibit 3).pdf (48.0 KB) , 111912coughlin4.wmv (298.2 KB) , 111912coughlin6.wmv (3.6 MB) , 11 27 12 11 29 12 and 12 3 12
emails to psferrazza@washoecounty.us and zyoung@da.washoecountys.us in response to Order to submit materials regarding Leslie's ineffective assistance 063341 0204.htm (245.1 KB) ,
11 8 12 Homer email and 11 9 12 Skau email 063341 0204.htm (121.3 KB) , 6 7 12 60838 Order temporarily suspended Coughlin's law license scr 111 0204 12-17976.pdf (198.3 KB) , 12 1
30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs attachment.pdf (327.9 KB)
Dear Office of Bar Counsel,
This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
Cc: Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you purportedly served, so
you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set
forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th
St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently
not there. Today, Reno Carson Messanger Service again attempted to serve you there at around 11:00 a.m. They called my
office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me
with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that
address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick
up at our Office, third floor of City Hall.
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted
mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to
serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a photograph
of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau fraudulently procurred Couglin's attendance at
the 11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only
Coughlin's formal disciplinary hearing but also the petty larceny trial of 11/19 and 11/20 and is a straight scum bag move by Creig Skau.
Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the JAVS audio transwcript of the 10/22/12
Hearing in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he fails to inform the court
of the waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez (whom, somehow, Judge Sferrazza was apparently aware of and had opinions on....curiously).
Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341 (really, everything Jim Leslie did in this case or
any other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is dragging his feet, your honor...He's wasting county assets."...Really, Jim, this is a
grievance against you for seeking to coerce a waiver of Coughlin's fifth amendment rights incident to your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression
Hearing or the Trial..and a greivance against DDA Young for similarly coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the first for 11/20
to get an idea of the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep Coughlin's laptops over night...but there is some really bad
audio on there with Judge Sferrazza and DDA Young getting completely coercive with respect to a waiver of Coughlin's Fifth Amendment rights and "you can't put on anything else or any evidence,
YOU NEED TO TESTIFY!" and Young "you Honor, it was my understanding that you let mr. Coughlin out of custody on the condition that he testify! If he won't do it TAKE HIM BACK INTO
CUSTODY!"
add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive any reports from dispatch of "a possible
fight" where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and therefore, such allegations of a report from dispatch of "a possible fight" did not
bare on Duralde's probable cause/reasonable suspicion analysis. further young put on perured testimony by Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when
Young was provide a video wherein Zarate admits he only inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant
Tibbals or anyone with the WCPD.
And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon arriving...yet, every bit of video evidence and or
testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to hearing "the man with the six pack" threaten to throw the iPhone "in the river if someone doesn't claim it
right now" was continually excluded as "hearsay"....
A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):
Dear Judge Sferrazza and DDA Young,
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr.
Leslie's representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot receive
from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to Leslie's failure to utilize any of the
work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of 11:27:11 pm
reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the
Dispatch recordings (and those provided by City Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid of anything for
the 6 minutes in which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which required production
of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main justification for the pat down
and search incident to arrest and led to a justification for not excluding anything "discerned incident to the pat down"...the only problem is is that Duralde and Rosa already are marked as on the scene
by 11:26:00 pm, and therefore could not have read the text screens in their vehicles to recieved the text only 11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to
which Coughlin's 911 call is not reported accurately at all further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge Sferrazza ordering him to produce in
response to my subpoena duces tecum to Kelley Odom and ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two
of the 911 calls are missing. There is no audio of any RPD-ECOMM/Dispatch communications between the 11:28:17 pm mark and the 11:36:27 pm
mark...which is disturbing, considering the RPD and Ecomm did not know I was filming/recording the arrest. Had I not captured a recording of the
arrest, how little would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many things revealed by the arrest recording
contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further, where Zarate does not
allege to have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on 8/29/12 does testify to seeing the phone light up
in Coughlin's pocket...but wait...yeah, that's it...he saw it light up from all the way across the skate park...but wait...come November 19th, 2012 he changes
his story and decides he saw it light up from "2 to 3 feet away from Coughlin"....There a movie floating around somewhere out there that does a timeline
of all these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
And one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the
pat-down search of the Defendant was proper under the totality of the circumstances. Prior to arriving, Officer Duralde learned that the scene involved a
loud disturbance with possible fight, thereby immediately raising the concern of weapons and the safety of all those present." And, of course, Officer
Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and sang the "possible fight...report from dispatch of a possible fight"
tune all the live long day...which was the basis for the reasonable suspicion for the pat-down (and Judge Sferrazza did change his Suppression Motion
Ruling at the Trial somewhat...altering it to make less obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in
the Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson admitting to hearing the "man with a six pack
threaten to throw the iPhone into the river" capture on video and audio recordings into the record...despite Duralde testifying to a multitude of double
hearsay (and not even capture on a recording so close in time to the arrest and at the very same location, involving the majority of the players in the arrest
itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed on"
date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in
support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney whom dared to answer one of the officer's questions by asking a question
seeking clarification as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the
Officer's did not receive the text from dispatch reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year old
Austin Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to
RPD rcr.3gp 46 seconds in length) lying in asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition to Goodnights 2/14/12 Motion to Suppress, both
Goble, Lichty, and Zarate all have motivations apparent which preclude them from being deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted to in his testimony
at trial to being aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and double hearsay Duralde testified to at trial after "refreshing his recollection" upon a review of
either his "Supplemental Declaration" (an attachment to the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the question....how was it not misconduct by the
State and prejudicial to the point of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to (the password for the phone)...and when Goble alleges Duralde gave him back the
phone...and the call into the iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for the State and the RPD here is that two hostile witnesses (in addition to Coughlin's various statements related thereto, during his
testimony and on the media admitted into evidence) testified that RPD Officer Duralde committed misconduct by lying about the purported order or
point in time in relation to the arrest and search of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde
removed the phone from Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask question related to the phone
and to verify ownership of the phone (which would include gathering the phone number for the iPhone, which necessarily would mean that Duralde's
allegation of only searching Coughlin after performing some call to the iPhone and hearsaying it vibrate (even though multiple witness (Templeton,
Zarate, Goble, Lichty testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all) Goble testified that Duralde already had
the iPhone prior to Goble conferring with Duralde or otherwise giving Duralde any phone number to call in an attempt to verify the phone revealing an
incoming call LED display scree light up alert (Goble's statements that the phone would "light up" and that he, as Duralde quotes him in the Narrative,
"could not hear the phone
I have 30 days from the date of conviction to report a conviction to the State Bar of Nevada and the United States Patent and Trademark Office (USPTO)
for these two convictions "possessing or receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney of record for me on this cases RCR2011-063341, had served (see attached) a subpoena on ECOMM and
Kelley Odom on 10/03/12. Given that Mr. Leslie was not relieved as my counsel until at the earliest 10/22/12 (so Judge Sferrazza's contention that
Coughlin "has had forever to get his defense ready in this case" and that "no continuance will be granted on account of the formal disciplinary hearing
before the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge Sferrazza
indicated some canon preventing him from testifying at the formal disciplinary proceeding...that didn't stop 063341 being specifically pled in the SBN
NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the SBN Coughlin's
2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally released them o October
30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his formal
disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on 11/14/12
after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point is,
if the RJC and both of you want to be associate with a Schaeffer style Mirch-ing, then this may be your chance. But you won't be able to say you
didn't have plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure to turn over anything
to me in the "hand off transmittal" he insisted upon (despite a digital transmission being required per the Order of Judge Sferrazza, I believe) requires
some explanation.
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith attempt to comply with Judge Sferrazza
ordering him to comply with the subpoena duces tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it of
8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin Lichty's cellular phone, 775 233 8593, which
Goble is seen in the attached still frame picture culled from a video Coughlin took of the moments prior to the arrival of the RPD, being handed by the
"man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton testifying that they do not know that man and did
not know him prior to that night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of the
"man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to
steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in
the attached still frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two 911
calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls for Service
Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number (belonging to
Austin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law license away from me for at least 5 years, if
not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in the middle of the ice rink plaza downtown on 8/20/11
at 11:20 pm ish in Reno, "man with a six pack of beer" picks it up, offers it up, receiving no response threatens to "throw it in the river if someone
doesn't claim it immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's Narrative of unknown origin date") told
Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in his Narrative)
contain the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde
indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the video Coughlin filmed of the arrest, title:

Then, Officer Rosa is proven to be on the bridge and not in his squad car reading texts from dispatch n the following time stamped file: "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396
on the other end"
Further, Officer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of
printing" variations...).
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc of phone susps os left on post lighting up in sups pock RP screaming at susp
2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone just socked a minor, waive that cop down 10 10 with open line
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the Ecomm
recordings and dispatch logs...
1. VID_20110820_232413 your all on tape now goble and friends.3gp 8 seconds long
2. VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID_20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records for the iPhone reveal only four calls occurred in or out during the relevant time frame:
Goble's AT&T records:
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..." Previous to that, DDA Young had successfully kept every single witness from specifically
identifying who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh, that's Colton" 8 feet
from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the misconduct of a prosecution witness....Goble, batterying Coughlin with a lit cigarette, that
Coughlin capture on tape, on June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later by a 3
Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look at the
circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a Trial before
Judge Linda Gardner in a divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues printing it out and bringing it with me (my
legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence exclusively hearsay testimony (often unattributed to anyone in particular) to support his win on the "sufficient probable cause to support a search incident to arrest"
despite NRS 171.136 forbidding such an arrest (where Duralde obviously overcharged the alleged crime as a "felony grand larceny"...even making smug commentary about the "certain benefits of charging this as a felony" and saying "oooh, that's a felony", both
matters that Leslie insisted refraining from getting into while he was attorney of record, and further, despite Coughlin complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail for Duralde) Coughlin was
denied the right to cross examine the arresting officer...which is too bad considering his Narrative alternately claims that Goble told him they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation of NRS 205.275, a misdemeanor, in the manner following, to wit:
That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully possess or withhold stolen goods having a value less than Two Hundred Fifty Dollars ($250.00), to
wit: an iPhone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, for his own gain or to prevent the true owner from again possessing said property, knowing that the property was obtained by means
of larceny or under such circumstances as should have caused a reasonable man to know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574. Must allege the good were received from someone other than the defendant: Gaddis, 424 U.S.
544, Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the robbery
proceeds in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff in error, a...The next assignment of error is that the State failed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show (1)
that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one charged with receiving it has actually received the property stolen or aided in
concealing it; (3) that the receiver knew the property was stolen at the time he received it and (4) that he received the property for his own gain or to prevent the owner from possessing it. (People v.
Piszczek,404 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN.
407 Ill. 596 (1950). 96 N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that if a criminal conviction is to be upheld,
[ 21 Ill. App.3d 980 ]
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327 (1946)), and must contain the nature and elements of the offense in order that the
defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this omission,
creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from himself, the fact that
the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v.
Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the
offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does not
create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances that
would reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question (in any
manner whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it is
not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the offense
of theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property soon after a
theft is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the necessary elements
of the offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of these words would only be grammatically redundant and mere
surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the defendant guilty beyond a reasonable doubt. For this reason I, too, would
reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in "larceny" and "theft" cases. He erroneously urges that the state failed to meet that
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the time
and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot receive
from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4 Cal.App.2d 214, 40
P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States,
418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and later acknowledged by the court
to be such when it set aside the receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner of handling the error effectively cured it. The error was not cured
by the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant guilty of burglary, Count 2, or receiving, Count 3.
Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element of the crime of receiving stolen goods..17. Criminal Law. In prosecution for
receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again possessing
property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession thereof. Comp.
Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for possession of
stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish probable cause that
she had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the proof did not show that she knew the property was stolen and that such knowledge cannot be inferred from mere possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a conviction for possessing stolen property on the ground that the legislature did
not intend to compound the punishment for larceny or robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property. Point v. State,
102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests with
the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see Gilman
275 V. Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378.
triem 929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb,
838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following two timestamped recordings finally provided by City Attorney Skau (WCPD Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet" incident to the
inappropriat placement by Judge Sferrazza of Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of
avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a
"rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge
Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon Judge Sferrazza . You are to his constituency by remixing is previous order regardless of the extent
to which Coughlin was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they are and where only those aspects of a summary proceeding that in year to the
landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to bring counterclaims were matters Coughlin was
precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in
violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings
Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of
that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public defender applying good nicely peers
deciding that the night was doing too much to assist Coughlin in defending himself and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy session while Coughlin was in
custody on July Friday, July 13 at approximately 430 man and you good night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial on July 16, 2012 Monday morning
at 9 AM and it was only upon Coughlin arriving and being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file
stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and
through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or
photograph any written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of the State, the existence of which is known or by
the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including those preserved on pocket recording devices, 9-1-1
emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling the extent to which on the record at that July 16 trial date Washoe County public defender
Jeremy Bosler indicated that Jim Leslie would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And that Leslie would be prepared to try the case by Friday and that the
court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have completed all the trial prep Jim Leslie would be doing on this case by Friday,
and that that would be the case whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim Leslie felt that the
judges of the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr. Leslie has any skin in this game whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing disregard for the
rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe County District Attorney's Office and therein secure added boys from local law enforcement District
Attorney's Office and perhaps the Reno justice court itself. Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders office in connection with
February 27, 2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted whether they they have been sworn prior thereto or not an especially where
Dogan's coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the confiscation without a search warrant or court order of any kind (or at least one ever served on Coughlin in
any manner) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young
on February 27, 2012 in RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict between that traffic citation trial in the Reno Muni
court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno employees of and admission to taking
bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on
November 13, 2011. That criminal trespass conviction has now become the subject of a Nevada Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of
the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that judge Sferrazza presided over wherein judge Sferrazza purportedly controlled the
civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December 26 submitted for filing December 26, 2011 was not file stamped by the civil division staff of the Reno justice
court. This impropriety is further problematic where Coughlin had served upon the Reno justice court's custodian of records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012
letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar of Nevada, which ultimately became one of the three grievances depicted
numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State Bar stamped August 23, 2012 (in addition to the NG 12 0434 grievance by judge Nash Holmes incident
to the February 27, 2012 trial in 11 TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being
held with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at
Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD
Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or her partner officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial
arrest on that day in where Lopez also admits none of those individuals or anyone present that day identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about
5 feet high underneath the former home law office wherein Coughlin was found at a time when Coughlin still had not receive back from the Reno justice court the impermissible $2275 rent escrow deposit judge
Sferrazza ordered in violation of Nevada law considering judge Sferrazza's admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was correct and his assertion that the
Reno justice court had no then corollary to Las Vegas justice court rule 44 that may support the secret quote house rules been fact in the civil division of the Reno justice court wherein tenants were in summary
eviction matters were subject to forced rent escrow deposit in violation of justice court rules civil procedure 83 and that the Reno justice court had neither published nor had approved by the Nevada Supreme Court
any sort of corollary to justice court rule Las Vegas rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the Washoe County Sheriff's office
deputy Machen filed a false affidavit on November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of
Law, and Order of Summary Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact
that his sister judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the "Clerk of Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
sanctioning Coughlin incident to a divorce matter where and he was representing a victim of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former prosecutor judge
Linda Gardner in comparison to the extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy district attorney Young's repeated malfeasance misconduct
violations stays pending competency or evaluations failure to turn over exculpatory materials failure to propound discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in
conjunction with scattershot three, count them three prosecutions of Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young
amended the criminal complaint from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the
January 14, 2012 arrest in the matter to a charge that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort to achieve a plea-bargain and resolve what is a messy case
the city of Reno Police Department and emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-000375 run the rental at which the domestic violence resulted in
Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against
Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false
statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of
summary eviction matter in 1708 Barber which judge Sferrazza presided and which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee award
against Pro per appellant Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's
office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was
assigned to Coughlin appeal of the petty larceny conviction of a candy bar and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license
incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a misdemeanor
(much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying at the petty
larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar and some cough
drops in connection with Coughlin's selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that Walmart alleges to have
had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and where French you admit that his supervisors had previously
indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning some of Walmarts policies and where John Ellis of the W. 7th St., Walmart in any as yet unknown loss prevention
associate specifically and expressly threatening abuse of process against Coughlin on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and customer service
managers many of whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from the policy which Walmart holds out to the
public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the convenient for getting in
misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 affected a citizen"s arrest of Coughlin on that
date in connection with the alleged petty larceny by Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days after Coughlin filed a written complaint detailing
the police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20, 2011 in 063341 a justice court criminal petty larceny and
receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American jurisprudence that one cannot be charged with both petty larceny and receiving stolen property of
the same item particularly where the receiving of the item is alleged to have been from oneself after one had larceny is the item lending an inference that Joe Sferrazza seeking to sink his jurisdictional hucksters
deeply into Coughlin's light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in connection with its numerous since is violating about law respecting the manner in
which evictions are carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory arrest and prosecution of Coughlin where the judiciary in Washoe County is off criticizes
being overly influenced by the District Attorney's Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of
law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed defender there despite
his express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin
established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing
the November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion of the hearing which are trial which judge Howard down such a matter of public concern that he Five city of Reno
employees at the courthouse until nine o'clock at night to get it done that in fact judge Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault
that all and where the Reno Municipal Court had previously granted a continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's
criminal trespass complaint (connected to the summary eviction matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a
continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week vacation by Richard G Hill that Hill alleges enabled him to commander the
Reno justice court judge Sferrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest
personal property lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November
17 as Janice admitted when judge Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be able to
control the justice court in his desired to prevent such a hearing been set until he returned from his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to contest
personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow
the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve
Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for
something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate McGeorge school law along with wash County Dist.
Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently granted 2004 graduate McGeorge school of law deputy district attorney Zach young in order taking
away the ability to file by fax from Coughlin a privilege that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 hearing at
which Coughlin's then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young alleged who filed on November
26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge
Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote
representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he and
his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org)
(former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed Coughlin's work before him
and in Nevada Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the hearing and in violation of Supreme
Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in any matters relative to the ultimate Supreme Court rule 105 complaint
against Coughlin for over six months at least and so in no way can be said to just stuff I his last-minute supplementing judge Beesley and milquetoast attempts to provide Coughlin S supplemental designation of
witness and summary of evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY at the hearing (both of those gentlemen attended
McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of Coughlin's competency as an attorney at the hearing
despite the fact that neither of them could provide anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in
judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal
disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 from his clients and using it on hookers and
luxury designer goods. Apparently creditors rights specialist bankruptcy judge Beesley sees competency in Mr. Harris and could overlook the $755,000 for my client where it be $14 worth of candy bars and cough
drops from Coughlin and Coughlin's March 30, 2012 filing in Cadle Co. v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at 2:30 pm in representing Mr. Keller
that was affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice
court wherein the audio record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary eviction case against Coughlin through despite Judge
Schroeder admittedly having had a different order of hearing the cases planned for that morning docket and despite the fact that the fax header on the summary eviction order that was hurriedly moved through
indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime
shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they entered with their guns and/or pagers drawn in and immediately placed Coughlin in handcuffs and told
him he was detained in contrast to the typical procedures carried out by the Sheriff's office incident to evictions in Washoe County. Incident to that summary eviction (where the docket, at least, more review is
necessary, indicates that Kern and Western Nevada Management's Sue King switched up their basis for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for
seeking an eviction to one for non-payment of rent (seemingly in response to Coughlin Pre Hearing Brief pointing out the difficulties they would face under Glazer in pursuing a No Cause, particularly against
Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to
Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw Coughlin under the bus at Coughlin's 11/14/12
formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy bar
conviction that resulted in the current now 5 month long suspension of Coughlin's license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL,
ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of
Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email
to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR
26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order Coughlin's
property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately admitted to
having released to the City of Reno Marshals on 2/28/12, denied having the micro sd card, denied the micro sd ever being booked into property, alleged to have given Judge Sferrazza's former tribal court Bailiff
and former Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys so Eastman could arrange for Coughlin's dog Jackson Pawluck to be fed and
cared for during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card confiscating without a warrant/5
day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's law office,
where RPD Sargent John Tarter told Coughlin to leave after Coughlin presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department officers and
managing caught to get Coughlin subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin reporting to Sargent
John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him as he too was on Richard Hill's payroll that
RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia
Lopez refused to undertake any diligent inquiry response to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121 River rock property for the
month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any diligence by both
officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10, 2012 trial
date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed a
grievance with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's
smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of a search incident to arrest given Coughlin property had been booked into his personal property at
the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily sentencing Coughlin to 5 days in jail for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS 22.100,
but characterizing her Order as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in nature, and
therefore requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even said what Holme's alleged he did in rendering her
"second bit at the apple" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030 (which is civil in
nature) for conduct not committed in the immediate presence of the Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and hiding some component part
thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she rendered in that traffic
citation case stemming from Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly after being released from a 3 day custodial
arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter presided over by Judge Sferrazza). Like the Order
Judge Linda Gardner claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the
Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to
Contest Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza
may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton as to
the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court bailiffs had either as bailiff arrested told Coughlin that he would put his foot
of Coughlin's ass or made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on two different occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing
office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. Dr. Merliss owns the property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was
leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately
August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding
rent. All of his clahns were decided adversely to his position at the eviction hearing. Justice of the Peace Peter Sferazza ordered Coughlin evicted from the premises effective November 1, 2011.
On that date, the Washoe County Sheriffs Department performed their normal eviction procedure: locks were changed and the eviction notice was posted on the front door. We
videotaped the home and its contents at that time. Upon inspection over the next few days, it became apparent that "somebody" was breaking into the home on a regular basis. On Sunday,
November 13, 2011, Dr. Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true for Hill to write "The lease expired in February 2011." The Standard Rental Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in accordance with the
NRS 118A holdover tenant provision. Further, it is not accurate for Hill to write "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with Coughlin's former co-tenant,
Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011 and June
2011 and only sent the landlord Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr. Merliss's assent to
Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's secretly absconding with Coughlin's rental
contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss). Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the
record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in violation of NRCP 11) admitted, under oath, that he had expressly, in writing, assented to
an agreement with Coughlin for a rent deduction of $350 going forward in exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artificial turf installation Coughlin had
installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it
was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn Service to "deal with the weeds" at Coughlin's former home law
office. "Dealing with the weeds", to Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law office substantial losses lost profits time away from work and
expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid
for services to landlord Merliss, who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the
weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds at the
property Merliss owns next-door at 252 Mill St.
Hill's grievance of 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days before. Dr. Merliss discovered that the basement door was barricaded (not locked) from the inside. The Reno Police
Department was summoned. They tried to coax whoever was in the basement out, without success. After Dr. Merliss had to kick the door down, it "was discovered that Mr. Coughlin
had broken in and was in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is also facing a
contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012,
but was continued at the request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process, a lien was asserted against
the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the Reno Justice Court. The court tried to
promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then reinitiated that process and a hearing was held in
December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing. You may also want to contact Reno Justice Court staff, and in
particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time
window to remove his personal property. The first day was Thursday, December 22, 20 11. After Coughlin was allowed into the home that first day, he sent out an e-mail to the effect
that because he had appealed Judge Sferazza's order, he was entitled to a stay of proceedings and was to resume in the home. As a result, he did very little to remove any of his
personal property that day. On Friday, December 23, 2011, after he learned, again, that his stay had been denied, Coughlin assembled a small crew and they were able to remove a
substantial amount of his personal property. (You need to understand that Mr. Coughlin is a hoarder. We have the photos and videos if you would like to see them.) However, Mr.
Coughlin did not get all of his property out. For example, I counted 13 car seats that he had somehow managed to get down into the basement.
Having failed to remove all of his belongings, Mr. Coughlin then moved before Judge Flanagan for a temporary restraining order to prevent the disposal of his abandoned property in
accordance with Judge Sferazza's order. Attached is Mr. Coughlin's motion, my office's opposition, and Mr. Coughlin's reply. These documents demonstrate Mr. Coughlin's
complete and utter incompetence as an attorney.
On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request for a temporary restraining order. On January 12, 2011, the contractor hired to clean the house commenced work.
Mr. Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the house. Coughlin called the police, who
arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5
minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
Close
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead
with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Print
in compliance with Judge Sferrazza Order of 9/5/12 FW: Zach Coughlin has shared a folder with you
Sent: Tue 11/27/12 8:26 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
re:rcr2011-063341
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance of counsel claim and or the coerced waiver
of my Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent
faxing of numerous filings to the wrong fax number by myself.
https://skydrive.live.com/redir?resid=43084638F32F5F28!5141&authkey=!APibWiVXTMSWkw0
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
View photos Download all
in compliance with
Judge Sferrazza
Order of 9/5/12
You are invited to view Zach's album. This album has 43 files.
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf
4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
11 21 12 Notice of Irregularities 063341 with ex 1 started revised.pdf
11 30 11 063341 Coughlin_Discovery Received_11.30.11 rotated.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdf
11 13 12 063341 submission of materials and motion for order dmv and cell records or subpoena.pdf
11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text of motion no exhibits.pdf
2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed pdffactpro more nuance.pdf
final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341 - Copy.pdf
pre trial brief state of nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd and tagged jbig2 lossy.pdf
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf
pre trial brief state of nevada v coughlin rcr2011-063341.pdf
rcr11-063341 notice of appearance coughin file 3 3 2012.pdf
rcr11-063341 affidavit in support of motion to file pre-trail motions late bw - Copy.pdf
11 27 12 complete with ex 1 063341 notice of developments.pdf
11 26 12 0204 Notice of Hill and Baker Malfeasance for Motion for New Disciplinary Hearing or Trial 063341 1708 60331 61383.pdf
6 25 12 Order for Sanctiosn 03628 0204 Flanagan $40K in attorneys fees summary eviction appeal.pdf
10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order to Baker 1708 0204.pdf
FW: Zach Coughlin
From: stuttle@washoecounty.us
CC: CWood@washoecounty.us; RBaker@washoecounty.us
Subject: RE: Zach Coughlin has shared a folder with you
Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:

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

Steve Tuttle

Court Administrator
Reno Justice Court

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Saturday, November 03, 2012 9:39 PM
To: Tuttle, Steve
Subject: Zach Coughlin has shared a folder with you

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

Share your files with

IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND IN CASE ANYTHING GOES
MISSING AGAIN
Sent: Thu 11/29/12 4:57 PM
To:
stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us (psferrazza@washoecounty.us); rjcweb@washoecounty.us
(rjcweb@washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 29 12 063341 MOTION FOR NEW TRIAL FINAL WITH 217 MENTION.pdf
EX1 063341 FINAL.pdf
data-2012-11-24-17-43-52 063341 11 19 12 lichty admits phone did not vibrate.wav
data-2012-11-24-17-44-12.wav
data-2012-11-24-18-40-33.wav
data-2012-11-24-18-40-47.wav
data-2012-11-24-18-43-05.wav
data-2012-11-24-18-45-14.wav
data-2012-11-24-18-49-41.wav
data-2012-11-24-18-49-41(1).wav
data-2012-11-24-18-53-39.wav
data-2012-11-24-18-53-39(1).wav
data-2012-11-24-19-00-18.wav
data-2012-11-24-19-00-18(1).wav
data-2012-11-24-19-21-24.wav
data-2012-11-24-19-21-24(1).wav
data-2012-11-24-19-26-17.wav
data-2012-11-24-19-31-25.wav
data-2012-11-24-19-37-26.wav
data-2012-11-24-19-40-46.wav
Download all

911 calls missing from what was produced by City Attorney Skau
Sent: Mon 12/03/12 2:53 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr.
Leslie's representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young
on this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by himduring the commission of the burglary charged in Count 2. Since a thief cannot
receive from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to Leslie's failure to utilize any of
the work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of
11:27:11 pm reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could
"hear" on the Dispatch recordings (and those provided by City Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously
devoid of anything for the 6 minutes in which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena
which required production of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main
justification for the pat down and search incident to arrest and led to a justification for not excluding anything "discerned incident to the pat down"...the only problem is is that Duralde and Rosa
already are marked as on the scene by 11:26:00 pm, and therefore could not have read the text screens in their vehicles to recieved the text only 11:27:11 pm dispatch entry about "someone just
socked a minor". Further, the extent to which Coughlin's 911 call is not reported accurately at all further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the
dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge Sferrazza ordering him to produce in
response to my subpoena duces tecum to Kelley Odom and ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct.
Two of the 911 calls are missing. There is no audio of any RPD-ECOMM/Dispatch communications between the 11:28:17 pm mark and the
11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm did not know I was filming/recording the arrest. Had I not captured a
recording of the arrest, how little would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many things revealed by
the arrest recording contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further,
where Zarate does not allege to have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on 8/29/12 does testify to
seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw it light up from all the way across the skate park...but wait...come
November 19th, 2012 he changes his story and decides he saw it light up from "2 to 3 feet away from Coughlin"....There a movie floating around
somewhere out there that does a timeline of all these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to
sworn testimony by these witnesses...etc. And one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5,
wherein Young writes: "In the instant case, the pat-down search of the Defendant was proper under the totality of the circumstances. Prior to
arriving, Officer Duralde learned that the scene involved a loud disturbance with possible fight, thereby immediately raising the concern of weapons
and the safety of all those present." And, of course, Officer Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and
sang the "possible fight...report from dispatch of a possible fight" tune all the live long day...which was the basis for the reasonable suspicion for the
pat-down (and Judge Sferrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less obvious the extent to which
Young was repeatedly allowed to enter hearsay into the record, both in the Suppression Motion Hearing and at Trial, whereas Coughin never could get
that darn Nicole Watson admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on video and audio
recordings into the record...despite Duralde testifying to a multitude of double hearsay (and not even capture on a recording so close in time to the
arrest and at the very same location, involving the majority of the players in the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed
on" date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in
support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney whom dared to answer one of the officer's questions by asking a question
seeking clarification as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the
Officer's did not receive the text from dispatch reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year
old Austin Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt
prior to RPD rcr.3gp 46 seconds in length) lying in asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition to Goodnights 2/14/12 Motion to
Suppress, both Goble, Lichty, and Zarate all have motivations apparent which preclude them from being deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted
to in his testimony at trial to being aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and double hearsay Duralde testified to at trial after "refreshing his
recollection" upon a review of either his "Supplemental Declaration" (an attachment to the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
question....how was it not misconduct by the State and prejudicial to the point of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to (the password for the phone)...and when Goble alleges Duralde gave him back
the phone...and the call into the iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for the State and the RPD here is that two hostile witnesses (in addition to Coughlin's various statements related thereto, during
his testimony and on the media admitted into evidence) testified that RPD Officer Duralde committed misconduct by lying about the purported order
or point in time in relation to the arrest and search of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde
removed the phone from Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask question related to the
phone and to verify ownership of the phone (which would include gathering the phone number for the iPhone, which necessarily would mean that
Duralde's allegation of only searching Coughlin after performing some call to the iPhone and hearsaying it vibrate (even though multiple witness
(Templeton, Zarate, Goble, Lichty testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all) Goble testified that
Duralde already had the iPhone prior to Goble conferring with Duralde or otherwise giving Duralde any phone number to call in an attempt to verify
the phone revealing an incoming call LED display scree light up alert (Goble's statements that the phone would "light up" and that he, as Duralde
quotes him in the Narrative, "could not hear the phone
I have 30 days from the date of conviction to report a conviction to the State Bar of Nevada and the United States Patent and Trademark Office
(USPTO) for these two convictions "possessing or receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney of record for me on this cases RCR2011-063341, had served (see attached) a subpoena on ECOMM
and Kelley Odom on 10/03/12. Given that Mr. Leslie was not relieved as my counsel until at the earliest 10/22/12 (so Judge Sferrazza's contention
that Coughlin "has had forever to get his defense ready in this case" and that "no continuance will be granted on account of the formal disciplinary
hearing before the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge
Sferrazza indicated some canon preventing him from testifying at the formal disciplinary proceeding...that didn't stop 063341 being specifically pled in
the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial
Secretary Lori Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the
SBN Coughlin's 2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally
released them o October 30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a
defense in his formal disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of
the hearing on 11/14/12 after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and
SCR 105(4)...But the point is, if the RJC and both of you want to be associate with a Schaeffer style Mirch-ing, then this may be your chance.
But you won't be able to say you didn't have plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure to turn over
anything to me in the "hand off transmittal" he insisted upon (despite a digital transmission being required per the Order of Judge Sferrazza, I believe)
requires some explanation.
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith attempt to comply with Judge
Sferrazza ordering him to comply with the subpoena duces tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events
surround it of 8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin Lichty's cellular phone, 775 233
8593, which Goble is seen in the attached still frame picture culled from a video Coughlin took of the moments prior to the arrival of the RPD, being
handed by the "man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton testifying that they do not know
that man and did not know him prior to that night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they
gather the identify of the "man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having
attacked him and attempting to steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge
were "unsubstantiated"). Oddly, in the attached still frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty
that Goble utilized to make his two 911 calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) taking
place beginning at 11:22:52 pm (though the ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call
comes in is designated on the "Calls for Service Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911
entry for the 775 233 8593 number (belonging to Austin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking
my law license away from me for at least 5 years, if not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in
the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in Reno, "man with a six pack of beer" picks it up, offers it up, receiving no
response threatens to "throw it in the river if someone doesn't claim it immediately" whereupon Goble's friend Nate Zarate apparently (according to
RPD Duralde's Narrative of unknown origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in
his Narrative)
contain the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde
indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the video Coughlin filmed of the arrest, title:

Then, Officer Rosa is proven to be on the bridge and not in his squad car reading texts from dispatch n the following time stamped file: "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying
charles 396 on the other end"
Further, Officer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of
printing" variations...).
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc of phone susps os left on post lighting up in sups pock RP screaming at susp
2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone just socked a minor, waive that cop down 10 10 with open line
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the
Ecomm recordings and dispatch logs...
1. VID_20110820_232413 your all on tape now goble and friends.3gp 8 seconds long
2. VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID_20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records for the iPhone reveal only four calls occurred in or out during the relevant time frame:
Goble's AT&T records:
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..." Previous to that, DDA Young had successfully kept every single witness from specifically
identifying who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh, that's Colton" 8
feet from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the misconduct of a prosecution witness....Goble, batterying Coughlin with a lit cigarette,
that Coughlin capture on tape, on June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later
by a 3 Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you
look at the circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a
Trial before Judge Linda Gardner in a divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues printing it out and
bringing it with me (my legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence exclusively hearsay testimony (often unattributed to anyone in particular) to support his win on the "sufficient probable cause to support a search incident to
arrest" despite NRS 171.136 forbidding such an arrest (where Duralde obviously overcharged the alleged crime as a "felony grand larceny"...even making smug commentary about the "certain benefits of charging this as a felony" and saying "oooh, that's a
felony", both matters that Leslie insisted refraining from getting into while he was attorney of record, and further, despite Coughlin complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail for Duralde)
Coughlin was denied the right to cross examine the arresting officer...which is too bad considering his Narrative alternately claims that Goble told him they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation of NRS 205.275, a misdemeanor, in the manner following, to wit:
That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully possess or withhold stolen goods having a value less than Two Hundred Fifty Dollars ($250.00),
to wit: an iPhone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, for his own gain or to prevent the true owner from again possessing said property, knowing that the property was obtained by
means of larceny or under such circumstances as should have caused a reasonable man to know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574. Must allege the good were received from someone other than the defendant: Gaddis, 424
U.S. 544, Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the
robbery proceeds in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff in error, a...The next assignment of error is that the State failed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show
(1) that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one charged with receiving it has actually received the property stolen or
aided in concealing it; (3) that the receiver knew the property was stolen at the time he received it and (4) that he received the property for his own gain or to prevent the owner from possessing it.
(People v. Piszczek,404 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186."
PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96 N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that if a criminal conviction is to be upheld,
[ 21 Ill. App.3d 980 ]
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327 (1946)), and must contain the nature and elements of the offense in order that
the defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this
omission, creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from
himself, the fact that the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446,
448-449 (1929); People v. Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the
indictment failed to charge the offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490
(1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does
not create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances
that would reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question
(in any manner whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it
is not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the
offense of theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property
soon after a theft is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971),
1 Ill.App.3d 860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the
necessary elements of the offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of these words would only be grammatically redundant and mere
surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the defendant guilty beyond a reasonable doubt. For this reason I, too, would
reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in "larceny" and "theft" cases. He erroneously urges that the state failed to meet that
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the
time and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot
receive from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4
Cal.App.2d 214, 40 P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961);
Thomas v. United States, 418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and
later acknowledged by the court to be such when it set aside the receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner of handling the error
effectively cured it. The error was not cured by the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant
guilty of burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element of the crime of receiving stolen goods..17. Criminal Law. In prosecution
for receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again
possessing property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession
thereof. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for
possession of stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish
probable cause that she had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the proof did not show that she knew the property was stolen and that such knowledge cannot be inferred from mere
possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a conviction for possessing stolen property on the ground that the
legislature did not intend to compound the punishment for larceny or robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property.
Point v. State, 102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests
with the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see
Gilman 275 V. Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2
378. triem 929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re
Cobb, 838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d
427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following two timestamped recordings finally provided by City Attorney Skau (WCPD Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the
youths prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest,
incident to the theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet"
incident to the inappropriat placement by Judge Sferrazza of Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to
further his stated goal of avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin,
as he, in fact did, deposit a "rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich man's opposing counsel
Casey Baker, Esq. coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon Judge Sferrazza . You are to his constituency by remixing is
previous order regardless of the extent to which Coughlin was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they are and where only those aspects
of a summary proceeding that in year to the landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to
bring counterclaims were matters Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner
in which service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same
bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let
them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public defender applying good nicely
peers deciding that the night was doing too much to assist Coughlin in defending himself and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy session while
Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial on July 16,
2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's
December 19, 2011 file stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the Defendant, ZACHARY
BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295,
inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of
the State, the existence of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including
those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling the extent to which on the record at
that July 16 trial date Washoe County public defender Jeremy Bosler indicated that Jim Leslie would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And that Leslie
would be prepared to try the case by Friday and that the court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have completed all
the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the case whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf
or willingness to do so, or indication that Jim Leslie felt that the judges of the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr. Leslie has any skin in this game
whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing disregard
for the rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe County District Attorney's Office and therein secure added boys from local law
enforcement District Attorney's Office and perhaps the Reno justice court itself. Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders
office in connection with February 27, 2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted whether they they have been sworn prior
thereto or not an especially where Dogan's coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the confiscation without a search warrant or court order of any kind (or
at least one ever served on Coughlin in any manner) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the
clandestine status conference between Dogan young on February 27, 2012 in RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling
conflict between that traffic citation trial in the Reno Muni court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30
highest-paid city of Reno employees of and admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest
based upon a criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal trespass conviction has now become the subject of a Nevada Supreme Court case in 61901 wherein
Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that
judge Sferrazza presided over wherein judge Sferrazza purportedly controlled the civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December 26 submitted for filing
December 26, 2011 was not file stamped by the civil division staff of the Reno justice court. This impropriety is further problematic where Coughlin had served upon the Reno justice court's custodian of
records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012 letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against
Coughlin to the State Bar of Nevada, which ultimately became one of the three grievances depicted numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State
Bar stamped August 23, 2012 (in addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial in 11 TR 26800 held in violation of NRS 178.405 by way of NRS
5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including then Administrativ Judge William Gardner, who refused
to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris
Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor
Hill meritless or her partner officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial arrest on that day in where Lopez also admits none of those individuals or anyone present
that day identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about 5 feet high underneath the former home law office wherein Coughlin was found at a
time when Coughlin still had not receive back from the Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's
admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule 44
that may support the secret quote house rules been fact in the civil division of the Reno justice court wherein tenants were in summary eviction matters were subject to forced rent escrow deposit in violation of
justice court rules civil procedure 83 and that the Reno justice court had neither published nor had approved by the Nevada Supreme Court any sort of corollary to justice court rule Las Vegas rule 44 (JCRLV
44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the Washoe County Sheriff's office deputy Machen filed a false affidavit on November 7, 2011
alleging to have personally served Coughlin with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of Law, and Order of Summary Eviction (which Casey D.
Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact that his sister judge Linda Gardner is listed as the
grievant (and him goes to Pat King's awkward assertions that the "Clerk of Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order sanctioning Coughlin incident to a divorce
matter where and he was representing a victim of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former prosecutor judge Linda Gardner in comparison to the
extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy district attorney Young's repeated malfeasance misconduct violations stays pending
competency or evaluations failure to turn over exculpatory materials failure to propound discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in conjunction with
scattershot three, count them three prosecutions of Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young amended the
criminal complaint from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 14,
2012 arrest in the matter to a charge that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort to achieve a plea-bargain and resolve what is a messy case the city
of Reno Police Department and emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's
calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against
Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false
statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of
summary eviction matter in 1708 Barber which judge Sferrazza presided and which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee award
against Pro per appellant Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's
office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was
assigned to Coughlin appeal of the petty larceny conviction of a candy bar and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license
incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a
misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying
at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar
and some cough drops in connection with Coughlin's selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that
Walmart alleges to have had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and where French you admit that
his supervisors had previously indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning some of Walmarts policies and where John Ellis of the W. 7th St., Walmart in
any as yet unknown loss prevention associate specifically and expressly threatening abuse of process against Coughlin on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant
store managers and customer service managers many of whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from
the policy which Walmart holds out to the public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at Walmart.com no
matter what the convenient for getting in misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011
affected a citizen"s arrest of Coughlin on that date in connection with the alleged petty larceny by Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days
after Coughlin filed a written complaint detailing the police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20,
2011 in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American jurisprudence that one cannot be
charged with both petty larceny and receiving stolen property of the same item particularly where the receiving of the item is alleged to have been from oneself after one had larceny is the item lending an
inference that Joe Sferrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in
connection with its numerous since is violating about law respecting the manner in which evictions are carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory
arrest and prosecution of Coughlin where the judiciary in Washoe County is off criticizes being overly influenced by the District Attorney's Office. That Walmart petty larceny conviction stemmed from a trial
before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the Wal-
Mart case, as judge Kenneth Howard denied Coughlin a court appointed defender there despite his express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority
exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin
extends further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing the November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion
of the hearing which are trial which judge Howard down such a matter of public concern that he Five city of Reno employees at the courthouse until nine o'clock at night to get it done that in fact judge
Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault that all and where the Reno Municipal Court had previously granted a
continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's criminal trespass complaint (connected to the summary eviction
matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-
week vacation beginning early November 2011 and it was that same six-week vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge Sferrazza to denying
Coughlin a hearing on his motion to contest personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest personal property lien on November 17,
2011 even where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as Janice admitted when judge
Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be able to control the justice court in his
desired to prevent such a hearing been set until he returned from his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge
Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow the justice court to
setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a
violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for
something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate McGeorge school law along with wash County
Dist. Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently granted 2004 graduate McGeorge school of law deputy district attorney Zach young in
order taking away the ability to file by fax from Coughlin a privilege that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27,
2012 hearing at which Coughlin's then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young alleged who
filed on November 26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had
merely comply with judge Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort
whatsoever incident to his quote representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he
and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at
www.nvbar.org) (former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed
Coughlin's work before him and in Nevada Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the
hearing and in violation of Supreme Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in any matters relative to the
ultimate Supreme Court rule 105 complaint against Coughlin for over six months at least and so in no way can be said to just stuff I his last-minute supplementing judge Beesley and milquetoast attempts to
provide Coughlin S supplemental designation of witness and summary of evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY
at the hearing (both of those gentlemen attended McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of
Coughlin's competency as an attorney at the hearing despite the fact that neither of them could provide anything in the way of specificity with regard to what issues they would take with any of the work they
reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting
to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating
some $755,000 from his clients and using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge Beesley sees competency in Mr. Harris and could overlook the
$755,000 for my client where it be $14 worth of candy bars and cough drops from Coughlin and Coughlin's March 30, 2012 filing in Cadle Co. v. Keller (an adversary proceeding in the NVB wherein
Coughlin had a hearing on March 15, 2012 at 2:30 pm in representing Mr. Keller that was affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that
morning obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice court wherein the audio record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to
hurriedly move the case summary eviction case against Coughlin through despite Judge Schroeder admittedly having had a different order of hearing the cases planned for that morning docket and despite the
fact that the fax header on the summary eviction order that was hurriedly moved through indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe
County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they
entered with their guns and/or pagers drawn in and immediately placed Coughlin in handcuffs and told him he was detained in contrast to the typical procedures carried out by the Sheriff's office incident to
evictions in Washoe County. Incident to that summary eviction (where the docket, at least, more review is necessary, indicates that Kern and Western Nevada Management's Sue King switched up their basis
for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for seeking an eviction to one for non-payment of rent (seemingly in response to Coughlin Pre
Hearing Brief pointing out the difficulties they would face under Glazer in pursuing a No Cause, particularly against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where
the Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for
which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw Coughlin under the bus at Coughlin's
11/14/12 formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy
bar conviction that resulted in the current now 5 month long suspension of Coughlin's license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL,
ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of
Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit
Email to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7)
Exhibit 11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order
Coughlin's property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
admitted to having released to the City of Reno Marshals on 2/28/12, denied having the micro sd card, denied the micro sd ever being booked into property, alleged to have given Judge Sferrazza's former tribal
court Bailiff and former Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys so Eastman could arrange for Coughlin's dog Jackson Pawluck
to be fed and cared for during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card confiscating without a
warrant/5 day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's
law office, where RPD Sargent John Tarter told Coughlin to leave after Coughlin presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department
officers and managing caught to get Coughlin subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin
reporting to Sargent John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him as he too was on
Richard Hill's payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer
Carter and Sargent Marcia Lopez refused to undertake any diligent inquiry response to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121
River rock property for the month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query
Hill with any diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told
Coughlin at an April 10, 2012 trial date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact
that at that time he had filed a grievance with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's
smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of a search incident to arrest given Coughlin property had been booked into his personal property
at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily sentencing Coughlin to 5 days in jail for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS
22.100, but characterizing her Order as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in
nature, and therefore requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even said what Holme's alleged he did in
rendering her "second bit at the apple" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030
(which is civil in nature) for conduct not committed in the immediate presence of the Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and hiding
some component part thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she
rendered in that traffic citation case stemming from Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly after being released
from a 3 day custodial arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter presided over by Judge
Sferrazza). Like the Order Judge Linda Gardner claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis FV11-03383 (see attached in Exhibit 1), Judge Sferrazza
attempted to characterize the Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed stamped Motion to Contest Personal Property Lien as an
"Order Resolving Tenant's Motion to Contest Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was certainly not "agreeing" to anything, nor was he waiving his
right to appeal any Order Judge Sferrazza may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice
court bailiffs radius in chief bailiff Sexton as to the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court bailiffs had either as
bailiff arrested told Coughlin that he would put his foot of Coughlin's ass or made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on two different occasions the week
of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. Dr. Merliss owns the property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property
was leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in
approximately August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that
justified his withholding rent. All of his clahns were decided adversely to his position at the eviction hearing. Justice of the Peace Peter Sferazza ordered Coughlin evicted from the premises
effective November 1, 2011. On that date, the Washoe County Sheriffs Department performed their normal eviction procedure: locks were changed and the eviction notice was
posted on the front door. We videotaped the home and its contents at that time. Upon inspection over the next few days, it became apparent that "somebody" was breaking into the
home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true for Hill to write "The lease expired in February 2011." The Standard Rental Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in accordance with
the NRS 118A holdover tenant provision. Further, it is not accurate for Hill to write "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with Coughlin's former co-
tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011
and June 2011 and only sent the landlord Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr.
Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's
secretly absconding with Coughlin's rental contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss).
Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and
eviction notices, in violation of NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an agreement with Coughlin for a rent deduction of $350 going forward in
exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the
landlord's landscaper for the other property Merliss owned next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the
"$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn Service to "deal with the weeds" at Coughlin's former
home law office. "Dealing with the weeds", to Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law office substantial losses
lost profits time away from work and expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf
installation even though they knew it was there prior to submitting their bid for services to landlord Merliss, who apparently did not realize or remember that he had also assented to a $350
rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin
put into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Hill's grievance of 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days before. Dr. Merliss discovered that the basement door was barricaded (not locked) from the inside. The Reno
Police Department was summoned. They tried to coax whoever was in the basement out, without success. After Dr. Merliss had to kick the door down, it "was discovered that Mr.
Coughlin had broken in and was in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is
also facing a contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That was scheduled for
January 10, 2012, but was continued at the request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process, a lien was asserted
against the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the Reno Justice Court. The
court tried to promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then reinitiated that process and a hearing
was held in December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing. You may also want to contact Reno Justice
Court staff, and in particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting
Coughlin a two-day time window to remove his personal property. The first day was Thursday, December 22, 20 11. After Coughlin was allowed into the home that first day, he
sent out an e-mail to the effect that because he had appealed Judge Sferazza's order, he was entitled to a stay of proceedings and was to resume in the home. As a result, he did
very little to remove any of his personal property that day. On Friday, December 23, 2011, after he learned, again, that his stay had been denied, Coughlin assembled a small crew
and they were able to remove a substantial amount of his personal property. (You need to understand that Mr. Coughlin is a hoarder. We have the photos and videos if you would
like to see them.) However, Mr. Coughlin did not get all of his property out. For example, I counted 13 car seats that he had somehow managed to get down into the basement.
Having failed to remove all of his belongings, Mr. Coughlin then moved before Judge Flanagan for a temporary restraining order to prevent the disposal of his abandoned property
in accordance with Judge Sferazza's order. Attached is Mr. Coughlin's motion, my office's opposition, and Mr. Coughlin's reply. These documents demonstrate Mr. Coughlin's
complete and utter incompetence as an attorney.
On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request for a temporary restraining order. On January 12, 2011, the contractor hired to clean the house commenced
work. Mr. Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the house. Coughlin called the
police, who arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about
5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151
unintelligible.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go
ahead with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell phone susp os also loud verb disturb.wav
Close
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-16-41 AM Source_ID = 13 Duralde indicated he will be en route to main station to drop off Coughlin's smartphone for copying data prior to
depart.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-41 AM Source_ID = 6 Duralde's wife Jessica c151 reno, Alaksa can you switch to share some information call please.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead with that.wav
11 30 12 063341 updated motion for new trial with ex 1 attached in 2 pages per format.pdf
Download all

Print
Case No. RCR2011-063341
From:Jeannie Homer (HomerJ@reno.gov)
Sent: Thu 11/08/12 2:48 PM
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order toQuash Subpoenas and for Protective Order
Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte Emergency Order PendingHearing.pdf (81.0 KB)
Please see attached documents from Creig Skau, Deputy City Attorney:

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

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

Thank you.

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

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Fwd: FW: Case No. RCR2011-063341
From:Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
Cc: Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted
mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted
to serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a
photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:

IN THE JUSTICE COURT OF RENO TOWNSHIP

COUNTYOF WASHOE, STATE OF NEVADA

STATE OF NEVADA,
Plaintiffs,

vs.

COUGHLIN, ZACHARY BARKER

Defendant.

CASE
NO.:
RCR2011-
063341

DEPT.
NO.: 2

EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (RCAO) represents a number of City of Reno employees who have been named in subpoenas. The RCAO contacted Court
personnel on November 7, 2012 to request a time to appear for an order shortening time regarding a motion to quash and for protective order. Due to the proximity of the trial date in this matter,
November 19, 2012, the Court directed the RCAO to file and serve its substantive motion and provide notice that the matter would be heard on November 8, 2012 at 9:00 am. The City of Reno
filed its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared on behalf of the RCAO and the City employees requesting protective relief.
Zack Young was present in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defenders office represented Mr. Coughlin, that the Public
Defender was served believing this was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himself this morning and attempted to call and left a voice mail message with a phone
number believed to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and
filed requests for relief similar to the RCAOs requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr. Coughlin, no argument was received on the merits of the motion.
However, the Court finds that the RCAOs motion and supporting materials present a sufficient evidentiary basis to issue this Order.

The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 13, 2012. Oral presentations shall be limited to 10 minutes each. The
Clerk shall notify Mr. Bosler and Mr. Wong of the hearing.
2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance with NRS 174.305 is hereby quashed. Any subpoena not personally served by
a non-party or otherwise properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds such as relevancy or undue burden until the
hearing on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this matter on November 13, 2012, to the effect that upon service of this
Order on Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter issue or cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena duces
tecum in this case unless he has first presented the proposed subpoena or subpoena duces tecum to the Court for the Courts review regarding adequacy, relevancy and necessity of the subpoena
or subpoena duces tecum, and sufficiency of the proposed method of service.
4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order and the RCAOs motion and any supplements by personal
service upon Zachary Barker Coughlin at the address in the Courts file, 1471 E. 9
th
Street, Reno, NV 89512, with a copy mailed to said address. Service shall also be attempted by email at
zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.

/s/

JUSTICE OF THE PEACE

The City of Reno's Motion states:

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

IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTYOF WASHOE, STATE OF NEVADA

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

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

JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and any additional or further evidence the Court deems just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. On October 26, 2012, City of Reno Emergency Communication Center employees (ECOMM) Suzy Rogers and Kelley Odom received emails from Zach Coughlin containing nine (9)
Subpoenas, copies of which are attached as Exhibit 1 and incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among other things, the City of Reno Police Report and City of Reno ECOMM materials
regarding Case Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno for $108. A copy of the letter is attached as Exhibit 2 and
incorporated herein by reference. On November 5, 2012, this same letter was sent again to Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah
Montgomery and Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated because service of the subpoenas for these four
(4) individuals was ineffective, these individuals would not be appearing on November 19, 2012. (Exhibit 2).
4. On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a Notice of Errata and Revised Supplemental Motion For a New Trial by sliding them
through the security glass in the front office of the Reno Police Department at approximately 4:50 p.m. after being told the office was closed. Three (3) subpoenas contained in this packet
are duplicates. As such, this packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM employees Kelley Odom and Suzy Rogers. A copy of this packet
is attached as Exhibit 3 and incorporated herein by reference.
5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking documents previously requested
in earlier subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials unrelated to Case RMC RCR2011-063341. A copy of these documents is
attached as Exhibit 4 and incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin regarding the letter this office mailed on November 2, 2012. Among other things,
Mr. Coughlin did not indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese. Mr. Coughlin did state to have these
witnesses ready for trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing seventeen (17) pages of blended documents regarding matters pending before
Reno Justice Court on November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department. The subpoena duces tecum on the first page of
the packet contains many unreadable names. A copy of the packet is attached as Exhibit 5.
1. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of materials from an unidentified person. The cover sheet of the packed is entitled Subpoena Duces
Tecum regarding Case RCR2011-063341. This document also appears to contain names of other individuals but the handwriting is unreadable. It is not known if the other individuals
on this subpoena are City employees. A headnote on the Subpoena indicates that if the requested documents are e-mailed to Mr. Coughlin, personal appearance may not be required. A
copy of the packet is attached as Exhibit 6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party and is not less than 18 years of age. Service of a subpoena upon a person named therein shall be made by
delivering a copy thereof to such person and, if the person's attendance is commanded, by tendering to that person the fees for one day's attendance and the mileage allowed by law.
When the subpoena is issued on behalf of the State or an officer or agency thereof, fees and mileage need not be tendered. Prior notice, not less than 15 days, of any commanded
production of documents and things or inspection of premises before trial shall be served on each party in the manner prescribed by Rule 5(b).

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

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

III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel Harley or any other City employee whose names were unreadable in the subpoenas for
failure to comply with JCRCP Rule 45;
2. To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate
to the City or to this matter because they failed to comply with JCRCP Rule 45.
3. Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior to issuance and
service to ensure Mr. Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney

By:

CREIGTON SKAU


P.O. Box 1900

Reno, NV 89505

Attorneys for City of Reno

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

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

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

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

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

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

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

Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from representation:
Rul e 3: Aut hor i zat i on t o Repr esent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw 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
Hi zachcoughlin,
You r Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
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.
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Hi zachcoughlin,
Your Fax was delivered @ 08:13:34 AM on 2012-06-28.
to me
to me
to me
Please get this to these City of Reno employees
Hi zachcoughlin,
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341



Thank you.

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


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

to me
to me
Sent: Wed 11/28/12 12:35 AM
To: renodirect@reno.gov (renodirect@reno.gov)
sometimes they don't clean out their inbox, but I seem to not have my email set up to receive bounceback messages perfectly all the time, so in an abundance of caution, I ask that Reno Direct
help make sure these good folks get the message below:
kbeechler@reno.gov
odomk@reno.gov
bonyr@reno.gov
christensend@reno.gov

Subject: RE: RCR12-065630
Date: Thu, 8 Nov 2012 05:02:29 -0800
Dear Mr. Dogan,
I understand it is my inviolable right as a criminal defendant to subpoena witnesses. Please subpoena RPD Sargent Zach Thew and inteview him
regarding any claim of right defense Coughlin may have respecting any alleged issuance by Thew to Coughlin of an invitation to Call him at a certain
RPD number and or 911 in connection with various discussion Thew and Couglin had prior to the 1/14/12 arrest. Please also (in conjunction with the
investigator on this case, and I have yet to be informed of whom that is...and Mr. Novak, I appreciate the work and notations you made to the file that I
have only just been made privy to by Mr. Leslie...I submit you are done a disservice where there is not more transparency given to the results of your
work to your criminal indigent defendants, as the circumstances dictate they assume the worst when supporting documentation to cursory contentions is
not show.
So, whom is the investigator here, and will you please provide me the documentation detailing the results of the investgiation undertaken? If no, please
indicate so in writing and detail the basis for such a refusal.
Mr. Dogan and or Mr. Leslie, please also subpoena Sargent Paul Sifre and Officer Schaur. Please propound to DDA Young the videos I am attaching
once again, on of the moments just prior to arrest with Sifre, where Sargent Sifre violates fundamental tenants of domestic violence victim advocacy
wherein he engages in "blame the victim" behavior (Coughlin was adjudge a victim of domestic violence on or about 1/23/12 by Master Edmonson, in
two separate cases FV12-00188 and 187..
Further, view the "Sargent Lopez I have a question for you video and attached Motion for New Trial filing in the criminal trespass conviction matter (see
also, 61901 on the N. S. Ct. site) 11 cr 26405, wherein, on 1/13/12, one day prior to the arrest in the case you are attorney of record on rcr2012-065630,
on 1/14/12) RPD Sargent Marcia Lopes is caught on taping admitting to fraud on her part, that of Officer Chris Carter, Jr., landlord Merliss, and opposing
counsel Hill incident to the criminal trespass arrest. Please develop a defense and investigation based upon witness bias an motive, seeking to draw a
connection between the actions a day later by Sifre, Schaur, et al, vis a vis the interaction with Sargent Lopez here. Please also interview and subpoena
Officer Travis Warren, whom Coughlin has recently learned approached and met with his parents at Coughlin's father's medical practice (and Coughlin's
father is both John Kadlic, Reno City Attorney, and perhaps Robert Bony, Esq., Deputy City Attorney's patients) and purportedly sought to "have
Coughlin committed" or somethign along those lines. Please develop a defense and collect and provide investigation relative to the idea that doing so
by the RPD and or Reno City Attorney is violative of Palmer v. Pioneer, and has prejudiced Coughlin's case (what if your family deserted you Biray, in
part, due to fraudulent misrepresentations by local law enforcement with an agenda that includes covering up a number of wrongful arrests potentially
exposing them to both criminal and civil penalties? What would you think of a public defender and his assistant who had not done jack to advocate on
your behalf? Who had not sent out a single subpoena? Why haven't you collected the dispatch tapes, not just the 911 calls. The communications
between dispatch and the RPD are likely way more revelatory than the calls themselves. You are aware, are you not, that RPD Officer Duralde an 5
other officers pulled Coughlin over shortly after midnight on 1/13/12, just after Coughlin had bailed out on the jaywalking arrest, right? You are aware
Coughlin filed a written complaint against Duralde (arresting Officer in the case Goodnight, then Leslie was one in rcr2011-063341, right) on 9/7/12 and
1/8/12, right? You were aware of that, right Biray? Right, Leslie? So, please subpoena the dispatch communications between the RPD and
Ecomm, not just the logs, which is what Ecomm tried to pass off as responsive recently. The audio tapes...Kariann Beechler. She fees it appropriate
to act as a filter to complaints of police misconduct, even though engendering legitimate and perceived fear of substantial immediate harm at the hands of
local law enforcement. Further, please subpoena Deputy Medina and Sargent Bradshaw. Also, review the results of a subpoena duces tecum to the
RPD regarding anything related to Coughlin, especially the 11/15/11 incident with Sargent Tarter...
Can you indicate whether the "misuse of 911" statue appears in any published decisions? Why did you indicate, on the record, in court on 11/6/12 that
you are "unaware of any basis for an opposition" the DDA Young's Motion to Amend? Are you indicating you have failed to receive the voluminous
correspondence and media submission from Coughlin wherein the prejudice to Coughlin and his defense was detailed, especially vis a vis the denial of a
speedy trial (60 days), the spoliation of evidence angle, and the prosecutorial misconduct line of argument (DDA Young attempted to hold a trial on
5/7/12 in violation of the mandatory stay in NRS 178.405 in view of the then still pending Order for Competency Evaluation you, Dogan, procurred at a
Status Conference with Young on 2/27/12, wherein Judge Schroeder is listed as the Hearing Judge. Neither of you have ever denied that in any way.
Then Young violated NRs 178.405 again by filing, at 2:55pm on that day, a document in the associate case rcr2011-063341, despite the file stamping
of 1:31 pm 2/27/12 on Judge Clifton's Order For Competency Evaluation. Neither you, Dogan, nor Young have ever denied the veracity of that
statement, despite it being assert directly to you on numerous occasions.
As to the amended charge, please see the attached Beckett treatment of it (former Nye County DA, SCR 111(10), etc.
Further, please subpoena and interview Officer Alan Weaver, Sargent Brian Dye, and Sargent Oliver Miller to develop more clearly a basis for moving
for a mistrial for prosecutorial and or law enforcement misconduct here (by only against DDA Young should you obtain some reasonable sufficient basis
for viewing his complicity in this mesdeeds, or assent to them in and way,.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv
10 31 12 marked as received by Clerk of Court Orduna and proof of service by Rick Reasoner 0204.pdf
2 27 12 065630 Young and Dogan Clandestine Status Conference leads to SBN SCR 105 Complaint against Coughlin 0434 Nash.pdf
2 27 12 Judge Schroeder status conference clifton order rcr2012-065630 26800.pdf
Chief Marshal Roper and Marshal Harley on setting the record straight in NG12-0435
2 28 and 3 12 and 3 12 and 3 14 nash orders and grievances 26800 0204 0434.pdf
5 4 12 mch goondnight email trespas rmc 26405 loomis young 063341 065630.htm
5 4 12 email goodnight mhc hazlett young trespass loomis.htm
rmc longoni handout demanding payment on transcripts on appeals in violation of nevada law 26405 cr11-2064 cr12-1262 26406 11 tr26800 ocr.pdf
12 21 11 email to rmc regarding no response from Longoni.pdf
10 5 12 stamped 60838 SCR 111 King SBN Susich Motion Show Cause against NNDB and SBN 12-31434.pdf
2 28 12 Contempt Order Nash 26800 26405 065630 00696 063341 bf size reduced.pdf
Download all
From: BDogan@washoecounty.us
Subject: RCR12-065630
Date: Fri, 28 Sep 2012 17:33:45 +0000
Your case with me has been continued to October 30th, at 10:00 A.M.

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

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

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

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

Sent: Thu 11/22/12 1:23 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); odomk@reno.gov (odomk@reno.gov); newmanh@reno.gov
(newmanh@reno.gov)
1 attachment
rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv (13.3 MB)
video of RPD Marcia Lopez admitting to misconduct on 1/13/12 supporting inference of retaliation and motive for 1/14/12 065630 arrest and prosecution
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Judge Howard and Cassandra Jackson want to explain
Sent: Thu 11/22/12 12:56 AM
To: je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
(eifert.nta@att.net); mike@tahoelawyer.com (mike@tahoelawyer.com); patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); skauc@reno.gov
(skauc@reno.gov); robertsp@reno.gov (robertsp@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); wongd@reno.gov (wongd@reno.gov)
6 attachments
DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) , 12 16 11 email to plongoni@charter.net longoni and 12 21 11 email to ballardd@reno.gov regarding
longoni 22176 26800 0204 0435.pdf (22.7 KB) , 10 9 12 Affidavit of Laura Peters 0204 never sent to Coughlin no proof of service, yet file stamped.pdf (1516.8 KB) , 12 15 11 22176 2064
Order by Howard on transcript costs.pdf (92.8 KB) , 12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf (110.8 KB) , 11 16 12 skau grievance materials combined 0204
063341.pdf (1943.8 KB)

How RMC handouts and agreements with Pam Longoni are not violating NRS 189.030 and NRS 4.14(a)

RCA Skau wants to explain his lies about the judge authorize service by email for an unnoticed hearing where Skau sought to argue email service was
insufficient when it came to his people...Then RCA Hazlett-Stevens want to explain his mysterious claims to have not received the Notice of Appeal in
cr12-1262 or why he puts on perjured testimony by Richard G. Hill, Esq., RCA Pam Roberts would like to explain the same for 11 cr 22176. RCA
Allison Ormaas wants to explain what she was whispering in RMC Marshal Harley's ears on 2/27/12 and whether it was about the same failure to chart
follow up on, or report RPD Chris Carter's admission that "Richard Hill pays me a lot of money, so I arrest who he says to and do what he says to do...",
just like Reno City Attorney Chief Criminal Deputy Dan Wong explained he was surely not going to do to when Coughlin made the same report to him on
1/19/12....

SBN Clerk of Court Laura Peters wants to explain how she approved fax filing for Coughlin on 9/11/12, and how her Affidavit of 10/9/12 wound up in the
Disciplinary file only made available to Coughlin 5 days before the hearing (with thousands of pages of filler and duplicates to hide the little it
contained...which in the case of Linda Gardner's grievance, was a mysterious printout from a blog and no more...no cover letter, no nothing...and Kings
email where he purports that the "Clerk of Court" sent him the Order still has not been clarified, though Joey Orduna Hastings, Clerk of Court of the
Second Judicial District Court wants to indicate whether she sent it to the SBN, or, more likely, the Clerk of Court of one of the Muni Court Departments
(probably Judge Nash Holmes' in D3, considering her 3/23/12 email to the SBN about Coughlin's clothing choices to check on a traffic citation at a munic
court filing office window...) who got ahold of District Court Judge Linda Gardners April 2009 Order when Judge L. Gardner passed it to her brother,
RMC William Gardner, who refused to recuse himself from Coughlin's criminal trespass case based upon Richard Hill's Complaint, but did manage to
pass his sister's Order around to his fellow Judges and hold meetings with them about how to get back at Coughlin for pointing out things they do that
violate due process rights and other laws. Like those requiring a stay of proceedings when a defendants competency is brought into question. DDA
Young is great at violating those laws, and bossing Judge Sferrazza around in court, demanding he take into custody anyone who doesn't do just exactly
what DDA Young wants and or give just exactly the answer he is looking for....

Pat King, Laura Peters and David Clark want to explain how their statements and corresponence with Coughlin respecting his right to issue subpoenas
and waiver of witness fees of fees for subpoena duces tecums departed remarkably from the sudden about face on that issue when the Motions to Quash
started coming in, though the Disciplinary Hearing of 11/14/12 went on just they same, right....

Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper, and Marshal Joel Harley,
Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment violation if the person was guilty of the crime you suspected him of
committing when you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy Sleazy, WCPD Jim Leslie by muscling over
indigent criminal defendants for him when Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to Jimmy's rescue and tells
Coughlin, Leslie at his side, that "I'm going to put my foot up your ass..." Reyes watches defendants get put in jail for months day in day out for doing less
than that....
Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for information on the transmission of the Eviction Order in rjc 2011-
001708 to the Washoe County Sheriff's Office.
Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits of service he files, and Maureen and Roxy's assertions that the
"receipt" of the eviction Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must effect the lockout "within 24 hours of
receipt of the Order"...and Casey Baker, Esq. wants to explain his testimony of 6/18/12 when he explained what he did with the Sheriff's Office on
October 28th, 2011...and Reno Carson Messenger service want to explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple minutes to 5 pm, and definitely not sooner than 4:48 pm, despite
Machens 11/1/11 Affidavit of Service (that his supervisor Stuchell had to admit was false in that it alleged "personal service" where the WCSO admits no
one was home (and the locksmith totally refutes Hill's testimony of 6/18/12 "they tried to serve it to you but you ran away..." (really, Rich, becaue Casey
didn't testify to that, but he did say that you weren't even there that day, so what do you base that sworn allegations on Rich, besides your desire to mitigate
your liability for all your misdeeds there?).
Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash Holmes got "confused" on in her "sworn testimony"...which is
shaping up to look at lot like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a disbarment, which in Nevada, are
irrevocable as of 2008. To be clear, Judge Nash Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways. The attached audio
from the Hearing and Judges Nash Holmes various Orders (which reveal a disturbing attempt to mix and match various civil and criminal contempt
statutes, some plenary, some summary, and add the transmogrification of a "simple traffic citation Trial" into some sort of Summary Disciplinary
Hearing...which SBN Bar Counsel Pat King is only too happy to sign on to, eager to kick back and rely on SCR 111(5) after having fed Judge Nash
Holmes the instruction to make sure to copy and paste as many sections of the Rules of Professional Conduct into an "Order" that is sure to point out the
burden of proof necessary for a "ethical violation" finding in a Disciplinary Hearing setting. The only thing less transparent than this awkward attempt by
Bar Counsel and Judge Nash Holmes to get 'r done was the brother and sister act by Judge William Gardner and his sister Judge Linda Gardner,
complimented, of course, by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge L. Gardner's April 2009 Order sanctioning
Coughlin, which Washoe Legal Services's Paul Elcano cited as the sole reason for Coughlin's firing (and which begat the Mandamus Petition against L.
Gardner in 54844, the wrongful termination suit against WLS in 60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner refused to
recuse himself from, etc., etc.
WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS 178.405 and the communications with RMC Judge Nash Holmes
regarding the 2/27/12 Order for Competency Evaluation that should have prevented her from even holding the Trial (the one that occurred right after RMC
Marshal Harley served a civil eviction appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve Coughlin the Order to Show
Cause in cv11-03628 that Coughlin had already received in connection with his being the attorney of record and an e-filer on that matter...see Caplow).
RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about their misconduct in 11 CR 26405 and the extent to which Richard
Hill and his client, Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405 and 61901.
Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v. Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on
that too..
RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who was working that night of the 8/20/11 arrest that started a year in
which Coughlin was arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one for "misuse of 911" even though Coughlin
received two protection orders in FV12-00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the night upon his walking to his
car after being released from jail on a 15 degree night on 1/13/12, where five other RPD Officers helped Officer Duralde with the pressing matter of the
sudden disappearance of Coughlin's license plate...), (all suspiciously close in time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12
with the RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying that dispatch reported to himself and RPD Officer's Alaksa and Rosa
that night about "a possible fight" thus supporting their reponse and the associated Terry Stop weapons check frisk pat down and custodial arrest for a
misdemeanor allegedly occuring outside their presence after 7 pm:
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 toNRS 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.
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-Mart are in a long term business partnership where the 2nd St. Wal-
Mart is on tribal land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely making misdemeanor petty theft/shoplifting
tribal officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a chance to explain how she prosecutes cases based upon arrests by
tribal officers for misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal officers under NRS 171.1255.
contributed greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr. Garin/Ms. Nordstrom should be provided transcripts from
the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
spouse.
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts with my father, Palmer v. Pioneer, etc.
So, this is the Elcano approach...he gets an email on 4/19/12 that is a written employment law centered complaint from an employee...and he has the
employee suspended within days thereafter...then claims to have not received the email, then adopts some Duluth Model "Power and Control" wheel co-
opting or leveraging of "treatment" or armchair psychiatry...
Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79. Stephen Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction
resulting in 6/7/12 temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82 (twice Coughlin's RMC court appointed counsel, allowed to
withdraw with pay both times, refused to advocate in any way). Gammick, McGeorge '82. Springgate, McGeorge '85 (opposing consel in ng12-0435
asking for sanctions in divorce case closing argument). Kandaras, McGeorge '91 (Deputy District Attorney involved in warrantless seizure of Coughlin's
smart phone. DDA Z. Young, McGeorge '04. Hazlett-Stevens, McGeorge, '06.
What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned Coughlin about "recording devices" and or whether he was
recording BEFORE the one restroom break, purposefully changing the order of the questioning and the restroom break to suggest some furtive activity on
Coughlin's part, which Judge Nash Holmes then further attempted to amplify in her assertion that Marshal Joel Harley was ordered to follow Coughlin
into the restroom and that a Marshal asserted to her that Coughlin "disassembled a recording device" in the restroom and "hid a part or portion of it in the
restroom"
Fraud on the court Conduct of counsel in omitting portion of deposition when deposition is read into record, and giving impression that entire document is
being proffered, resulting in buttressing of his party's position is fraud on the court warranting the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172,
subd. 1(a, d). Sierra Glass & Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119, rehearing denied.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events and when she asked Coughlin her questions about recording, considering when a
restroom break took place an exactly what it is she asked Couglin and when, and what his responses were, and when some allegations by "the Marshal" were made, what they consisted of,
etc.. on 3/12/12 in 11 tr 26800 the audio transcript reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some extreme form of mental illness. during the trial I asked the defendant attorney
repeatedly if he was recording the proceedings he denied that vehemently a few times and then he quote took the fifth a few other times and then he requested to be excused to go to
the bathroom and the Marshal later reported to me that while the gentleman was in the bathroom he disassembled a recording device in his pocket and took the memory out of it and
it was later found in that, uh, by the Marshal no one else had gone into the bathroom and that was retrieved and it was put into his possession at the Sheriff's office and when they
booked him into jail for the contempt charge that was booked into evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme Court Rule
229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering
from some extreme form of mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under
oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her mental processes" loophole, as he has done.
Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to
get his driver's license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez and Officer Carter's explanations thereof in 11 CR 26405 and 61901) and
three days spent in jail, upon being released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John Tarter, RMC Marshal Joel Harley, just before Trial (when
Judge Nash Holmes couldn't be found and WCPD Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of Coughlin in rcr2012-065630 at 1:31 pm...and the 11
TR 26800 Trial starting late, not at 1 pm as noticed, but at 3 pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein they brainstormed ways of
combating Coughlin's championing of due process rights for the disenfranchised...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything or whether he possessed a "recording device" until AFTER the
one and only restroom break Judge Nash Holmes mentions on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER THE
RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND
WHICH OCCURED AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY CITY
ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM
IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF
THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on
in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and
prosecutors and public defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that neither
YOung nor Dogan wish to testify about...but which seems to have been held anyways after a written communication of its being reset was transmitted to Coughlin by Dogan,
wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about Coughlin that RMC Administrative Judge
William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for Competency
Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of
approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege
theft or possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That,
and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the WCPD
Motion to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in cr12-0376 didn't
even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within
NRs 5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final
appealable order, Judge Nash HOlmes continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 .
But adjudication by a trial judge of a contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the Oliver case that a
person charged with contempt before a "one-man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in
his immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also orders no
sufficiently detailed or capable of being known how to comply with, not sufficient warning, violate Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the "immediate presence" of the Court. Maybe Marshal Harley and some
other Marshal have misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is entirely misleading an
inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an
inappropriate, particulary where she not only purports to issue a "summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes appears to try to
transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to
sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat
King wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some musings by Judge Nash Holmes purporting to
make "rulings" finding "by clear and convincing evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to
Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge Gardners Administrative
Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was
dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension
Order in cr11-2064, which was denied based upon a civilpreparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in place with this Pam
Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the
transcript's preparation would absolutely not start until a down payment was made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly hung up the
phone on him and otherwise ignored his communications (there may be an issue of the email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an
affidavit as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf
too...
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435 (stamped as "received" by the SBN from the "Clerk of Court" of
some still unnamed Court (I'd bet its from the RMC Clerk of Court, whom King purported to have certified documents from a Court she doesn't even work for at the 11/14/12
Disciplinary Hearing...but then again, Panel Chair Echeverria allow WLS's Elcano to certify documents just because he claimed to have watched a tape of a hearing, where Elcano
is neither a licensed attorney, nor does he work for any Court....), depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12 email to
Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna
Hastings that would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent contention that the
NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have anything
to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the problems with the practice
of this attorney being experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what should be a simple traffic citation case are self-explanatory and are included,
together with copies of massive documents Me. Coughlin has fax filed to our court in this case. Audio recordings of two of my hearings in this matter are also included. He failed to appear for the second one this
past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate
him between cases very easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
th
St. #2 Reno NY 89512), although I heard today he may be living in his
vehicle somewhere. We do have an address for his mother, however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr.Coughlin late last year that is now on appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently
pending in his court with Mr. Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order, simply because they appear to demonstrate that he is quickly
decompensating in his mental status. Our staff also made you some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him and him and him and him and him in
Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You can see his behavior in my traffic citation case does not appear to bean isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed
for Contempt of Court and they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your pursuit of this matter. Mr.Coughlin has positioned himself as a vexatious litigant in our court,
antagonizing the staff and even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a caseof some urgency, and I apologize for taking two days to get this package to you;
our IT person was ill and could not make the copies of the audios of Mr.Coughlin's hearings until today, and I felt it was important that the audios be included in the materials to be considered by the State Bar. On
February 27, 2012, Mr. Coughlin told me he was actively practicing law and had appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of law in
Northern Nevada and could be jeopardizing someone's freedom or property interests. "
Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily proven to be patently false at Disciplinary Hearings (to the extent one is allowed to offer
such proof, which Panel Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5) vacation with his "Clerk of Court" Laura Peters...whose lies about
SCR 105(4) resulted in Panel Chair Echeverria quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King filed on behalf of his former co-worker at the
AG's Office, Reno City Attorney Dan Wong...While the other Reno City Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve you by email"...
Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts with my family
Sent: Thu 11/22/12 12:37 AM
To: skent@skentlaw.com (skent@skentlaw.com); eifert.nta@att.net (eifert.nta@att.net); complaints@nvbar.org (complaints@nvbar.org); cvellis@bhfs.com (cvellis@bhfs.com); davidc@nvbar.org
(davidc@nvbar.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com (mike@tahoelawyer.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); jgarin@lipsonneilson.com (jgarin@lipsonneilson.com); snordstrom@lipsonneilson.com (snordstrom@lipsonneilson.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); roperj@reno.gov (roperj@reno.gov); duralden@reno.gov (duralden@reno.gov); duraldej@reno.gov (duraldej@reno.gov);
lopezm@reno.gov (lopezm@reno.gov); carterc@reno.gov (carterc@reno.gov); tarterj@reno.gov (tarterj@reno.gov); leedyw@reno.gov (leedyw@reno.gov); lookt@reno.gov (lookt@reno.gov);
sifrep@reno.gov (sifrep@reno.gov); weavera@reno.gov (weavera@reno.gov); millero@reno.gov (millero@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us); voldenburg@rsic.org (voldenburg@rsic.org); kcrawford@rsic.org (kcrawford@rsic.org); dbraunworth@rsic.org
(dbraunworth@rsic.org); jreyes@washoecounty.us (jreyes@washoecounty.us); stuttle@washoecounty.us (stuttle@washoecounty.us)
8 attachments
10 25 12 61901 opposition (Filed Motion Motion for leave to file opposition or opposition to scr 111(4) petition)_001 - Copy.pdf (225.1 KB) , 11 2 12 file stamped complete notice of errata
and revised supplemental 26405 1708 0204.pdf (884.6 KB) , contempt scr 119(2) in re coughlin 60838 (Filed Motion Motion for Order to Show Cause or Contempt Order Against Bar
Counsel and NNDB)_001.pdf (294.3 KB) , 6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf (2.2 MB) , 6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and
11.25(3)(c) lacking due process 60838 0204.pdf (129.1 KB) , 11 9 12 stamped 60302 Notice of Lack of Access with both parts of exhibit 1.pdf (5.0 MB) , 10 31 11 receipt 1708 lockout
wcso 26405 03628 60331 within 24 hours hill tried to get at 5 01pm versus baker oct 28th testimony from Memo of Costs - EX 1 (4-3-12).pdf (19.7 KB) , 11 1 11 locksmith receipt wcso
lockout from Memo of Costs - EX 1 (4-3-12)-2 compare 6 18 testimony when the locksmith finally got there.pdf (79.3 KB)
Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper, and Marshal Joel Harley,

Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment violation if the person was guilty of the crime you suspected him of
committing when you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy Sleazy, WCPD Jim Leslie by muscling over
indigent criminal defendants for him when Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to Jimmy's rescue and tells
Coughlin, Leslie at his side, that "I'm going to put my foot up your ass..." Reyes watches defendants get put in jail for months day in day out for
doing less than that....

Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for information on the transmission of the Eviction Order in rjc 2011-
001708 to the Washoe County Sheriff's Office.

Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits of service he files, and Maureen and Roxy's assertions that the
"receipt" of the eviction Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must effect the lockout "within 24 hours of
receipt of the Order"...and Casey Baker, Esq. wants to explain his testimony of 6/18/12 when he explained what he did with the Sheriff's Office on
October 28th, 2011...and Reno Carson Messenger service want to explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple minutes to 5 pm, and definitely not sooner than 4:48 pm, despite
Machens 11/1/11 Affidavit of Service (that his supervisor Stuchell had to admit was false in that it alleged "personal service" where the WCSO admits no
one was home (and the locksmith totally refutes Hill's testimony of 6/18/12 "they tried to serve it to you but you ran away..." (really, Rich, becaue Casey
didn't testify to that, but he did say that you weren't even there that day, so what do you base that sworn allegations on Rich, besides your desire to
mitigate your liability for all your misdeeds there?).
Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash Holmes got "confused" on in her "sworn
testimony"...which is shaping up to look at lot like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash Holmes testified falsely at the 11/14/12 Disciplinary
Hearing in a number of ways. The attached audio from the Hearing and Judges Nash Holmes various Orders (which reveal a disturbing
attempt to mix and match various civil and criminal contempt statutes, some plenary, some summary, and add the transmogrification of a
"simple traffic citation Trial" into some sort of Summary Disciplinary Hearing...which SBN Bar Counsel Pat King is only too happy to sign on
to, eager to kick back and rely on SCR 111(5) after having fed Judge Nash Holmes the instruction to make sure to copy and paste as many
sections of the Rules of Professional Conduct into an "Order" that is sure to point out the burden of proof necessary for a "ethical violation"
finding in a Disciplinary Hearing setting. The only thing less transparent than this awkward attempt by Bar Counsel and Judge Nash
Holmes to get 'r done was the brother and sister act by Judge William Gardner and his sister Judge Linda Gardner, complimented, of
course, by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge L. Gardner's April 2009 Order sanctioning Coughlin,
which Washoe Legal Services's Paul Elcano cited as the sole reason for Coughlin's firing (and which begat the Mandamus Petition against L.
Gardner in 54844, the wrongful termination suit against WLS in 60302, the criminal trespass conviction in 11 CR 26405 that Judge W.
Gardner refused to recuse himself from, etc., etc.
WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS 178.405 and the communications with RMC Judge Nash
Holmes regarding the 2/27/12 Order for Competency Evaluation that should have prevented her from even holding the Trial (the one that
occurred right after RMC Marshal Harley served a civil eviction appeal document on behalf of the process server Richard G. Hill, Esq. hired
to serve Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received in connection with his being the attorney of
record and an e-filer on that matter...see Caplow).
RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about their misconduct in 11 CR 26405 and the extent to
which Richard Hill and his client, Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405 and 61901.
Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v. Wells Fargo, LLC. Officers Wesley and Look wanted
to weigh in on that too..
RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who was working that night of the 8/20/11 arrest that
started a year in which Coughlin was arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one for "misuse of
911" even though Coughlin received two protection orders in FV12-00187, and -00188), with Officer Duralde pulling Couglin over in the
middle of the night upon his walking to his car after being released from jail on a 15 degree night on 1/13/12, where five other RPD
Officers helped Officer Duralde with the pressing matter of the sudden disappearance of Coughlin's license plate...), (all suspiciously close in
time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12 with the RPD) wanted to weigh in on the misconduct attendant
to Duralde's testifying that dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a possible fight" thus
supporting their reponse and the associated Terry Stop weapons check frisk pat down and custodial arrest for a misdemeanor allegedly
occuring outside their presence after 7 pm:
(e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the manner provided in NRS 171.137;
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-Mart are in a long term business partnership where the 2nd St.
Wal-Mart is on tribal land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely making misdemeanor petty theft/shoplifting
tribal officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a chance to explain how she prosecutes cases based upon
arrests by tribal officers for misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal officers under NRS 171.1255.
contributed greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr. Garin/Ms. Nordstrom should be provided transcripts
from the 11/14/12 Hearing.

NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
spouse.
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts with my father, Palmer v. Pioneer, etc.
So, this is the Elcano approach...he gets an email on 4/19/12 that is a written employment law centered complaint from an employee...and
he has the employee suspended within days thereafter...then claims to have not received the email, then adopts some Duluth Model
"Power and Control" wheel co-opting or leveraging of "treatment" or armchair psychiatry...
Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79. Stephen Kent, McGeorge '80. RMC Judge Howard
(Wal-Mart conviction resulting in 6/7/12 temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82 (twice Coughlin's RMC
court appointed counsel, allowed to withdraw with pay both times, refused to advocate in any way). Gammick, McGeorge '82.
Springgate, McGeorge '85 (opposing consel in ng12-0435 asking for sanctions in divorce case closing argument). Kandaras, McGeorge
'91 (Deputy District Attorney involved in warrantless seizure of Coughlin's smart phone. DDA Z. Young, McGeorge '04. Hazlett-Stevens,
McGeorge, '06.
What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned Coughlin about "recording devices" and or
whether he was recording BEFORE the one restroom break, purposefully changing the order of the questioning and the restroom break to
suggest some furtive activity on Coughlin's part, which Judge Nash Holmes then further attempted to amplify in her assertion that Marshal
Joel Harley was ordered to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin "disassembled a recording
device" in the restroom and "hid a part or portion of it in the restroom"
Fraud on the court Conduct of counsel in omitting portion of deposition when deposition is read into record, and giving impression that
entire document is being proffered, resulting in buttressing of his party's position is fraud on the court warranting the imposition of
sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d). Sierra Glass & Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119,
rehearing denied.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events and when she asked Coughlin her questions about recording, considering when a
restroom break took place an exactly what it is she asked Couglin and when, and what his responses were, and when some allegations by "the Marshal" were made, what they consisted of,
etc.. on 3/12/12 in 11 tr 26800 the audio transcript reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some extreme form of mental illness. during the trial I asked the defendant attorney
repeatedly if he was recording the proceedings he denied that vehemently a few times and then he quote took the fifth a few other times and then he requested to be excused to go to
the bathroom and the Marshal later reported to me that while the gentleman was in the bathroom he disassembled a recording device in his pocket and took the memory out of it and
it was later found in that, uh, by the Marshal no one else had gone into the bathroom and that was retrieved and it was put into his possession at the Sheriff's office and when they
booked him into jail for the contempt charge that was booked into evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme Court Rule
229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering
from some extreme form of mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under
oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her mental processes" loophole, as he has done.
Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to
get his driver's license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez and Officer Carter's explanations thereof in 11 CR 26405 and 61901) and
three days spent in jail, upon being released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John Tarter, RMC Marshal Joel Harley, just before Trial
(when Judge Nash Holmes couldn't be found and WCPD Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of Coughlin in rcr2012-065630 at 1:31 pm...and
the 11 TR 26800 Trial starting late, not at 1 pm as noticed, but at 3 pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein they brainstormed ways of
combating Coughlin's championing of due process rights for the disenfranchised...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything or whether he possessed a "recording device" until AFTER the one and only restroom break Judge Nash
Holmes mentions on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO
TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS
AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S
ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on
in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors and public defenders were non
too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that neither YOung nor Dogan wish to testify about...but which seems to have been held
anyways after a written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst
Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately 11/28/12, which resultd in
Young promptly amending his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab makes his so charging
Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his
own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in cr12-0376 didn't
even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a
contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the Oliver case that a person charged with contempt before a "one-man grand jury" could not be
summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in
both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being known how to comply with, not sufficient warning, violate Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe
she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to issue a "summary criminal contempt" conviction against an attorney, but
also where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs
to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes
phone in her testimony, and it probably won't even be sworn testimony, but rather just some musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of things
outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes,
Judge William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the
appeal was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was
denied based upon a civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the
audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down payment was made. Plus, even where Coughlin
caved to the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his communications (there may be an issue of the email Longoni holding out to the public issuing a "bounceback"...but
she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435 (stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed Court (I'd bet its from the
RMC Clerk of Court, whom King purported to have certified documents from a Court she doesn't even work for at the 11/14/12 Disciplinary Hearing...but then again, Panel Chair Echeverria allow WLS's Elcano to certify
documents just because he claimed to have watched a tape of a hearing, where Elcano is neither a licensed attorney, nor does he work for any Court....), depending upon whom you ask and what King means by "Clerk of
Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna
Hastings that would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge
L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the problems with the
practice of this attorney being experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what should be a simple traffic citation case are self-explanatory and are
included, together with copies of massive documents Me. Coughlin has fax filed to our court in this case. Audio recordings of two of my hearings in this matter are also included. He failed to appear for the
second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate
him between cases very easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
th
St. #2 Reno NY 89512), although I heard today he may be living in his
vehicle somewhere. We do have an address for his mother, however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently
pending in his court with Mr. Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order, simply because they appear to demonstrate that he is quickly
decompensating in his mental status. Our staff also made you some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him and him and him and him and him
in Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You can see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed
for Contempt of Court and they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court,
antagonizing the staff and even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a case of some urgency, and I apologize for taking two days to get this package to you;
our IT person was ill and could not make the copies of the audios of Mr. Coughlin's hearings until today, and I felt it was important that the audios be included in the materials to be considered by the State Bar.
On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of law in
Northern Nevada and could be jeopardizing someone's freedom or property interests. "
Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily proven to be patently false at Disciplinary Hearings (to the extent one is allowed to offer
such proof, which Panel Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5) vacation with his "Clerk of Court" Laura Peters...whose lies about
SCR 105(4) resulted in Panel Chair Echeverria quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King filed on behalf of his former co-worker at the
AG's Office, Reno City Attorney Dan Wong...While the other Reno City Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve you by email"...

Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 16 11 voicemail from Tim regarding Washoe Legal Service's Elcano's attempt to settle lawsuit with treatment routine 60302 ng12-0204.mp3
3 8 11 voice mail from Tim Coughlin to Zach Coughlin regarding SBN's Coe Swobe's contacting him for WLS's Elcano ng12-0204.mp3
LITIGATION HOLD NOTICE TO THE RENO MUNICIPAL COURT RMC Ballard
4 27 09 email from WLS's Elcano to Coughlin to call SBN's Swobe ng12-0204.pdf
June_2008_Nevada_Lawyer In re Mirch compare to ng12-0204.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal harley.pdf
2 27 12 Order For Competency Evaluation Judge Clifton RCR2012-065630 1 31 pm file stamp rjc rmc schroeder nash holmes young dogan 26800 26405 loomis - Copy.pdf
3 7 12 rmc 11 cr 26405 loomis gardner 178.405 Coughlin Trial Setting 26800 00696 063341 065630.pdf
3 8 12 26800 nash barker denial return of bail $100 wcso rmc 0204 00696.pdf
3 8 12 Coughlin Trial Setting 11 cr 26405 april 10 8 am trial loomis gardner 650630 26800 0032 0376.pdf
3 9 12 needs stamped 11 tr 26800 0204 MOTION TO RETURN CELL PHONES; MOTION TO SET ASIDE SUMMARY.pdf
3 12 12 rmc 11 tr 26800 order judge nash holme suspending case and referring to the SBN enhanc.pdf
3 13 12 158 pm 26800 Nash rmc SUA SPONTE ORDER DENYING RELIEF SOUGHT IN IMPROPER DOCUMENT.pdf
3 13 12 1238pm 11 TR 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT RPD WCSO RMC RJC NASH KING CLARK SBN check.pdf
3 13 1238 pm 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT 0204 0434.pdf
3 16 12 sbn grievance king with ng12-0434 nash 26800 of 3 14 12 and ng12-0434 4 10 09 linda gardner sanction order 00696 26405.pdf
3 30 12 nash order releasing property 26800 0204 0434 cleaned up-3.pdf
5 4 12 goodnight email 063341 26405 26800 regarding mhc loomis hazlett-stevens 0204 0434.pdf
5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844 dd.pdf
5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844.pdf
Download all

Sent: Mon 11/19/12 6:44 AM
To: christensend@reno.gov (christensend@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); lefcourt@lefcourtlaw.com (lefcourt@lefcourtlaw.com); roperj@reno.gov (roperj@reno.gov)
Dear Sirs,
I submit this respectfully to each of you. If the RMC or the Marshals have a counsel of record, please let me know, otherwise, I have some questions.
First, is it appropriate for Suzanne Ramos to be exhorting individuals to seek protection orders against me, particularly given her connection to Washoe
Legal Services, whom I am suing, if that is in fact what Ms. Ramos is doing, if not, no disrespect meant to Ms. Ramos...However, just the other day she
and Chief Criminal Deputy City Attorney Wong laughed malevolently at me in the elevator, cackling profusely, as the idea of my being able to partake in
any of the victim's services offered, even if my victimizer's may, in some instances, be local law enforcement...this was an echo back to the 1/14/12
"misuse of 911 arrest"....
One, did the "Clerk of Court" for the RMC transmit Judge W. Gardner's sister's April 2009 Order to the State Bar of Nevada at any time. Two, under
what authority does the RMC's Donna Ballard or Cassandra Jackson, or anyone therein have to be "certifying" Orders from the Second Judicial District
Court for the SBN? Three, of the audio transcripts provided by the RMC to the SBN on the prosecutions and citations related to Zachary B. Coughlin,
which were provided to the SBN, and which were provided to the Screening Panel, and which were certified, and which were not certified.
What is the cost of a "certified" audio transcript? What is the difference between a "certified" audio transcript, and the audio transcript provided to
Coughlin's mother, Mary Barker for the 2/27/12 Trial in 11 TR 26800.
THE RMC AND ITS MARSHALS ARE HEREBY PLACED ON A LITIGATION HOLD NOTICE (TO WHATEVER EXTENT THEY WERE NOT
ALREADY) AS TO ALL MATERIALS AND OR DOCUMENTATION RELATED TO THE 2/27/12 "MISDEMEANOR OF CRIMINAL
CONTEMPT" (CITING TO A CIVIL STATUTE, AND NOT EVEN THE SUMMARY CONTEMPT ONE, NRS 22.030 (WHERE IS THE AFFIDAVIT
OF MARSHAL JOEL HARLEY OR ANY OTHER MARSHAL, as required by NRS 22.030 for alleged conduct not occurring in the 'immediate
presence' of the court. WHOSE REPORTS TO JUDGE NASH HOLMES WERE RELIED UPON IN HER ORDER AS RENDERED ON 2/27/12,
AND AGAIN AS REDUCED TO WRITING ON 2/28/12 AND 3/12/12? PLEASE PROVIDE A COPY THEREOF).
Judge Nash Holmes' testimony at the SBN Disciplinary hearing on 11/14/12 was completely false in a number of instances. Please have Judge Nash
Holmes review the audio transcript of that Trial in 11 TR 26800 and speak with the Marshals, and court staff and consider whether there aren't some
material misrepresentations being made, or which were made, under oath, at the 11/14/12 Disciplinary Hearing. The audio transcript of the hearing
clearly controverts Judge Nash Holmes depiction of a numbers of events during that Trial, chief of which concerns her testimony that she asked Coughlin
questions directed to "recording" and "recording devices" at a number of of points during the trial, which is false. There was one, and only one brief
exchange in that regard. Further, Judge Nash Holmes explicitly misrepresented the order of the one restroom break in relation to the one instance of
Judge Nash Holmes briefly questioning Coughlin about "recording" or "recording devices". The audio transcript does contain a statement by Judge
Nash Holmes indicating "I saw it..I saw it" when Coughlin noted for this record that Marshal Harley was whispering in DCA Ormaas's ears (or vice
versa)...and DCA Ormaas was apparently so comfortable during particularly contentious points in the trial (such as when Judge Nash Holmes ordered a
Marshal to escort Coughlin to the restroom, and refused to allow Coughlin to take even one sheet of yellow legal paper with him, whereupon Ormaas
jokingly asked: "Can Terry (RMC Marshal) escort me to the restroom?". Perhaps the time for doing hit pieces on Coughlin is over and it might be
useful to ask yourself whether DCA Ormaas and Marshal Harley have behaved in a manner that has caused the RMC undue burden. To wit: did
Marshal Harley create an appearance of impropriety and or violate the "courthouse sanctuary" doctrine in interrupting a plea bargaining conference
between Ormaas and Coughlin to attempt to personally serve Coughlin with an Order to Show Cause in the Richard G. Hill, Esq led summary eviction
from Coughlin's former home law office case (and despite the rulings therein, 11 TR 26800 bares a strong connection to Mr. Hill and that eviction case,
which begat the criminal trespass case, which begat the custodial jaywalking case, which begat the "misue of 911" case, which begat arrests on 6/28/12
and 7/3/12, and threats thereof on 9/21/12... ), on appeal in CV11-03628. Was Marshal Harley smirking when he attempted to effect service on
Coughlin on behalf of WCSO Deputy Machen (whose 11/7/11 Affidavit of Service in the trial court summary eviction trial in that matter, rjc Rev2011-
001708, incorrectly asserted personal service upon Coughlin of the lockout Order on 11/1/11, for which his supervisor Liz Stuchell subsequently admitted
in writing meant merely posting the Order on the former home law office's door when the tenant was not there. Why was such an Order to Show Cause
even being served, in light of Caplow, and Coughlin having been a registered efiler at that time, and therefore served electronically the Order to Show
Cause (at a 3/23/12 Hearing) on 2/8/10 and the Notice of Entry of Order thereof on 2/10/10. Perhaps Hill and Baker were unsure of the import of
Caplow where the opposing counsel was appearing pro se...but to a indigent defendant who had already been denied a single continuance by Judge
Howard (based upon his mistaken belief that Coughlin had done anything contributing to the continuance of the 11/14/11 original Trial date in 11 CR
22176 (which, in the final three minutes tacked onto the record in that matter, Judge Howard admits, though his amelioration consisted not of continuing
the matter and allowing an innocent man, Coughlin, to arrange to address the unlawful rent distraint Richard Hill was applying to the excuplatory video,
audio and other materials that will demonstrate that Wal-Mart had previously expressed a specific retaliatory animus and plan of action against Coughlin
(something AP Associate Frontino testified to/admitted somewhat at Trial). Perhaps the Hastings law school connection between Pamela Roberts and
someone Coughlin is suing, Caryn Sternlicht of Washoe Legal Services contributed to Ms. Roberts abruptly backing out of the continuance she had
agreed to in writing (Coughlin had been evicted less than one month prior, with an intervening criminal trespass arrest). Its time for City Attorney
Kadlic and the Reno Police Department to cease telling themselves they are doing Coughlin some sort of favor or "helping him get help", and, rather,
address the extent to which, beginning wit an extremely suspect arrest on 8/20/11 (a retaliatory overcharging of "felony grand larceny" by the RPD in
rcr2011-063341 resulted in Coughlin being hit very hard in a number of ways incident to a sudden 7 day jail stay, during which time a summary eviction
order was served. Thirteen days after being released from custody incident to that first arrest, came the 9/9/11 Wal-Mart arrest (which was violative of
Nevada law in that, especially where City Attorney Roberts and Wal-Mart readily concede that no "citizen's arrest" or "shopkeeper's privilege" was
present in that matter, as the audio transcript reveals, and NRS 171.1255 forbids tribal police from making misdemeanor arrests, which is exactly what
they did in that case, 11 CR 22176. The audio record is devoid of a jurisdictional finding for that and other good reasons, including, the fact that
whether or not Coughlin has any tribal or Indian blood was not established, which means a jurisdictional basis for the prosecution was not either, in which
case, the conviction may not stand, as the appropriate forum may well be in a Tribal Court. Regardless, the RMC's practice of presenting the method of
and manner of affecting the preparation of transcripts in criminal appeals is directly at odds with Nevada law, and arguably illegal, and Coughlin hereby
requests that the RMC and or City of Reno immediately arrange for the transcripts in all cases he has appeared before the RMC in (and in all hearings in
all those cases) immediately be ordered prepared and provided to Coughlin within 10 days. The mitigation of damages incident to the torts committed
upon Coughlin arguably dictate that this be done, and at no charge whatsoever, whether up front or down the road.
Please have Judge Nash Holmes and Marshals Harley, Coppa, Townsend, and Deighton prepare affidavits immediately dispelling the damaging and
material misrepresentations or omissions they have made (whether purposefully, negligently, or inadvertently) that have arguably cost a patent attorney in
the prime of his career earning wise his livelihood, and therefore, subjected this municipality to significant liability, regardless of what immunity only a
select few of those individuals may enjoy. A notice of appeal of the "misdemeanor of criminal contempt" NRS 22.010 conviction was filed, and that is
a final appealable order (and one really has not other choice but to view it as a summary contempt conviction given the summary nature of the manner in
which is was handled...though, contrary to Judge Howard's indications to Coughlin in the last three minutes of the audio transcript in 11 CR 22176, such
orders are, in fact appealable, even where the summary incarceration has already been served. Please consider whether the RMC has a duty to transmit
the ROA and order the preparation of transcripts in both 11 cr 22176 (for both the summary contempt conviction and the petty larceny conviction) and 11
tr 22176 to the District Court immediately. Additionally, please indicate in writing the City Attorney's stance on appointing an alternate prosecutor and
or the recusal of all RMC Judges from matters involving Coughlin. Additionally, the City of Reno might want to consider whether SBN Pat King is using
the RMC to make his job easier, where he seeks to obtain "convictions" that specifically find by the burden of proof required in disciplinary hearings to
prove ethical rules violations under Schaefer (the "by clear and convincing evidence" language echoed in Judge Nash Holmes' March 12th, 2012 Order,
which looks particularly influenced by King and the SBN now that the SBN has been forced to release certain internal documents and submissions.
Additionally, given recent admissions by the WCPD and information gleaned from materials it too has finally been forced to release, the RMC and
Judge Nash Holmes are hereby requested to consider whether the content of her 3/14/12 grievance to the SBN against Coughlin may need some revising,
and request is hereby made for an Affidavit by Judge Nash Holmes addressing such request, respectfully made. Lastly, Couglin hereby requests, that,
given the circumstances, and his indigency, the complete files and all audio transcripts and other materials subpoenaed (and please consider whether the
SBN has finally been forced to recognize the extent to which its agents and or the NNDB and or Panel made representations to Coughlin that materially
alter the viability of the views on the adequacy of the technical compliance with NRCP 45 by Coughlin's subpoenas as set forth by City Attorney Bony,
Chief Criminal Deputy City Attorney Wong, and City Attorney Skau given the dictates of SCR 105(4).
Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to determine whether underlying circumstances of
conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada
v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39
2. Indictment
Sincerely,
new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105 Complaint
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
rmc longoni handout demanding payment on transcripts on appeals in violation of nevada law 26405 cr11-2064 cr12-1262 26406 61901 60302 11 tr26800.pdf
cr12-1018 rmc transcript pam longoni failure to prepare and forward on appeal nrs 189.030otjl.pdf
DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf
RMC transcripts on appeal failure to pepare Pam Longoni cr12-1018otjl.pdf
cr12-1018 rmc transcript pam longoni failure to prepare and forward on appeal nrs 189.030.pdf
12 16 11 email to plongoni@charter.net longoni and 12 21 11 email to ballardd@reno.gov regarding longoni 22176 26800 0204 0435.htm
6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
Download all

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
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204 25 page discovery northwind ncs krebs reduced size.pdf
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-000018 0204 Leed.pdf
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder ptthoa 0204.pdf
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
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
Tribal Police not allowed to arrest for misdemeanors FW: Case No. RCR2011-063341
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

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.
spouse.
(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.
(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:
(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;
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:
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.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar number must be conspicuously displayed on
the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the receiving
party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
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.
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

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
Jun 27
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.
Jun 27
Hi zachcoughlin,
Jun 28
Hi zachcoughlin,
Jun 28
Hi zachcoughlin,
Vox ox noreply@voxox.com
to me
to me
to me
to me
SUBPOENA AND SUBPOENA DUCES TECUM ATTACHED
Jun 28
Hi zachcoughlin,
to me
Sent: Fri 11/09/12 2:41 AM
To: renodirect@reno.gov (renodirect@reno.gov)
10 attachments
SAM_0201.3gp.001 (4.0 MB) , subpoena rpd rosa 063341 911 dispatch.pdf (575.2 KB) , rpd alaksa 063341 rpd 26405.pdf (588.1 KB) , rcr2011-063341 subpoena scott weese reno
emergency communications 911 dispatch.pdf (590.8 KB) , 063341 subpoena reno emergency communications dispatch 911 26405 1708.pdf (626.7 KB) , subpoena reno police department
rpd custodian of records 063341.pdf (611.2 KB) , subpoena city of reno emergency dispatch services reno emergency communications rcr2011-063341.pdf (588.4 KB) , subpoena savannah
montgomery reno emergency communications dispatch 911 063341.pdf (601.6 KB) , 063341 subpoena to emergency reno emergency communications dispatch 911 26800 26405.pdf (5.8
MB) , fax email letter to rmc administrator cassandra jackson subpoenaa 26800 26405 063341.pdf (51.8 KB)
Zach Coughlin, Esq. (law license in Nevada temporarily suspended)
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949.667.7402
October 26th, 2012,
TO:
Reno Direct, RMC administrator Cassandra Jackson, City Attorney Hazlett, Judicial Assistant Lisa Wagner
Reno Municipal Court
775-326-6612 office
775-334-2399 duty phone
send via US Mail, Fax and Email

Dear Reno Direct/ Administrator of Reno Municipal Court Cassandra Jackson

On October 22nd, 2012 in RCR2012-063341 Judge Sferrazza rendered an Order allowing me to serve subpoenas and subpoena duces tecums without first paying the statutory
fees. It is unclear whether I will ultimately be responsible for them, but the Judge was clear that I could served them without making the payments (an IFP, I suppose).

Please find those subpoena and subpoena duces tecums attached. The Trial is set to resume November 19th, 2012, so time is of the essence and I appreciate your offices
cooperation in this regard. Please note that of material relevance is what the RPD was told by the dispatchers/emergency services personnel. Additionally, upon information
and belief, not all of the 911 calls have been propounded, despite previous subpoena and or requests by my former public defender, Mr. Goodnight.

In the videos I took of the arrest and the moments prior thereto, it appears that a Tanner Chan is making what I believe to be a 911 call, and I believe others did that night as well,
August 20th, 2011 between approximately 11:18 pm and midnight in relation to the purported larceny of a cell phone at the skate plaza in front of City Hall in downtowan Reno,
10 N. Center St., Reno NV.

Additionally, none of the dispatch recordings have been propounded and I am requesting that you do so now. I am requesting, but not limiting my request to, all recordings and
or documentation related to what any of the officer's involved in my arrest in RCR2011-063341 communicated or had communicated to them concerning the arrest and events
leading thereto, and those events occurring afterwards, on August 20th, 2011.

Also, I would like all recordings and documentation related to my arrest on November 13th, 2011 in relation to RMC case 11 CR 26405, a criminal trespass arrest involving RPD
Officer Chris Carter Jr. and Sargent Marcia Lopez. Further, I would like any and all recordings or documentation related to me in any way whatsoever. I would prefer that
they be transmitted to me digitally, via email, dropbox, skydrive or some other digitally verifiable means as to the date and content of the transmission.

Please be sure to include all materials related to my arrests in rcr2012-065620 (january 14th, 2012), rmc 12 CR 00696 (January 12th, 2012 custodial arrest for petty larceny at
approximately 3pm at 121 River Rock St., Reno 89501), June 28th, 2012 arrest at 1680 Sky Mountain Drive by WCSO, July 3rd, 2012 arrest at approximately 11 am by RPD in
RMC 12 CR 12420, September 9th, 2011 arrest at approximately 10 pm in RMC 11 CR 22176, traffic citation on November 15th, 2011 by Sargent Tarter et all near St. Laurence
and Forrest in 11 TR 26800 ( 11 TR 26800: Case number WC 12-1805 and referred to under Control # C-47951).

And any other incidents involving Zachary Barker Coughlin (might be mispelled Cuoghlin) dob 9/27/1976 (dob might be listed incorrectly is some places).

Sincerely,

Zach Coughlin

http://www.nvbar.org/lawyer-detail/11245

please find verfication that this is my email address above
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
RE: Case No. RCR2011-063341
Tel and Fax 949 667 7402
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:
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.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar number must be conspicuously displayed on
the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the receiving
party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
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.
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

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
Jun 27
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.
Jun 27
Hi zachcoughlin,
Jun 28
Hi zachcoughlin,
Jun 28
Hi zachcoughlin,
Jun 28
to me
to me
to me
to me
RE: ATTN Renee Brown Reno Postmaster reFW: complaint by Reno Nevada Attorney against postal supervisors at Golden
Valley Station
Hi zachcoughlin,
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341



Thank you.

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


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

to me
Sent: Thu 11/08/12 11:45 AM
To: Brown, Renee M - Reno, NV (renee.m.brown@usps.gov)
Cc: SLHofheins@uspis.gov (slhofheins@uspis.gov); WPHeister@uspis.gov (wpheister@uspis.gov); melinda.a.varszegi@usps.gov (melinda.a.varszegi@usps.gov); marybarkbark@yahoo.com
(marybarkbark@yahoo.com)
Dear Ms. Brown,
I am writing to seek your assistance, please. We had some issues in March-April ish of 2012...and I have some somewhat similar issues now...I am an
attorney (well, a suspended attorney...but I still have a license with the USPTO, but my Nevada license was temporarily suspended on 6/7/12....I have
moved a lot this year and only have one mailing address for either business or personal....please see my email below to my mother, Mary Barker,
respecting the confusion attendant to her paying for my po box for six months or so starting in april. Before that I had the problems with the Gold
Vallen or North Hills Station (Passot, Terri James Buck Hyde, etc) not letting me get a key to my mailbox, despit NRS 118a.160 and I would like any
documentation or representations made to the USPS by Nv Energy or Park Terrace Town Homes HOA, Sue King, Western Nevada Management or Gayle
Kern, Esq. regarding my rights at 1422 E. 9th St. #2...as i believe their misrepresentations to the USPS may have damaged me greatly in causing
difficulties in getting my mail...but my exigent concern today is figuring out what I need to do to make sure I am getting my mail forward from the
following previous address:
PO Box 60952, Reno NV 89506 (this is a box that belongs to either or both Pam or Peter Eastman, or maybe even InsureSmart....I was allowed to utilize
this box during a very trying time, incident to the 1422 E. 9th St. #2 disputes...however, not all mail was forwarded to me from this box upon my filing a
change of address on or around 4/16/12 to have mail sent to the box my mom got me, in her name, po box 3961, reno 89505 (at the downtown vassar
station). for instance, an application for some governmental benefit was not forwarded from that box, and I am told that it might be the case the
governmental mailings are not forward or some other problem
in NOvember through December 2011 i rented a studio at 817 N. Virginia St. Reno 89503 (though I see different zip codes assigned to that
address). that is the silver dollar motor lodge.. i tried filing change of address for that weekly rental business (that allows renting
monthly for extended periods) and was told I couldn't because it is a business or something like that...
1422 E. 9th St. #2., reno 89512 is an old address for me, as is, by now, the PO Box 3961 my mom got me, but which is in her name (see
email below and my concerns respecting whether i need worry about filing changes of address for myself as a person and as a business (ie,
an attorney).
I would appreciate some help with this, it would make up some for the problems and treatment in january through may 2012 with hyde,
passot, james, et al...
Please address for all purposes as of today and going forward should be:
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
m: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/08/12 11:30 AM
To: marybarkbark@yahoo.com (marybarkbark@yahoo.com); mary@vsanevada.org (mary@vsanevada.org)
Hi Mom,
Hope the RA is okay today with the weather getting colder. I think it is so neat that, ironically it was Ohio that sealed the Deal for President
Obama....
VERY IMPORTANT
Mom, becaue the po box 3961 is in your name...and i confirmed this with the vassar station...you need to file a change of address at following link or in a
station:
https://moversguide.usps.com/icoa/icoa-main-flow.do?execution=e1s1
this has some really BIG implications and consequences for me regarding notice, service, due process, my mail, etc....so please do this TODAY if you can, PLEASE and copy me on all the confirmation emails from the
USPS (it costs $1 to do it online...but I prefer that method...
Please try to change the address in my name from the box in your name (this could get really complicated and difiicult, unfortunately, as became apparent with the old PO Box 60952, Reno 89506....
Also, it might be necessary to do a change both for me personally "Zach Coughlin" and one for me as a business, ie and attorney (regardless of the suspension)....i still get mail at the po box 3961 at vassar
sometimes...though much mail seems to have been forward pursuant to my handing a change of address to the vassar station on or around 10/5/12...
One more thing....really would BE HUGE...could you buy me a book off amazon? I don't even have a debit card right now and it will take 10 days at least and $5 to get one....and the book is only like $8, and that
includes mailing..i need it asap:
http://www.amazon.com/s/ref=nb_sb_noss_2?url=search-alias%3Daps&field-
keywords=%22west's+analysis+of+american+law%22&rh=i%3Aaps%2Ck%3A%22west's+analysis+of+american+law%22
its called "West's Analysis of American Law" and any version from any year will do, the cheapest one is fine. Actually i would love to have two different versions, but one would do....PLEASE! thanks so much
love you
Love You,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: renee.m.brown@usps.gov
CC: SLHofheins@uspis.gov; WPHeister@uspis.gov; melinda.a.varszegi@usps.gov
Date: Tue, 24 Apr 2012 17:26:10 -0500
Subject: FW: ATTN Renee Brown Reno Postmaster reFW: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station
Dear Mr. Coughlin,

Thank you for your patience.
I have contacted our representatives in the Law Department in Salt Lake city. Your concerns are under review and are being further investigated.
Melinda Varszeqi has been assigned to your case and has been assigned as your point of contact. Ms. Varszeqi can be reached at the email address above; and by phone at (801)
984-8400.

Respectfully,

Renee Brown
Postmaster Reno NV
Nevada Sierra District
Office (775) 788-0634
Cell (775) 240-0296 (Not for Public)

CONFIDENTIALITY NOTICE
This communication is intended for the sole use of the individual or entity to which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If the reader of this communication is not the intended recipient or the employee or agent responsible for
delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication may be strictly prohibited. If you have received this communication in error, please notify me immediately by telephone (775- 788- 0626) and return the communication to me
at 2000 Vassar Street, Reno, NV 89510- 9998. Thank you

Sent: Monday, April 16, 2012 5:44 PM
To: Brown, Renee M - Reno, NV; rmbrown@uspis.gov
Subject: ATTN Renee Brown Reno Postmaster reFW: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station
Dear Reno Postal Inspector Renee Brown,
I respectfully submit this to you as an attorney whose law license is now in jeopardy, in large part to the malfeasance and retaliation of the Golden Valley Station supervisors Terri James, Buck Hyde
and "Ms. Passot".
I would appreciate a written response and something I can show to the State Bar of Nevada and my clients indicating my lack of culpability.
To: renee.brown@usps.gov
Subject: ATTN Renee Brown Reno Postmaster reFW: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station
Date: Mon, 16 Apr 2012 17:24:58 -0700
Dear Inspector Hofheins and Inspector Heister,
Please forward on all correspondences you have received from me to Reno Postmaster Renee Brown and please also email me back with Ms. Brown's
email address and fax number. I have her phone number, or rather the one I have left messages for her at, which is actually a number for her assistant,
Charlena Balz. I was told by the supervisors at the Golden Valley Station, here in Reno, NV that while my change of address from the 1422 E. 9th St.
#2 address was processing (to my then PO BOX 60952) that my mail would be held at the Golden Valley Station and I could pick it up there. However,
when I went to pick it up, I was assaulted by supervisor Buck Hyde. Additionally, it seems someone has taken care to pick out most all of the mail from
courts that was addressed to me and return it to the courts, rather than forward it on to me, as was done with other less important looking mail. This
misleading and dishonest approach by the Golden Valley Station USPS supervisors Buck Hyde, Terri James, and "Ms. Passot" (Ms. James refused to tell
me Ms. Passot's first name) has real dire consequences for me and my law practice, for which I may well have to proceed with a Federal Torts Claim Act
against your organization. I consider their actions criminal, volitional, and intentional, and therefore, this does come within your jurisdiction.
Please confirm that you are forward this and all other correspondences from me to Renee Brown.
FURTHER, PLEASE NOTE, I HAVE A NEW PO BOX, IT IS LISTED IMMEDIATELY BELOW:
From: SLHofheins@uspis.gov
To: zachcoughlin@hotmail.com; steven.l.hofheins@usps.gov
Date: Mon, 26 Mar 2012 10:25:44 -0500
Subject: RE: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station
We cover all of Nevada with the exception of Clark County. We are out of the office quite a bit. However, I have returned calls to you and your phone number seem's to be
disconnected. This is not an Inspector issue. We are criminal investigators and have nothing to do with the day to day operations of the Postal Service. Since you have opened a
P.O. Box, let your clients know your correct mailing address there will be no delay in delivery. If you do not let your clients know your correct mailing address, your mail will be
delayed through the forwarding system. I believe the Sierra Station is a 24 hour facility so you can get your PO Box mail anytime. Window services close at 5:00 pm and
the employee's there need to close and prepare for the next business day.

Steve Hofheins
US Postal Inspector
Sent: Friday, March 23, 2012 10:19 PM
To: Hofheins, Stephen L; steven.l.hofheins@usps.gov
Subject: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station

To: warren.p.heister@usps.gov
Date: Fri, 23 Mar 2012 22:00:53 -0700
Dear USPS Postal Inspectors Hofheins and Heister,
I have never once had either of you pick up the phone when I call. This is an emergency, to me. My clients and myself are being damaged daily by
the usps withholding my mail. I submitted a change of address online over one week ago. Supervisors at the Golden Valley station, (in addition to
much misconduct and retaliation) told me they would hold me mail for the week or so it indicated at www.usps.gov that it would take to process my
change of address (given some complication with updating my address linked to my debit card from the address I was changing from: 1422 E. 9th St. to
the PO Box I am changing it to: found at the bottom of this email ( and here: Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, , fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473) of address would take to go into affect and that I could pick it up there in the meantime ( I am a practicing attorney, I
can't wait 7-10 days to get my mail, this was explained). I want to get my mail, TODAY, RIGHT NOW. You can contact me via email, Do not
contact me via telephone, I want a RESPONSE IN WRITING. I do not want Buck Hyde to place his hands on me or push me physically again, nor to
ASSAULT me again. That man is so far from a professional it is breathtaking, period. Here is how I believe it may work. Hyde, Passot, and Terri
James violate my rights, interfere with my mail, retaliate. That causes myself and my clients damage. We sue you for those damages. Federal Torts
Claims Act. Also, please accept this as an official written complaint. I wish for the complaint process to start now, but I reserve the right to update or
supplement my complaint at a later time.
Please forward this on to the appropriate authorities and or inspectors. The acts and events referred to related to both the Downtown Reno post office
and especially the Golden Valley Station post office, that was assigned to my recent address of 1422 E. 9th St. #2, Reno 89512. I have been greatly
inconvenience and damage and am seeking relief in both law and equity.
I am writing about a possible violation of the Federal Tort Claims Act or other applicable laws. I wish to complain about the conduct of "Ms. Passot",
Terri James, and Buck Hyde, all of which have retaliated against me and otherwise denied me my mail and behaved in an extremely unprofessional
manner. I am an attorney in Nevada and it is of the utmost importance that I get my mail. Mr. Hyde has recently put his hands on me and otherwise
assaulted me and both he, Mrs. James, and Ms. Passot have threatened the abuse of process, all seemingly to save their station a $40 key charge or to
otherwise let me know what a big deal it is that they are "Feds".
Please place a copy of this Complaint in their employment or personnel files and I will provide further supplementary documentation in support of this
Complaint soon. In the meantime. Please tell Golden Valley Station and Mr. Hyde to cease attacking me and otherwise abusing process and to allow
me to retrieve my mail at once. Mr. Hyde and another older gentleman indicate my mail would be held for another week, about one week ago, after
much dispute, yet when I showed up to retrieve my mail Mr. Hyde behaved in an embarassing manner and I have not been allowed to get my mail while
the most recent change of address to a PO Box goes through. They have all admitted to retaliating against me under color of law.
To: kenneth.a.snavely@usps.gov; penny.a.woodworth@usps.gov; ted.w.snyder@usps.gov
Subject: FW: complaint by Reno Nevada Attorney against postal supervisors at Golden Valley Station
Date: Fri, 23 Mar 2012 16:58:31 -0700
Please note my new address. Please contact me only in writing.


To: kenneth.a.snavely@usps.gov; penny.a.woodworth@usps.gov; ted.w.snyder@usps.gov
Date: Thu, 22 Mar 2012 13:22:41 -0700
Dear USPS Postal Inspectors,
RE: RCR12-065630
Please forward this on to the appropriate authorities and or inspectors. The acts and events referred to related to both the Downtown Reno post office
and especially the Golden Valley Station post office, that was assigned to my recent address of 1422 E. 9th St. #2, Reno 89512. I have been greatly
inconvenience and damage and am seeking relief in both law and equity.
I am writing about a possible violation of the Federal Tort Claims Act or other applicable laws. I wish to complain about the conduct of "Ms. Passot",
Terri James, and Buck Hyde, all of which have retaliated against me and otherwise denied me my mail and behaved in an extremely unprofessional
manner. I am an attorney in Nevada and it is of the utmost importance that I get my mail. Mr. Hyde has recently put his hands on me and otherwise
assaulted me and both he, Mrs. James, and Ms. Passot have threatened the abuse of process, all seemingly to save their station a $40 key charge or to
otherwise let me know what a big deal it is that they are "Feds".
Please place a copy of this Complaint in their employment or personnel files and I will provide further supplementary documentation in support of this
Complaint soon. In the meantime. Please tell Golden Valley Station and Mr. Hyde to cease attacking me and otherwise abusing process and to allow
me to retrieve my mail at once. Mr. Hyde and another older gentleman indicate my mail would be held for another week, about one week ago, after
much dispute, yet when I showed up to retrieve my mail Mr. Hyde behaved in an embarassing manner and I have not been allowed to get my mail while
the most recent change of address to a PO Box goes through. They have all admitted to retaliating against me under color of law.
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: Thu 11/08/12 5:02 AM
To: Dogan, Biray (bdogan@washoecounty.us); ltibbals@washoecounty.us (ltibbals@washoecounty.us); kbeechler@reno.gov (kbeechler@reno.gov); odomk@reno.gov (odomk@reno.gov);
bonyr@reno.gov (bonyr@reno.gov); christensend@reno.gov (christensend@reno.gov)
Dear Mr. Dogan,
I understand it is my inviolable right as a criminal defendant to subpoena witnesses. Please subpoena RPD Sargent Zach Thew and inteview him
regarding any claim of right defense Coughlin may have respecting any alleged issuance by Thew to Coughlin of an invitation to Call him at a certain
RPD number and or 911 in connection with various discussion Thew and Couglin had prior to the 1/14/12 arrest. Please also (in conjunction with the
investigator on this case, and I have yet to be informed of whom that is...and Mr. Novak, I appreciate the work and notations you made to the file that I
have only just been made privy to by Mr. Leslie...I submit you are done a disservice where there is not more transparency given to the results of your
work to your criminal indigent defendants, as the circumstances dictate they assume the worst when supporting documentation to cursory contentions is
not show.
So, whom is the investigator here, and will you please provide me the documentation detailing the results of the investgiation undertaken? If no, please
indicate so in writing and detail the basis for such a refusal.
Mr. Dogan and or Mr. Leslie, please also subpoena Sargent Paul Sifre and Officer Schaur. Please propound to DDA Young the videos I am attaching
once again, on of the moments just prior to arrest with Sifre, where Sargent Sifre violates fundamental tenants of domestic violence victim advocacy
wherein he engages in "blame the victim" behavior (Coughlin was adjudge a victim of domestic violence on or about 1/23/12 by Master Edmonson, in
two separate cases FV12-00188 and 187..
Further, view the "Sargent Lopez I have a question for you video and attached Motion for New Trial filing in the criminal trespass conviction matter (see
also, 61901 on the N. S. Ct. site) 11 cr 26405, wherein, on 1/13/12, one day prior to the arrest in the case you are attorney of record on rcr2012-065630,
on 1/14/12) RPD Sargent Marcia Lopes is caught on taping admitting to fraud on her part, that of Officer Chris Carter, Jr., landlord Merliss, and opposing
counsel Hill incident to the criminal trespass arrest. Please develop a defense and investigation based upon witness bias an motive, seeking to draw a
connection between the actions a day later by Sifre, Schaur, et al, vis a vis the interaction with Sargent Lopez here. Please also interview and subpoena
Officer Travis Warren, whom Coughlin has recently learned approached and met with his parents at Coughlin's father's medical practice (and Coughlin's
father is both John Kadlic, Reno City Attorney, and perhaps Robert Bony, Esq., Deputy City Attorney's patients) and purportedly sought to "have
Coughlin committed" or somethign along those lines. Please develop a defense and collect and provide investigation relative to the idea that doing so
by the RPD and or Reno City Attorney is violative of Palmer v. Pioneer, and has prejudiced Coughlin's case (what if your family deserted you Biray, in
part, due to fraudulent misrepresentations by local law enforcement with an agenda that includes covering up a number of wrongful arrests potentially
exposing them to both criminal and civil penalties? What would you think of a public defender and his assistant who had not done jack to advocate on
your behalf? Who had not sent out a single subpoena? Why haven't you collected the dispatch tapes, not just the 911 calls. The communications
between dispatch and the RPD are likely way more revelatory than the calls themselves. You are aware, are you not, that RPD Officer Duralde an 5
other officers pulled Coughlin over shortly after midnight on 1/13/12, just after Coughlin had bailed out on the jaywalking arrest, right? You are aware
Coughlin filed a written complaint against Duralde (arresting Officer in the case Goodnight, then Leslie was one in rcr2011-063341, right) on 9/7/12 and
1/8/12, right? You were aware of that, right Biray? Right, Leslie? So, please subpoena the dispatch communications between the RPD and
Ecomm, not just the logs, which is what Ecomm tried to pass off as responsive recently. The audio tapes...Kariann Beechler. She fees it appropriate
to act as a filter to complaints of police misconduct, even though engendering legitimate and perceived fear of substantial immediate harm at the hands of
local law enforcement. Further, please subpoena Deputy Medina and Sargent Bradshaw. Also, review the results of a subpoena duces tecum to the
RPD regarding anything related to Coughlin, especially the 11/15/11 incident with Sargent Tarter...
Can you indicate whether the "misuse of 911" statue appears in any published decisions? Why did you indicate, on the record, in court on 11/6/12 that
you are "unaware of any basis for an opposition" the DDA Young's Motion to Amend? Are you indicating you have failed to receive the voluminous
correspondence and media submission from Coughlin wherein the prejudice to Coughlin and his defense was detailed, especially vis a vis the denial of a
speedy trial (60 days), the spoliation of evidence angle, and the prosecutorial misconduct line of argument (DDA Young attempted to hold a trial on
5/7/12 in violation of the mandatory stay in NRS 178.405 in view of the then still pending Order for Competency Evaluation you, Dogan, procurred at a
Status Conference with Young on 2/27/12, wherein Judge Schroeder is listed as the Hearing Judge. Neither of you have ever denied that in any way.
Then Young violated NRs 178.405 again by filing, at 2:55pm on that day, a document in the associate case rcr2011-063341, despite the file stamping
of 1:31 pm 2/27/12 on Judge Clifton's Order For Competency Evaluation. Neither you, Dogan, nor Young have ever denied the veracity of that
statement, despite it being assert directly to you on numerous occasions.
As to the amended charge, please see the attached Beckett treatment of it (former Nye County DA, SCR 111(10), etc.
Further, please subpoena and interview Officer Alan Weaver, Sargent Brian Dye, and Sargent Oliver Miller to develop more clearly a basis for moving
for a mistrial for prosecutorial and or law enforcement misconduct here (by only against DDA Young should you obtain some reasonable sufficient basis
for viewing his complicity in this mesdeeds, or assent to them in and way,.
(No Subject)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
2 27 12 065630 Young and Dogan Clandestine Status Conference leads to SBN SCR 105 Complaint against Coughlin 0434 Nash.pdf
2 27 12 Judge Schroeder status conference clifton order rcr2012-065630 26800.pdf
2 28 and 3 12 and 3 12 and 3 14 nash orders and grievances 26800 0204 0434.pdf
5 4 12 mch goondnight email trespas rmc 26405 loomis young 063341 065630.htm
5 4 12 email goodnight mhc hazlett young trespass loomis.htm
rmc longoni handout demanding payment on transcripts on appeals in violation of nevada law 26405 cr11-2064 cr12-1262 26406 11 tr26800 ocr.pdf
12 21 11 email to rmc regarding no response from Longoni.pdf
10 5 12 stamped 60838 SCR 111 King SBN Susich Motion Show Cause against NNDB and SBN 12-31434.pdf
2 28 12 Contempt Order Nash 26800 26405 065630 00696 063341 bf size reduced.pdf
Download all
From: BDogan@washoecounty.us
Subject: RCR12-065630
Date: Fri, 28 Sep 2012 17:33:45 +0000
Your case with me has been continued to October 30th, at 10:00 A.M.

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

Sent: Thu 11/08/12 2:10 AM
(No Subject)
To: bonyr@reno.gov (bonyr@reno.gov); christensend@reno.gov (christensend@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
Hi Guys,
Check out this picture, how player is that, mang? See the cameras atop of City Hall, overlook the skate plaze, and inthe same mis en scene, the RPD sign admitting to recording the
action...Belissimo. Please turn over the videos, which you were put on a LITIGATION HOLD NOTICE sufficient to maintain within one week of the arrest at the Skate Plaza on August 20th, 2011 for
the events occuring between 11:10 pm and midnight on that date....in RCR2011-063341.
Thanks,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 7 12 for bony and christensen 063341 0204.pdf
for DDA Young, City Attorney's Bony and Christensen city hall cameras and RPD recording admission 063341.pdf
10 4 12 ORDER STRIKING document filed in error on 10 2 12 and returning document 26800 0204 0434 nash 00696 26405 with ex 1 10 2 12 filing by couglin noa notice.pdf
11 7 12 certified mailings of subpoena under NRS 174.345 063341 0402.pdf
Download all

Sent: Wed 11/07/12 6:33 AM
To: odomk@reno.gov (odomk@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); bdogan@washoecounty.us (bdogan@washoecounty.us)
Rule3.8. Special Responsibilities of a Prosecutor. The prosecutor in a criminal case shall:
(a)Refrain from prosecuting a charge that the prosecutor knows is not supported by probable cause;
(b)Make reasonable efforts to assure that the accused has been advised of the right to, and the procedure for obtaining, counsel and has been given reasonable opportunity to obtain counsel;
(c)Not seek to obtain from an unrepresented accused a waiver of important pretrial rights, such as the right to a preliminary hearing;
(d)Make timely disclosure to the defense of all evidence or information known to the prosecutor that tends to negate the guilt of the accused or mitigates the offense, and, in connection with
sentencing, disclose to the defense and to the tribunal all unprivileged mitigating information known to the prosecutor, except when the prosecutor is relieved of this responsibility by a protective order
of the tribunal;
(e)Not subpoena a lawyer in a grand jury or other criminal proceeding to present evidence about a past or present client unless the prosecutor reasonably believes:
(1)The information sought is not protected from disclosure by any applicable privilege;
(2)The evidence sought is essential to the successful completion of an ongoing investigation or prosecution; and
(3)There is no other feasible alternative to obtain the information;
(f)Except for statements that are necessary to inform the public of the nature and extent of the prosecutors action and that serve a legitimate law enforcement purpose, refrain from making
extrajudicial comments that have a substantial likelihood of heightening public condemnation of the accused and exercise reasonable care to prevent investigators, law enforcement personnel,
employees or other persons assisting or associated with the prosecutor in a criminal case from making an extrajudicial statement that the prosecutor would be prohibited from making under Rule 3.6 or
this Rule.
this is my request for reciprocal discovery in all three matters. I have fired Biray Dogan. He is not my attorney. I have also fired Jim Leslie in RCR2012-067980. And, Leslie has been
remove in 2012-063341. Both Leslie, You, and Dogan have deprived me of my right to a preliminary hearing: http://www.sltrib.com/sltrib/home/51524700-76/court-hernandez-
preliminary-hearing.html.csp Well, those are probably for when one is in custody...and instead the system got my bail money. At least I don't sound as clueluess as Bob Bony, talking 'bout
RJCR 45....Huh? I served those criminal subpoenas via the mail NRS 174.somethin' somethin. Hey, Jim Leslie, why we going on about you can't track down Nicole Watson? Why didn't you
mail a subpoena to Templeton? Why did you mislead me Jim. Biray, as long as I am stuck with you on this case (hopefully not long at all), I want you to send a subpoena to ECOMM (you know
Kelley Odom, and send one to Harriet Truman of the RPD too) gathering all that great exculpatory stuff that DDA Young has failed to propound. Then review that Motion for a Mistrail alleging
Prosecutorial Misconduct that Sean Sullivan filed awhile back. Biray, have you seen your google results lately?
Further, while I was a licensed attorney, I filed an appearance in rcr2012-065630, which I do not believe requires an order to remove Dogan... I could be wrong, but that is my position on it.
Dear DDA Young,
Please comply with your RPC 3.8 duties and refrain

Mr. Young, please be advised that RPD Sargent Marcia Lopez was caught on tape (and very distraugt about it) admitting to police misconduct and a false arrest sheet by Chris Carter on January 13th,
2012, about 24 hours before old RPD Sargent Sifre arrested Coughlin for "misuse of 911" (okay, he ordered Schaur to do it)...Anyways, Biray and I are going to need those dispatch tapes of the back
and forth between the RPD (all of em) and ECOMM and anyone else.
All of the allegations herein also relate to "irregularities" in the proceedings and prosecutorial misconduct" justfying the relief requested herein. Coughlin's ability to get this exculpatory video wherein
Sargent Lopez admits RPD Officer Carter and Richard Hill, Esq. and Casey Baker, Esq. lied, under oath (in Hill's case) at the June 18th, 2012 Trial and in violation of NRCP Rule 11 (in Baker's case in
his November 21st, 2011 Opposition to Coughlin's Motion to Contest Personal Property Lien) was severaly comprimised, to an excusable neglect extent, and to a good cause standard, by the various
fraudulent, retaliatory arrests and incarcerations (which often involve arbitrary denial of detainee's medications and access to even one sheet of paper, even where indigent, to file a document), and the
fraudulent attempts by RPD in sending out Officer Warren (who is a specialized officer in that regard and may well have good intentions, but the City Attorney and the RPD do him no favors where
they attempt to cover over police misconduct by diagnosing the victim of it) and others to alienate Coughlin from his family and any other type of a support system, all in the name of covering up
wrongful arrests by the WCPD, and or WCSO and or wrongful "summary contempt" findings, including those in 11 TR 26800, RCR 2012-065630 (Sargent Sifre's order to arrest Couglin on January
14th, 2012 for "misuse of emergency communications" NRS 207.245 (because reports of police misconduct or harassment never qualify as a "perceived emergency" according to Kariann Beechler of
ECOMM) (though, Judge Clifton does seem to have a bit of a fairness streak within him, and may indeed reveal a penchant for demonstrating the extent to which, no term limits be damned, the
judiciary in Washoe County is not going to be pushed around and once it becomes clear that DDA Young is trying to pull an In Re Beckett (57280) on Coughlin, even where Young is violating RPC
3.8 in that he lacks probable cause to so amend his Complaint, well...) And the three different Beckett matters (57763, 57280, and 54454) (Beckett, a District Attorney in Nye County
NRS 207.245 seeks to amend the politically trick y to maintain NRS 207.245 misuse of 911 by a domestic violence victim (as adjudge in FV12-00187 and 188) charge to a misdemeanor giving him far
more "leverage", the offense of Resisting, Delaying, or Obstructing a Public Officer in violation of NRS 199 . 280(3), in light of Coughlin's chosen profession, attorney, and SCR 111(6), attorney's
convicted of crimes requiring Bar Counsel seek to take away one's license upon a conviction::( 6). Definition of serious crime. The term serious crime means (1) a felony and (2) any crime
less than a felony a necessary element of which is, as determined by the statutory or common-law definition of the crime, improper conduct as an attorney, interference with the administration of
CLARIFICATION on Change of Address for Zach Coughlin
justice, false swearing, misrepresentation, fraud, willful failure to file an income tax return, deceit, bribery, extortion, misappropriation, theft, or an attempt or a conspiracy or solicitation of another to
commit a serious crime. Compare
Also, Mr. Young, you know Zarate is lying as a witness. That is putting on perjured testimony. Zarate's statements in the VIDEO0100 that i have provided you in hard copy and digital formats
directly contradict his sworn testimony that he "personally eye witnessed" Coughlin grabbing the phone from the "man with the six pack". Then, you have Duralde and Zarate contradicting each
other about what Zarate told Duralde (one sentence according to Zarate...and that one sentence is captured at teh start of the tape of the arrest...but ol' Nick Duralde's testimony and
Supplemental Decl (and why was the Narrative apparently only prepared three months after the arrest, when it was propounded on 11 30 11?) attributes a whole bunch the "material elements"
that Officer Duralde neede to support his pc finding...kind of looks like a little "shake and bake" from Officer Duralde...unless you want to make you star witness Zarate the liar....either way, you
lose, as you are the prosecutor putting on the perjured testimony and persisting in a prosecution where you can't get a receiving conviction, especially at this late stage, do to Staab an other cases,
for the various "other person" and failure to specify, and duplicity/double jeapoardy rationale I have set forth to you...so you are left trying to get petty larceny, but you need intent at the time of
the "taking", and you need that intent to be to "permanently deprive"...and any furtiveness circumstantial you might put on is negated by the "son, son, don't put your...." and "you just admitted"
interchange...So you are basically prosecuting someone for asserting their fourth amendment rights....not good for your look...how did you draw mop up duty for all the lame brained ego drive
wrongful arrests by the RPD this past year? Why does Hicks get all the good looks? You deserve better, ZY.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
10-00626.pdf
EXAMPLE DEFENDANTS MOTION TO DISMISS FOR PROSECUTORIAL MISCONDUCT 063341 26405.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630 final with index to exhibits.pdf
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Sent: Mon 11/05/12 2:45 AM
To: joey.hasting@washoecourts.us (joey.hasting@washoecourts.us); jacksonc@reno.gov (jacksonc@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); wagnerl@reno.gov
(wagnerl@reno.gov); tognonim@reno.gov (tognonim@reno.gov); shermanm@reno.gov (shermanm@reno.gov); lopezv@reno.gov (lopezv@reno.gov); renodirect@reno.gov
(renodirect@reno.gov); renomunirecords@reno.gov (renomunirecords@reno.gov); rjcweb@washoecounty.us (rjcweb@washoecounty.us); gaylekern@kernltd.com (gaylekern@kernltd.com);
jgarin@lipsonneilson.com (jgarin@lipsonneilson.com); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); stuttle@washoecounty.us (stuttle@washoecounty.us); eflex@washoecourts.us
(eflex@washoecourts.us); efiling@nvcourts.nv.gov (efiling@nvcourts.nv.gov)
Dear RMC, RJC, Second Judicial District Court, WCDA, and City Attorney's Office,
I apologize for the confusion in my last email, please ignore the address on the April 2012 Notice that was inadvertently attached thereto and any address
FW: please file this with the RMC
included in any email that was found therein.
Please be aware that the following is my current contact, mailing, and business address and fax, phone, and emails information:
Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Mon 11/05/12 2:31 AM
To: ormaasa@reno.gov (ormaasa@reno.gov); renomunirecords@reno.gov (renomunirecords@reno.gov); jacksonc@reno.gov (jacksonc@reno.gov); tognonim@reno.gov (tognonim@reno.gov);
lopezv@reno.gov (lopezv@reno.gov); ballardd@reno.gov (ballardd@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); wongd@reno.gov (wongd@reno.gov);
sooudib@reno.gov (sooudib@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); efiling@nvcourts.nv.gov (efiling@nvcourts.nv.gov); eflex@washoecourts.us
(eflex@washoecourts.us); joey.hasting@washoecourts.us (joey.hasting@washoecourts.us)
1 attachment
4 16 12 rmc notice of non service.pdf (96.8 KB)
Dear Reno Municipal Court and City of Reno Attorney, WCDA, and WDC,
Please note my new address for all future matters, and that my phone number is now the same as my fax number. Please update my address with
all RMC Departments.
Please alert Department 3 of this, as 12 00696 and 11 TR 26800 are still before it
12 CR 12420 is still before Department 1
Department 2 has 11 CR 26405 (which may be marked as "closed", however, a Motion for New Trial, etc. has recently been filed therein
Department 1 has 11 CR22176 and has yet to rule on several motions filed therein.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: renodirect@reno.gov
Subject: please file this with the RMC
Date: Mon, 16 Apr 2012 16:30:30 -0700
RE: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
FW: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
in 11 tr 26800
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); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); 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 12:29 AM
To: tognonim@reno.gov (tognonim@reno.gov)
FW: Mr. King's assertion in his 3/16/12 letter
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)
resent due to error in your email address below
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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 12:28 AM
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)
resent becase of error in your addres below
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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,):

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
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-J uly 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 RJ C 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, J udge 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 J udge 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).
FW: request for audio records
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 J udge 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, J udge Nash Holmes provides no attribution for such hearsay in her extremely reckless assertion) in RJ C 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
RJ C 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 J udge 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 J ames, 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 J udge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what J udge Nash Holmes is referring to when she describes difficulty contacting me (the
attempts by J udge 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 J ustice 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 RJ C 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 J ames 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: Sat 11/03/12 9:31 PM
To: carothersr@reno.gov (carothersr@reno.gov); Rogers@reno.gov (rogers@reno.gov)
Hi!
I will be out of the office until November 14th.
If you are inquiring about a tape request or wish to request a tape please contact Supervisor Robin Carothers at carothersr@reno.gov.
If this is relative to unit # entries or premise hazards contact Supervisor Suzy Rogers at .
If this is relative to some other matter and you need a response prior to my return please contact the Assistant Manager Kelley Odom at 334-1202.
Thank You
Ella Mae Carthen
Operations
COR Emergency Communications
Supervisor line (775) 334-2399
Office line (775) 326-6613
carthene@reno.gov
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: ecommops@reno.gov; odomk@reno.gov; beechlerk@reno.gov; zyoung@da.washoecounty.us; kadlicj@reno.gov; wongd@reno.gov; lstuchell@washoecounty.us; renodirect@reno.gov
Subject: FW: request for audio records
Date: Sat, 3 Nov 2012 21:30:08 -0800
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
rmc subpoena 063341 TO ECOMM ODOM AND OTHERS.pdf
0204 ECOMM SUBPOENA.pdf
Download all
To: ecommops@reno.gov; odomk@reno.gov; beechlerk@reno.gov
Date: Sat, 3 Nov 2012 20:18:12 -0800
Hi ECOMM,
RENO JUSTICE COURT CASE RCR2011-063341 D2
THIS IS A SUBPOENA FOR
STATE OF NEVADA, PLAINTIFF
V.
ZACH COUGHLIN, DEFENDANT
SUBPOENA AND SUBPOENA DUCES TECUM
ATTN: YOU MUST COMPLY IN ACCORD WITH JCRCP 45 AND OR NRCP 45
ATTN: CUSTODIAN OF RECORDS ECOMM, KELLY ODOM, CITY OF RENO, RENO POLICE DEPARTMENT ETC.

Please just send me (preferably by email) any and all recordings or documentation of any sort involving Zach Coughlin or Zach Cuoghlin, whether with a
date of birth of 9/27/76 or 9/1/76, or any other DOB, including for Zachary Coughlin or Zach Caughlin or any iteration of those names, including dispatch
recordings (not just the 911 calls, by all recordings, including communications with the police officers or other law enforcement personel), including those
in any way related to incidents or arrests on, but not limited to, the following:
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa and OFficer Alaksa as well with various 911/rpd/dispatch calls
including some made by the following numbers
any call ever made from or to:
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
also, my former Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena for these matrials on 10 3 12. I got Leslie removed and am now representign myself in RCR2012-
063341. Leslie says ECOMM and ODOM failed to produce anything or respond in any way...which I doubt...so please just include the response to that subpoena in what you send me
i also want anything related to the following criminal cases:
in the Reno MUnic Court 11 cr 22176 (occuring at the w. 2nd st. walmart on 9/9/11 at around 9 pm, arrest by RSIC,
NOvember 13th, 2011 arrest in RMC 11 cr 26405 (arrest by reno pd at 121 River Rock St. reno 89501 at sometime around noon)
November 30th, 2011 arrest by reno marshals in 11 cr 22176
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 89501 as well, please include anythign related to Richard G. HIll or Matt Merliss's calls to law enforcement, including anything on
HIll's tpo in rcp2012-000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill st.
january 14th, 2012 arrest in rcr2012-065630
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in any way connected to coughlin on or around the 1422 E. 9th St. #2 address between
december 1, 2011 and the present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
anything related to reno marshal rmc arrest in 11 tr 26800 on 2/27/12
anything on the 11/15/11 incident resulting in 11 tr 26800 on st laurence involving the rpd, sargent tarter, 652 forrest st. richard hill, etc.
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact anything involving Zach Coughlin and any law enforcement figures at or around Northwinds
Apartments at 1680 sky mountain drive and or Superior mini storage at
1. Google+ page
7795 White Fir Street Reno, NV 89523
(775) 746-4322
or at some west fourth street address or Superior MIni STorage, especially on or around september 22nd 2012 whether involving officer alan weaver or
sargent oliver miller or not, including calls for law enforcement response by matt grant (a woman) or ken grant or marvin dye or anyone with superior mini storage
the july 3rd, 2012 arrest in rmc 12 cr 12420 AND ANYTHING AN EVERYTHING OTHERWISE RELATED TO ZACH COUGHLIN IN ANY WAY, DONT FORGET THE JAN 13 2012 STUFF
WITH SARGENT LOPEZ AND OFFICER WEAVER AND AVILA, ALL THE SARGENT SIFRE STUFF,
ANYTHING IN CR12-0376...ANDYTHING IN MH12-0032
I am subpoening all these materials incident to Judge Sferrazzas 10/22/12 ORder in RCR2011-063341, in which he granted me the right
to issue these subpoenas upon you without paying up front the witness fees or other expenses (IFP)
THanks,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 2011 11:04:35 -0800
From: EcommOps@reno.gov
Subject: request for audio records
Mr. Coughlin,

Your request for audio records has been received. However, I do not have sufficient information to process it.

Can you tell me the date and time this occurred, along with the location so I will be able to locate the call.

Thanks,
Ella Mae

Close Print
FW: please file this with the RMC
Sent: Mon 11/05/12 2:31 AM
To: ormaasa@reno.gov (ormaasa@reno.gov); renomunirecords@reno.gov (renomunirecords@reno.gov); jacksonc@reno.gov (jacksonc@reno.gov); tognonim@reno.gov
(tognonim@reno.gov); lopezv@reno.gov (lopezv@reno.gov); ballardd@reno.gov (ballardd@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov);
wongd@reno.gov (wongd@reno.gov); sooudib@reno.gov (sooudib@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); efiling@nvcourts.nv.gov
(efiling@nvcourts.nv.gov); eflex@washoecourts.us (eflex@washoecourts.us); joey.hasting@washoecourts.us (joey.hasting@washoecourts.us)
1 attachment
Dear Reno Municipal Court and City of Reno Attorney, WCDA, and WDC,
Please note my new address for all future matters, and that my phone number is now the same as my fax number. Please update my
address with all RMC Departments.
Please alert Department 3 of this, as 12 00696 and 11 TR 26800 are still before it
12 CR 12420 is still before Department 1
Department 2 has 11 CR 26405 (which may be marked as "closed", however, a Motion for New Trial, etc. has recently been filed therein
Department 1 has 11 CR22176 and has yet to rule on several motions filed therein.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Subject: please file this with the RMC
Date: Mon, 16 Apr 2012 16:30:30 -0700
in 11 tr 26800
RE: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
FW: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
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); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); 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
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;
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Sun 11/04/12 12:29 AM
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)
resent due to error in your email address below
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Sat, 3 Nov 2012 03:13:58 -0700
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Sun 11/04/12 12:28 AM
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)
resent becase of error in your addres below
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Subject: FW: Mr. King's assertion in his 3/16/12 letter
Date: Sat, 3 Nov 2012 03:00:11 -0700

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,):

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):


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

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.


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

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

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-J uly 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 RJ C 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
Anyway, I deny guilt on each an every allegation made against me by Hill, J udge 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 J udge 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 J udge 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, J udge Nash Holmes provides no attribution for such hearsay in her extremely reckless assertion) in RJ C 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 RJ C 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 J udge 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 J ames, 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 J udge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what J udge
Nash Holmes is referring to when she describes difficulty contacting me (the attempts by J udge 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 J ustice
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 RJ C 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 J ames 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: Sat 11/03/12 9:31 PM
To: carothersr@reno.gov (carothersr@reno.gov); Rogers@reno.gov (rogers@reno.gov)
Hi!
I will be out of the office until November 14th.
If you are inquiring about a tape request or wish to request a tape please contact Supervisor Robin Carothers at carothersr@reno.gov.
If this is relative to unit # entries or premise hazards contact Supervisor Suzy Rogers at .
If this is relative to some other matter and you need a response prior to my return please contact the Assistant Manager Kelley Odom at 334-1202.
Thank You
Ella Mae Carthen
Operations
COR Emergency Communications
Supervisor line (775) 334-2399
Office line (775) 326-6613
carthene@reno.gov
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: ecommops@reno.gov; odomk@reno.gov; beechlerk@reno.gov; zyoung@da.washoecounty.us; kadlicj@reno.gov; wongd@reno.gov; lstuchell@washoecounty.us;
renodirect@reno.gov
Date: Sat, 3 Nov 2012 21:30:08 -0800
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Download all
Date: Sat, 3 Nov 2012 20:18:12 -0800
Hi ECOMM,
V.

Please just send me (preferably by email) any and all recordings or documentation of any sort involving Zach Coughlin or Zach Cuoghlin,
whether with a date of birth of 9/27/76 or 9/1/76, or any other DOB, including for Zachary Coughlin or Zach Caughlin or any iteration of those
names, including dispatch recordings (not just the 911 calls, by all recordings, including communications with the police officers or other law
enforcement personel), including those in any way related to incidents or arrests on, but not limited to, the following:
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa and OFficer Alaksa as well with various 911/rpd/dispatch
calls including some made by the following numbers
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
also, my former Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena for these matrials on 10 3 12. I got Leslie removed and am now representign myself in
RCR2012-063341. Leslie says ECOMM and ODOM failed to produce anything or respond in any way...which I doubt...so please just include the response to that subpoena in what you
send me
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 89501 as well, please include anythign related to Richard G. HIll or Matt Merliss's calls to law enforcement, including
anything on HIll's tpo in rcp2012-000018)
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in any way connected to coughlin on or around the 1422 E. 9th St. #2 address
between december 1, 2011 and the present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact anything involving Zach Coughlin and any law enforcement figures at or around
Northwinds Apartments at 1680 sky mountain drive and or Superior mini storage at
1. Google+ page
(775) 746-4322
THanks,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 2011 11:04:35 -0800
Mr. Coughlin,



Thanks,
Ella Mae

Sent: Sat 11/03/12 9:30 PM
To: ecommops@reno.gov (ecommops@reno.gov); odomk@reno.gov (odomk@reno.gov); beechlerk@reno.gov (beechlerk@reno.gov); ZYOUNG@DA.WASHOECOUNTY.US
(zyoung@da.washoecounty.us); kadlicj@reno.gov (kadlicj@reno.gov); WONGD@RENO.GOV (wongd@reno.gov); lstuchell@washoecounty.us
(lstuchell@washoecounty.us); renodirect@reno.gov (renodirect@reno.gov)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Download all
Date: Sat, 3 Nov 2012 20:18:12 -0800
Hi ECOMM,
V.

whether with a date of birth of 9/27/76 or 9/1/76, or any other DOB, including for Zachary Coughlin or Zach Caughlin or any iteration of those
names, including dispatch recordings (not just the 911 calls, by all recordings, including communications with the police officers or other law
enforcement personel), including those in any way related to incidents or arrests on, but not limited to, the following:
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa and OFficer Alaksa as well with various 911/rpd/dispatch
calls including some made by the following numbers
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
RCR2012-063341. Leslie says ECOMM and ODOM failed to produce anything or respond in any way...which I doubt...so please just include the response to that subpoena in what you
send me
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in any way connected to coughlin on or around the 1422 E. 9th St. #2 address
between december 1, 2011 and the present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact anything involving Zach Coughlin and any law enforcement figures at or around
Northwinds Apartments at 1680 sky mountain drive and or Superior mini storage at
1. Google+ page
(775) 746-4322
THanks,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 2011 11:04:35 -0800
Mr. Coughlin,



Thanks,
Ella Mae

Sent: Sat 11/03/12 8:18 PM
To: EcommOps@reno.gov (ecommops@reno.gov); odomk@reno.gov (odomk@reno.gov); beechlerk@reno.gov (beechlerk@reno.gov)
Hi ECOMM,
V.

whether with a date of birth of 9/27/76 or 9/1/76, or any other DOB, including for Zachary Coughlin or Zach Caughlin or any iteration of
those names, including dispatch recordings (not just the 911 calls, by all recordings, including communications with the police officers or
other law enforcement personel), including those in any way related to incidents or arrests on, but not limited to, the following:
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa and OFficer Alaksa as well with various
911/rpd/dispatch calls including some made by the following numbers
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
RCR2012-063341. Leslie says ECOMM and ODOM failed to produce anything or respond in any way...which I doubt...so please just include the response to that subpoena in what
you send me
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in any way connected to coughlin on or around the 1422 E. 9th St. #2
address between december 1, 2011 and the present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact anything involving Zach Coughlin and any law enforcement figures at or
around Northwinds Apartments at 1680 sky mountain drive and or Superior mini storage at
1. Google+ page
(775) 746-4322
THanks,
convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 2011 11:04:35 -0800
Mr. Coughlin,



Thanks,
Ella Mae

Sent: Sat 11/03/12 3:14 AM
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)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Sat 11/03/12 3:00 AM
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)

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,):

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):


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

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.


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

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

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-J uly 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 RJ C 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
Anyway, I deny guilt on each an every allegation made against me by Hill, J udge 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 J udge 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 J udge 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, J udge Nash Holmes provides no attribution for such hearsay in her extremely reckless assertion) in RJ C 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 RJ C 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 J udge 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 J ames, 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 J udge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what J udge
Nash Holmes is referring to when she describes difficulty contacting me (the attempts by J udge 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 J ustice
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 RJ C 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 J ames 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,
RE: please email me the materials produced by ecomm/K. Odom/ dispatch tapes
Sent: Fri 11/02/12 7:40 PM
To: Leslie, Jim (jleslie@washoecounty.us); odomk@reno.gov (odomk@reno.gov); beechlerk@reno.gov (beechlerk@reno.gov); renodirect@reno.gov (renodirect@reno.gov);
kadlicj@reno.gov (kadlicj@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
Mr. Leslie, of course you continue to prevaricate. Please get me something in writing regarding you utter failure to propound any of the materials, response, or
documentation received in connection with the subpoena of 10 3 12, that your office served on ECOMM's Kelly Odom, which you admitted to being completely
unaware of today (actually, you indicted a complete lack of concern for such matters)...especially given the material relevance in this case RCR2011-063341 of
what was communicated between ECOMM/Emergency Dispatch and the RPD, especially given the arresting officer here, Nick Duralde's wife, Jessica Duralde is
a dispatcher who was on duty with ECOMM during the arrest, and especially considering that ECOMM and the RPD were involved in the wrongful arrest of
Coughlin on 1/14/12 for the "misuse of emergency services where no emergency or perceived emergency exists" as ECOMM, including Kariann Beechler, have
indicated that any complaint of an emergency or fear of police misconduct or report thereof is not something that ECOMM concerns itself with (similarly, and
complaint regarding ECOMM or fear of an emergency attendant thereto)....

I have a trial resuming on November 19th, 2011. Also, Ms. Beechler and Ms. Odom, will you please agree to showing up at the State Bar of Nevada on
November 14th, 2012 at 9 am to testify in the disciplinary matter wherein the "misuse"/ECOMM arrest is a material issue?

Please email me the materials produced in response to the subpoena of 10 3 12 in my case RCR2012-063341 to this address/

Thanks,

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

Sent: Friday, November 02, 2012 12:13 AM
To: Leslie, J im; Gray, Linda; Tibbals, Leslie; Dogan, Biray
Subject: please email me the materials produced by ecomm/K. Odom/ dispatch tapes

Dear Mr. Leslie,

Please email me the materials produced by ecomm/K. Odom (in response to your subpoena of 10 3 12, surely you have review these materials given your stated
intention on 9 5 12 to jam me into a conclusion of trial on 10 15 12, at which time you anticipated "calling no witnesses" and "being able to wrap this thing up in
less than an hour, Your Honor..."

So, please send me the materials propounded by ECOMM/the RPD/ K. Odom/ Emergency Communications, etc., along with an inventory of what fails are
included therein (to the extent the attachment file name don't make that obvious. The nice thing about the audio files that ECOMM produced to you is they
are such small files. For instance, the 911 recordings propounded earlier (2 calls be Goble, one by Coughlin) are each only about 200 kb in size...My hotmail
accepts up to 25 mb files at a time, and to the extent you have anything larger than that (pretty doubtful, beyond the large video files I have given to you) it
really should be no trouble for you to digitially transmit (and it is so cute how you have developed this "hand-off transmittal" jibberish/garbage to make an
attempt to excuse your transparent refusal to be held accountable to the 1's and 0's of a digital transmission (but you do leave yourself exposed to a claim that
you have failed to maintain a client's file...by your indication that you wish to ("because there is just no time to put a cd in the computer and click "attach" and
add an .avi file to an email") do a "hand-off transmittal", at which point you purport to be handing over the only copies your office has of things like the
materials propounded by ECOMM/K. Odom.

Please get this done today, or a continuance will be in order.

Oh, if you are so busy, Jim, perhaps some of your staff could do the emailing and the clicking of the "attachment" button, etc., etc.

Jim, I haven't heard anything substantive from Biray Dogan in months depsite my numerous written inquiries. You claim to be responsible for his work as his
supervisor....yet, I also remember you putting a "gag order" on Joe Goodnight, preventing him from even speaking when appearing on my behalf in court (truly
an odd sight/lack of sound). Have you placed a similar "no speach or communication" embargo on Mr. Dogan? How does that relate to Dogan and your
professional responsibilities?

I am still waiting to get a copy of anything, anything at all that your office has to support your contention, made under oath, that it noticed me in any way on
the August 6th, 2012 "combo hearing", which the record reflects I failed to appear at, which has not subjected me to certain bail revocation consequences.
Ms. Gray, you will recall our conversations in that regard, and the statements you made, which conflict sharply with those made under oath by Mr. Leslie.
Please go ahead and send me any such documentation or explanation, and be prepared to speak to these discrepancies at my bar hearing on November 14th,
2012, 9 am, at the State Bar of Nevada's Offices at 9200 Double R. Blvd., Reno, NV, all of you.

Sincerely,

Zach Coughlin

RE: Coughlin: Petit larceny case
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
350 South Center Street
Fifth Floor
Reno, NV 89509
1-800-762-8031
you violated NRS 178.405
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: Fri 10/12/12 5:39 AM
To: hsotelo@tmcc.edu; renodirect@reno.gov; rjcweb@washoecounty.us; stuttle@washoecounty.us
Dear Mr. Sotelo,
PLease go ahead and get me the audio of the July 5th, 2012 unnoticed bail hearing wherein Keith Loomis appeared with me (it was also an arraignment for the July 3rd, 2012 arrest.
Your September 30th, Motion to Withdraw violated Nevada law. I need that audio in 12 CR 12420 and I also want you to get the audio from the associated protection order
hearing in RJC RCP2012-000287, Milan Krebs v. Zach Coughlin.
Please get that to me right away or provide me with the $70 it would cost me to do it. Further, I want all the police reports and or records in any way connected to the "10 visits" by
the RPD to Northwind Apartments, and I don't have the $25 subpoena fees, and I also want Sargent Dye, Officer Weaver, Sargent Oliver Miller, Lieutenant Brown, Sargent Bradshaw,
and the Emergency Dispatch and RPD custodians of records served with subpoenas and for subpoena duces tecums to be sent out demanding all media recordings and documentation
in any way connected to Zach Coughlin, including dispatch recordings and logs, and 911 calls. Please do this right away Mr. Sotelo, and or provide me with the fees and costs
necessary for me to do it in your stead. FURTHER, PLEASE INDICATE SPECIFICALLY WHAT EXACTLY YOU FEEL COUGHLIN WAS DOING OR MIGHT DO THAT WAS
SO OBJECTIONABLE OR REPUGNANT, AND INDICATE WHY YOUR THROWING COUGHLIN UNDER THE BUS AS YOU DID IS NOT TANTAMOUNT TO
MISCONDUCT AND OR LIBEL.
FW: respectfully submitted
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the practice and proceedings of justice courts in similar cases. An
appeal perfected transfers the action to the district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS 5.010. The municipal court
must be treated and considered as a justice court whenever the proceedings thereof are called into question.
178.405 - Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant;
notice of suspension to be provided to other departments.
178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial, when upon conviction the defendant is brought up for
judgment or when a defendant who has been placed on probation or whose sentence has been suspended is brought before the court, if doubt arises as to the competence of the
defendant, the court shall suspend the proceedings, the trial or the pronouncing of the judgment, as the case may be, until the question of competence is determined.
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any other departments of the court of the suspension in writing.
Upon receiving such notice, the other departments of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to be competent.
[1911 Cr. Prac. 536; A 1919, 416; 1919 RL 7386; NCL 11184](NRS A 1967, 1449; 1981, 1656; 1991, 1003; 2003, 1018; 2007, 186)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 10/11/12 3:54 PM
To: renodirect@reno.gov; kadlicj@reno.gov; rjcweb@washoecounty.us; zyoung@da.washoecounty.us; bdogan@washoecounty.us; jleslie@washoecounty.us;
jbosler@washoecounty.us
6 attachments
20120605_101513 Northwind manager handy man attacks from golf cart 6 5 12.mp4 (3.1 MB) , landlord tenant law manual for police in minnesota.pdf (735.1 KB) ,
Police_manual_-_final_as_adopted_by_State's_Attorney.pdf (263.7 KB) , trespass criminal civil evictdion.pdf (69.8 KB) , 6 8 12 fax to northwind with page numbers.pdf
(50.7 KB) , northwind fax 6 4 12 habitability retaliation etc.pdf (45.8 KB)
Zach Coughlin
RE: Coughlin: RCR11-063341 (Petit Larceny) and RCR12-067!0 (Re"i"ting) and RCR2012-06#630 ($i"ue o%
11)
&ro$: 'ach Coughlin ((achcoughlin)hot$ail*co$)
+ent: ,hu 10-11-12 6:31 P.
,o: /le"lie)0a"hoecounty*u"1 eno2a3)0a"hoecounty*u"1 lti44al")0a"hoecounty*u"1
c%ortier)0a"hocounty*u"1 /goodnight)0a"hoecounty*u"1 4dogan)0a"hoecounty*u"1
/4o"ler)0a"hoecounty*u"1 lgray)0a"hoecounty*u"1 lcarl"on)0a"hoecounty*u"1 r/c0e4)0a"hoecounty*u"1
renodirect)reno*go21 co5logicr5d)reno*go21 da2idc)n24ar*org1 t"u"ich)n2detr*org1 5atric33)n24ar*org1
n2"ccler3)n2court"*n2*go2
6utloo3 7cti2e 8ie0
attach$ent" (total 6*3 .9)
"u45oena" and "u45oena duce" tecu$" to "er2e %or client Coughlin redcuced %ile "i(e*5d%:o0nload
5olice re5ort coughlin 7 11 again"t RP: :uralde Ro"a - Co5y*ht$9loc3ed
5olice re5ort coughlin REP6R,;<= RP: :>R7L:E R6+7 97R<E+ :>R;6 E,C 6& 7 11*5d%:o0nload
(c 1 ! 12 reno 5olice de5art$ent online 5olice re5ort 4urglary durden etc*ht$9loc3ed
2012060#?101#13 <orth0ind $anager handy $an attac3" %ro$ gol% cart 6 # 12*$54:o0nload
R.C tran"cri5t" on a55eal %ailure to 5e5are Pa$ Longoni cr12-101!*5d%:o0nload
:o0nload all a" (i5
:ear @CP:A @C:7A and Reno Police :e5art$entA
Plea"e con"ider thi" co$$unication to 4e the %iling o% a 5olice re5ort*
Bou guy" ta3e action during a 5ending Co$5etency E2aluation all the ti$e***"ee =oodnight "etting the ,rial %or
.ay a%ter the 2-27-12 6rder %or Co$5etency E2aluation that :ogan 5rocured a%teA u5on in%or$ation and 4elie%A
a55arently 2iolating $y attorney client 5ri2ilege 0ith ::7 Boung and the R.C-Cudge <a"h Dol$e" (and a
"igned letter 4y Cudge <a"h Dol$e" the the +tate 9ar o% <e2ada dated .arch 12thA 2012 ad$it" to
corre"5ondence and or co$$unication" 4et0een the @CP: and R.C-Cudge <a"h Dol$e" concerning
CoughlinA to 0hich the @CP: ha" "tead%a"tly re%u"ed to 5ro2ide any an"0er" to CoughlinE" Fue"tion")*
.r* Le"lieA thatE" the the thingA though* Bou are "till collecting a "alary 4a"eA in 5artA on your 4eing li"ted a" $y
attorney o% record* &or the ti$e 4eingA you ha2e a duty to re5re"ent $e* Bou %ailed to "u45oena any4ody in
thi" ca"e***=oodnight $anaged to "care ,e$5leton and :a0"on into "ho0ing on Culy 16thA 2012 (that 0a" a
,rial dateA Ci$A de"5ite your 4lundering characteri(ation o% it on the ta5e-tran"cri5t" o% your a4o$ina4le
Ge%%ort"G at re5re"entation at the Dearing on the .otion to +u55re"" and the ,rial (7ugu"t 2thA and +e5te$4er
#thA 2012)*

Plea"e co5y $e 2ia %aH and e$ail on any and all %iling" 0ith the court in any o% the $atter" the @CP: a55ear"
%or $e on* .r* Le"lieA you $aintain you ha2e a "u5er2i"ory ca5acity that ha" allo0ed you to chi$e in %ro$ the
chea5 "eat" in e%%ort" to thro0 $e under the 4u" and 5lay CB7A in $atter" and hearing" 0here :ogan or
1-1#
=oodnight 0ere a55earing***4ut then you %ail to actually %ul%ill any o% the dutie" attendant to "uch an
arrange$ent 0hen ; reFue"t a co5y o% $y %ile %ro$ you in RCR2012-06#630 (not to $ention the Culy 31"tA 2012
.otion to 7$end Co$5laint 4y ::7 BoungA or :oganE" utter %ailure to co$$unicate 0ith $e in any 0ay
0hat"oe2er***clearly you ha2e i$5o"ed a Egag orderE on :ogan "i$ilar to the one you i$5o"ed on =oodnight at a
hearing in RCR2011-063341A and ; ha2e the CourtE" audio %ro$ all tho"e hearing"A Ci$A and it ainEt good %or you
0hatE" one the$A 3no0 0ot ; $eanI :ogan and =oodnight 0ill %ind una2ailing any de%en"e" the "ee3 to a""ert
to the e%%ect that GCi$ Le"lie $ade $e do itG* =66:<;=D,A ; D78E REJ>E+,A ;< @R;,;<=A 7<
EKPL7<7,;6< &R6. B6> &6R B6>R +>::E< :;+7PPE7R7<CE .;<>,E+ PR;6R ,6 ,DE C>LB
16,DA 2012 ,R;7L :7,EA 7<: ,DE RE+P6<+E+ B6> D78E PR68;:E: +6 &7R D78E 9EE<
;<C6.PLE,E* PLE7+E RE+P6<: C6.PLE,ELBA ;< @R;,;<=* .R* :6=7<A +;.;L7RLBA ; D78E
REJ>E+,E: REP6<+E+ &R6. B6>A ;< @R;,;<=A 7+ ,6 ,DE EK,E<, 7<: C6<,E<, 6& B6>R
C6..><;C7,;6<+ @;,D ,DE R.CA C>:=E <7+D D6L.E+A LE;,D L66.;+A E,C*A E,C* @D;LEA
&6R 7 ,;.EA B6> +EE.E: ,6 E=E, ;,E ,D7, B6> @ERE 9E;<= >+E: (7<: C;. LE+L;E
,E+,;&;E: ><:ER 67,D ,D7, DE D7: <6 L<6@LE:=E 6& 7<;C7,;6<+ 9E,@EE<
,DE R.C-C>:=E <7+D D6L.E+A 7<: ,DE @CP: ;< 7R
RE+P6<+E+ ,6 &7R D78E 9EE< ;<C6.PLE,E 7+ @ELL* PLE7+E RE+P6<: ,6 .B ;<J>;R;E+A
;< @R;,;<= 7<: CE7+E &7;L;<= ,6 REC6=<;'E .B ;<8;6L79LE R;=D, ,6 C6<:>C,
:;+C68ERB 7<: +>9P6E<7 @;,<E++E+ 7<: :6C>.E<,7,;6<* ; :6 <6, @7<, ,DE @CP:
;<&6R.7LLB REJ>E+,;<= ;<&6R.7,;6< 6R &6R @;,<E++E+ ,6 7PPE7R** ,D;+ <6
,6>R<7.E<,A :7<;EL-+6<A ,D;+ &6R RE7L* ; @7<, RE7L +>9P6E<7+A 7<: +>9P6E<7
:>CE+ ,EC>.+ +ER8E: 6< ,DE ;<:;8;:>7L+ @D6. ; D78E REJ>E+,E: ,DE 9E +ER8E:
6<* <6, E8ERB :;.E 6& B6>R 9>:=E, +D6>L: =6 ,6 B6>R +7L7R;E+*
Plea"e 5ro2ide $e 4y e$ail and %aH a co5y o% $y Co$5etency E2aluation and any other docu$entation
"u4$itted there0ithA incident to the +e5te$4er #thA 2012 6rder %or Co$5etency E2aluation*
.r* =oodnightA 5lea"e eH5lain your action" in "etting ,rial date"A de"5ite $y eH5re"" indication that you re%rain
%ro$ doing "oA during the 5endency o% the 6rder %or Co$5etency E2aluation (you %iled ReFue"t" %or
+u4$i""ion on .ay 3rdA 2011A and "et a ,rial date %or .ay 7thA 2012A de"5ite the %act that Cudge ElliotE" 6rder
in CR12-0376 did not re$and /uri"diction 4ac3 to the RCC until it 0a" %ile "ta$5ed on .ay thA 2012* @hat
occurred at the .ay 7thA 2012 G,rialG dateA 0herein you a55eared utterly un5re5ared to go %or0ard 0ith ,rial
(you ad$itted "o$e thing" that dayA 2i" a 2i" your %ailure to e2en 2ie0 certain eHcul5atory 2ideo" that 0ere
5ro2ided to you that i" on 5ar 0ith the 5u4lic de%ender" 0ho %ell a"lee5 at trial****G@ee3end at 9ernieE"G indeed*
@ee3end at Cere$yE"*
.r* =oodnightA 0hat ocuredat the .ay 7thA 2012 ,rialA in ca$eraA ought 4e indicati2e to you o% the rationale
4ehind the dictate" o% <R+ 17!*40#* <o0A i% ; get arre"tedA 5re-trial "er2ice" cite" to "o$e eH5ul"ion %ro$
.ental Dealth Court a" a 4a"i" %or denying $e an 6R* .y 4eing in /ail %ro$ Culy 3rdA 2012 to Culy 21"tA 2012
re"ulted in $y 4eing 5re2ented %ro$ challengeing a M40A0#0 attorneyE" %ee" a0ard again"t $e 5er"onallyA and
that eHtended incarceration 0a" 4a"ed largely u5on 5re-trial "er2ice" citing to the .CD "ituationA 0hich
in2ol2ed negligence and $i"conduct on =oodnight and the @CP:E" 5art (;E$ loo3ing at you Cenni%er Rain") in
%ailing to counter the lie" told 4y Reno 9iondo and +haron :ollarhide)* Plea"e addre"" the inaccuracie"
contained in the RCC %iled in all three $atter"A includingA 4ut not li$ited toA the li4elou" 0riting" 4y Reno
9iondoA co2ering u5 the .CDE" 4reach o% the contract entered into 0ith $e in .ay 2012 ("ee $y earlier 0ritten
corre"5ondence to you in thi" regardA co$5lete 0ith that .CD ContractA and the li"t o% 5rohi4ited $edication"A
0hich did not include the $edication ; 0a" "u4"eFuently re$o2ed %ro$ the .CD %or ta3ing***0hich 0a" 5ri2ate
in%or$ationA until :ogan 2iolated $y D;P77 right"A 0ith Cere$y 9o"ler and Chri" &ortierE" 4le""ingA "o$e $ay
"ayA intentionally in an atte$5t to di"credit $e and 5lay CB7 %urther %or the @CP:A in addition to 9o"lerE"
2-1#
i$5er$i""i4le %aHing to the R.C $aterial" %ro$ La3eE" Cro""ing that eHceeded the "co5e o% any authori(ation
Leith Loo$i" $ay ha2e coerced out o% $e incident to the Culy #thA 2012 unnoticed 4ail hearing in R.C
12CR12420 (charge under5inning that cu"todial arre"t ha" 4een dro55ed)* 9o"ler %aHed $aterial" that eHceed
the li$ited authori(ation to 5ro2ide the teHt only o% the Co$5etency E2aluation" conducted 4y La3eE" Cro""ingA
including letter" %ro$ :r* <iegh4or" and other" that 0ere not 5art o% the Co$5etency E2aluation and included
in a Ci$ Le"lie-"tyle atte$5t to thro0 oneE" client under the 4u"A 5eriod*
Ci$A you 3no0 %ull 0ell that ; ha2e 4een clear to you that ; 0i"h to te"ti%y at ,rial and at the Dearing on the
.otion to +u55re""A and %urtherA that ; 0i"h to retain all right" ; ha2e 0ith re"5ect to li$iting the "co5e and
5lace$ent o% "uch te"ti$ony (order o% 5re"entationA etc*) and the all conco$itant right" to ha2e the +tateE"
0itne""e" i$5eached 0ith the eHcu5latory 2ideo and audio e2idence the @CP: 0a" 5ro2idedA 0hich ; ha2e
declared to youA under 5enalty o% 5er/uryA 0a" %il$ed or recorded 4y $e and ha" not 4e doctored or altered in
any 0ay***though ; ha2e "ought an indication %ro$ you 0ith re"5ect to the eHtent that G"ni55et"G o% the 2ariou"
2ideo or audio $ay 4e utili(ed at the +u55re""ion Dearing or ,rialA to 0hich you "co%%ed that $y 0ondering
"uch a thing 0a" indicati2e o% $y lac3 o% %itne"" to 4e an attorneyA a" you %eel that only the +tate "hould 4e
allo0ed to "electi2ely choo"e 0hat it 5ut" into e2idence or u"e" to re%re"h 0itne"" recollection or i$5each
te"ti$onyA a con"tant the$e throughout the Ci$ Le"lie de%en"e 5lay4oo3* ,he +tate ha" 4een 5ro2ided all tho"e
eHcul5atory $edia $aterial"A .r* Le"lie* Plea"e 5ro2ide "o$e legal citation %or you contention that it 0ould 4e
i$5er$i""i4le to introduce or utili(e only "elected 5ortion" o% "uch $edia 0here the +tate clearly ha" an a4ility
to utili(e any 5ortion" thereo% that it $ay "o choo"e*
; 4elie2eA .r* Le"lie that you ha2e duty to "ee3 to correct the in/u"tice 5er5etuated the Dearing on the .otion to
+u55re"" 0here you de5ri2ed $e o% $y right to te"ti%yA includingA 4ut not li$ited toA your 4right line re%u"al to
utili(e any o% the eHcu5latory $edia (to "ho0 0itne"" 4ia"A %or i$5each$entA or to re%re"h 0itne"" recollectionA
"uch at ::7 Boung "ho0ing :uralde 5ortion" o% hi" 5olice re5ort 4ut not introducing it into e2idenceA etc*) or
"ee3 their introduction*
PLE7+E D78E ,DE 7,,7CDE: +>9P6E<7+ 7<: +>9P6E<7 :>CE+ ,EC>.+ +ER8E:* <icole
@at"on and Lucy 9yington and 7u"tin Lichty (and ; 5ro2ide Le"lie 0ith LicthyE" licen"e 5late nu$4erA "o
"u45oena hi" addre"" %ro$ the :.8) are "tudent" at .cJueen Digh +chool in RenoA <e2adaA "oA "houldnEt 4e
too hard to trac3 the$ do0n* Court %iling" "ho0 the the @CP: ha" addre""e" %or ,e$5leton and :a0"onA and
Le"lie $ade indication that the @CP: ha" <icole @at"onE" addre""A yet only li"ted her tele5hone nu$4er in a
court %iling li"ting 0itne""e" the de%en"e intend" to callA an act 0hich i$5eriled the a4ility the actually call herA
gi2en the +tateE" antici5ated o4/ection 4a"ed u5on a lac3 o% 5ro2iding an addre"" %or her 0here the @CP: ha"
one* ,he 11 di"5atch record" and call log" and the call record" %ro$ the iPhone allegedly 4elonging to =o4le
0ill re2eal the cellular nu$4er o% G>&C =uyGA the one a""ailant 0ho"e na$e Le"lie %ailed to elicit te"ti$ony
direct toA de"5ite alleged 2icti$ =o4le indicating that that early t0entie" "o$ething $ale indi2idual" 0a" Gthe
$o"t 5hy"ically aggre""i2e 0ith CoughlinG and that it 0ould ha2e 4e rather rea"ona4le %or Coughlin to %eel
attac3ed and threatened 4y that indi2idual*
&urtherA ; :E.7<: ,6 9E PR68;:E: ,DE .7,ER;7L+ PR6:>CE: 9B 7,N, 6R 7R P>RP6R,E: REJ>E+, &6R ,DE C7LL REC6R:+-;<:;C;7 6&
6@<ER+D;P 6& ,DE ;PD6<E 6& 6<E C6RB =69LEA 24A 6& RE<6A <E87:7 (including $aterial"
relati2e to =o4leE" incon"i"tent te"ti$ony 2i" a 2i" the o0ner"hi5 o% the iPhone and the $anner and ti$e at
0hich he ca$e to 5o""e""A it* Plea"e ha2e =o4leE" 4rotherA Ryan =o4leA "er2ed a "u45oena and +u45oena :uce"
,ecu$ in that regardA a" =o4le ha"A in hi" @itne"" +tate$ent and te"ti$ony a" trial $ade incon"i"tent a""ertion"
3-1#
a" to ho0 he got the iPhone and 0hen)* 7l"oA =o4leE" "0orn te"ti$ony that he hadA a" o% the day he 0a"
te"ti%yingA not heard anything o% "o$e $an o%%ering the iPhone u5 to the deni(en" o% the "3ate 5ar3 or a4out any
attac3" on Coughlin (and a cla""ic $o$ent occurred 0hen Le"lie $ade a hear"ay o4/ection on 4ehal% o% the
+tate incident to Le"lieE" o0n Fue"tion regarding a i$$unity %ro$ 5ro"ecution a%%orded =o4le %or the Cune #thA
2012 lit cigarette a""ault and 4attery u5on Coughlin 4y =o4leA 7<: +PE7L;<= 6& ,D7,A PLE7+E
+>9P6E<7 ,DE B6><= @6.7< :R;8;<= ,DE LEK>+A @D6+E L;CE<+E PL7,E 7PPE7R+ 6<
,DE 8;:E6 PR68;:E 6& ,D7, 7++7>L, 7<: 97,,ERB 7<: DER +>9+EJ>E<, ,R7+D
,7LL;<=A @D;CD @7+ +L>RRE:)*
; @7<, 7 C6PB 6& 7=DL;< ,6 6R &R6. E.ER=E<CB :;+P7,CD +ER8;CE+A ,DE
RE<6 P6L;CE :EP7R,.E<, (@DE,DER ,DE C7LL+ 9E,@EE< C6>=DL;< 7<: L;E>,E<7<,
9R6@< 6R +7R=E<, 6L;8ER .;LLERA +7R=E<, '7CD ,DE@ 6R 7<B6<E EL+E* &>R,DERA ;
@7<, ,DE 11 C7LL 7<: :;+P7,CD REP6R,+ ;<C;:E<, ,6 ,DE C7<>7RB 12,DA 2012
C>+,6:;7L 7RRE+, 6& C6>=DL;<+ &6R C7B@7LL;<=A @DERE;< R;CD7R: =* D;LLA E+J*
C7LLE: ,DE P6L;CE 7<: +;=<E: 7 CR;.;<7L C6.PL7;<, 7=7;<+, C6>=DL;< &6R
,RE+P7++;<=* &urtherA ; 0ant a de%en"e 5re5ared that %ocu"e" on the @itne"" 9ia" and $oti2e" o% the Reno
Police :e5art$ent and the retaliatory arre"t" and 5ro"ecution" and di"cri$inatory en%orce$ent o% the cri$inal
la0A 5articularly 0here $y 5olice re5ort" and reFue"t" %or 5olice re"5on"e to 2ariou" $atter" ha2e gone
unre"5onded to (the .ay 2012 call" and co$$unication" at =+R 0ith RP: 6%%icer Loo3 a4out the the%t o% $y
=ary &i"her .ountain 4i3eA 0herein 6%%icer Loo3 re%u"ed to ta3e actionA de"5ite hi" 4eing a 5roce"" "er2er %or a
ci2il ,P6 5rocured 4y DillA 0hich Dill ha" "igned a "0orn :eclaration indicating he "ought at the RP:G"
direction (and the RP:A in +argent 6li2er .illerA +argent :yeA and 6%%icer 7lan @ea2er ha" de$on"trated an
intent and action" de"igned to in"titute %raudulent charge" again"t Coughlin (2i" a 2i" the .ilan Lre4" ,P6A
0hich Le"lie and :ogan ha2e re%u"ed to gather the audio %ro$ in RCC RCP2012-0002!7 de"5ite it" clear
$aterial rele2ance and utilityA e"5ecially 2i" a 2i" "u45oeaning Lre4" and inter2ie0ing hi$ incident to the
de%en"e in RCR2012-067!0 (and you 4etter hurryA Ci$A a" Lre4E" a2aila4ility $ay 4e li$ited i% he i" "ent 4ac3
into $ilitary "er2ice o2er"ea")* PLE7+E PR68;:E .E 7 C6PB 6& ,DE DE7R;<= 6< LRE9E+ ,P6
9E&6RE C>:=E 7L9R;=D,* &urther PLE7+EA &6R ,DE +7.E P>RP6+E+A =7,DER 7.E<,7,;6<A C7LL REC6R:;<=+ 6R REC6R:+A :;+P7,CD L6=+ 6R REC6R:;<=+A
@;,<E++ +,7,E.E<,+ E,C ;<C;:E<, ,6 ,DE +EP,E.9ER 1!-2#,D D7R7++.E<, 6&
C6>=DL;< 9B ,DE RP: 7, +>PER;6R .;<; +,6R7=EA ;<CL>:;<= ,D7, 9B +7R=E<, 6L;8ER
.;LLER 7<: 6&&;CER @E78ERA 7+ 0ell a" a call to la0 en%orce$ent reFue"ting a re"5on"e "i$ilar to that
"ho0n 4y the R+;C Police to @al-.art" urgent 5lea" %or hel5 incident to an alleged the%t o% a candy 4ar that ha"
%or$ed the 4a"i" %or a no0 4 $onth long "u"5en"ion o% CoughlinE" la0 licen"eA 0here a <orth0e"t Reno 7-11
con2ereted a55rHoi$ately M1*#0 %ro$ Coughin incident to ad2erti"ing one 5rice %or ga"olineA then charging
another***,he RP: re%u"ed to in2e"tigate or re"5ondeA $uch le"" a55ear to 2iolate the 7-11 $anager" &ourth
7$end$ent right"* +i$ilarly "u45oena the 6%%icerE" 0ho$ re5onded to Coughlin 11 call" incident to the
a""ault and 4attery 4y Cory =o4le on or a4out />ne #thA 2012A a" 0ell a" re5ort" 4y Coughlin and any 5olice
record" incident thereto 0ith re"5ect to the 6cto4er 4thA 2011 the%t o% CoughlinE" $ountain 4i3eA and Richard =*
Dill and .atthe0 C* .erli""E" tre"5a"" into CoughlinE" %or$er ho$e la0 o%%ice on <o2e$4er 13thA 2011A in
addition to DillE" 2ideo ta5ed con%e""ion to hi" contactorA Phil +te0art ha2ing a55arently "tolen CoughlinE"
ladder %or a 5eriod o% ti$e*PLE7+E .7LE <6,E 6& ,DE C>R;6>+ 7PPE7R7<CE 6& RP: +7R=E<,
9R7:+D7@ ,DR6>=D6>, 7LL ,DE+E .7,,ER+ 7<: .7LE ;<J>;RB RE+PEC,;<= 7:;6 &R6. ,DE C>LB #,DA 2012 7RR7;=<.E<, 7<:
;.PR6.P,> 97;L DE7R;<= ;< R.C 12CR12420 @DERE;< @;,<E++ 9;7+A .6,;8EA 7<: RP:
7<;.>+ 7=7;<+, C6>=DL;< RELE87<, ,6 ,DE ,DREE .7,,ER+ ,DE @CP: ;+ C>RRE<,LB
7PPE7R;<= 6< C6>=DL;<E+ 9ED7L& &6R ;+ CLE7RLB RE8E7LE:* PLE7+E +>9P6E<7 7=DL;< (;<CL>:;<= 7=DL;<E+ L7+, <7.E
;+ .;+PELLE: C>6=DL;<)A ;<CL>:;<= ,DE REP6R,+ &;LE: 7=7;<+, <6R,D@;<:+
7P7R,.E<,+ &6R ,DE;R 7,,E.P,E: 9RE7L ;<+ 7<: ,RE+P7++E+ ,6 C6>=DL;<E+ RE<,7L+
,DEREA 7<: ,DE ,RE+P7++E+A 7,,E.P,E: ,RE+P7++E+A 7<: 7,,E.P,E: 9RE7L ;<+ 9B
6&&;CER @E78ER 7<: <E87:7 C6>R, +ER8;CE+ >P6< C6>=DL;<E+ RE<,7L ,DERE 7+
@ELL* 7l"oA include the %ailed re"5on"e" 4y the RP: to the do$e"tic 2iolence again"t Coughlin detailed in :
&812-001!! '7CD7RB C6>=DL;< 8+* L7>R7 &6RE+DEE (:.)A and &812-001!7)* 6DA 7<: ,DE
&7;L>RE ,6 RE+P6<: ,DE ,DE P6L;CE REP6R, &;LE: 9B C6>=DL;< :E,7;L;<= ,D
:ECE.9ER 12,DA 2012 9>R=L7RB 6& 7PPR6K;.7,ELB M!A000 6& PR6PER,B &R6.
C6>=DL;<E+ &6R.ER L7@ 6&&;CEA :>R;<= 7 PER;6: ;< @D;CD R;CD7R: =* D;LLA E+J* @7+
7PPLB;<= 7< ><L7@&>L RE<, :;+,R7;<, >P6< C6>=DL;<E+ PER+6<7,LB 7<: CL;E<,E+
&;LE+ 7<: @DERE 8;:E6 :R;8ER+ L67:E: 6<,6 C6>=DL;<E+ D7R: :R;8E+ 6< :ECE.9ER
6,DA 2012 @7RR7<, 7< ;<8E+,;=7,;6< ;<,6 ,DE EK,E<, ,6 @D;CD D;LL 8;6L7,E:
C6>=DL;<E+ PR;87CB R;=D,+ 7<: 6R 6PP6+;<= C6><+ELE+ &;LE+ ;< ,R7;P+;<= ,DR6>=D
C6>=DL;<E+ L7@ 6&&;CE 7<: 7LLE=E:LB 7CCE++;<= 6R 7,,E.P,;<= ,6 C6PB D7R:
:R;8E+* &>R,DERA 7 CR;.;<7L ;<8E+,;=7,;6< ;<,6 ,DE EK,E<, ,6 @D;CD R;CD7R: =*
D;LLA E+J* &;LE: 7 &7L+E P6L;CE REP6R, 7<: 6R C6..;,,E: PERC>RB :>R;<= ,DE
CR;.;<7L ,RE+P7++ ,R;7L 6& C6>=DL;< ;<C;:E<, ,6 ,DE <68E.9ER 13,DA 2011 7RRE+,
9B RP: CDR;+ C7R,ER (7<: 7< ;<8E+;,=7,;6< 7<: C6.PL7;<, 7=7;<+, RP: 6&&;CER
CDR;+ C7R,ERA CR* ;+ DERE9B &;LE:A PLE7+E PL7CE 7 C6PB 6& ,D;+ ;< D;+ E.PL6B.E<,
&;LE 7<: ;<8E+,;=7,E 7+ ,6 ,DE EK,E<, ,6 @D;CD C7R,ER 8;6L7,E: <R+ 1*
+6.E,D;<= 796>, .;+C6<:>C, ;< D;+ 6&&;C;7L C7P7C;,B 6R &7L+E +,7,E.E<,+ ;< D;+
P6L;CE REP6R, @DERE DE P>RP6R,+ ,D7, DE 7<: +7R=E<, L6PE' ;:E<,;&;E:
,DE.+EL8E+ 7+ RP: 6R 7C,;<= ><:ER C6L6R 6& L7@ 9E&6RE ,DE L7<:L6R:
7PP7RE<,LB L;CLE: ;< ,DE :66R ,6 ,DE J>7+;-97+E.E<, 7, C6>=DL;<E+ &6R.ER L7@
6&&;CEA :E+P;,E ,DE &7C, ,D7, +7R=E<, L6PE' .7B D78E 7:.;,,E: 6< 8;:E6 ,D7,
<E;,DER +DE <6R C7R,ER ;:E<,;&;E: ,DE.+EL8E+ 7+ L7@ E<&6RCE.E<, ;< 7RE: ,E+,;.6<E 1!,DA 2012 ,R;7L ;< ,D7, .7,,ER (+EE
7,,7CDE: ,R7<+CR;P, 9B P7. L6<=6<;A @D;CD .7B <6, <ECE++7R;LB 9E 7CC>R7,ELB
7<: &7;,D&>LLB ,R7<+CR;9E: =;8E< RECE<, 7LLE=7,;6<+ 9B 6,DER 7=7;<+, L6<=6<;
7<: ,DE &7;L>RE 6& +DE 7<: ,DE R.C ,6 &6LL6@ <R+ 1!*030 ;<C;:E<, ,6 ,DE @7L-
.7R, C6<8;C,;6< 6& C6>=DL;< ;< 11 CR 22176 7<: +>9+EJ>E<,LB &7;LE: 7PPE7 (Cudge
ElliotE" 6rder cite" the %ailure to 5oint to "ection" o% a tran"cri5t that 0a" the R.CE" re"5on"i4ility to ha2e
5roduced 0ithin 10 day" o% CoughlinE" :ece$4er 13thA 2011 %iling o% a <otice o% 755eal)L ;< CR11-2064)* ;
@7<, 7 C6PBA ; :6<E, @7<, LE+L;E PRE,E<:;<= ,6 D78E 69,7;<E: ,DE 7>:;6 7<:
.7L;<= G7< EKEC>,;8E :EC;+;6<G ,D7, ;+ @7+ <6, RELE87<, 6R >+E&>L (Ci$A you really
need to co$e u5 0ith another go to $o2eA you u"e that one 0ay too $uch*)*
&urtherA ; 0i"h to %ile a 5olice re5ort again"t City o% Reno .ar"hal Darley %or 0hat 0ere 5ur5ortedly %al"e
"tate$ent" $ade to R.C Cudge <a"h Dol$e" leading to $y arre"t on &e4ruary 27thA 2012* Cudge <a"h Dol$e"
in her 5re"entation in court on .arch 12thA 2012 indicate" that DarleyA a55arentlyA %ollo0ed Coughlin into the
re"troo$ at the R.C and 5eered into a "tallA 5ur5orting to 0itne"" Coughlin Gdi"a""e$4le hi" "$art5honeG or
recording de2ice (and "u$$ary conte$5t %inding" %or conduct allegedly occurring out"ide the courtE" 5re"ence
reFuire and a%%ida2itA and hereA .ar"hal Darley need" to "u4$it and 7%%ida2it and eH5lain hi" $i"conduct and or
lie"A a" doe" .ar"hal :eightonA :e5uty DodgeA ,ri"h 9ec3$anA .ary Landara"A 9iray :oganA and any other
indi2idual" connected to the action" ta3en again"t Coughlin in connection 0ith that &e4ruary 27thA 2012 arre"t
u5on the "u"5en"ion o% the tra%%ic citation ,rial in 11,R26!00* ,he 5ur5orted "earch incident to arre"t o%
CoughlinE" D,C =2 "$art 5honeA hi" +a$"ung %li5 5honeA and a $icro "d card (the data 0a" 0i5ed %ro$ the
#-1#
"$art5hone and the $icro "d card u5on the"e ite$" %inally 4eing returned to Coughlin "o$e 37 day" later*** and
it 0a" i$5er$i""i4le %or the "$art5hone and data card to 4e 4oo3ed into 5ro5erty on &e4ruary 27thA 2012 at the
@a"hoe County :etention CenterA only to 4e retrie2ed the %ollo0ing day 4y the City o% Reno .ar"hal" and
returned to the R.C***that i" not a "earch incident to arre"tA it i" not clo"e enough in ti$e to the arre"tA it
occurred a%ter the 5ro5erty 0a" already 4oo3ed into 5ro5erty at the @C:C and there 0a" not ri"3 o% "5oliation
o% Ge2idenceGA 5articulary 0here neither .ar"hal DarleyA Cudge <a"h Dol$e"A nor City 7ttorney 7lli"on 6r$aa"
ha" 4een reFuired to "ay $uch o% anything on the record to e"ta4li"h the 5ro4a4le cau"e %or conducting "uch an
unla0%ul "earch indicent to arre"tA or the rationale %or "uch an arre"t any0ayA 4eyond a "ee$ingly 5reteHutal
%inding that Coughlin co$$itted G"u$$ary cri$inal conte$5tGA $ade one "econd a%ter Coughlin uttered the
te"ti$ony: G+argent ,arter lied 0hen he "aid that****G and $ade /u"t $inute" a%ter CoughlinE" return %ro$ a
re"troo$ 4rea3 0here Cudge <a"h Dol$e" ordered the City o% Reno .ar"hal" to acco$5any Coughlin into the
re"troo$A and u5on returing Cudge <a"h Dol$e" i$$ediatelyA "ua "5onteA 4egan interrogating Coughlin and
atte$5ting to coerece con"ent %ro$ Coughlin to an i$5er$i""i4le 2iolation o% CoguhlinE" &ourth and &i%th
7$end$ent right"A and 0here Cudge <a"h Dol$e" later $ade the erronoue" and co$5lete un"u55orted 4y
"5eci%ic %act" or e2idence %inding that Coughlin GliedG or G5ro4a4ly liedG 0ith re"5ect to Fue"tioning 4y Cudge
<a"h Dol$e" a" to 0hether Coughlin 0a" recording the 5roceeding* @C+6 Patricia 9ec3$an 5ro2ide
Coughin a hand0ritten note at the @C:7 indicatingA 4ut un"igned that G5er Cudge" 6rder"A contact R.C
.ar"hal :ayton (:eightonA "ic)G in re"5on"e to CoughlinE" 5oint Fue"tioning" regarding the chain o% cu"tody
and 5o""e""ion o% the the "$art5hone and $icro "d card 4oo3ed into CoughlinE" 5er"onal 5ro5erty 4y the
@C:C "ta%% on &e4ruary 27thA 2012A and a55arently retrie2e the %ollo0ing day 4y the City o% Reno .ar"hall"A
an i$5er$i""i4le atte$5t at conducting a "earch incident to arre"t %or G"u$$ary cri$inal conte$5tG that 0a" in
no 0ayA at lea"t on 5a5erA related to any action" 4y Coughlin con"cerning any 5ur5orted GrecordingG or
Grecording de2ice"G 4ut ratherA 5erha5" 5reteHuallyA to CoughlinE" G5er"i"ting in line" o% inFuiry a%ter 4eing
ad$oni"hed 4y the Court to cea"e doing "oG and other %airly innocuou" "ounding allegation" that a55arently
0arranted a "u$$ary # day incarceration o% then attorney CoughlinA de"5ite hi" indication that hi" clientE"
intere"t" $ay 4e 5re/udiced 4y the lac3 o% any "tay at allA and 0here M100 in 4ail 0a" retained 4y the R.CA
de"5ite Coughlin not 4eing relea"ed a day early a" agreed to* ,hat &e4ruary 27thA 2012 +tatu" Con%erence in
RCR2012-06#630A occurring out"ide :oganE" clientE" 5re"enceA 0hich "tarted at a55roHi$ately 3:00 5$ a%ter
Cudge <a"h Dol$e" 0a" %inally located 4y her a""i"tant***and curiou"ly clo"e in ti$e to the clande"tine &e4ruary
27thA 2012 +tatu" Con%erence 4et0een @CP: 9iray :ogan and ::7 'ach Boung (0hich Coughlin had 4een
5ro2ided noticeA in 0ritingA on &e4ruary 24thA 2012A to the e%%ect that that +tatu" Con%erence in that $atter
RCR2012-06#630 0a" continued to .arch 2thA 2012 in light o% a "cheduling con%lict 0ith CoughlinE" R.C
tra%%ic citation ,rial (incident to RP: +argent ,arterE" <o2e$4er 1#thA 2011 order %or "o$e other o%%icer 0ho
0a"nEt e2en there that ,arter called in /u"t to 0rite the tic3etA "trangelyA u5on ,arter telling Coughlin to lea2e
Richard =* D;llA E"F*E" o%%icerA 0here Coughlin had gone "ee3ing hi" "tate i""ued dri2erE" licen"eA 0alletA 3ey"A
and clientE" %iled u5on 4eing relea"e %ro$ 3 day" in cu"tody incident to a cu"todial tre"5a"" arre"t o2 <o2e$4er
13thA 2011 4y RP: Chri" CarterA 0ho$ lied in hi" 5olice re5ort regarding 0hether Coughlin indicated a
re"i"tance to lea2ing the 5re$i"e" a%ter 4eing told toA or gi2en a 0arning (and CarterE" lie" are con%ir$ed 4y the
2ery 2ideo ta5e" o% the interaction" that Richard =* D;ll 5ro5ounded to the Reno City 7ttorneyE" 6%%iceA not that
that "to55ed Chri" Da(lett-+te2en" %ro$ "u4orning D;llE" 5er/uryA "i$ilar to Pa$ela Ro4ert" "u4orning the
5er/ury o% R+;C 6%%icer La$eron Cra0%ord incident to the @al-.art candy 4ar 5etty larceny ,rial on
<o2e$4er 30thA 2011 (0here Coughlin 0a" denied a continuance e2en 0here D;ll 0a" a55lying an unla0%ul
rent di"traint to eHcu5latory 2ideo" 4elong in to Coughlin re2ealing an eH5re"" retaliatory intent 4y @al-.art
$anager" and 7P 7""ociate" 5rior to the +e5te$4er thA 2011 5etty larceny arre"t o% Coughlin 4y 6%%icer
Cra0%ordA %or conduct allegedly occuring a%ter 75$A out"ide the o%%icerE" 5re"ence* Cra0%ord had to lie at ,rial
in te"ti%ying that Coughlin %ailed to 5roduce hi" dri2erE" licen"eA to get around the "tatutory 5rohi4ition %or
$a3ing "uch a cu"todial arre"t %or a $i"de$eanor (Cra0%ord 0a"nEt a4le to %udge the 2alue o% the ite$ Fuite li3e
old RP: <ichola" :uralde did incident to an arre"t on 7ugu"t 20thA 2011 %or the alleged 5etty larceny o% an
iPhone that Cory =o4le ha" te"ti%ied in RCR20110-063341 0a" o2er three year" old at the ti$e o% the arre"t and
6-1#
5urcha"ed %or M300 ne0 in Cune 200!***RP: :uralde $ade "$ug retaliatory "tate$ent" to Coughlin 0ith re"5ect
to the $i"conduct he 0a" co$$itting (5reteHtual o2ercharging to get around the &ourth 7$end$ent and <R+
dictate" again"t cu"todial arre"t" %or conduct occuring a%ter 7 5$ and not in the o%%icerE" 5re"ence)*
.r* Le"lieA you recently 0rote: G&inallyA at thi" 5ointA a%ter ha2ing again re2ie0ed the docu$ent" and e2idence
in the 5etit larceny ca"e a" 0ell a" ha2ing again re2ie0ed your 2ariou" e$ail" co$$unication"A de$and"A
threat"A and "ugge"tion" (including tho"e 0ith $erit and tho"e lac3ing $erit)A it i" $y intention i% ; continue to
4e your attorney that u5on re"u$5tion o% 5etit larceny trial ; 0ill call u5on you to decide 0hether or not you
0ill te"ti%y (to dateA de"5ite $y re5eated e%%ort"A you ha2e e2aded 5ro2iding a "traight an"0er to that Fue"tion
and ha2e e2en e2aded $y atte$5t" to hel5 5re5are you %or te"ti$ony "hould you decide to te"ti%y)* ;% you do
not clearly "tate your de"ire to te"ti%yA then the 5re"u$5tion 0ill 4e that you 0i"h to rely on your &i%th
7$end$ent right not to 4e co$5elled to te"ti%y and u5on that 5re"u$5tion you 0ill not 4e called a" a 0itne""
%or your de%en"e* 6ther than youA ; antici5ate no de%en"e 0itne""e" at thi" 5oint in ti$eA although ; continued to
gi2e that Fue"tion con"ideration and re-e2aluation on an ongoing 4a"i" along 0ith re2ie0 and re-re2ie0 o% the
%ile and te"ti$ony thu" %ar adduced*

7ny date" 5rior to the 10-22-12 co$5etency hearing in your ca"e 0ith .r* :ogan 0ill al"o need to 4e re"et to a
date on or a%ter 10-22-12A "inceA a" noted a4o2eA no court action can 4e ta3en 5ending the o%%icial court
deter$ination o% co$5etency*G
Ci$A you ha2e 4een 5ro2ided 5lenty o% rea"on" to get tho"e 0itne""e" "er2ed "u45oena" and to (ealou"ly
ad2ocateA 0ith rea"ona4le diligence and co$5etencyA yet you continue to a55ear to 4e doing your G@ee3end at
Cere$yE"G routineA 5lea"e cea"e that a55roach* 7nd your characteri(ation" o% your Gatte$5t" to hel5G $e 5re5are
%or ,rial or to te"ti%y (no real e%%ort" 2i" a 2i" the +u55re""ion DearingA huhI) are laugha4le***i% 4y Ghel5 you
5re5areG you $ean G"tor$ed out o% $eeting" and hung u5 5hone call" li3e a $id-career :iana Ro""-"tyle di2aG
thenA uhA yeahA ; gue"" you could "ay you Ghel5G a "cintilla or t0oA oh and donEt %orget to credit your"el% %or
$anaging not to utili(e incredi4ly "trong eHcul5atory e2idenceA or $aterial 0itne""e"A or the rea$" o% eHcellent
legal analy"i" and re"earch ; ha2e 5ro2ided you****i% you con"ider that Ghel5GA that i"* =et tho"e "u45oena" and
"u45oena duce" tecu$ "er2eA 5lea"eA .r* Le"lie*
,he @CP: ha" a duty to continue re5re"enting $e during thi" ti$eA and that include" all the Rule" o%
Pro%e""ional ConductA you $ay 0ant to go through the$ 0ith a %ine tooth co$4 a" you are $a3ing thi" reallyA
really ea"y %or $e***5ractically li3e ta3ing candy %ro$ a 4a4yA and ; 0ould 5re%er to "ee the @CP: 5ro2ide at
lea"t adeFuate re5re"entation hereA rather "tu44ornly 5er"i"t in it" current cour"e o% conduct*
+incerelyA
'ach Coughlin
P6 96K 361
RenoA <8 !#0#
,el 77# 33! !11!
&aH 4 667 7402
'achCoughlin)hot$ail*co$
&ro$: Cle"lie)0a"hoecounty*u"
,o: (achcoughlin)hot$ail*co$
7-1#
+u4/ect: Coughlin: RCR11-063341 (Petit Larceny) and RCR12-067!0 (Re"i"ting)
:ate: ,huA 11 6ct 2012 17:4#:03 O0000
.r* Coughlin:

Plea"e ta3e note that in your 5etit larceny ca"e the co$5etency hearing ha" 4een $o2ed %ro$ 10-1#-12 to
10-22-12 at 10:00 a*$* and the trial in that 5etit larceny ca"e ha" 4een re"et to 11-1-12 at !:30 a*$*

Plea"e al"o ta3e note that in your re"i"ting ca"eA the $i"de$eanor 5retrial hearing i" re"et %or 10-22-12 at 10 a*$*
@e are re"etting the 5retrial hearing on the 12-067!0 ca"e to coincide 0ith the 10-22-12 10 a*$* co$5etency
hearingA "ince under la0 0e cannot hold an earlier 5retrial in that ca"e until co$5etency in the 5etit larceny ca"e
i" deter$ined 4y the court u5on the La3e" re5ort*

@e are al"o "ending regular $ail noti%ication o% the"e date change" in addition to thi" e$ail noti%ication*
,he rea"on %or the change o% date" i" that ; a$ una2aila4le on 10-1#-12*

7dditionallyA gi2en your re5eated co$5laint" and re5eated eH5re""ion" o% lac3 o% "ati"%action a4out the
5er%or$ance o% any and all attorney" a""igned to youA and gi2en that the %eed4ac3 0e are recei2ing %ro$ La3e"
Cro""ing i" that you are legally co$5etent and are a4le to a""i"t and coo5erate 0ith coun"elA "hould you "o
choo"eA it i" $y intention to a"3 the court on 10-22-12 to relie2e our o%%ice and 5er$it you to "el%-re5re"ent*
Plea"e note that a" a courte"y to you ; had the re"u$5tion o% trial in the 5etit larceny ca"e 5u"hed out 5a"t the
co$5etency hearingA "o that i% you are 5er$itted to "el%-re5re"ent you 0ill ha2e inter2ening ti$e to 5re5are %or
re"u$5tion o% trialA recei2e any $aterial" %ro$ our o%%ice that are a55ro5riate to a "el%-re5re"entation hand-o%%A
and 5ur"ue any $otion" you dee$ a55ro5riate again"t the "tateP" ca"e 5rior to re"u$5tion o% trial*

;%A ho0e2erA you o55o"e "el%-re5re"entationA ; 0ill a"3 the court to cea"e entertaining any and all %urther
co$5laint" 4y you again"t coun"elA "ince 4y o55o"ing "el%-re5re"entation you 0ill ha2e decided to re$ain
re5re"ented 4y your a""igned coun"el* +ince La3e" re5ort" that you are co$5etent and a4le to interact 0ith
coun"el li3e a nor$al 5er"onA a""u$ing you 2oluntarily choo"e to "o conduct your"el%A there are no re$aining
eHcu"e" %or your 4eha2ior and certainly no eHcu"e" 4a"ed on $ental ina4ilityA de%iciencyA or inco$5etency*

&inallyA at thi" 5ointA a%ter ha2ing again re2ie0ed the docu$ent" and e2idence in the 5etit larceny ca"e a" 0ell a"
ha2ing again re2ie0ed your 2ariou" e$ail" co$$unication"A de$and"A threat"A and "ugge"tion" (including tho"e
0ith $erit and tho"e lac3ing $erit)A it i" $y intention i% ; continue to 4e your attorney that u5on re"u$5tion o%
5etit larceny trial ; 0ill call u5on you to decide 0hether or not you 0ill te"ti%y (to dateA de"5ite $y re5eated
e%%ort"A you ha2e e2aded 5ro2iding a "traight an"0er to that Fue"tion and ha2e e2en e2aded $y atte$5t" to hel5
5re5are you %or te"ti$ony "hould you decide to te"ti%y)* ;% you do not clearly "tate your de"ire to te"ti%yA then
the 5re"u$5tion 0ill 4e that you 0i"h to rely on your &i%th 7$end$ent right not to 4e co$5elled to te"ti%y and
u5on that 5re"u$5tion you 0ill not 4e called a" a 0itne"" %or your de%en"e* 6ther than youA ; antici5ate no
de%en"e 0itne""e" at thi" 5oint in ti$eA although ; continued to gi2e that Fue"tion con"ideration and re-
e2aluation on an ongoing 4a"i" along 0ith re2ie0 and re-re2ie0 o% the %ile and te"ti$ony thu" %ar adduced*

7ny date" 5rior to the 10-22-12 co$5etency hearing in your ca"e 0ith .r* :ogan 0ill al"o need to 4e re"et to a
date on or a%ter 10-22-12A "inceA a" noted a4o2eA no court action can 4e ta3en 5ending the o%%icial court
deter$ination o% co$5etency*

,han3 youA

Ca$e" 9* Le"lieA E"F*
!-1#
Chie% :e5uty Pu4lic :e%ender
@a"hoe County Pu4lic :e%enderP" 6%%ice
3#0 +outh Center +treet
&i%th &loor
RenoA <8 !#0
1-!00-762-!031
:irect :ial: 77#-337-4!2!
&aH: 77#-337-4!#6
E$ail: /le"lie)0a"hoecounty*u"

,he content" o% thi" co$$unication and all acco$5anying docu$ent" and attach$ent" contain
C6<&;:E<,;7L ;<&6R.7,;6<A are legally 5ri2ilegedA and are intended %or u"e and re2ie0 only 4y the
5arty "ending "a$e and the intended reci5ient* ;% you are not the intended reci5ientA you are here4y noti%ied that
any di"clo"ureA co5yingA di"tri4utionA u"e or ta3ing any action reliant on "aid content" are C6<&;:E<,;7L and
"trictly 5rohi4ited* ;% you recei2ed thi" co$$unication in errorA 5lea"e i$$ediately noti%y u" at 77#-337-4!00
to arrange return o% the original tran"$ittal* ,han3 you*

ro$: (achcoughlin)hot$ail*co$
,o: 4dogan)0a"hoecounty*u"1 /4o"ler)0a"hoecounty*u"1 /le"lie)0a"hoecounty*u"
+u4/ect: $i"ue o% 11 ca"e
:ate: ,huA 20 +e5 2012 02:20:22 -0700
.r* :oganA

6hA loo3 at thatA there i" the .DC contract 0ith Coughlin that %ail" to eHclude the $edication Coughlin 0a"
ta3ing and 0hich the .DC and 9iondo cited a" their rationale %or eH5elling CoughlinA li4elling hi$A in %act*
<ot that old Cenni%er Rain" 0a" going to ad2ocate anything a4out thatI ; ha2e no idea 0hat the 5ur5o"e o%
e2en ha2ing an attorney there i"I 7nd Cudge Elliot 0a" really thro0n %or a loo5 0hen 9iray $entioned a
G"ocial 0or3erG on "ta%% at the @CP:A in that tran"cri5t o% the 75ril 27thA 2011 Dearing that ; %inally got" $y
hand" on*

; a$ curiou" to hear yoru theory o% the ca"e (0hether the charge 4e re"i"ting or o4"tructing arre"t or 0hate2er it
0a" Boung "ought to a$end the Co$5laint to ("o$ething $ore in line 0ith a EGeriou" cri$eG 2i" a 2i" a +CR
111(6) analy"i"A or i% the charge re$ai"n $i"ue o% e$ergency "er2ice"* Plea"e 5ro2ide $e 0ith any no2el legal
re"earch you culled %or thi" ca"e* 7dditionallyA yoru 0ere already 5ro2ided the"e 2ideo"A 4ut here they are
againA 2ideo" o% 4oth arre"t" $ade or ordered 4y +argent +i%re (0ho get" M1!#L a year and a4out our ageA
9iray) 0ithin a 36 hour 5eriod o% each otherA 0ith an inter2ening 5ullo2er 4y 6%%icer :uralde and # other RP:
5er"onnel late at night a%ter Coughlin 4onded out on the cu"todial arre"t %or /ay0al3ing on Canuary 12thA 2012*
9irayA "o$e 5eo5le $ight "ay that ::7 Boung ha" u"ed youA the @C:7 6%%ice ha" u"ed youA the R.C and
-1#
Cudge <a"h Dol$e" ha2e u"ed youA and 5erh5a" e2en that .r* 9o"ler and .r* Le"lie are u"ing you* .ay4e you
li3e it* .ay4e you li3e 4eing u"ed* .ay4e you li3e 4eing 5u"hed around* .ay4e you lo2e it* .ay4e that i"
0hat you are good at*

9irayA 5lea"e tell $e ho0 true any o% the %ollo0ing "tri3e" you a" 4eing:

+CR 111(6): G:e%inition o% Q"eriou" cri$e*R ,he ter$ Q"eriou" cri$eR $ean" (1) a %elony and (2) any cri$e le""
than a %elony a nece""ary ele$ent o% 0hich i"A a" deter$ined 4y the "tatutory or co$$on-la0 de%inition o% the
cri$eA i$5ro5er conduct a" an attorneyA inter%erence 0ith the ad$ini"tration o% /u"ticeA %al"e "0earingA
$i"re5re"entationA %raudA 0ill%ul %ailure to %ile an inco$e taH returnA deceitA 4ri4eryA eHtortionA $i"a55ro5riationA
the%tA or an atte$5t or a con"5iracy or "olicitation o% another to co$$it a Q"eriou" cri$e*R

CoughlinE" @CP:A 9iray :oganA E"F* and ::7 BoungA in the RCC 5ro"ecution %or G$i"u"e o% e$ergency
"er2ice"G (11 call")A 0hen con"idering their lac3 o% candor to the tri4unalA %airne"" to o55o"ing coun"el (gi2en
Coughlin %iled a <otice o% 755earance and ha" the right to re5re"ent hi$"el%A and i" an attorney)A ::7BoungE"
re5eated in"tance" o% 2iolating <R+ 0ith re"5ect to all $atter" 4eing "tayed u5on an 6rder %or Co$5etency
E2aluation 4eing entered again"t a 5artyA "uch a CoughlinA and the %ailure o% :ogan to alert Coughlin toA or
5ro2ide any co5y o% (de5"ite CoughlinE" re5eated 0ritten de$and") the Culy 31"tA 2012 .otion to 7$end
Co$5laint (thatA u5on Cudge +%erra((a Fuerrying ::7 Boung a" to 0hether the :7 e2en needed "ee3 an 6rder
allo0ing it to "o a$end "uch a Co$5laintA re"5onded that the :7 did notA 4ut that he 0a" /u"t "ee3ing one G%or
5ur5o"e" o% 3ee5ing the record EcleanEGA 0hate2er in the 0orld that $ean"* @hen 2ie0ed 0ith :oganA Boung and
Le"lieE" atte$5t" to "hu%%le Coughlin on through the .+C 5roce"" (::7 Boung indicatedA to Cudge +%erra((aA
on the recordA 0hile atte$5ting to chec3 o% the .+C 4oH $inute" 4e%ore the +tart o% the 7ugu"t 2thA 2012
iPhone 5etty larceny ,rialA that he antici5ated the .+C Gonly ta3ing a cou5le $inute"A at $o"tG and %elt it 0a"
CoughlinE" Go4"tructioni"tG and Gdi%%icultG attitude o% Gnon-co$5lianceG that 0a" 5re2enting hi$ %ro$ e%%ecting
hi" "tated goal* ::7 Boung clearly "u4"cri4e" to the RP: Ron Ro"a-<ic3 :uralde "chool o% GDo0E" that
runninE %or yaG "tyle retaliationA inti$idationA and $i"conduct*
.o"t trou4ling a4out :ogan and ::7 BoungE" a55arent con"5iracy to get an 6rder %or Co$5etency E2aluation
again"t Coughlin during their clande"tine .+C o% 2-27-12 (0hichA againA Coughlin 0a" noticedA in 0ritingA had
4een continued out to .arch 2thA 2012)A including i$5er$i""i4le co$$unication" to the R.C and Cudge <a"h
Dol$e" (0ho argua4ly 2iolated <R+ 4y continuing on 0ith the tra%%ic ,rial /u"t $inute" a%ter 4eing $ade a0are
o% the 2-27-12 6rder %or Co$5etency E2aluation in the RCC 4y :ogan andA 5erha5"A 4y ::7 Boung a" 0ellA i"
:oganE" %ailure to in%or$ Coughlin o% ::7 BoungE" RPC 3*! 2iolating .otion to 7$end Cri$inal Co$5laintA
0herein ::7 Boung "ee3" to alter the charge to one that 0ould in2o3e a $andatory +CR 111 Petition in light
o% +CR 111(6)E" de%inition o% a G"eriou" cri$eG and the G"tatutory or co$$on la0 de%initionG o% the cri$e %or
0hich ::7 BoungA though lac3ing G5ro4a4le cau"eG "u%%icient to "ati"%y hi" RPC 3*! dutyA "ought to ha2e "o
a$ended to an Go4"tructing or re"i"ting a 5u4lic o%%icerG chargeA 0hich o% cour"e %it" "Fuarely in the G"eriou"
cri$eG de%inition "et %orth in +CR 111(6)* +oA noA Cudge +%erra((aA Coughlin 0a" not Go2er-la0yering itG on
7ugu"t 2thA 2012 during the Gonly ta3e a $inute at $o"tG .+C :ogan and ::7 Boung (and Le"lie) "ought to
10-1#
"li5 5a"t Cudge +%erra((a right 4e%ore the 4ig iPhone 5etty larceny trial that $ay 0ell decide 0hether Coughlin
can e2er 5ractice la0 again (including a" a 5atent attorney 4e%ore the >+P,6)* CoughlinA on the recordA ri"3ed
going to /ail 0hen he indicated that 0hat :ogan ha" /u"t "aid 0ith re"5ect to 0hether Coughlin o4/ected to the
+tateE" "o a$ending the Co$5laint 0a" not 0hat Coughlin had indicated to hi" coun"elA in RCR2012-06#630
%ro$ a gro"" $i"de$eanor G$i"u"e o% 11G charge to a $i"de$eanor Go4"tructing and re"i"ting a 5u4lic o%%icer
chargeG* Coughlin re"5onded to Cudge +%erra((aE" incredulity at hi" o4/ecting to a$ending to a le""er charge
(Coughlin indicated doing "oA ho0e2er counter-intuiti2eA G$ay "o$eho0 inureG to hi" 4ene%it)A then Cudge
+%erra((a indicated Coughlin Gde%initelyG 0a" Go2er-la0yering itG***4ut then Peter C* 0ent Peter C*A li3ely "en"ing
an atte$5t to 5ull the 0ool o2er oneE" eye"A and 4ecau"e Gga$e recogni(e ga$eA real recogni(e realG***Cudge
+%erra((a decided to not countenance :ogan and Boung atte$5t" to lead the RCC and Coughlin 4lindly (and in a
.+C that G"hould only la"t a $inute or t0o at $o"tG 5er ::7 Boung) through their tiredA tac3yA hac3neyedA
"ordid little 5lan* ,here i" a rea"on Cudge +%erra((a i" o%ten $entioned a" the 4e"t o% all the %ine RCC Cudge" 4y
long ti$e local attorney"* :ogan and BoungA de"5ite 4eing 0ell a0are o% the +e5te$4er #thA 2012 6rder %or
Co$5etency E2aluation "till ha2e %ailed to 2acate the .otion Dearing "et %or 6cto4er 2ndA 2012 in that regard*

.ay4e old 'ach Boung gonna gi2e hi" 4uddy 9iray :ogan a /o4 5ic3ing u5 hi" dry cleaning or "o$ethinE 0hen
:oganE" get di"4arred on account o% the 5ri$ro"e 5ath he got led on do0n 4y olE nice olE 'ach BoungA 0ho$ i"
the GniceG and G%airG one co$5ared to Dal"tead and***re$e$4er "aying that 9-,o0nI De nicinE you into 4ar
grie2ance" and "tic3y 0ic3et" a 5lenty*
'ach Coughlin
P6 96K 361
RenoA <8 !#0#
,el 77# 33! !11!
&aH 4 667 7402
'achCoughlin)hot$ail*co$
re"5ect%ully "u4$itted
+ent: &ri 6-0!-12 4:41 P.
,o: 0ea2era)reno*go21 4arne"$)reno*go2
6 attach$ent"
2012060#?101#13 <orth0ind $anager handy $an attac3" %ro$ gol% cart 6 # 12*$54 (3*1 .9) A landlord tenant
la0 $anual %or 5olice in $inne"ota*5d% (73#*1 L9) A Police?$anual?-
?%inal?a"?ado5ted?4y?+tateE"?7ttorney*5d% (263*7 L9) Atre"5a"" cri$inal ci2il e2ictdion*5d% (6*! L9) A 6 ! 12
%aH to north0ind 0ith 5age nu$4er"*5d% (#0*7 L9) A north0ind %aH 6 4 12 ha4ita4ility retaliation etc*5d% (4#*!
L9)
:ear 6%%icer @ea2er and 6%%icer 9arne"A
; a$ re"5ect%ully "u4$itting thi" "u55le$entary $aterial to the 5olice re5ort ; "u4$itted to you in 5er"on on
Cune 6A 2012 regarding the a""ault ; 0a" the 2icti$ o% at the hand" o% $aintenance "ta%% $e$4er Lu3e o%
<orth0ind 75art$ent" on Cune #thA 2012A and the atte$5t" at unla0%ul entry co$$itted 4y <orth0ind .anager
:0ayne Ca3o4 on or a4out Cune 4A 2012*
; a$ attaching an article you $ay %ind o% intere"t regarding the inter"ection o% landlord tenant la0 and 5olice
0or3A 2i" a 2i" cri$inal-ci2il $atter" and the %ine di"tinction" that "o$eti$e" ari"e* ; didnEt "ee anything in
there on 6%%icer @ea2er" %ine hy5othetical regarding entry 0ithout 5er$i""ion 0hen a 4urglary $ay 4e
11-1#
occurring* ,hat "ituation 5ro4a4ly doe" not co$e u5 that o%ten 4ecau"e hardly any4ody 4ut the 5olice 0ould 4e
4ra2e enough to enter "uch a dangerou" "ituation*
; a55reciate the 4ra2e "er2ice 4oth o% you 5ro2ide* ; a$ attaching thi" $aterial" /u"t 4ecau"e they are intere"ting
to $e and $ay 4e to you and in no 0ay 0i"h %or "o attaching the"e to 4e inter5reted a" a critici"$ o% either o%
your 5olice 0or3*
+incerelyA
'ach Coughlin
<e2ada court "er2ice" attac3 and atte$5ted 4rea3 in
+ent: &ri 6-22-12 :34 7.
,o: 0ea2era)reno*go2
<C7 and northern" $g$t tried to 4rea3 again on Cune 14th*
&ro$ $y 7ndroid 5hone on ,-.o4ile* ,he %ir"t nation0ide 4= net0or3*
<C77 and :0ayne /a3o4
+ent: &ri 6-22-12 :36 7.
,o: 0ea2era)reno*go2
Lee5 turning light o%% atte$5ting 4rea3 in $aliciou" a4u"e o% 5roce"" clai$ing color o% la0
&ro$ $y 7ndroid 5hone on ,-.o4ile* ,he %ir"t nation0ide 4= net0or3*

--&or0arded .e""age 7ttach$ent--
,hi" incident ha" 4een re5orted to the
Reno Police :e5art$ent
and i" 5ending a55ro2al Reno Police :e5art$ent
4## E* 2nd +treet
RenoA <8 !#02
77#-334-217#
=eneral ;n%or$ation
;ncident ,y5e Dara""$ent
,e$5orary Re5ort <u$4er ,1100##6
Re5ort :ate 0-07-2011 0:36 P.
Re5orting Per"on ;n%or$ation
<a$e cuoghlinA (ach
Do$e 7ddre"" 121 ri2er roc3 +treetA RenoA <8 !#01A >+
Do$e Phone 77#-33!-!11!
12-1#
E$ail (achcoughlin)hot$ail*co$
Race >n3no0n
+eH .ale
:69 0-01-177
;ncident ;n%or$ation
;ncident Location 1 <orth center +treetA RenoA <8 !#01
;ncident ,i$e ("tart) 0-02-2011 0:1# P.
;ncident ,i$e (end) 0-02-2011 0:## P.
Location ,y5e 8acantA E$5ty Lot
;ncident :e"cri5tion ; 0a" 4attered 4y 6%%icer <ic3 :uralde on !-20-11 at a55roH 11:305$* De touched $y
5eni"A 4are "3in" on hi" hand" "e2eral %inger" touched $y 5eni" during hi" +;,7* :uralde al"o "la$$ed $y
head do0n into the to5 o% the trun3 o% hi" 5olice car*
; 0a" arre"ted that nightA ho0e2erA 6%%icer :uralde re%u"ed to arre"t any o% the 3 indi2idual" 0ho a""aulted and
4attered $e on the 4ridge leading to the +ienaA %urther he re%u"ed to collect identitie" o% the other 2 $ain
a""ailant" in addition to oneA Cory =o4le* ,he"e young $en tried to "teal $y 4i3e and $y dog and one
atte$5ted to reach into $y "hortE" 5oc3et and ta3e "o$ething* ,he acted in the conteHt o% a $o4 o% young "3ater
youth "urrounding $e on the 4ridge and 4ac3ing $e u5 2ery near the onco$ing one 0ay tra%%ic and re%u"ed $y
5lea"e to let $e $o2e 0ith the$ 4ac3 to the "a%er "3ate 5la(eA con"idering $y dogA 4i3eA and the onco$ign
tra%%icA and their $o4 li3e 4eha2iour* ,here 0ere a55roHi$ately 20 "3ater youth" "urrounding $e until 6%%icer
:uralde "ho0ed u5 and "tarted u5 0ith hi" 5eni" touching and right" tra$5ling act* Ro4 :a0"on 0a" 0ith one
o% the"e $ain a""ailant" on -2-11 %or 0hich :urio and 9arne" cite R112471302
on -2-11 ; 0a" a""aulted and 4attered 4y a hi"5anic 0o$anA a55roH* 20 yoA 0ho$ 6%%icer 9arne" inter2ie0edA
a%ter ; called 11 0hen ; again ca$e acro"" her on the "treet at 1 <* Center +t* "3ate 5la(e* 9arne" ad$itted to
$e that the a""ailant ad$itted %lic3ing $y 4a"e4all ca5 o%% $y head* 9arne" ad$itted that he %ailed to a"3 the
a""ailant i% "he hit $e in the 4ac3 o% $y head a" ; 0a" retreating %ro$ her on"laught o% 2er4al threat" and
aggre"i2e ge"ticulation"* 9arne" "aid GnoA ; didnEt a"3 herA it doe"nEt $atter any0ay"G* &urtherA al"o in the "a$e
"3ate 5la(e on -2-11 Ro4 :a0"onA 20 o% Reno $ade 2er4al threat" to $e and a""aulted $e 0ith a deadly
0ea5onA a "3ate 4oard coc3ed 4ac3 and chec3 "0ung 2ery hard 2 %eet %ro$ $e re5eatedly* ; /u$5ed 4ac3
"e2eral %eet re5eatedly*
Per"on ;n%or$ation
<o 1
<a$e CuoghlinA 'ach
E$5loyer <a$e (achcoughlin)hot$ail*co$
Do$e 7ddre"" 121 ri2er roc3 +treetA renoA <8 !#01A >+
Do$e Phone 77#-33!-!11!
Print ,hi" Re5ort
Clo"e @indo0
--&or0arded .e""age 7ttach$ent--
13-1#
,hi" incident ha" 4een re5orted to the
Reno Police :e5art$ent
and i" 5ending a55ro2al Reno Police :e5art$ent
4## E* 2nd +treet
RenoA <8 !#02
77#-334-217#
=eneral ;n%or$ation
;ncident ,y5e Re"idential 9urglary
,rac3ing <u$4er ,1200021
Re5ort :ate 01-0!-2012 01:3# 7.
Re5orting Per"on ;n%or$ation
<a$e CoughlinA 'ach
Do$e 7ddre"" 1422 Ea"t th +treetA 2A RenoA <8 !#12A >+
Do$e Phone 77#-22-6737
E$5loyer <a$e 'ach CoughlinA E"F*
@or3 7ddre"" 121 Ri2er Roc3 +treetA renoA <8 !#01A >+
@or3 Phone 77#-33!-!11!
Race >n3no0n
+eH .ale
:69 0-01-176
;ncident ;n%or$ation
;ncident Location 121 ri2er roc3 +treetA RenoA <8 !#01
;ncident ,i$e ("tart) 12-12-2011 01:2# 7.
;ncident ,i$e (end) 01-0!-2012 01:2# 7.
Location ,y5e Retail +tore
.ethod o% Entry >n3no0n
;ncident :e"cri5tion i al"o 0ant to re5ort a ,re"5a"" 4y Coel :urdenA 5roce"" "er2er %or <e2ada Court +er2ice"
on or a4out 6cto4er 20thA 2011* .r* :urden and an a""ociate %ro$ <e2ada Court +er2ice" a""aulted $y la0
5ractice and tre"5a""ed 4ehind the 4ac3 gate into the 4ac3 yard to 4ang on 4ac3 roo$ 0indo0"* Bou guy" %elt it
nece""ary to do a cu"todial arre"t on $e %or tre"5a""A 0ellA ho0 a4out %or the$I +ee attached 5leading* Ca"ey
9a3erA E"F* re5orted the 4urglary o% a55roH 12 12 11 to $e in an e$ail on 12 14 11A "ee attached 5leading*
7l"oA richard hillA e"F* 0ithheld $y +tate o% <e2ada dri2erE" licen"e %ro$ <o2e$4er 1#thA 2011 to <o2e$4er
22nd 2011 and contri4uted to the %al"e arre"t again"t $e %or tre"5a"" %ro$ <o2e$4er 12A 2011A lying to 6%%icer
Carter and Lo5e( a4out 0hether hi" o%%ice had "ent $e a 4ill %or the %ull rental 2alue o% the 5ro5erty %or
<o2e$4er 2011* 6%%icer Carter indicated that Richard DillA E"F* 5ay" hi$ a lot o% $oney and there%oreA 6%%icer
Carter arre"t" 0ho Richard D;ll "ay" to and doe" 0hat Richard Dill tell" hi$ to do*
7l"oA ; 0a" arre"ted on 7ugu"t 20thA 2011A 0rong%ully and a$ here4y co$5laining o% the lie" <ate 'arate toldA
6%%icer :uralde touching $y 5eni" and conducting an i$5er$i""i4le "earch 5rior to a "earch incident to arre"tA
6%%icer Ro"a atte$5ting to eHtort a con"ent to an i$5er$i""i4le "earch 4y threatening to de%a$e $e to the +tate
9ar o% <e2adaA etc* etc*
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1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the practice and proceedings of justice courts in similar cases. An
appeal perfected transfers the action to the district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS 5.010. The municipal court
must be treated and considered as a justice court whenever the proceedings thereof are called into question.
178.405 - Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant;
notice of suspension to be provided to other departments.
178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial, when upon conviction the defendant is brought up for
judgment or when a defendant who has been placed on probation or whose sentence has been suspended is brought before the court, if doubt arises as to the competence of the
defendant, the court shall suspend the proceedings, the trial or the pronouncing of the judgment, as the case may be, until the question of competence is determined.
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any other departments of the court of the suspension in writing.
Upon receiving such notice, the other departments of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to be competent.
[1911 Cr. Prac. 536; A 1919, 416; 1919 RL 7386; NCL 11184](NRS A 1967, 1449; 1981, 1656; 1991, 1003; 2003, 1018; 2007, 186)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 10/11/12 3:54 PM
To: renodirect@reno.gov; kadlicj@reno.gov; rjcweb@washoecounty.us; zyoung@da.washoecounty.us; bdogan@washoecounty.us; jleslie@washoecounty.us;
jbosler@washoecounty.us
6 attachments
Zach Coughlin
Order dissolving protection order Krebs v. Coughlin re Northwind Apartments
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
Sent: Wed 10/10/12 11:53 AM
To: coplogicrpd@reno.gov; dispatch@reno.gov; 037nor2@acg.com; 037nor4@acg.com
1 attachment
I demand my summary eviction hearing, before a jury based upon 6 28 12 notice and my faxed Tenants Answer of
6 30 12 i
rjc rcp2012-000287 Order for Coughlin to get property with civil standby rpd krebs northwind.pdf (176.5 KB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Wed 10/10/12 5:38 AM
To: stuttle@washoecounty.us; kstancil@washoecounty.us; rjcweb@wasoecounty.us; 037nor2@acg.com; 037nor4@acg.com; nevcs@nevcs.com; chansen@washoecounty.us;
renodirect@reno.gov; rjcweb@washoecounty.us; cwood@washoecounty.us; william@hornelawfirm.com; pilbinfo@ag.nv.gov; tsegerblom@asm.state.nv.us
Dear Mr. Tuttle and Supervisor, Civil Division Stancil and Supervisor of the Civil Division at Sparks Justice Court Hansen,
Mr. Hansen, I believe I am entitled to a hearing in your court. I would like one. May I have a date. Mr. Tuttle and Ms. Stancil, I
believe I am entitled to several hearings in your court, may I have such and a date and time for them?
I am writing to demand respectfully my hearing incident to the NOtice served on my rental at Northwind Apartments 1680 Sky Mountin
Drive unit 29 on June 28th, 2012. I believe the tenant's affidavit I filed in response to that 5 day notice should be given a brand new case
number, though the designation by ncs that it was an "Amended NOtice" pursuant to is is is is is is is isis it is as if the isthe 6/14/12 one (the
one R. Wray lied about effecting "personal service" on me of, which got me arrested just before I was to fax to the RJC, by noon, a Tenant's
Answer or MOtion to Dismiss for failure to state a cause of action or deficieny of service of process or something (I arguably needn't have
even filed anything in the RJC where the 6/14/12 notice listed Sparks Justice Court.
Oh, it gets better...Nevada Courts services filed a Landlord's Affidavit attesting to have rented Coughlin a "dwelling" which is defined as a
"sleeping place or residence" in NRS 118A...and pursued an eviction under NRS 118A...citing a breach by Coughlin for allegedly using the
unit 29 for a residence or sleeping place, instead of pursuing NRS 40.760 or NRS 118.475 eviction remedies (which, by the way, may result
in the Sheriff evicting Coughlin or forcing him to quit any alleged use of Unit 29 as a "dwelling place or residence", but YOU WILL NOT
THAT UNDER THOSE STATUTES COUGHLIN WOULD BE ALLOWED, UNDER THE LAW TO CONINUTE STORING AND
ACCESSING HIS PROPERTY THERE!!!!CAN'T HAVE IT BOTH WAYS ALL THE TIME, GUYS. Oh, also, who in the hell signed
the Landlord's affidavit? There is no textual indication of whom the solitary letter of a "signature" belongs to....maybe because it would
be a NRCP 11 violation for a corporation to appear "pro se", especially where represented by someone committing the unauthoried practice
of law?
R. Wray made some interesting statements on the video of the 6/28/12 arrest filmed by Coughlin, especially concerning Coughlin's
contention that Wray and NOrthwind's Dwane Jakob's attempts to break and enter and trespass into Unit 29 constituted "personally serving"
Coughlin a 5 day Unlawful Detainer Notice on 6/14/12. If NCS did not "personally serve" Coughlin, then Coughlin would have had until
June 28th, 2012 at noon at the earliest (and arguably until the close of business at 5pm on 6/28/12 to file a response (ie Tenant's Answer or
MOtion to Dismiss, etc), in Sparks Justice Court OR EVEN in REno Justice Court. Coughlin was arrested at 10:30 am on 6/28/12,
thereby, under color of law, the WCSO, NCS and NOrthwind and Jakob fraudulently prevented Coughlin from filing (if he did not already
previously, espeically in the 6/13/12 faxes that are mysteriously unaccounted for in rJC files) a Tenan'ts Response (tEnan'ts answer, or
Tenant's AFfidavit or Motion to Dismiss, etc.).
So, R. Wray and NCS, its kind of a big deal that you lied about effecting personal service on 6/14/12 of the 5 day notice.
Coughlin has three different version of that notice or "Declaration of Srevice by License PRocess SErver" R. Wray. in one, a time of 9:23
(presumably am, but that is not circled, nor is pm) on 6/14/12 is listed, and a rubber stamp indicating "r. wray", is there, along with a
hadnwritten "reg #r-043948" is there. that Declaration indicates that R. WRay "personally served" the partey named, Coughlin. Oddly,
this first version (and all three of these are in the RJC file in rev2012-001048) instead of "jennifer Chandler" being in , I guess, the signature
line for the "agent" of the landlrod (and she always just places a "rubber stamp" of her name anyways..", instead of Jennifer Chandler, on the
one 6/14/12 5 day NOtice (and all version sof this notice have checks on box 3 and 6, which read "3. Recieved a 5 day notice of possible
unlawful detiner for failure to comply with the rental agreement....6. Remained in possesion of the premises subject to the provision of
Chpater 118A of the NRS after having failed to perform the basic or contractual obligations imposed upon you by that Chapter, namey
(SEE ATTAChed)" though the "attached just seems to include a copy of the "Rental Agreement" with no real indication of how
Coughlin was in violation of it, and no indication of why NOrthwinds feels Coughlin remained in violation thereof despite Coughlin's
written communications indicating that he was not in breach. Anyways, rather tha a rubber stamp indicating "jennifer Chandler" on that
one 5 day notice, the one where WRay actually affixes his actual signature, follow by a handwritt r-043948 (his licensed process sever
number), the spot usually baring the "Jennifer Chandler" rubber stamp is instead taken up by a signature by Nevada Court Services resient
notary public HB Cedomio....AGain, there is no time listed on that first version of the NOtice or which includeds at the bottom the
"Declaration of Service...."
In the second version of the "notice of Unlawful detainer..." served on June 14th, 2012, in his "Declaration of Service by Licnese process
Server" (which, arguably inovkes the "penalty of perjury dicate of NRS 53.045...) Wray against declares he personally served Coughlin,
with a time of 9:23 indicated, and a rubber stamp of "R. Wray" on the signature line, with a handwritten "REg #R-043948" (and that
version was faxed by the Sparks Justice Court to the Reno Justice Court on June 28th, 2012 at 11:05 am, (in a 13 page fax, many pages of
which are not in the RJC file, though that fax does included the header from the fax from Coughlin to the "Sparks Justice Court on 6 26 12
at 12:00pm, which was a 10 page fax, and the versio of the 6/14/12 5 day notice with Declartion of Service by r. Wray indicating a time of
9:23 is page 6 of 10 of Coguhlin's fax to the Sparks Justice Couer (according to the fax hearders) while also being page 12 of teh June 28th,
2012 fax from the Sparks Justice court to the Reno Justice Court. right about the moment Coughlin was being placed in WCSO Deputy
Machen squad or patrol vehicle for transprot to the jail, where Coughlin would be forced to fork over some more bail, etc., etc.
IN the Third version of the "Declaration of Service" on the same June 14th, 2012 "NOTICE OF UNLAWFUL DETAINER FOR FAILURE
TO VACATE PREMISES ..This third version of his 6/14/12 Declaration of Service by Licensed PRocess Serve R. Wray has the typical
"jennifer chandler" rubber stamp for the NOtice half of the page, and has a rubber stamp for "?R.wray", along with a clearly differt
handwrirtn note of "reg# r043" (obviously, aside from the handwriting "analysis" the handwrittn numberical indication of the process
servicer number is truncated on this third version by 3 numbers). Additionaly this third version indicates it was "personally served" at
12:54 pm.
Why all the different versions? why, if personally service was effect at 9:23 am, woud R. Wray need to return and do it again, all for Unit
29, nmin you only (all the other Declartions of Service from that date of 6/14/12 , ie for units 45 and 71, indicate that Wray merely posted
teh notice to the rented property (and therefore would entail 3 more days fro mailing to get "construtive notice" under NRCP 6(e) and NRCP
5(b)(2), which landlord's like Northwinds just hate.
Then there is the fact that NCS snuck into the file later a whole nother type of notice, one under NRS 40.760...which, of course, changes
everything..
OF course, Wray did not "personally serve" Coughlin. Wray attempts to make some half-baked argument about how he slid (after failing
in his attempts to break and enter and trespass in to Unit 29 on 6/14/29) the 5 day UD Notice into a crack in the door of the rental, and
perceived it to "move" after he let go of it, thereby, apparently, entitling him to assert that he effected "personal service" upon tenant Zach
Coughlin, or, apparently, otherwise complied with NRCP 5, and therefore cut short the time for Coughlin to respond as a tenant and secure a
hearing (rather than be incarcerated after having unknown violent sounding figures (flashbacks to other interactions with Nevada Court
Services) banging on his doors, refusing to indentify themselves, then ultimately taking a chainsaw (or sawz-all) to a metal door to a
confined windowless rental.
NRS 40.400 makes NRCP the applicable rules here, not JCRCP, nor JCRRT:
RULE 5. SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS
Rule
Drafters Note
Commentary
(a) Service: When Required. Except as otherwise provided in these rules, every order required by its terms to be served, every pleading
subsequent to the original complaint unless the court otherwise orders because of numerous defendants, every paper relating to discovery
required to be served upon a party unless the court otherwise orders, every written motion other than one which may be heard ex parte, and
every written notice, appearance, demand, offer of judgment, designation of record on appeal, and similar paper shall be served upon each of
the parties. No service need be made on parties in default for failure to appear except that pleadings asserting new or additional claims for
relief against them shall be served upon them in the manner provided for service of summons in Rule 4.
[As amended; effective September 27, 1971.]
(b) Same: How Made.
(1) Whenever under these rules service is required or permitted to be made upon a party represented by an attorney, the service shall be
made upon the attorney unless the court orders that service be made upon the party.
(2) Service under this rule is made by:
(A) Delivering a copy to the attorney or the party by:
(i) handing it to the attorney or to the party;
(ii) leaving it at the attorneys or partys office with a clerk or other person in charge, or if there is no one in charge, leaving it in a
conspicuous place in the office; or
(iii) if the office is closed or the person to be served has no office, leaving it at the persons dwelling house or usual place of abode with
some person of suitable age and discretion residing there.
(B) Mailing a copy to the attorney or the party at his or her last known address. Service by mail is complete on mailing; provided, however,
a motion, answer or other document constituting the initial appearance of a party must also, if served by mail, be filed within the time
allowed for service; and provided further, that after such initial appearance, service by mail be made only by mailing from a point within the
State of Nevada.
(C) If the attorney or the party has no known address, leaving a copy with the clerk of the court.
(D) Delivering a copy by electronic means if the attorney or the party served has consented to service by electronic means. Service by
electronic means is complete on transmission provided, however, a motion, answer or other document constituting the initial appearance of a
party must also, if served by electronic means, be filed within the time allowed for service. The served attorneys or partys consent
to service by electronic means shall be expressly stated and filed in writing with the clerk of the court and served on the other parties to the
action. The written consent shall identify:
(i) the persons upon whom service must be made;
(ii) the appropriate address or location for such service, such as the electronic-mail address or facsimile number;
(iii) the format to be used for attachments; and
(iv) any other limits on the scope or duration of the consent.
An attorneys or partys consent shall remain effective until expressly revoked or until the representation of a party changes through
entry, withdrawal, or substitution of counsel. An attorney or party who has consented to service by electronic means shall, within 10 days
after any change of electronic-mail address or facsimile number, serve and file notice of the new electronic-mail address or facsimile
number.
(3) Service by electronic means under Rule 5(b)(2)(D) is not effective if the party making service learns that the attempted service did not
reach the person to be served.
(4) Proof of service may be made by certificate of an attorney or of the attorneys employee, or by written admission, or by affidavit, or
other proof satisfactory to the court. Failure to make proof of service shall not affect the validity of service"
In the legal work drafted and filed by a non-attorney, a criminal violation in NCS's and Jeff Chandler's committing the authorized practice of
law (what happens to people doing plastic surgery without a license? jail time, lots of it...because something could go badly, badly wrong
and people could get hurt...like Coughlin got hurt, damaged, arrested, financially destroyed, etc., etc. here. thin skull plaintiff,
consequential damages Winchell v Schiff 2008 case seafood, storage place lost business and lost profits $300K damages, etc.. while in
jail Coughlin was prevented from filing in matters that ultimately wound up with a $40,050 judgment against Coughlin, and there's more,
for which NOrthwind, and NCS, Chandler and WRay, and perhaps, some others, will be liable.). In the "Affidavit of Landlord for
Breach" filed on June 27th, 2012 by ,well, who knows, given it just says "Lanldord" and has what appear s to be a handwritten "S" in the
signature line...but, lets say it was filed by Jeff Chandler, whom crossed the bar and argued before Judge Pearson on July 31st, 2011 in
REv2012-001048 on behalf of his "client' Northwind Apartments, Associates LLC (see acg-ampi.com, doing business in 10 states, kinda
seems like they could afford and attorney rather than destroy our community with hack pretend lawyers who play dress as a Sheriff and
bully peopel while attempting to break and enter and trespass...and then RPD Alan Weaver and SArgent Oliver Miller, and WCSO Deputy
John Machen and Deputy Gomez chip in some Soldal v. Cook County violating 1983 violations as well....puke, puke. puke... IN the
"Affidavit of Landlord for Breach" that Chandler drafted and filed, he wrote, at paragraph 4. "him and nation surrender of the premises was
to have taken place on or before June 13, 2012. That legal notice has been served on the tenant's in accordance with the provisions of NRS
chapter 40.280 as amended on 6/14/12."
Chandler's Affidavit of Landlord for Breach demonstrates a lack of candor to the tribunal, which would be professional misconduct to report
to the SBN, but, Chadler aint a lawyer, so,and what are ya goin' ta do? DDA Yound? DDA Kandaras, isn't that your jurisdiction?
That is a criminal law violation, right, unauthorized practice of law...and in that June 27th, 2012 Affidavit of Landlord Chandler sneakily
lists "N/a" in the blank for the "original period of is (blank) terminating on o forr transferring to a periodic tenancy on that date. A
copy of the written rental agreement, if any , is attached hereto."....Upon information and belief, chandler failed to inlcude a copy of the
Rental Agreement in at least one of these NOrthwind files (not sure if it was in the one for unit 29, rev2012-001048, but it woudl make
sense, as Northwind's eggs were all in that basket in a sense.) Anyways, the Rental AGreement makes clear the period is not "n/a"...why
would Chandler do that? Coudl it be that NRS 40.253 has differ atent laws for tenancies where the rent is reserved by a period of 1 week
or less? Coughlin paid for one month's rent up front at the time the Renal Agreement was signed. Also, see isthe craigslist ad Coughlin
responded to placed by Northwind, and incorporated into an "Rental Agreement", along with verbal indications, arguably, under NRS
118A.160 (which only applies to "dwelling places", but the Landlord's Affidavit inidcates this rental was, in paragraph 2 such, as it states
"2. That yor affiant isrented a certain dwelling or apartment to Zach Coughlin, located at 1680 sky mountain dr...#29, Reno, NV
on 5/4/12 for an original period of N/a terminating on or transferrinto a periodic tenancy on that date. a copy of the written rental
agreemet if any, is attached hereto.".. Chandler seems to want to take advanteg of NRS 40.253(2)'s quickie service approach for week to
week rentals, which unit 29, by virtue of the terms of the Rental Agreement, clearly was not. as him and him and him this but the new the
signatures is written in the amount of $75 is due no later than the first of late after the for every month late is asked Bob Loblaw clearly this
was a periodic tenancy of month to month for variety further one provision and this one is rental agreements has written 30 days notice to
vacate is required or rental will be responsible the next months rent covered Chandler tends to one characterize this as a week to week or
less type tenancy to take advantage of the lessons service requirements there and found in NRS 40.253(1)-(2):
Further, the Rental Agreement is not necessarily limited to the document that NOrthwind Apartments purports to be the "GARAGE /
CARPORT RENTAL AGREEMENT" as their exists no limitation in that document that affirmatively disclaims any incorporation of
statements by then Manage Deede Call (whom mysteriously disappeared upon current Manager Dwayne Jakob showing up) or incorporated
into the Rental Agreement or Lease by virtue of the advertisements that Northwinds held out to the public on Craigslist, which is how
Coughlin learned of their offer, upon which Coughlin called then Manager Deede Call and met with her in person. Attached in Exhibit 1
is the Craigslist ad that Northwinds was running at the time, and it read:
"$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below
Welcome to Northwind Apartments. We offer storage units to non-Northwind Residents! If you need more storage, we offer garages to
rent for $75 per month. They are a full size single car garage. Most public storages would charge over $150 dollars for the same size! Our
community is located in northwest Reno, right
off of McCarran. Please call us at (775) 747-9200 or come by. We are located at 1680 Sky Mountain Drive in Northwest Reno."
AND IT GETS BETTER: The thing about NRS 40.760 is that it specifically indicates that it does not apply to "garages". And
Judges don't legislate from the bench, they just apply the law as written, so people can depend on notice provided by precedent and
published laws. To do otherwise is judicial misconduct arguably requiring a Complaint with the Judicial Discipline Commission.
Further Coughlin asked and then Manager Deede Call (she is listed as the manager on the "RENTAL AGREEMENT" of May 4th, 2012,
and it bears hers and Coguhlin's signature, numerous questions vis a vis the use of the rental, and clearly, Deede Call gave Coughlin
permission (and actually, Call did not indicate any "special permission" to use the rentals for something other than parking a car was
necessary to obtain anyways, and no one has established that Coughlin did not use the rentals for parking anyways, and any Fourth
Amendment violating trespass and videoing of Coughlin's rentals is not admissible anyways. Soldal v. Cook Co.
CHAPTER 40 - ACTIONS AND PROCEEDINGS IN PARTICULAR CASES CONCERNING PROPERTY SUMMARY PROCEEDINGS
FOR OBTAINING POSSESSION OF REAL PROPERTY, RECREATIONAL VEHICLE OR MOBILE HOME
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant for default in payment of rent.
NRS 40.280 Service of notices to quit; proof required before issuance of order to remove.
NRS 40.400 Rules of practice.
CHAPTER 108 - STATUTORY LIENS
LIENS OF OWNERS OF FACILITIES FOR STORAGE
NRS 108.475 Use of storage space for residence prohibited; eviction; nature of facility; effect of issuance of document of
title for property.
CHAPTER 118A - LANDLORD AND TENANT: DWELLINGS
CHAPTER 197 - CRIMES BY AND AGAINST THE EXECUTIVE POWER OF THIS STATE
NRS 197.090 Interfering with public officer.
NRS 197.100 Influencing public officer.
NRS 197.110 Misconduct of public officer.
NRS 197.120 False impersonation of public officer; intrusion into and refusal to surrender public office.
NRS 197.130 False report by public officer.
NRS 197.140 Public officer making false certificate.
NRS 197.160 Fraudulently presenting claim to public officer.
NRS 197.180 Wrongful exercise of official power.
NRS 197.190 Obstructing public officer.

The arrest of Coughlin at Northwinds Apartments on June 28th, 2012 by the same WCSO Deputy Machen who filed a false affidavit
attesting to have "personally served" Coughlin the Summary Eviction ORder from Coughlin's former home law office on November 1st,
2011, when in reality, Machen just posted the Order to the door when nobody was home (and therefore committed trespass under color of
law, as he failed to comply with NRCP 5(b)(2) (made applicable to landlord tenant matters by NRS 40.400) and NRCP 6(e).
So, WCSO Machen arrested Coughlin for a violation of NRS 197.190:
NRS 197.190 Obstructing public officer. Every person who, after due notice, shall refuse or neglect to make or furnish any statement, report or
information lawfully required of the person by any public officer, or who, in such statement, report or information shall make any willfully untrue, misleading or
exaggerated statement, or who shall willfully hinder, delay or obstruct any public officer in the discharge of official powers or duties, shall, where no other
provision of law applies, be guilty of a misdemeanor.
Yet DDA charged Coughlin in the Criminal Complaint in RJC RCR2012-067980 with a different crime, NRS 199.280:
"NRS: CHAPTER 199 - CRIMES AGAINST PUBLIC JUSTICE
OTHER OFFENSES
NRS 199.280 Resisting public officer.
A person who, in any case or under any circumstances not otherwise specially provided for, willfully resists, delays or obstructs a public officer in discharging
or attempting to discharge any legal duty of his or her office shall be punished:
1. Where a firearm is used in the course of such resistance, obstruction or delay, or the person intentionally removes, takes or attempts to remove or
take a firearm from the person of, or the immediate presence of, the public officer in the course of such resistance, obstruction or delay, for a category C felony as
provided in NRS 193.130.
2. Where a dangerous weapon, other than a firearm, is used in the course of such resistance, obstruction or delay, or the person intentionally removes,
takes or attempts to remove or take a weapon, other than a firearm, from the person of, or the immediate presence of, the public officer in the course of such
resistance, obstruction or delay, for a category D felony as provided in NRS 193.130.
3. Where no dangerous weapon is used in the course of such resistance, obstruction or delay, for a misdemeanor."
Why the change from DDA Young? It couldn't be becuase NRS 199.280 is more damaging to Coughlin's law license, in light of SCR 111(6), than would be a
simple little NRS 197.190 charge, could it? Is that permissible where the WCDA and WCSO have a vested interest in discrediting and demolishing Coughlin in
light of allegation of misconduct by both of those offices with respect to its treatment of Coughlin, in addition to misconduct against Coughlin by the WCDC?
Nevada Supreme Court Rule 111(6): "6. Definition of serious crime. The term serious crime means (1) a felony and (2) any crime less than a
felony a necessary element of which is, as determined by the statutory or common-law definition of the crime, improper conduct as an attorney, interference with
the administration of justice, false swearing, misrepresentation, fraud, willful failure to file an income tax return, deceit, bribery, extortion, misappropriation,".
Convictions of a "serious crime" require Bar Counsel to file a SCR 111 Petition against the attorney.
Could there be any clear demonstration of the retaliatory animus against Coughlin by the Washoe County District Attorney's Office? Are prosecutors paid to
play out grudges and sanction misconduct by local law enforcement? Rather than just a "resisting" charge, DDA Young and the WCDA want to try to glom on
a "false swearing" and "inteferring with the administration of justice" claim, even where the know of the 6/26/12 written correspondence by Coughlin to both the
Sparks and Reno Justice Courts and the Civil Division of the Washoe County Sheriff's Office. Enough is Enough. This prosecutorial misconduct must not
stand.
But, really Coughlin is hereby complaining to the landlord, pursuant to NS 118A.510 of a violation of the criminal law by one who is arguably an "agent" of the
landlord (not making a bribery allegation here, to be clear, though):
NRS 197.200 Oppression under color of office.
1. An officer, or a person pretending to be an officer, who unlawfully and maliciously, under pretense or color of official authority:
(a) Arrests or detains a person against the persons will;
(b) Seizes or levies upon anothers property;
(c) Dispossesses another of any lands or tenements; or
(d) Does any act whereby the person, property or rights of another person are injured,
commits oppression.
2. An officer or person committing oppression shall be punished:
(a) Where physical force or the immediate threat of physical force is used, for a category D felony as provided in NRS 193.130.
(b) Where no physical force or immediate threat of physical force is used, for a gross misdemeanor.
Further, this is an officil written complaint against WCSO Deputy Machen and Gomez, please place a copy of this Complaint in their employment and personnel
files, and please do the same with respect to RPD Officer Alan Weaver, Sargent Dye, Sargent Oliver Miller, and Officer Welch for their gross misdemeanor,
consisting of doing that which is the domain of the Sheriff under NRS 40.760 in conection with the matter at Superior Mini Storage on or around September 21st,
2012 under the following law, in light of teh language in NRS 40.760 and NRS 108.475, which I made the RPD aware of at the time, and Soldal v. Cook Co.
Couldn't be too much of a budget crunch when local law enforcement acts the way they do, veritably goading civil rights tenant's right attorney's into suing
them through their reckless and tacky behavior: NRS 197.180 Wrongful exercise of official power. Any person who willfully takes upon
himself or herself to exercise or officiate in any office or place of another, without being lawfully authorized thereto, is guilty of a gross misdemeanor.
Also, uner NRS 118A.510, I am complaining of the following violations of criminal law on Northwind's behalf:
NRS 197.120 False impersonation of public officer; intrusion into and refusal to surrender public office. Every person who shall falsely
personate or represent any public officer, or who shall willfully intrude into a public office to which the person has not been duly elected or appointed, or who
shall willfully exercise any of the functions or perform any of the duties of such officer, without having duly qualified therefor, as required by law, or who, having
been an executive or administrative officer, shall willfully exercise any of the functions of office after his or her right to do so has ceased, or wrongfully refuse to
surrender the official seal or any books or papers appertaining to such office, upon the demand of his or her lawful successor, shall be guilty of a gross
misdemeanor.
[1911 C&P 67; RL 6332; NCL 10016]
NRS 197.130 False report by public officer. Every public officer who shall knowingly make any false or misleading statement in any
official report or statement, under circumstances not otherwise prohibited by law, shall be guilty of a gross misdemeanor.
NEvada Court Services regularly attempts to mislead tenant's into thinking the act with color of law. From Joel Durden barking at me in his Sheriff look-a-like getup that he is an
"officer of the court" and from "Court Services" to having the word "Court" in their name,etc., etc. NEvad Court Services impersonates public officers. Additionally, Machen's
police report is false to the extent that it fails to indicate that, at least at some point, Machen and or Deputy Gomez refused to idnetify themslevs. They don't know what someone is
doing inside when they purport to "knock and announce" and the must reasonably be expected to assume one could have not heard their initial announcing their idnetify (whether
because they had headphones or, were in the bathroom, whatever...and Machen and his cowboy partner Gomez refused to identify themselves in response to a request that they do
so by Coughlin, and similarly refused to slide through the door any paperwork or warrant describing the purpose of their visit.
WCSO is that Machem's Affidavit of Service indicates that he "personally served" me, which kind of reminds me of all that robo-signing
and MERS fraud I come across in my day job (and do you wonder how many attorneys in the foreclosure defense game I am in constant
contact with who are watching and witness the potential RICO violations this writing mentions?), which includes being a foreclosure
defense attorney. So which is it? Did Machem "personally serve" me the Summary Eviction Order? Richard G. Hill, Esq. likes to
argue that I was "served" in compliance with all time related rules because it was done in the "usual custom and practice of the WCSO.
What, exactly, is the "usual custom and practice of the WCSO? I hear a lot about this "within 24 hours" stuff. So, I go hunting for some
black letter law to support what those at the RJC and in the clueless community at large (which often includes Nevada Legal Services and
Washoe Legal Services, the people you guys had such trouble actually serving in the lawsuits I filed, which may have actually helped
improved legal services in this community, if they were not dismissed due to insufficiency of service of process, even where the IFP
required the WCSO to served the defendants....). Anyway, back to the "within 24 hours" phraseology: "

This whole business about The court may thereupon issue an order directing the sheriff or constable of the county to remove the tenant
within 24 hours after receipt of the order... is inapplicable to this situation, where an Order Granting Summary Eviction was signed by
October 27th, 2011. That language is only found in situations inapplicable to the current one. NRS 40.253(3)(b)(2), and NRS 40.253(5)(a)
are the only sections of NRS 40 where this within 24 hours language occurs, and those situations only apply where, in:
40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: . (2) That if the court determines
that the tenant is guilty of an unlawful detainer, the court may issue a summary order for removal of the tenant or an order providing for the
nonadmittance of the tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order
and,
40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords agent may apply by affidavit
of complaint for eviction to the justice court of the township in which the dwelling, apartment, mobile home or commercial premises are
located or to the district court of the county in which the dwelling, apartment, mobile home or commercial premises are located, whichever
has jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or constable of the county to remove the tenant
within 24 hours after receipt of the order. The way these summary eviction proceedings are being carried out in Reno Justice Court
presently shocks the conscience and violates Nevada law. There is not basis for effectuating a lockout the way WCSO's Deputy Machem did
in this case. The above two sections containing the within 24 hours of receipt language are inapplicable, as those situations do not
invoke the present circumstances, where the Tenant did file an Affidavit and did contest this matter to a degree not often seen. To require
Nevada's tenants to get up and get out within 24 hours of receipt of the order (what does that even mean? The use of terms like
rendition, rendered, notice of entry, pronounced, is absent here, and this receipt of the order language is
something rarely found elsewhere in Nevada law-see attached DMV statutory citations, and in employment law litigations where one must
file a Complaint within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b), and NRCP 6(e) in imputing
receipt of such a letter, when actual receipt is not shown, by applying a constructive notice standard that relies upon the days for
mailing extension of time for items served in the mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir.
2009), the record did not reflect when the plaintiff received his right-to-sue letter. The letter was issued on November 24, 2006. The court
calculated that the 90-day period commenced on November 30, 2006, based on three days for mailing after excluding Saturdays and
Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must exhaust administrative remedies and sue within 90
days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin County Welcome Center v. Brown, 466 U.S. 147, 148
n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)(granting plaintiff an additional three days for mailing pursuant to Rule 6).
Further, despite what the inaccurate handouts of Nevada Legal Services may say about this 24 hours and the applicability of the
JCRCP to cases like these, NRS 40.400 Rules of practice, holds that :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. As such NRCP 6(a),(e) applies to the Order of
Summary Eviction that WCSO Deputy Machem alleged, under penalty of perjury, that he "personally served" upon me on November 1,
2011. That is a lie by Mr. Machem, unless "personally served" is defined in a rather impersonal way and or Machem and I have totally
different understanding of the definition of "personally served", which may be the case. Or, perhaps the Sheriff's Office is busy and
doesn't want to wait around to "personally serve" every tenant it wishes to evict. Fine, then just use the "mail it and allow three days" rule
in NRCP 6(e)...the landlord's might not like it, but they can use that frustration as an incentive not to jump to litigating every disagreement
about habitability that a tenant brings to them. You may not realize how ridiculous some landlord's get. In my case, I offered to fix
basic things that clearly implicated the habitability rules in NRS 118A.290 and the Californian neurosurgeon, Beverly Hill High School
graduate landlord balked and complained then hired and attorney four days into a dispute.....at which point the rules against contacting
represented parties prevented much in the way of real settlement discussion, particularly where opposing counsel has continuously
demonstrated a complete indifference to pursuing settlement (why would he at the rates he bills hours at?). I just don't think the
Sheriff's Office needs to sully its image or damage the citizen tenants of Washoe County in the name of pleasing people like Dr. Matt
Merliss or Richard G. Hill, Esq.
I am hereby complaining to Northwind Apartments of a violation of the criminal law by one of its agents R. Wray and other process servers
with NCS (Oh, and RPD Officer Weaver also threatened to use "hydraulic explosives" to gain entry to one of my three rentals at Northwind,
though no exigent circumstance existed and though he lacked a warrant. I have previously complained of Lou Cadia, Milan Krebs, both
Northwind Maintenance Personnel, and Northwind Property Manager or Apartment Manager Dwayne Jakob attempt to break and enter into
my rentals (why is it when Richard G. Hill, Esq. calls the RPD and alleges I am trespassing, I get subject to a custodial arrest and Hill gets
the State Bar of Nevada to try to prosecute me for "breaking an entering", even though WCSO Machen lied in his Affidavit of Service in
RJC rev2011-0010708, and the Court had failed to return to me at the time of arrest the $2,275 it wasn't permitted to require I deposit in a
"rent escrow" account in the first place, and where Hill and his contractor are caught on video admitting to having remove my ladder from
the former law office (in a video of December 23rd, 2011...why doesn't the RPD arrest Hill and Phil Stewart for larceny of my ladder? Do
I have to be Wal-Mart or Richard G. Hill or Northwinds Apartments (ie, rich, connected) to get the RPD to enforce the law when I complain
of a violation?
NRS 40.280 Service of notices to quit; proof required before issuance of order to remove.
1. Except as otherwise provided in NRS 40.253, the notices required by NRS 40.251 to 40.260, inclusive, may be served:
(a) By delivering a copy to the tenant personally, in the presence of a witness;
(b) If the tenant is absent from the tenants place of residence or from the tenants usual place of business, by leaving a copy with a person of suitable age and discretion
at either place and mailing a copy to the tenant at the tenants place of residence or place of business; or
(c) If the place of residence or business cannot be ascertained, or a person of suitable age or discretion cannot be found there, by posting a copy in a conspicuous place on the
leased property, delivering a copy to a person there residing, if the person can be found, and mailing a copy to the tenant at the place where the leased property is situated.
2. Service upon a subtenant may be made in the same manner as provided in subsection 1.
3. Before an order to remove a tenant is issued pursuant to subsection 5 of NRS 40.253, a landlord shall file with the court a proof of service of any notice required by that section.
Before a person may be removed as prescribed in NRS 40.290 to 40.420, inclusive, a landlord shall file with the court proof of service of any notice required pursuant to
NRS 40.255. Except as otherwise provided in subsection 4, this proof must consist of:
(a) A statement, signed by the tenant and a witness, acknowledging that the tenant received the notice on a specified date;
(b) A certificate of mailing issued by the United States Postal Service; or
(c) The endorsement of a sheriff, constable or other process server stating the time and manner of service.
4. If service of the notice was not delivered in person to a tenant whose rent is reserved by a period of 1 week or less and the tenancy has not continued for more than 45 days, proof
of service must include:
(a) A certificate of mailing issued by the United States Postal Service or by a private postal service to the landlord or the landlords agent; or
(b) The endorsement of a sheriff or constable stating the:
(1) Time and date the request for service was made by the landlord or the landlords agent;
(2) Time, date and manner of the service; and
(3) Fees paid for the service."
[
NRS 118A.430 Failure of tenant to comply with rental agreement or perform basic obligations: Termination of rental agreement.
1. Except as otherwise provided in this chapter, if the tenant fails to comply with the rental agreement or fails to perform his or her basic obligations under this chapter,
the landlord may deliver a written notice to the tenant specifying the acts and omissions constituting the breach and that the rental agreement will terminate as provided in this section.
If the breach is remediable and the tenant does not adequately remedy the breach or use his or her best efforts to remedy the breach within 5 days after receipt of the notice, or if the
breach cannot be remedied, the landlord may terminate the rental agreement.
2. If the tenant is not reasonably able to remedy the breach, the tenant may avoid termination of the rental agreement by authorizing the landlord to enter and remedy the
breach and by paying any reasonable expenses or damages resulting from the breach or the remedy thereof.
Northwinds and NCS failed to comply with NRS 118A.430(1) (to the extent it even applies her) in that in no way did it "deliver a written notice to the tenant specifying
the acts and omissions constituting the breach". Northwinds simply wrote "see attached", after paragraph 6 of teh 6/14/12 Notice, which
reads "6. Remained in posssession of the premises subject to the provisions of Chapter 118A of the NRS after having failed ot perfrom the
basic or contractual obligations imposed upon you by that Chapter, namely: (SEE ATTACHED)" and then NCS, at most, include a copy of
the "Rental Agreement" with its filing of this Notice to the RJC, which in no way specifies what aspect of that Rental Agreement Coughlin
is purportedly in breach of, or what facts supports such an allegation.
Any Order he is void or subject oa NRCP 60b set aside based upon the fraud of NCS and Wray in lying where he declares (under penalty
of perjury) to have "personally served" Coughlin the 5 day notie on 6/14/12, and under NRCP 60b4 void for lack of jurisdiction where NCS
failed to specify in the Lanldord's Affidavit all that required under NRS 40.253. and for so many other reasons, such at 118A does not apply
if the rental is deemed to be not e "dwelling", and that an illegal lockout is not available even if Coughlin is ruled to have been "using as a
residence" the rental, should the rental be a "storage facility" which City of Reno Code Enforcement does not view it to be...and Further, by
Northwinds very own descriptives, it is a garage, one they held out to the public for more than mere "parking a car", and as such, under
NRS 40.760 and 108.4733, 108.475 and NRS 40.760 are not even available to Northwind. They. Are. Stuck. Deal With It.
NRS 108.4733 Facility defined. Facility means real property divided into individual storage spaces. The term does not include a garage or storage area in a private residence.
NRS 108.4746 Storage space defined. Storage space means a space used for storing personal property, which is rented or leased to an individual occupant who has access to the space.
NRS 108.475 Use of storage space for residence prohibited; eviction; nature of facility; effect of issuance of document of title for property.
1. A person shall not use a storage space at a facility for a residence. The owner of such a facility shall evict any person who uses a storage space at the facility as a residence in the manner provided for in NRS
40.760.
NRS 108.4755 Contents of rental agreement.
1. Each rental agreement must be in writing and must contain:
(a) A provision printed in a size equal to at least 10-point type that states, IT IS UNLAWFUL TO USE A STORAGE SPACE IN THIS FACILITY AS A RESIDENCE.
MISCELLANEOUS PROVISIONS
NRS 40.760 Summary eviction of person using facility for storage as residence.
1. When a person is using a storage space at a facility as a residence, the owner or the owners agent shall serve or have served a notice in writing which directs the person to cease using the storage space as a residence no
later than 24 hours after receiving the notice. The notice must advise the person that:
(a) NRS 108.475 requires the owner to ask the court to have the person evicted if the person has not ceased using the storage space as a residence within 24 hours; and
(b) The person may continue to use the storage space to store the persons personal property in accordance with the rental agreement.
2. If the person does not cease using the storage space as a residence within 24 hours after receiving the notice to do so, the owner of the facility or the owners agent shall apply by affidavit for summary
eviction to the justice of the peace of the township wherein the facility is located. The affidavit must contain:
(a) The date the rental agreement became effective.
(b) A statement that the person is using the storage space as a residence.
(c) The date and time the person was served with written notice to cease using the storage space as a residence.
(d) A statement that the person has not ceased using the facility as a residence within 24 hours after receiving the notice.
3. Upon receipt of such an affidavit the justice of the peace shall issue an order directing the sheriff or constable of the county to remove the person within 24 hours after receipt of the order. The sheriff or constable
shall not remove the persons personal property from the facility.
4. For the purposes of this section:
(a) Facility means real property divided into individual storage spaces. The term does not include a garage or storage area in a private residence.
(b) Storage space means a space used for storing personal property, which is rented or leased to an individual occupant who has access to the space.
(Added to NRS by 1989, 213; A 2011, 1830)
Nevada Process Server Licensing Requirements
It is required that all process servers are licensed and 21, or over, two-years experience as a process server and insurance against liability to third persons with limits of no less then $200,000.
No bonding is required. However, applicants must deposit $750 upon submitting their application to pay for a background investigation, the maximum an applicant can be charged for a
background check is $1500. Applicants must also pass a written application and may be required to pass an oral exam as well. Licenses are issued by the Nevada Private Investigators
Licensing Board. Nevada is the most expensive state in the nation to get licensed. [Nevada Revised Statutes 648.110 and 648.135]
"NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant for default in payment of rent.
1. Except as otherwise provided in subsection 10, in addition to the remedy provided in NRS 40.2512 and 40.290 to 40.420, inclusive, when the tenant of any dwelling, apartment,
mobile home, recreational vehicle or commercial premises with periodic rent reserved by the month or any shorter period is in default in payment of the rent, the landlord or the
landlords agent, unless otherwise agreed in writing, may serve or have served a notice in writing, requiring in the alternative the payment of the rent or the surrender of the
premises:
(a) At or before noon of the fifth full day following the day of service; or
(b) If the landlord chooses not to proceed in the manner set forth in paragraph (a) and the rent is reserved by a period of 1 week or less and the tenancy has not continued for more
than 45 days, at or before noon of the fourth full day following the day of service.
As used in this subsection, day of service means the day the landlord or the landlords agent personally delivers the notice to the tenant. If personal service was not so
delivered, the day of service means the day the notice is delivered, after posting and mailing pursuant to subsection 2, to the sheriff or constable for service if the request for
service is made before noon. If the request for service by the sheriff or constable is made after noon, the day of service shall be deemed to be the day next following the day that
the request is made for service by the sheriff or constable.
2. A landlord or the landlords agent who serves a notice to a tenant pursuant to paragraph (b) of subsection 1 shall attempt to deliver the notice in person in the manner set forth
in paragraph (a) of subsection 1 of NRS 40.280. If the notice cannot be delivered in person, the landlord or the landlords agent:
(a) Shall post a copy of the notice in a conspicuous place on the premises and mail the notice by overnight mail; and
(b) After the notice has been posted and mailed, may deliver the notice to the sheriff or constable for service in the manner set forth in subsection 1 of NRS 40.280. The sheriff or
constable shall not accept the notice for service unless it is accompanied by written evidence, signed by the tenant when the tenant took possession of the premises, that the landlord or
the landlords agent informed the tenant of the provisions of this section which set forth the lawful procedures for eviction from a short-term tenancy. Upon acceptance, the sheriff
or constable shall serve the notice within 48 hours after the request for service was made by the landlord or the landlords agent.
3. A notice served pursuant to subsection 1 or 2 must:
(a) Identify the court that has jurisdiction over the matter; and
(b) Advise the tenant:
(1) Of the tenants right to contest the matter by filing, within the time specified in subsection 1 for the payment of the rent or surrender of the premises, an affidavit with the court
that has jurisdiction over the matter stating that the tenant has tendered payment or is not in default in the payment of the rent;
(2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue a summary order for removal of the tenant or an order providing for the
nonadmittance of the tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order; and
(3) That, pursuant to NRS 118A.390, a tenant may seek relief if a landlord unlawfully removes the tenant from the premises or excludes the tenant by blocking or attempting to block
the tenants entry upon the premises or willfully interrupts or causes or permits the interruption of an essential service required by the rental agreement or chapter 118A of NRS.
4. If the tenant files such an affidavit at or before the time stated in the notice, the landlord or the landlords agent, after receipt of a file-stamped copy of the affidavit which was
filed, shall not provide for the nonadmittance of the tenant to the premises by locking or otherwise.
5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling, apartment, mobile home or
commercial premises are located or to the district court of the county in which the dwelling, apartment, mobile home or commercial premises are located, whichever has jurisdiction
over the matter. The court may thereupon issue an order directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order. The affidavit
must state or contain:
(1) The date the tenancy commenced.
(2) The amount of periodic rent reserved.
(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the first months rent, by the tenant.
(4) The date the rental payments became delinquent.
(5) The length of time the tenant has remained in possession without paying rent.
(6) The amount of rent claimed due and delinquent.
(7) A statement that the written notice was served on the tenant in accordance with NRS 40.280.
(8) A copy of the written notice served on the tenant.
(9) A copy of the signed written rental agreement, if any.
(b) Except when the tenant has timely filed the affidavit described in subsection 3 and a file-stamped copy of it has been received by the landlord or the landlords agent, and
except when the landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may, in a peaceable manner, provide for the nonadmittance of the tenant to
the premises by locking or otherwise.
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the information contained in the affidavit, and the filing by the landlord of the affidavit
permitted by subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the hearing upon the parties, to determine the truthfulness and sufficiency
of any affidavit or notice provided for in this section. If the court determines that there is no legal defense as to the alleged unlawful detainer and the tenant is guilty of an unlawful
detainer, the court may issue a summary order for removal of the tenant or an order providing for the nonadmittance of the tenant. If the court determines that there is a legal defense
as to the alleged unlawful detainer, the court shall refuse to grant either party any relief, and, except as otherwise provided in this subsection, shall require that any further proceedings
be conducted pursuant to NRS 40.290 to 40.420, inclusive. The issuance of a summary order for removal of the tenant does not preclude an action by the tenant for any damages or
other relief to which the tenant may be entitled. If the alleged unlawful detainer was based upon subsection 5 of NRS 40.2514, the refusal by the court to grant relief does not preclude
the landlord thereafter from pursuing an action for unlawful detainer in accordance with NRS 40.251.
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a motion, file a motion with the court, on a form provided by the clerk of the court, to
dispute the amount of the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 for the inventory, moving and storage of personal property left on the
premises. The motion must be filed within 20 days after the summary order for removal of the tenant or the abandonment of the premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed from the premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the motion. The hearing must be held within 10 days after the filing of the motion. The
court shall affix the date of the hearing to the motion and order a copy served upon the landlord by the sheriff, constable or other process server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges determined to be due or if no charges are determined to be due.
9. A landlord shall not refuse to accept rent from a tenant that is submitted after the landlord or the landlords agent has served or had served a notice pursuant to subsection 1 if
the refusal is based on the fact that the tenant has not paid collection fees, attorneys fees or other costs other than rent, a reasonable charge for late payments of rent or dishonored
checks, or a security. As used in this subsection, security has the meaning ascribed to it in NRS 118A.240.
10. This section does not apply to the tenant of a mobile home lot in a mobile home park or to the tenant of a recreational vehicle lot in an area of a mobile home park in this State
other than an area designated as a recreational vehicle lot pursuant to the provisions of subsection 6 of NRS 40.215.
(Added to NRS by 1967, 195; A 1969, 263, 575; 1973, 1085; 1975, 1202; 1977, 418, 1346; 1979, 1398, 1879; 1985, 229; 1987, 1239; 1989, 1082, 1232; 1991, 113; 1995, 1851; 1997,
3511; 1999, 981; 2009, 1966; 2011, 235, 1489)
NRS 40.254 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant from certain types of property. Except as otherwise provided by specific statute, in
addition to the remedy provided in NRS 40.251 and in NRS 40.290 to 40.420, inclusive, when the tenant of a dwelling unit which is subject to the provisions of chapter 118A of NRS,
part of a low-rent housing program operated by a public housing authority, a mobile home or a recreational vehicle is guilty of an unlawful detainer, the landlord is entitled to the
summary procedures provided in NRS 40.253 except that:
1. Written notice to surrender the premises must:
(a) Be given to the tenant in accordance with the provisions of NRS 40.280;
(b) Advise the tenant of the court that has jurisdiction over the matter; and
(c) Advise the tenant of the tenants right to contest the notice by filing within 5 days an affidavit with the court that has jurisdiction over the matter that the tenant is not guilty of
an unlawful detainer.
2. The affidavit of the landlord or the landlords agent submitted to the justice court or the district court must contain:
(a) The date when the tenancy commenced, the term of the tenancy, and, if any, a copy of the rental agreement.
(b) The date when the tenancy or rental agreement allegedly terminated.
(c) The date when the tenant became subject to the provisions of NRS 40.251 to 40.2516, inclusive, together with any supporting facts.
(d) The date when the written notice was given, a copy of the notice and a statement that notice was served in accordance with NRS 40.280.
(e) A statement that the claim for relief was authorized by law.
3. If the tenant is found guilty of unlawful detainer as a result of the tenants violation of any of the provisions of NRS 453.011 to 453.552, inclusive, except NRS 453.336, the
landlord is entitled to be awarded any reasonable attorneys fees incurred by the landlord or the landlords agent as a result of a hearing, if any, held pursuant to subsection 6
of NRS 40.253 wherein the tenant contested the eviction.
(Added to NRS by 1985, 227; A 1989, 1084, 1234; 1991, 115; 1995, 1853; 2001, 1065; 2003, 561)"
I WOULD LIKE TO KNOW WHY THE FILE IN RJC REV2012-001048 HAS MY 6 PAGE FAX OF JUNE 30TH, 2012 (AND PLEASE
NOTE THE LIMITED OR SPECIAL APPEARANCE NATURE OF THAT FILING IN THE NOTE AT THE BOTTOM OF THE FIRST
PAGE....YET IT IS NOT FILE STAMPED, AND I WAS NEVER CALLED, OR FAXED, OR NOTIFIED IN ANY WAY
CONCERNING THE SCHEDULING OF MY CONSTITUTIONALLY GUARANTEED HEARING BEFORE A SUMMARY EVICTION
OR STATUS OF MY IFP REQUEST.
MY POSITION IS THAT I AM ENTITLED TO A SUMMARY EVICTION HEARING ON UNIT 29 AND THAT IT IS LONG
OVERDUE. PLEASE LET ME KNOW WHEN THAT HEARING CAN TAKE PLACE. I DO NOT BELIEVE ANY JUDGE
CURRENTLY HAS JURISDICTION ON IT, AND THAT THE NEW CASE, WITH A NEW CASE NUMBER SHOULD BE
"RANDOMLY ASSIGNED"
Further in the Reno justice court file for rjc rev2012-001048 is a tenant affidavit and declaration from Coughlin faxed to the court on June 30, 2012 contain six pages it is unclear why
Coughlin was not granted a summary eviction hearing as required by law and Coughlin is hereby demanding one and a jury trial which he is entitled to one pursuant the 19 Seventies
the Court decision and FRCP rule 30 a.m. that Coughlin is requesting one prior to the time set for hearing that's right folks were going to a jury trial when Nevada court services
served an amended eviction notice on June 28 Coughlin there and had five days to file for an eviction summary eviction hearing and he did so on June 30 just for the Reno PD
managed commit another wrongful arrest of Coughlin further there was County jail failed to transfer Coughlin for the July 5 hearing on Coughlin's motion to set aside the original June
27 order however the June 27 order in this case was extinguished by that posting of an amended lockout notice therefore and eight it's not file stamp but it should be by the Reno
justice court the six page fax by Coughlin on June 30, 2012, though Karen Stancil appears to have handwritten in the case number RJC rev2012-001048
PLEASE NOTE I AM USING AUDIO DICTATION TRANSCRIPTION SOFTWARE FOR THIS CORRESPONDENCE AND IT MIGHT HAVE SOME ERRORS, WHICH
COULD GREATLY ALTER THE MEANING, AS I DON'T HAVE TIME TO CORRECT THEM RIGHT NOW.
additionaly THERE WAS SEVERAL FAXES TO THE RJC CIVIL DIVISION BY COUGHLIN ON OR ABOUT JUNE 13TH, 2012, AND COUGHLIN REQUESTS A COPY OF
THOSE OR SOME INDICATION OF WHY THEY WERE NOT FILED AND COUGHLIN WILL CHECK HIS OWN RECORDS IN THAT REGARD WHEN HE HAS
TIME...HOWEVER, TO THE EXTENT ONE OF THOSE FILINGS WAS A TENANT'S AFFIDAVIT DIRECTED TOWARDS UNIT 29, LOTS OF PROCEDURAL
IMPLICATIONS WILL STEM.
NORTHWIND APARTMENT
ASSOC LLC
1031 XPRESS
NORTHWIND LLC
110 110TH AVE NE STE
550
BELLEVUE, WA 98004
Description Summary
Fictitious Firm Name - Counter
74040
04/01/1997 12:00:00 AM Expiration Date: 04/01/2002
Business Name: NORTHWIND APARTMENTS Owners: NORTHWIND APARTMENT ASSOCIATES, LLC
s Firm Name - Counter - 109351
Filing Information
Filing Number
109351
Filing Date
03/16/2006 12:00:00 AM
Expiration Date
03/16/2011
Business Information
Business Name
RENO RED BOOK
Owner Information
Owner/Corporate Name
JEFFREY G CHANDLER u
Fictitious Firm Name - Counter
104085
12/08/2004 12:00:00 AM Expiration Date: 12/08/2009
Business Name: BOTTS CANDY COMPANY Owners: JENNIFER V CHANDLER, CINDY R VANDERZIEL
Him and him and him and him motion a set of society eviction order of the number of bases one it went unopposed and
hundred Polk case Coughlin wins in that regard to the notice of hearing by the Reno justice court is dated July 31,
2012 are not as of the hearing on July 21, 2012 stated July 24, 2012 and him notices on what the hearing is limited
to quote you may appear on the data show cause why the court should or should not grant motion to stay the eviction
order in the motion for expedited relief following legal lot coverage utility shut off. If you the. Must be prepared
to provide testimonial documentary evidence the court which torture position if he failed to appear karmic
renovation would form a dismiss case. With what the notice does not say is that the hearing will address the motion
to set aside eviction order Coughlin filed on July 24, 2012 and that which and for which now he request the court to
rule in his favor or at least provide hearing or at the very and for or at the very least require Northwind and/or
their qualified attorneys or whoever to file an opposition something under of explaining why their are three
separate notices for her three separate process affidavits of service for the June 14, 2012 personal service of a
five-day unlawful detainer affidavit by Robert Ray of Nevada court services that's right there's three separate ones
and Coughlin's possession now and they bear different things as well isn't that interesting half add to that the
fact that Nevada court services agreed with Coughlin's assessment that its original on June 14 notice of unlawful
detainer failure to vacate premises was ineffective and that it listed the wrong forum is or court for the tenant to
file a tenant at search engines affidavit as required by law under 40.253 that's not something the judge piercing
can excised from the law or legislate from the bench out of existence that is a law. The Reno justice court does not
have jurisdiction with the notice last Sparks justice court the fugitive document for the landlord to file it
landlord's affidavit and then to manage to get Coughlin arrested based upon a void order that should never issued
judge Shrader particularly where supervisor of the syllable division Karen Stancil was alerted and well in advance
by Coughlin through phone calls and mid-June in that June 26 of written correspondence to the court that included in
the file on the left side of the correspondence and where the Sparks justice court itself fax the Reno justice court
that a fax alerting it to the problematic aspects of the June 14 notice Coughlin was arrested he went to jail he
paid bail he did time incurred massive damages it's appalling for judge piercing to ignore all this while also
sanctioning the unauthorized practice of law by Jeff Chandler Nevada court services who dress up like they are
Sheriff's and managed to the word court into their name and bang on people store and leave off the Nevada part so
much so that it and it seems as though they are actually acting with color of law in the screening you to come out
of your house and bang on the door parted sounds like they are cost of the Sheriff and have to do exactly what you
said. Those few who don't Nevada court services has something up their sleeve in the form of attempting to break and
enter and one's residence or sex service of process by as Nevada court services has done to Coughlin on numerous
occasions sometimes captured on videotape further Nevada court services is trespassed on numerous occasions like
office property Coughlin however is the only one who's arrested and convicted trespassing and had reported rehashes
patent trademark office and had impact his ability to practice his chosen profession for which he has to does have a
law license and actually did that a lot four. Further there's initial conflict in the judge piercing work to the
district attorneys office first 12 years of his career and the Washoe County Sheriff and potentially Washoe County
District Attorney's Office may have it engages the misconduct in connection with the approximately 10 different
incarcerations Coughlin space this year most all connected one where another To the Way, Reno justice court handles
landlord-tenant matters or fails to apply the law as written and created by the assembly the Senate i.e. the
legislature Nevada and Carson City to be clear Nevada court services recognize the validity of Coughlin's argument
that when he announced to them on June 28 at approximately 10 AM to 10:45 AM is where Coughlin pointed out that the
the June 14 notice listed Sparks justice court that Nevada court services responded by serving in the amended
declaration of service by license process server on June 28 thereby vitiate in any order lockout order rescinding
and waving it etc. etc. June 28, 2012 fax from the Sparks justice court to the Reno justice court contains a fax
Coughlin sent the Sparks justice court on June 26 that at 12 PM noon of that date that faction Coughlin was 10 pages
the facts from the Sparks justice court the Reno justice court was apparently 13 pages no number of those pages are
not included in the file of this matter and the Reno justice court back to the three different notices of unlawful
detainer either stamped by w which doesn't count by the way one needs to sign something attorneys don't get a stamp
things and file them and then later on claim they didn't commit commit misconduct or her perjury or rule 11
violation merely because it is sign something Nevada court services continues to just put stamps instead of actual
signatures and that's an appropriate and under the Aiken case is in Nevada and summary of proceedings the technical
aspects of notice and due process requirements must be strictly adhered to not run out with the bathwater by judge
Pearson because he either doesn't like off-line or thinks Coughlin doesn't deserve due process of the law article
protection because Coughlin's an attorney you know Coughlin's not a license attorney currently needs not able to
make attorney money or do attorney things or even commit the unauthorized practice of law with impunity like Nevada
court services because know Coughlin you know of Coughlin was to do so the State Bar would find it to be a contempt.
Further judge Pearson's order for summary eviction of July 31 is void in several respects one it purports rule one
units 2971 when unit 71 is not properly before the court unit 71 has its own case numbers of rev2012-0067 and
rev2012-001082 (the multiplicty is due to, as here, THE RJC shortcutting due process aspects of the process,
whererin "Orders" by Judges paid quite a bit of money are nothing more than handwritten notes on Coughlin's own
filings...Some of those such "note ORders" by Judge Schroeder resulte in confusing vis a vis whether Coguhlin's
IFP's were granted, and necessitated the filing of companion cases for units 45 and 71 in rev2012-0067 and rev201-
0068 in rev2012-001082 and rev2012-00183. To simply make Coughlin scapegoated all medicine blame him for taking of
regardless the July 31 order by judge Pearson in rev 2012 00 1048 purports rule on matters not noticed in the July
24 notice specifically in that order which reads the court finds eviction was appropriate motion to stay eviction
order denied motion to set aside eviction order denies motion to contest personal property lien denied motion on
illegal lockout denied tenant have always property removed is 2971 by 5 PM on August 5, 2012 only about half of that
order was properly before the court notice litigants that I'm what was notice to the litigants in the July 24 notice
was that the hearing would be limited to the motion to stay eviction order in a motion for expedited relief
following illegal lockout utility shutoff however the order went on to rule on matters non-there and noticed
including the motion to set aside the eviction order the motion to contest personal property lien and that matters
related to the property of a unit not even involved in a case number unit 71 further there required Coughlin a hub
Allis property removed even earlier than the law requires given that after the 30 day plan under NRS 118 A.460 the
landlord may not dispose of the property until 14 days of pass from mailing to the tenant last known address a
certified letter. So there and again judge Pearson is violating the law in failing to apply evenly to Coughlin in
fact he's attempting to exCise protections accorded and Coughlin under Nevada's landlord tenant law which is the
most pro-landlord law set of laws in the country but that's not good enough for judge piercing he wants to cut even
more protections out of it when it comes to Coughlin and the reasoning behind that is not clear though Coughlin has
had some issues with Washoe County District Attorney's Office this year in judge Pearson did spend the first 12
years of his career there.
Attached in exhibit a are the three different June 14 declarations of service by license process server Robert (or Ryan?) Wray ..That's right, Coughlin has in his possession three
different NOtice of UD dated 6/14/12 and either "stamped" with "R. Way" or actually containing a handwritten signature by R. Wray (though the one actually signed lacks a time
indication, and they all lack a "manner of service" or any other particular beyond falsely attesting to have been "personally served". WRay and NORthwinds manager attempted to
break and enter into unit 29 in hopes of effecting "personal service" upon Coughlin in a unit that had not windows and that had the door closed and locked and or barred. That is a
criminal act and Coughlin is now again hereby complaining about it to the landlrod, so have fun reading NRS 118A.510's and NRS 118A.390 and I'll see you in Court, and WRay,
you should probably self report to the process server licensing body and hope for the best. Check out the video fo the 6/28/12 arrest wherein the WCSO's Gomez and Machen tell
Chandler to "let us do the talking, Jeff", then Chandler, dressed up in an outfit and with a company name intended to connote color of law type authority, purports to trespass Coughlin
from the whole place, ie, the entire premises at 1680 Sky Mountain Dr., depsit Coughlin still having, at the time, one, and perhaps two valid leases, to units 45 and 71. Further, the
Washoe County Detention Center or jail took a tenan'ts affidavit from Coughlin on or aoround July 15th, 2012 for units 45 and another for unit 71 and due to Coughlin's indigency,
the jail library indicate it would be filed with the rjc....WAs it? LITIGATION HOLD NOTIE TO THE JAIL AND THE RJC.
To: chansen@washoecounty.us
Subject: Reno eviction noticed for Sparks Justice Court
Date: Tue, 26 Jun 2012 09:10:14 -0700
Dear Civil Supervisor Hansen
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Dear Sparks Justice Court,
I called and received permission to file this by fax...I am indigent and request a fee waiver, and failing that, an opportunity to cure any filing fee deficiency.
To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us; chansen@washoecounty.us; milllerr@reno.gov
Date: Tue, 26 Jun 2012 07:58:36 -0700
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful detainer?) for rentals located at 1680 Sky Mountain Drive, Reno,
89523, but the notice indicates that I must file a Tenant's Answer with the Sparks Justice Court.
Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court has 4 judicial days a week, the deadline for filing a special
appearance (to contest jurisdiction) and or a Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he indicated the WCSO planned to come effectuate an eviction on this
date, June 26, 2012. I believe that would be premature, as Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit by noon after the
fifth full day (judicial days) and Fridays in Sparks Justice Court are not full days in that sense, and regardless, Sparks Justice Court, I believe, is not the appropriate
forum where, as here, the situs is located in Reno (Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
Sparks, Nevada 89431
(775)353.7603 Phone
(775)352.3004 Fax
Civil Department Supervisor
Chris Hansen
chansen@washoecounty.us
The Civil Division of Sparks Justice Court is made up of three major functions:
Civil
Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive damages, an action to obtain possession of property, a writ of
restitution, or other like actions, legal counsel is suggested for these types of actions.
Evictions
An act or process of legally dispossessing a person of land or rental property.
Small Claims
An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims action may be filed with the Sparks Justice Court if one of the
following applies to the defendant:
1. They reside within the boundaries of the Sparks Township;
2. They are employed within the boundaries of the Sparks Township; and/or,
3. They do business within the boundaries of the Sparks Township.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
LITIGATION HOLD NOTICE FW: Reno eviction noticed for Sparks Justice Court
From: Zach Coughlin(zachcoughlin@hotmail.com)
Sent: Fri 9/21/12 2:36 PM
To: stuttle@washoecounty.us; millero@reno.gov; jmachen@washoecounty.us; brownk@reno.gov; renodirect@reno.gov; lstuchell@washoecounty.us; kadlicj@reno.gov; christensend@reno.gov;
mkandaras@da.washoecounty.us; apminfo@acg.com; apminfo@yahoo.com; superior.storage@yahoo.com; 037nor4@acg.com; info@acg-apmi.com; chansen@washoecounty.us; kstancil@washoecounty.us
Download all as zip
Dear Sirs and Madams,

Please accept this as a LITIGATION HOLD NOTICE REQUIRING THE PRODUCTION AND MAINTENANCE OF ALL MATERIALS, RECORDINGS, DOCUMENTATION, OR OTHER MATERIALS IN ANY WAY
RELATED TO ZACHARY BARKER COUGHLIN AND HIS TRIALS AND TRIBULATIONS WITH LOCAL LAW ENFORCEMENT, EMERGENCY SERVICES, ET AL WITHIN THE PAST COUPLE YEARS WITHIN BOTH CIVIL
AND CRIMINAL CASES, MATTERS, AND INCIDENTS AND WITHIN ANY OTHER SETTINGS.

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

To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us; stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com; info@acg-
apmi.com; rjcweb@wasoecounty.us; jboles@callatg.com; apminfo@acg.com
Subject: FW: Reno eviction noticed for Sparks Justice Court
Date: Mon, 2 Jul 2012 17:21:54 -0700
NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on July 29th, 2012"...giving me five days to get my stuff out of
unit 29 (the one the subject of Judge Schroeer's Eviction Order, which was effectively rescinded by their serving a new 5 day unlawful detainer notice....) as well
as units 71 and 45...whicih are two units to which i still have valide lease agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated
they will arrest me for criminal trespass for accessing any units in the complex, including those to which I still have a valid possessory or property interest, in
violation of 42 usc 1983).

why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel" good looks and a much higher paying job than I will ever
have? What up wit that?

Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed up and put "Sparks Justice Court on Greenbrae" as the place
for the tenant to file a Tenan'ts Answer or Affidavit. Doing so will make the RJC Order by Judge Schroeder null and void (Karen Stancil, Chief Civil Clerk at
RJC admits this, but really, the fault lies with NCS and Northwind, not the committed professional at the RJC).
Hotmail Active View 2 attachments (total 1164.6 KB)
coughlin ...pdf
Download (78.3 KB)
combined ...pdf
Download (1086.2 KB)
LITIGATION HOLD NOTICE CONCERNING ANY RECORDS YOU HAVE MADE INVOLVING ME IN ANY
WAY OR ANY DOCUMETNATION FW: Reno eviction noticed for Sparks Justice Court
The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe where they have a valid reason for being or a lawful right to be.
NRS 207.200, RMC 8.10.040.

In
Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
predecessor statute to NRS 40.2516 to mean that the alternative five (5) day notice must be given
6
before the tenants can be dispossed and a lease can be validly terminated. The court stated that this
five (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
ttp://www.constitution.org/ussc/506-056a.htm

U.S. Supreme Court
SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
SEVENTH CIRCUIT
No. 91-6516
Argued October 5, 1992
Decided December 8, 1992
Sent: Wed 10/10/12 12:54 AM
To: kstancil@washoecounty.us; rjcweb@washoecounty.us; millero@reno.gov; weavera@reno.gov; renodirect@reno.gov; jmachen@washoecounty.us
2 attachments
coughlin v northwind 16_TenantsAffidavit_DeclarationOther_PrivateHousing other than nonpayment of rent.pdf (76.3 KB) , combined northwind v coughlin eviction
filings.pdf (1058.4 KB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us; stuttle@washoecounty.us; jamchen@washoecounty.us;
037nor4@acg.com; info@acg-apmi.com; rjcweb@wasoecounty.us; jboles@callatg.com; apminfo@acg.com
Date: Mon, 2 Jul 2012 17:21:54 -0700
unit 29 (the one the subject of Judge Schroeer's Eviction Order, whicLIh was effectively rescinded by their serving a new 5 day unlawful detainer notice....) as
well as units 71 and 45...whicih are two units to which i still have valide lease agreements, ie, I cannot be trespassing for accessing them (the Reno PD has
indicated they will arrest me for criminal trespass for accessing any units in the complex, including those to which I still have a valid possessory or property
interest, in violation of 42 usc 1983).


NRS 207.200, RMC 8.10.040.

In Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
6

U.S. Supreme Court
SEVENTH CIRCUIT
No. 91-6516
While eviction proceedings were pending, Terrace Properties and Margaret Hale forcibly evicted petitioners, the Soldal family, and their mobile home from a
Terrace Properties' mobile home park. At Hale's request, Cook County, Illinois, Sheriff's Department deputies were present at the eviction. Although they knew
that there was no eviction order and that Terrace Properties' actions were illegal, the deputies refused to take Mr. Soldal's complaint for criminal trespass or
otherwise interfere with the eviction. Subsequently, the state judge assigned to the pending eviction proceedings ruled that the eviction had been unauthorized, and
the trailer, badly damaged during the eviction, was returned to the lot. Petitioners brought an action in the Federal District Court under 42 U.S.C. 1983, claiming
that Terrace Properties and Hale had conspired with the deputy sheriffs to unreasonably seize and remove their home in violation of their Fourth and Fourteenth
Amendment rights. The court granted defendants' motion for summary judgment, and the Court of Appeals affirmed. Acknowledging that what had occurred was
a "seizure" in the literal sense of the word, the court reasoned that it was not a seizure as contemplated by the Fourth Amendment because, inter alia, it did not
invade petitioners' privacy.
Held:
The seizure and removal of the trailer home implicated petitioners' Fourth Amendment rights. Pp. 61-72.
(a) A "seizure" of property occurs when "there is some meaningful interference with an individual's possessory interests in that property." United
States v. Jacobsen, 466 U.S. 109, 113 . The language of the Fourth Amendment - which protects people from unreasonable searches and seizures of
"their persons, houses, papers, and effects" - cuts against the novel holding below, and this Court's cases unmistakably hold that the Amendment
protects property even where privacy or liberty is not implicated. See, e.g., ibid.; Katz v. United States, 389 U.S. 347, 350 . This Court's "plain view"
decisions also make untenable the lower court's construction of the Amendment. If the Amendment's boundaries were defined exclusively by rights of
privacy, "plain view" seizures, rather than being scrupulously subjected to Fourth Amendment inquiry, Arizona v. Hicks, 480 U.S. 321, 326 -327,
would not implicate that constitutional provision at all. Contrary to the Court of Appeals' [506 U.S. 56, 57] position, the Amendment protects seizure even
though no search within its meaning has taken place. See, e.g., Jacobsen, supra, at 120-125. Also contrary to that court's view, Graham v. Connor, 490
U.S. 386 , does not require a court, when it finds that a wrong implicates more than one constitutional command, to look at the dominant character of
the challenged conduct to determine under which constitutional standard it should be evaluated. Rather, each constitutional provision is examined in
turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp. 61-71.
(b) The instant decision should not foment a wave of new litigation in the federal courts. Activities such as repossessions or attachments, if they
involve entering a home, intruding on individuals' privacy, or interfering with their liberty, would implicate the Fourth Amendment even on the Court
of Appeals' own terms. And numerous seizures of this type will survive constitutional scrutiny on "reasonableness" grounds. Moreover, it is unlikely
that the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed to seize property in the absence of
objectively reasonable grounds for doing so. Pp. 71-72.
942 F.2d 1073, reversed and remanded.
WHITE, J., delivered the opinion for a unanimous Court.
John L. Stainthorp argued the cause and filed briefs for petitioners.
Kenneth L. Gillis argued the cause for respondents. With him on the brief were Jack O'Malley, Renee G. Goldfarb, and Kenneth T. McCurry. [*]
[ Footnote *] James D. Holzhauer, Timothy S. Bishop, John A. Powell, Steven R. Shapiro, Harvey M. Grossman, and Alan K. Chen filed a brief for the
American Civil Liberties Union et al. as amici curiae urging reversal.
Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad filed a brief for the National League of Cities et al. as amici curiae urging affirmance.
JUSTICE WHITE delivered the opinion of the Court.
I
Edward Soldal and his family resided in their trailer home, which was located on a rented lot in the Willoway Terrace mobile [506 U.S. 56, 58] home park in Elk
Grove, Illinois. In May 1987, Terrace Properties, the owner of the park, and Margaret Hale, its manager, filed an eviction proceeding against the Soldals in an
Illinois state court. Under the Illinois Forcible Entry and Detainer Act, Ill.Rev.Stat., ch. 110, 9-101 et seq. (1991), a tenant cannot be dispossessed absent a
judgment of eviction. The suit was dismissed on June 2, 1987. A few months later, in August 1987, the owner brought a second proceeding of eviction, claiming
nonpayment of rent. The case was set for trial on September 22, 1987.
Rather than await judgment in their favor, Terrace Properties and Hale, contrary to Illinois law, chose to evict the Soldals forcibly two weeks prior to the
scheduled hearing. On September 4, Hale notified the Cook County's Sheriff's Department that she was going to remove the trailer home from the park, and
requested the presence of sheriff deputies to forestall any possible resistance. Later that day, two Terrace Properties employees arrived at the Soldals' home
accompanied by Cook County Deputy Sheriff O'Neil. The employees proceeded to wrench the sewer and water connections off the side of the trailer home,
disconnect the phone, tear off the trailer's canopy and skirting, and hook the home to a tractor. Meanwhile, O'Neil explained to Edward Soldal that "`he was there
to see that [Soldal] didn't interfere with [Willoway's] work.'" Brief for Petitioner 6.
By this time, two more deputy sheriffs had arrived at the scene, and Soldal told them that he wished to file a complaint for criminal trespass. They referred him to
deputy Lieutenant Jones, who was in Hale's office. Jones asked Soldal to wait outside while he remained closeted with Hale and other Terrace Properties
employees for over 20 minutes. After talking to a district attorney and making Soldal wait another half hour, Jones told Soldal that he would not accept a
complaint because "ìt was between the landlord and the tenant ... [and] they were going to go ahead and continue to move [506 U.S. 56, 59] out the trailer.'" Id., at 8.
1 Throughout this period, the deputy sheriffs knew that Terrace Properties did not have an eviction order and that its actions were unlawful. Eventually, and in the
presence of an additional two deputy sheriffs, the Willoway workers pulled the trailer free of its moorings and towed it onto the street. Later, it was hauled to a
neighboring property.
On September 9, the state judge assigned to the pending eviction proceedings ruled that the eviction had been unauthorized, and ordered Terrace Properties to
return the Soldals' home to the lot. The home, however, was badly damaged.
[2]
The Soldals brought this action under 42 U.S.C. 1983, alleging a violation of
their rights under the Fourth and Fourteenth Amendments. They claimed that Terrace Properties and Hale had conspired with Cook County deputy sheriffs to
unreasonably seize and remove the Soldals' trailer home. The District Judge granted defendants' motion for summary judgment on the grounds that the Soldals
had failed to adduce any evidence to support their conspiracy theory and, therefore, the existence of state action necessary under 1983.
[3]

The Court of Appeals for the Seventh Circuit, construing the facts in petitioners' favor, accepted their contention that there was state action. However, it went on
to hold that [506 U.S. 56, 60] the removal of the Soldals' trailer did not constitute a seizure for purposes of the Fourth Amendment or a deprivation of due process for
purposes of the Fourteenth.
On rehearing, a majority of the Seventh Circuit, sitting en banc, reaffirmed the panel decision.
[4]
Acknowledging that what had occurred was a "seizure" in the
literal sense of the word, the court reasoned that, because it was not made in the course of public law enforcement, and because it did not invade the Soldals'
privacy, it was not a seizure as contemplated by the Fourth Amendment. 942 F.2d 1073, 1076 (1991). Interpreting prior cases of this Court, the Seventh Circuit
concluded that, absent interference with privacy or liberty, a "pure deprivation of property" is not cognizable under the Fourth Amendment. Id., at 1078-1079.
Rather, petitioners' property interests were protected only by the Due Process Clauses of the Fifth and Fourteenth Amendments.
[5]

We granted certiorari to consider whether the seizure and removal of the Soldals' trailer home implicated their Fourth Amendment rights, 503 U.S. 918 (1992),
and now reverse.
[6]
[506 U.S. 56, 61]
II
The Fourth Amendment, made applicable to the States by the Fourteenth, Ker v. California, 374 U.S. 23, 30 (1963), provides in pertinent part that the "right of
the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated... ."
A "seizure" of property, we have explained, occurs when "there is some meaningful interference with an individual's possessory interests in that property." United
States v. Jacobsen, 466 U.S. 109, 113 (1984). In addition, we have emphasized that "at the very core" of the Fourth Amendment "stands the right of a man to
retreat into his own home." Silverman v. United States, 365 U.S. 505, 511 (1961). See also Oliver v. United States, 466 U.S. 170, 178 -179 (1984); Wyman v.
James, 400 U.S. 309, 316 (1971); Payton v. New York, 445 U.S. 573, 601 (1980).
As a result of the state action in this case, the Soldals' domicile was not only seized, it literally was carried away, giving new meaning to the term "mobile
home." We fail to see how being unceremoniously dispossessed of one's home in the manner alleged to have occurred here can be viewed as anything but a
seizure invoking the protection of the Fourth Amendment. Whether the Amendment was in fact [506 U.S. 56, 62] violated is, of course, a different question that
requires determining if the seizure was reasonable. That inquiry entails the weighing of various factors, and is not before us.
The Court if Appeals recognized that there had been a seizure, but concluded that it was a seizure only in a "technical" sense, not within the meaning of the
Fourth Amendment. This conclusion followed from a narrow reading of the Amendment, which the court construed to safeguard only privacy and liberty
interests, while leaving unprotected possessory interests where neither privacy nor liberty was at stake. Otherwise, the court said,
"a constitutional provision enacted two centuries ago [would] make every repossession and eviction with police assistance actionable under - of all
things - the Fourth Amendment[, which] would both trivialize the amendment and gratuitously shift a large body of routine commercial litigation from
the state courts to the federal courts. That trivializing, this shift, can be prevented by recognizing the difference between possessory and privacy
interests." 942 F.2d, at 1077.
Because the officers had not entered Soldal's house, rummaged through his possessions, or, in the Court of Appeals' view, interfered with his liberty in the course
of the eviction, the Fourth Amendment offered no protection against the "grave deprivation" of property that had occurred. Ibid.
We do not agree with this interpretation of the Fourth Amendment. The Amendment protects the people from unreasonable searches and seizures of "their
persons, houses, papers, and effects." This language surely cuts against the novel holding below, and our cases unmistakably hold that the Amendment protects
property as well as privacy.
[7]
This much [506 U.S. 56, 63] was made clear in Jacobsen, supra, where we explained that the first Clause of the Fourth Amendment
"protects two types of expectations, one involving "searches," the other "seizures." A "search" occurs when an expectation of privacy that society is
prepared to consider reasonable is infringed. A "seizure" of property occurs where there is some meaningful interference with an individual's
possessory interests in that property." 466 U.S., at 113 (footnote omitted).
See also id., at 120; Horton v. California, 496 U.S. 128, 133 (1990); Arizona v. Hicks, 480 U.S. 321, 328 (1987); Maryland v. Macon, 472 U.S. 463, 469 (1985);
Texas v. Brown, 460 U.S. 730, 747 -748 (1983) (STEVENS, J., concurring in judgment); United States v. Salvucci, 448 U.S. 83, 91 , n. 6 (1980). Thus, having
concluded that chemical testing of powder found in a package did not compromise its owner's privacy, the Court in Jacobsen did not put an end to its inquiry, as
would be required under the view adopted by the Court of Appeals and advocated by respondents. Instead, adhering to the teachings of United States v. Place, 462
U.S. 696 (1983), it went on to determine whether the invasion of the owners' "possessory interests" occasioned by the destruction of the powder was reasonable
under the Fourth Amendment. Jacobsen, supra, at 124-125. In Place, although we found that subjecting luggage to a "dog sniff" did not constitute a search for
Fourth Amendment purposes because it did not compromise any privacy interest, taking custody of Place's suitcase was deemed an unlawful seizure, for it
unreasonably infringed "the suspect's possessory interest in his luggage." 462 U.S., at 708 . 8 Although lacking a privacy component, the property rights in both
instances nonetheless were not [506 U.S. 56, 64] disregarded, but rather were afforded Fourth Amendment protection.
Respondents rely principally on precedents such as Katz v. United States, 389 U.S. 347 (1967), Warden, Maryland Penitentiary v. Hayden, 387 U.S. 294 (1967),
and Cardwell v. Lewis, 417 U.S. 583 (1974), to demonstrate that the Fourth Amendment is only marginally concerned with property rights. But the message of
those cases is that property rights are not the sole measure of Fourth Amendment violations. The Warden opinion thus observed, citing Jones v. United States,
362 U.S. 257 (1960), and Silverman v. United States, 365 U.S. 505 (1961), that the "principal" object of the Amendment is the protection of privacy, rather than
property, and that "this shift in emphasis from property to privacy has come about through a subtle interplay of substantive and procedural reform." 387 U.S., at
304 . There was no suggestion that this shift in emphasis had snuffed out the previously recognized protection for property under the Fourth Amendment. Katz, in
declaring violative of the Fourth Amendment the unwarranted overhearing of a telephone booth conversation, effectively ended any lingering notions that the
protection of privacy depended on trespass into a protected area. In the course of its decision, the Katz Court stated that the Fourth Amendment can neither be
translated into a provision dealing with constitutionally protected areas nor into a general constitutional right to privacy. The Amendment, the Court said, protects
individual privacy against certain kinds of governmental intrusion, "but its protections go further, and often have nothing to do with privacy at all." 389 U.S., at
350 .
As for Cardwell, a plurality of this Court held in that case that the Fourth Amendment did not bar the use in evidence of paint scrapings taken from and tire
treads observed on the defendant's automobile, which had been seized in a parking lot and towed to a police lockup. Gathering this evidence was not deemed to
be a search, for nothing from the [506 U.S. 56, 65] interior of the car and "no personal effects, which the Fourth Amendment traditionally has been deemed to protect"
were searched or seized. 417 U.S., at 591 (opinion of BLACKMUN, J.). No meaningful privacy rights were invaded. But this left the argument, pressed by the
dissent, that the evidence gathered was the product of a warrantless, and hence illegal, seizure of the car from the parking lot where the defendant had left it.
However, the plurality was of the view that, because, under the circumstances of the case, there was probable cause to seize the car as an instrumentality of the
crime, Fourth Amendment precedent permitted the seizure without a warrant. Id., at 593. Thus, both the plurality and dissenting Justices considered the
defendant's auto deserving of Fourth Amendment protection even though privacy interests were not at stake. They differed only in the degree of protection that
the Amendment demanded.
The Court of Appeals appeared to find more specific support for confining the protection of the Fourth Amendment to privacy interests in our decision in Hudson
v. Palmer, 468 U.S. 517 (1984). There, a state prison inmate sued, claiming that prison guards had entered his cell without consent and had seized and destroyed
some of his personal effects. We ruled that an inmate, because of his status, enjoyed neither a right to privacy in his cell nor protection against unreasonable
seizures of his personal effects. Id., at 526-528, and n. 8; id., at 538 (O'CONNOR, J., concurring). Whatever else the case held, it is of limited usefulness outside
the prison context with respect to the coverage of the Fourth Amendment.
We thus are unconvinced that any of the Court's prior cases supports the view that the Fourth Amendment protects against unreasonable seizures of property only
where privacy or liberty is also implicated. What is more, our "plain view" decisions make untenable such a construction of the Amendment. Suppose, for
example, that police officers lawfully enter a house, by either complying with the warrant requirement or satisfying one of its recognized exceptions - [506 U.S. 56,
66] e.g., through a valid consent or a showing of exigent circumstances. If they come across some item in plain view and seize it, no invasion of personal privacy
has occurred. Horton, 496 U.S., at 133 -134; Brown, supra, at 739 (opinion of REHNQUIST, J.). If the boundaries of the Fourth Amendment were defined
exclusively by rights of privacy, "plain view" seizures would not implicate that constitutional provision at all. Yet, far from being automatically upheld, "plain
view" seizures have been scrupulously subjected to Fourth Amendment inquiry. Thus, in the absence of consent or a warrant permitting the seizure of the items in
question, such seizures can be justified only if they meet the probable-cause standard, Arizona v. Hicks, 480 U.S. 321, 326 -327 (1987), 9 and if they are
unaccompanied by unlawful trespass, Horton, 496 U.S., at 136 -137. 10 That is because, the absence of a privacy interest notwithstanding, "[a] seizure of the
article ... would obviously invade the owner's possessory interest." Id., at 134; see also Brown, 460 U.S., at 739 (opinion of REHNQUIST, J.). The plain-view
doctrine "merely reflects an application of the Fourth Amendment's central requirement of reasonableness to the law governing seizures of property." Ibid.;
Coolidge v. New Hampshire, 403 U.S. 443, 468 (1971); id., at 516 (WHITE, J., concurring and dissenting).
The Court of Appeals understandably found it necessary to reconcile its holding with our recognition in the plain-view cases that the Fourth Amendment protects
property as such. In so doing, the court did not distinguish this case on the ground that the seizure of the Soldals' home took place in a [506 U.S. 56, 67] noncriminal
context. Indeed, it acknowledged what is evident from our precedents - that the Amendment's protection applies in the civil context as well. See O'Connor v.
Ortega, 480 U.S. 709 (1987); New Jersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v. Tyler, 436 U.S. 499, 504 -506 (1978); Marshall v. Barlow's,
Inc., 436 U.S. 307, 312 -313 (1978); Camara v. Municipal Court of San Francisco, 387 U.S. 523, 528 (1967). 11
Nor did the Court of Appeals suggest that the Fourth Amendment applied exclusively to law enforcement activities. It observed, for example, that the
Amendment's protection would be triggered "by a search or other entry into the home incident to an eviction or repossession," 942 F.2d, at 1077. 12 Instead, the
court sought to explain why the Fourth Amendment protects against seizures of property in the plain-view context, but not in this case, as follows:
"[S]eizures made in the course of investigations by police or other law enforcement officers are almost always, as in the plain view cases, the
culmination of searches. The police search in order to seize, and it is the search [506 U.S. 56, 68] and ensuing seizure that the Fourth Amendment, by its
reference to "searches and seizures," seeks to regulate. Seizure means one thing when it is the outcome of a search; it may mean something else when
it stands apart from a search or any other investigative activity. The Fourth Amendment may still nominally apply, but, precisely because there is no
invasion of privacy, the usual rules do not apply." Id., at 1079 (emphasis in original).
We have difficulty with this passage. The court seemingly construes the Amendment to protect only against seizures that are the outcome of a search. But our
cases are to the contrary, and hold that seizures of property are subject to Fourth Amendment scrutiny even though no search within the meaning of the
Amendment has taken place. See, e.g., Jacobsen, 466 U.S., at 120 -125; Place, 462 U.S., at 706 -707; Cardwell, 417 U.S., at 588 -589. 13 More generally, an
officer who happens to come across an individual's property in a public area could seize it only if Fourth Amendment standards are satisfied - for example, if the
items are evidence of a crime or contraband. Cf. Payton v. New York, [506 U.S. 56, 69] 445 U.S., at 587 . We are also puzzled by the last sentence of the excerpt,
where the court announces that the "usual rules" of the Fourth Amendment are inapplicable if the seizure is not the result of a search or any other investigative
activity "precisely because there is no invasion of privacy." For the plain-view cases clearly state that, notwithstanding the absence of any interference with
privacy, seizures of effects that are not authorized by a warrant are reasonable only because there is probable cause to associate the property with criminal
activity. The seizure of the weapons in Horton, for example, occurred in the midst of a search, yet we emphasized that it did not "involve any invasion of
privacy." 496 U.S., at 133 . In short, our statement that such seizures must satisfy the Fourth Amendment and will be deemed reasonable only if the item's
incriminating character is "immediately apparent," id., at 136-137, is at odds with the Court of Appeals' approach.
The Court of Appeals' effort is both interesting and creative, but, at bottom, it simply reasserts the earlier thesis that the Fourth Amendment protects privacy, but
not property. We remain unconvinced, and see no justification for departing from our prior cases. In our view, the reason why an officer might enter a house or
effectuate a seizure is wholly irrelevant to the threshold question whether the Amendment applies. What matters is the intrusion on the people's security from
governmental interference. Therefore, the right against unreasonable seizures would be no less transgressed if the seizure of the house was undertaken to collect
evidence, verify compliance with a housing regulation, effect an eviction by the police, or on a whim, for no reason at all. As we have observed on more than one
occasion, it would be "anomalous to say that the individual and his private property are fully protected by the Fourth Amendment only when the individual is
suspected of criminal behavior." Camara 387 U.S., at 530 ; see also O'Connor, 480 U.S., at 715 ; T.L.O., 469 U.S., at 335 . [506 U.S. 56, 70]
The Court of Appeals also stated that, even if, contrary to its previous rulings, "there is some element or tincture of a Fourth Amendment seizure, it cannot carry
the day for the Soldals." 942 F.2d, at 1080. Relying on our decision in Graham v. Connor, 490 U.S. 386 (1989), the court reasoned that it should look at the
"dominant character of the conduct challenged in a section 1983 case [to] determine the constitutional standard under which it is evaluated." 942 F.2d, at 1080.
Believing that the Soldals' claim was more akin to a challenge against the deprivation of property without due process of law than against an unreasonable seizure,
the court concluded that they should not be allowed to bring their suit under the guise of the Fourth Amendment.
But we see no basis for doling out constitutional protections in such fashion. Certain wrongs affect more than a single right, and, accordingly, can implicate more
than one of the Constitution's commands. Where such multiple violations are alleged, we are not in the habit of identifying, as a preliminary matter, the claim's
"dominant" character. Rather, we examine each constitutional provision in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment and
Fourteenth Amendment Due Process Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth Amendment and Fourteenth Amendment Due Process Clause).
Graham is not to the contrary. Its holding was that claims of excessive use of force should be analyzed under the Fourth Amendment's reasonableness standard,
rather than the Fourteenth Amendment's substantive due process test. We were guided by the fact that, in that case, both provisions targeted the same sort of
governmental conduct and, as a result, we chose the more "explicit textual source of constitutional protection" over the "more generalized notion of `substantive
due process.'" 490 U.S., at 394 -395. Surely, Graham does not bar resort in this case to the Fourth Amendment's specific protection for "houses, papers, [506 U.S. 56,
71] and effects," rather than the general protection of property in the Due Process Clause.
III
Respondents are fearful, as was the Court of Appeals, that applying the Fourth Amendment in this context inevitably will carry it into territory unknown and
unforeseen: routine repossessions, negligent actions of public employees that interfere with individuals' right to enjoy their homes, and the like, thereby
federalizing areas of law traditionally the concern of the States. For several reasons, we think the risk is exaggerated. To begin, our decision will have no impact
on activities such as repossessions or attachments if they involve entry into the home, intrusion on individuals' privacy, or interference with their liberty, because
they would implicate the Fourth Amendment even on the Court of Appeals' own terms. This was true of the Tenth Circuit's decision in Specht, with which, as we
previously noted, the Court of Appeals expressed agreement.
More significantly, "reasonableness is still the ultimate standard" under the Fourth Amendment, Camara, supra, at 539, which means that numerous seizures of
this type will survive constitutional scrutiny. As is true in other circumstances, the reasonableness determination will reflect a "careful balancing of governmental
and private interests." T.L.O., supra, at 341. Assuming, for example, that the officers were acting pursuant to a court order, as in Specht v. Jensen, 832 F.2d 1516
(CA10 1987), or Fuentes v. Shevin, 407 U.S. 67 , (1972), and, as often would be the case, a showing of unreasonableness on these facts would be a laborious task
indeed. Cf. Simms v. Slacum, 3 Cranch 300, 301 (1806). Hence, while there is no guarantee against the filing of frivolous suits, had the ejection in this case
properly awaited the state court's judgment, it is quite unlikely that the federal court would have been bothered with a 1983 action alleging a Fourth Amendment
violation. [506 U.S. 56, 72]
Moreover, we doubt that the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed to seize property in the absence of
objectively reasonable grounds for doing so. In short, our reaffirmance of Fourth Amendment principles today should not foment a wave of new litigation in the
federal courts.
IV
The complaint here alleges that respondents, acting under color of state law, dispossessed the Soldals of their trailer home by physically tearing it from its
foundation and towing it to another lot. Taking these allegations as true, this was no "garden variety" landlord-tenant or commercial dispute. The facts alleged
suffice to constitute a "seizure" within the meaning of the Fourth Amendment, for they plainly implicate the interests protected by that provision. The judgment of
the Court of Appeals is, accordingly, reversed, and the case is remanded for further proceedings consistent with this opinion.
So ordered.
Footnotes
[1] Jones' statement was prompted by a district attorney's advice that no criminal charges could be brought because, under Illinois law, a criminal action cannot be
used to determine the right of possession. See Ill.Rev.Stat. ch. 110, 9-101 et seq. (1991); People v. Evans, 163 Ill.App. 3d 561, 114 Ill.Dec. 662, 516 N.E.2d 817
(1st Dist. 1987).
[2] The Soldals ultimately were evicted per court order in December 1987.
[3] Title 42 U.S.C. 1983 provides that:
"Every person who, under color of any statute, ordinance, regulation, custom or usage, of any State ... subjects, or causes to be subjected, any citizen of
the United States ... to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured
in an action at law, suit in equity, or other proper proceeding for redress."
[4] The court reiterated the panel's conclusion that a conspiracy must be assumed on the state of the record and, therefore, that the case must be treated in its
current posture "as if the deputy sheriffs themselves seized the trailer, disconnected it from the utilities, and towed it away." 942 F.2d 1073, 1075 (CA7 1991) (en
banc).
[5] The court noted that, in light of the existence of adequate judicial remedies under state law, a claim for deprivation of property without due process of law was
unlikely to succeed. Id., at 1075-1076. See Parratt v. Taylor, 451 U.S. 527 (1981). In any event, the Soldals did not claim a violation of their procedural rights.
As noted, the Seventh Circuit also held that respondents had not violated the Soldals' substantive due process rights under the Fourteenth Amendment. Petitioners
assert that this was error, but, in view of our disposition of the case, we need not address the question at this time.
[6] Under 42 U.S.C. 1983, the Soldals were required to establish that the respondents, acting under color of state law, deprived them of a constitutional right, in
this instance, their Fourth and Fourteenth Amendment freedom from unreasonable seizures by the State. See Monroe v. Pape, [506 U.S. 56, 61] 365 U.S. 167, 184
(1961). Respondents request that we affirm on the ground that the Court of Appeals erred in holding that there was sufficient state action to support a 1983 action.
The alleged injury to the Soldals, it is urged, was inflicted by private parties for whom the county is not responsible. Although respondents did not cross-petition,
they are entitled to ask us to affirm on that ground if such action would not enlarge the judgment of the Court of Appeals in their favor. The Court of Appeals
found that, because the police prevented Soldal from using reasonable force to protect his home from private action that the officers knew was illegal, there was
sufficient evidence of conspiracy between the private parties and the officers to foreclose summary judgment for respondents. We are not inclined to review that
holding. See Adickes v. S.H. Kress & Co., 398 U.S. 144, 152 -161 (1970).
[7] In holding that the Fourth Amendment's reach extends to property as such, we are mindful that the Amendment does not protect possessory interests in all
kinds of property. See, e.g., Oliver v. United States, 466 U.S. 170, 176 -177 (1984). This case, however, concerns a house, which the Amendment's language
explicitly includes, as it does a person's effects.
[8] Place also found that to detain luggage for 90 minutes was an unreasonable deprivation of the individual's "liberty interest in proceeding with his itinerary,"
which also is protected by the Fourth Amendment. 462 U.S., at 708 -710.
[9] When "operational necessities" exist, seizures can be justified on less than probable cause. 480 U.S., at 327 . That in no way affects our analysis, for even then
it is clear that the Fourth Amendment applies. Ibid; see also United States v. Place, 462 U.S. 696 , at 703 (1983).
[10] Of course, if the police officers' presence in the home itself entailed a violation of the Fourth Amendment, no amount of probable cause to believe that an
item in plain view constitutes incriminating evidence will justify its seizure. Horton, 496 U.S., at 136 -137.
[11] It is true that Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), cast some doubt on the applicability of the Amendment to
noncriminal encounters such as this. Id., 18 How. at 285. But cases since that time have shed a different light, making clear that Fourth Amendment guarantees
are triggered by governmental searches and seizures "without regard to the use to which [houses, papers, and effects] are applied." Warden, Maryland Penitentiary
v. Hayden, 387 U.S. 294, 301 (1967). Murray's Lessee's broad statement that the Fourth Amendment "has no reference to civil proceedings for the recovery of
debt" arguably only meant that the warrant requirement did not apply, as was suggested in G.M. Leasing Corp. v. United States, 429 U.S. 338, 352 (1977).
Whatever its proper reading, we reaffirm today our basic understanding that the protection against unreasonable searches and seizures fully applies in the civil
context.
[12] This was the view expressed by the Court of Appeals for the Tenth Circuit in Specht v. Jensen, 832 F.2d 1516 (1987), remanded on unrelated grounds, 853
F.2d 805 (1988) (en banc), with which the Seventh Circuit expressly agreed. 942 F.2d, at 1076.
[13] The officers in these cases were engaged in law enforcement, and were looking for something that was found and seized. In this broad sense, the seizures
were the result of "searches," but not in the Fourth Amendment sense. That the Court of Appeals might have been suggesting that the plain-view cases are
explainable because they almost always occur in the course of law enforcement activities receives some support from the penultimate sentence of the quoted
passage, where the court states that the word "seizure" might lose its usual meaning "when it stands apart from a search or any other investigative activity." Id., at
1079 (emphasis added). And, in the following paragraph, it observes that, "[o]utside of the law enforcement area, the Fourth Amendment retains its force as a
protection against searches, because they invade privacy. That is why we decline to confine the amendment to the law enforcement setting." Id., at 1079-1080.
Even if the court meant that seizures of property in the course of law enforcement activities, whether civil or criminal, implicate interests safeguarded by the
Fourth Amendment, but that pure property interests are unprotected in the non-law-enforcement setting, we are not in accord, as indicated in the body of this
opinion. [506 U.S. 56, 73]

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

Date: Tue, 26 Jun 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Date: Tue, 26 Jun 2012 07:58:36 -0700
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful detainer?) for rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the
notice indicates that I must file a Tenant's Answer with the Sparks Justice Court.
Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court has 4 judicial days a week, the deadline for filing a special appearance (to
contest jurisdiction) and or a Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he indicated the WCSO planned to come effectuate an eviction on this date, June 26,
2012. I believe that would be premature, as Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit by noon after the fifth full day (judicial days) and
Fridays in Sparks Justice Court are not full days in that sense, and regardless, Sparks Justice Court, I believe, is not the appropriate forum where, as here, the situs is located in Reno
(Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
Civil
Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive damages, an action to obtain possession of property, a writ of restitution, or other
like actions, legal counsel is suggested for these types of actions.
my car was searched incident to a routine traffic citation by Officer Weaver, who threatened to do it again last
week
Evictions
Small Claims
An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims action may be filed with the Sparks Justice Court if one of the following
applies to the defendant:
Sent: Mon 10/01/12 4:45 AM
To: hsotelo@tmcc.edu; kadlicj@reno.gov; sooudib@reno.gov; coplogicrpd@reno.gov; renodirect@reno.gov
Dear City of Reno City Attorney's Office and Reno Police Department,

Search incident to routine traffic citation. A routine
traffic citation may not be used as the basis for the
search of an entire vehicle incident to arrest.
Knowles
v. Iowa
, 525 U.S. 113, 114 (1998) (stop of motorist for
speeding did not authorize a search of the vehicle
incident to arrest even though state law authorized law
enforcement officer to place suspect under arrest for
suspected violation of any traffic or motor vehicle
equipment law).

Any argument that the arrest was for "disturbing the peace" is defeated by the fact that, one, that charge was dropped (but not before Coughlin spent 20 days in
jail on it sustaining massive losses, including financial, associated with his confinement and being prevented from filing legal documents), and also where, the
alleged crime did not occur in the officer's presence.

Please remit $150,000.00 to me within 15 days of your receipt of this litigation demand letter.

LITIGATION HOLD NOTICE UPDATE REGARDING SEPTEMBER 21, 2012 RPD MISCONDUCT AT
SUPERIOR SELF STORAGE, OFFICER WEAVER SARGENT MILLER
Please place a copy of this formal written complaint in Officer Weaver's personnel and emploment file, which will be subpoened someday, no doubt, and will
reveal whether or not you complied with this request.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Sun 9/23/12 4:39 PM
To: hsotelo@tmcc.edu; stuttle@washoecounty.us; rjcweb@wasoecounty.us; renodirect@reno.gov; nvrenopd@coplogic.com; superior.storage@yahoo.com
7 attachments
9 21 11 police report and supplement coughlin Superior Storage LLC.pdf (45.0 KB) , complaint to bar counsel regarding eviction unauthorized practice of law.pdf (97.3
KB) , landlord tenant law manual for police in minnesota.pdf (735.1 KB) , Landlords, Tenants, and Police Civil Liability.pdf (69.8 KB) , Verified Complaint for Illegal
Lockout Against Superior Storage LLC 9 22 12 Coughlin v Superior Storage LLC et al.pdf (1856.5 KB) , failure of court clerk to maintain proper records.pdf (28.8 KB) ,
k8 k. Resignation, suspension, or removal. clerks of court.pdf (50.2 KB)
Dear Reno Direct,
Please updat the attached police report of 9 7 2011 to include the correct spelling of my name: Zach Coughlin, ie, not Cuoghlin, and my correct birth date
9/27/76, rather than the 9/1/77 listed and know that this police report relates to the currently pending criminal matter in RJC 2011-063341. Further, please be
aware that your RPD Officers are constantly harrassing me, as three more showed up yesterday at 9 22 12 during the very limited time I was accorded to remove
my personalty (I was given until 9pm on both Friday and Saturday to do so, however, when I went on Friday a different lock was on the unit, and on Saturday
when I went, Superior Mini Storage's Matt Grant called the police while I was there just shortly after I obtained a confirmation from her regarding my permission
to be there until 9pm. Without even asking me to leave, Matt Grant called the RPD (perhaps the "my own personal cop" she referred to when she indicated she
was calling the police on 9/21/12) and, apparently dispatch agreed to send out Sargent O. Miller, Judge Welch, er, Officer Welch, and another unidenftified office
without even asking, or perhaps without caring after asking, whether Grant had even told me to leave. I left upon being threatened witha criminal trespass
arrest by Sargent Miller (whom has, along with Ltn. Brown, threatened to do that in the past, even where I had a valid, outstanding lease at Northwinds
Apartments circa June/July 2012, but ultimately, made the decision to have Officer Weaver shove a disturbing the peace complaint and TPO application under
Northwind Apartment's maintenance man, Milan Kreb's nose on July 3rd, 2012 (in RJC RCP2012-000287 incident to the evictions in RJC's 2012-001048, 2012-
001068, and , whereupon I spent 18 days in jail due to Reno City Attorney Jill Drake violating the rules of professional conduct in arguing for a ten fold cash bail
only bail increase, not supportable under Nevada law on the basis of 'for the public health and safety" (the Bench Book of 2008 and 2010 supplements makes
clear that bail is for one reason and one reason only, and that is not it).

No, Henry Sotelo, I did not well know that about the trespass charge being dismissed because the witness did not appear in the matter you are collecting $7K
a month to appear to be representing me and other criminal indigents on, in RMC 12 CR 12420. Please provide me the audio of the hearing/Trial on
September 4th, 2012. Please prepare a Motion to Dismiss based upon the insufficiency of the information pled in the complaint. Officer Weaver came and
harrassed me again on Friday, threatening to charge me with "failure to secure a load" again and then seeking to influence a private person to file another
specious criminal complaint against me, and at this point you are becoming complicit in his misconduct, I would imagine, in some people's eyes given you
repeated failure to do any advocacy on my behalf, while continuing to draw a check from the same place as Weaver and Sargent O. Miller

You need to file a Motion To Show Cause against the City of Reno for even pleading the criminal trespass complaint, but it is useful that you have admitted in
writing that they only dismissed for the witness failing to appear, please seek that have that witness held in contempt if permissible (i spent 20 days in jail,
was evicted, missed court deadliens while in jail costing me over $40,000 because denied by jail staff ability to file document and they would not transport me
to my eviction hearing on July 5th, 2011 in REV2012-001048). It was completely inappropriate where I still had leases there, so much so that EVEN the
RPD wouldn't make an arrest for it.

I do find it interesting that the City of Reno manages to send out a code enforcement officer to pick up a little "citation money" both a Northwinds and at
Superior Storage LLC, which, I guess, some might see as a sort of impermissible token of the landlords gratification for the RPD helping them subvert the lawful
eviction process I was denied.

Further, the Washoe County Detenction Center refused to transport me to my summary eviction proceeding on July 5th, 2012, and I submitted kites with
handwritten Tenant's Answers that apparently were not filed in the RJC, then had a non lawyer appear in court on Northwinds behalf, pass the bar, and make
arguments to the court, all in violation of NRCP 11. Nothing in NRS 40 or NRS 118A lets an "agent of the landlord" do anything beyond post an eviction
notice, much less do as Nevada Court Servcies Jeff Chandler did and draft pleadings (choosing between notices and NRS 40.760 is a technical bit of legal
analysis, and Judge Pearson made Coughlin pay for the malpractice of Chandler and NCS, even where there even so practicing was a criminal law violation, the
unauthorized practice of law.

Sincerley,

Zach Coughlin

Date: Sun, 23 Sep 2012 07:30:05 -0700
Subject: Re: LITIGATION HOLD NOTICE UPDATE REGARDING SEPTEMBER 21, 2012 RPD MISCONDUCT AT SUPERIOR SELF STORAGE, OFFICER WEAVER
SARGENT MILLER
From: hsotelo@tmcc.edu
Zach,

The Trespass charge, as you well know, was dismissed on the last trial date because the witnesses did not appear. I then argued the Motion to Dismiss the Traffic charge. That is
now on hold pending the results of your Reno Justice Court Competency Hearing. Thus that leaves only the Traffic case.

Obviously, we are not in agreement as to how to proceed with your case. The attorney-client relationship has broken down. You are still accusing me of conspiring
against you and you have put me on a "litigation hold". Thus I can no longer represent you adequately.

On Fri, Sep 21, 2012 at 4:33 PM, Zach Coughlin <zachcoughlin@hotmail.com> wrote:
Dear Mr. Sotelo, et al,

LITIGATION HOLD NOTICE REGARDING ALL MATERIALS IN ANY WAY CONNECTED WITH ANYTING CONNECTED WITH ZACHARY BARKER COUGHLIN, ESQ.

What charges are still pending? Is the criminal trespass charge still pending? Was the criminal trespass charge Complaint ever file stamped in
RMC 12 CR 12420? Please copy me on each and everything filed stamped in this case, and all other materials. Additionally, YOU ARE ON
A LITIGATION HOLD NOTICE WITH RESPECT TO ANYTHING AND EVERYTHING YOU HAVE OR HAVE ACCESS TO IN
CONNECTION WITH THIS CASE, OR ANY OTHER MATTER INVOLVING ME IN ANY WAY VIS A VIS THE RMC OR YOUR
EMPLOYER, or, to the extent you are an independent contractor, that which concerns your business partners or associates.

This is a misdemeanor case, one involving a custodial arrest and a search of my vehicle (and Bighorn Towing demanded money they were not
entitled to for my vehicle, and they are all the way over in Sparks, why use them?). You seem to wish to characterize this matter as a traffic
citation, more akin to a parking ticket, however, one does not spend nearly 20 days in jail (during which the WCDC denied me in my attempts
to arrange my affairs and access justice, incident to which I sustained a $40,050 judgment against myself, personally and was prevented from seeking
relief from, so please, WCDC CONSIDER THIS A LITIGATION HOLD NOTICE WITH ALL MATERIALS INCIDENT THERETO AS WELL)
for a parking ticket or administrative citation. This case involves a misdemeanor arrest, face it. You seem to be willing to make the misconduct
of others your problem, which I don't understand. I get it, your are company guy and all, but you are taking it a bit far, no? Next thing you are
going to be getting all Keith Loomis on criminal indigent defendants and smirking at them about how "your job is gone" when some single mother
with a baby is pleading for an OR so she doesn't lose her job over some jaywalking arrest or something ridiculous like that, Loomis refusing to even
argue for an OR release or some similar position. Pull the video of the various times I was brough into video court while in jail from July 3rd
thorugh July 21st, 2012. I was harassed again today by Officer Weaver, whom is really distinguishing himself, along with Sargent O. Miller.
Soldal v. Cook Co. Same RPD who arrested and retaliated against me at Northwinds Apartment between June 5th, 2012 through August
2012, along with Lieutenant Brown and Sargent Dye, threatening me with criminal trespass arrests even where I still had valid leases at Northwinds
Apartments, and therefore, "a lawful right to be there" under NRS 207.200. Pushing some maintenance man into signing a "disturbing the
peace" criminal Complaint (and Officer Weaver was trying to pull this trick again at Superior Self Storage today) does not absolve the City of Reno
or RPD for liability for wrongful arrest (the old, "hey, that guy signed the criminal Complaint, we, the RPD, just made the arrest based on it" thing
won't work, ask Wheeler v. Coss). But, the RPD must have thought I was on to something because, at Northwinds, it failed to follow through on
Sargent Miller and Lt. Brown's promises to arrest me for criminal trespass. Enter Officer Weaver with his phenomenal display of judgement and
"concern" for Coughlin, and the July 3rd, 2012 arrest for "disturbing the peace", "proof of insurance" (despite Sargent Dye and Officer Weaver
admitting that Coughlin produced proof of valid, current insurance via a pdf displayed on a 5 inch smartphone screen prior to the custodial arrest),
and "failure to secure a load on a truck", which Officer Weaver was again today threatening to arrest Coughlin, in full view of the 5 other RPD
personel who were, yet again, seeking to form some sort of landlord eviction consulting service providing the unauthorized practice of law.
That's a pretty competitive field, just ask Nevada Court Services.

Please consider Wheeler v. Coss.

Please accept this writing as an update to my recent LITIGATION HOLD NOTICES to include the RPD misconduct this morning at Superior Self
Storage, again in violation of Soldal v. Cook Co., http://en.wikipedia.org/wiki/Soldal_v._Cook_County

Sincerely,

Zach Coughlin
PO BOX 3961
I NEED ACCESS TO MY PROPERTY TODAY, IMMEDIATELY, OTHERWISE I WILL INCUR VAST
CONSEQUENTIAL DAMAGES
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Nevada Court Services in backyard visible at 20 second mark SAM_0028.avi
.
--
Henry Sotelo, Esq.Coordinator/InstructorParalegal/Law ProgramTruckee Meadows Community CollegeRed Mountain Building, 207P7000 Dandini Blvd.Reno,
NV 89512
Sent: Sun 9/23/12 1:56 PM
To: superior.storage@yahoo.com; derek@tahoequarterly.com; doug@tahoequarterly.com; millero@reno.gov; renodirect@reno.gov; coplogicrpd@reno.gov; kadlicj@reno.gov;
weavera@reno.gov; brownk@reno.gov
5 attachments
9 21 11 police report and supplement coughlin Superior Storage LLC.pdf (45.0 KB) , complaint to bar counsel regarding eviction unauthorized practice of law.pdf (97.3
KB) , landlord tenant law manual for police in minnesota.pdf (735.1 KB) , Landlords, Tenants, and Police Civil Liability.pdf (69.8 KB) , Verified Complaint for Illegal
Lockout Against Superior Storage LLC 9 22 12 Coughlin v Superior Storage LLC et al.pdf (1856.5 KB)

Dear Superior Storage LLC a/k/a Superior Mini Storage, and Reno Direct

Please respond via email, in writing, providing me your "permission" to be on the property, today, immediately (although I maintain I have a lawful right to be
there) and assurances that you will not seek to have me arrested for criminal trespass. Yesterday you

I do find it interesting that the City of Reno manages to send out a code enforcement officer to pick up a little "citation money" both a Northwinds and at
Superior Storage LLC, which, I guess, some might see as a sort of impermissible token of the landlords gratification for the RPD helping them subvert the lawful
eviction process I was denied.

Dear Reno Direct,
Please updat the attached police report of 9 7 2011 to include the correct spelling of my name: Zach Coughlin, ie, not Cuoghlin, and my correct birth date
9/27/76, rather than the 9/1/77 listed and know that this police report relates to the currently pending criminal matter in RJC 2011-063341. Further, please be
aware that your RPD Officers are constantly harrassing me, as three more showed up yesterday at 9 22 12 during the very limited time I was accorded to remove
FW: Soldal v. Cook County FW: Verified Complaint for Illegal Lockout attached
my personalty (I was given until 9pm on both Friday and Saturday to do so, however, when I went on Friday a different lock was on the unit, and on Saturday
when I went, Superior Mini Storage's Matt Grant called the police while I was there just shortly after I obtained a confirmation from her regarding my permission
to be there until 9pm. Without even asking me to leave, Matt Grant called the RPD (perhaps the "my own personal cop" she referred to when she indicated she
was calling the police on 9/21/12) and, apparently dispatch agreed to send out Sargent O. Miller, Judge Welch, er, Officer Welch, and another unidenftified office
without even asking, or perhaps without caring after asking, whether Grant had even told me to leave. I left upon being threatened witha criminal trespass arrest
by Sargent Miller (whom has, along with Ltn. Brown, threatened to do that in the past, even where I had a valid, outstanding lease at Northwinds Apartments
circa June/July 2012, but ultimately, made the decision to have Officer Weaver shove a disturbing the peace complaint and TPO application under Northwind
Apartment's maintenance man, Milan Kreb's nose on July 3rd, 2012 (in RJC RCP2012-000287 incident to the evictions in RJC's 2012-001048, 2012-001068, and
, whereupon I spent 18 days in jail due to Reno City Attorney Jill Drake violating the rules of professional conduct in arguing for a ten fold cash bail only bail
increase, not supportable under Nevada law on the basis of 'for the public health and safety" (the Bench Book of 2008 and 2010 supplements makes clear that bail
is for one reason and one reason only, and that is not it).

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Phone and Fax 949 667 7402
Sent: Sat 9/22/12 6:27 PM
To: renodirect@reno.gov; aclunv@aclunv.org
1 attachment
Verified Complaint for Illegal Lockout Against Superior Storage LLC 9 22 12 Coughlin v Superior Storage LLC et al.pdf (1856.5 KB)
Landlord get the sub-lessee out even faster than the already warp speed summary eviction process in Nevada, City of Rneo (like in Northwinds Apartments matter) gets another code
violation revenue event...Coughlin gets to move his stuff yet again, and the RPD get to continue in their long running game of kick the can with the (suspended) attorney. Almost
everyone wins....
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: millero@reno.gov; weavera@reno.gov; brownk@reno.gov; superior.storage@yahoo.com; kadlicj@reno.gov; christensend@reno.gov; aclunv@aclunv.org
Subject: Soldal v. Cook County FW: Verified Complaint for Illegal Lockout attached
Date: Sat, 22 Sep 2012 16:17:21 -0700
Dear Lieutenant Brown, Sargent Miller, and Officer Dye,

Sargent Miller, along with Officer Welch and, I believe two other officers whose names I did not get today, told me I must leave the premises at 7750 W. 4th St.,
Reno 89523, Superior Mini Storage or face a criminal trespass arrest. Yesterday, I reported to the Reno Police Department the trespass to my chattels and
invasion of privacy against my personalty by Matt Grant of Superior, yet the RPD took no action. The RPD has consistently "played favorites" rather than
enforce the law where it is within its jurisdiction to do so, and has further consistently acted outside of its jurisdiction, in violation of Soldal v. Cook County and
42 USC Sec. 1983 in refusing to enforce the law where doing so is within its jurisdiction and where, arguably, the RPD is required to, all incident to a retaliatory
animus against me while asserting pretexutal basis for violating my rights (18 days in jail custodial arrest for "failure to secure a load to one's truck), arguing for a
bail increase of a factor of ten (cash required for bail-wise) based, in part upon "failure to show proof of insurance" where Officer Weaver and Sargent Dye admit
to having seen proof of my car insurance, though failing to accept it as it was on a pdf on my smartphone's screen versus a printed card. There is nothing in
the statutes or law that allows for such a refusal to ackowledge my form of proof of insurance.
In some respects I actually could, at least partially, believe these RPD personnel believe they are doing their job, however, I think that, with some training and
education, the RPD may be made more well aware of the enormous social cost attendant to wrongful evictions and of what a bullying, menacing, malevolent role
the RPD is currently taking in overextending landlord rights in a state where the law, and how it is applied in our Justice Courts, is already amongst the 5-10
most pro landlord states in our country. So, if you are telling yourself you are the "good guys" here, I must disagree. Consider the cost to Matt Grant and
Superior by being forced to pursue a civil remedy (and the attached Verified Complaint for Illegal Lockout is provided to set forth the factual and legal basis
for asserting that I would not be in committing criminal trespass under either RMC 8.10.040 or NRS 207.200 given I have a lawful right to go to those two units
as Superior, regardless of whether the tenant has actually abandonded his lease (I have not been provided anything in writing to suggest that, Superior refuses to
provide me a copy of the Lease with Swanson that allegedly makes explicilty clear, and where such a term is not unenforceable under Nevada law, the
proposition that there is an absolute bar to subleasing or that the landlord's refusal to allow one is not conditioned upon a reasonability standard, or that Officer
Welch is able to take money out of some poor Judge's mouth by holding a Summary Eviction Hearing in the Superior Mini Storage Office, ex parte, outside my
presence, and then to render his Lockout Order to me in the parking lot minutes later with an addedendum that I am to "remove all" my "property today or be
arrested for criminal trespass for leaving any of your property at Superior whether or not you personally set foot on the property or not". I would think maybe
that is more of a nuisance crime to dump a bunch of property somewhere without any lawful right, maybe littering, but I had not thought of it as trespass, though
I admit it is a creative application of the law. I just wish the RPD would use some of that creativity and initiative in a way that might benefit Nevada's
Tenants, whom are not, I assure you, a bunch of degenerate mental case squatters. The are people just like you and me and the consequences of their not being
afforded the notice and due process accorded them under law is far greater to them and our community in general than would result from making poor Matt Grant
and Superior Storage actually pursue the excruciatingly long civil remedy process of, I don't know, posting a Notice of Breach Notice ot the Tenant's/Sub-
Lessee's door, waiting three days, going to a hearing if the Tenant's even bothers to contest it, winning at the hearing in probably 90% of cases even though the
actual standard only requires the Tenant show that the landlord has not proven its case is a "slam dunk", and then having the Sheriff perform a lockout. Its a
cost of doing business. We all have them, and Superior is no different. These costs are important, as they encourage parties to settle and behave
reasonably. Throwing tenant's in jail for 20 days based upon Distrubing the peace complaints Officer Weaver manufactures for them is not permissible.
Its approaching an attorney entering a pact with his friend to rig a slip and fall scenario. Its no bueno.

Please let me know as soon as possible, via email, in writing as to whether, and if yes, when I may return to the Superior premises absent the impermissible threat
of criminal prosecution, made under color of law by the Reno PD.

Incidentally, I believe such matters are within the jurisdiction of the Sheriff under NRS 108.475 and NRS 40.470, though it seams that the RPD may be correct
here to suggest it is trespassing if one has not colorable right to be there, and therefore its not a

Please consider why it is that Matt Grant and Superior had four more RPD Sargent and Officers utilize valuable City resources today. Grant admits she called
the police because she believe Coughlin was taking photographs and or video of the contents of a different tenant or twos units, ones that had the doors wide open
exposing the contents to anyone walking by. Grant clearly wished to avoid any evidence being gathered to suggest that other tenant's are doing just the sort of
thing that she alleged Coughlin is doing and which she asserts presented such and utter "emergency" as to allow her to enter Coughlin's rentals unnoticed, and
despite Coughlin express indication that he was not granting her access to do so, and where she further violated trespass laws, Coughlin's privacy rights, and
perhaps some other laws related to touching and looking through one's personalty and videotaping it, within one's rental where no permission was provided.
Grant can assert Coughlin lacked permission to, allegedly, video tape the open to the public contents of another tenant's unit, however, Coughlin did not walk
into the unit, refuse to leave or case doing so after being told not to, then proceed to open box and video tape the contents. To the extent the RPD sanctiosn
such conduct while also threatening Coughlin with criminal trespass custodial arrest where Coughlin has provided evidence of and asserted a colro claim that he is
lawfully entitled to be there at Superior, then the RPD violates Soldal v. Cook County, in my opinion. But, I could be wrong.

Sincerely,

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

To: superior.storage@yahoo.com; derek@tahoequarterly.com
Subject: Verified Complaint for Illegal Lockout attached
Date: Sat, 22 Sep 2012 12:08:10 -0700
Please let me know your attorney's name if you have one and provide him my contact information.

LITIGATION HOLD NOTICE: YOU ARE REQUIRED AND PLACE ON NOTICE TO MAINTAIN THE LEASE AGREEMENT BETWEEN SUPERIOR STORAGE LLC AND
DEREK SWANSON, DOUG SWANSON OR OR TAHOE QUARTERLY AND ANYTHING RELATED TO THE LEASE AGREEMENT BETWEEN DEREK SWANSON,
TAHOE QUARTERLY AND OR ZACH COUGHLIN

Soldal v. Cook County FW: Verified Complaint for Illegal Lockout attached
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Sat 9/22/12 4:17 PM
To: millero@reno.gov; weavera@reno.gov; brownk@reno.gov; superior.storage@yahoo.com; kadlicj@reno.gov; christensend@reno.gov; aclunv@aclunv.org
1 attachment
Verified Complaint for Illegal Lockout Against Superior Storage LLC 9 22 12 Coughlin v Superior Storage LLC et al.pdf (1856.5 KB)
Dear Lieutenant Brown, Sargent Miller, and Officer Dye,

Sargent Miller, along with Officer Welch and, I believe two other officers whose names I did not get today, told me I must leave the premises at 7750 W. 4th St.,
Reno 89523, Superior Mini Storage or face a criminal trespass arrest. Yesterday, I reported to the Reno Police Department the trespass to my chattels and
invasion of privacy against my personalty by Matt Grant of Superior, yet the RPD took no action. The RPD has consistently "played favorites" rather than
enforce the law where it is within its jurisdiction to do so, and has further consistently acted outside of its jurisdiction, in violation of Soldal v. Cook County and
42 USC Sec. 1983 in refusing to enforce the law where doing so is within its jurisdiction and where, arguably, the RPD is required to, all incident to a retaliatory
animus against me while asserting pretexutal basis for violating my rights (18 days in jail custodial arrest for "failure to secure a load to one's truck), arguing for a
bail increase of a factor of ten (cash required for bail-wise) based, in part upon "failure to show proof of insurance" where Officer Weaver and Sargent Dye admit
to having seen proof of my car insurance, though failing to accept it as it was on a pdf on my smartphone's screen versus a printed card. There is nothing in
the statutes or law that allows for such a refusal to ackowledge my form of proof of insurance.
In some respects I actually could, at least partially, believe these RPD personnel believe they are doing their job, however, I think that, with some training and
education, the RPD may be made more well aware of the enormous social cost attendant to wrongful evictions and of what a bullying, menacing, malevolent role
the RPD is currently taking in overextending landlord rights in a state where the law, and how it is applied in our Justice Courts, is already amongst the 5-10
most pro landlord states in our country. So, if you are telling yourself you are the "good guys" here, I must disagree. Consider the cost to Matt Grant and
Superior by being forced to pursue a civil remedy (and the attached Verified Complaint for Illegal Lockout is provided to set forth the factual and legal basis
for asserting that I would not be in committing criminal trespass under either RMC 8.10.040 or NRS 207.200 given I have a lawful right to go to those two units
as Superior, regardless of whether the tenant has actually abandonded his lease (I have not been provided anything in writing to suggest that, Superior refuses to
provide me a copy of the Lease with Swanson that allegedly makes explicilty clear, and where such a term is not unenforceable under Nevada law, the
proposition that there is an absolute bar to subleasing or that the landlord's refusal to allow one is not conditioned upon a reasonability standard, or that Officer
Welch is able to take money out of some poor Judge's mouth by holding a Summary Eviction Hearing in the Superior Mini Storage Office, ex parte, outside my
presence, and then to render his Lockout Order to me in the parking lot minutes later with an addedendum that I am to "remove all" my "property today or be
arrested for criminal trespass for leaving any of your property at Superior whether or not you personally set foot on the property or not". I would think maybe
that is more of a nuisance crime to dump a bunch of property somewhere without any lawful right, maybe littering, but I had not thought of it as trespass, though
I admit it is a creative application of the law. I just wish the RPD would use some of that creativity and initiative in a way that might benefit Nevada's
Tenants, whom are not, I assure you, a bunch of degenerate mental case squatters. The are people just like you and me and the consequences of their not being
afforded the notice and due process accorded them under law is far greater to them and our community in general than would result from making poor Matt Grant
and Superior Storage actually pursue the excruciatingly long civil remedy process of, I don't know, posting a Notice of Breach Notice ot the Tenant's/Sub-
Lessee's door, waiting three days, going to a hearing if the Tenant's even bothers to contest it, winning at the hearing in probably 90% of cases even though the
actual standard only requires the Tenant show that the landlord has not proven its case is a "slam dunk", and then having the Sheriff perform a lockout. Its a
cost of doing business. We all have them, and Superior is no different. These costs are important, as they encourage parties to settle and behave
reasonably. Throwing tenant's in jail for 20 days based upon Distrubing the peace complaints Officer Weaver manufactures for them is not permissible.
Its approaching an attorney entering a pact with his friend to rig a slip and fall scenario. Its no bueno.

Please let me know as soon as possible, via email, in writing as to whether, and if yes, when I may return to the Superior premises absent the impermissible threat
of criminal prosecution, made under color of law by the Reno PD.

Incidentally, I believe such matters are within the jurisdiction of the Sheriff under NRS 108.475 and NRS 40.470, though it seams that the RPD may be correct
here to suggest it is trespassing if one has not colorable right to be there, and therefore its not a

Please consider why it is that Matt Grant and Superior had four more RPD Sargent and Officers utilize valuable City resources today. Grant admits she called
the police because she believe Coughlin was taking photographs and or video of the contents of a different tenant or twos units, ones that had the doors wide open
exposing the contents to anyone walking by. Grant clearly wished to avoid any evidence being gathered to suggest that other tenant's are doing just the sort of
thing that she alleged Coughlin is doing and which she asserts presented such and utter "emergency" as to allow her to enter Coughlin's rentals unnoticed, and
despite Coughlin express indication that he was not granting her access to do so, and where she further violated trespass laws, Coughlin's privacy rights, and
perhaps some other laws related to touching and looking through one's personalty and videotaping it, within one's rental where no permission was provided.
Grant can assert Coughlin lacked permission to, allegedly, video tape the open to the public contents of another tenant's unit, however, Coughlin did not walk
into the unit, refuse to leave or case doing so after being told not to, then proceed to open box and video tape the contents. To the extent the RPD sanctiosn
such conduct while also threatening Coughlin with criminal trespass custodial arrest where Coughlin has provided evidence of and asserted a colro claim that he is
lawfully entitled to be there at Superior, then the RPD violates Soldal v. Cook County, in my opinion. But, I could be wrong.

Sincerely,

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

To: superior.storage@yahoo.com; derek@tahoequarterly.com
Subject: Verified Complaint for Illegal Lockout attached
LITIGATION HOLD NOTICE UPDATE REGARDING SEPTEMBER 21, 2012 RPD MISCONDUCT AT
SUPERIOR SELF STORAGE, OFFICER WEAVER SARGENT MILLER
Date: Sat, 22 Sep 2012 12:08:10 -0700
Please let me know your attorney's name if you have one and provide him my contact information.

LITIGATION HOLD NOTICE: YOU ARE REQUIRED AND PLACE ON NOTICE TO MAINTAIN THE LEASE AGREEMENT BETWEEN SUPERIOR STORAGE LLC AND
DEREK SWANSON, DOUG SWANSON OR OR TAHOE QUARTERLY AND ANYTHING RELATED TO THE LEASE AGREEMENT BETWEEN DEREK SWANSON,
TAHOE QUARTERLY AND OR ZACH COUGHLIN

Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Fri 9/21/12 4:33 PM
To: hsotelo@tmcc.edu; kadlicj@reno.gov; sooudib@reno.gov; renodirect@reno.gov; lstuchell@washoecounty.us; pkelly@washoecounty.us; brownk@reno.gov
Dear Mr. Sotelo, et al,

LITIGATION HOLD NOTICE REGARDING ALL MATERIALS IN ANY WAY CONNECTED WITH ANYTING CONNECTED WITH ZACHARY BARKER COUGHLIN, ESQ.

What charges are still pending? Is the criminal trespass charge still pending? Was the criminal trespass charge Complaint ever file stamped in RMC 12 CR
12420? Please copy me on each and everything filed stamped in this case, and all other materials. Additionally, YOU ARE ON A LITIGATION HOLD
NOTICE WITH RESPECT TO ANYTHING AND EVERYTHING YOU HAVE OR HAVE ACCESS TO IN CONNECTION WITH THIS CASE, OR ANY
OTHER MATTER INVOLVING ME IN ANY WAY VIS A VIS THE RMC OR YOUR EMPLOYER, or, to the extent you are an independent contractor, that
which concerns your business partners or associates.

This is a misdemeanor case, one involving a custodial arrest and a search of my vehicle (and Bighorn Towing demanded money they were not entitled to for my
vehicle, and they are all the way over in Sparks, why use them?). You seem to wish to characterize this matter as a traffic citation, more akin to a parking
ticket, however, one does not spend nearly 20 days in jail (during which the WCDC denied me in my attempts to arrange my affairs and access justice,
incident to which I sustained a $40,050 judgment against myself, personally and was prevented from seeking relief from, so please, WCDC CONSIDER THIS A
LITIGATION HOLD NOTICE WITH ALL MATERIALS INCIDENT THERETO AS WELL) for a parking ticket or administrative citation. This case
LITIGATION HOLD NOTICE
involves a misdemeanor arrest, face it. You seem to be willing to make the misconduct of others your problem, which I don't understand. I get it, your are
company guy and all, but you are taking it a bit far, no? Next thing you are going to be getting all Keith Loomis on criminal indigent defendants and smirking
at them about how "your job is gone" when some single mother with a baby is pleading for an OR so she doesn't lose her job over some jaywalking arrest or
something ridiculous like that, Loomis refusing to even argue for an OR release or some similar position. Pull the video of the various times I was brough
into video court while in jail from July 3rd thorugh July 21st, 2012. I was harassed again today by Officer Weaver, whom is really distinguishing himself,
along with Sargent O. Miller. Soldal v. Cook Co. Same RPD who arrested and retaliated against me at Northwinds Apartment between June 5th,
2012 through August 2012, along with Lieutenant Brown and Sargent Dye, threatening me with criminal trespass arrests even where I still had valid leases at
Northwinds Apartments, and therefore, "a lawful right to be there" under NRS 207.200. Pushing some maintenance man into signing a "disturbing the
peace" criminal Complaint (and Officer Weaver was trying to pull this trick again at Superior Self Storage today) does not absolve the City of Reno or RPD for
liability for wrongful arrest (the old, "hey, that guy signed the criminal Complaint, we, the RPD, just made the arrest based on it" thing won't work, ask Wheeler
v. Coss). But, the RPD must have thought I was on to something because, at Northwinds, it failed to follow through on Sargent Miller and Lt. Brown's
promises to arrest me for criminal trespass. Enter Officer Weaver with his phenomenal display of judgement and "concern" for Coughlin, and the July 3rd,
2012 arrest for "disturbing the peace", "proof of insurance" (despite Sargent Dye and Officer Weaver admitting that Coughlin produced proof of valid, current
insurance via a pdf displayed on a 5 inch smartphone screen prior to the custodial arrest), and "failure to secure a load on a truck", which Officer Weaver was
again today threatening to arrest Coughlin, in full view of the 5 other RPD personel who were, yet again, seeking to form some sort of landlord eviction
consulting service providing the unauthorized practice of law. That's a pretty competitive field, just ask Nevada Court Services.

Please consider Wheeler v. Coss.

Please accept this writing as an update to my recent LITIGATION HOLD NOTICES to include the RPD misconduct this morning at Superior Self Storage, again
in violation of Soldal v. Cook Co., http://en.wikipedia.org/wiki/Soldal_v._Cook_County

Sincerely,

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

Nevada Court Services in backyard visible at 20 second mark SAM_0028.avi
.
Sent: Fri 9/21/12 3:22 PM
To: millero@reno.gov; brownk@reno.gov; renodirect@reno.gov; rjcweb@wasoecounty.us; jgoodnight@washoecounty.us; jmachen@washoecounty.us;
jgomez@washoecounty.us; apminfo@yahoo.com; aclunv@aclunv.org; apminfo@acg.com; 037nor4@acg.com; 037nor2@acg.com; jleslie@washoecounty.us;
zyoung@da.washoecounty.us
14 attachments
filings.pdf (1058.4 KB) , northwind fax 6 4 12 habitability retaliation etc.pdf (45.8 KB) , unlawful detainer warning Northwind for unit 45 june 5th by r wray stamped at
12 54 pm and .pdf (432.4 KB) , northwind proof of service for 29 of june 14 and june 5 r wray notice of unlawful detainer.pdf (1401.6 KB) , supplement to tenants motion
to dismiss northwind in sparks justice court.pdf (98.3 KB) , data-2012-6-29-15-56-59 northwind rpd miller civil criminal matter dance.3gp (325.4 KB) , northwind v
coughjlin combined for rjc judges chamers vacate summary eviction motion affidavit, amended motion and proposed order.pdf (130.9 KB) , IMAG0309 amended notice
for unit 29 on 6 28 12 northwind vitiating earlier eviction order of 6 27 12.jpg (1717.3 KB) , 6 8 12 fax to northwind with page numbers.pdf (50.7 KB) ,
20120605_101513 Northwind manager handy man attacks from golf cart 6 5 12-20120728-105853.mp4 (3.1 MB) , northwind lou cadia milan krebs admitting dwayne
tried to lift door up 6 5 12.mp4 (498.1 KB) , police reports filed by Coughlin regarding Northwind Apartments.htm (32.1 KB) , VIDEO0009 northwind you can't trespsass
me from the whole place pre 7 2 12 probably.mp4 (4.2 MB)

Date: Mon, 2 Jul 2012 17:21:54 -0700


NRS 207.200, RMC 8.10.040.

In
Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
6

U.S. Supreme Court
SEVENTH CIRCUIT
No. 91-6516
Held:
I
[2]
[3]

[4]
[5]

and now reverse.
[6]
[506 U.S. 56, 61]
II
[7]
350 .
III
violation. [506 U.S. 56, 72]
federal courts.
IV
So ordered.
Footnotes
(1st Dist. 1987).
banc).
context.
opinion. [506 U.S. 56, 73]

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

Date: Tue, 26 Jun 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Date: Tue, 26 Jun 2012 07:58:36 -0700
(Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Close
Chris Hansen
Civil
Evictions
Small Claims
Print
Your Online Police Report T12004553 Has Been Submitted
From:
NvRenoPd@coplogic.com
Sent: Fri 6/08/12 4:39 PM
****DO NOT RESPOND TO THIS E-MAIL****
****THIS IS AN UN-MONITORED MAIL BOX****
Your online report has been successfully received and the
tracking number is T12004553.
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 ten 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
From:
Sent: Fri 6/08/12 4:45 PM
Your online report has been successfully received and the
tracking number is T12004554.
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 ten business days.
(No Subject)
Thank you for using our online reporting system and please
contact us with any suggestions you have for improving our
system.
Online Officer
Your Online Police Report 120103420 Has Been Approved
From:
Sent: Mon 6/11/12 4:10 PM
1 attachment
report-120103420-0.pdf (71.4 KB)
Your report has been approved report and the permanent number of the case is
120103420.
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.
Online Officer
From:
Sent: Mon 6/11/12 4:11 PM
1 attachment
report-120103420-1.pdf (70.9 KB)
Your report has been approved supplemental report and the permanent number of the case is
120103420.
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.
Online Officer
Sent: Fri 9/21/12 2:57 PM
To: millero@reno.gov; brownk@reno.gov; kadlicj@reno.gov; sooudib@reno.gov; hsotelo@tmcc.edu
6 attachments
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Date: Fri, 8 Jun 2012 16:41:49 -0700
Sincerely,
Zach Coughlin
Subject: LITIGATION HOLD NOTICE FW: Reno eviction noticed for Spr!" #u"tice Court
Fro$: %c& Cou'&(in )*c&cou'&(in+&ot$i(,co$-
Sent: Fri ./01/10 0:23 45
To: "tutt(e+6"&oecount7,u"8 $i((ero+reno,'ov8 j$c&en+6"&oecount7,u"8 bro6n!+reno,'ov8
renodirect+reno,'ov8 ("tuc&e((+6"&oecount7,u"8 !d(icj+reno,'ov8 c&ri"ten"end+reno,'ov8
$!ndr"+d,6"&oecount7,u"8 p$info+c',co$8 p$info+7&oo,co$8 "uperior,"tor'e+7&oo,co$8
92:nor;+c',co$8 info+c'<p$i,co$8 c&n"en+6"&oecount7,u"8 !"tnci(+6"&oecount7,u"
Out(oo! Active =ie6
0 ttc&$ent" )tot( 113;,3 >?-
cou'&(in v nort&6ind 13@Tennt"Affidvit@Dec(rtionOt&er@4rivteHou"in' ot&er t&n nonp7$ent of
rent,pdfDo6n(od
co$bined nort&6ind v cou'&(in eviction fi(in'",pdfDo6n(od
Do6n(od (( " *ip
Der Sir" nd 5d$"A

4(e"e ccept t&i" " LITIGATION HOLD NOTICE REBCIRING THE 4RODCCTION AND
5AINTENANCE OF ALL 5ATERIALSA RECORDINGSA DOCC5ENTATIONA OR OTHER 5ATERIALS
IN AND WAD RELATED TO %ACHARD ?AR>ER COCGHLIN AND HIS TRIALS AND TRI?CLATIONS
WITH LOCAL LAW ENFORCE5ENTA E5ERGENCD SER=ICESA ET AL WITHIN THE 4AST COC4LE
DEARS WITHIN ?OTH CI=IL AND CRI5INAL CASESA 5ATTERSA AND INCIDENTS AND WITHIN
AND OTHER SETTINGS,

Sincere(7A
%c& Cou'&(in
4O ?OE 2.31
RenoA N= F.G9G
Te( ::G 22F F11F
FH .;. 33: :;90
%c&Cou'&(in+&ot$i(,co$

Fro$: *c&cou'&(in+&ot$i(,co$
To: !bro6n+nvbr,or'8 $i(((err+reno,'ov8 $i((err+reno,'ov8 "tutt(e+6"&oecount7,'ov8
r"i(v+6"&oecount7,u"8 "tutt(e+6"&oecount7,u"8 j$c&en+6"&oecount7,u"8 92:nor;+c',co$8
info+c'<p$i,co$8 rjc6eb+6"oecount7,u"8 jbo(e"+c((t',co$8 p$info+c',co$
Subject: FW: Reno eviction noticed for Spr!" #u"tice Court
Dte: 5onA 0 #u( 0910 1::01:G; <9:99
NOrt&6ind nd Nevd Court Service" "erved nd I$ended G d7 notice of un(6fu( detiner on #u(7 0.t&A
0910I,,,'ivin' $e five d7" to 'et $7 "tuff out of unit 0. )t&e one t&e "ubject of #ud'e Sc&roeerJ" Eviction
OrderA 6&ic& 6" effective(7 re"cinded b7 t&eir "ervin' ne6 G d7 un(6fu( detiner notice,,,,- " 6e(( " unit"
:1 nd ;G,,,6&ici& re t6o unit" to 6&ic& i "ti(( &ve v(ide (e"e 'ree$ent"A ieA I cnnot be tre"p""in' for
cce""in' t&e$ )t&e Reno 4D &" indicted t&e7 6i(( rre"t $e for cri$in( tre"p"" for cce""in' n7 unit" in
1/11
t&e co$p(eHA inc(udin' t&o"e to 6&ic& I "ti(( &ve v(id po""e""or7 or propert7 intere"tA in vio(tion of ;0 u"c
1.F2-,

6&7 doe" Sr'ent 5i((er &ve to 'ive $e &rd ti$eK I"nJt it enou'& for &i$ to &ve &i" IDen*e(I 'ood (oo!"
nd $uc& &i'&er p7in' job t&n I 6i(( ever &veK W&t up 6it t&tK

Nort&6ind nd Nevd Court Service" )6&ic& i" prcticin' eviction (6 6it&out (icen"e- "cre6ed up nd put
ISpr!" #u"tice Court on GreenbreI " t&e p(ce for t&e tennt to fi(e TennJt" An"6er or Affidvit, Doin' "o
6i(( $!e t&e R#C Order b7 #ud'e Sc&roeder nu(( nd void )>ren Stnci(A C&ief Civi( C(er! t R#C d$it" t&i"A
but re((7A t&e fu(t (ie" 6it& NCS nd Nort&6indA not t&e co$$itted profe""ion( t t&e R#C-,
T&e Notice $u"t identif7 t&e Court 6it& juri"diction, NRS ;9,0G2)2-)-, ONe cnnot be tre"p""in' in p(c6e
6&ere t&e7 &ve v(id re"on for bein' or (6fu( ri'&t to be, NRS 09:,099A R5C F,19,9;9,

In
Ai!in" v, Andre6"A .1 Nev, :;3A G;0 4,0d :2; )1.:G-A t&e Supre$e COC(i con"trued t&e
predece""or "ttute to NRS ;9,0G13 to $en t&t t&e (terntive five )G- d7 notice $u"t be 'iven
3
before t&e tennt" cn be di"po""ed nd (e"e cn be v(id(7 ter$inted, T&e court "tted t&t t&i"
five )G- d7 notice reLuire$ent I ,,, neit&er cn be 6ved nor ne'(ected,I .1 Nev, t :;F,
ttp://666,con"titution,or'/u""c/G93<9G3,&t$

C,S, Supre$e Court
SOLDAL v, COO> COCNTDA G93 C,S, G3 )1..0-
G93 C,S, G3 SOLDALA ET CE, v, COO> COCNTDA ILLINOIS ET AL,
CERTIORARI TO THE CNITED STATES COCRT OF A44EALS FOR THE
SE=ENTH CIRCCIT
No, .1<3G13
Ar'ued October GA 1..0
Decided Dece$ber FA 1..0
W&i(e eviction proceedin'" 6ere pendin'A Terrce 4ropertie" nd 5r'ret H(e forcib(7 evicted petitioner"A t&e
So(d( f$i(7A nd t&eir $obi(e &o$e fro$ Terrce 4ropertie"J $obi(e &o$e pr!, At H(eJ" reLue"tA Coo!
Count7A I((inoi"A S&eriffJ" Deprt$ent deputie" 6ere pre"ent t t&e eviction, A(t&ou'& t&e7 !ne6 t&t t&ere 6"
no eviction order nd t&t Terrce 4ropertie"J ction" 6ere i((e'(A t&e deputie" refu"ed to t!e 5r, So(d(J"
co$p(int for cri$in( tre"p"" or ot&er6i"e interfere 6it& t&e eviction, Sub"eLuent(7A t&e "tte jud'e ""i'ned
to t&e pendin' eviction proceedin'" ru(ed t&t t&e eviction &d been unut&ori*edA nd t&e tri(erA bd(7
d$'ed durin' t&e evictionA 6" returned to t&e (ot, 4etitioner" brou'&t n ction in t&e Feder( Di"trict Court
under ;0 C,S,C, 1.F2A c(i$in' t&t Terrce 4ropertie" nd H(e &d con"pired 6it& t&e deput7 "&eriff" to
unre"onb(7 "ei*e nd re$ove t&eir &o$e in vio(tion of t&eir Fourt& nd Fourteent& A$end$ent ri'&t", T&e
court 'rnted defendnt"J $otion for "u$$r7 jud'$entA nd t&e Court of Appe(" ffir$ed, Ac!no6(ed'in'
0/11
t&t 6&t &d occurred 6" I"ei*ureI in t&e (iter( "en"e of t&e 6ordA t&e court re"oned t&t it 6" not
"ei*ure " conte$p(ted b7 t&e Fourt& A$end$ent becu"eA inter (iA it did not invde petitioner"J privc7,
He(d:
T&e "ei*ure nd re$ov( of t&e tri(er &o$e i$p(icted petitioner"J Fourt& A$end$ent ri'&t", 4p, 31<:0,
)- A I"ei*ureI of propert7 occur" 6&en It&ere i" "o$e $enin'fu( interference 6it& n individu(J" po""e""or7
intere"t" in t&t propert7,I Cnited Stte" v, #cob"enA ;33 C,S, 19.A 112 , T&e (n'u'e of t&e Fourt&
A$end$ent < 6&ic& protect" peop(e fro$ unre"onb(e "erc&e" nd "ei*ure" of It&eir per"on"A &ou"e"A pper"A
nd effect"I < cut" 'in"t t&e nove( &o(din' be(o6A nd t&i" CourtJ" c"e" un$i"t!b(7 &o(d t&t t&e
A$end$ent protect" propert7 even 6&ere privc7 or (ibert7 i" not i$p(icted, SeeA e,',A ibid,8 >t* v, Cnited
Stte"A 2F. C,S, 2;:A 2G9 , T&i" CourtJ" Ip(in vie6I deci"ion" ("o $!e untenb(e t&e (o6er courtJ"
con"truction of t&e A$end$ent, If t&e A$end$entJ" boundrie" 6ere defined eHc(u"ive(7 b7 ri'&t" of privc7A
Ip(in vie6I "ei*ure"A rt&er t&n bein' "crupu(ou"(7 "ubjected to Fourt& A$end$ent inLuir7A Ari*on v, Hic!"A
;F9 C,S, 201A 203 <20:A 6ou(d not i$p(icte t&t con"titution( provi"ion t ((, Contrr7 to t&e Court of
Appe("J MG93 C,S, G3A G:N po"itionA t&e A$end$ent protect" "ei*ure even t&ou'& no "erc& 6it&in it" $enin'
&" t!en p(ce, SeeA e,',A #cob"enA "uprA t 109<10G, A("o contrr7 to t&t courtJ" vie6A Gr&$ v, ConnorA
;.9 C,S, 2F3 A doe" not reLuire courtA 6&en it find" t&t 6ron' i$p(icte" $ore t&n one con"titution(
co$$ndA to (oo! t t&e do$innt c&rcter of t&e c&((en'ed conduct to deter$ine under 6&ic& con"titution(
"tndrd it "&ou(d be ev(uted, Rt&erA ec& con"titution( provi"ion i" eH$ined in turn, SeeA e,',A Hud"on v,
4($erA ;3F C,S, G1: , 4p, 31<:1,
)b- T&e in"tnt deci"ion "&ou(d not fo$ent 6ve of ne6 (iti'tion in t&e feder( court", Activitie" "uc& "
repo""e""ion" or ttc&$ent"A if t&e7 invo(ve enterin' &o$eA intrudin' on individu("J privc7A or interferin'
6it& t&eir (ibert7A 6ou(d i$p(icte t&e Fourt& A$end$ent even on t&e Court of Appe("J o6n ter$", And
nu$erou" "ei*ure" of t&i" t7pe 6i(( "urvive con"titution( "crutin7 on Ire"onb(ene""I 'round", 5oreoverA it i"
un(i!e(7 t&t t&e po(ice 6i(( often c&oo"e to furt&er n enterpri"e !no6in' t&t it i" contrr7 to t&e (6A or
proceed to "ei*e propert7 in t&e b"ence of objective(7 re"onb(e 'round" for doin' "o, 4p, :1<:0,
.;0 F,0d 19:2A rever"ed nd re$nded,
WHITEA #,A de(ivered t&e opinion for unni$ou" Court,
#o&n L, Stint&orp r'ued t&e cu"e nd fi(ed brief" for petitioner",
>ennet& L, Gi((i" r'ued t&e cu"e for re"pondent", Wit& &i$ on t&e brief 6ere #c! OJ5((e7A Renee G,
Go(dfrbA nd >ennet& T, 5cCurr7, MON
M Footnote ON #$e" D, Ho(*&uerA Ti$ot&7 S, ?i"&opA #o&n A, 4o6e((A Steven R, S&piroA Hrve7 5,
Gro""$nA nd A(n >, C&en fi(ed brief for t&e A$ericn Civi( Libertie" Cnion et (, " $ici curie ur'in'
rever"(,
Ric&rd RudA Crter G, 4&i((ip"A 5r! D, Hop"onA nd 5r! E, Hddd fi(ed brief for t&e Ntion( Le'ue of
Citie" et (, " $ici curie ur'in' ffir$nce,
#CSTICE WHITE de(ivered t&e opinion of t&e Court,
I
Ed6rd So(d( nd &i" f$i(7 re"ided in t&eir tri(er &o$eA 6&ic& 6" (octed on rented (ot in t&e Wi((o67
Terrce $obi(e MG93 C,S, G3A GFN &o$e pr! in E(! GroveA I((inoi", In 57 1.F:A Terrce 4ropertie"A t&e o6ner
of t&e pr!A nd 5r'ret H(eA it" $n'erA fi(ed n eviction proceedin' 'in"t t&e So(d(" in n I((inoi" "tte
court, Cnder t&e I((inoi" Forcib(e Entr7 nd Detiner ActA I((,Rev,Stt,A c&, 119A P .<191 et "eL, )1..1-A tennt
cnnot be di"po""e""ed b"ent jud'$ent of eviction, T&e "uit 6" di"$i""ed on #une 0A 1.F:, A fe6 $ont&"
(terA in Au'u"t 1.F:A t&e o6ner brou'&t "econd proceedin' of evictionA c(i$in' nonp7$ent of rent, T&e
c"e 6" "et for tri( on Septe$ber 00A 1.F:,
Rt&er t&n 6it jud'$ent in t&eir fvorA Terrce 4ropertie" nd H(eA contrr7 to I((inoi" (6A c&o"e to evict
t&e So(d(" forcib(7 t6o 6ee!" prior to t&e "c&edu(ed &erin', On Septe$ber ;A H(e notified t&e Coo! Count7J"
S&eriffJ" Deprt$ent t&t "&e 6" 'oin' to re$ove t&e tri(er &o$e fro$ t&e pr!A nd reLue"ted t&e pre"ence of
"&eriff deputie" to fore"t(( n7 po""ib(e re"i"tnce, Lter t&t d7A t6o Terrce 4ropertie" e$p(o7ee" rrived t
t&e So(d("J &o$e cco$pnied b7 Coo! Count7 Deput7 S&eriff OJNei(, T&e e$p(o7ee" proceeded to 6renc&
2/11
t&e "e6er nd 6ter connection" off t&e "ide of t&e tri(er &o$eA di"connect t&e p&oneA ter off t&e tri(erJ"
cnop7 nd "!irtin'A nd &oo! t&e &o$e to trctor, 5en6&i(eA OJNei( eHp(ined to Ed6rd So(d( t&t IQ&e
6" t&ere to "ee t&t MSo(d(N didnJt interfere 6it& MWi((o67J"N 6or!,JI ?rief for 4etitioner 3,
?7 t&i" ti$eA t6o $ore deput7 "&eriff" &d rrived t t&e "ceneA nd So(d( to(d t&e$ t&t &e 6i"&ed to fi(e
co$p(int for cri$in( tre"p"", T&e7 referred &i$ to deput7 Lieutennt #one"A 6&o 6" in H(eJ" office, #one"
"!ed So(d( to 6it out"ide 6&i(e &e re$ined c(o"eted 6it& H(e nd ot&er Terrce 4ropertie" e$p(o7ee" for
over 09 $inute", After t(!in' to di"trict ttorne7 nd $!in' So(d( 6it not&er &(f &ourA #one" to(d So(d(
t&t &e 6ou(d not ccept co$p(int becu"e IQit 6" bet6een t&e (nd(ord nd t&e tennt ,,, MndN t&e7 6ere
'oin' to 'o &ed nd continue to $ove MG93 C,S, G3A G.N out t&e tri(er,JI Id,A t F, 1 T&rou'&out t&i" periodA
t&e deput7 "&eriff" !ne6 t&t Terrce 4ropertie" did not &ve n eviction order nd t&t it" ction" 6ere
un(6fu(, Eventu((7A nd in t&e pre"ence of n ddition( t6o deput7 "&eriff"A t&e Wi((o67 6or!er" pu((ed t&e
tri(er free of it" $oorin'" nd to6ed it onto t&e "treet, LterA it 6" &u(ed to nei'&borin' propert7,
On Septe$ber .A t&e "tte jud'e ""i'ned to t&e pendin' eviction proceedin'" ru(ed t&t t&e eviction &d been
unut&ori*edA nd ordered Terrce 4ropertie" to return t&e So(d("J &o$e to t&e (ot, T&e &o$eA &o6everA 6"
bd(7 d$'ed, M0N T&e So(d(" brou'&t t&i" ction under ;0 C,S,C, 1.F2A ((e'in' vio(tion of t&eir ri'&t"
under t&e Fourt& nd Fourteent& A$end$ent", T&e7 c(i$ed t&t Terrce 4ropertie" nd H(e &d con"pired
6it& Coo! Count7 deput7 "&eriff" to unre"onb(7 "ei*e nd re$ove t&e So(d("J tri(er &o$e, T&e Di"trict
#ud'e 'rnted defendnt"J $otion for "u$$r7 jud'$ent on t&e 'round" t&t t&e So(d(" &d fi(ed to dduce
n7 evidence to "upport t&eir con"pirc7 t&eor7 ndA t&ereforeA t&e eHi"tence of "tte ction nece""r7 under
1.F2, M2N
T&e Court of Appe(" for t&e Sevent& CircuitA con"truin' t&e fct" in petitioner"J fvorA ccepted t&eir contention
t&t t&ere 6" "tte ction, Ho6everA it 6ent on to &o(d t&t MG93 C,S, G3A 39N t&e re$ov( of t&e So(d("J tri(er
did not con"titute "ei*ure for purpo"e" of t&e Fourt& A$end$ent or deprivtion of due proce"" for purpo"e"
of t&e Fourteent&,
On re&erin'A $jorit7 of t&e Sevent& CircuitA "ittin' en bncA reffir$ed t&e pne( deci"ion, M;N
Ac!no6(ed'in' t&t 6&t &d occurred 6" I"ei*ureI in t&e (iter( "en"e of t&e 6ordA t&e court re"oned t&tA
becu"e it 6" not $de in t&e cour"e of pub(ic (6 enforce$entA nd becu"e it did not invde t&e So(d("J
privc7A it 6" not "ei*ure " conte$p(ted b7 t&e Fourt& A$end$ent, .;0 F,0d 19:2A 19:3 )1..1-,
Interpretin' prior c"e" of t&i" CourtA t&e Sevent& Circuit conc(uded t&tA b"ent interference 6it& privc7 or
(ibert7A Ipure deprivtion of propert7I i" not co'ni*b(e under t&e Fourt& A$end$ent, Id,A t 19:F<19:.,
Rt&erA petitioner"J propert7 intere"t" 6ere protected on(7 b7 t&e Due 4roce"" C(u"e" of t&e Fift& nd
Fourteent& A$end$ent", MGN
We 'rnted certiorri to con"ider 6&et&er t&e "ei*ure nd re$ov( of t&e So(d("J tri(er &o$e i$p(icted t&eir
Fourt& A$end$ent ri'&t"A G92 C,S, .1F )1..0-A nd no6 rever"e, M3N MG93 C,S, G3A 31N
II
T&e Fourt& A$end$entA $de pp(icb(e to t&e Stte" b7 t&e Fourteent&A >er v, C(iforniA 2:; C,S, 02A 29
)1.32-A provide" in pertinent prt t&t t&e Iri'&t of t&e peop(e to be "ecure in t&eir per"on"A &ou"e"A pper"A nd
effect"A 'in"t unre"onb(e "erc&e" nd "ei*ure"A "&(( not be vio(ted,,, ,I
A I"ei*ureI of propert7A 6e &ve eHp(inedA occur" 6&en It&ere i" "o$e $enin'fu( interference 6it& n
individu(J" po""e""or7 intere"t" in t&t propert7,I Cnited Stte" v, #cob"enA ;33 C,S, 19.A 112 )1.F;-, In
dditionA 6e &ve e$p&"i*ed t&t It t&e ver7 coreI of t&e Fourt& A$end$ent I"tnd" t&e ri'&t of $n to
retret into &i" o6n &o$e,I Si(ver$n v, Cnited Stte"A 23G C,S, G9GA G11 )1.31-, See ("o O(iver v, Cnited
Stte"A ;33 C,S, 1:9A 1:F <1:. )1.F;-8 W7$n v, #$e"A ;99 C,S, 29.A 213 )1.:1-8 47ton v, Ne6 Dor!A ;;G
C,S, G:2A 391 )1.F9-,
A" re"u(t of t&e "tte ction in t&i" c"eA t&e So(d("J do$ici(e 6" not on(7 "ei*edA it (iter((7 6" crried
67A 'ivin' ne6 $enin' to t&e ter$ I$obi(e &o$e,I We fi( to "ee &o6 bein' uncere$oniou"(7 di"po""e""ed
of oneJ" &o$e in t&e $nner ((e'ed to &ve occurred &ere cn be vie6ed " n7t&in' but "ei*ure invo!in' t&e
protection of t&e Fourt& A$end$ent, W&et&er t&e A$end$ent 6" in fct MG93 C,S, G3A 30N vio(ted i"A of
cour"eA different Lue"tion t&t reLuire" deter$inin' if t&e "ei*ure 6" re"onb(e, T&t inLuir7 enti(" t&e
;/11
6ei'&in' of vriou" fctor"A nd i" not before u",
T&e Court if Appe(" reco'ni*ed t&t t&ere &d been "ei*ureA but conc(uded t&t it 6" "ei*ure on(7 in
Itec&nic(I "en"eA not 6it&in t&e $enin' of t&e Fourt& A$end$ent, T&i" conc(u"ion fo((o6ed fro$ nrro6
redin' of t&e A$end$entA 6&ic& t&e court con"trued to "fe'urd on(7 privc7 nd (ibert7 intere"t"A 6&i(e
(evin' unprotected po""e""or7 intere"t" 6&ere neit&er privc7 nor (ibert7 6" t "t!e, Ot&er6i"eA t&e court
"idA
I con"titution( provi"ion encted t6o centurie" 'o M6ou(dN $!e ever7 repo""e""ion nd eviction 6it& po(ice
""i"tnce ctionb(e under < of (( t&in'" < t&e Fourt& A$end$entMA 6&ic&N 6ou(d bot& trivi(i*e t&e
$end$ent nd 'rtuitou"(7 "&ift (r'e bod7 of routine co$$erci( (iti'tion fro$ t&e "tte court" to t&e
feder( court", T&t trivi(i*in'A t&i" "&iftA cn be prevented b7 reco'ni*in' t&e difference bet6een po""e""or7
nd privc7 intere"t",I .;0 F,0dA t 19::,
?ecu"e t&e officer" &d not entered So(d(J" &ou"eA ru$$'ed t&rou'& &i" po""e""ion"A orA in t&e Court of
Appe("J vie6A interfered 6it& &i" (ibert7 in t&e cour"e of t&e evictionA t&e Fourt& A$end$ent offered no
protection 'in"t t&e I'rve deprivtionI of propert7 t&t &d occurred, Ibid,
We do not 'ree 6it& t&i" interprettion of t&e Fourt& A$end$ent, T&e A$end$ent protect" t&e peop(e fro$
unre"onb(e "erc&e" nd "ei*ure" of It&eir per"on"A &ou"e"A pper"A nd effect",I T&i" (n'u'e "ure(7 cut"
'in"t t&e nove( &o(din' be(o6A nd our c"e" un$i"t!b(7 &o(d t&t t&e A$end$ent protect" propert7 " 6e((
" privc7, M:N T&i" $uc& MG93 C,S, G3A 32N 6" $de c(er in #cob"enA "uprA 6&ere 6e eHp(ined t&t t&e fir"t
C(u"e of t&e Fourt& A$end$ent
Iprotect" t6o t7pe" of eHpecttion"A one invo(vin' I"erc&e"AI t&e ot&er I"ei*ure",I A I"erc&I occur" 6&en n
eHpecttion of privc7 t&t "ociet7 i" prepred to con"ider re"onb(e i" infrin'ed, A I"ei*ureI of propert7
occur" 6&ere t&ere i" "o$e $enin'fu( interference 6it& n individu(J" po""e""or7 intere"t" in t&t propert7,I
;33 C,S,A t 112 )footnote o$itted-,
See ("o id,A t 1098 Horton v, C(iforniA ;.3 C,S, 10FA 122 )1..9-8 Ari*on v, Hic!"A ;F9 C,S, 201A 20F
)1.F:-8 5r7(nd v, 5conA ;:0 C,S, ;32A ;3. )1.FG-8 TeH" v, ?ro6nA ;39 C,S, :29A :;: <:;F )1.F2-
)STE=ENSA #,A concurrin' in jud'$ent-8 Cnited Stte" v, S(vucciA ;;F C,S, F2A .1 A n, 3 )1.F9-, T&u"A &vin'
conc(uded t&t c&e$ic( te"tin' of po6der found in pc!'e did not co$pro$i"e it" o6nerJ" privc7A t&e Court
in #cob"en did not put n end to it" inLuir7A " 6ou(d be reLuired under t&e vie6 dopted b7 t&e Court of
Appe(" nd dvocted b7 re"pondent", In"tedA d&erin' to t&e tec&in'" of Cnited Stte" v, 4(ceA ;30 C,S,
3.3 )1.F2-A it 6ent on to deter$ine 6&et&er t&e inv"ion of t&e o6ner"J Ipo""e""or7 intere"t"I occ"ioned b7
t&e de"truction of t&e po6der 6" re"onb(e under t&e Fourt& A$end$ent, #cob"enA "uprA t 10;<10G, In
4(ceA (t&ou'& 6e found t&t "ubjectin' (u'''e to Ido' "niffI did not con"titute "erc& for Fourt&
A$end$ent purpo"e" becu"e it did not co$pro$i"e n7 privc7 intere"tA t!in' cu"tod7 of 4(ceJ" "uitc"e 6"
dee$ed n un(6fu( "ei*ureA for it unre"onb(7 infrin'ed It&e "u"pectJ" po""e""or7 intere"t in &i" (u'''e,I ;30
C,S,A t :9F , F A(t&ou'& (c!in' privc7 co$ponentA t&e propert7 ri'&t" in bot& in"tnce" nonet&e(e"" 6ere
not MG93 C,S, G3A 3;N di"re'rdedA but rt&er 6ere fforded Fourt& A$end$ent protection,
Re"pondent" re(7 princip((7 on precedent" "uc& " >t* v, Cnited Stte"A 2F. C,S, 2;: )1.3:-A WrdenA
5r7(nd 4enitentir7 v, H7denA 2F: C,S, 0.; )1.3:-A nd Crd6e(( v, Le6i"A ;1: C,S, GF2 )1.:;-A to
de$on"trte t&t t&e Fourt& A$end$ent i" on(7 $r'in((7 concerned 6it& propert7 ri'&t", ?ut t&e $e""'e of
t&o"e c"e" i" t&t propert7 ri'&t" re not t&e "o(e $e"ure of Fourt& A$end$ent vio(tion", T&e Wrden
opinion t&u" ob"ervedA citin' #one" v, Cnited Stte"A 230 C,S, 0G: )1.39-A nd Si(ver$n v, Cnited Stte"A 23G
C,S, G9G )1.31-A t&t t&e Iprincip(I object of t&e A$end$ent i" t&e protection of privc7A rt&er t&n propert7A
nd t&t It&i" "&ift in e$p&"i" fro$ propert7 to privc7 &" co$e bout t&rou'& "ubt(e interp(7 of
"ub"tntive nd procedur( refor$,I 2F: C,S,A t 29; , T&ere 6" no "u''e"tion t&t t&i" "&ift in e$p&"i" &d
"nuffed out t&e previou"(7 reco'ni*ed protection for propert7 under t&e Fourt& A$end$ent, >t*A in dec(rin'
vio(tive of t&e Fourt& A$end$ent t&e un6rrnted over&erin' of te(ep&one boot& conver"tionA effective(7
ended n7 (in'erin' notion" t&t t&e protection of privc7 depended on tre"p"" into protected re, In t&e
cour"e of it" deci"ionA t&e >t* Court "tted t&t t&e Fourt& A$end$ent cn neit&er be trn"(ted into
provi"ion de(in' 6it& con"titution((7 protected re" nor into 'ener( con"titution( ri'&t to privc7, T&e
G/11
A$end$entA t&e Court "idA protect" individu( privc7 'in"t certin !ind" of 'overn$ent( intru"ionA Ibut it"
protection" 'o furt&erA nd often &ve not&in' to do 6it& privc7 t ((,I 2F. C,S,A t 2G9 ,
A" for Crd6e((A p(ur(it7 of t&i" Court &e(d in t&t c"e t&t t&e Fourt& A$end$ent did not br t&e u"e in
evidence of pint "crpin'" t!en fro$ nd tire tred" ob"erved on t&e defendntJ" uto$obi(eA 6&ic& &d been
"ei*ed in pr!in' (ot nd to6ed to po(ice (oc!up, Gt&erin' t&i" evidence 6" not dee$ed to be "erc&A for
not&in' fro$ t&e MG93 C,S, G3A 3GN interior of t&e cr nd Ino per"on( effect"A 6&ic& t&e Fourt& A$end$ent
trdition((7 &" been dee$ed to protectI 6ere "erc&ed or "ei*ed, ;1: C,S,A t G.1 )opinion of ?LAC>5CNA
#,-, No $enin'fu( privc7 ri'&t" 6ere invded, ?ut t&i" (eft t&e r'u$entA pre""ed b7 t&e di""entA t&t t&e
evidence 't&ered 6" t&e product of 6rrnt(e""A nd &ence i((e'(A "ei*ure of t&e cr fro$ t&e pr!in' (ot
6&ere t&e defendnt &d (eft it, Ho6everA t&e p(ur(it7 6" of t&e vie6 t&tA becu"eA under t&e circu$"tnce" of
t&e c"eA t&ere 6" probb(e cu"e to "ei*e t&e cr " n in"tru$ent(it7 of t&e cri$eA Fourt& A$end$ent
precedent per$itted t&e "ei*ure 6it&out 6rrnt, Id,A t G.2, T&u"A bot& t&e p(ur(it7 nd di""entin' #u"tice"
con"idered t&e defendntJ" uto de"ervin' of Fourt& A$end$ent protection even t&ou'& privc7 intere"t" 6ere
not t "t!e, T&e7 differed on(7 in t&e de'ree of protection t&t t&e A$end$ent de$nded,
T&e Court of Appe(" ppered to find $ore "pecific "upport for confinin' t&e protection of t&e Fourt&
A$end$ent to privc7 intere"t" in our deci"ion in Hud"on v, 4($erA ;3F C,S, G1: )1.F;-, T&ereA "tte pri"on
in$te "uedA c(i$in' t&t pri"on 'urd" &d entered &i" ce(( 6it&out con"ent nd &d "ei*ed nd de"tro7ed
"o$e of &i" per"on( effect", We ru(ed t&t n in$teA becu"e of &i" "ttu"A enjo7ed neit&er ri'&t to privc7 in
&i" ce(( nor protection 'in"t unre"onb(e "ei*ure" of &i" per"on( effect", Id,A t G03<G0FA nd n, F8 id,A t G2F
)OJCONNORA #,A concurrin'-, W&tever e("e t&e c"e &e(dA it i" of (i$ited u"efu(ne"" out"ide t&e pri"on conteHt
6it& re"pect to t&e cover'e of t&e Fourt& A$end$ent,
We t&u" re unconvinced t&t n7 of t&e CourtJ" prior c"e" "upport" t&e vie6 t&t t&e Fourt& A$end$ent
protect" 'in"t unre"onb(e "ei*ure" of propert7 on(7 6&ere privc7 or (ibert7 i" ("o i$p(icted, W&t i"
$oreA our Ip(in vie6I deci"ion" $!e untenb(e "uc& con"truction of t&e A$end$ent, Suppo"eA for eH$p(eA
t&t po(ice officer" (6fu((7 enter &ou"eA b7 eit&er co$p(7in' 6it& t&e 6rrnt reLuire$ent or "ti"f7in' one
of it" reco'ni*ed eHception" < MG93 C,S, G3A 33N e,',A t&rou'& v(id con"ent or "&o6in' of eHi'ent
circu$"tnce", If t&e7 co$e cro"" "o$e ite$ in p(in vie6 nd "ei*e itA no inv"ion of per"on( privc7 &"
occurred, HortonA ;.3 C,S,A t 122 <12;8 ?ro6nA "uprA t :2. )opinion of REHNBCISTA #,-, If t&e boundrie"
of t&e Fourt& A$end$ent 6ere defined eHc(u"ive(7 b7 ri'&t" of privc7A Ip(in vie6I "ei*ure" 6ou(d not
i$p(icte t&t con"titution( provi"ion t ((, DetA fr fro$ bein' uto$tic((7 up&e(dA Ip(in vie6I "ei*ure"
&ve been "crupu(ou"(7 "ubjected to Fourt& A$end$ent inLuir7, T&u"A in t&e b"ence of con"ent or 6rrnt
per$ittin' t&e "ei*ure of t&e ite$" in Lue"tionA "uc& "ei*ure" cn be ju"tified on(7 if t&e7 $eet t&e probb(e<
cu"e "tndrdA Ari*on v, Hic!"A ;F9 C,S, 201A 203 <20: )1.F:-A . nd if t&e7 re uncco$pnied b7 un(6fu(
tre"p""A HortonA ;.3 C,S,A t 123 <12:, 19 T&t i" becu"eA t&e b"ence of privc7 intere"t not6it&"tndin'A
IMN "ei*ure of t&e rtic(e ,,, 6ou(d obviou"(7 invde t&e o6nerJ" po""e""or7 intere"t,I Id,A t 12;8 "ee ("o
?ro6nA ;39 C,S,A t :2. )opinion of REHNBCISTA #,-, T&e p(in<vie6 doctrine I$ere(7 ref(ect" n pp(iction
of t&e Fourt& A$end$entJ" centr( reLuire$ent of re"onb(ene"" to t&e (6 'overnin' "ei*ure" of propert7,I
Ibid,8 Coo(id'e v, Ne6 H$p"&ireA ;92 C,S, ;;2A ;3F )1.:1-8 id,A t G13 )WHITEA #,A concurrin' nd
di""entin'-,
T&e Court of Appe(" under"tndb(7 found it nece""r7 to reconci(e it" &o(din' 6it& our reco'nition in t&e
p(in<vie6 c"e" t&t t&e Fourt& A$end$ent protect" propert7 " "uc&, In "o doin'A t&e court did not di"tin'ui"&
t&i" c"e on t&e 'round t&t t&e "ei*ure of t&e So(d("J &o$e too! p(ce in MG93 C,S, G3A 3:N noncri$in(
conteHt, IndeedA it c!no6(ed'ed 6&t i" evident fro$ our precedent" < t&t t&e A$end$entJ" protection pp(ie"
in t&e civi( conteHt " 6e((, See OJConnor v, Orte'A ;F9 C,S, :9. )1.F:-8 Ne6 #er"e7 v, T,L,O,A ;3. C,S, 20GA
22; <22G )1.FG-8 5ic&i'n v, T7(erA ;23 C,S, ;..A G9; <G93 )1.:F-8 5r"&(( v, ?r(o6J"A Inc,A ;23 C,S, 29:A
210 <212 )1.:F-8 C$r v, 5unicip( Court of Sn Frnci"coA 2F: C,S, G02A G0F )1.3:-, 11
Nor did t&e Court of Appe(" "u''e"t t&t t&e Fourt& A$end$ent pp(ied eHc(u"ive(7 to (6 enforce$ent
ctivitie", It ob"ervedA for eH$p(eA t&t t&e A$end$entJ" protection 6ou(d be tri''ered Ib7 "erc& or ot&er
entr7 into t&e &o$e incident to n eviction or repo""e""ionAI .;0 F,0dA t 19::, 10 In"tedA t&e court "ou'&t to
3/11
eHp(in 6&7 t&e Fourt& A$end$ent protect" 'in"t "ei*ure" of propert7 in t&e p(in<vie6 conteHtA but not in
t&i" c"eA " fo((o6":
IMSNei*ure" $de in t&e cour"e of inve"ti'tion" b7 po(ice or ot&er (6 enforce$ent officer" re ($o"t (67"A
" in t&e p(in vie6 c"e"A t&e cu($intion of "erc&e", T&e po(ice "erc& in order to "ei*eA nd it i" t&e "erc&
MG93 C,S, G3A 3FN nd en"uin' "ei*ure t&t t&e Fourt& A$end$entA b7 it" reference to I"erc&e" nd "ei*ure"AI
"ee!" to re'u(te, Sei*ure $en" one t&in' 6&en it i" t&e outco$e of "erc&8 it $7 $en "o$et&in' e("e 6&en
it "tnd" prt fro$ "erc& or n7 ot&er inve"ti'tive ctivit7, T&e Fourt& A$end$ent $7 "ti(( no$in((7
pp(7A butA preci"e(7 becu"e t&ere i" no inv"ion of privc7A t&e u"u( ru(e" do not pp(7,I Id,A t 19:.
)e$p&"i" in ori'in(-,
We &ve difficu(t7 6it& t&i" p""'e, T&e court "ee$in'(7 con"true" t&e A$end$ent to protect on(7 'in"t
"ei*ure" t&t re t&e outco$e of "erc&, ?ut our c"e" re to t&e contrr7A nd &o(d t&t "ei*ure" of propert7 re
"ubject to Fourt& A$end$ent "crutin7 even t&ou'& no "erc& 6it&in t&e $enin' of t&e A$end$ent &" t!en
p(ce, SeeA e,',A #cob"enA ;33 C,S,A t 109 <10G8 4(ceA ;30 C,S,A t :93 <:9:8 Crd6e((A ;1: C,S,A t GFF <GF.,
12 5ore 'ener((7A n officer 6&o &ppen" to co$e cro"" n individu(J" propert7 in pub(ic re cou(d "ei*e it
on(7 if Fourt& A$end$ent "tndrd" re "ti"fied < for eH$p(eA if t&e ite$" re evidence of cri$e or
contrbnd, Cf, 47ton v, Ne6 Dor!A MG93 C,S, G3A 3.N ;;G C,S,A t GF: , We re ("o pu**(ed b7 t&e ("t
"entence of t&e eHcerptA 6&ere t&e court nnounce" t&t t&e Iu"u( ru(e"I of t&e Fourt& A$end$ent re
inpp(icb(e if t&e "ei*ure i" not t&e re"u(t of "erc& or n7 ot&er inve"ti'tive ctivit7 Ipreci"e(7 becu"e t&ere
i" no inv"ion of privc7,I For t&e p(in<vie6 c"e" c(er(7 "tte t&tA not6it&"tndin' t&e b"ence of n7
interference 6it& privc7A "ei*ure" of effect" t&t re not ut&ori*ed b7 6rrnt re re"onb(e on(7 becu"e
t&ere i" probb(e cu"e to ""ocite t&e propert7 6it& cri$in( ctivit7, T&e "ei*ure of t&e 6epon" in HortonA
for eH$p(eA occurred in t&e $id"t of "erc&A 7et 6e e$p&"i*ed t&t it did not Iinvo(ve n7 inv"ion of
privc7,I ;.3 C,S,A t 122 , In "&ortA our "tte$ent t&t "uc& "ei*ure" $u"t "ti"f7 t&e Fourt& A$end$ent nd
6i(( be dee$ed re"onb(e on(7 if t&e ite$J" incri$intin' c&rcter i" Ii$$edite(7 pprentAI id,A t 123<12:A
i" t odd" 6it& t&e Court of Appe("J pproc&,
T&e Court of Appe("J effort i" bot& intere"tin' nd cretiveA butA t botto$A it "i$p(7 re""ert" t&e er(ier t&e"i"
t&t t&e Fourt& A$end$ent protect" privc7A but not propert7, We re$in unconvincedA nd "ee no ju"tifiction
for deprtin' fro$ our prior c"e", In our vie6A t&e re"on 6&7 n officer $i'&t enter &ou"e or effectute
"ei*ure i" 6&o((7 irre(evnt to t&e t&re"&o(d Lue"tion 6&et&er t&e A$end$ent pp(ie", W&t $tter" i" t&e
intru"ion on t&e peop(eJ" "ecurit7 fro$ 'overn$ent( interference, T&ereforeA t&e ri'&t 'in"t unre"onb(e
"ei*ure" 6ou(d be no (e"" trn"'re""ed if t&e "ei*ure of t&e &ou"e 6" undert!en to co((ect evidenceA verif7
co$p(ince 6it& &ou"in' re'u(tionA effect n eviction b7 t&e po(iceA or on 6&i$A for no re"on t ((, A" 6e
&ve ob"erved on $ore t&n one occ"ionA it 6ou(d be Ino$(ou" to "7 t&t t&e individu( nd &i" privte
propert7 re fu((7 protected b7 t&e Fourt& A$end$ent on(7 6&en t&e individu( i" "u"pected of cri$in(
be&vior,I C$r 2F: C,S,A t G29 8 "ee ("o OJConnorA ;F9 C,S,A t :1G 8 T,L,O,A ;3. C,S,A t 22G , MG93 C,S,
G3A :9N
T&e Court of Appe(" ("o "tted t&tA even ifA contrr7 to it" previou" ru(in'"A It&ere i" "o$e e(e$ent or tincture
of Fourt& A$end$ent "ei*ureA it cnnot crr7 t&e d7 for t&e So(d(",I .;0 F,0dA t 19F9, Re(7in' on our
deci"ion in Gr&$ v, ConnorA ;.9 C,S, 2F3 )1.F.-A t&e court re"oned t&t it "&ou(d (oo! t t&e Ido$innt
c&rcter of t&e conduct c&((en'ed in "ection 1.F2 c"e MtoN deter$ine t&e con"titution( "tndrd under
6&ic& it i" ev(uted,I .;0 F,0dA t 19F9, ?e(ievin' t&t t&e So(d("J c(i$ 6" $ore !in to c&((en'e 'in"t
t&e deprivtion of propert7 6it&out due proce"" of (6 t&n 'in"t n unre"onb(e "ei*ureA t&e court
conc(uded t&t t&e7 "&ou(d not be ((o6ed to brin' t&eir "uit under t&e 'ui"e of t&e Fourt& A$end$ent,
?ut 6e "ee no b"i" for do(in' out con"titution( protection" in "uc& f"&ion, Certin 6ron'" ffect $ore t&n
"in'(e ri'&tA ndA ccordin'(7A cn i$p(icte $ore t&n one of t&e Con"titutionJ" co$$nd", W&ere "uc&
$u(tip(e vio(tion" re ((e'edA 6e re not in t&e &bit of identif7in'A " pre(i$inr7 $tterA t&e c(i$J"
Ido$inntI c&rcter, Rt&erA 6e eH$ine ec& con"titution( provi"ion in turn, SeeA e,',A Hud"on v, 4($erA
;3F C,S, G1: )1.F;- )Fourt& A$end$ent nd Fourteent& A$end$ent Due 4roce"" C(u"e-8 In'r&$ v,
Wri'&tA ;29 C,S, 3G1 )1.::- )Ei'&t& A$end$ent nd Fourteent& A$end$ent Due 4roce"" C(u"e-, Gr&$ i"
:/11
not to t&e contrr7, It" &o(din' 6" t&t c(i$" of eHce""ive u"e of force "&ou(d be n(7*ed under t&e Fourt&
A$end$entJ" re"onb(ene"" "tndrdA rt&er t&n t&e Fourteent& A$end$entJ" "ub"tntive due proce"" te"t,
We 6ere 'uided b7 t&e fct t&tA in t&t c"eA bot& provi"ion" tr'eted t&e "$e "ort of 'overn$ent( conduct
ndA " re"u(tA 6e c&o"e t&e $ore IeHp(icit teHtu( "ource of con"titution( protectionI over t&e I$ore
'ener(i*ed notion of Q"ub"tntive due proce"",JI ;.9 C,S,A t 2.; <2.G, Sure(7A Gr&$ doe" not br re"ort in
t&i" c"e to t&e Fourt& A$end$entJ" "pecific protection for I&ou"e"A pper"A MG93 C,S, G3A :1N nd effect"AI
rt&er t&n t&e 'ener( protection of propert7 in t&e Due 4roce"" C(u"e,
III
Re"pondent" re ferfu(A " 6" t&e Court of Appe("A t&t pp(7in' t&e Fourt& A$end$ent in t&i" conteHt
inevitb(7 6i(( crr7 it into territor7 un!no6n nd unfore"een: routine repo""e""ion"A ne'(i'ent ction" of pub(ic
e$p(o7ee" t&t interfere 6it& individu("J ri'&t to enjo7 t&eir &o$e"A nd t&e (i!eA t&ereb7 feder(i*in' re" of
(6 trdition((7 t&e concern of t&e Stte", For "ever( re"on"A 6e t&in! t&e ri"! i" eH''erted, To be'inA our
deci"ion 6i(( &ve no i$pct on ctivitie" "uc& " repo""e""ion" or ttc&$ent" if t&e7 invo(ve entr7 into t&e
&o$eA intru"ion on individu("J privc7A or interference 6it& t&eir (ibert7A becu"e t&e7 6ou(d i$p(icte t&e
Fourt& A$end$ent even on t&e Court of Appe("J o6n ter$", T&i" 6" true of t&e Tent& CircuitJ" deci"ion in
Spec&tA 6it& 6&ic&A " 6e previou"(7 notedA t&e Court of Appe(" eHpre""ed 'ree$ent,
5ore "i'nificnt(7A Ire"onb(ene"" i" "ti(( t&e u(ti$te "tndrdI under t&e Fourt& A$end$entA C$rA "uprA
t G2.A 6&ic& $en" t&t nu$erou" "ei*ure" of t&i" t7pe 6i(( "urvive con"titution( "crutin7, A" i" true in ot&er
circu$"tnce"A t&e re"onb(ene"" deter$intion 6i(( ref(ect Icrefu( b(ncin' of 'overn$ent( nd privte
intere"t",I T,L,O,A "uprA t 2;1, A""u$in'A for eH$p(eA t&t t&e officer" 6ere ctin' pur"unt to court orderA
" in Spec&t v, #en"enA F20 F,0d 1G13 )CA19 1.F:-A or Fuente" v, S&evinA ;9: C,S, 3: A )1.:0-A ndA " often
6ou(d be t&e c"eA "&o6in' of unre"onb(ene"" on t&e"e fct" 6ou(d be (boriou" t"! indeed, Cf, Si$$" v,
S(cu$A 2 Crnc& 299A 291 )1F93-, HenceA 6&i(e t&ere i" no 'urntee 'in"t t&e fi(in' of frivo(ou" "uit"A &d
t&e ejection in t&i" c"e proper(7 6ited t&e "tte courtJ" jud'$entA it i" Luite un(i!e(7 t&t t&e feder( court
6ou(d &ve been bot&ered 6it& 1.F2 ction ((e'in' Fourt& A$end$ent vio(tion, MG93 C,S, G3A :0N
5oreoverA 6e doubt t&t t&e po(ice 6i(( often c&oo"e to furt&er n enterpri"e !no6in' t&t it i" contrr7 to t&e
(6A or proceed to "ei*e propert7 in t&e b"ence of objective(7 re"onb(e 'round" for doin' "o, In "&ortA our
reffir$nce of Fourt& A$end$ent princip(e" tod7 "&ou(d not fo$ent 6ve of ne6 (iti'tion in t&e feder(
court",
I=
T&e co$p(int &ere ((e'e" t&t re"pondent"A ctin' under co(or of "tte (6A di"po""e""ed t&e So(d(" of t&eir
tri(er &o$e b7 p&7"ic((7 terin' it fro$ it" foundtion nd to6in' it to not&er (ot, T!in' t&e"e ((e'tion" "
trueA t&i" 6" no I'rden vriet7I (nd(ord<tennt or co$$erci( di"pute, T&e fct" ((e'ed "uffice to con"titute
I"ei*ureI 6it&in t&e $enin' of t&e Fourt& A$end$entA for t&e7 p(in(7 i$p(icte t&e intere"t" protected b7
t&t provi"ion, T&e jud'$ent of t&e Court of Appe(" i"A ccordin'(7A rever"edA nd t&e c"e i" re$nded for
furt&er proceedin'" con"i"tent 6it& t&i" opinion,
So ordered,
Footnote"
M1N #one"J "tte$ent 6" pro$pted b7 di"trict ttorne7J" dvice t&t no cri$in( c&r'e" cou(d be brou'&t
becu"eA under I((inoi" (6A cri$in( ction cnnot be u"ed to deter$ine t&e ri'&t of po""e""ion, See
I((,Rev,Stt, c&, 119A P .<191 et "eL, )1..1-8 4eop(e v, Evn"A 132 I((,App, 2d G31A 11; I((,Dec, 330A G13 N,E,0d
F1: )1"t Di"t, 1.F:-,
M0N T&e So(d(" u(ti$te(7 6ere evicted per court order in Dece$ber 1.F:,
M2N Tit(e ;0 C,S,C, 1.F2 provide" t&t:
IEver7 per"on 6&oA under co(or of n7 "ttuteA ordinnceA re'u(tionA cu"to$ or u"'eA of n7 Stte ,,, "ubject"A
or cu"e" to be "ubjectedA n7 citi*en of t&e Cnited Stte" ,,, to t&e deprivtion of n7 ri'&t"A privi(e'e"A or
i$$unitie" "ecured b7 t&e Con"titution nd (6"A "&(( be (ib(e to t&e prt7 injured in n ction t (6A "uit in
eLuit7A or ot&er proper proceedin' for redre"",I
M;N T&e court reiterted t&e pne(J" conc(u"ion t&t con"pirc7 $u"t be ""u$ed on t&e "tte of t&e record ndA
F/11
t&ereforeA t&t t&e c"e $u"t be treted in it" current po"ture I" if t&e deput7 "&eriff" t&e$"e(ve" "ei*ed t&e
tri(erA di"connected it fro$ t&e uti(itie"A nd to6ed it 67,I .;0 F,0d 19:2A 19:G )CA: 1..1- )en bnc-,
MGN T&e court noted t&tA in (i'&t of t&e eHi"tence of deLute judici( re$edie" under "tte (6A c(i$ for
deprivtion of propert7 6it&out due proce"" of (6 6" un(i!e(7 to "ucceed, Id,A t 19:G<19:3, See 4rrtt v,
T7(orA ;G1 C,S, G0: )1.F1-, In n7 eventA t&e So(d(" did not c(i$ vio(tion of t&eir procedur( ri'&t", A"
notedA t&e Sevent& Circuit ("o &e(d t&t re"pondent" &d not vio(ted t&e So(d("J "ub"tntive due proce"" ri'&t"
under t&e Fourteent& A$end$ent, 4etitioner" ""ert t&t t&i" 6" errorA butA in vie6 of our di"po"ition of t&e
c"eA 6e need not ddre"" t&e Lue"tion t t&i" ti$e,
M3N Cnder ;0 C,S,C, 1.F2A t&e So(d(" 6ere reLuired to e"tb(i"& t&t t&e re"pondent"A ctin' under co(or of
"tte (6A deprived t&e$ of con"titution( ri'&tA in t&i" in"tnceA t&eir Fourt& nd Fourteent& A$end$ent
freedo$ fro$ unre"onb(e "ei*ure" b7 t&e Stte, See 5onroe v, 4peA MG93 C,S, G3A 31N 23G C,S, 13:A 1F;
)1.31-, Re"pondent" reLue"t t&t 6e ffir$ on t&e 'round t&t t&e Court of Appe(" erred in &o(din' t&t t&ere
6" "ufficient "tte ction to "upport 1.F2 ction, T&e ((e'ed injur7 to t&e So(d("A it i" ur'edA 6" inf(icted
b7 privte prtie" for 6&o$ t&e count7 i" not re"pon"ib(e, A(t&ou'& re"pondent" did not cro""<petitionA t&e7 re
entit(ed to "! u" to ffir$ on t&t 'round if "uc& ction 6ou(d not en(r'e t&e jud'$ent of t&e Court of Appe("
in t&eir fvor, T&e Court of Appe(" found t&tA becu"e t&e po(ice prevented So(d( fro$ u"in' re"onb(e force
to protect &i" &o$e fro$ privte ction t&t t&e officer" !ne6 6" i((e'(A t&ere 6" "ufficient evidence of
con"pirc7 bet6een t&e privte prtie" nd t&e officer" to forec(o"e "u$$r7 jud'$ent for re"pondent", We re
not inc(ined to revie6 t&t &o(din', See Adic!e" v, S,H, >re"" R Co,A 2.F C,S, 1;;A 1G0 <131 )1.:9-,
M:N In &o(din' t&t t&e Fourt& A$end$entJ" rec& eHtend" to propert7 " "uc&A 6e re $indfu( t&t t&e
A$end$ent doe" not protect po""e""or7 intere"t" in (( !ind" of propert7, SeeA e,',A O(iver v, Cnited Stte"A ;33
C,S, 1:9A 1:3 <1:: )1.F;-, T&i" c"eA &o6everA concern" &ou"eA 6&ic& t&e A$end$entJ" (n'u'e eHp(icit(7
inc(ude"A " it doe" per"onJ" effect",
MFN 4(ce ("o found t&t to detin (u'''e for .9 $inute" 6" n unre"onb(e deprivtion of t&e individu(J"
I(ibert7 intere"t in proceedin' 6it& &i" itinerr7AI 6&ic& ("o i" protected b7 t&e Fourt& A$end$ent, ;30 C,S,A
t :9F <:19,
M.N W&en Iopertion( nece""itie"I eHi"tA "ei*ure" cn be ju"tified on (e"" t&n probb(e cu"e, ;F9 C,S,A t 20: ,
T&t in no 67 ffect" our n(7"i"A for even t&en it i" c(er t&t t&e Fourt& A$end$ent pp(ie", Ibid8 "ee ("o
Cnited Stte" v, 4(ceA ;30 C,S, 3.3 A t :92 )1.F2-,
M19N Of cour"eA if t&e po(ice officer"J pre"ence in t&e &o$e it"e(f enti(ed vio(tion of t&e Fourt& A$end$entA
no $ount of probb(e cu"e to be(ieve t&t n ite$ in p(in vie6 con"titute" incri$intin' evidence 6i(( ju"tif7
it" "ei*ure, HortonA ;.3 C,S,A t 123 <12:,
M11N It i" true t&t 5urr7J" Le""ee v, Hobo!en Lnd R I$prove$ent Co,A 1F Ho6, 0:0 )1FG3-A c"t "o$e doubt
on t&e pp(icbi(it7 of t&e A$end$ent to noncri$in( encounter" "uc& " t&i", Id,A 1F Ho6, t 0FG, ?ut c"e"
"ince t&t ti$e &ve "&ed different (i'&tA $!in' c(er t&t Fourt& A$end$ent 'urntee" re tri''ered b7
'overn$ent( "erc&e" nd "ei*ure" I6it&out re'rd to t&e u"e to 6&ic& M&ou"e"A pper"A nd effect"N re
pp(ied,I WrdenA 5r7(nd 4enitentir7 v, H7denA 2F: C,S, 0.;A 291 )1.3:-, 5urr7J" Le""eeJ" brod
"tte$ent t&t t&e Fourt& A$end$ent I&" no reference to civi( proceedin'" for t&e recover7 of debtI r'ub(7
on(7 $ent t&t t&e 6rrnt reLuire$ent did not pp(7A " 6" "u''e"ted in G,5, Le"in' Corp, v, Cnited Stte"A
;0. C,S, 22FA 2G0 )1.::-, W&tever it" proper redin'A 6e reffir$ tod7 our b"ic under"tndin' t&t t&e
protection 'in"t unre"onb(e "erc&e" nd "ei*ure" fu((7 pp(ie" in t&e civi( conteHt,
M10N T&i" 6" t&e vie6 eHpre""ed b7 t&e Court of Appe(" for t&e Tent& Circuit in Spec&t v, #en"enA F20 F,0d
1G13 )1.F:-A re$nded on unre(ted 'round"A FG2 F,0d F9G )1.FF- )en bnc-A 6it& 6&ic& t&e Sevent& Circuit
eHpre""(7 'reed, .;0 F,0dA t 19:3,
M12N T&e officer" in t&e"e c"e" 6ere en''ed in (6 enforce$entA nd 6ere (oo!in' for "o$et&in' t&t 6"
found nd "ei*ed, In t&i" brod "en"eA t&e "ei*ure" 6ere t&e re"u(t of I"erc&e"AI but not in t&e Fourt&
A$end$ent "en"e, T&t t&e Court of Appe(" $i'&t &ve been "u''e"tin' t&t t&e p(in<vie6 c"e" re
eHp(inb(e becu"e t&e7 ($o"t (67" occur in t&e cour"e of (6 enforce$ent ctivitie" receive" "o$e "upport
fro$ t&e penu(ti$te "entence of t&e Luoted p""'eA 6&ere t&e court "tte" t&t t&e 6ord I"ei*ureI $i'&t (o"e
./11
it" u"u( $enin' I6&en it "tnd" prt fro$ "erc& or n7 ot&er inve"ti'tive ctivit7,I Id,A t 19:. )e$p&"i"
dded-, AndA in t&e fo((o6in' pr'rp&A it ob"erve" t&tA IMoNut"ide of t&e (6 enforce$ent reA t&e Fourt&
A$end$ent retin" it" force " protection 'in"t "erc&e"A becu"e t&e7 invde privc7, T&t i" 6&7 6e
dec(ine to confine t&e $end$ent to t&e (6 enforce$ent "ettin',I Id,A t 19:.<19F9, Even if t&e court $ent
t&t "ei*ure" of propert7 in t&e cour"e of (6 enforce$ent ctivitie"A 6&et&er civi( or cri$in(A i$p(icte
intere"t" "fe'urded b7 t&e Fourt& A$end$entA but t&t pure propert7 intere"t" re unprotected in t&e non<(6<
enforce$ent "ettin'A 6e re not in ccordA " indicted in t&e bod7 of t&i" opinion, MG93 C,S, G3A :2N

%c& Cou'&(in
4O ?OE 2.31
RenoA N= F.G9G
Te( ::G 22F F11F
FH .;. 33: :;90

To: c&n"en+6"&oecount7,u"
Subject: Reno eviction noticed for Spr!" #u"tice Court
Dte: TueA 03 #un 0910 9.:19:1; <9:99
Der Civi( Supervi"or Hn"en
%c& Cou'&(in
4O ?OE 2.31
RenoA N= F.G9G
Te( ::G 22F F11F
FH .;. 33: :;90
Der Spr!" #u"tice CourtA
I c((ed nd received per$i""ion to fi(e t&i" b7 fH,,,I $ indi'ent nd reLue"t fee 6iverA nd fi(in' t&tA n
opportunit7 to cure n7 fi(in' fee deficienc7,
To: "&eriff6eb+6"&oecount7,u"8 ("tuc&e((+6"&oecount7,u"8 !"tnci(+6"&oecount7,u"8
c&n"en+6"&oecount7,u"8 $i(((err+reno,'ov
Subject: Reno eviction noticed for Spr!" #u"tice Court
Dte: TueA 03 #un 0910 9::GF:23 <9:99
Der Spr!" #u"tice CourtA WCSOA R4DA nd Reno #u"tice Court,
I &ve received )t&ou'& not per"on((7 "erved- 6&t pper" to be n eviction notice )G d7 un(6fu( detinerK-
for rent(" (octed t 13F9 S!7 5ountin DriveA RenoA F.G02A but t&e notice indicte" t&t I $u"t fi(e TenntJ"
19/11
An"6er 6it& t&e Spr!" #u"tice Court,
A$ I $i"t!en in vie6in' t&i" $tter to be out"ide t&e juri"diction of t&e Spr!" #u"tice CourtA nd rt&erA
$tter to be &nd(ed in Reno #u"tice CourtK
Given Spr!" #u"tice Court i" open G d7" 6ee! )c(o"e" t noon on Frid7"- nd Reno #u"tice Court &" ;
judici( d7" 6ee!A t&e ded(ine for fi(in' "peci( ppernce )to conte"t juri"diction- nd or TenntJ"
An"6er of Affidvit i" difficu(t to $e"ure,
I "po!e 6it& Reno 4o(ice Deprt$ent 6&o identified &i$"e(f " Sr'ent 5i((er ("t 6ee! nd &e indicted t&e
WCSO p(nned to co$e effectute n eviction on t&i" dteA #une 03A 0910, I be(ieve t&t 6ou(d be pre$tureA
" Nevd Lnd(ord Tennt (6 provide" for fi(in' TenntJ" An"6er or Affidvit b7 noon fter t&e fift& fu((
d7 )judici( d7"- nd Frid7" in Spr!" #u"tice Court re not fu(( d7" in t&t "en"eA nd re'rd(e""A Spr!"
#u"tice CourtA I be(ieveA i" not t&e pproprite foru$ 6&ereA " &ereA t&e "itu" i" (octed in Reno )Wrd 1<npK-
Sincere(7A
%c& Cou'&(in
4O ?OE 2.31
RenoA N= F.G9G
te( ::G 22F F11F
fH .;. 33: :;92
Civi( Divi"ion
329 Greenbre Drive
Spr!"A Nevd F.;21
)::G-2G2,:392 4&one
)::G-2G0,299; FH
Civi( Deprt$ent Supervi"or
C&ri" Hn"en
c&n"en+6"&oecount7,u"
T&e Civi( Divi"ion of Spr!" #u"tice Court i" $de up of t&ree $jor function":
Civi(
Civi( Co$p(int" for d$'e" in eHce"" of SG999 or if "uit invo(ve" brec& of contrctA punitive d$'e"A n
ction to obtin po""e""ion of propert7A 6rit of re"titutionA or ot&er (i!e ction"A (e'( coun"e( i" "u''e"ted for
t&e"e t7pe" of ction",
Eviction"
An ct or proce"" of (e'((7 di"po""e""in' per"on of (nd or rent( propert7,
S$(( C(i$"
An ction fi(ed in order to obtin $onetr7 jud'$ent, C(i$" $u"t not eHceed SG999, A "$(( c(i$" ction
$7 be fi(ed 6it& t&e Spr!" #u"tice Court if one of t&e fo((o6in' pp(ie" to t&e defendnt:
T&e7 re"ide 6it&in t&e boundrie" of t&e Spr!" To6n"&ip8
T&e7 re e$p(o7ed 6it&in t&e boundrie" of t&e Spr!" To6n"&ip8 nd/orA
T&e7 do bu"ine"" 6it&in t&e boundrie" of t&e Spr!" To6n"&ip,
11/11
here is that citation you asked for
Sent: Fri 9/21/12 1:21 AM
To: hsotelo@tmcc.edu; jleslie@washoecounty.us; lstuchell@washoecounty.us; hazlett-stevensc@reno.gov
Hi Guys,
The RPD and WCSO arrest reports, incident reports, 911 calls, dispatch logs and calls, and internal memorandum are all requested by me, and any relevancy
objectdions you may have, are, nhopefully, addressed herein. rjc rcp2012-000287 contains Milan Krebs TPO application, which references serveral police
reports he filed, apparently, involving me, thsoe my cross examination of him there touched on those matters somewhat.
The RPD incident reports and Krebs TPO application and the audio of the TPO hearing is relevant, and the testimony of Krebs employer in the eviction matter rjc rev2012-0001048
is relevant, it goes to witness bias, motive, retaliation, and creidibility.
VI. Particular Types of Evidence

E. Evidence from Prior Proceeding
2. Requisites for Admissibility
a. In General
Topic Summary Correlation Table References
917. Motive and opportunity for cross-examination
West's Key Number Digest
West's Key Number Digest, Criminal Law k544 West's Key Number Digest, Evidence k578
A.L.R. Library
Admissibility in evidence of deposition as against one not a party at time of its taking, 4 A.L.R.3d 1075
What Constitutes Similar Motive for Purposes of Rule 804(b)(1) of Federal Rules of Evidence, Excepting Such Testimony From Hearsay Rule if Party Against Whom Such Testimony
is Offered had Opportunity and "Similar Motive" to Develop Testimony, 138 A.L.R. Fed. 367
Under the Federal Rules of Evidence, and the Uniform Rules of Evidence, the former testimony of an unavailable witness is admissible if the party against whom the testimony is now
offered, or in a civil action or proceeding, a predecessor in interest, had an opportunity and similar motive to develop the testimony by direct, cross, or redirect examination.[FN1]
This cross-examination requirement operates to screen out those statements which, although made under oath, were not subject to the scrutiny of a party interested in thoroughly
testing their validity.[FN2] The requirement that trial counsel have a sufficient opportunity to test the testimony of an unavailable witness by cross-examination is ordinarily satisfied
by showing a similarity of parties and issues.[FN3]
The requirement of a meaningful opportunity to cross-examine is not satisfied where the party against whom the testimony is offered had neither the opportunity[FN4] nor a similar
motive[FN5] to cross-examine the witness at a previous deposition. The former testimony will
be admitted if the motivation to cross-examine was similar,[FN6] and former testimony will be excluded if the motivation was not similar.[FN7] Opportunity and motivation to cross-
examine the deponent in the first instance are the important factors, rather than the actual extent of cross-examination.[FN8] Since parties, at times, for tactical or other reasons, may,
as with a live witness at trial, choose not to cross-examine,[FN9] actual cross-examination at the prior hearing or trial is not required; it is necessary merely that the party against
whom the testimony is sought to be offered had an adequate opportunity and motive to exercise the right of cross-examination.[FN10] However, mere opportunity to cross-examine
the witness is not enough; there must also be a perceived real need or incentive to thoroughly cross-examine at the time of the deposition.[FN11]
CUMULATIVE SUPPLEMENT
Cases:
Cross-examination, and thus confrontation, has been accomplished, in context of determining admissibility at trial of an unavailable witness's preliminary hearing testimony, where
the defendant has had the opportunity to cross-examine witness at preliminary hearing, probing into areas such as bias and testing the veracity of the testimony, and this is particularly
so in cases where the defendant was represented by the same counsel at the preliminary hearing and at trial. U.S.C.A. Const.Amend. 6. Com. v. Wholaver, 989 A.2d 883 (Pa. 2010).
[END OF SUPPLEMENT]
[FN1] Fed. R. Evid. 804(b)(1); Uniform Rules of Evidence 804(b)(1).
[FN2] U.S. v. Pizarro, 717 F.2d 336, 14 Fed. R. Evid. Serv. 1 (7th Cir. 1983).
[FN3] Skyers v. U.S., 619 A.2d 931 (D.C. 1993).
[FN4] U.S. v. Feldman, 761 F.2d 380, 18 Fed. R. Evid. Serv. 1, 84 A.L.R. Fed. 649 (7th Cir. 1985); Hewitt v. Hutter, 432 F. Supp. 795, 1 Fed. R. Evid. Serv. 916 (W.D. Va. 1977),
judgment aff'd, 574 F.2d 182 (4th Cir. 1978).
[FN5] U.S. v. Feldman, 761 F.2d 380, 18 Fed. R. Evid. Serv. 1, 84 A.L.R. Fed. 649 (7th Cir. 1985).
[FN6] Dykes v. Raymark Industries, Inc., 801 F.2d 810, 21 Fed. R. Evid. Serv. 953 (6th Cir. 1986); Clay v. Johns-Manville Sales Corp., 722 F.2d 1289, 14 Fed. R. Evid. Serv. 1205
(6th Cir. 1983); Murray v. Toyota Motor Distributors, Inc., 664 F.2d 1377, 9 Fed. R. Evid. Serv. 1128 (9th Cir. 1982); Matter of Johns-Manville/Asbestosis Cases, 93 F.R.D. 853, 10
Fed. R. Evid. Serv. 961 (N.D. Ill. 1982).
[FN7] U.S. v. Feldman, 761 F.2d 380, 18 Fed. R. Evid. Serv. 1, 84 A.L.R. Fed. 649 (7th Cir. 1985); Baylor v. Jefferson County Bd. of Educ., 733 F.2d 1527, 17 Ed. Law Rep. 500, 15
Fed. R. Evid. Serv. 1324 (11th Cir. 1984); Matter of Sterling Nav. Co.,
Ltd., 444 F. Supp. 1043 (S.D. N.Y. 1977).
[FN8] DeLuryea v. Winthrop Laboratories, a Div. of Sterling Drug, Inc., 697 F.2d 222, 12 Fed. R. Evid. Serv. 515 (8th Cir. 1983); Hendrix v. Raybestos-Manhattan, Inc.,
776 F.2d 1492, 19 Fed. R. Evid. Serv. 903, 3 Fed. R. Serv. 3d 1169 (11th Cir. 1985).
[FN9] People v. Nucci, 162 A.D.2d 725, 557 N.Y.S.2d 422 (2d Dep't 1990).
[FN10] DeLuryea v. Winthrop Laboratories, a Div. of Sterling Drug, Inc., 697 F.2d 222, 12 Fed. R. Evid. Serv. 515 (8th Cir. 1983); Hendrix v. Raybestos-Manhattan, Inc.,
776 F.2d 1492, 19 Fed. R. Evid. Serv. 903, 3 Fed. R. Serv. 3d 1169 (11th Cir. 1985); In re Related Asbestos Cases, 543 F. Supp. 1142, 11 Fed. R. Evid. Serv. 889 (N.D.
Cal. 1982); Com. v. Canon, 373 Mass. 494, 368 N.E.2d 1181 (1977); People v. Nucci, 162 A.D.2d 725, 557 N.Y.S.2d 422 (2d Dep't 1990).
An exception to the rule against hearsay permitting the admission of prior testimony when a witness is unavailable does not require the defendant to have actually
conducted a cross-examination; instead, it only requires that he or she be given an opportunity to question the witness, and, by requiring an opportunity to cross-examine,
the exception affords protection to the defendant's constitutional right to confront witnesses. Stouffer v. State, 2006 OKCR 46, 147 P.3d245 (Okla. Crim. App. 2006),
cert. denied, 127 S. Ct. 2060, 167 L. Ed. 2d 787 (U.S. 2007).


a. In General
918. Motive and opportunity for cross-examinationDetermination of similarity of motive to cross-examine
A.L.R. Library
Admissibility or use in criminal trial of testimony given at preliminary proceeding by witness not available at trial, 38 A.L.R.4th 378
In determining whether the party against whom the evidence is offered had a similar motive to develop the testimony, a court must evaluate not only the similarity of the issues but
also the purpose for which the testimony is given.[FN1] Accordingly, in assessing the similarity of motive, the court must consider whether the party resisting the offered testimony at
a pending proceeding had at a prior proceeding an interest of substantially similar intensity to prove or disprove the same side of a substantially similar issue.[FN2] Circumstances or
factors which influence motive to develop testimony include: (1) the type of proceeding in which the testimony is given;[FN3] (2) trial strategy; (3) the potential parties or financial
stakes; and (4) the number of issues and parties. These factors may differ greatly in civil and criminal cases involving the same defendant, and may, in a criminal trial, prohibit the
admission, against the defendant, of a deposition previously taken in a civil trial involving the same defendant.[FN4]
For the purpose of admitting the prior testimony of an unavailable witness, the defendant's interests and motive for cross-examination in both proceedings need not be identical, only
similar.[FN5] That is, a "similar motive" does not mean "identical motive."[FN6]
State courts have approached the issue of whether a criminal defendant's motive to cross-examine a witness at the preliminary hearing was similar to the motive he or she would have
had to cross-examine, in different ways, the witness at trial.[FN7] According to one view, defense attorneys always have similar motives to cross-examine at preliminary hearings and
trials.[FN8] Other courts hold that the motives of the defense attorney, at preliminary hearings and trials, must be compared on a case-by-case basis.[FN9]
Cases:
A defendant's interest and motive in impeaching a witness's testimony at a second proceeding need only be similar, not identical, to his interest at a first proceeding for the testimony
from the first proceeding to be admissible in the second upon the witness's unavailability under exception to the defendant's constitutionally guaranteed right of confrontation. People
v. Valencia, 43 Cal. 4th 268, 74 Cal. Rptr. 3d 605, 180 P.3d 351 (2008), cert. denied, 129 S. Ct. 198, 172 L. Ed. 2d 158 (2008).
A defendant's interest and motive at a second proceeding is not dissimilar to his interest at a first proceeding, within meaning of statute governing admission of prior testimony of
unavailable witnesses under exception to a defendant's constitutionally guaranteed right of confrontation, simply because events occurring after the first proceeding might have led
counsel to alter the nature and scope of cross-examination of the witness in certain particulars. People
v. Valencia, 43 Cal. 4th 268, 74 Cal. Rptr. 3d 605, 180 P.3d 351 (2008), cert. denied, 129 S. Ct. 198, 172 L. Ed. 2d 158 (2008).
Defendant on trial for felony murder had an opportunity and similar motive to cross examine at the preliminary hearing a witness who was unavailable for trial, such that admission of
witness's preliminary-hearing testimony was admissible at trial under the exception to the hearsay rule for a statement of an unavailable witness; purpose of the preliminary hearing
was to determine whether there was probable cause to believe that defendant committed an offense, defendant's motive for cross examining witness was to show that defendant did not
rape and murder victim, and defendant's motive at trial likewise to show that he was not guilty of raping and murdering victim. NMRA, Rules 5302(C), 11804(A)(5), (B)(1).
State v. Lopez, 2011-NMSC-035, 258 P.3d 458 (N.M. 2011).
[END OF SUPPLEMENT]
Both the Sixth Amendment's confrontation clause and the rules of evidence bar admission of previous testimony of an unavailable witness, unless the defendant had a prior
opportunity and similar motive to cross-examine the witness. State v. Benn, 161 Wash. 2d 256, 165 P.3d 1232 (2007), petition for cert. filed (U.S. Jan. 7, 2008).
[FN2] U.S. v. DiNapoli, 8 F.3d 909, 38 Fed. R. Evid. Serv. 277, 138 A.L.R. Fed. 739
(2d Cir. 1993); People v. Seijas, 36 Cal. 4th 291, 30 Cal. Rptr. 3d 493, 114 P.3d 742 (2005).
The preliminary hearing testimony of an attempted murder victim, who died in an unrelated homicide before trial, was admissible; the defendant had a similar interest and
similar motives for cross-examining the victim at the preliminary hearing, that is, challenging the witness's credibility and discrediting his account of shooting, even if
counsel was not then aware of the victim's illegal drug activities. People v. Harris, 37 Cal. 4th 310, 33 Cal. Rptr. 3d 509, 118 P.3d 545 (2005), cert. denied, 547 U.S. 1065,
126 S. Ct. 1655, 164 L. Ed. 2d 411 (2006).
[FN3] U.S. v. DiNapoli, 8 F.3d 909, 38 Fed. R. Evid. Serv. 277, 138 A.L.R. Fed. 739 (2d Cir. 1993).
As to the use, in civil case, of former testimony in criminal case, see 908.
As to the right of accused to reproduce former testimony, see 907.
[FN5] People v. Harris, 37 Cal. 4th 310, 33 Cal. Rptr. 3d 509, 118 P.3d 545 (2005), cert. denied, 547 U.S. 1065, 126 S. Ct. 1655, 164 L. Ed. 2d 411 (2006).
[FN6] People v. Harris, 37 Cal. 4th 310, 33 Cal. Rptr. 3d 509, 118 P.3d 545 (2005), cert. denied, 547 U.S. 1065, 126 S. Ct. 1655, 164 L. Ed. 2d 411 (2006);State v.
DeSantiago, 149 Wash. 2d 402, 68 P.3d 1065 (2003).
[FN7] Rodriguez v. State, 711 P.2d 410 (Wyo. 1985).
[FN8] State v. Brooks, 638 P.2d 537 (Utah 1981).


a. In General
919. Motive and opportunity for cross-examinationIn criminal proceedings
A.L.R. Library
Admissibility or use in criminal trial of testimony given at preliminary proceeding by witness not available at trial, 38 A.L.R.4th 378
The use of a former witness' testimony is not violative of the accused's constitutional right to be confronted with witnesses against him or her if, at the preliminary hearing
or former trial, the accused had been accorded an adequate opportunity to cross-examine such witness.[FN1] A court will not impute to a defendant who flees before trial
knowledge that he or she waived his or her right to cross-examine witnesses against him or her.[FN2]
The requirement that the party against whom the evidence is to be admitted must have been able to conduct cross-examination at the former proceeding is generally
satisfied if the former testimony comes from another hearing of the same criminal proceeding, such as before a grand jury if the hearsay testimony is offered against the
government,[FN3] or from a prior trial of the same criminal defendant.[FN4] A preliminary hearing affords a constitutionally adequate opportunity to cross-examine
opposing witnesses, especially where extensive cross-examination is conducted by the same counsel who represented the defendant at trial, and the hearing is conducted
before a judicial tribunal equipped to provide a judicial record of the hearing.[FN5] Transcripts of prior state prosecutions have been excluded from federal prosecutions
on the ground that the federal government had no opportunity to cross-examine in the state proceedings.[FN6]
A defendant is not entitled, under the Confrontation Clause, to a cross-examination that is effective in whatever way and to whatever extent defense might wish.[FN7] If a
party against whom the testimony is now offered is the one against whom the testimony was offered previously, no unfairness is apparent in requiring the party to accept
his or her own prior conduct of cross-examination or decision not to cross-examine. Consequently, the court's inquiry focuses not on the extent of cross-examination at
the former proceeding but on whether the party's handling of the testimony was meaningful in light of the circumstances which prevailed when the former testimony was
offered.[FN8]
Cases:
Defendant's right to confront witnesses at trial in capital murder prosecution was not violated simply because prosecution witness, at in limine hearing to determine
whether he could invoke privilege against self-incrimination for purposes of trial, testified on both direct and cross-examination that he had told the truth at preliminary
hearing, though witness's preliminary hearing testimony was admitted at trial because of his unavailability as result of asserting the privilege; witness's answer to general
question calling for his ratification of his preliminary hearing testimony had no impact on defendant's confrontation rights. People v. Williams, 43 Cal. 4th 584, 75 Cal.
Rptr. 3d 691, 181 P.3d 1035 (2008), cert. denied, 129 S. Ct. 1000, 173 L. Ed. 2d 298 (2009).
Testimony of witness, who lived two miles from victim's house, from prior capital murder trial was admissible at fourth trial, since witness was unavailable for trial, issues
were unchanged, defendant had prior opportunity to cross-examine her, and her testimony revealed probative and relevant facts for jury. Murray v. State, 3 So. 3d 1108
(Fla. 2009).
Defendant on trial for felony murder had an opportunity and similar motive to cross examine at the preliminary hearing a witness who was unavailable for trial, such that
admission of witness's preliminary-hearing testimony was admissible at trial under the exception to the hearsay rule for a statement of an unavailable witness; purpose of
the preliminary hearing was to determine whether there was probable cause to believe that defendant committed an offense, defendant's motive for cross examining
witness was to show that defendant did not rape and murder victim, and defendant's motive at trial likewise to show that he was not guilty of raping and murdering victim.
NMRA, Rules 5302(C), 11804(A)(5), (B)(1). State v. Lopez, 2011-NMSC-035, 258 P.3d 458 (N.M. 2011).
Cross-examination, and thus confrontation, has been accomplished, in context of determining admissibility at trial of an unavailable witness's preliminary hearing
testimony, where the defendant has had the opportunity to cross-examine witness at preliminary hearing, probing into areas such as bias and testing the veracity of the
testimony, and this is particularly so in cases where the defendant was represented by the same counsel at the preliminary hearing and at trial. U.S.C.A. Const.Amend. 6.
Com. v. Wholaver, 989 A.2d 883 (Pa. 2010).
[END OF SUPPLEMENT]
[FN1] U.S. v. Davis, 551 F.2d 233, 1 Fed. R. Evid. Serv. 833 (8th Cir. 1977); State v. Browder, 507 So. 2d 1040 (Ala. Crim. App. 1987); People v. Brock, 38 Cal. 3d 180,
211 Cal. Rptr. 122, 695 P.2d 209 (1985); Alston v. U. S., 383 A.2d 307 (D.C. 1978); Stearsman v. State, 237 Ind. 149, 143 N.E.2d 81 (1957); State v. Brown, 181 Kan.
375, 312 P.2d 832 (1957); Com. v. Siegfriedt, 402 Mass. 424, 522 N.E.2d 970 (1988); People v. Sinclair, 327 Mich. 686, 42 N.W.2d 786 (1950); Meyers v. State, 112 Neb.
149, 198 N.W. 871 (1924); Aesoph v. State, 102 Nev. 316, 721 P.2d 379 (1986); People v. Hayes, 110 A.D.2d 1035, 489 N.Y.S.2d 19 (4th Dep't 1985); State v. Prince, 270
N.C. 769, 154 S.E.2d 897 (1967); State v. Swiden, 62 S.D. 208, 252 N.W. 628 (1934); Fisher v. Com., 217 Va. 808, 232 S.E.2d 798 (1977); Pettit v. Rhay, 62 Wash. 2d
515, 383 P.2d 889 (1963).
[FN2] U.S. v. Deeb, 13 F.3d 1532, 38 Fed. R. Evid. Serv. 1087 (11th Cir. 1994).
[FN3] U.S. v. Henry, 448 F. Supp. 819, 3 Fed. R. Evid. Serv. 340 (D.N.J. 1978).
[FN4] U.S. v. Pizarro, 717 F.2d 336, 14 Fed. R. Evid. Serv. 1 (7th Cir. 1983); U.S. v. Davis, 551 F.2d 233, 1 Fed. R. Evid. Serv. 833 (8th Cir. 1977).
A defendant had an adequate opportunity and similar motive, in a first trial, to develop a witness's testimony by direct, cross, or redirect examination, as would warrant
the admission of that prior testimony at retrial in which the witness was unavailable; cross-examination in the first trial made a serious effort to undermine and discredit
the witness's testimony, matters in dispute at the first trial were essentially identical to those in dispute at retrial, and the importance of those matters to the outcome of
both proceedings was the same. U.S. v. Mejia, 376 F. Supp. 2d 460 (S.D. N.Y. 2005).
[FN5] California v. Green, 399 U.S. 149, 90 S. Ct. 1930, 26 L. Ed. 2d 489 (1970).
The testimony of a witness at a suppression hearing, at which a capital murder defendant sought to suppress a witness's pre-trial identification of him and any resulting in-
court identifications, was admissible at trial under the exception to the rule against hearsay for former testimony when the declarant is unavailable, as defense counsel had
a similar motive at both proceedings in his cross-examination of the witness, that is, he needed to show either that the witness was mistaken in her identification, or that
she was biased in some way, and the suppression hearing was a full-fledged hearing, in that the prosecutor presented the witness's testimony at the suppression hearing to
place the defendant at the murder scene, and he used her testimony to accomplish the same objective at trial. Bertrand v. State, 363 Ark. 422, 214 S.W.3d 822 (2005).
[FN6] U.S. v. Barrett, 766 F.2d 609, 18 Fed. R. Evid. Serv. 1170 (1st Cir. 1985).
[FN7] Com. v. Siegfriedt, 402 Mass. 424, 522 N.E.2d 970 (1988).
The trial court did not abuse its discretion in denying a capital murder defendant's motion to bar from admission prior testimony of a crime scene technician in the
defendant's re-trial, as the defendant had an opportunity at the first trial to cross-examine the
technician, the motive and focus of that cross-examination was the same as that which would have guided the cross-examination at his re-trial, the fact that the defendant's
convictions were reversed based on prior counsel's ineffectiveness in failing to investigate certain evidence did not provide a basis for concluding that counsel's cross-
examination of the technician at the first trial was necessarily deficient, and the technician's testimony was necessary to state's case. People v. Sutherland, 223 Ill. 2d 187,
307 Ill. Dec. 524, 860 N.E.2d 178 (2006), as modified on denial of reh'g, (Dec. 4, 2006) and cert. denied, 128 S. Ct. 70, 169 L. Ed. 2d 55 (U.S. 2007).
[FN8] U.S. v. Pizarro, 717 F.2d 336, 14 Fed. R. Evid. Serv. 1 (7th Cir. 1983).
For the purpose of admitting prior testimony of an unavailable witness, the defendant's interest and motive for cross-examination at a second proceeding is
not dissimilar to his or her interest at a first proceeding, simply because events occurring after the first proceeding might have led counsel to alter the nature
and scope of cross-examination of the witness in certain particulars. People v. Harris, 37 Cal. 4th 310, 33 Cal. Rptr. 3d 509, 118 P.3d 545 (2005), cert. denied,
547 U.S. 1065, 126 S. Ct. 1655, 164 L. Ed. 2d 411 (2006).
For discussion of the accused's right to confront witnesses, generally, see Am. Jur. 2d, Criminal Law 1072.
[FN9] Scott v. State, 272 Ark. 88, 612 S.W.2d 110 (1981); Rodriguez v. State, 711 P.2d 410 (Wyo. 1985).

Particular Types of Evidence

2. Testimony, in General
a. In General
1364. Effect of witnesses' credibility, generally
A.L.R. Library
Necessity of, and prejudicial effect of omitting, cautionary instruction to jury as to reliability of, or factors to be considered in evaluating, eyewitness identification testimonystate
cases, 23 A.L.R.4th 1089
Use of drugs as affecting competency or credibility of witness, 65 A.L.R.3d 705
Forms
Am. Jur. Pleading and Practice Forms, Evidence 176, 177, 179 (Factors to be considered in ascertaining or evaluating credibility of witnesses)
The factfinder is free to determine the credibility of the witnesses.[FN1] More specifically, a trier of fact has the power to accept or reject, in whole or in part, a witness's
testimony.[FN2]
A trier of fact is free to believe or disbelieve an expert witness.[FN3]
When the testimony of a witness is not believed, the trier of fact may simply disregard it; normally, the discredited testimony is not considered a sufficient basis for drawing a
contrary conclusion.[FN4] However, a jury may not properly disregard the testimony of a witness,
even an interested one, without some reason to do so that is apparent from the record.[FN5] It has sometimes been stated that a jury is not permitted to disbelieve testimony unless
there is good reason for questioning the credibility of the witnesses.[FN6]
Observation:
Where there is conflicting testimony about factual matters, the resolution of which depends upon a determination of the credibility of the witnesses, the matter is one of the weight of
the evidence, not its sufficiency.[FN7] In other words, attacks on witness credibility are simple challenges to the quality and not to the sufficiency of the evidence.[FN8]
A jury is free to reject the testimony of a defendant where that testimony is inconsistent with other direct or circumstantial evidence.[FN9] The trier of fact may take into consideration
all the circumstances of the case,[FN10] such as whether the testimony is reasonable and consistent with other evidence; the witness's appearance, conduct, memory and knowledge of
the facts; the witness's interest in the trial;[FN11] and the witness's emotional or mental state.[FN12] The trier of fact may also consider the relationship of the witnesses to the party
involved and their feelings towards the party.[FN13] A family relationship between a witness and a party, for example, may bear upon the witness's bias; the fact of the relationship
does not establish bias, but is simply a circumstance considered by the fact-finder in appraising credibility.[FN14]
Cases:
When evidence is merely potentially exculpatory, the failure to preserve potentially useful evidence does not constitute a denial of due process of law unless the defendant can show
bad faith on the part of the police. U.S.C.A. Const.Amend. 14. State v. Lehr, 254 P.3d 379 (Ariz. 2011), petition for cert. filed (U.S. July 27, 2011).
Jury alone determines what weight to give evidence and may reject it or accept all or any part of it that the jurors believe to be true. Smith v. State, 2010 Ark. 75, 2010 WL565246
(2010).
The trier of fact may credit part of a witness's testimony and reject other parts. State v. Michael H., 291 Conn. 754, 970 A.2d 113 (2009).
Trier of fact may credit part of a witness's testimony and reject other parts. Hicks v. State, 287 Conn. 421, 948 A.2d 982 (2008).
The trier of fact has the right to accept part and disregard part of the testimony of a witness. Costanzo v. Gray, 112 Conn. App. 614, 963 A.2d 1039 (2009), certification denied, 291
Conn. 905, 967 A.2d 1220 (2009).
A trier of fact is the sole arbiter of credibility, and thus is free to accept or reject, in whole or in part, the testimony offered by either party. Somers v. Chan, 110 Conn. App. 511, 955
A.2d 667 (2008).
Jurors may consider the tenor of a witness's testimony in deciding whether to believe the words that witness has spoken on the stand, but jurors cannot find in those mannerisms words
and entire sentences unspoken in court and use such constructs to supplement the actual evid
ence to render a verdict that suits their sense of fairness notwithstanding the law. State v. Brooks, 263 P.3d 161 (Kan. 2011).
The trier of fact has the right to believe the evidence presented by one litigant in preference to another. Miller v. Com., 283 S.W.3d 690 (Ky. 2009).
The trier of fact may believe any witness in whole or in part. Miller v. Com., 283 S.W.3d 690 (Ky. 2009).
The trier of fact may take into consideration all the circumstances of the case, including the credibility of the witness. Miller v. Com., 283 S.W.3d 690 (Ky. 2009).
Conflicting expert testimonyoften called a "battle of the experts"requires the fact-finder to assign credibility, and the fact-finder is free to accept or reject any of the expert
opinions. Estate ex rel. Campbell v. Calhoun Health Services, 66 So. 3d 129 (Miss. 2011).
Jury is free to believe or disbelieve any of the witness testimony. State v. Celis-Garcia, 344 S.W.3d 150 (Mo. 2011).
[END OF SUPPLEMENT]
[FN1] Com. v. Cousar, 593 Pa. 204, 928 A.2d 1025 (2007), petition for cert. filed
(U.S. Jan. 22, 2008).
Credibility determinations are within the sole province of the jury. Com., Dept. of General Services v. U.S. Mineral Products Co., 927 A.2d 717 (Pa. Commw. Ct. 2007).
[FN2] Jeffers v. State, 934 A.2d 908 (Del. 2007); Taylor v. Taylor, 288 Ga. App. 334, 654 S.E.2d 146 (2007); Porter v. Hu, 116 Haw. 42, 169 P.3d 994 (Ct. App. 2007); State v. Ware,
959 So. 2d 459 (La. 2007); People v. Schumacher, 276 Mich. App. 165, 740 N.W.2d 534 (2007), appeal denied, 480 Mich. 1043, 743 N.W.2d 876 (2008); Conrad v. Michelle & John,
Inc., 394 N.J. Super. 1, 925 A.2d 54 (App. Div. 2007); Com. v. Faulk, 2007 PA Super 185, 928 A.2d 1061 (2007); Russo v. State, 228 S.W.3d 779 (Tex. App. Austin 2007), petition
for discretionary review refused, (Dec. 5, 2007).
[FN3] Lubetzky v. Friedman, 228 Cal. App. 3d 35, 278 Cal. Rptr. 706 (2d Dist. 1991), opinion modified, (Mar. 19, 1991); Mather v. Griffin Hosp., 207 Conn. 125, 540 A.2d666
(1988); Sims v. Dibler, 172 Ohio App. 3d 486, 2007-Ohio-3035, 875 N.E.2d 965 (7th Dist. Jefferson County 2007).
Weight of expert opinion and insanity defense, see 1420.
[FN4] Evans-Reid v. District of Columbia, 930 A.2d 930 (D.C. 2007).
[FN5] White v. Greater Arizona Bicycling Ass'n, 216 Ariz. 133, 163 P.3d 1083 (Ct. App. Div. 2 2007).
[FN6] Page v. Crisp, 303 S.C. 117, 399 S.E.2d 161 (Ct. App. 1990).
[FN7] State v. Wilhite, 961 So. 2d 565 (La. Ct. App. 2d Cir. 2007), writ denied, 973 So. 2d 755 (La. 2008).
Assessing weight and sufficiency generally, see 1357. [FN8] U.S. v. Lee, 991 F.2d 343 (6th Cir. 1993). [FN9] Alvin v. State, 287 Ga. App. 350, 651 S.E.2d 489
(2007). Circumstantial evidence, generally, see 1361. [FN10] Bissell v. Baumgardner, 236 S.W.3d 24 (Ky. Ct. App. 2007). [FN11] State v. Frake, 450 N.W.2d 817
(Iowa 1990). Inconsistent or conflicting evidence, generally, see 1371, 1372. The factfinder may treat an interested witness's testimony as conclusive if it is clear,
direct, and positive and there are no circumstances tending to discredit or impeach the
same. Wilz v. Flournoy, 228 S.W.3d 674 (Tex. 2007).
[FN12] U.S. v. Martinez, 877 F.2d 1480 (10th Cir. 1989), stating that the fact that a
witness was a teenager with a history of emotional problems and that another was a
drug addict were impeaching facts which posed a credibility issue to be resolved by the
factfinder and were properly left for the jury to consider.
A witness's paranoia and psychiatric treatment does not necessarily make his testimony
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Dear 7r( Leslie and 7r( Do$an AND 9A:IO;S <:OS!;TO:S AND LA= !N4O:!7!NT AG!NI!S,

ATT!NTION, THIS IS A LITIGATION HOLD NOTI!( <L!AS! >NO= THAT ?O; A:! NO=
:!@;I:!D TO 7AINTAIN AN? 7!DIA AND :!O:DS IN ?O;: <OSS!SSION, O: TO =HIH ?O;
O;LD A! :!ASONAAL? !B<!T!D TO A@;I:! O: 7AINTAIN, THAT :!LAT! IN AN? =A? TO
TH! 9A:IO;S =:ONG4;L A::!STS O4 "AHA:? A( O;GHLIN THAT ?O;: AG!NI!S HA9!
!NGAG!D IN O9!: TH! <AST ,C 7ONTHS( :!NO IT? O:7AAS, TH! LAST TI7! I DIS;SS!D
SO7!THING =ITH ?O; THAT ?O; A:G;AAL? HAD A D;T? TO DO;7!NT AND 4OLLO= ;<
ON, I =O;ND ;< A!ING >IDNA<<!D AND HAD 7? S7A:T<HON! !BT:AT!D 4:O7 7?
L;TH!S, ONL? TO HA9! IT AND A 7I:O SD A:D :!T;:N!D =I<!D O4 DATA, DATA
=HIH ?O; A<<A:!NTL? =!:! 4!A:4;L 7IGHT SO7!HO= S;GG!ST A <;:<OS!4;L TAT
ON ?O;: <A:T TO A9OID DO;7!NTING AN? 7ISOND;T A? TH! LA= !N4O:!7!NT
AG!NI!S ?O; =O:> =ITH AND =HIH ?O;: I9IL DI9ISION D!4!NDS IN =:ONG4;L
A::!ST LA=S;ITS( THIS IS SI7ILA: TO TH! SIT;ATION DDA ?O;NG 4INDS HI7S!L4 IN
;::!NTL? IN <:OS!;TING O;GHLIN 4O: D7IS;S! O4 *,,D =H!:! O;GHLIN
ALL!G!DL? ALL!D *,, TO :!<O:T 7ISOND;T A;SING HI7 S!:IO;S 4!A: A? LOAL
LA= !N4O:!7!NT( >IND O4 A T:I>? THING TO <:OS!;T!, SO7! 7IGHT SA?(
AN?=A?S(((

I #a1e been callin$ and or /ritin$ bot# of 0ou on a dail0 basis and #a1e not recei1ed an0 response from eit#er
of 0ou( T#is is interestin$ considerin$ 7r( LeslieEs statements in #is email belo/ from * C .F,.( <lease
indicate a list of dates and time /#en I can meet /it# eit#er of 0ou %and #opefull0 not some Din1esti$atorD li2e
Larr0 arlsen /#o just sits t#ere all empt0 #eaded and carefree, onl0 to later admit #e #ad done absolutel0 no
/or2 on m0 case, despite sittin$ in on t/o meetin$s, and t#at #e #ad no plans to do an0 /or2 or in1esti$ation on
m0 case((((

Gim, t#e ::.F,,HF6--C, Trial resumes on October ,5t#, .F,.( Despite 0our indication to t#e court on
September 5t#, .F,., t#e conclusion of t#e Trial /ill ta2e more t#an an #our( I donEt t#in2 0ou $et it( I reall0
donEt t#in2 0ou $et it, Gim( T#ere is a lot of /or2 to do, and since t#e ourt #as ruled t#at I am stuc2 /it# 0ou
%until at least t#e competenc0 e1aluation is complete), 0ou are still attorne0 of record, and #a1e a dut0 to
prepare for trial( Also, c#ec2 out Goodni$#tEs :equest for Submission on 7a0 5t#, .F,.( Notice t#at it as2s for
somet#in$ t#erein( =#0 didnEt 0ou or Goe e1er follo/ up on t#atI T#at is prejudicial to m0 interests(
,+,F

Aira0, I am still /aitin$ to #ear bac2 from 0ou re$ardin$ /#0 0ou #a1e failed to pro1ide me a cop0 of m0 file in
::.F,.HF656-F( On Gul0 .6t#, .F,. at .:,6pm 0ou indicated t#at 0ou personall0 #ad pro1ided me t#e file
durin$ m0 pre1ious 1isit to t#e office( A0 .:,J 0ou #ad c#an$ed t#at stor0 to one /#ere 0ou sa/ Gim Leslie
$i1e me t#e file( A0 .:,* pm 0ou indicated t#at it /as not true t#at a manilla folder containin$ m0 file #ad
been placed for me at t#e front des2 for a fe/ da0s, t#en returned bac2 to t#e office, despite 0our receptionist
confirmin$ t#is( =e donEt need to $et into /#at Leslie T#ibault #as to sa0 about 0ou, eit#er of 0ou, do /eI

I /ant 0ou to fa3 or email me m0 file, preferabl0 email( T#at /a0, t#ere is no debate, 0ou #a1e proof 0ou sent
it, and I /ill #a1e it( If 0ou must fa3 it fine, m0 fa3 is *C* 66K KCF.( If 0ou /ant to continue moti1atin$ me,
t#en $o a#ead and be a pain and tell me I #a1e to pic2 it up, or t#at 0ou alread0 t#in2 0ou or Gim pro1ided it and
Dare /e $oin$ to just 2eep doin$ t#is o1er and o1er /#ere /e pro1ide 0ou copies and copies of t#e same t#in$D
bla#, bla#( Go a#ead, Aira0( Go a#ead(

No/, surel0, 0ou #a1e documentation of /#at 0ou #a1e pro1ided me alread0, Airar0( Good( No/, c#ec2 to see
if an0 DDisco1er0D 0ou #a1e pro1ided me includes t#e dispatc# reports from t#e ni$#t of t#e Ganuar0 ,Ct#, .F,.
arrest, or if it just contains Sc#aurEs Narrati1e and dispatc# reports from t#e /ee small #ours of Ganuar0 ,.t#H
,-t#, /#en :<D Duralde %/#om 7r( Leslie cross e3amined t#e ot#er da0 /#ile ma2in$ ar$ument to t#e ourt
t#at Dnobod0 did an0t#in$ /ron$ in t#is case, certainl0 not t#e :<D)( Actuall0, 7r( Leslie, I filed a complaint
/it# t#e :<D %or attempted to, sometimes t#e0 refuse to accept suc# t#in$s) on or about September Kt#, .F,,,
and Officer :osa clearl0 did some t#in$s /ron$ on t#e 1ideo of t#e arrest, so(((

Airar0, please ser1e a subpoena duces tecum on t#e =DA and t#e :<D, and t#e emer$enc0 ser1ices di1ision
$at#erin$ t#e media recordin$s made b0 emer$enc0 ser1ices of t#e arrest on Ganuar0 ,Ct#, .F,. and t#e e1ents
leadin$ up to t#at arrest, includin$ t#e man0 *,, calls and responses b0 t#e :<D in relation to t#e domestic
1iolence I /as a 1ictim of at ,C.. !( *t# St(, :eno, N9 J*5,., and for /#ic# I recei1ed t/o <rotection Orders
in 49,.HFF,JK and 49,.HFF,JJ %see attac#ed)( <lease subpoena and inter1ie/ prior to Trial, and disclose as a
/itness I intend to call at trial %I #a1e an in1iolable :i$#t to Subpoena =itnesses, and no Dmeans and
objecti1esD 1ersus DtacticsD claptrap out of 0ou or Leslie is c#an$in$ t#at( bot# Sar$ent <aul Sifre %/#om
directed bot# t#e arrest on Ganuar0 ,.t#, .F,. for Dja0/al2in$D /#erein e3cessi1e force /as used on me b0
:<D Officer Loo2 and Leed0), /#ile Sifre obstructed justice b0 turnin$ off m0 1ideo camera, and Sar$ent "ac#
T#e/, /#om #ad in t#e da0s pre1ious to t#e Ganuar0 ,Ct#, .F,. arrest at ,C.. !( *t# St( %I returned #ome t#at
e1enin$ to find m0 do$ missin$ and m0 1iolent abusi1e roomates ma2in$ menacin$ statements in t#at re$ard)
#ad $i1en me permission to call #im and pro1ided t/o numbers at /#ic# to do so, one of /#ic# /as t#e *,,,
and t#e ot#er /as a --CH number( Sifre directed t#e arrest b0 Sc#aur on Ganuar0 ,Ct#, .F,., and I #a1e
pro1ided 0ou a 1ideo of Sifre c#idin$ me immediatel0 prior to t#e arrest for Dplacin$ 0ourself in situations
/#ere 0ou are t#e 1ictimD( 4rom m0 time in t#e domestic 1iolence ad1ocac0 sp#ere I 2no/ suc# a 1ie/point is
common to an abuser, and t#at is /#at Sifre is( 4urt#er, please subpoena t#e records related to Sar$ent Sifre
detainin$ me for an #our outside of m0 sisterEs #ouse and allo/in$ m0 do$ to escape and be lost %for /#ic# t#e
ount0 is still impermissibl0 see2in$ to bill me)(

If 0ou donEt /ant to do t#ese t#in$s, please pro1ide a response in /ritin$ t#at I can cop0 and past into m0
omplaint and $rei1ance a$ainst 0ou s#ould 0our response be as tepid and transparent as t#e ones 0ou #a1e
pro1ided in t#e past( 4urt#er, I demand t#at 0ou file %after presentin$ a Draft for m0 appro1al) a 7otion to
Dismiss based upon t#e insufficienc0 of t#e information in t#e complaint and upon t#e fact t#at t#e arrest /as
for alle$ed conduct t#at did not occur in t#e presence of t#e officer %does t#e disco1er0 0ou #a1e, or /#ic# ma0
be in t#e courtEs file spea2 to conduct on t#e da0s pre1iousI)( I also /ant 0ou to de1elop a defense t#at points to
t#e comparable misue of *,, b0 m0 sister and or ore0 Goble, and t#e retalitator0 nature of t#is arrest and
.+,F
prosecution, especiall0 1is a 1is t#e pullo1er b0 Duralde and CH5 ot#er officers later at ni$#t on Ganuar0 ,.t#,
.F,., and t#e suspicious and coerci1e attempts to dissuade m0 testimon0 b0 :<D Sar$ent D0e and =ea1er on
September Ct#, .F,. for t#e Trial of t#at da0 in ,. : ,.C.F %/#ic# in1ol1es t#e Nort#/ind Apartments
situation t#at 7r( Leslie is acti1e /it#in, or s#ould be, in ::.F,.HF6K*JF)( Sar$ent D0e just #appened to roll
up into an empt0 par2in$ lot I /as in at ,.:,5 am on September Ct#, .F,. /antin$ ot discuss t#e Trial in ,. :
,.C.F t#at /as to ta2e place #ours later in t#e :7( =e tal2ed about cell p#one pro1iders sellin$ G<S data to
la/ enforcement and t#e potential for abuse t#ereof b0 retaliator0 policin$ ent#usiasts, /#ic# Dane laussen
and t#e Ne1ada c#apter of t#e AL; are doin$ suc# find ad1ocac0 a$ainst:

#ttps:++ssl(cap/i&(com+aclu+issues+alert+IalertidL6,F.*5J,Mt0peLOI
sNsrcL;N=,.FFF,FFMmsL/ebNactionN$psact.N#omepa$e
#ttp:++///(aclu(or$+node+-C*F.

Spea2in$ of t#e use of force reportin$ requirements, I /onder if t#e =as#oe ount0 Gail c#arted t#e beatin$s I
endured t#ere /#ile ser1in$ ,J da0s in jail on a Soldal 1( oo2 ount0 1iolatin$ Ddisturbin$ t#e peaceD arrest b0
:<D Sar$ent =ea1er and Officer D0e after I pointed out t#at unaut#ori&ed practitionerEs of la/ %t#e0 ad1ertise
as a Dfull ser1ice e1iction consultin$ firmD) Ne1ada ourt Ser1ices and :<D Lieutenant Aro/n /#ere actuall0
/ron$ in su$$estin$ t#at one could be arrested for criminal trespass /#ere #e still #as a 1alid lease to a rental in
t#e Nort#/ind Apartments comple3, and t#at :<D Sar$ent 7iller et al /ould be un/ise to follo/ t#e tact of
Geff #andler and Ne1ada ourt Ser1ices(((?es Sar$ent 7iller et al persisted in t#reatenin$ a lease #older off t#e
propert0 /it# criminal trespass c#ar$es, on to clean it up a little a fe/ da0s later and decide to #ed$e t#eir bets a
bit more /it# a Ddisturbin$ t#e peaceD c#ar$e, /#ereupon Sar$ent D0e and Officer =ea1er s#o/ed up to an
unnoticed bail #earin$ da0s later and succeeded in $ettin$ Gill Dra2e, !sq( to 1iolate :< -(J and Ne1ada La/
in ad1ocatin$ for a bail increase %from a bondable O,,C,5 to a cas# onl0 O-,FFF) based upon Dpublic #ealt# and
safet0D rationale, /#ere Ne1ada la/ onl0 allo/s for bail to be set based upon one purpose, insurin$ t#e
defendantEs appearance at Trial(

T#en, in court t#at mornin$ /#ile a/aitin$ Trial, :<D Officer D0e $a1e ou$#lin t#e old menacin$
e3a$$erated e0e /in2 mo1e( Nice( Spea2in$ of t#at, 7r( Leslie, I am demandin$ t#at 0ou draft for m0
appro1al for filin$ a 7otion to Dismiss similar to t#e one abo1e in t#at DDA ?oun$Es omplaint lac2 a
sufficientl0 detailed specification of t#e facts support t#e elements of t#e crime c#ar$e, etc( <lease also draft a
7otion to Suppresss based upon t#e lac2 of reasonableness in ma2in$ suc# an arrest, especiall0 in t#e manner
in /#ic# it /as made, $i1en t#e ad1ance notice t#at /as pro1ided to t#e :G, =SO and :<D /it# respect to
t#e insufficienc0 of t#e 5 da0 unla/ful detainer notice in li$#t of AA ..K and t#e dictates of N:S CF(.5-, /#ic#
require t#e appropriate court to file a TenantEs Ans/er be listed on suc# an ;nla/ful Detainer Notice to @uit(
T#e Notice, /#ic# /as drafted b0 a nonHattorne0 for Ne1ada ourt Ser1ices, /#ic# commits t#e unaut#ori&ed
practice of la/, /#ic# DDA ?oun$ is enablin$) listed Spar2s Gustice ourt, rat#er t#an :eno Gustice ourt( 7r(
Leslie, I demand t#at 0ou procure and pro1ide a cop0 to me of t#e Hearin$ on t#at e1iction :G :e1.F,.H
FF,FCJ and in t#e T<O Hearin$ in :G :<.F,.HFF.JK, /#erein t#e testimon0 of 7ilan >rebs and D/a0ne
Ga2ob relates to t#eir percipient 2no/led$e of t#e facts and e1ents immediatel0 in1ol1ed in t#e arrest in
::.F,.HF6K*JF( I #a1e c#ec2ed t#e ourt records and 0ou #a1e so far failed to Order an0 of t#ese( <lease
do(

I still #a1e not #eard from eit#er of 0ou /it# re$ard to /#et#er t#e Trial in ::.F,.HF656-F at * am is 1acated
due to t#e Order for ompetenc0 !1aluation 7r( Leslie procured in ::.F,,HF6--C, on September 5t#, .F,.,
and /#et#er t#e same is true for t#e #earin$ t#at I belie1e is set for October .nd %please confirm t#is to me in
/ritin$ and pro1ide a time, in addition to a time to meet to prepare for t#at #earin$, /#ic# see2s to amend t#e
-+,F
c#ar$e to one t#at is not onl0 lac2in$ in probable cause and indicati1e of a retaliator0 prosecution, but /#ic#
/ill #a1e /orse consequences for me under S: ,,,%6), t#an /ould a $ross misdemeanor( 7r( Do$an and 7r(
Leslie, <lease repl0 in /ritin$ /it# a a citation to t#e N:S t#at pre1ents a police officer from ma2in$ a
custodial arrest after Kpm, suc# as t#e one on Ganuar0 ,Ct#, .F,., for a nonHfelon0 not committed in #is
presence( 7r( Leslie, 0ou failed to cite to t#at statute in Trial in ::.F,,HF6--C,, and seein$ as #o/ 0ou
#a1enEt filed a sin$le pa$e of an0 le$al /or2 in t#at case(((Spea2in$ of people /#o are luc20 enou$# to $et paid
for not doin$ an0 /or2:

Name !1o No1a2
<osition HI!4 IN9!STIGATO: %<D)
=as#oe ount0
Notice
4or =as#oe ount0, DTotal <a0D fi$ures include man0 pa0 cate$ories not included in t#e DAase <a0D or
DO1ertimeD fi$ures, includin$: lon$e1it0, bonus pa0, premium pa0s, allo/ances and milea$e reimbursement(
?ear .FF*
Aase <a0 OK*,5J,(6F
O1ertime and
allbac2 ollected OF(FF
Total <a0 OJF,6-,(6F
Aenefits AccumulatedO.K,*6J(KC
Total <a0 M Aenefits O,FJ,6FF(-C
7r( Leslie, I bet Larr0 arlson is $lad 0ou as2ed #im to sit in on t/o client meetin$s /it# ou$#lin /#en 0ou
m0steriousl0 decided to replace Goe Goodni$#t, !sq( after #is Ds#ado/0D remo1al from t#e case just minutes
before Trial on Gul0 ,6t#, .F,. in :G ::.F,.HF6--C,( I /ill remind 0ou, 7r( Leslie, t#at if I belie1e 0ou
are or are about to commit perjur0 upon t#e ourt I #a1e a dut0 to ta2e certain steps to address an0 suc#
malfeasance on 0our part( So,please #a1e 0our le$al assistant Linda Gra0 under subpoena and read0 to testif0 at
t#e resumption of t#e Trial on October ,5t#, .F,.(

arlson La/rence = <ublic Defender H IN9!STIGATO: II %<D)O65,K,,(CC OF(FF O,,55F(FF
O.6,**.(FK O*C,.5-(5, =as#oe ount0 .F,,

!mail:
jlunt'/as#oecount0(us
:i$#t of indi$ent defendant in state criminal case to assistance of in1esti$ators( J, A(L(:(Ct# .5* %Ori$inall0
publis#ed in ,**F)(

I am tr0in$ to t#in2 of e1en one t#in$ 7r( No1a2 or 7r( arlson, or an0 =<D In1esti$ator did on an0 of t#e
t#ree case in /#ic# 0our offices #as represented me t#is 0ear t#at /ould, 0ou 2no/, tend to furt#er t#e
Dad1ocac0D t#e 1arious public defenders #a1e put fort#(((((?ea#, I $ot not#in$( an 0ou #elp me out #ere, !1oI
an 0ou name somet#in$ besides sa0in$, a$ain: DI called t#e /itnesses and as2ed t#em if t#eir stories /ere true
and t#e0 said D0esD and so I said Dt#an2sD and t#at concluded m0 in1esti$ation, donEt tell me #o/ to do m0 job,
0ouEre not t#e boss of me(D
I li2e t#at Gerem0 Aosler, !sq( I #a1e seen some real c#an$es in #im latel0( GT loo2inE s#arp t#ese da0s( Not
man0 people 2no/ t#is, but most people 2ne/ #im as DGatorD in colle$e, and it /asnEt uncommon to #ear #im
C+,F
sa0 t#in$s li2e: DGator donEt pla0 no s#Pt( Gator ainEt ne1er been about pla0inE no s#Pt((((D( :umor is #e $ettinE
tired of tr0in$ ot ma2e c#ic2en salad out of c#ic2en s#((((/ell, 0ou $et t#e idea( Sure /ould be nice to see #is
people do a little bit better b0 #im( After all, #e #as come so far from bein$ 2no/n as t#e =as#oe ount0
District Attorne0Es D#andHpic2edD <ublic Defender, $oin$ to far as to pull #is la/0ers out of t#e Si3t#
Amendment questionable !arl0 ase :esolution pro$ram %!:) in 4ebuar0 of .FFJ(

#ttp:++///(aclun1(or$+press+acluHne1adaHpetitionsHne1adaHsupremeHcourtHpro1ideHamicusHsupportH!:H
c#allen$e

Aut, a lot of #is accomplis#ments do sound 2ind of Dsocial /or2DHesque, rat#er t#an s#orin$ up, sa0, t#e offices
practices to counter retaliator0 prosecutions and arrests, prosecutor misconduct, protectin$ defendantEs pri1ac0
ri$#ts %no sa0in$ an0 names no/((((but Aira0 Do$an li2es to read 7ental Healt# ourt patients prescriptions
into t#e open record in a public courtroom full of fort0 members of t#e public after /ee2s of tal2inE up t#e
e3treme pri1ac0 safe$uards and HI<AA t#isEnEt#at of t#e 7H pro$ram, t#en Aosler and Do$an refuse to see2
to sri2e or ot#er/ise ameliorate Do$anEs bone #ead mo1e(((unless, it /as a retaliator0 mo1e t#at /as actuall0
rat#er premeditated((((#mmmn(((()( 7r( AoslerEs social /or2 includes a len$t#0 list of ac#ie1ements, its just t#at
not man0 of t#em #a1e an0t#in$ to do /it# sa0, e3pandin$ t#e scope of, sa0 Terr0, or utili&in$ t#e import of
Soldal 1( oo2 ount0, or de1elopin$ approac#es to combat all t#e preHte3tual police /or2 $oin$ on amon$st
local la/ enforcement( :at#er, most of #is Daccomplis#mentsD seem to stem from a place of 1ie/in$ t#e
defendant as $uilt0 and un#ealt#0 and, if #e is reall0 luc20, $ettin$ into some Dalternati1eD forum to a1oid t#e
clobberin$ t#e defendant /ould face upon facin$ attorne0s /it# t#e =DA /#o #a1e Dbrief ban2sD and stuff:

;nder 7r( AoslerQs direction, t#e =as#oe ount0 <ublic DefenderEs Office #as #ad man0 accomplis#ments
includin$:
:ene$otiatin$ a dru$ e1aluation contract to maintain uniform qualit0 of e1aluations produced and create cost
certaint0
Installed Lan$ua$e Line in office to pro1ide immediate telep#onic access for clients and t#e public to ,5F
different lan$ua$e interpreters
!stablis#ed a formal Interns#ip <ro$ram /it#Ao0dLa/Sc#ool to attract and retain Ne1ada students in <ublic
Interest la/
reated a ount0 Ser1ices+ommunit0 Information 2ios2 in office to assist clients and public
<ro1ided speciali&ed trainin$ to t#e :eno <olice DepartmentQs risis Inter1ention Team on identif0in$ mental
#ealt# issues and accessin$ mental #ealt# ser1ices to reduce jail o1ercro/din$
Accepted appointment to t#e Supreme ourt Aenc# Aar ommittee to e1aluate and impro1e appellate court
processes and practice
Assisted in de1elopment of standardi&ed pleadin$s and procedures in criminal competenc0 e1aluations to
en#ance an accused personRs abilit0 to recei1e treatment to/ards competenc0
Initiated participation in t#e Gu1enile Detention Alternati1es Initiati1e %GDAI) /it# t#e =as#oe ount0
Department of Gu1enile Ser1ices
!stablis#ed ,HJFF line for toll free communication b0 outHofHstate clients and /itnesses
Our future $oals include:
Arin$ attorne0 caseloads into compliance /it# nationall0 recommended standards
Implement projects to compl0 /it# t#e Adoption and Safe 4amilies Act %AS4A)
Institute an effecti1e le$islati1e ad1ocac0 pro$ram /it# <ublic DefenderEs Offices state/ide
De1elop a La/ :elated !ducation %L:!) pro$ram for local ju1enile population
<articipate in electronic data s#arin$ t#rou$# eHfilin$ and a 7ultiHount0 Inte$rated Gustice Information S0stem
%7IGIS)
<ro1ide communit0 outreac# pro$rams to e3plain t#e mission and ser1ices of t#e =as#oe ount0 <ublic
5+,F
DefenderEs Office

To /it, =<D Goe Goodni$#t, !sq( li2es to tout t#e SOLA! <ro$ram and a D#olisticD approac#, just as lon$
as t#e actual criminal defense t0pe stuff %0ou 2no/ le$al resarc#, fact $at#erin$, spinnin$ on a le1el some/#at
commensurate to /#at 0ou 2no/ t#e DA is /illin$ to do) is t#e Ddonut #oleD part of t#e D#olisticD banquet of
social /or2 t#e public defender currentl0 pro1ides( =#0, I t#in2 it /as Gennifer :ains, !sq( /#o announced at
t#e 7ental Healt# ourt orientation t#at Dt#e Gud$e doesnEt /ant to #ear an0t#in$ I #a1e to sa0, #e /ants to #ear
from 0ouSD( Great( So t#at e3plains /#0 t#e0 are $i1in$ 0ou OJF> and bennies( T#en Goodni$#t admits t#at,
despite bein$ at t#e =<D for J 0ears defendin$ misdemeanors, #e /as una/are of t#e deadline to file an
appeal upon a con1ictio of suc# a c#ar$e, under N:S ,J*(F,F( O#( He also admitted #e /as una/are t#at t#e
=as#oe ount0 La/ Librar0 #ad free =estla/ access( I mean, Le3is is just so solid, 0ou 2no/(

T#en t#ere is Aira0 Do$anEs commentar0 on t#e prospect of actuall0 filin$ some le$al /or2 to c#allen$e t#e
sufficienc0 of a omplaint b0 Dlets t#ro/ some mud up and see /#at stic2sD DDA "ac# DNorman Nifon$D
?oun$, !sq(, /#om li2es to brin$ up t#e accusedEs Dcustod0 statusD out of t#e blue for no discernible reason
ot#er t#an it sure is a lot easier for #im to compete a$ainst someone /#en t#e0 are loc2ed up, and subject to all
t#e depri1ations of oneEs access to justice t#at t#e =as#oe ount0 Detention enter so, so 1er0 $ood at(
Do$anEs comments /ere: DcanEt t#e DA just prett0 muc# sa0 /#ate1er in t#e omplaint and c#an$e it /#ene1er,
and not #a1e to meet an0 sort of pleadin$ standard or notice requirements li2e t#ose I /ent to la/ sc#ool to
learn aboutID(

On t#at note, Aira0:

T ,,F( #ar$in$ particular mode of commission
=estEs >e0 Number Di$est
=estEs >e0 Number Di$est, Larcen0 2.J%,), -C, -5 to -*
A $eneral rule of criminal pleadin$ is t#at if an offense ma0 be committed in 1arious modes, t#e part0 c#ar$ed
is entitled to #a1e t#at mode stated in t#e indictment /#ic# is to be pro1ed on t#e trial,U4N,V and t#is rule #as
been applied in larcen0 prosecutions(U4N.V T#e 7odel <enal ode states t#at an accusation of t#eft ma0 be
supported b0 e1idence t#at it /as committed in an0 manner t#at /ould be t#eft under t#e ode Article on t#eft,
not/it#standin$ t#e specification of a different manner in t#e indictment or information, subject onl0 to t#e
po/er of t#e court to ensure fair trial b0 $rantin$ a continuance or ot#er appropriate relief /#ere t#e conduct of
t#e defense /ould be prejudiced b0 lac2 of fair notice or b0 surprise(U4N-V
=#ere an act /#ic# /as not larcen0 at common la/ is made larcen0 b0 statute, it is not sufficient to c#ar$e t#e
commission of larcen0 merel08 rat#er, t#e indictment s#ould state t#e particular act specified b0 statute as
constitutin$ t#e crime(U4NCV Similarl0, an indictment in t#e commonHla/ form is $enerall0 insufficient in a
prosecution for t#e larcen0 under a statute(U4N5V
On t#e ot#er #and, it #as been #eld t#at in a prosecution for larcen0 it is not necessar0 t#at t#e manner in /#ic#
stolen propert0 /as ta2en and carried a/a0 be alle$ed, and t#e /ords Db0 tric2D are not required in an
indictment c#ar$in$ larcen0 /#en propert0 /as obtained b0 tric2 or fraud(U4N6V A statute ma0 e3pressl0
remo1e t#e requirement t#at a larcen0 indictment specif0 t#at t#e defendant committed larcen0 in an0 particular
manner, e3cept in certain stated cases(U4NKV
<ractice Guide:
=#en t#e manner of t#eft is not an element of t#e offense, and t#e information does not so specif0, t#e
information and disco1er0 materials presented to t#e defendant ma0 adequatel0
place #im or #er on notice of t#e manner of t#eft(U4NJV
6+,F
T#e rule t#at, /#en a statute c#aracteri&es an offense in $eneric terms merel0, an information c#ar$in$ t#e
offense must state t#e specific acts on /#ic# t#e c#ar$e is based applies to larcen0 prosecutions(U4N*V
Ho/e1er, in prosecutions under suc# a statute, t#ere is no necessit0 of a detailed specification in c#ar$in$ an
ordinar0 t#eft of propert0(U4N,FV
U4N,V Am( Gur( .d, Indictments and Informations T ,,-(
U4N.V 7iller 1( State, 65C S(=(.d KC, %Te3( App( Houston ,Ct# Dist( ,*J-)(
U4N-V 7odel <enal ode T ..-(,%,) %.FF,)(
U4NCV ;(S( 1( Nort#/a0, ,.F ;(S( -.K, K S( t( 5JF, -F L( !d( 66C %,JJK)(
U4N5V State 1( Gac2son, .,J N(( -K-, ,, S(!(.d ,C*, ,-, A(L(:( ,C- %,*CF)(
U4N6V State 1( Aarbour, ,5- N(( App( 5FF, 5KF S(!(.d ,.6 %.FF.)(
U4NKV <eople 1( Norman, 6 7isc( -d -,K, KJ* N(?(S(.d 6,- %Sup .FFC)(
U4NJV om( 1( S#amber$er, .FF, <A Super -5,, KJJ A(.d CFJ %.FF,)(
U4N*V State 1( >esterson, CF- S(=(.d 6F6 %7o( ,*66)(
U4N,FV State 1( 7iles, C,. S(=(.d CK- %7o( ,*6K)( 1( Ganuar0, ,K6 S(=(-d ,JK %7o( t( App( =(D( .FF5)(
U4NKV 7odel <enal ode T ..-(,%-) %.FF,)(

So, DDA Norman Nifon$ is c#ar$in$ ou$#lin /it# Dpett0 larcen0D, and, on t#e same set of facts %not t#at
Norman actuall0 set fort# in an0 specificit0 /#atsoe1er in #is omplaint an0 actual facts) /it# recei1in$ stolen
propert0:
T ,,,( Goinder of ot#er offenses8 election
=estEs >e0 Number Di$est, Larcen0 2.J%,), .J%C)
A(L(:( Librar0
<articipation in larcen0 or t#eft as precludin$ con1iction for recei1in$ or concealin$ t#e stolen propert0, .*
A(L(:(5t# 5*(

No/, 0ou can lead a Gim Leslie, !sq( to precedent and le$al ar$ument, but 0ou canEt ma2e #im ad1ocate
&ealousl0 on a defendantEs be#alf, can 0ouI 7r( 7ar1ic2 2no/s /#at IEm tal2inE Ebout(

ou$#lin /as represented b0 Le/ Taitel, !sq( in a criminal trespass matter in :eno 7uni ourt, ,, : .6CF5,
/#ere ou$#lin /as con1icted of trespass at #is former #ome la/ office despite t#e :G impermissibl0 ta2in$
O.,.K5 Drent escro/D from ou$#lin %t#ere is no L9G: CC in :eno Gustice ourt) durin$ t#e pendec0 of a
summar0 e1iction proceedi$n of a commercial tenant /#ere t#e nonHpa0ment of rent /as neit#er pled nor
alle$ed, in 1iolation of N:S CF(.5-, and /#ere Taitel %/#om is no/ emplo0ed in t#e !: pro$ram b0 =as#oe
Le$al Ser1ices, /#om ou$#lin is suin$ for /ron$ful termination after =LS fired domestic 1iolence attorne0
ou$#lin, <aul !lcano, !3ecuti1e DirectorEs /ords, based sole0 on a O,,FFF attorne0Es fee sanction 4amil0
ourt Gud$e Linda Gardner sanctioned ou$#lin /it# personall0 in a di1orce Trial, /#ereupon ou$#lin filed a
<etition for =rit of 7andamus to c#allen$e t#e sanction:
#ttp:++caseinfo(n1supremecourt(us+public+case9ie/(doIcsIIDL..KC6

Aut, despite t#e fact t#at #e is #er brot#er, :eno 7unic( ourt Gud$e =illiam Gardner refused to recuse #imself
from t#e criminal trespass matter a$ainst ou$#lin( 4urt#er, Gud$e =( Gardner admitted t#at #e #ad just da0s
prior passed alon$ #is sisterEs April .FF* sanction Order to :7 Gud$e Nas# Holmes %/#om, li2e all Gud$es
/it# t#e :7 and all court appointed defenders /it# t#e :7, is a former prosecutor), /#o promptl0 struc2
ou$#linEs Notice of Appeal of a summar0 contempt Order b0 Gud$e Nas# Holmes stemmin$ from a traffic
citation in connection /it# ou$#linEs e1iction b0 :ic#ard G( Hill, !sq( from #is former #ome la/ office %at
/#ic# TaitelEs business partners, Dprocess ser1in$, full ser1ice e1iction consultin$ firmD

K+,F

;#, so, $i1en t#at t#at sort of en1ironment is /#at indi$ent criminal defendants %e1en t#ose /it# a la/ de$ree,
and, sometimes, a la/ license, dependin$) are deali$n /it#, per#aps t#e qualifications t#at Gim Leslie, !sq(
touted as e1inced b0 Gerem0 Aosler in #is impressions of #im, are not all t#at useful( Leslie /rote in .FF5: DI
belie1e #e #as in mind t#e truest interests of t#e <ublic DefenderEs Office and t#e public at lar$e, and t#at #e
possesses a mature, realistic 1ie/ of t#e role in our societ0 of a <ublic Defender and a <ublic DefenderEs
OfficeD(

=#en 0ou are $oin$ up a$ainst a bloodsportinE, adrenaline jun20, DNorman Nifon$D %/#om tac2il0 sa0s t#in$s
at Trial li2e D?our Honor, I donEt #a1e a do$ in t#at fi$#t, so /it# respect to t#at 7otion I /ill refrain from((((D
A Ddo$ in t#at fi$#tDI Li2e a criminal prosecution is a do$fi$#t, li2e a Dbad ne/& 2ennel&D ille$al do$ fi$#t to
t#e deat# t0pe t#in$(((() /#o /ill $lad0 de1ote at least ,C mont#s of public resources in see2in$ a pett0
larcen0+recei1in$ stolen propert0 con1iction of an attorne0 % in :G ::.F,,HF6--C,, State 1 ou$#lin) /#o
is accused of retrie1in$ a p#one from someone /#om found it lost, mislaid, or abandoned on t#e $round at a
s2ate pla&a at ,, pm in do/nto/n :eno and #eld it aloft and loudl0 e3claimed to all present t#at #e /ould
Dt#ro/ t#is p#one in t#e ri1er if someoneD did not claim it ri$#t a/a0 %testimon0 alread0 admitted to at t#e still
on$oin$ Trial b0 t#e prosecutionEs o/n /itness)( T#is, e1en /#ere t#ere e3ists, and /as pro1ided to t#e
prosecutor, an e3culpator0 1ideo of t#e e1ents prior to and t#e arrest itself, /#erein :<D Officers are clearl0
depicted be#a1in$ in a retaliator0, preHte3tual manner, and /#ere t#ere is more t#an a stron$ su$$estion t#at
some Dcreati1e remi3in$D of t#e facts and timelines is bein$ put for/ard b0 t#e :<D %suc# as o1er1aluin$ a
t#ree 0ear old i<#one sufficient to c#ar$e ou$#lin /it# felon0 $rand larcen0 and t#erefore $et around t#e
statutor0 dictates of No Norman Nifon$( T#atEs a bad Norman Nifon$( I /is# somebod0 /ould tell me /#en
m0 friend "? comes bac2, because I donEt 2no/ #o/ muc# more of t#is Norman Nifon$ cat I can stomac#( 7r(
Leslie, I donEt 2no/ #o/ useful #a1in$ a mature, measured indi1idual as <ublic Defender /ould be under t#ose
conditions( ?ou mi$#t need to #a1e someone /#o is more t#an /illin$ to $et do/n in t#e sandbo3 and pla0
patt0 ca2e /it# /#oe1er /ant it( Oran$e /ed$e( Guicebo3( 4ruit :ollH;p( 7otion to Suppress(

N:S ,K,(,.C Arrest b0 peace officer (
,( ((( a peace officer ma0 ma2e an arrest in obedience to a /arrant deli1ered to #im or #er, or ma0, /it#out a
/arrant, arrest a person:
%a) 4or a public offense committed or attempted in t#e officerEs presence(
%b) =#en a person arrested #as committed a felon0 or $ross misdemeanor, alt#ou$# not in t#e officerEs presence(
%c) =#en a felon0 or $ross misdemeanor #as in fact been committed, and t#e officer #as reasonable cause for
belie1in$ t#e person arrested to #a1e committed it(
%d) On a c#ar$e made, upon a reasonable cause, of t#e commission of a felon0 or $ross misdemeanor b0 t#e
person arrested(D

?es, Aira0, 0ou s#ould still ar$uin$ t#at statute e1en t#ou$# t#e DA c#ar$ed ou$#lin /it# t#e $ross
misdemeanor of D7isue of *,,D as ou$#linEs alle$ed callin$ *,, to report #is fear re$ardin$ retaliaton b0 :eno
<olice Department Officers for ou$#linEs complainin$ about t#eir earlier misconduct 1itiates an0 Dreasonable
causeD findin$, clearl0, especiall0 $i1en t#e 1oluminous e1idence of retaliation and misconduct b0 just a couple
members of t#e :<D to/ards ou$#lin since Au$ust .F,,(

T/o offenses committed b0 t#e same person ma0 be included in t#e same indictment, in different courts, /#ere
t#e0 are of t#e same $eneral nature and belon$ to t#e same famil0 of crimes and /#ere t#e mode of trial and
nature of t#e punis#ment are also t#e same, alt#ou$# t#e0 ma0 be punis#ed /it# different de$rees of se1erit0(
U4N,V T#us, indictments c#ar$in$ one count of $rand larcen0 in t#e second de$ree and multiple counts of
J+,F
commercial bribeHrecei1in$,U4N.V or t#e offenses of larcen0 and of recei1in$ stolen $oods,U4N-V ma0 be
proper(
aution:
Since t#e crimes of larcen0, recei1in$, and possession of stolen propert0 are separate and distinct offenses,
$enerall0 le$islatures do not intend to punis# a defendant for recei1in$ or possessin$ t#e same $oods t#at #e or
s#e stole( T#erefore, t#ou$# a defendant ma0 be indicted and tried on c#ar$es of larcen0, recei1in$, and
possession of t#e same propert0, t#e defendant ma0 be con1icted of onl0 one of t#ose offenses(U4NCV
U4N,V Am( Gur( .d, Indictments and Informations TT .FF to .FC( U4N.V <eople 1( Sil1erman, ,F6 7isc( .d C6J,
C-C N(?(S(.d -,* %Sup ,*JF)( U4N-V Lo$an 1( om(, -,* S(=(.d C65 %>0( ,*5J)(
U4NCV State 1( <err0, -F5 N(( ..5, .JK S(!(.d J,F %,*J.)(

A( Indictment, Information, or omplaint
.( <articular Alle$ations
a( In General
Topic Summar0 orrelation Table :eferences
T ,,-( Generall0
=estEs >e0 Number Di$est, Larcen0 2.J%,), .J%.)
An indictment for t#eft must disclose t#at propert0 alle$ed to #a1e been stolen /as subject to t#eft8 t#e
indictment is defecti1e if it s#o/s on its face t#at t#in$ alle$ed to #a1e been stolen /as propert0 not subject to
t#eft(U4N,V
An indictment t#at insufficientl0 alle$es t#e identit0 of t#e 1ictim in a c#ar$e for larcen0 is fatall0 defecti1e and
cannot support a con1iction of eit#er a misdemeanor or a felon0(U4N.V
U4N,V Aourland 1( State, ,-- Te3( rim( 5CC, ,,. S(=(.d K.F %,*-K)( As to t#e sufficienc0 of an indictment in
commonHla/ form /#ere prosecution is for
larcen0 of a t#in$ /#ic# is t#e subject of larcen0 onl0 b0 1irtue of a statute, and not at common la/, see T *6(
U4N.V State 1( Norman, ,C* N(( App( 5JJ, 56. S(!(.d C5- %.FF.)(

;ntil t#e0 stop me, bur0, murder me, or drop me,

"ac# ou$#lin, !sq(
To "ac# ou$#lin
4rom: Leslie, Gim %Gleslie'/as#oecount0(us)
Sent: Tue *+FC+,. C:55 <7
To: "ac# ou$#lin %&ac#cou$#lin'#otmail(com)
7r( ou$#lin:

I #ad e3pected to #ear from 0ou after last =ednesda0Qs close of proceedin$s, so /e could /or2 on trial issues
and prepare 0ou in case 0ou testif0 at t#e trial, but t#is email from 0ou is t#e first communication since last
=ednesda0( Aased on 0our acrimonious temperament to/ard 0our assi$ned counsel, includin$ me, I doubt 0ou
/ould #a1e participated meanin$full0 in an0 suc# preparation efforts, but I /ould #a1e been /illin$ to tr0, as I
*+,F
#a1e done before( I /is# 0ou /ould #a1e communicated /it# me earlier(

Games A( Leslie, !sq
"ac# ou$#lin
<O AOB -*6,
:eno, N9 J*5F5
Tel KK5 --J J,,J
4a3 *C* 66K KCF.
"ac#ou$#lin'#otmail(com
,F+,F
LITIGATION HOLD NOTICE AND SUBPOENAyour 11 7 11 response to discovery request in rjc rcr2011-063341
unbelievable. U.S. v. Gatto, 727 F. Supp. 903 (D.N.J. 1989). Even if a witness testifies as to a period during which he was under the influence of drugs, a jury is entitled to
believe the witness and can discount the testimony as it sees fit. U.S. v. Bailey, 510 F.3d 726 (7th Cir. 2007).
[FN13] Patterson v. State, 181 Ga. App. 68, 351 S.E.2d 503 (1986).
[FN14] Crewe v. Blackmon, 289 S.C. 229, 345 S.E.2d 754 (Ct. App. 1986).
The trial court has the discretion to reject testimony of biased witnesses. State v. Rus
sell, 92 N.C. App. 639, 376 S.E.2d 458 (1989).
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Fri 9/21/12 12:02 AM
To: newmanp@reno.gov; renodirect@reno.gov
ATTENTION, THIS IS A LITIGATION HOLD NOTICE; YOU MAY BE REQUIRED TO HOLD ANY AND ALL DOCUMENTATION, RECORDINGS,
REPORTS, 911 AND OR DISPATCH CALLS, VIDEOS, ETC. INVOLVING ZACHARY BARKER COUGHLIN IN ANY WAY IN LIGHT ON
ANTICIPATED FUTURE LITIGATION IN CONNECTION WITH ANY INVOLVEMENT WITH ZACHARY BARKER COUGHLIN AND LOCAL AND
STATE LAW ENFORCEMENT AGENCIES, INCLUDING THE RENO POLICE DEPARTMENT, WASHOE COUNTY SHERIFF, WCDA, CITY OF RENO
CITY ATTORNEY'S OFFICE, ETC. PLEASE RETAIN AND FORWARD A COPY OF ANY SUCH MATERIALS ON TO THIS EMAIL ADDRESS OR
THE FOLLOWING ADDRESS FOR ZACHARY BARKER COUGHLIN:
PO BOX 3961
RENO, NV 89505
TEL:775 338 8118
FAX:949 667 7402

Dear Ms. Newman,

Please respond fully, and as required under the law to the Request for Discovery and subpoenas you were served, not merely asking the officers if they recorded anything and checking
to "see if something was booked into evidence". Read the Request for Discovery very, very carefully, Ms. Newman, and the subpoenas.

If your case then involves a 911 call you may have to trace the source.
Example:
A driver calls in an injury accident on her cell phone from a city street in San Mateo.
The call will be routed to the CHP dispatch center in Vallejo and put on hold. Once answered and recorded by CHP dispatchers, the call will be transferred to the San Mateo
Police Department.
Only then will San Mateo Police dispatch determine the nature of the call to dispatch a San Mateo Police officer to the scene.
The call may also be transferred again to Fire Department response and Ambulance.
Result for the Lawyer:
Given this present circumstance the record keeping for the call may be in a variety of locations. The CHP dispatch may have the only record of the original call. Frequently this
original caller is a witness to the accident but is not necessarily a witness who is later identified in the subsequent police report.
2. Distinctions between local land line 911 system and CHP 911 system
Keep in mind that the local 911 system is generally superior to the wireless CHP 911 system on a variety of fronts.
Local System
a. The land-line is rarely overloaded for call delays.
b. The system has a direct link to the address source of the call. This is usually one of the methods a dispatcher/supervisor can use to run a search related to calls generated from a
particular residence over a historical period of time or phone number to answer an inquiry or subpoena.
c. Rarely does the system pass the call on to another agency outside the city from which the call is generated so tracking is less of an issue.
CHP System
a. The single advantage is that by nature it is wireless.
b. System is seriously overloaded.
c. The content and quality of materials contained within the call log is likely to be far more limited than that of a local 911 system.
d. If the CHP dispatcher was not successful in obtaining the name and contact information from the original caller the lawyer will be gifted with another layer of red tape and
subpoenas to obtain the personal information of the caller.
e. CHP is likely to be a by the book organization whereas you may find that local agencies may be somewhat more relaxed in following strict guidelines related to the release of call-
log information.
C. State Requirements for Record keeping: the voice-call and the log-entry
1. Audio voice 911 call:
California Government Code 26202.6 and 34090.6 audio recordings including the 911 system may be destroyed after 100 days.
2. 911 Call Log:
34090.6 of the Government Code appears to be interpreted by local law enforcement as authority to destroy 911 logs after 2 years.
Result for the lawyer:
Each agency is functioning by their own standard operating procedure. Therefore it must be addressed on a case-by-case basis and one must presume the records must be obtained
immediately.
Examples of local law enforcement record retention:
San Francisco Police Department
Voice call 3 years (but started in March of 2005)
Call Log 3 years
San Rafael Police Department
Voice call 180 days
Call Log Permanent (they retain records indefinitely)
San Jose Police Department
Voice call 14 months
Call Log 7 years
Lessons Learned:
a. Value Immediately determine value of the voice call and call log(s).
b. Notice Put the agency on notice by letter and phone call that both the voice call(s) and call log(s) are maters of present or future litigation and they are required to retain those
records for the entirety of the litigation process per. California Government Code Sections 26202.6 and 34090.6.
b. Preservation Get those records in hand as quickly as possible to ensure their preservation.
D. The law and privacy / confidentiality considerations
1. The subpoena request
Generally, I have found that law enforcement agencies will not contest the request for records from an interested party in a filed case when the record request addresses the specific
instances of the litigation in question. However, if you are asking the agency to produce records for a range of dates or calls privacy issues could arise.
Example of Subpoena Language:
Please provide copies of all 911 logs generated from the address of 13 Satan Way, Fontana, CA 92335 from May 4, 2004 to the present.
wrongful arrests, malicious/retaliatory prosecutions FW: Reno eviction noticed for Sparks Justice Court
2. The mixed results
Making an all inclusive broad brush request can potentially get complicated if the source address has residents who are not named parties to the litigation; such as a nursing home with
multiple residents. Other residents who are non-parties may be calling the 911 for reasons that are completely unrelated to your case. Again, this is a case by case basis and the product
you receive will largely be based on the systems being used, the skill of the person making the search and what internal protocols they may be following before they release the
documents requested.
Sit back and wait for the result.
3. Statutory considerations
In enacting this chapter, the Legislature, mindful of the right of individuals to privacy, finds and declares that access to information concerning the conduct of the peoples
business is a fundamental and necessary right of every person in this state Government Code Section 6250.
4. California Public Records Act and the balance between public need and confidentiality
Judicial decisions interpreting the California Public Records Act (CPRA) seek to balance the public right to access to information, the governments need, or lack of need, to
preserve confidentiality, and the individuals right to privacy. Copley Press, Inc. v. Superior Court (2006) 48 Cal.Rptr.3d 183, 39 Cal.4th 1272, 141 P.3d 288, on remand 2006 WL
3190280, unpublished.
5. Burden is on the Agency
California Public Records Act (CPRA) exemptions are to be narrowly construed, and the government agency opposing disclosure bears the burden of proving that one or more apply
in a particular case. County of Los Angeles v. Superior Court (Axelrad) (App. 2 Dist. 2000) 98 Cal.Rptr.2d 564, 82 Cal.App.4th 819, review denied.
E. Approach to Subpoena 911 call logs
The basics
1. What am I after and why do I want it?
2. Call the dispatch center, ask for the custodian of records and follow the procedures outlined above.
a. I am not on the dark side (sound familiar?)
b. We have a common interest to get the bad guy.
c. Get them emotionally involved.
d. Can you please help me?
e. I know I need to write a subpoena can you tell me how you want it to read to make it easier on you and make sure that I am getting what I need.
f. Tell them it is going in the mail today.
g. Address it to that person.
h. You will get what you want because the person on the other end likes to hammer bad guys too.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Tue 9/11/12 1:30 PM
To: jleslie@washoecounty.us; bdogan@washoecounty.us; zyoung@da.washoecounty.us; mkandaras@da.washoecounty.us; bsooudi@reno.gov; sooudib@reno.gov;
drakej@reno.gov
2 attachments
filings.pdf (1058.4 KB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Date: Mon, 2 Jul 2012 17:21:54 -0700


NRS 207.200, RMC 8.10.040.

6

U.S. Supreme Court
SEVENTH CIRCUIT
No. 91-6516
Held:
I
[2]
[3]

[4]
[5]

and now reverse.
[6]
[506 U.S. 56, 61]
II
[7]
350 .
III
violation. [506 U.S. 56, 72]
federal courts.
IV
So ordered.
Footnotes
(1st Dist. 1987).
banc).
context.
opinion. [506 U.S. 56, 73]

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

Date: Tue, 26 Jun 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Date: Tue, 26 Jun 2012 07:58:36 -0700
(Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
please note my new address if it has not already been noted
motion for preparation of transcript at public expense etc
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
Civil
Evictions
Small Claims
Sent: Sat 9/08/12 2:00 PM
To: renomunirecords@reno.gov
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Tue 8/07/12 11:42 PM
To: hazlett-stevensc@reno.gov; kadlicj@reno.gov; drakej@reno.gov
1 attachment
IMAG0569 motion for preparation of transcript at public expense and opposition to motion to dismiss rmc 11cr26405.jpg (2.8 MB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Tue 8/07/12 11:01 PM
To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
6 attachments
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
global resolution
Date: Fri, 8 Jun 2012 16:41:49 -0700
Sincerely,
Zach Coughlin
Sent: Mon 8/06/12 4:45 PM
To: jleslie@washoecounty.us; zyoung@da.washoecounty.us; mkandaras@da.washoecounty.us; kadlicj@reno.gov; christensend@reno.gov
Dear Mr. Leslie, DDA Young, DDA Kandaras, and City Attorney Kadlic, and Deputy City Attorney Christensen,
Will you please confer with DDA Young and, perhaps, DDA Kandaras (I believe she is the appropriate attorney to discuss
resolution of any potential civil claims with, as well as, perhaps, City Attorney Kadlic or Deputy City Attorney Christensen given the
August 20th, 2011 arrest in RCR 201-063341 was made by a RPD Officer and that there is potentially an issue of misconduct/a Fourth
Amendment Violation that could arise at trial if the issue of whether the officer reached into the accused's pocket, prior to the technical point
of arrest, to turn on the cell phone, for the purpose of calling it an applying a "plain sight or feel or sound" approach to finding probable
cause to arrest for a misdemeanor allegedly occurring outside the officer's presence, after 7 p.m., and to therefore conduct a search
incident to arrest. I would greatly appreciate an opportunity to avoid having those issues come up on the record at Trial, or ever....
Mr. Leslie, I would appreciate it if you would confer with the above listed attorney's as to whether the proposed plea agreement I wrote of
recently is acceptable (it basically amends the previous plea agreement by including a waiver on my part of any civil causes of action that I
may have against the various governmental entities potentially liable in connection with any of those three arrests in exchange for excising
from the previously proposed plea agreement those portions suspending a sentence and requiring the defendant to "obey all laws". I wrote
previously:
"I am fairly opposed to resolutions of the criminal matters that include any "obey all laws" and "180 days suspended sentence" types of
conditions, not because I think the prosecutors or the system is unreasonable, but...well, I have upset a good number of members of law
enforcement and I may wish to leave the area for an extended time (only if legally allowed to do so), and for the same reasons (and because
I already have two convictions) I would prefer not to go into Mental Health Court (though I greatly respect Judge Breen), in addition to
some other more personal reasons that relate to my father, whom I love. However, my whole life has been somewhat of a Mental Health
Court or diversion program with my Dad in it, as he has been involved in physician diversion programs for those with mental health
problems and substance abuse issues, and that has resulted in a tough love approach for years, taken to an extreme, which, at times, has
seemed to complicate, if not derail entirely, my attempts to address the various issues that I face."
I would prefer not to get too into it, but the situation with my Dad is somewhat like that seen in Christian Scientist families. When I say
"tough love", I am not referring to, lets say, hypothetically, a physician parent not giving one a temporary loan when one's girlfriend of five
years steals a couple months rent from him. I am referring to such a parent harassing one for years, pulling prescription records in
violation of privacy laws, demanding to commandeer one's approach to treating ADHD and/or depression or treatement resistant depression,
calling up State Bars and Dean of Law Schools with his "diagnosis", criticizing anyone and everyone who drinks alcohol ever as a "drunk",
implementing manipulative tactics reminiscent of the Duluth Model of the "Power and Control Wheel" commonly found in the domestic
violence literature, Munchausen by Proxy, just generally being a control freak as most all physicians are, bad mouthing one professionally
for years from a bully pulpit, calling up one's domestic partners and convincing them to leave one while unduly influencing them via the
"MD effect", alienating one from all other family members by means of financial control incident to a punishment reward apparatus applied
to the family on a large scale, etc., etc., and just basically viewing one's offspring in narcissistic personality disorder style that sees them as
an extension of one's ego rather than separate, distinct human beings capable of and entitled to makes their own choices about things, ("oh,
you take that medication for ADHD, well, I am an AA bleeding deacon and don't care if you haven't had a drink or drug in 6 years, I am
going to systematically and proactively-"letting you have your pain"- destroy your life in any and every way I can until I bring you the
"incomprehensible demoralization" cited in the Big Book of Alcoholics Anonymous so necessary, in my opinion to rebuilding you in my
own image, er, I mean, to your recovery")... etc., etc...
I am going to have plenty of mental health oversight regardless of whether I go into Mental Health Court or whether I have a suspended
sentence hanging over my head, and I have a great many reasons to obey all laws. Please consider that the August 20th, 2011 arrest
occurred just days after I was first threatened with a summary eviction from my former home law office by a veteran commercial litigator,
that I spent nearly 7 days in jail in connection with it, and lost some money and clients while in jail in addition to sustaining some other
significant financial damages. Then, just some 13 days after being release from jail on August 26th, 2011, I was arrested and subsequently
convicted of petty larceny in RMC 11 CR 22176, which I reported to the State Bar of Nevada under SCR 111 and the United States Patent
11 CR 26405 and appeal in CR12-1262: Notice of RMC's failure to file timely filed Notice of Appeal resulted in
dismissal of Appeal in CR12-1262
and Trademark Office under 37 CFR 11.24 and 11.25, resulting in the suspension of my law license and reports of that conviction and
suspension running in numerous newspapers and television news reports in light of an Associated Press article on it. I realize many would
consider the chances of any civil claims I may bring to be very thin, but please consider any benefit that would inure to your organizations
and or law enforcement as a whole incident to my waiver of any such claims in exchange for this amended plea agreement as well as
whether you might, per chance, take some pity on me and forgive me for my inappropriate behavior this past year.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Mon 8/27/12 4:49 PM
To: hazlett-stevensc@reno.gov; kadlicj@reno.gov; drakej@reno.gov
3 attachments
cr12-1262 motion to set aside order dismissing appeal.pdf (141.2 KB) , notice filing in 11 cr 26405 complete to file on 8 27 12.pdf (198.6 KB) , ex 1 to motion to set
aside dismissal cr12-1262 bw.pdf (2.7 MB)
11 CR 26405 and appeal in CR12-1262: Notice of RMC's failure to file timely filed Notice of Appeal resulted in dismissal of Appeal in CR12-1262
also please find motion to reconsider, alter, amend, set aside, etc. the recent order dismissing the appeal in cr12-1262.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Close Print
FW: Reno eviction noticed for Sparks J ustice Court
Sent: Mon 8/06/12 3:55 PM
To: keithloomis@earthlink.net; kadlicj@reno.gov; drakej@reno.gov
2 attachments
coughlin v northwind 16_TenantsAffidavit_DeclarationOther_PrivateHousing other than nonpayment of rent.pdf (76.3
KB) , combined northwind v coughlin eviction filings.pdf (1058.4 KB)
please view this in conjunction with the email I just sent.

Sincerely,

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

To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us;
stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com; info@acg-apmi.com; rjcweb@wasoecounty.us;
jboles@callatg.com; apminfo@acg.com
Subject: FW: Reno eviction noticed for Sparks J ustice Court
Date: Mon, 2 J ul 2012 17:21:54 -0700
NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on J uly 29th, 2012"...giving
me five days to get my stuff out of unit 29 (the one the subject of J udge Schroeer's Eviction Order, which was effectively
rescinded by their serving a new 5 day unlawful detainer notice....) as well as units 71 and 45...whicih are two units to which i
still have valide lease agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated they will arrest
me for criminal trespass for accessing any units in the complex, including those to which I still have a valid possessory or
property interest, in violation of 42 usc 1983).

why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel" good looks and a much
higher paying job than I will ever have? What up wit that?

Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed up and put "Sparks J ustice
Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer or Affidavit. Doing so will make the RJ C Order by
J udge Schroeder null and void (Karen Stancil, Chief Civil Clerk at RJ C admits this, but really, the fault lies with NCS and
Northwind, not the committed professional at the RJ C).
The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe where they have a valid
reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.

6

U.S. Supreme Court
SEVENTH CIRCUIT
No. 91-6516
While eviction proceedings were pending, Terrace Properties and Margaret Hale forcibly evicted petitioners, the Soldal
family, and their mobile home from a Terrace Properties' mobile home park. At Hale's request, Cook County, Illinois, Sheriff's
Department deputies were present at the eviction. Although they knew that there was no eviction order and that Terrace
Properties' actions were illegal, the deputies refused to take Mr. Soldal's complaint for criminal trespass or otherwise interfere
with the eviction. Subsequently, the state judge assigned to the pending eviction proceedings ruled that the eviction had been
unauthorized, and the trailer, badly damaged during the eviction, was returned to the lot. Petitioners brought an action in the
Federal District Court under 42 U.S.C. 1983, claiming that Terrace Properties and Hale had conspired with the deputy sheriffs
to unreasonably seize and remove their home in violation of their Fourth and Fourteenth Amendment rights. The court granted
defendants' motion for summary judgment, and the Court of Appeals affirmed. Acknowledging that what had occurred was a
"seizure" in the literal sense of the word, the court reasoned that it was not a seizure as contemplated by the Fourth
Amendment because, inter alia, it did not invade petitioners' privacy.
Held:
(a) A "seizure" of property occurs when "there is some meaningful interference with an individual's possessory
interests in that property." United States v. J acobsen, 466 U.S. 109, 113 . The language of the Fourth Amendment -
which protects people from unreasonable searches and seizures of "their persons, houses, papers, and effects" - cuts
against the novel holding below, and this Court's cases unmistakably hold that the Amendment protects property
even where privacy or liberty is not implicated. See, e.g., ibid.; Katz v. United States, 389 U.S. 347, 350 . This
Court's "plain view" decisions also make untenable the lower court's construction of the Amendment. If the
Amendment's boundaries were defined exclusively by rights of privacy, "plain view" seizures, rather than being
scrupulously subjected to Fourth Amendment inquiry, Arizona v. Hicks, 480 U.S. 321, 326 -327, would not
implicate that constitutional provision at all. Contrary to the Court of Appeals' [506 U.S. 56, 57] position, the
Amendment protects seizure even though no search within its meaning has taken place. See, e.g., J acobsen, supra,
at 120-125. Also contrary to that court's view, Graham v. Connor, 490 U.S. 386 , does not require a court, when it
finds that a wrong implicates more than one constitutional command, to look at the dominant character of the
challenged conduct to determine under which constitutional standard it should be evaluated. Rather, each
constitutional provision is examined in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp. 61-71.
(b) The instant decision should not foment a wave of new litigation in the federal courts. Activities such as
repossessions or attachments, if they involve entering a home, intruding on individuals' privacy, or interfering with
their liberty, would implicate the Fourth Amendment even on the Court of Appeals' own terms. And numerous
seizures of this type will survive constitutional scrutiny on "reasonableness" grounds. Moreover, it is unlikely that
the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed to seize
property in the absence of objectively reasonable grounds for doing so. Pp. 71-72.
WHITE, J ., delivered the opinion for a unanimous Court.
J ohn L. Stainthorp argued the cause and filed briefs for petitioners.
Kenneth L. Gillis argued the cause for respondents. With him on the brief were J ack O'Malley, Renee G. Goldfarb, and
Kenneth T. McCurry. [*]
[ Footnote *] J ames D. Holzhauer, Timothy S. Bishop, J ohn A. Powell, Steven R. Shapiro, Harvey M. Grossman, and Alan K.
Chen filed a brief for the American Civil Liberties Union et al. as amici curiae urging reversal.
Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad filed a brief for the National League of Cities et al.
as amici curiae urging affirmance.
J USTICE WHITE delivered the opinion of the Court.
I
Edward Soldal and his family resided in their trailer home, which was located on a rented lot in the Willoway Terrace mobile
[506 U.S. 56, 58] home park in Elk Grove, Illinois. In May 1987, Terrace Properties, the owner of the park, and Margaret Hale, its
manager, filed an eviction proceeding against the Soldals in an Illinois state court. Under the Illinois Forcible Entry and
Detainer Act, Ill.Rev.Stat., ch. 110, 9-101 et seq. (1991), a tenant cannot be dispossessed absent a judgment of eviction. The
suit was dismissed on J une 2, 1987. A few months later, in August 1987, the owner brought a second proceeding of eviction,
claiming nonpayment of rent. The case was set for trial on September 22, 1987.
Rather than await judgment in their favor, Terrace Properties and Hale, contrary to Illinois law, chose to evict the Soldals
forcibly two weeks prior to the scheduled hearing. On September 4, Hale notified the Cook County's Sheriff's Department that
she was going to remove the trailer home from the park, and requested the presence of sheriff deputies to forestall any
possible resistance. Later that day, two Terrace Properties employees arrived at the Soldals' home accompanied by Cook
County Deputy Sheriff O'Neil. The employees proceeded to wrench the sewer and water connections off the side of the trailer
home, disconnect the phone, tear off the trailer's canopy and skirting, and hook the home to a tractor. Meanwhile, O'Neil
explained to Edward Soldal that "`he was there to see that [Soldal] didn't interfere with [Willoway's] work.'" Brief for
Petitioner 6.
By this time, two more deputy sheriffs had arrived at the scene, and Soldal told them that he wished to file a complaint for
criminal trespass. They referred him to deputy Lieutenant J ones, who was in Hale's office. J ones asked Soldal to wait outside
while he remained closeted with Hale and other Terrace Properties employees for over 20 minutes. After talking to a district
attorney and making Soldal wait another half hour, J ones told Soldal that he would not accept a complaint because "ìt was
between the landlord and the tenant ... [and] they were going to go ahead and continue to move [506 U.S. 56, 59] out the trailer.'"
Id., at 8. 1 Throughout this period, the deputy sheriffs knew that Terrace Properties did not have an eviction order and that its
actions were unlawful. Eventually, and in the presence of an additional two deputy sheriffs, the Willoway workers pulled the
trailer free of its moorings and towed it onto the street. Later, it was hauled to a neighboring property.
On September 9, the state judge assigned to the pending eviction proceedings ruled that the eviction had been unauthorized,
and ordered Terrace Properties to return the Soldals' home to the lot. The home, however, was badly damaged.
[2]
The Soldals
brought this action under 42 U.S.C. 1983, alleging a violation of their rights under the Fourth and Fourteenth Amendments.
They claimed that Terrace Properties and Hale had conspired with Cook County deputy sheriffs to unreasonably seize and
remove the Soldals' trailer home. The District J udge granted defendants' motion for summary judgment on the grounds that the
Soldals had failed to adduce any evidence to support their conspiracy theory and, therefore, the existence of state action
necessary under 1983.
[3]

The Court of Appeals for the Seventh Circuit, construing the facts in petitioners' favor, accepted their contention that there was
state action. However, it went on to hold that [506 U.S. 56, 60] the removal of the Soldals' trailer did not constitute a seizure for
purposes of the Fourth Amendment or a deprivation of due process for purposes of the Fourteenth.
[4]
Acknowledging that what
had occurred was a "seizure" in the literal sense of the word, the court reasoned that, because it was not made in the course of
public law enforcement, and because it did not invade the Soldals' privacy, it was not a seizure as contemplated by the Fourth
Amendment. 942 F.2d 1073, 1076 (1991). Interpreting prior cases of this Court, the Seventh Circuit concluded that, absent
interference with privacy or liberty, a "pure deprivation of property" is not cognizable under the Fourth Amendment. Id., at
1078-1079. Rather, petitioners' property interests were protected only by the Due Process Clauses of the Fifth and Fourteenth
Amendments.
[5]

We granted certiorari to consider whether the seizure and removal of the Soldals' trailer home implicated their Fourth
Amendment rights, 503 U.S. 918 (1992), and now reverse.
[6]
[506 U.S. 56, 61]
II
The Fourth Amendment, made applicable to the States by the Fourteenth, Ker v. California, 374 U.S. 23, 30 (1963), provides
in pertinent part that the "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable
searches and seizures, shall not be violated... ."
A "seizure" of property, we have explained, occurs when "there is some meaningful interference with an individual's
possessory interests in that property." United States v. J acobsen, 466 U.S. 109, 113 (1984). In addition, we have emphasized
that "at the very core" of the Fourth Amendment "stands the right of a man to retreat into his own home." Silverman v. United
States, 365 U.S. 505, 511 (1961). See also Oliver v. United States, 466 U.S. 170, 178 -179 (1984); Wyman v. J ames, 400 U.S.
309, 316 (1971); Payton v. New York, 445 U.S. 573, 601 (1980).
As a result of the state action in this case, the Soldals' domicile was not only seized, it literally was carried away, giving new
meaning to the term "mobile home." We fail to see how being unceremoniously dispossessed of one's home in the manner
alleged to have occurred here can be viewed as anything but a seizure invoking the protection of the Fourth Amendment.
Whether the Amendment was in fact [506 U.S. 56, 62] violated is, of course, a different question that requires determining if the
seizure was reasonable. That inquiry entails the weighing of various factors, and is not before us.
The Court if Appeals recognized that there had been a seizure, but concluded that it was a seizure only in a "technical" sense,
not within the meaning of the Fourth Amendment. This conclusion followed from a narrow reading of the Amendment, which
the court construed to safeguard only privacy and liberty interests, while leaving unprotected possessory interests where
neither privacy nor liberty was at stake. Otherwise, the court said,
"a constitutional provision enacted two centuries ago [would] make every repossession and eviction with police
assistance actionable under - of all things - the Fourth Amendment[, which] would both trivialize the amendment
and gratuitously shift a large body of routine commercial litigation from the state courts to the federal courts. That
trivializing, this shift, can be prevented by recognizing the difference between possessory and privacy interests."
942 F.2d, at 1077.
Because the officers had not entered Soldal's house, rummaged through his possessions, or, in the Court of Appeals' view,
interfered with his liberty in the course of the eviction, the Fourth Amendment offered no protection against the "grave
deprivation" of property that had occurred. Ibid.
We do not agree with this interpretation of the Fourth Amendment. The Amendment protects the people from unreasonable
searches and seizures of "their persons, houses, papers, and effects." This language surely cuts against the novel holding
below, and our cases unmistakably hold that the Amendment protects property as well as privacy.
[7]
This much [506 U.S. 56, 63]
was made clear in J acobsen, supra, where we explained that the first Clause of the Fourth Amendment
"protects two types of expectations, one involving "searches," the other "seizures." A "search" occurs when an
expectation of privacy that society is prepared to consider reasonable is infringed. A "seizure" of property occurs
where there is some meaningful interference with an individual's possessory interests in that property." 466 U.S., at
113 (footnote omitted).
See also id., at 120; Horton v. California, 496 U.S. 128, 133 (1990); Arizona v. Hicks, 480 U.S. 321, 328 (1987); Maryland v.
Macon, 472 U.S. 463, 469 (1985); Texas v. Brown, 460 U.S. 730, 747 -748 (1983) (STEVENS, J ., concurring in judgment);
United States v. Salvucci, 448 U.S. 83, 91 , n. 6 (1980). Thus, having concluded that chemical testing of powder found in a
package did not compromise its owner's privacy, the Court in J acobsen did not put an end to its inquiry, as would be required
under the view adopted by the Court of Appeals and advocated by respondents. Instead, adhering to the teachings of United
States v. Place, 462 U.S. 696 (1983), it went on to determine whether the invasion of the owners' "possessory interests"
occasioned by the destruction of the powder was reasonable under the Fourth Amendment. J acobsen, supra, at 124-125. In
Place, although we found that subjecting luggage to a "dog sniff" did not constitute a search for Fourth Amendment purposes
because it did not compromise any privacy interest, taking custody of Place's suitcase was deemed an unlawful seizure, for it
unreasonably infringed "the suspect's possessory interest in his luggage." 462 U.S., at 708 . 8 Although lacking a privacy
component, the property rights in both instances nonetheless were not [506 U.S. 56, 64] disregarded, but rather were afforded
Fourth Amendment protection.
Respondents rely principally on precedents such as Katz v. United States, 389 U.S. 347 (1967), Warden, Maryland
Penitentiary v. Hayden, 387 U.S. 294 (1967), and Cardwell v. Lewis, 417 U.S. 583 (1974), to demonstrate that the Fourth
Amendment is only marginally concerned with property rights. But the message of those cases is that property rights are not
the sole measure of Fourth Amendment violations. The Warden opinion thus observed, citing J ones v. United States, 362 U.S.
257 (1960), and Silverman v. United States, 365 U.S. 505 (1961), that the "principal" object of the Amendment is the
protection of privacy, rather than property, and that "this shift in emphasis from property to privacy has come about through a
subtle interplay of substantive and procedural reform." 387 U.S., at 304 . There was no suggestion that this shift in emphasis
had snuffed out the previously recognized protection for property under the Fourth Amendment. Katz, in declaring violative of
the Fourth Amendment the unwarranted overhearing of a telephone booth conversation, effectively ended any lingering
notions that the protection of privacy depended on trespass into a protected area. In the course of its decision, the Katz Court
stated that the Fourth Amendment can neither be translated into a provision dealing with constitutionally protected areas nor
into a general constitutional right to privacy. The Amendment, the Court said, protects individual privacy against certain kinds
of governmental intrusion, "but its protections go further, and often have nothing to do with privacy at all." 389 U.S., at 350 .
As for Cardwell, a plurality of this Court held in that case that the Fourth Amendment did not bar the use in evidence of paint
scrapings taken from and tire treads observed on the defendant's automobile, which had been seized in a parking lot and towed
to a police lockup. Gathering this evidence was not deemed to be a search, for nothing from the [506 U.S. 56, 65] interior of the
car and "no personal effects, which the Fourth Amendment traditionally has been deemed to protect" were searched or seized.
417 U.S., at 591 (opinion of BLACKMUN, J .). No meaningful privacy rights were invaded. But this left the argument,
pressed by the dissent, that the evidence gathered was the product of a warrantless, and hence illegal, seizure of the car from
the parking lot where the defendant had left it. However, the plurality was of the view that, because, under the circumstances
of the case, there was probable cause to seize the car as an instrumentality of the crime, Fourth Amendment precedent
permitted the seizure without a warrant. Id., at 593. Thus, both the plurality and dissenting J ustices considered the defendant's
auto deserving of Fourth Amendment protection even though privacy interests were not at stake. They differed only in the
degree of protection that the Amendment demanded.
The Court of Appeals appeared to find more specific support for confining the protection of the Fourth Amendment to privacy
interests in our decision in Hudson v. Palmer, 468 U.S. 517 (1984). There, a state prison inmate sued, claiming that prison
guards had entered his cell without consent and had seized and destroyed some of his personal effects. We ruled that an
inmate, because of his status, enjoyed neither a right to privacy in his cell nor protection against unreasonable seizures of his
personal effects. Id., at 526-528, and n. 8; id., at 538 (O'CONNOR, J ., concurring). Whatever else the case held, it is of
limited usefulness outside the prison context with respect to the coverage of the Fourth Amendment.
We thus are unconvinced that any of the Court's prior cases supports the view that the Fourth Amendment protects against
unreasonable seizures of property only where privacy or liberty is also implicated. What is more, our "plain view" decisions
make untenable such a construction of the Amendment. Suppose, for example, that police officers lawfully enter a house, by
either complying with the warrant requirement or satisfying one of its recognized exceptions - [506 U.S. 56, 66] e.g., through a
valid consent or a showing of exigent circumstances. If they come across some item in plain view and seize it, no invasion of
personal privacy has occurred. Horton, 496 U.S., at 133 -134; Brown, supra, at 739 (opinion of REHNQUIST, J .). If the
boundaries of the Fourth Amendment were defined exclusively by rights of privacy, "plain view" seizures would not implicate
that constitutional provision at all. Yet, far from being automatically upheld, "plain view" seizures have been scrupulously
subjected to Fourth Amendment inquiry. Thus, in the absence of consent or a warrant permitting the seizure of the items in
question, such seizures can be justified only if they meet the probable-cause standard, Arizona v. Hicks, 480 U.S. 321, 326 -
327 (1987), 9 and if they are unaccompanied by unlawful trespass, Horton, 496 U.S., at 136 -137. 10 That is because, the
absence of a privacy interest notwithstanding, "[a] seizure of the article ... would obviously invade the owner's possessory
interest." Id., at 134; see also Brown, 460 U.S., at 739 (opinion of REHNQUIST, J .). The plain-view doctrine "merely reflects
an application of the Fourth Amendment's central requirement of reasonableness to the law governing seizures of property."
Ibid.; Coolidge v. New Hampshire, 403 U.S. 443, 468 (1971); id., at 516 (WHITE, J ., concurring and dissenting).
The Court of Appeals understandably found it necessary to reconcile its holding with our recognition in the plain-view cases
that the Fourth Amendment protects property as such. In so doing, the court did not distinguish this case on the ground that
the seizure of the Soldals' home took place in a [506 U.S. 56, 67] noncriminal context. Indeed, it acknowledged what is evident
from our precedents - that the Amendment's protection applies in the civil context as well. See O'Connor v. Ortega, 480 U.S.
709 (1987); New J ersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v. Tyler, 436 U.S. 499, 504 -506 (1978);
Marshall v. Barlow's, Inc., 436 U.S. 307, 312 -313 (1978); Camara v. Municipal Court of San Francisco, 387 U.S. 523, 528
(1967). 11
Nor did the Court of Appeals suggest that the Fourth Amendment applied exclusively to law enforcement activities. It
observed, for example, that the Amendment's protection would be triggered "by a search or other entry into the home incident
to an eviction or repossession," 942 F.2d, at 1077. 12 Instead, the court sought to explain why the Fourth Amendment protects
against seizures of property in the plain-view context, but not in this case, as follows:
"[S]eizures made in the course of investigations by police or other law enforcement officers are almost always, as
in the plain view cases, the culmination of searches. The police search in order to seize, and it is the search [506 U.S.
56, 68] and ensuing seizure that the Fourth Amendment, by its reference to "searches and seizures," seeks to regulate.
Seizure means one thing when it is the outcome of a search; it may mean something else when it stands apart from
a search or any other investigative activity. The Fourth Amendment may still nominally apply, but, precisely
because there is no invasion of privacy, the usual rules do not apply." Id., at 1079 (emphasis in original).
We have difficulty with this passage. The court seemingly construes the Amendment to protect only against seizures that are
the outcome of a search. But our cases are to the contrary, and hold that seizures of property are subject to Fourth Amendment
scrutiny even though no search within the meaning of the Amendment has taken place. See, e.g., J acobsen, 466 U.S., at 120 -
125; Place, 462 U.S., at 706 -707; Cardwell, 417 U.S., at 588 -589. 13 More generally, an officer who happens to come across
an individual's property in a public area could seize it only if Fourth Amendment standards are satisfied - for example, if the
items are evidence of a crime or contraband. Cf. Payton v. New York, [506 U.S. 56, 69] 445 U.S., at 587 . We are also puzzled by
the last sentence of the excerpt, where the court announces that the "usual rules" of the Fourth Amendment are inapplicable if
the seizure is not the result of a search or any other investigative activity "precisely because there is no invasion of privacy."
For the plain-view cases clearly state that, notwithstanding the absence of any interference with privacy, seizures of effects
that are not authorized by a warrant are reasonable only because there is probable cause to associate the property with criminal
activity. The seizure of the weapons in Horton, for example, occurred in the midst of a search, yet we emphasized that it did
not "involve any invasion of privacy." 496 U.S., at 133 . In short, our statement that such seizures must satisfy the Fourth
Amendment and will be deemed reasonable only if the item's incriminating character is "immediately apparent," id., at 136-
137, is at odds with the Court of Appeals' approach.
The Court of Appeals' effort is both interesting and creative, but, at bottom, it simply reasserts the earlier thesis that the
Fourth Amendment protects privacy, but not property. We remain unconvinced, and see no justification for departing from our
prior cases. In our view, the reason why an officer might enter a house or effectuate a seizure is wholly irrelevant to the
threshold question whether the Amendment applies. What matters is the intrusion on the people's security from governmental
interference. Therefore, the right against unreasonable seizures would be no less transgressed if the seizure of the house was
undertaken to collect evidence, verify compliance with a housing regulation, effect an eviction by the police, or on a whim, for
no reason at all. As we have observed on more than one occasion, it would be "anomalous to say that the individual and his
private property are fully protected by the Fourth Amendment only when the individual is suspected of criminal behavior."
Camara 387 U.S., at 530 ; see also O'Connor, 480 U.S., at 715 ; T.L.O., 469 U.S., at 335 . [506 U.S. 56, 70]
The Court of Appeals also stated that, even if, contrary to its previous rulings, "there is some element or tincture of a Fourth
Amendment seizure, it cannot carry the day for the Soldals." 942 F.2d, at 1080. Relying on our decision in Graham v. Connor,
490 U.S. 386 (1989), the court reasoned that it should look at the "dominant character of the conduct challenged in a section
1983 case [to] determine the constitutional standard under which it is evaluated." 942 F.2d, at 1080. Believing that the Soldals'
claim was more akin to a challenge against the deprivation of property without due process of law than against an
unreasonable seizure, the court concluded that they should not be allowed to bring their suit under the guise of the Fourth
Amendment.
But we see no basis for doling out constitutional protections in such fashion. Certain wrongs affect more than a single right,
and, accordingly, can implicate more than one of the Constitution's commands. Where such multiple violations are alleged, we
are not in the habit of identifying, as a preliminary matter, the claim's "dominant" character. Rather, we examine each
constitutional provision in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment and Fourteenth
Amendment Due Process Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth Amendment and Fourteenth Amendment
Due Process Clause). Graham is not to the contrary. Its holding was that claims of excessive use of force should be analyzed
under the Fourth Amendment's reasonableness standard, rather than the Fourteenth Amendment's substantive due process test.
We were guided by the fact that, in that case, both provisions targeted the same sort of governmental conduct and, as a result,
we chose the more "explicit textual source of constitutional protection" over the "more generalized notion of `substantive due
process.'" 490 U.S., at 394 -395. Surely, Graham does not bar resort in this case to the Fourth Amendment's specific
protection for "houses, papers, [506 U.S. 56, 71] and effects," rather than the general protection of property in the Due Process
Clause.
III
Respondents are fearful, as was the Court of Appeals, that applying the Fourth Amendment in this context inevitably will
carry it into territory unknown and unforeseen: routine repossessions, negligent actions of public employees that interfere with
individuals' right to enjoy their homes, and the like, thereby federalizing areas of law traditionally the concern of the States.
For several reasons, we think the risk is exaggerated. To begin, our decision will have no impact on activities such as
repossessions or attachments if they involve entry into the home, intrusion on individuals' privacy, or interference with their
liberty, because they would implicate the Fourth Amendment even on the Court of Appeals' own terms. This was true of the
Tenth Circuit's decision in Specht, with which, as we previously noted, the Court of Appeals expressed agreement.
More significantly, "reasonableness is still the ultimate standard" under the Fourth Amendment, Camara, supra, at 539, which
means that numerous seizures of this type will survive constitutional scrutiny. As is true in other circumstances, the
reasonableness determination will reflect a "careful balancing of governmental and private interests." T.L.O., supra, at 341.
Assuming, for example, that the officers were acting pursuant to a court order, as in Specht v. J ensen, 832 F.2d 1516 (CA10
1987), or Fuentes v. Shevin, 407 U.S. 67 , (1972), and, as often would be the case, a showing of unreasonableness on these
facts would be a laborious task indeed. Cf. Simms v. Slacum, 3 Cranch 300, 301 (1806). Hence, while there is no guarantee
against the filing of frivolous suits, had the ejection in this case properly awaited the state court's judgment, it is quite unlikely
that the federal court would have been bothered with a 1983 action alleging a Fourth Amendment violation. [506 U.S. 56, 72]
Moreover, we doubt that the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed
to seize property in the absence of objectively reasonable grounds for doing so. In short, our reaffirmance of Fourth
Amendment principles today should not foment a wave of new litigation in the federal courts.
IV
The complaint here alleges that respondents, acting under color of state law, dispossessed the Soldals of their trailer home by
physically tearing it from its foundation and towing it to another lot. Taking these allegations as true, this was no "garden
variety" landlord-tenant or commercial dispute. The facts alleged suffice to constitute a "seizure" within the meaning of the
Fourth Amendment, for they plainly implicate the interests protected by that provision. The judgment of the Court of Appeals
is, accordingly, reversed, and the case is remanded for further proceedings consistent with this opinion.
So ordered.
Footnotes
[1] J ones' statement was prompted by a district attorney's advice that no criminal charges could be brought because, under
Illinois law, a criminal action cannot be used to determine the right of possession. See Ill.Rev.Stat. ch. 110, 9-101 et seq.
(1991); People v. Evans, 163 Ill.App. 3d 561, 114 Ill.Dec. 662, 516 N.E.2d 817 (1st Dist. 1987).
"Every person who, under color of any statute, ordinance, regulation, custom or usage, of any State ... subjects, or
causes to be subjected, any citizen of the United States ... to the deprivation of any rights, privileges, or immunities
secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other
proper proceeding for redress."
[4] The court reiterated the panel's conclusion that a conspiracy must be assumed on the state of the record and, therefore, that
the case must be treated in its current posture "as if the deputy sheriffs themselves seized the trailer, disconnected it from the
utilities, and towed it away." 942 F.2d 1073, 1075 (CA7 1991) (en banc).
[5] The court noted that, in light of the existence of adequate judicial remedies under state law, a claim for deprivation of
property without due process of law was unlikely to succeed. Id., at 1075-1076. See Parratt v. Taylor, 451 U.S. 527 (1981). In
any event, the Soldals did not claim a violation of their procedural rights. As noted, the Seventh Circuit also held that
respondents had not violated the Soldals' substantive due process rights under the Fourteenth Amendment. Petitioners assert
that this was error, but, in view of our disposition of the case, we need not address the question at this time.
[6] Under 42 U.S.C. 1983, the Soldals were required to establish that the respondents, acting under color of state law, deprived
them of a constitutional right, in this instance, their Fourth and Fourteenth Amendment freedom from unreasonable seizures by
the State. See Monroe v. Pape, [506 U.S. 56, 61] 365 U.S. 167, 184 (1961). Respondents request that we affirm on the ground that
the Court of Appeals erred in holding that there was sufficient state action to support a 1983 action. The alleged injury to the
Soldals, it is urged, was inflicted by private parties for whom the county is not responsible. Although respondents did not
cross-petition, they are entitled to ask us to affirm on that ground if such action would not enlarge the judgment of the Court
of Appeals in their favor. The Court of Appeals found that, because the police prevented Soldal from using reasonable force to
protect his home from private action that the officers knew was illegal, there was sufficient evidence of conspiracy between the
private parties and the officers to foreclose summary judgment for respondents. We are not inclined to review that holding.
See Adickes v. S.H. Kress & Co., 398 U.S. 144, 152 -161 (1970).
[7] In holding that the Fourth Amendment's reach extends to property as such, we are mindful that the Amendment does not
protect possessory interests in all kinds of property. See, e.g., Oliver v. United States, 466 U.S. 170, 176 -177 (1984). This
case, however, concerns a house, which the Amendment's language explicitly includes, as it does a person's effects.
[8] Place also found that to detain luggage for 90 minutes was an unreasonable deprivation of the individual's "liberty interest
in proceeding with his itinerary," which also is protected by the Fourth Amendment. 462 U.S., at 708 -710.
[9] When "operational necessities" exist, seizures can be justified on less than probable cause. 480 U.S., at 327 . That in no
way affects our analysis, for even then it is clear that the Fourth Amendment applies. Ibid; see also United States v. Place, 462
U.S. 696 , at 703 (1983).
[10] Of course, if the police officers' presence in the home itself entailed a violation of the Fourth Amendment, no amount of
probable cause to believe that an item in plain view constitutes incriminating evidence will justify its seizure. Horton, 496
U.S., at 136 -137.
[11] It is true that Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), cast some doubt on the
applicability of the Amendment to noncriminal encounters such as this. Id., 18 How. at 285. But cases since that time have
shed a different light, making clear that Fourth Amendment guarantees are triggered by governmental searches and seizures
"without regard to the use to which [houses, papers, and effects] are applied." Warden, Maryland Penitentiary v. Hayden, 387
U.S. 294, 301 (1967). Murray's Lessee's broad statement that the Fourth Amendment "has no reference to civil proceedings
for the recovery of debt" arguably only meant that the warrant requirement did not apply, as was suggested in G.M. Leasing
Corp. v. United States, 429 U.S. 338, 352 (1977). Whatever its proper reading, we reaffirm today our basic understanding that
the protection against unreasonable searches and seizures fully applies in the civil context.
[12] This was the view expressed by the Court of Appeals for the Tenth Circuit in Specht v. J ensen, 832 F.2d 1516 (1987),
remanded on unrelated grounds, 853 F.2d 805 (1988) (en banc), with which the Seventh Circuit expressly agreed. 942 F.2d, at
1076.
[13] The officers in these cases were engaged in law enforcement, and were looking for something that was found and seized.
In this broad sense, the seizures were the result of "searches," but not in the Fourth Amendment sense. That the Court of
Appeals might have been suggesting that the plain-view cases are explainable because they almost always occur in the course
of law enforcement activities receives some support from the penultimate sentence of the quoted passage, where the court
states that the word "seizure" might lose its usual meaning "when it stands apart from a search or any other investigative
activity." Id., at 1079 (emphasis added). And, in the following paragraph, it observes that, "[o]utside of the law enforcement
area, the Fourth Amendment retains its force as a protection against searches, because they invade privacy. That is why we
decline to confine the amendment to the law enforcement setting." Id., at 1079-1080. Even if the court meant that seizures of
property in the course of law enforcement activities, whether civil or criminal, implicate interests safeguarded by the Fourth
Amendment, but that pure property interests are unprotected in the non-law-enforcement setting, we are not in accord, as
indicated in the body of this opinion. [506 U.S. 56, 73]

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

Subject: Reno eviction noticed for Sparks J ustice Court
Date: Tue, 26 J un 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Dear Sparks J ustice Court,
I called and received permission to file this by fax...I am indigent and request a fee waiver, and failing that, an opportunity to cure any filing
fee deficiency.
To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us; chansen@washoecounty.us;
milllerr@reno.gov
Date: Tue, 26 J un 2012 07:58:36 -0700
Dear Sparks J ustice Court, WCSO, RPD, and Reno J ustice Court.
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful detainer?) for rentals
located at 1680 Sky Mountain Drive, Reno, 89523, but the notice indicates that I must file a Tenant's Answer with the Sparks
J ustice Court.
Am I mistaken in viewing this matter to be outside the jurisdiction of the Sparks J ustice Court, and rather, a matter to be
handled in Reno J ustice Court?
Given Sparks J ustice Court is open 5 days a week (closes at noon on Fridays) and Reno J ustice Court has 4 judicial days a week,
the deadline for filing a special appearance (to contest jurisdiction) and or a Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he indicated the WCSO planned to
come effectuate an eviction on this date, J une 26, 2012. I believe that would be premature, as Nevada Landlord Tenant law
provides for filing a Tenant's Answer or Affidavit by noon after the fifth full day (judicial days) and Fridays in Sparks J ustice
Court are not full days in that sense, and regardless, Sparks J ustice Court, I believe, is not the appropriate forum where, as
here, the situs is located in Reno (Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
The Civil Division of Sparks J ustice Court is made up of three major functions:
Civil
Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive damages, an action to obtain
possession of property, a writ of restitution, or other like actions, legal counsel is suggested for these types of actions.
Evictions
request for a pre trial motion and bail motion
Small Claims
An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims action may be filed with
the Sparks J ustice Court if one of the following applies to the defendant:
Sent: Mon 8/06/12 3:54 PM
To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
7 attachments
20120605_101458 admitting dwayne tried to lift door up 6 5 12.mp4 (498.1 KB) , 20120605_101513 Northwind
manager handy man attacks from golf cart 6 5 12.mp4 (3.1 MB) , northwind v coughjlin combined for rjc judges
chamers vacate summary eviction motion affidavit, amended motion and proposed order.pdf (130.9 KB) , supplement
to tenants motion to dismiss northwind in sparks justice court.pdf (98.3 KB) , 6 8 12 fax to northwind with page
numbers.pdf (50.7 KB) , northwind fax 6 4 12 habitability retaliation etc.pdf (45.8 KB) , emails to
weavera@reno.gov.pdf (32.5 KB)
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 J Uly 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, J udge
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, J ared 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 J uly 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 J uly 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 J uly 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 J une 28th, 2012 eviction of
Coughlin by posting an Amended 5 Day Unlawful Detainer Notice on unit 29 on J une 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada
Courts Services that the J uly 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 J uly 28th, 2012 to file a Tenant's Answer,
whereas the eviction/lockout/arrest of J une 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 J une 2012 reporting extortionate
threats by another maintenance man at Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne J akob, 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, RJ C, Sparks J ustice
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 J une 5th, 2012, not from J uly 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 J une 26th, and J uly 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
Cl ose Pr i nt
Ful l vi ew
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NvRenoPd@copl ogi c. com
To zachcoughl i n@hot mai l . com
Fr om: NvRenoPd@coplogic.com
Sent : Fr i 6/ 08/ 12 4: 39 PM
To: zachcoughl i n@hot mai l . com
****DO NOT RESPOND TO THI S E- MAI L****
****THI S I S AN UN- MONI TORED MAI L BOX****
Your onl i ne r epor t has been successf ul l y r ecei ved and t he
t r acki ng number i s T12004553.
You wi l l be not i f i ed vi a emai l of any pr obl ems wi t h your
r epor t . Once your r epor t i s appr oved, i t wi l l be i ssued
a case number and you wi l l r ecei ve a PDF copy as an at t achment
i n your emai l wi t hi n appr oxi mat el y t en busi ness days.

Thank you f or usi ng our onl i ne r epor t i ng syst emand pl ease
cont act us wi t h any suggest i ons you have f or i mpr ovi ng our
syst em.

Onl i ne Of f i cer
Reno Pol i ce Depar t ment

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Sent : Fr i 6/ 08/ 12 4: 45 PM
Your onl i ne r epor t has been successf ul l y r ecei ved and t he
t r acki ng number i s T12004554.
You wi l l be not i f i ed vi a emai l of any pr obl ems wi t h your
r epor t . Once your r epor t i s appr oved, i t wi l l be i ssued
a case number and you wi l l r ecei ve a PDF copy as an at t achment
i n your emai l wi t hi n appr oxi mat el y t en busi ness days.

Thank you f or usi ng our onl i ne r epor t i ng syst emand pl ease
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Sent : Mon 6/ 11/ 12 4: 10 PM
1 at t achment
r epor t - 120103420- 0. pdf ( 71. 4 KB)

Your r epor t has been appr oved r epor t and t he per manent number of t he case i s
120103420.

t he del i cat e i nf or mat i on i n hi s r epor t has been r epl aced f or *** t o suppor t i sol at i on i n t hi s emai l .

Thank you f or usi ng our onl i ne r epor t i ng syst emand pl ease cont act us wi t h any suggest i ons you have f or i mpr ovi ng our
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6 26 12 warning to wcso rpd, etc. Reno eviction noticed for Sparks J ustice
Court
Sent : Mon 6/ 11/ 12 4: 11 PM
1 at t achment
r epor t - 120103420- 1. pdf ( 70. 9 KB)

Your r epor t has been appr oved suppl ement al r epor t and t he per manent number of t he case i s
120103420.

t he del i cat e i nf or mat i on i n hi s r epor t has been r epl aced f or *** t o suppor t i sol at i on i n t hi s emai l .

Thank you f or usi ng our onl i ne r epor t i ng syst emand pl ease cont act us wi t h any suggest i ons you have f or i mpr ovi ng our
syst em.

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Sent: Wed 7/25/12 4:09 PM
To: kadlicj@reno.gov; zyoung@da.washoecounty.us; mkandaras@da.washoecounty.us; hazlett-stevensc@reno.gov
1 attachment
KB)
http://www.youtube.com/watch?v=B-xXtP3-yVU
http://www.youtube.com/watch?v=aKeIYy1CF_c&feature=channel&list=UL
http://www.youtube.com/watch?v=6SvV59vUJ wM&feature=channel&list=UL
http://www.youtube.com/watch?v=8-_USIE79kY&feature=channel&list=UL
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Date: Tue, 26 J un 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
fee deficiency.
milllerr@reno.gov
Date: Tue, 26 J un 2012 07:58:36 -0700
J ustice Court.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
Civil
Reno eviction noticed for Sparks J ustice Court
Evictions
Small Claims
Sent: Wed 7/25/12 4:02 PM
To: mkandaras@da.washoecounty.us; kadlicj@reno.gov
2 attachments
KB) , combined northwind v coughlin eviction filings.pdf (1058.4 KB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us;
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Subject: FW: Reno eviction noticed for Sparks J ustice Court
Date: Mon, 2 J ul 2012 17:21:54 -0700
NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on J uly 29th, 2012"...giving
me five days to get my stuff out of unit 29 (the one the subject of J udge Schroeer's Eviction Order, which was effectively
rescinded by their serving a new 5 day unlawful detainer notice....) as well as units 71 and 45...whicih are two units to which i
still have valide lease agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated they will arrest
me for criminal trespass for accessing any units in the complex, including those to which I still have a valid possessory or
property interest, in violation of 42 usc 1983).

why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel" good looks and a much
higher paying job than I will ever have? What up wit that?

Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed up and put "Sparks J ustice
Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer or Affidavit. Doing so will make the RJ C Order by
J udge Schroeder null and void (Karen Stancil, Chief Civil Clerk at RJ C admits this, but really, the fault lies with NCS and
Northwind, not the committed professional at the RJ C).
The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe where they have a valid
reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.

6

U.S. Supreme Court
SEVENTH CIRCUIT
No. 91-6516
While eviction proceedings were pending, Terrace Properties and Margaret Hale forcibly evicted petitioners, the Soldal
family, and their mobile home from a Terrace Properties' mobile home park. At Hale's request, Cook County, Illinois, Sheriff's
Department deputies were present at the eviction. Although they knew that there was no eviction order and that Terrace
Properties' actions were illegal, the deputies refused to take Mr. Soldal's complaint for criminal trespass or otherwise interfere
with the eviction. Subsequently, the state judge assigned to the pending eviction proceedings ruled that the eviction had been
unauthorized, and the trailer, badly damaged during the eviction, was returned to the lot. Petitioners brought an action in the
Federal District Court under 42 U.S.C. 1983, claiming that Terrace Properties and Hale had conspired with the deputy sheriffs
to unreasonably seize and remove their home in violation of their Fourth and Fourteenth Amendment rights. The court granted
defendants' motion for summary judgment, and the Court of Appeals affirmed. Acknowledging that what had occurred was a
"seizure" in the literal sense of the word, the court reasoned that it was not a seizure as contemplated by the Fourth
Amendment because, inter alia, it did not invade petitioners' privacy.
Held:
(a) A "seizure" of property occurs when "there is some meaningful interference with an individual's possessory
interests in that property." United States v. J acobsen, 466 U.S. 109, 113 . The language of the Fourth Amendment -
which protects people from unreasonable searches and seizures of "their persons, houses, papers, and effects" - cuts
against the novel holding below, and this Court's cases unmistakably hold that the Amendment protects property
even where privacy or liberty is not implicated. See, e.g., ibid.; Katz v. United States, 389 U.S. 347, 350 . This
Court's "plain view" decisions also make untenable the lower court's construction of the Amendment. If the
Amendment's boundaries were defined exclusively by rights of privacy, "plain view" seizures, rather than being
scrupulously subjected to Fourth Amendment inquiry, Arizona v. Hicks, 480 U.S. 321, 326 -327, would not
implicate that constitutional provision at all. Contrary to the Court of Appeals' [506 U.S. 56, 57] position, the
Amendment protects seizure even though no search within its meaning has taken place. See, e.g., J acobsen, supra,
at 120-125. Also contrary to that court's view, Graham v. Connor, 490 U.S. 386 , does not require a court, when it
finds that a wrong implicates more than one constitutional command, to look at the dominant character of the
challenged conduct to determine under which constitutional standard it should be evaluated. Rather, each
constitutional provision is examined in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp. 61-71.
(b) The instant decision should not foment a wave of new litigation in the federal courts. Activities such as
repossessions or attachments, if they involve entering a home, intruding on individuals' privacy, or interfering with
their liberty, would implicate the Fourth Amendment even on the Court of Appeals' own terms. And numerous
seizures of this type will survive constitutional scrutiny on "reasonableness" grounds. Moreover, it is unlikely that
the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed to seize
property in the absence of objectively reasonable grounds for doing so. Pp. 71-72.
WHITE, J ., delivered the opinion for a unanimous Court.
J ohn L. Stainthorp argued the cause and filed briefs for petitioners.
Kenneth L. Gillis argued the cause for respondents. With him on the brief were J ack O'Malley, Renee G. Goldfarb, and
Kenneth T. McCurry. [*]
[ Footnote *] J ames D. Holzhauer, Timothy S. Bishop, J ohn A. Powell, Steven R. Shapiro, Harvey M. Grossman, and Alan K.
Chen filed a brief for the American Civil Liberties Union et al. as amici curiae urging reversal.
Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad filed a brief for the National League of Cities et al.
as amici curiae urging affirmance.
J USTICE WHITE delivered the opinion of the Court.
I
Edward Soldal and his family resided in their trailer home, which was located on a rented lot in the Willoway Terrace mobile
[506 U.S. 56, 58] home park in Elk Grove, Illinois. In May 1987, Terrace Properties, the owner of the park, and Margaret Hale, its
manager, filed an eviction proceeding against the Soldals in an Illinois state court. Under the Illinois Forcible Entry and
Detainer Act, Ill.Rev.Stat., ch. 110, 9-101 et seq. (1991), a tenant cannot be dispossessed absent a judgment of eviction. The
suit was dismissed on J une 2, 1987. A few months later, in August 1987, the owner brought a second proceeding of eviction,
claiming nonpayment of rent. The case was set for trial on September 22, 1987.
Rather than await judgment in their favor, Terrace Properties and Hale, contrary to Illinois law, chose to evict the Soldals
forcibly two weeks prior to the scheduled hearing. On September 4, Hale notified the Cook County's Sheriff's Department that
she was going to remove the trailer home from the park, and requested the presence of sheriff deputies to forestall any
possible resistance. Later that day, two Terrace Properties employees arrived at the Soldals' home accompanied by Cook
County Deputy Sheriff O'Neil. The employees proceeded to wrench the sewer and water connections off the side of the trailer
home, disconnect the phone, tear off the trailer's canopy and skirting, and hook the home to a tractor. Meanwhile, O'Neil
explained to Edward Soldal that "`he was there to see that [Soldal] didn't interfere with [Willoway's] work.'" Brief for
Petitioner 6.
By this time, two more deputy sheriffs had arrived at the scene, and Soldal told them that he wished to file a complaint for
criminal trespass. They referred him to deputy Lieutenant J ones, who was in Hale's office. J ones asked Soldal to wait outside
while he remained closeted with Hale and other Terrace Properties employees for over 20 minutes. After talking to a district
attorney and making Soldal wait another half hour, J ones told Soldal that he would not accept a complaint because "ìt was
between the landlord and the tenant ... [and] they were going to go ahead and continue to move [506 U.S. 56, 59] out the trailer.'"
Id., at 8. 1 Throughout this period, the deputy sheriffs knew that Terrace Properties did not have an eviction order and that its
actions were unlawful. Eventually, and in the presence of an additional two deputy sheriffs, the Willoway workers pulled the
trailer free of its moorings and towed it onto the street. Later, it was hauled to a neighboring property.
On September 9, the state judge assigned to the pending eviction proceedings ruled that the eviction had been unauthorized,
and ordered Terrace Properties to return the Soldals' home to the lot. The home, however, was badly damaged.
[2]
The Soldals
brought this action under 42 U.S.C. 1983, alleging a violation of their rights under the Fourth and Fourteenth Amendments.
They claimed that Terrace Properties and Hale had conspired with Cook County deputy sheriffs to unreasonably seize and
remove the Soldals' trailer home. The District J udge granted defendants' motion for summary judgment on the grounds that the
Soldals had failed to adduce any evidence to support their conspiracy theory and, therefore, the existence of state action
necessary under 1983.
[3]

The Court of Appeals for the Seventh Circuit, construing the facts in petitioners' favor, accepted their contention that there was
state action. However, it went on to hold that [506 U.S. 56, 60] the removal of the Soldals' trailer did not constitute a seizure for
purposes of the Fourth Amendment or a deprivation of due process for purposes of the Fourteenth.
[4]
Acknowledging that what
had occurred was a "seizure" in the literal sense of the word, the court reasoned that, because it was not made in the course of
public law enforcement, and because it did not invade the Soldals' privacy, it was not a seizure as contemplated by the Fourth
Amendment. 942 F.2d 1073, 1076 (1991). Interpreting prior cases of this Court, the Seventh Circuit concluded that, absent
interference with privacy or liberty, a "pure deprivation of property" is not cognizable under the Fourth Amendment. Id., at
1078-1079. Rather, petitioners' property interests were protected only by the Due Process Clauses of the Fifth and Fourteenth
Amendments.
[5]

We granted certiorari to consider whether the seizure and removal of the Soldals' trailer home implicated their Fourth
Amendment rights, 503 U.S. 918 (1992), and now reverse.
[6]
[506 U.S. 56, 61]
II
The Fourth Amendment, made applicable to the States by the Fourteenth, Ker v. California, 374 U.S. 23, 30 (1963), provides
in pertinent part that the "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable
searches and seizures, shall not be violated... ."
A "seizure" of property, we have explained, occurs when "there is some meaningful interference with an individual's
possessory interests in that property." United States v. J acobsen, 466 U.S. 109, 113 (1984). In addition, we have emphasized
that "at the very core" of the Fourth Amendment "stands the right of a man to retreat into his own home." Silverman v. United
States, 365 U.S. 505, 511 (1961). See also Oliver v. United States, 466 U.S. 170, 178 -179 (1984); Wyman v. J ames, 400 U.S.
309, 316 (1971); Payton v. New York, 445 U.S. 573, 601 (1980).
As a result of the state action in this case, the Soldals' domicile was not only seized, it literally was carried away, giving new
meaning to the term "mobile home." We fail to see how being unceremoniously dispossessed of one's home in the manner
alleged to have occurred here can be viewed as anything but a seizure invoking the protection of the Fourth Amendment.
Whether the Amendment was in fact [506 U.S. 56, 62] violated is, of course, a different question that requires determining if the
seizure was reasonable. That inquiry entails the weighing of various factors, and is not before us.
The Court if Appeals recognized that there had been a seizure, but concluded that it was a seizure only in a "technical" sense,
not within the meaning of the Fourth Amendment. This conclusion followed from a narrow reading of the Amendment, which
the court construed to safeguard only privacy and liberty interests, while leaving unprotected possessory interests where
neither privacy nor liberty was at stake. Otherwise, the court said,
"a constitutional provision enacted two centuries ago [would] make every repossession and eviction with police
assistance actionable under - of all things - the Fourth Amendment[, which] would both trivialize the amendment
and gratuitously shift a large body of routine commercial litigation from the state courts to the federal courts. That
trivializing, this shift, can be prevented by recognizing the difference between possessory and privacy interests."
942 F.2d, at 1077.
Because the officers had not entered Soldal's house, rummaged through his possessions, or, in the Court of Appeals' view,
interfered with his liberty in the course of the eviction, the Fourth Amendment offered no protection against the "grave
deprivation" of property that had occurred. Ibid.
We do not agree with this interpretation of the Fourth Amendment. The Amendment protects the people from unreasonable
searches and seizures of "their persons, houses, papers, and effects." This language surely cuts against the novel holding
below, and our cases unmistakably hold that the Amendment protects property as well as privacy.
[7]
This much [506 U.S. 56, 63]
was made clear in J acobsen, supra, where we explained that the first Clause of the Fourth Amendment
"protects two types of expectations, one involving "searches," the other "seizures." A "search" occurs when an
expectation of privacy that society is prepared to consider reasonable is infringed. A "seizure" of property occurs
where there is some meaningful interference with an individual's possessory interests in that property." 466 U.S., at
113 (footnote omitted).
See also id., at 120; Horton v. California, 496 U.S. 128, 133 (1990); Arizona v. Hicks, 480 U.S. 321, 328 (1987); Maryland v.
Macon, 472 U.S. 463, 469 (1985); Texas v. Brown, 460 U.S. 730, 747 -748 (1983) (STEVENS, J ., concurring in judgment);
United States v. Salvucci, 448 U.S. 83, 91 , n. 6 (1980). Thus, having concluded that chemical testing of powder found in a
package did not compromise its owner's privacy, the Court in J acobsen did not put an end to its inquiry, as would be required
under the view adopted by the Court of Appeals and advocated by respondents. Instead, adhering to the teachings of United
States v. Place, 462 U.S. 696 (1983), it went on to determine whether the invasion of the owners' "possessory interests"
occasioned by the destruction of the powder was reasonable under the Fourth Amendment. J acobsen, supra, at 124-125. In
Place, although we found that subjecting luggage to a "dog sniff" did not constitute a search for Fourth Amendment purposes
because it did not compromise any privacy interest, taking custody of Place's suitcase was deemed an unlawful seizure, for it
unreasonably infringed "the suspect's possessory interest in his luggage." 462 U.S., at 708 . 8 Although lacking a privacy
component, the property rights in both instances nonetheless were not [506 U.S. 56, 64] disregarded, but rather were afforded
Fourth Amendment protection.
Respondents rely principally on precedents such as Katz v. United States, 389 U.S. 347 (1967), Warden, Maryland
Penitentiary v. Hayden, 387 U.S. 294 (1967), and Cardwell v. Lewis, 417 U.S. 583 (1974), to demonstrate that the Fourth
Amendment is only marginally concerned with property rights. But the message of those cases is that property rights are not
the sole measure of Fourth Amendment violations. The Warden opinion thus observed, citing J ones v. United States, 362 U.S.
257 (1960), and Silverman v. United States, 365 U.S. 505 (1961), that the "principal" object of the Amendment is the
protection of privacy, rather than property, and that "this shift in emphasis from property to privacy has come about through a
subtle interplay of substantive and procedural reform." 387 U.S., at 304 . There was no suggestion that this shift in emphasis
had snuffed out the previously recognized protection for property under the Fourth Amendment. Katz, in declaring violative of
the Fourth Amendment the unwarranted overhearing of a telephone booth conversation, effectively ended any lingering
notions that the protection of privacy depended on trespass into a protected area. In the course of its decision, the Katz Court
stated that the Fourth Amendment can neither be translated into a provision dealing with constitutionally protected areas nor
into a general constitutional right to privacy. The Amendment, the Court said, protects individual privacy against certain kinds
of governmental intrusion, "but its protections go further, and often have nothing to do with privacy at all." 389 U.S., at 350 .
As for Cardwell, a plurality of this Court held in that case that the Fourth Amendment did not bar the use in evidence of paint
scrapings taken from and tire treads observed on the defendant's automobile, which had been seized in a parking lot and towed
to a police lockup. Gathering this evidence was not deemed to be a search, for nothing from the [506 U.S. 56, 65] interior of the
car and "no personal effects, which the Fourth Amendment traditionally has been deemed to protect" were searched or seized.
417 U.S., at 591 (opinion of BLACKMUN, J .). No meaningful privacy rights were invaded. But this left the argument,
pressed by the dissent, that the evidence gathered was the product of a warrantless, and hence illegal, seizure of the car from
the parking lot where the defendant had left it. However, the plurality was of the view that, because, under the circumstances
of the case, there was probable cause to seize the car as an instrumentality of the crime, Fourth Amendment precedent
permitted the seizure without a warrant. Id., at 593. Thus, both the plurality and dissenting J ustices considered the defendant's
auto deserving of Fourth Amendment protection even though privacy interests were not at stake. They differed only in the
degree of protection that the Amendment demanded.
The Court of Appeals appeared to find more specific support for confining the protection of the Fourth Amendment to privacy
interests in our decision in Hudson v. Palmer, 468 U.S. 517 (1984). There, a state prison inmate sued, claiming that prison
guards had entered his cell without consent and had seized and destroyed some of his personal effects. We ruled that an
inmate, because of his status, enjoyed neither a right to privacy in his cell nor protection against unreasonable seizures of his
personal effects. Id., at 526-528, and n. 8; id., at 538 (O'CONNOR, J ., concurring). Whatever else the case held, it is of
limited usefulness outside the prison context with respect to the coverage of the Fourth Amendment.
We thus are unconvinced that any of the Court's prior cases supports the view that the Fourth Amendment protects against
unreasonable seizures of property only where privacy or liberty is also implicated. What is more, our "plain view" decisions
make untenable such a construction of the Amendment. Suppose, for example, that police officers lawfully enter a house, by
either complying with the warrant requirement or satisfying one of its recognized exceptions - [506 U.S. 56, 66] e.g., through a
valid consent or a showing of exigent circumstances. If they come across some item in plain view and seize it, no invasion of
personal privacy has occurred. Horton, 496 U.S., at 133 -134; Brown, supra, at 739 (opinion of REHNQUIST, J .). If the
boundaries of the Fourth Amendment were defined exclusively by rights of privacy, "plain view" seizures would not implicate
that constitutional provision at all. Yet, far from being automatically upheld, "plain view" seizures have been scrupulously
subjected to Fourth Amendment inquiry. Thus, in the absence of consent or a warrant permitting the seizure of the items in
question, such seizures can be justified only if they meet the probable-cause standard, Arizona v. Hicks, 480 U.S. 321, 326 -
327 (1987), 9 and if they are unaccompanied by unlawful trespass, Horton, 496 U.S., at 136 -137. 10 That is because, the
absence of a privacy interest notwithstanding, "[a] seizure of the article ... would obviously invade the owner's possessory
interest." Id., at 134; see also Brown, 460 U.S., at 739 (opinion of REHNQUIST, J .). The plain-view doctrine "merely reflects
an application of the Fourth Amendment's central requirement of reasonableness to the law governing seizures of property."
Ibid.; Coolidge v. New Hampshire, 403 U.S. 443, 468 (1971); id., at 516 (WHITE, J ., concurring and dissenting).
The Court of Appeals understandably found it necessary to reconcile its holding with our recognition in the plain-view cases
that the Fourth Amendment protects property as such. In so doing, the court did not distinguish this case on the ground that
the seizure of the Soldals' home took place in a [506 U.S. 56, 67] noncriminal context. Indeed, it acknowledged what is evident
from our precedents - that the Amendment's protection applies in the civil context as well. See O'Connor v. Ortega, 480 U.S.
709 (1987); New J ersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v. Tyler, 436 U.S. 499, 504 -506 (1978);
Marshall v. Barlow's, Inc., 436 U.S. 307, 312 -313 (1978); Camara v. Municipal Court of San Francisco, 387 U.S. 523, 528
(1967). 11
Nor did the Court of Appeals suggest that the Fourth Amendment applied exclusively to law enforcement activities. It
observed, for example, that the Amendment's protection would be triggered "by a search or other entry into the home incident
to an eviction or repossession," 942 F.2d, at 1077. 12 Instead, the court sought to explain why the Fourth Amendment protects
against seizures of property in the plain-view context, but not in this case, as follows:
"[S]eizures made in the course of investigations by police or other law enforcement officers are almost always, as
in the plain view cases, the culmination of searches. The police search in order to seize, and it is the search [506 U.S.
56, 68] and ensuing seizure that the Fourth Amendment, by its reference to "searches and seizures," seeks to regulate.
Seizure means one thing when it is the outcome of a search; it may mean something else when it stands apart from
a search or any other investigative activity. The Fourth Amendment may still nominally apply, but, precisely
because there is no invasion of privacy, the usual rules do not apply." Id., at 1079 (emphasis in original).
We have difficulty with this passage. The court seemingly construes the Amendment to protect only against seizures that are
the outcome of a search. But our cases are to the contrary, and hold that seizures of property are subject to Fourth Amendment
scrutiny even though no search within the meaning of the Amendment has taken place. See, e.g., J acobsen, 466 U.S., at 120 -
125; Place, 462 U.S., at 706 -707; Cardwell, 417 U.S., at 588 -589. 13 More generally, an officer who happens to come across
an individual's property in a public area could seize it only if Fourth Amendment standards are satisfied - for example, if the
items are evidence of a crime or contraband. Cf. Payton v. New York, [506 U.S. 56, 69] 445 U.S., at 587 . We are also puzzled by
the last sentence of the excerpt, where the court announces that the "usual rules" of the Fourth Amendment are inapplicable if
the seizure is not the result of a search or any other investigative activity "precisely because there is no invasion of privacy."
For the plain-view cases clearly state that, notwithstanding the absence of any interference with privacy, seizures of effects
that are not authorized by a warrant are reasonable only because there is probable cause to associate the property with criminal
activity. The seizure of the weapons in Horton, for example, occurred in the midst of a search, yet we emphasized that it did
not "involve any invasion of privacy." 496 U.S., at 133 . In short, our statement that such seizures must satisfy the Fourth
Amendment and will be deemed reasonable only if the item's incriminating character is "immediately apparent," id., at 136-
137, is at odds with the Court of Appeals' approach.
The Court of Appeals' effort is both interesting and creative, but, at bottom, it simply reasserts the earlier thesis that the
Fourth Amendment protects privacy, but not property. We remain unconvinced, and see no justification for departing from our
prior cases. In our view, the reason why an officer might enter a house or effectuate a seizure is wholly irrelevant to the
threshold question whether the Amendment applies. What matters is the intrusion on the people's security from governmental
interference. Therefore, the right against unreasonable seizures would be no less transgressed if the seizure of the house was
undertaken to collect evidence, verify compliance with a housing regulation, effect an eviction by the police, or on a whim, for
no reason at all. As we have observed on more than one occasion, it would be "anomalous to say that the individual and his
private property are fully protected by the Fourth Amendment only when the individual is suspected of criminal behavior."
Camara 387 U.S., at 530 ; see also O'Connor, 480 U.S., at 715 ; T.L.O., 469 U.S., at 335 . [506 U.S. 56, 70]
The Court of Appeals also stated that, even if, contrary to its previous rulings, "there is some element or tincture of a Fourth
Amendment seizure, it cannot carry the day for the Soldals." 942 F.2d, at 1080. Relying on our decision in Graham v. Connor,
490 U.S. 386 (1989), the court reasoned that it should look at the "dominant character of the conduct challenged in a section
1983 case [to] determine the constitutional standard under which it is evaluated." 942 F.2d, at 1080. Believing that the Soldals'
claim was more akin to a challenge against the deprivation of property without due process of law than against an
unreasonable seizure, the court concluded that they should not be allowed to bring their suit under the guise of the Fourth
Amendment.
But we see no basis for doling out constitutional protections in such fashion. Certain wrongs affect more than a single right,
and, accordingly, can implicate more than one of the Constitution's commands. Where such multiple violations are alleged, we
are not in the habit of identifying, as a preliminary matter, the claim's "dominant" character. Rather, we examine each
constitutional provision in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment and Fourteenth
Amendment Due Process Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth Amendment and Fourteenth Amendment
Due Process Clause). Graham is not to the contrary. Its holding was that claims of excessive use of force should be analyzed
under the Fourth Amendment's reasonableness standard, rather than the Fourteenth Amendment's substantive due process test.
We were guided by the fact that, in that case, both provisions targeted the same sort of governmental conduct and, as a result,
we chose the more "explicit textual source of constitutional protection" over the "more generalized notion of `substantive due
process.'" 490 U.S., at 394 -395. Surely, Graham does not bar resort in this case to the Fourth Amendment's specific
protection for "houses, papers, [506 U.S. 56, 71] and effects," rather than the general protection of property in the Due Process
Clause.
III
Respondents are fearful, as was the Court of Appeals, that applying the Fourth Amendment in this context inevitably will
carry it into territory unknown and unforeseen: routine repossessions, negligent actions of public employees that interfere with
individuals' right to enjoy their homes, and the like, thereby federalizing areas of law traditionally the concern of the States.
For several reasons, we think the risk is exaggerated. To begin, our decision will have no impact on activities such as
repossessions or attachments if they involve entry into the home, intrusion on individuals' privacy, or interference with their
liberty, because they would implicate the Fourth Amendment even on the Court of Appeals' own terms. This was true of the
Tenth Circuit's decision in Specht, with which, as we previously noted, the Court of Appeals expressed agreement.
More significantly, "reasonableness is still the ultimate standard" under the Fourth Amendment, Camara, supra, at 539, which
means that numerous seizures of this type will survive constitutional scrutiny. As is true in other circumstances, the
reasonableness determination will reflect a "careful balancing of governmental and private interests." T.L.O., supra, at 341.
Assuming, for example, that the officers were acting pursuant to a court order, as in Specht v. J ensen, 832 F.2d 1516 (CA10
1987), or Fuentes v. Shevin, 407 U.S. 67 , (1972), and, as often would be the case, a showing of unreasonableness on these
facts would be a laborious task indeed. Cf. Simms v. Slacum, 3 Cranch 300, 301 (1806). Hence, while there is no guarantee
against the filing of frivolous suits, had the ejection in this case properly awaited the state court's judgment, it is quite unlikely
that the federal court would have been bothered with a 1983 action alleging a Fourth Amendment violation. [506 U.S. 56, 72]
Moreover, we doubt that the police will often choose to further an enterprise knowing that it is contrary to the law, or proceed
to seize property in the absence of objectively reasonable grounds for doing so. In short, our reaffirmance of Fourth
Amendment principles today should not foment a wave of new litigation in the federal courts.
IV
The complaint here alleges that respondents, acting under color of state law, dispossessed the Soldals of their trailer home by
physically tearing it from its foundation and towing it to another lot. Taking these allegations as true, this was no "garden
variety" landlord-tenant or commercial dispute. The facts alleged suffice to constitute a "seizure" within the meaning of the
Fourth Amendment, for they plainly implicate the interests protected by that provision. The judgment of the Court of Appeals
is, accordingly, reversed, and the case is remanded for further proceedings consistent with this opinion.
So ordered.
Footnotes
[1] J ones' statement was prompted by a district attorney's advice that no criminal charges could be brought because, under
Illinois law, a criminal action cannot be used to determine the right of possession. See Ill.Rev.Stat. ch. 110, 9-101 et seq.
(1991); People v. Evans, 163 Ill.App. 3d 561, 114 Ill.Dec. 662, 516 N.E.2d 817 (1st Dist. 1987).
"Every person who, under color of any statute, ordinance, regulation, custom or usage, of any State ... subjects, or
causes to be subjected, any citizen of the United States ... to the deprivation of any rights, privileges, or immunities
secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other
proper proceeding for redress."
[4] The court reiterated the panel's conclusion that a conspiracy must be assumed on the state of the record and, therefore, that
the case must be treated in its current posture "as if the deputy sheriffs themselves seized the trailer, disconnected it from the
utilities, and towed it away." 942 F.2d 1073, 1075 (CA7 1991) (en banc).
[5] The court noted that, in light of the existence of adequate judicial remedies under state law, a claim for deprivation of
property without due process of law was unlikely to succeed. Id., at 1075-1076. See Parratt v. Taylor, 451 U.S. 527 (1981). In
any event, the Soldals did not claim a violation of their procedural rights. As noted, the Seventh Circuit also held that
respondents had not violated the Soldals' substantive due process rights under the Fourteenth Amendment. Petitioners assert
that this was error, but, in view of our disposition of the case, we need not address the question at this time.
[6] Under 42 U.S.C. 1983, the Soldals were required to establish that the respondents, acting under color of state law, deprived
them of a constitutional right, in this instance, their Fourth and Fourteenth Amendment freedom from unreasonable seizures by
the State. See Monroe v. Pape, [506 U.S. 56, 61] 365 U.S. 167, 184 (1961). Respondents request that we affirm on the ground that
the Court of Appeals erred in holding that there was sufficient state action to support a 1983 action. The alleged injury to the
Soldals, it is urged, was inflicted by private parties for whom the county is not responsible. Although respondents did not
cross-petition, they are entitled to ask us to affirm on that ground if such action would not enlarge the judgment of the Court
of Appeals in their favor. The Court of Appeals found that, because the police prevented Soldal from using reasonable force to
protect his home from private action that the officers knew was illegal, there was sufficient evidence of conspiracy between the
private parties and the officers to foreclose summary judgment for respondents. We are not inclined to review that holding.
See Adickes v. S.H. Kress & Co., 398 U.S. 144, 152 -161 (1970).
[7] In holding that the Fourth Amendment's reach extends to property as such, we are mindful that the Amendment does not
protect possessory interests in all kinds of property. See, e.g., Oliver v. United States, 466 U.S. 170, 176 -177 (1984). This
case, however, concerns a house, which the Amendment's language explicitly includes, as it does a person's effects.
[8] Place also found that to detain luggage for 90 minutes was an unreasonable deprivation of the individual's "liberty interest
in proceeding with his itinerary," which also is protected by the Fourth Amendment. 462 U.S., at 708 -710.
[9] When "operational necessities" exist, seizures can be justified on less than probable cause. 480 U.S., at 327 . That in no
way affects our analysis, for even then it is clear that the Fourth Amendment applies. Ibid; see also United States v. Place, 462
U.S. 696 , at 703 (1983).
[10] Of course, if the police officers' presence in the home itself entailed a violation of the Fourth Amendment, no amount of
probable cause to believe that an item in plain view constitutes incriminating evidence will justify its seizure. Horton, 496
U.S., at 136 -137.
[11] It is true that Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), cast some doubt on the
applicability of the Amendment to noncriminal encounters such as this. Id., 18 How. at 285. But cases since that time have
shed a different light, making clear that Fourth Amendment guarantees are triggered by governmental searches and seizures
"without regard to the use to which [houses, papers, and effects] are applied." Warden, Maryland Penitentiary v. Hayden, 387
U.S. 294, 301 (1967). Murray's Lessee's broad statement that the Fourth Amendment "has no reference to civil proceedings
for the recovery of debt" arguably only meant that the warrant requirement did not apply, as was suggested in G.M. Leasing
Corp. v. United States, 429 U.S. 338, 352 (1977). Whatever its proper reading, we reaffirm today our basic understanding that
the protection against unreasonable searches and seizures fully applies in the civil context.
[12] This was the view expressed by the Court of Appeals for the Tenth Circuit in Specht v. J ensen, 832 F.2d 1516 (1987),
remanded on unrelated grounds, 853 F.2d 805 (1988) (en banc), with which the Seventh Circuit expressly agreed. 942 F.2d, at
1076.
[13] The officers in these cases were engaged in law enforcement, and were looking for something that was found and seized.
In this broad sense, the seizures were the result of "searches," but not in the Fourth Amendment sense. That the Court of
Appeals might have been suggesting that the plain-view cases are explainable because they almost always occur in the course
of law enforcement activities receives some support from the penultimate sentence of the quoted passage, where the court
states that the word "seizure" might lose its usual meaning "when it stands apart from a search or any other investigative
activity." Id., at 1079 (emphasis added). And, in the following paragraph, it observes that, "[o]utside of the law enforcement
area, the Fourth Amendment retains its force as a protection against searches, because they invade privacy. That is why we
decline to confine the amendment to the law enforcement setting." Id., at 1079-1080. Even if the court meant that seizures of
property in the course of law enforcement activities, whether civil or criminal, implicate interests safeguarded by the Fourth
Amendment, but that pure property interests are unprotected in the non-law-enforcement setting, we are not in accord, as
indicated in the body of this opinion. [506 U.S. 56, 73]

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

Date: Tue, 26 J un 2012 09:10:14 -0700
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
fee deficiency.
milllerr@reno.gov
Date: Tue, 26 J un 2012 07:58:36 -0700
J ustice Court.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
Fwd: Wheeler v cross 344 fed apps 420
Wheeler v cross 344 fed apps 420
please provide to J udge Gardner, seeking permission to file
Civil
Evictions
Small Claims
Sent: Wed 7/25/12 1:43 PM
To: kadlicj@reno.gov
My J uly 3 disturbing the peace arrest was for conduct allegedly outside officers presence...impermissible Search of vehicle....I
don't want much....
-------- Original message --------
Subject: Wheeler v cross 344 fed apps 420
From: Zach Coughlin <zachcoughlin@hotmail.com>
CC:
is a lot like the arrest Rpd did on me J uly 3 2012. Doing 17 days in jail....Rpd ignored the video and police report I filed J une 5
2012 showing an assault and admission of attempted Break in and trespass by northerns apt staff, one of whom signed the
criminal complaint in my d
Sent: Wed 7/25/12 1:39 PM
is a lot like the arrest Rpd did on me J uly 3 2012. Doing 17 days in jail....Rpd ignored the video and police report I filed J une 5
2012 showing an assault and admission of attempted Break in and trespass by northerns apt staff, one of whom signed the
criminal complaint in my d
Sent: Tue 7/24/12 6:40 PM
To: renomunirecords@reno.gov; ballardd@reno.gov
1 attachment
11 cr 25405 soldal version final[1].pdf (129.0 KB)
Dear RMC,

I am unable to print this document (I have no money and much of my property is being illegally withheld by a landlord...) that
I attempted to filed on or about 6/25/12...i did serve it to C. Hazlett-Stevens of the City Attorney's Office and I attempted to
file it in person...near 5pm...I have been told by Mr. Tuttle of the RJ C that the doors lock on a timer at 5pm...Well, I was not
locked out...but the Deputy at the metal detector turned me away, citing that it was closing time....I was arrested twice in the
motion for new trial
next few days, though I believe I tried to fax this to the RMC (as an emergency measure and hopefully not in violation of
J udge Gardners earlier Order regarding faxing....) on or about 6/30/12...

Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 6/28/12 2:13 AM
To: hazlett-stevensc@reno.gov; kadlicj@reno.gov
1 attachment
11 cr 25405 soldal version final.pdf (154.9 KB)
Zach Coughlin,Esq.
Nevada Bar No: 9473 (currently suspended)
PO BOX 3961
Reno, NV 89505
tel: 775 338 8118
fax: 949 667 7402
Pro Se Defendant
regardin 11 cr 22176: Motion for New Trial, etc. (14 pages)
also sent to Hon. J udge William Gardner
1 South Sierra Street, P.O. Box 1900 reno nv
* Fax number:
7753343859
Christopher P. Hazlett-Stevens Company: Reno City Attorney's Office Address: P. O. Box 1900 ~Reno , NV 89505 Phone Number: 775-326-
6628 Fax number: 775-334-4226 Email: hazlett-stevensc@reno.gov
Dear J udge Gardner and Mr. Hazlett-Stevens,
I attempted to file a tolling motion on J une 25th and again on J une 26th, 2012. on the 25th Filing office supervisor Donna Ballard and Court
Administrator Cassandra J ackson decided to refuse to accept my filing, apparently. Then on J une 26th, 2012, I ented the court prior to the
"timed lockign of the doors" that I have been educated on previously by court adminstration in relation to seekign to file documents close to
closing time, however, I was again refused in my attempt to file another such tolling motion and to access justice. I am fax this filing to both
of you, with the caveat that I do not wish to violate any dicate against fax filign that J udge Gardner may have in effect (I am a bit unclear
FW: Reno eviction noticed for Sparks Justice Court
Zach Coughlin (zachcoughlin@hotmailcom!"#$%#&%
'o: k(ro)n@nv(arorg* milllerr@renogov* millerr@renogov* stuttle@)ashoecount+gov*
rsilva@)ashoecount+us* stuttle@)ashoecount+us* ,amchen@)ashoecount+us* $-"nor.@acgcom*
info@acg/apmicom* r,c)e(@)asoecount+us* ,(oles@callatgcom* apminfo@acgcom
From: Zach Coughlin (zachcoughlin@hotmailcom!
Sent: 0on "#$%#&% 1:%& 20
'o: k(ro)n@nv(arorg3 milllerr@renogov3 millerr@renogov3 stuttle@)ashoecount+gov3
rsilva@)ashoecount+us3 stuttle@)ashoecount+us3 ,amchen@)ashoecount+us3 $-"nor.@acgcom3
info@acg/apmicom3 r,c)e(@)asoecount+us3 ,(oles@callatgcom3 apminfo@acgcom
4utlook 5ctive 6ie)
% attachments (total &&7.7 89!
coughlin v north)ind &7:'enants5ffidavit:;eclaration4ther:2rivate<ousing other than nonpa+ment
of rentpdf;o)nload
com(ined north)ind v coughlin eviction filingspdf;o)nload
;o)nload all as zip
=4rth)ind and =evada Court Services served and >amended 1 da+ notice of unla)ful detainer on Jul+
%?th* %$&%>giving me five da+s to get m+ stuff out of unit %? (the one the su(,ect of Judge Schroeer@s
Aviction 4rder* )hich )as effectivel+ rescinded (+ their serving a ne) 1 da+ unla)ful detainer
notice! as )ell as units "& and .1)hicih are t)o units to )hich i still have valide lease agreements*
ie* B cannot (e trespassing for accessing them (the Reno 2; has indicated the+ )ill arrest me for
criminal trespass for accessing an+ units in the compleC* including those to )hich B still have a valid
possessor+ or propert+ interest* in violation of .% usc &?D-!

)h+ does Sargent 0iller have to give me a hard timeE Bsn@t it enough for him to have his >;enzel>
good looks and a much higher pa+ing ,o( than B )ill ever haveE What up )it thatE

=orth)ind and =evada Court Services ()hich is practicing eviction la) )ithout a license! scre)ed up
and put >Sparks Justice Court on Freen(rae> as the place for the tenant to file a 'enan@ts 5ns)er or
5ffidavit ;oing so )ill make the RJC 4rder (+ Judge Schroeder null and void (8aren Stancil* Chief
Civil Clerk at RJC admits this* (ut reall+* the fault lies )ith =CS and =orth)ind* not the committed
professional at the RJC!
'he =otice must identif+ the Court )ith ,urisdiction =RS .$%1-(-!(a! 4=e cannot (e trespassing in
a plac)e )here the+ have a valid reason for (eing or a la)ful right to (e =RS %$"%$$* R0C
D&$$.$

Bn 5ikins v 5ndre)s* ?& =ev ".7* 1.% 2%d "-. (&?"1!* the Supreme C4Gli construed the
predecessor statute to =RS .$%1&7 to mean that the alternative five (1! da+ notice must (e given
&#&%
7
(efore the tenants can (e dispossed and a lease can (e validl+ terminated 'he court stated that this
five (1! da+ notice reHuirement > neither can (e )aved nor neglected> ?& =ev at ".D
ttp:##)))constitutionorg#ussc#1$7/$17ahtm

GS Supreme Court
S4I;5I v C448 C4G='J* 1$7 GS 17 (&??%!
1$7 GS 17 S4I;5I* A' GK v C448 C4G='J* BIIB=4BS A' 5I
CAR'B4R5RB '4 '<A G=B'A; S'5'AS C4GR' 4F 522A5IS F4R '<A
SA6A='< CBRCGB'
=o ?&/71&7
5rgued 4cto(er 1* &??%
;ecided ;ecem(er D* &??%
While eviction proceedings )ere pending* 'errace 2roperties and 0argaret <ale forci(l+ evicted
petitioners* the Soldal famil+* and their mo(ile home from a 'errace 2roperties@ mo(ile home park 5t
<ale@s reHuest* Cook Count+* Bllinois* Sheriff@s ;epartment deputies )ere present at the eviction
5lthough the+ kne) that there )as no eviction order and that 'errace 2roperties@ actions )ere illegal*
the deputies refused to take 0r Soldal@s complaint for criminal trespass or other)ise interfere )ith the
eviction Su(seHuentl+* the state ,udge assigned to the pending eviction proceedings ruled that the
eviction had (een unauthorized* and the trailer* (adl+ damaged during the eviction* )as returned to the
lot 2etitioners (rought an action in the Federal ;istrict Court under .% GSC &?D-* claiming that
'errace 2roperties and <ale had conspired )ith the deput+ sheriffs to unreasona(l+ seize and remove
their home in violation of their Fourth and Fourteenth 5mendment rights 'he court granted defendants@
motion for summar+ ,udgment* and the Court of 5ppeals affirmed 5ckno)ledging that )hat had
occurred )as a >seizure> in the literal sense of the )ord* the court reasoned that it )as not a seizure as
contemplated (+ the Fourth 5mendment (ecause* inter alia* it did not invade petitioners@ privac+
<eld:
'he seizure and removal of the trailer home implicated petitioners@ Fourth 5mendment rights 2p 7&/
"%
(a! 5 >seizure> of propert+ occurs )hen >there is some meaningful interference )ith an individual@s
possessor+ interests in that propert+> Gnited States v Jaco(sen* .77 GS &$?* &&- 'he language of
the Fourth 5mendment / )hich protects people from unreasona(le searches and seizures of >their
persons* houses* papers* and effects> / cuts against the novel holding (elo)* and this Court@s cases
unmistaka(l+ hold that the 5mendment protects propert+ even )here privac+ or li(ert+ is not
implicated See* eg* i(id3 8atz v Gnited States* -D? GS -."* -1$ 'his Court@s >plain vie)>
decisions also make untena(le the lo)er court@s construction of the 5mendment Bf the 5mendment@s
(oundaries )ere defined eCclusivel+ (+ rights of privac+* >plain vie)> seizures* rather than (eing
scrupulousl+ su(,ected to Fourth 5mendment inHuir+* 5rizona v <icks* .D$ GS -%&* -%7 /-%"* )ould
not implicate that constitutional provision at all Contrar+ to the Court of 5ppeals@ L1$7 GS 17* 1"M
position* the 5mendment protects seizure even though no search )ithin its meaning has taken place
See* eg* Jaco(sen* supra* at &%$/&%1 5lso contrar+ to that court@s vie)* Fraham v Connor* .?$ GS
-D7 * does not reHuire a court* )hen it finds that a )rong implicates more than one constitutional
command* to look at the dominant character of the challenged conduct to determine under )hich
%#&%
constitutional standard it should (e evaluated Rather* each constitutional provision is eCamined in turn
See* eg* <udson v 2almer* .7D GS 1&" 2p 7&/"&
((! 'he instant decision should not foment a )ave of ne) litigation in the federal courts 5ctivities such
as repossessions or attachments* if the+ involve entering a home* intruding on individuals@ privac+* or
interfering )ith their li(ert+* )ould implicate the Fourth 5mendment even on the Court of 5ppeals@
o)n terms 5nd numerous seizures of this t+pe )ill survive constitutional scrutin+ on >reasona(leness>
grounds 0oreover* it is unlikel+ that the police )ill often choose to further an enterprise kno)ing that
it is contrar+ to the la)* or proceed to seize propert+ in the a(sence of o(,ectivel+ reasona(le grounds
for doing so 2p "&/"%
?.% F%d &$"-* reversed and remanded
W<B'A* J* delivered the opinion for a unanimous Court
John I Stainthorp argued the cause and filed (riefs for petitioners
8enneth I Fillis argued the cause for respondents With him on the (rief )ere Jack 4@0alle+* Renee
F Foldfar(* and 8enneth ' 0cCurr+ LNM
L Footnote NM James ; <olzhauer* 'imoth+ S 9ishop* John 5 2o)ell* Steven R Shapiro* <arve+ 0
Frossman* and 5lan 8 Chen filed a (rief for the 5merican Civil Ii(erties Gnion et al as amici curiae
urging reversal
Richard Ruda* Carter F 2hillips* 0ark ; <opson* and 0ark A <addad filed a (rief for the =ational
Ieague of Cities et al as amici curiae urging affirmance
JGS'BCA W<B'A delivered the opinion of the Court
B
Ad)ard Soldal and his famil+ resided in their trailer home* )hich )as located on a rented lot in the
Willo)a+ 'errace mo(ile L1$7 GS 17* 1DM home park in Alk Frove* Bllinois Bn 0a+ &?D"* 'errace
2roperties* the o)ner of the park* and 0argaret <ale* its manager* filed an eviction proceeding against
the Soldals in an Bllinois state court Gnder the Bllinois Forci(le Antr+ and ;etainer 5ct* BllRevStat*
ch &&$* O ?/&$& et seH (&??&!* a tenant cannot (e dispossessed a(sent a ,udgment of eviction 'he suit
)as dismissed on June %* &?D" 5 fe) months later* in 5ugust &?D"* the o)ner (rought a second
proceeding of eviction* claiming nonpa+ment of rent 'he case )as set for trial on Septem(er %%* &?D"
Rather than a)ait ,udgment in their favor* 'errace 2roperties and <ale* contrar+ to Bllinois la)* chose to
evict the Soldals forci(l+ t)o )eeks prior to the scheduled hearing 4n Septem(er .* <ale notified the
Cook Count+@s Sheriff@s ;epartment that she )as going to remove the trailer home from the park* and
reHuested the presence of sheriff deputies to forestall an+ possi(le resistance Iater that da+* t)o
'errace 2roperties emplo+ees arrived at the Soldals@ home accompanied (+ Cook Count+ ;eput+
Sheriff 4@=eil 'he emplo+ees proceeded to )rench the se)er and )ater connections off the side of the
trailer home* disconnect the phone* tear off the trailer@s canop+ and skirting* and hook the home to a
tractor 0ean)hile* 4@=eil eCplained to Ad)ard Soldal that >Phe )as there to see that LSoldalM didn@t
interfere )ith LWillo)a+@sM )ork@> 9rief for 2etitioner 7
9+ this time* t)o more deput+ sheriffs had arrived at the scene* and Soldal told them that he )ished to
file a complaint for criminal trespass 'he+ referred him to deput+ Iieutenant Jones* )ho )as in <ale@s
office Jones asked Soldal to )ait outside )hile he remained closeted )ith <ale and other 'errace
2roperties emplo+ees for over %$ minutes 5fter talking to a district attorne+ and making Soldal )ait
another half hour* Jones told Soldal that he )ould not accept a complaint (ecause >Pit )as (et)een the
landlord and the tenant LandM the+ )ere going to go ahead and continue to move L1$7 GS 17* 1?M
out the trailer@> Bd* at D & 'hroughout this period* the deput+ sheriffs kne) that 'errace 2roperties did
not have an eviction order and that its actions )ere unla)ful Aventuall+* and in the presence of an
additional t)o deput+ sheriffs* the Willo)a+ )orkers pulled the trailer free of its moorings and to)ed it
onto the street Iater* it )as hauled to a neigh(oring propert+
-#&%
4n Septem(er ?* the state ,udge assigned to the pending eviction proceedings ruled that the eviction
had (een unauthorized* and ordered 'errace 2roperties to return the Soldals@ home to the lot 'he home*
ho)ever* )as (adl+ damaged L%M 'he Soldals (rought this action under .% GSC &?D-* alleging a
violation of their rights under the Fourth and Fourteenth 5mendments 'he+ claimed that 'errace
2roperties and <ale had conspired )ith Cook Count+ deput+ sheriffs to unreasona(l+ seize and remove
the Soldals@ trailer home 'he ;istrict Judge granted defendants@ motion for summar+ ,udgment on the
grounds that the Soldals had failed to adduce an+ evidence to support their conspirac+ theor+ and*
therefore* the eCistence of state action necessar+ under &?D- L-M
'he Court of 5ppeals for the Seventh Circuit* construing the facts in petitioners@ favor* accepted their
contention that there )as state action <o)ever* it )ent on to hold that L1$7 GS 17* 7$M the removal of
the Soldals@ trailer did not constitute a seizure for purposes of the Fourth 5mendment or a deprivation
of due process for purposes of the Fourteenth
4n rehearing* a ma,orit+ of the Seventh Circuit* sitting en (anc* reaffirmed the panel decision L.M
5ckno)ledging that )hat had occurred )as a >seizure> in the literal sense of the )ord* the court
reasoned that* (ecause it )as not made in the course of pu(lic la) enforcement* and (ecause it did not
invade the Soldals@ privac+* it )as not a seizure as contemplated (+ the Fourth 5mendment ?.% F%d
&$"-* &$"7 (&??&! Bnterpreting prior cases of this Court* the Seventh Circuit concluded that* a(sent
interference )ith privac+ or li(ert+* a >pure deprivation of propert+> is not cogniza(le under the Fourth
5mendment Bd* at &$"D/&$"? Rather* petitioners@ propert+ interests )ere protected onl+ (+ the ;ue
2rocess Clauses of the Fifth and Fourteenth 5mendments L1M
We granted certiorari to consider )hether the seizure and removal of the Soldals@ trailer home
implicated their Fourth 5mendment rights* 1$- GS ?&D (&??%!* and no) reverse L7M L1$7 GS 17*
7&M
BB
'he Fourth 5mendment* made applica(le to the States (+ the Fourteenth* 8er v California* -". GS
%-* -$ (&?7-!* provides in pertinent part that the >right of the people to (e secure in their persons*
houses* papers* and effects* against unreasona(le searches and seizures* shall not (e violated >
5 >seizure> of propert+* )e have eCplained* occurs )hen >there is some meaningful interference )ith
an individual@s possessor+ interests in that propert+> Gnited States v Jaco(sen* .77 GS &$?* &&-
(&?D.! Bn addition* )e have emphasized that >at the ver+ core> of the Fourth 5mendment >stands the
right of a man to retreat into his o)n home> Silverman v Gnited States* -71 GS 1$1* 1&& (&?7&! See
also 4liver v Gnited States* .77 GS &"$* &"D /&"? (&?D.!3 W+man v James* .$$ GS -$?* -&7
(&?"&!3 2a+ton v =e) Jork* ..1 GS 1"-* 7$& (&?D$!
5s a result of the state action in this case* the Soldals@ domicile )as not onl+ seized* it literall+ )as
carried a)a+* giving ne) meaning to the term >mo(ile home> We fail to see ho) (eing
unceremoniousl+ dispossessed of one@s home in the manner alleged to have occurred here can (e
vie)ed as an+thing (ut a seizure invoking the protection of the Fourth 5mendment Whether the
5mendment )as in fact L1$7 GS 17* 7%M violated is* of course* a different Huestion that reHuires
determining if the seizure )as reasona(le 'hat inHuir+ entails the )eighing of various factors* and is
not (efore us
'he Court if 5ppeals recognized that there had (een a seizure* (ut concluded that it )as a seizure onl+
in a >technical> sense* not )ithin the meaning of the Fourth 5mendment 'his conclusion follo)ed
from a narro) reading of the 5mendment* )hich the court construed to safeguard onl+ privac+ and
li(ert+ interests* )hile leaving unprotected possessor+ interests )here neither privac+ nor li(ert+ )as at
stake 4ther)ise* the court said*
>a constitutional provision enacted t)o centuries ago L)ouldM make ever+ repossession and eviction
)ith police assistance actiona(le under / of all things / the Fourth 5mendmentL* )hichM )ould (oth
.#&%
trivialize the amendment and gratuitousl+ shift a large (od+ of routine commercial litigation from the
state courts to the federal courts 'hat trivializing* this shift* can (e prevented (+ recognizing the
difference (et)een possessor+ and privac+ interests> ?.% F%d* at &$""
9ecause the officers had not entered Soldal@s house* rummaged through his possessions* or* in the Court
of 5ppeals@ vie)* interfered )ith his li(ert+ in the course of the eviction* the Fourth 5mendment
offered no protection against the >grave deprivation> of propert+ that had occurred B(id
We do not agree )ith this interpretation of the Fourth 5mendment 'he 5mendment protects the people
from unreasona(le searches and seizures of >their persons* houses* papers* and effects> 'his language
surel+ cuts against the novel holding (elo)* and our cases unmistaka(l+ hold that the 5mendment
protects propert+ as )ell as privac+ L"M 'his much L1$7 GS 17* 7-M )as made clear in Jaco(sen*
supra* )here )e eCplained that the first Clause of the Fourth 5mendment
>protects t)o t+pes of eCpectations* one involving >searches*> the other >seizures> 5 >search> occurs
)hen an eCpectation of privac+ that societ+ is prepared to consider reasona(le is infringed 5 >seizure>
of propert+ occurs )here there is some meaningful interference )ith an individual@s possessor+
interests in that propert+> .77 GS* at &&- (footnote omitted!
See also id* at &%$3 <orton v California* .?7 GS &%D* &-- (&??$!3 5rizona v <icks* .D$ GS -%&*
-%D (&?D"!3 0ar+land v 0acon* ."% GS .7-* .7? (&?D1!3 'eCas v 9ro)n* .7$ GS "-$* "." /".D
(&?D-! (S'A6A=S* J* concurring in ,udgment!3 Gnited States v Salvucci* ..D GS D-* ?& * n 7
(&?D$! 'hus* having concluded that chemical testing of po)der found in a package did not
compromise its o)ner@s privac+* the Court in Jaco(sen did not put an end to its inHuir+* as )ould (e
reHuired under the vie) adopted (+ the Court of 5ppeals and advocated (+ respondents Bnstead*
adhering to the teachings of Gnited States v 2lace* .7% GS 7?7 (&?D-!* it )ent on to determine
)hether the invasion of the o)ners@ >possessor+ interests> occasioned (+ the destruction of the po)der
)as reasona(le under the Fourth 5mendment Jaco(sen* supra* at &%./&%1 Bn 2lace* although )e found
that su(,ecting luggage to a >dog sniff> did not constitute a search for Fourth 5mendment purposes
(ecause it did not compromise an+ privac+ interest* taking custod+ of 2lace@s suitcase )as deemed an
unla)ful seizure* for it unreasona(l+ infringed >the suspect@s possessor+ interest in his luggage> .7%
GS* at "$D D 5lthough lacking a privac+ component* the propert+ rights in (oth instances
nonetheless )ere not L1$7 GS 17* 7.M disregarded* (ut rather )ere afforded Fourth 5mendment
protection
Respondents rel+ principall+ on precedents such as 8atz v Gnited States* -D? GS -." (&?7"!*
Warden* 0ar+land 2enitentiar+ v <a+den* -D" GS %?. (&?7"!* and Card)ell v Ie)is* .&" GS 1D-
(&?".!* to demonstrate that the Fourth 5mendment is onl+ marginall+ concerned )ith propert+ rights
9ut the message of those cases is that propert+ rights are not the sole measure of Fourth 5mendment
violations 'he Warden opinion thus o(served* citing Jones v Gnited States* -7% GS %1" (&?7$!* and
Silverman v Gnited States* -71 GS 1$1 (&?7&!* that the >principal> o(,ect of the 5mendment is the
protection of privac+* rather than propert+* and that >this shift in emphasis from propert+ to privac+ has
come a(out through a su(tle interpla+ of su(stantive and procedural reform> -D" GS* at -$. 'here
)as no suggestion that this shift in emphasis had snuffed out the previousl+ recognized protection for
propert+ under the Fourth 5mendment 8atz* in declaring violative of the Fourth 5mendment the
un)arranted overhearing of a telephone (ooth conversation* effectivel+ ended an+ lingering notions
that the protection of privac+ depended on trespass into a protected area Bn the course of its decision*
the 8atz Court stated that the Fourth 5mendment can neither (e translated into a provision dealing )ith
constitutionall+ protected areas nor into a general constitutional right to privac+ 'he 5mendment* the
Court said* protects individual privac+ against certain kinds of governmental intrusion* >(ut its
protections go further* and often have nothing to do )ith privac+ at all> -D? GS* at -1$
5s for Card)ell* a pluralit+ of this Court held in that case that the Fourth 5mendment did not (ar the
1#&%
use in evidence of paint scrapings taken from and tire treads o(served on the defendant@s automo(ile*
)hich had (een seized in a parking lot and to)ed to a police lockup Fathering this evidence )as not
deemed to (e a search* for nothing from the L1$7 GS 17* 71M interior of the car and >no personal
effects* )hich the Fourth 5mendment traditionall+ has (een deemed to protect> )ere searched or
seized .&" GS* at 1?& (opinion of 9I5C80G=* J! =o meaningful privac+ rights )ere invaded 9ut
this left the argument* pressed (+ the dissent* that the evidence gathered )as the product of a
)arrantless* and hence illegal* seizure of the car from the parking lot )here the defendant had left it
<o)ever* the pluralit+ )as of the vie) that* (ecause* under the circumstances of the case* there )as
pro(a(le cause to seize the car as an instrumentalit+ of the crime* Fourth 5mendment precedent
permitted the seizure )ithout a )arrant Bd* at 1?- 'hus* (oth the pluralit+ and dissenting Justices
considered the defendant@s auto deserving of Fourth 5mendment protection even though privac+
interests )ere not at stake 'he+ differed onl+ in the degree of protection that the 5mendment
demanded
'he Court of 5ppeals appeared to find more specific support for confining the protection of the Fourth
5mendment to privac+ interests in our decision in <udson v 2almer* .7D GS 1&" (&?D.! 'here* a
state prison inmate sued* claiming that prison guards had entered his cell )ithout consent and had
seized and destro+ed some of his personal effects We ruled that an inmate* (ecause of his status*
en,o+ed neither a right to privac+ in his cell nor protection against unreasona(le seizures of his personal
effects Bd* at 1%7/1%D* and n D3 id* at 1-D (4@C4==4R* J* concurring! Whatever else the case held*
it is of limited usefulness outside the prison conteCt )ith respect to the coverage of the Fourth
5mendment
We thus are unconvinced that an+ of the Court@s prior cases supports the vie) that the Fourth
5mendment protects against unreasona(le seizures of propert+ onl+ )here privac+ or li(ert+ is also
implicated What is more* our >plain vie)> decisions make untena(le such a construction of the
5mendment Suppose* for eCample* that police officers la)full+ enter a house* (+ either compl+ing
)ith the )arrant reHuirement or satisf+ing one of its recognized eCceptions / L1$7 GS 17* 77M eg*
through a valid consent or a sho)ing of eCigent circumstances Bf the+ come across some item in plain
vie) and seize it* no invasion of personal privac+ has occurred <orton* .?7 GS* at &-- /&-.3 9ro)n*
supra* at "-? (opinion of RA<=QGBS'* J! Bf the (oundaries of the Fourth 5mendment )ere defined
eCclusivel+ (+ rights of privac+* >plain vie)> seizures )ould not implicate that constitutional provision
at all Jet* far from (eing automaticall+ upheld* >plain vie)> seizures have (een scrupulousl+ su(,ected
to Fourth 5mendment inHuir+ 'hus* in the a(sence of consent or a )arrant permitting the seizure of the
items in Huestion* such seizures can (e ,ustified onl+ if the+ meet the pro(a(le/cause standard* 5rizona
v <icks* .D$ GS -%&* -%7 /-%" (&?D"!* ? and if the+ are unaccompanied (+ unla)ful trespass*
<orton* .?7 GS* at &-7 /&-" &$ 'hat is (ecause* the a(sence of a privac+ interest not)ithstanding*
>LaM seizure of the article )ould o(viousl+ invade the o)ner@s possessor+ interest> Bd* at &-.3 see
also 9ro)n* .7$ GS* at "-? (opinion of RA<=QGBS'* J! 'he plain/vie) doctrine >merel+ reflects an
application of the Fourth 5mendment@s central reHuirement of reasona(leness to the la) governing
seizures of propert+> B(id3 Coolidge v =e) <ampshire* .$- GS ..-* .7D (&?"&!3 id* at 1&7
(W<B'A* J* concurring and dissenting!
'he Court of 5ppeals understanda(l+ found it necessar+ to reconcile its holding )ith our recognition in
the plain/vie) cases that the Fourth 5mendment protects propert+ as such Bn so doing* the court did
not distinguish this case on the ground that the seizure of the Soldals@ home took place in a L1$7 GS
17* 7"M noncriminal conteCt Bndeed* it ackno)ledged )hat is evident from our precedents / that the
5mendment@s protection applies in the civil conteCt as )ell See 4@Connor v 4rtega* .D$ GS "$?
(&?D"!3 =e) Jerse+ v 'I4* .7? GS -%1* --. /--1 (&?D1!3 0ichigan v '+ler* .-7 GS .??* 1$.
/1$7 (&?"D!3 0arshall v 9arlo)@s* Bnc* .-7 GS -$"* -&% /-&- (&?"D!3 Camara v 0unicipal Court of
7#&%
San Francisco* -D" GS 1%-* 1%D (&?7"! &&
=or did the Court of 5ppeals suggest that the Fourth 5mendment applied eCclusivel+ to la)
enforcement activities Bt o(served* for eCample* that the 5mendment@s protection )ould (e triggered
>(+ a search or other entr+ into the home incident to an eviction or repossession*> ?.% F%d* at &$"" &%
Bnstead* the court sought to eCplain )h+ the Fourth 5mendment protects against seizures of propert+ in
the plain/vie) conteCt* (ut not in this case* as follo)s:
>LSMeizures made in the course of investigations (+ police or other la) enforcement officers are almost
al)a+s* as in the plain vie) cases* the culmination of searches 'he police search in order to seize* and
it is the search L1$7 GS 17* 7DM and ensuing seizure that the Fourth 5mendment* (+ its reference to
>searches and seizures*> seeks to regulate Seizure means one thing )hen it is the outcome of a search3
it ma+ mean something else )hen it stands apart from a search or an+ other investigative activit+ 'he
Fourth 5mendment ma+ still nominall+ appl+* (ut* precisel+ (ecause there is no invasion of privac+*
the usual rules do not appl+> Bd* at &$"? (emphasis in original!
We have difficult+ )ith this passage 'he court seemingl+ construes the 5mendment to protect onl+
against seizures that are the outcome of a search 9ut our cases are to the contrar+* and hold that
seizures of propert+ are su(,ect to Fourth 5mendment scrutin+ even though no search )ithin the
meaning of the 5mendment has taken place See* eg* Jaco(sen* .77 GS* at &%$ /&%13 2lace* .7% GS*
at "$7 /"$"3 Card)ell* .&" GS* at 1DD /1D? &- 0ore generall+* an officer )ho happens to come
across an individual@s propert+ in a pu(lic area could seize it onl+ if Fourth 5mendment standards are
satisfied / for eCample* if the items are evidence of a crime or contra(and Cf 2a+ton v =e) Jork*
L1$7 GS 17* 7?M ..1 GS* at 1D" We are also puzzled (+ the last sentence of the eCcerpt* )here the
court announces that the >usual rules> of the Fourth 5mendment are inapplica(le if the seizure is not
the result of a search or an+ other investigative activit+ >precisel+ (ecause there is no invasion of
privac+> For the plain/vie) cases clearl+ state that* not)ithstanding the a(sence of an+ interference
)ith privac+* seizures of effects that are not authorized (+ a )arrant are reasona(le onl+ (ecause there
is pro(a(le cause to associate the propert+ )ith criminal activit+ 'he seizure of the )eapons in <orton*
for eCample* occurred in the midst of a search* +et )e emphasized that it did not >involve an+ invasion
of privac+> .?7 GS* at &-- Bn short* our statement that such seizures must satisf+ the Fourth
5mendment and )ill (e deemed reasona(le onl+ if the item@s incriminating character is >immediatel+
apparent*> id* at &-7/&-"* is at odds )ith the Court of 5ppeals@ approach
'he Court of 5ppeals@ effort is (oth interesting and creative* (ut* at (ottom* it simpl+ reasserts the
earlier thesis that the Fourth 5mendment protects privac+* (ut not propert+ We remain unconvinced*
and see no ,ustification for departing from our prior cases Bn our vie)* the reason )h+ an officer might
enter a house or effectuate a seizure is )holl+ irrelevant to the threshold Huestion )hether the
5mendment applies What matters is the intrusion on the people@s securit+ from governmental
interference 'herefore* the right against unreasona(le seizures )ould (e no less transgressed if the
seizure of the house )as undertaken to collect evidence* verif+ compliance )ith a housing regulation*
effect an eviction (+ the police* or on a )him* for no reason at all 5s )e have o(served on more than
one occasion* it )ould (e >anomalous to sa+ that the individual and his private propert+ are full+
protected (+ the Fourth 5mendment onl+ )hen the individual is suspected of criminal (ehavior>
Camara -D" GS* at 1-$ 3 see also 4@Connor* .D$ GS* at "&1 3 'I4* .7? GS* at --1 L1$7 GS 17*
"$M
'he Court of 5ppeals also stated that* even if* contrar+ to its previous rulings* >there is some element or
tincture of a Fourth 5mendment seizure* it cannot carr+ the da+ for the Soldals> ?.% F%d* at &$D$
Rel+ing on our decision in Fraham v Connor* .?$ GS -D7 (&?D?!* the court reasoned that it should
look at the >dominant character of the conduct challenged in a section &?D- case LtoM determine the
constitutional standard under )hich it is evaluated> ?.% F%d* at &$D$ 9elieving that the Soldals@ claim
"#&%
)as more akin to a challenge against the deprivation of propert+ )ithout due process of la) than
against an unreasona(le seizure* the court concluded that the+ should not (e allo)ed to (ring their suit
under the guise of the Fourth 5mendment
9ut )e see no (asis for doling out constitutional protections in such fashion Certain )rongs affect
more than a single right* and* accordingl+* can implicate more than one of the Constitution@s
commands Where such multiple violations are alleged* )e are not in the ha(it of identif+ing* as a
preliminar+ matter* the claim@s >dominant> character Rather* )e eCamine each constitutional provision
in turn See* eg* <udson v 2almer* .7D GS 1&" (&?D.! (Fourth 5mendment and Fourteenth
5mendment ;ue 2rocess Clause!3 Bngraham v Wright* .-$ GS 71& (&?""! (Aighth 5mendment and
Fourteenth 5mendment ;ue 2rocess Clause! Fraham is not to the contrar+ Bts holding )as that claims
of eCcessive use of force should (e anal+zed under the Fourth 5mendment@s reasona(leness standard*
rather than the Fourteenth 5mendment@s su(stantive due process test We )ere guided (+ the fact that*
in that case* (oth provisions targeted the same sort of governmental conduct and* as a result* )e chose
the more >eCplicit teCtual source of constitutional protection> over the >more generalized notion of
Psu(stantive due process@> .?$ GS* at -?. /-?1 Surel+* Fraham does not (ar resort in this case to the
Fourth 5mendment@s specific protection for >houses* papers* L1$7 GS 17* "&M and effects*> rather than
the general protection of propert+ in the ;ue 2rocess Clause
BBB
Respondents are fearful* as )as the Court of 5ppeals* that appl+ing the Fourth 5mendment in this
conteCt inevita(l+ )ill carr+ it into territor+ unkno)n and unforeseen: routine repossessions* negligent
actions of pu(lic emplo+ees that interfere )ith individuals@ right to en,o+ their homes* and the like*
there(+ federalizing areas of la) traditionall+ the concern of the States For several reasons* )e think
the risk is eCaggerated 'o (egin* our decision )ill have no impact on activities such as repossessions
or attachments if the+ involve entr+ into the home* intrusion on individuals@ privac+* or interference
)ith their li(ert+* (ecause the+ )ould implicate the Fourth 5mendment even on the Court of 5ppeals@
o)n terms 'his )as true of the 'enth Circuit@s decision in Specht* )ith )hich* as )e previousl+ noted*
the Court of 5ppeals eCpressed agreement
0ore significantl+* >reasona(leness is still the ultimate standard> under the Fourth 5mendment*
Camara* supra* at 1-?* )hich means that numerous seizures of this t+pe )ill survive constitutional
scrutin+ 5s is true in other circumstances* the reasona(leness determination )ill reflect a >careful
(alancing of governmental and private interests> 'I4* supra* at -.& 5ssuming* for eCample* that the
officers )ere acting pursuant to a court order* as in Specht v Jensen* D-% F%d &1&7 (C5&$ &?D"!* or
Fuentes v Shevin* .$" GS 7" * (&?"%!* and* as often )ould (e the case* a sho)ing of
unreasona(leness on these facts )ould (e a la(orious task indeed Cf Simms v Slacum* - Cranch -$$*
-$& (&D$7! <ence* )hile there is no guarantee against the filing of frivolous suits* had the e,ection in
this case properl+ a)aited the state court@s ,udgment* it is Huite unlikel+ that the federal court )ould
have (een (othered )ith a &?D- action alleging a Fourth 5mendment violation L1$7 GS 17* "%M
0oreover* )e dou(t that the police )ill often choose to further an enterprise kno)ing that it is contrar+
to the la)* or proceed to seize propert+ in the a(sence of o(,ectivel+ reasona(le grounds for doing so
Bn short* our reaffirmance of Fourth 5mendment principles toda+ should not foment a )ave of ne)
litigation in the federal courts
B6
'he complaint here alleges that respondents* acting under color of state la)* dispossessed the Soldals of
their trailer home (+ ph+sicall+ tearing it from its foundation and to)ing it to another lot 'aking these
allegations as true* this )as no >garden variet+> landlord/tenant or commercial dispute 'he facts
alleged suffice to constitute a >seizure> )ithin the meaning of the Fourth 5mendment* for the+ plainl+
implicate the interests protected (+ that provision 'he ,udgment of the Court of 5ppeals is*
D#&%
accordingl+* reversed* and the case is remanded for further proceedings consistent )ith this opinion
So ordered
Footnotes
L&M Jones@ statement )as prompted (+ a district attorne+@s advice that no criminal charges could (e
(rought (ecause* under Bllinois la)* a criminal action cannot (e used to determine the right of
possession See BllRevStat ch &&$* O ?/&$& et seH (&??&!3 2eople v Avans* &7- Bll5pp -d 17&* &&.
Bll;ec 77%* 1&7 =A%d D&" (&st ;ist &?D"!
L%M 'he Soldals ultimatel+ )ere evicted per court order in ;ecem(er &?D"
L-M 'itle .% GSC &?D- provides that:
>Aver+ person )ho* under color of an+ statute* ordinance* regulation* custom or usage* of an+ State
su(,ects* or causes to (e su(,ected* an+ citizen of the Gnited States to the deprivation of an+ rights*
privileges* or immunities secured (+ the Constitution and la)s* shall (e lia(le to the part+ in,ured in an
action at la)* suit in eHuit+* or other proper proceeding for redress>
L.M 'he court reiterated the panel@s conclusion that a conspirac+ must (e assumed on the state of the
record and* therefore* that the case must (e treated in its current posture >as if the deput+ sheriffs
themselves seized the trailer* disconnected it from the utilities* and to)ed it a)a+> ?.% F%d &$"-*
&$"1 (C5" &??&! (en (anc!
L1M 'he court noted that* in light of the eCistence of adeHuate ,udicial remedies under state la)* a claim
for deprivation of propert+ )ithout due process of la) )as unlikel+ to succeed Bd* at &$"1/&$"7 See
2arratt v 'a+lor* .1& GS 1%" (&?D&! Bn an+ event* the Soldals did not claim a violation of their
procedural rights 5s noted* the Seventh Circuit also held that respondents had not violated the Soldals@
su(stantive due process rights under the Fourteenth 5mendment 2etitioners assert that this )as error*
(ut* in vie) of our disposition of the case* )e need not address the Huestion at this time
L7M Gnder .% GSC &?D-* the Soldals )ere reHuired to esta(lish that the respondents* acting under
color of state la)* deprived them of a constitutional right* in this instance* their Fourth and Fourteenth
5mendment freedom from unreasona(le seizures (+ the State See 0onroe v 2ape* L1$7 GS 17* 7&M
-71 GS &7"* &D. (&?7&! Respondents reHuest that )e affirm on the ground that the Court of 5ppeals
erred in holding that there )as sufficient state action to support a &?D- action 'he alleged in,ur+ to the
Soldals* it is urged* )as inflicted (+ private parties for )hom the count+ is not responsi(le 5lthough
respondents did not cross/petition* the+ are entitled to ask us to affirm on that ground if such action
)ould not enlarge the ,udgment of the Court of 5ppeals in their favor 'he Court of 5ppeals found that*
(ecause the police prevented Soldal from using reasona(le force to protect his home from private
action that the officers kne) )as illegal* there )as sufficient evidence of conspirac+ (et)een the
private parties and the officers to foreclose summar+ ,udgment for respondents We are not inclined to
revie) that holding See 5dickes v S< 8ress R Co* -?D GS &..* &1% /&7& (&?"$!
L"M Bn holding that the Fourth 5mendment@s reach eCtends to propert+ as such* )e are mindful that the
5mendment does not protect possessor+ interests in all kinds of propert+ See* eg* 4liver v Gnited
States* .77 GS &"$* &"7 /&"" (&?D.! 'his case* ho)ever* concerns a house* )hich the 5mendment@s
language eCplicitl+ includes* as it does a person@s effects
LDM 2lace also found that to detain luggage for ?$ minutes )as an unreasona(le deprivation of the
individual@s >li(ert+ interest in proceeding )ith his itinerar+*> )hich also is protected (+ the Fourth
5mendment .7% GS* at "$D /"&$
L?M When >operational necessities> eCist* seizures can (e ,ustified on less than pro(a(le cause .D$
GS* at -%" 'hat in no )a+ affects our anal+sis* for even then it is clear that the Fourth 5mendment
applies B(id3 see also Gnited States v 2lace* .7% GS 7?7 * at "$- (&?D-!
L&$M 4f course* if the police officers@ presence in the home itself entailed a violation of the Fourth
5mendment* no amount of pro(a(le cause to (elieve that an item in plain vie) constitutes
?#&%
incriminating evidence )ill ,ustif+ its seizure <orton* .?7 GS* at &-7 /&-"
L&&M Bt is true that 0urra+@s Iessee v <o(oken Iand R Bmprovement Co* &D <o) %"% (&D17!* cast
some dou(t on the applica(ilit+ of the 5mendment to noncriminal encounters such as this Bd* &D <o)
at %D1 9ut cases since that time have shed a different light* making clear that Fourth 5mendment
guarantees are triggered (+ governmental searches and seizures >)ithout regard to the use to )hich
Lhouses* papers* and effectsM are applied> Warden* 0ar+land 2enitentiar+ v <a+den* -D" GS %?.* -$&
(&?7"! 0urra+@s Iessee@s (road statement that the Fourth 5mendment >has no reference to civil
proceedings for the recover+ of de(t> argua(l+ onl+ meant that the )arrant reHuirement did not appl+*
as )as suggested in F0 Ieasing Corp v Gnited States* .%? GS --D* -1% (&?""! Whatever its
proper reading* )e reaffirm toda+ our (asic understanding that the protection against unreasona(le
searches and seizures full+ applies in the civil conteCt
L&%M 'his )as the vie) eCpressed (+ the Court of 5ppeals for the 'enth Circuit in Specht v Jensen* D-%
F%d &1&7 (&?D"!* remanded on unrelated grounds* D1- F%d D$1 (&?DD! (en (anc!* )ith )hich the
Seventh Circuit eCpressl+ agreed ?.% F%d* at &$"7
L&-M 'he officers in these cases )ere engaged in la) enforcement* and )ere looking for something that
)as found and seized Bn this (road sense* the seizures )ere the result of >searches*> (ut not in the
Fourth 5mendment sense 'hat the Court of 5ppeals might have (een suggesting that the plain/vie)
cases are eCplaina(le (ecause the+ almost al)a+s occur in the course of la) enforcement activities
receives some support from the penultimate sentence of the Huoted passage* )here the court states that
the )ord >seizure> might lose its usual meaning >)hen it stands apart from a search or an+ other
investigative activit+> Bd* at &$"? (emphasis added! 5nd* in the follo)ing paragraph* it o(serves that*
>LoMutside of the la) enforcement area* the Fourth 5mendment retains its force as a protection against
searches* (ecause the+ invade privac+ 'hat is )h+ )e decline to confine the amendment to the la)
enforcement setting> Bd* at &$"?/&$D$ Aven if the court meant that seizures of propert+ in the course
of la) enforcement activities* )hether civil or criminal* implicate interests safeguarded (+ the Fourth
5mendment* (ut that pure propert+ interests are unprotected in the non/la)/enforcement setting* )e
are not in accord* as indicated in the (od+ of this opinion L1$7 GS 17* "-M

Zach Coughlin
24 94K -?7&
Reno* =6 D?1$1
'el ""1 --D D&&D
FaC ?.? 77" ".$%
ZachCoughlin@hotmailcom

From: zachcoughlin@hotmailcom
'o: chansen@)ashoecount+us
Su(,ect: Reno eviction noticed for Sparks Justice Court
;ate: 'ue* %7 Jun %$&% $?:&$:&. /$"$$
;ear Civil Supervisor <ansen
&$#&%
Zach Coughlin
24 94K -?7&
Reno* =6 D?1$1
'el ""1 --D D&&D
FaC ?.? 77" ".$%
ZachCoughlin@hotmailcom
;ear Sparks Justice Court*
B called and received permission to file this (+ faCB am indigent and reHuest a fee )aiver* and failing
that* an opportunit+ to cure an+ filing fee deficienc+
From: zachcoughlin@hotmailcom
'o: sheriff)e(@)ashoecount+us3 lstuchell@)ashoecount+us3 kstancil@)ashoecount+us3
chansen@)ashoecount+us3 milllerr@renogov
Su(,ect: Reno eviction noticed for Sparks Justice Court
;ate: 'ue* %7 Jun %$&% $":1D:-7 /$"$$
;ear Sparks Justice Court* WCS4* R2;* and Reno Justice Court
B have received (though not personall+ served! )hat appears to (e an eviction notice (1 da+ unla)ful
detainerE! for rentals located at &7D$ Sk+ 0ountain ;rive* Reno* D?1%-* (ut the notice indicates that B
must file a 'enant@s 5ns)er )ith the Sparks Justice Court
5m B mistaken in vie)ing this matter to (e outside the ,urisdiction of the Sparks Justice Court* and
rather* a matter to (e handled in Reno Justice CourtE
Fiven Sparks Justice Court is open 1 da+s a )eek (closes at noon on Frida+s! and Reno Justice Court
has . ,udicial da+s a )eek* the deadline for filing a special appearance (to contest ,urisdiction! and or a
'enant@s 5ns)er of 5ffidavit is difficult to measure
B spoke )ith a Reno 2olice ;epartment )ho identified himself as Sargent 0iller last )eek and he
indicated the WCS4 planned to come effectuate an eviction on this date* June %7* %$&% B (elieve that
)ould (e premature* as =evada Iandlord 'enant la) provides for filing a 'enant@s 5ns)er or 5ffidavit
(+ noon after the fifth full da+ (,udicial da+s! and Frida+s in Sparks Justice Court are not full da+s in
that sense* and regardless* Sparks Justice Court* B (elieve* is not the appropriate forum )here* as here*
the situs is located in Reno (Ward &/napE!
Sincerel+*
Zach Coughlin
24 94K -?7&
Reno* =6 D?1$1
tel ""1 --D D&&D
faC ?.? 77" ".$-
&&#&%
Civil ;ivision
7-$ Freen(rae ;rive
Sparks* =evada D?.-&
(""1!-1-"7$- 2hone
(""1!-1%-$$. FaC
Civil ;epartment Supervisor
Chris <ansen
chansen@)ashoecount+us
'he Civil ;ivision of Sparks Justice Court is made up of three ma,or functions:
Civil
Civil Complaints for damages in eCcess of S1$$$ or if a suit involves a (reach of contract* punitive
damages* an action to o(tain possession of propert+* a )rit of restitution* or other like actions* legal
counsel is suggested for these t+pes of actions
Avictions
5n act or process of legall+ dispossessing a person of land or rental propert+
Small Claims
5n action filed in order to o(tain a monetar+ ,udgment Claims must not eCceed S1$$$ 5 small claims
action ma+ (e filed )ith the Sparks Justice Court if one of the follo)ing applies to the defendant:
'he+ reside )ithin the (oundaries of the Sparks 'o)nship3
'he+ are emplo+ed )ithin the (oundaries of the Sparks 'o)nship3 and#or*
'he+ do (usiness )ithin the (oundaries of the Sparks 'o)nship
&%#&%
motion for new trial
next few days, though I believe I tried to fax this to the RMC (as an emergency measure and hopefully not in violation of
Judge Gardners earlier Order regarding faxing....) on or about 6/30/12...

Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 6/28/12 2:13 AM
To: hazlett-stevensc@reno.gov; kadlicj@reno.gov
1 attachment
11 cr 25405 soldal version final.pdf (154.9 KB)
Zach Coughlin,Esq.
Nevada Bar No: 9473 (currently suspended)
PO BOX 3961
Reno, NV 89505
tel: 775 338 8118
fax: 949 667 7402
Pro Se Defendant
regardin 11 cr 22176: Motion for New Trial, etc. (14 pages)
also sent to Hon. Judge William Gardner
1 South Sierra Street, P.O. Box 1900 reno nv
* Fax number:
7753343859
Christopher P. Hazlett-Stevens Company: Reno City Attorney's Office Address: P. O. Box 1900 ~ Reno , NV 89505 Phone Number: 775-326-
6628 Fax number: 775-334-4226 Email: hazlett-stevensc@reno.gov
Dear Judge Gardner and Mr. Hazlett-Stevens,
I attempted to file a tolling motion on June 25th and again on June 26th, 2012. on the 25th Filing office supervisor Donna Ballard and Court
Administrator Cassandra Jackson decided to refuse to accept my filing, apparently. Then on June 26th, 2012, I ented the court prior to the
"timed lockign of the doors" that I have been educated on previously by court adminstration in relation to seekign to file documents close to
closing time, however, I was again refused in my attempt to file another such tolling motion and to access justice. I am fax this filing to both
of you, with the caveat that I do not wish to violate any dicate against fax filign that Judge Gardner may have in effect (I am a bit unclear
motion for new trial, motion for reconsideration, motion to alter or amend
whether that only applied to pre-trial motions or to anything).
I believe the Whitman, Sullivan, Donoho, and other Nv S. Ct decisions forbid Ms. Ballard and J ackson from so rejecting my filings, in
addition to NRCP 5(e).
Sincerely,
zAch Coughlin
Sent: Wed 6/27/12 1:53 PM
To: kadlicj@reno.gov; hazlett-stevensc@reno.gov
1 attachment
motion for new trial 11 cr 26405 4 pages submitted for filing 6 26 12 to rmc.pdf (4.3 MB)
Please find attached the tolling motions in the subject line
from Zach Coughlin
\(NV BAr No:9473, currently suspended)
PO BOX 3961
RENO, NV 89505
Tele: 775-338-8118
FAX: 949 667 7402
TO:
Reno City Attorney's Office
Christopher Hazlett-Stevens, Esq.
J ohn Kadlic, Esq.

Reno eviction noticed for Sparks J ustice Court
Email:

Sent: Tue 6/26/12 7:58 AM
milllerr@reno.gov
J ustice Court.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
Civil Division
630 Greenbrae Drive
(775)353.7603 Phone
(775)352.3004 Fax
Chris Hansen
Civil
Evictions
Small Claims
NCAA and Dwayne jakob
Nevada court services attack and attempted break in
respectfully submitted
Sent: Fri 6/22/12 9:36 AM
To: weavera@reno.gov
Keep turning light off attempting break in malicious abuse of process claiming color of law
From my Android phone on T-Mobile. The first nationwide 4G network.
Sent: Fri 6/22/12 9:34 AM
To: weavera@reno.gov
NCA and northerns mgmt tried to break again on J une 14th.
From my Android phone on T-Mobile. The first nationwide 4G network.
Sent: Fri 6/08/12 4:41 PM
6 attachments
20120605_101513 Northwind manager handy man attacks from golf cart 6 5 12.mp4 (3.1 MB) , landlord tenant law
manual for police in minnesota.pdf (735.1 KB) , Police_manual_-_final_as_adopted_by_State's_Attorney.pdf (263.7
KB) , trespass criminal civil evictdion.pdf (69.8 KB) , 6 8 12 fax to northwind with page numbers.pdf (50.7 KB) ,
northwind fax 6 4 12 habitability retaliation etc.pdf (45.8 KB)
I am respectfully submitting this supplementary material to the police report I submitted to you in person on
J une 6, 2012 regarding the assault I was the victim of at the hands of maintenance staff member Luke of
Northwind Apartments on J une 5th, 2012, and the attempts at unlawful entry committed by Northwind
Manager Dwayne J akob on or about J une 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
Cory Goble battery
of either of your police work.
Sincerely,
Zach Coughlin
Sent: Wed 6/06/12 1:36 AM
To: denneym@reno.gov; jgoodnight@washoecounty.us; zyoung@da.washoecounty.us
5 attachments
20120605_204307 cory goble flicks cigarette at coughlin hits coughlin's left shoulder.mp4 (5.5 MB) ,
20120605_210151 Pabst Blue Ribbon beer can beneath section of Lexus Goble was sitting in.jpg (1323.9 KB) ,
20120605_210154 the cigarette Goble flicked Coughlin.jpg (2.2 MB) , 20120605_204512 Goble's brunette female
friend taunting Coughlin over reputational damage done by Goble and Zarate's lying to RPD Officer Duralde.mp4 (3.9
MB) , Cory Goble address 5020 Las Brisas Blvd. Reno NV.pdf (188.2 KB)
denneym@reno.gov
Dear Officer Denney and the Reno Police Department, DDA Young, and DPD Goodnight,
This is the supplement to the report of the battery that Cory Goble committed upon me last night, J une 5th,
2012.
lexus rx300 brownish color license plate 073xyf brunette female early twenties behind the wheel, indicated
the lexus belonged to her early twenties blonde female friend. Cory Goble sat on the passenger side in the
back seat. Asian man early twenties in front passenger seat.
Reno Police Department case number 12-10761 for incident occurring at approximately 8:44pm in parking
lot of Imperial Lounge on Arlington and 2nd Street.
911 call made announcing Toyota Prius (license plate number provided during 911 call) was the getaway
vehicle for Goble and his three associates when Coughlin announced he was calling 911 to report the battery
by Cory Goble.
I was at the Washoe County Law Library until Nikki Britt, law librarian told me it was time to go at 7:30pm.
She let me stay after the usual 7:00pm closing time because she is nice and because the "Lawyer in the
Library" program was running late, so she was going to be there anyway. I left my car parked in the court
house's lot and decided to go for a walk in the entertainment corridor downtown between arlington and sierra
streets and First and Second Streets. I don't have much money right now and so I was more watching to big
screen television replays of the Heat Celtics game than anything else through the window in the imperial
parking lot. I didn't go in because I don't have much money to spend, the place looked kind of dead anyways,
and I was getting tired anyways after doing legal research for several hours. While watching the sports
highlights I heard a young man's voice kind of clowning me about my wearing a suit. Then the voice
exclaimed that I was "the guy who stole my phone". At that point I turned on my smart phone recorder and
that is where the tape starts, with Goble repeating that he was "over it" now and, apparently, no longer upset
about the situation, which was somewhat puzzling considering he did not lose the use of his phone for
anything more than a few minutes at the most back on August 20th, 2011, and also considering that the still
unidentified man that Nicole Watson admitted hearing say that he would throw the phone in question "in the
river" if it wasn't claimed immediately (http://www.youtube.com/watch?v=to_UOFIccLw at the four minute
ten second mark of the video just linked to Nicole Watson admits to hearing and seeing this man exclaim that
he would throw the iPhone in the river...so Goble's own friend, Nicole Watson admits that Goble's phone
would have been in the river anyways....)
J oe Goodnight never watched that video linked to, despite the fact that it was provided to him and qualifies as
exculpatory evidence. Goodnights admits that he failed to utilize or watch that video. The other individual
providing a witness statement, Nate Zarate, is seen in the videos attempting to dissuade Nicole Watson from
providing any insight into what she actually eye witnessed the night of the grand larceny arrest of Coughlin
by the RPD, at the behest of Goble and Zarate on August 20th, 2011.
In the video from J une 5, 2012, Cory Goble is seen with the word "FUCK" tatooed on the knuckles of his left
hand in large font and black ink. He appears highly intoxicated. A Pabst Blue Ribbon beer can was seen
under the section of the Lexus RX300 that Goble was seated in.
The early twenty somethings appeared to feel it rather necessary to switch cars, and possibly drivers. The
excuse proferred later, apparently by a shaggy brown haired taller early twenty something male that the RPD
interviewed, and whom was very threatening to Coughlin in the parking lot, seems thin. The excuse, that
these four switched cars because Coughlin was blocking the egress of their Lexus seems particularly suspect
considering the merely switched to a Toyota Prius parked some 3 parking spaces away. Why, if Coughlin
was truly preventing them from leaving he couldnt' have just blocked the Prius, is unclear.
What is clear is that no forcible "citizen's arrest" was made by Coughlin. Coughlin made the decision to
allow Goble and his associates to leave peaceably (though they likely presented a danger to others on the
road considering they all seemed intoxicated). However, in the video of the August 20th, 2011 arrest of
Coughlin, wherein Goble signed a criminal complaint, RPD Officer Duralde cheerfully dismisses Coughlin's
protestations that Coughlin himself called 911 in light of the skater youth's violent and threatening behavior
(attemting to steal Coughlin's pekingnese puppy and Coughlin's bike, attempting to reach into Coughlin's
shorts pocket, gleefully exclaimign the lack of culpability one of their cohorts would face given he was "only
17 years old and still a minor". Officer Duralde is hear in the video dismissing Coughlin's account of the
assaults and batteries this gang of skater youth committed by deeming their behavior a "citizen's arrest".
Coughlin, however, chose not to utilize any of the force or threat utilized by the skater youth's in the video of
the August 20th, 2011 arrest of Coughlin for grand larceny (Duralde cheerfully explained to Coughlin that he
was purposefully charging it as a "felony" and went on to detail the advantages to Duralde in doing so and the
disadvantages to Coughlin that that decision by Duralde would present.
I am reporting this battery by Goble within 48 hours of it taking place. As such, he should be arrested. I
swear, under penalty of perjury, that Goble flicked his lit cigarette directly at me, from about 3 feet away and
that it hit me in the left should area of my suit jacket and the sparks and ash exloded from the tip of the lit
cigarette when it hit my left shoulder of my suit jacket.
Mental health court
FW: release of information to my attorney
The attached video reveal Goble flicking his lit cigarette at me and it hitting my left should at the 51 second
mark. For a couple seconds afterwards I was literally to shocked to say anything, as it was such a
phenomenally stupid thing for him to have done, especially considering that his female friend had only just a
few moments before made sure to announce that I, Coughlin, was obviously recording and or filming the
interaction. The group admits that Goble started the conversation with me and they also readily acknowledge
that his conduct invited the interaction.
I appreciate your attention to this matter.
If you choose to make an arrest, locating Goble should not be that difficult. Goble's parents are apparently
located at 2480 Montego Dr_ Pamela and Timothy Goble. The Criminal Complaing by DDA Young list
Cory Goble's address as 5020 Las Brisas Blvd in Reno, NV.
Sincerely,
Zach Coughlin

From: Zach Coughlin,Esq. (zachcoughlin@hotmail.com)
Sent: Wed 5/09/12 12:04 PM
To: kadlicj@reno.gov; Timothy D. Coughlin, MD (tcoughlinmd@hotmail.com); peter.breen@washoecourts.us
I got i n t o MHC by or der of J udge Sf er r azza yest er day f or t he RJ C case st emmi ng f r om t he August ar r est , but i n t he
RMC t r espassi ng case, t he Reno Ci t y At t or ney i s obj ect i ng t o t hat . That at t or ney, Hazl et t - St evens l i ed t o me i n
Sept ember 2011 about whet her t he Ci t y At t or ney' s of f i ce had r ecei ved anyt hi ng r egar di ng my 9 9 11 ar r est .
I was st ar t ed on ant i depr essant s as a boy by my physi ci an f at her and was of f t hem dur i ng t he t wo ar r est s bet ween
August and Sept ember 2009. I asked f or some t empor ar y hel p wi t h obt ai ni ng some ant i depr essant s, but my f at her
i ndi cat ed he need t o put t hat money t owar d payi ng f or act i ng l essons f or hi s 30 year ol d st epson. I n t he past he has
cal l ed t he Dean of t he l aw school and pr ovi ded hi s own di agnosi s of me, whi ch wound up becomi ng t he subj ect of
sever al poi nt ed quest i ons i n a deposi t i on conduct ed by bar counsel f or t he Cal i f or ni a St at e Bar , whi ch deni ed me a
l i cense i n l ar ge l par t due t o t hat cal l t o t he Dean.
My psychi at r i st conf i r ms I was of f my medi cat i ons dur i ng t hat per i od dur i ng whi ch t hese ar r est s occur ed.
My f at her has i nt er f er r ed wi t h my heal t h car e cont i nual l y and i n der ogat i on of my pr i vacy r i ght s, usi ng shame and
mani pul at i on t o cont r ol t hat t o whi ch he i s not ent i t l ed t o.
I was deni ed counsel i n RMC 11 CR 22176, whi ch r esul t ed i n a convi ct i on f or eat i ng a candybar and cough dr ops whi l e
shoppi ng and event ual l y payi ng f or $90 of mer chandi se. A pet i t i on t o suspend my l aw l i cense was f i l ed on May 3, 2012.
I wi l l be f i l i ng a mot i on t o pr event such a suspensi on.
My dad cal l ed my gi r l f r i end up i n May 2011 and she br oke up wi t h me days l at er , st eal i ng t wo mont hs of r ent t hat I
had gi ven her t o f or war d t o our l andl or d. Ci t y At t or ney Rober t s of f er ed t est i mony she knew t o be f al se, t he Wal mar t
associ at e l i ed, as di d t he I ndi an Col ony Pol i ce i n t he candybar case. I n t he appeal of t hat case, J udge El l i ot ci t ed
a ci vi l st at ut e i n excusi ng t he RMC' s f ai l ur e t o pr epar e a t r anscr i pt . I f eel t he convi ct i on i n 11 CR 22176 shoul d be
over t ur ned and t hat case shoul d be i n ment al heal t h cour t .
Dependi ng on how t hi s t ur ns out , my Dad and I may never speak agai n.
Si ncer el y,
Zach Coughl i n, Esq. PO BOX 3961, Reno, NV 89505 t el 775 338 8118 f ax 949 667 7402
Sent: Wed 5/02/12 4:29 PM
To: jgoodnight@washoecounty.us; keithloomis@earthlink.net; keith@leelawoffice.net; patrickk@nvbar.org; coe@gbis.com;
zyoung@da.washoecounty.us; judgemcgee@msn.com; kadlicj@reno.gov; geofgiles@hotmail.com; hazlett-
stevensc@reno.gov; sooudib@reno.gov; robertsp@reno.gov; ormaasa@reno.gov
3 attachments
patrick o. king citations.pdf (1070.1 KB) , loomis allcases.pdf (624.7 KB) , giles allcases.pdf (1426.7 KB)

Dear Mr. Loomis and Mr. Goodnight, et al,

I am writing response to your putting for the idea of a global resolution. If any global resolution could be achieved it would
mean a great deal to me. I believe I am doing better now and this has been an enormously difficult time with a great deal of
damage done to my family relationships, reputation, finances, privacy rights, lost opportunities, etc.

I ask that you pursue, if possible including the conviction of 11 30 12 before J udge Howard on some Rule 60 relief from
judgment basis. I believe I filed a Rule 60 in that petit theft conviction in 11 TR 22176, however, I am not sure if the RMC filed
it, etc., etc. as sometimes there have been issues with having my filings accepted. I am just trying to move on with my life and
pick up the pieces. Of course, I wish I had handled some things better and am plenty willing to grovel for foregiveness before
whomever if it will help get these matters resolved without a conviction, and especially if it will get the conviction in 11 TR 22176
set aside or undone, etc. I did report that conviction to Bar Counsel (from RMC 11 TR 22176 before J udge Howard) under SCR
111, however, I believe a global resolution wherein that conviction is overturned would hel me retain my law license and avoid a
significant suspension. If that could be achieved it would be very easy for me to just move on and forget about seeking
recourse for the various things that have happened. Further, my main goal is to avoid a suspension of my law license or being
forced into a SCR 117 disability petition. I love the practice of law and take it very seriously. I have very few clients right now
because I know that is necessary to afford me that which I need to provide them services in a professional manner and to meet
all standards of care. I could be making more money right now, but I know the prudent thing is to not take on too many clients
and to do good work for those clients I do have. I attempt to mirror the approach of Geof Giles, whom could have a great deal
more foreclosure defense clients and clients in general than he currently does, but chooses to keep that roster relatively trim in
order to attempt to get the best precedent on the books as possible. Mr. Giles is doing work that is extremely important to
Nevadans right now in the foreclosure defense setting, including fighting the big removal and preemption fights. I have been
lucky to get to do a little research for him once in awhile, though I dont think I have found him any materials he did not already
have or otherwise get him anything useful, but at least
I get to see some of this exciting foreclosure battle up close.

Mr. Goodnight, please work with Mr. Loomis, he is the former District Attorney for Lyon County and is extremely well respected in
our profession. I am attaching a collection of his Westlaw profiler results. Mr. Loomis, J oe is a National Merit Finalist whom I
have known since I moved to Reno in 7th grade after sending 2 years in Dayton, Ohio before that I slit time between
Gardnerville 9 months a year with my mom and summers with my Dad in Reno. Also, if permissible, please work with
Bar Counsel Patrick King, whom Coe Swobe speaks highly of and who has been pretty patient with me throughout my recent
issues. I am attaching a collection of the signficant cases he has appeared on as well.

Coe Swobe, Esq. former state senator, and recipient of a commendation from President Reagan for his work in forming the TRPA,
and Keith Lee, Esq., whom started the Character and Fitness Committee, was student body president at UNR may be willing to
provide some insight into this situation. I will be attending Lawyers Concerned For Lawyers on Thursday nights, though an
extremely heavy deadline collection of late has been tough of late...

Basically, I was doing pretty well for some time, but creative differences at Washoe Legal Services resulted in our parting ways in
May 2009, though I still have an enormous deal of respect for Paul Elcano and the rest of Washoe Legal Services, and in some
ways owe him more than I am comfortable admitting for his insane decision to hire me in August 2007. After leaving WLS, the
economy turned sour, and the next 2 years were a combination of seeking employment and doing the scut work of preparing to
enter private practice. I can build a computer from the ground up and know what thermal paste is for a processor. I am
getting better with rules based calendaring software and the rest of all that is involved in practicing law these days.

However, my live-in girlfriend of four and a half years and I broke up in J une 2011. As confirmed by the landlord in RJ C
Rev2011-001708, my girlfriend took a couple months worth of my rent contributions and instead of forwarding it on to the
landlord, she secretly used it to get a new apartment, etc. She also took my beloved Pomeranian, Palin.

I was running low on money in early August 2011 and decided to take a 'medication holiday', which is an
accepted practice, especially considering the cost of the medication has skyrocketed somewhat in the last year or so. My
psychiatrist, Dr. Yassar's office will confirm that they have a record of my calling to cancel my August 2, 2011 appointment and
that I would have run out and did not refill my prescription by that date. I did not receive another prescription or otherwise fill
one until September 12, 2011.

I did not find out about the missing rent until mid August 2011 as the landlord had a practice of not even cashing rent checks for
months at a time....naturally, as he is a neurosurgeon who probably is not living paycheck to paycheck. Richard G. Hill, Esq.
entered the picture for the landlord on August 16th, 2011. I was arrested on the iphone in the skate plaza possession of lost or
mislaid property matter on August 20th, 2011 and the eviction Notice is dated August 22nd...and I sent 7 days in jail waiting for
an OR. Then, on September 9th, 2011 I was arrested on the eating a candy bar, etc, at WalMart while shopping for an paying
please file this with the RMC
for $90 worth of groceries. I do not believe I committed theft in either of the petit larceny cases, the arrests for which occurred
during a 19 day period wherein I had ceased taking a medication prescribed by my pscyhiatrist that I have been on for years and
years, mostly due to the cost of the medication skyrocketing lately, my girlfriend breaking up with me and making off with my
share of the rent, a tough economy, etc., etc. I believe my personality was made prickly from going off the medication abruptly
and that resulted in two arrests in situations where an arrest would not typically be made. I got back on one of my medications
immediately following my release from jail on September 12th, 2011. I still could not afford my other medication until I finally
filled it on April 28th, 2011. My dad is a physician and gave me this medication when I was a teenager.

The eviction Order by J udge Sferrazza (that Mr. Loomis made a brilliant argument against in the criminal trespass matter related
to the RJ C being divested of jurisdiction to enter that Order considering a Notice of Appeal was filed by me in the interim
between the two hearings) called for the lockout to take place on November 1, 2011. I was arrested for criminal trespass on
November 13th, 2011. Despite NRS 40.253 expressly forbidding it, J udge Sferrazza forced me to deposit my last $2,300 into the
RJ C's rent escrow account in order to preserve my right to litigate habitability. Even after the eviction Order was rendered on
October 27th, 2011 and for nearly 10 days thereafter, the RJ C continued to hold on to that $2,300 of mine. What was I
supposed to live on? Plus, the way the law is being applied currently, a tenant is forced to deposit such an escrow amount,
then, prepare for a hearing, then if the tenant loses, be ready for a Sheriff to be opening their door with his gun drawn after a
locksmith gained access to the rental just hours after the hearing itself. I do not get Section 8 housing benefits, do not get
welfare or food stamps, no medicaid, etc. Further, Richard G. Hill and Casey Baker actually got J udge Sferrazza to sign the Order
of 10/27/11 with a ruling wherein the $2,300 was awarded to the neurosurgeon, despite the Order as rendered in open court
having said no such thing. Simply put, they hand the court an Order that the court directed them to prepare based on what was
announced in open court, and rather than faithfully reproducing the same, they remix it to be what they had hoped the Order
would be in the first place, forcing J udge Sferrazza and I to correct their perfidy...just kidding, sort of... I had to file a J CRCP
Motion to Alter or Amend just to correct that and get that rent escrow deposit back. In Las Vegas, the J ustice Court had to get
Rule 44 passed off on by the Nevada Supreme Court just to be able to force such rent escrow deposits, as required by J CRCP
83. I think J udge Sferrazza just misread the statute, which is damn confusing and complex. Such forced rent escrow deposits in
the context of the speedy nature of these ultra quick summary eviction proceedings have a vast societal cost, as seen here. The
Reno Police Department has gotten a little disparage in this. Officer's have. My reputation will never be the same...the RJ C took
some lums.....and Richard G. Hill, Esq. got over $50,000 in fees to litigate a summary eviction from a commercial law office
where the only notice served failed to allege nonpayment of rent. NRS 40. 253 expressly forbids utilizing summary eviction
proceedings against commercial tenants unless non-payment of rent is alleged. My Lease Agreement allowed for the commercial
law office use for which the property was being utilized, in express, written terms. Richard G. Hill, Esq. committed a wrong site
surgery of a legal nature for his neurosurgeon client.

So, I was subject to a custodial arrest incident to Richard G. Hill, Esq. signing a criminal trespass complaint on November 13th,
2011. I spent three days in jail and more money on bail and got out on November 16th, 2011, then Thanksgiving week and
many deadlines in other cases took place... Then, on November 30th, 2011 the trial in RMC 11 TR 22176 in the candy bar case
took place and J udge Howard denied my request for a continuance, even where Richard G. Hill was subjecting exculpatory
materials to an unlawful rent distrain under NRS 118A.520 that I felt necessary to my defense of a matter for which a conviction
would require reporting under SCR 111. I was convicted and did report that to Bar Counsel. I was denied an attorney, yet
sentenced to 3 days in jail for summary contempt. It is my hope that there is some permissible manner for that conviction to be
overturned and to avoid a SCR 117 disability petition. I spent four years on the sidelines from 2001 to 2005 waiting to get a law
license. I have not had a relapse. Staying busy has always been the best thing for me, and a suspension, I believe, would have
a negative effect in that regard, and actually not benefit me or otherwise provide time for me to address any problems anyone
feels I might have. Simply put, I just want to practice law. I do not want to get into protracted wranglings and fighting city hall,
etc. while waiting out a suspension or worse. I know I have upset a good number of people and will be making amends for that
in the years to come.

I appreciate anything any of you can do to assist me here in achieving my stated goals and promise you I would pay it forward in
our profession in the future. There has been a silver lining in all this for me, however. I have been able to meet and watch
practice a number of fine attorneys and people, including Deputy City Attorneys Roberts, who had some very crafty moves in the
appeal of the candy bar case, Ormaas, Hazlett-Stevens, and Sooudi, as well as Deputy District Attorney Zach Young. And RJ C
Chief Bailiff Sexton and Bailiff English and I were able to joke the other day after a hearing wherein my arguments were roundly
smited about how I actually won the hearing because I did not have to go to jail at the conclusion of it, and how its those little
victories that one must build on in seeking to navigate in the legal profession while learning to practice law. And I may not have
ever received a license in the first place if it was not for Reno City Attorney J ohn Kadlic writing me a letter of recommendation to
the State Bar of Nevada and Nevada Supreme Court back in 2004 where I was languishing in Moral Character application
purgatory, or were it not for Keith Lee taking on my case pro bono when it seemed bleakest, or had J udge McGee and Coe not
been there to laugh with.

Sincerely,

Zach Coughlin, Esq.
Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473

CHANGE OF ADDRESS ATTORNEY COUGHLIN
CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
Sent: Mon 4/16/12 4:30 PM
1 attachment
in 11 tr 26800
No: 9473
Sent: Mon 4/16/12 3:28 PM
To: tbeko@etsreno.com; bgonsalves@live.com; jgarin@lipsonneilson.com; jgoodnight@washoecounty.us;
bdogan@washoecounty.us; keithloomis@earthlink.net; renodirect@reno.gov; renopd@coplogic.com;
kcordisco@da.washoecounty.us; jleslie@washoecounty.us; kadlicj@reno.gov; gfuller@grgflaw.com;
rjcweb@washoecourts.us; robertsp@reno.gov; heidi.howden@washoecourts.us; hazlett-stevensc@reno.gov;
sooudib@reno.gov; ormaasa@reno.gov
Please note my new address for all correspondence and or mailings:
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: Mon 4/16/12 2:38 PM
To: suzannew@nvbar.org; support@baralliance.com; renodirect@reno.gov; courtadmin@washoecourts.us;
courttech@washoecourts.us; joey.hastings@washoecourts.us; joey.orduna@washoecourts.us;
craig.franden@washoecourts.us; kstancil@washoecounty.us; stuttle@washoecounty.us; rbaker@washoecounty.us
Dear State Bar of Nevada, 2nd J udicial District Court, Reno J ustice Court, et al,
Please let me clarify and or change my recent communication. In my last correspondence I made a
misstatement based upon my misreading of SCR 79. Please allow me to correct that. My preferred mailing
address and my SCR 79 address should be the same, as listed directly below:
Zach Coughlin, Esq.
PO BOX 3961
Reno, NV 89505
Tel: 775 338 8118
Fax: 949 667 7402
email: ZachCoughlin@hotmail.com
website: www.ZachCoughlinEsq.wordpress.com
please make all the above information my preferred mailing address and publicly available.
FW: Evidence
As for any alternate mailing address, please change that to:
Zach Coughlin, Esq.
945 W. 12th St.
Reno, NV 89503
I will attempt to make these changes myself at the "portal" found at www.nvbar.org in the
member section, however, I am contacting you now in an abundance of caution.
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: Wed 4/04/12 11:07 PM
To: nrickey@washoecounty.us; renodirect@reno.gov; mhaley@washoecounty.us; tvinger@washoecounty.us;
rromero@washoecounty.us; bberryman@washoecounty.us; mkandaras@da.washoecounty.us;
william.rempel@latimes.com
Dear Deputy District Attorney Kandaras and Sheriff Haley,
I respectfully request for the WCSO to answer my questions with regard to what exactly will be returned to
me, including, but not limited to, whether a micro sd card will be returned and whether such a card was free
standing (ie, not inserted into any other personal property) or not, and whether any copies of the data on any
of my personal property has been made or whether such data has been accessed. I claim law enforcement
misconduct, not unprofessional treatment, vis a vis the incident on 3/30/12. DDA Kandaras, you wrote: " I
am unsure as to your complaint about the District Attorney possessing your evidence." Please
try to become sure and find out whether or not the DA, or anyone connected with the DA
"possessed" this "evidence". Additionally, please indicate what this "evidence" is "evidence" of,
whether any crime will be charge, and whether any probable cause, reasonable suspicion or other basis exists
or existed sufficient to justify this seizure of an attorney's personal property, including a smart phone and a
micro sd card, as well as another smart phone and an expensive electric shaver for now over 35 days.
Sincerely,
Zach Coughlin
No: 9473
Subject: RE: Evidence
Date: Wed, 4 Apr 2012 16:29:03 -0700
From: mkandaras@da.washoecounty.us
To: BBerryman@washoecounty.us; zachcoughlin@hotmail.com
CC: NRickey@washoecounty.us; renodirect@reno.gov; MHaley@washoecounty.us; TVinger@washoecounty.us;
RRomero@washoecounty.us
Dear Mr. Coughlin:

In reviewing the emails below as well as others generated with respect to the Holmes order, it appears that the staff is trying to
work with you to release your items in a timely manner. It is my understanding that when you came to the detention facility on
Friday, March 30, 2011, it was after 5:00 p.m. Because the evidence custodian is open during regular business hours, your request
could not be processed at that time. I was informed that staff told you yesterday that you could make arrangements to come pick
up your items. I see no reason why there should be any problems with this release as I am confident that all parties will treat
each other with the utmost professionalism and courtesy.

I did not receive copy of the Holmes order until Monday, April 2, 2012, when you sent it to me via email at about 4:00 p.m. I
have never requested that the items taken into evidence be routed to the District Attorneys office, nor have I ever viewed them. I
am unsure as to your complaint about the District Attorney possessing your evidence.

Please be advised that your claims of unprofessional treatment on March 30, 2012 will be reviewed. Have a nice evening.

Mary Kandaras
Deputy District Attorney
Phone: (775) 337 - 5723
Fax: (775) 337 - 5732

From: Berryman, Brandi J
Sent: Wednesday, April 04, 2012 3:08 PM
Cc: Rickey, Natasha; renodirect@reno.gov; Kandaras, Mary; Haley, Michael; Vinger, Todd; Romero, Renee L.

Mr. Coughlin,
Today will work just fine. Please give me a time before 5:00pm today that you are able to pick up your items.
Thank you,
Brandi Berryman
RE: Evidence

Sent: Wednesday, April 04, 2012 2:46 PM
To: Berryman, Brandi J ; Rickey, Natasha; renodirect@reno.gov; Kandaras, Mary; Haley, Michael; Vinger, Todd

Dear Ms. Kandaras, Berryman and Rickey,

Pleas answer my questions regarding the property that is to be released. The Order is dated 3/30/12, why does it take until 4/5/12 to have it available to me?
Am I going to be hassled and subject to abuse of process and threats of malicious prosecution and retaliatory arrest by unprofessional and malevolent
deputies like Deputy Beatson? Can I retrieve my items right now, today? Would an Order to Show Cause help you to follow the Order?

Thank You,

Zach Coughlin
PO BOX 60952, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

Subject: Evidence
Date: Tue, 3 Apr 2012 07:38:01 -0700
From: BBerryman@washoecounty.us
CC: NRickey@washoecounty.us
Hi Mr. Coughlin,
Please come to the front desk at the Sheriffs Office on Thursday, April 5
th
at 11:00am. Just let the person at the desk know you are here to pick up your evidence.
Be sure to have your ID as well.
Thank you,
Brandi Berryman
Washoe County Sheriff's Office
Crime Lab, Evidence
328-3060 (office)
328-2831 (fax)
Sent: Wed 4/04/12 2:45 PM
To: bberryman@washoecounty.us; nrickey@washoecounty.us; renodirect@reno.gov; mkandaras@da.washoecounty.us;
mhaley@washoecounty.us; tvinger@washoecounty.us
Dear Ms. Kandaras, Berryman and Rickey,

Pleas answer my questions regarding the property that is to be released. The Order is dated 3/30/12, why does it take until
4/5/12 to have it available to me? Am I going to be hassled and subject to abuse of process and threats of malicious
prosecution and retaliatory arrest by unprofessional and malevolent deputies like Deputy Beatson? Can I retrieve my items right
now, today? Would an Order to Show Cause help you to follow the Order?

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
Thank You,

Zach Coughlin
PO BOX 60952, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

Subject: Evidence
Date: Tue, 3 Apr 2012 07:38:01 -0700
From: BBerryman@washoecounty.us
CC: NRickey@washoecounty.us
Hi Mr. Coughlin,
Please come to the front desk at the Sheriffs Office on Thursday, April 5
th
at 11:00am. Just let the person at the desk know you are here to
pick up your evidence.
Be sure to have your ID as well.
Thank you,
Brandi Berryman
Washoe County Sheriff's Office
Crime Lab, Evidence
328-3060 (office)
328-2831 (fax)
Sent: Thu 3/29/12 2:39 PM
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
20 attachments
11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED.pdf (2.6 MB) , 2 24 20 fax to
rmc regarding deficiency in record on appeal - Copy.pdf (55.6 KB) , 3 19 12 fas to rmc marshals regarding property
wcso - Copy.pdf (40.0 KB) , 3 26 12 fax to rmc regarding address emails and car sleeping allegations - Copy.pdf
(51.9 KB) , J AMES MENZEL TransparentNevada rmc marshal menzel 2009 does not include health benefits.htm (3.6
KB) , J OEL HARLEY TransparentNevada RMC Marshal Harley.htm (3.3 KB) , J USTIN ROPER TransparentNevada
rmc chief marshal justin roper 2010 base pay 109K.htm (3.3 KB) , motion to set aside RMC 11 CR 22176 faxed 2 22
12 - Copy.pdf (196.5 KB) , Pages from mary barker rmc 11 tr 26800 order denying motion for return of bond -
Copy.pdf (508.2 KB) , cr11-2064 motion for extension fo tiem.pdf (133.2 KB) , CR11-2064-2676094 (Opposition to
Mtn ...).pdf (167.7 KB) , CR11-2064-2682479 (Supplemental ...).pdf (149.7 KB) , CR11-2064-2682487 (Supplemental
...).pdf (75.3 KB) , ex 44 pages all emails to renomunirecords@reno.gov from ZachCoughlin@hotmail.com.pdf (288.8
KB) , Motion_for_Continuance_to_Reno_City_Atty_Roberts_RMC.pdf (448.9 KB) , 2 24 20 fax to rmc regarding
deficiency in record on appeal.pdf (55.6 KB) , 3 19 12 fax to reno marshal division.pdf (193.0 KB) , chief marshal
justin roper roperj@reno.gov emails.pdf (155.9 KB) , complaint or grievance by J udge Dorothy Nash Holmes against
Reno attorney Coughlin with State Bar of Nevada 3 14 12.pdf (737.8 KB) , WCSO Beckman, Debi Campbell,
Cummings, Hodge Statements on property sezied from Reno Attorney by Reno Munic Court J udge Nash Holmes.pdf
(150.3 KB)
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.
No: 9473
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. J eanney,
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 J udge 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 J udge 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.
No: 9473
Detail page for J AMES MENZEL
Name J AMES 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
Detail page for J OEL HARLEY
Name J OEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Benefits AccumulatedN/A
Detail page for J USTIN ROPER
Name J USTIN 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 J AMES MENZEL
Position
Marshal
Reno
Notice
Year 2009
Base Pay $60,609.42
Overtime and
Callback Collected
$622.67
rpd sargent sifre loses Z coughlin's dog Jackson is gone voicemail from (775) 762-155 at !"27 #$
Zach %oughlin (&achcoughlin'hotmail(com) )*2*12
+o" renopd'coplogic(com, schult&t'cit-ofreno(com, kadlic.'reno(gov, renodirect'reno(gov,
cit-clerk'reno(gov, nvrenopd'coplogic(com, the/&'reno(gov, sifrep'reno(gov, ed'npri(org,
mar-0ark0ark'-ahoo(com, geofgiles'hotmail(com, carcoughster'gmail(com,
carl-(coughlincrc'gmail(com, melissa(l(ulloa'gmail(com, lori/'nv0ar(org
1utlook 2ctive 3ie/
4eno #olice 5epartment 6argent #aul 6ifre arrests 4eno 2ttorne- for misuse of 11
5ear %it- of 4eno 2nimal %ontrol, 6#%2, and 4eno #olice 5epartment, and 4eno %it- 2ttorne-'s
1ffice,

#lease help me find m- dog, and please place a cop- of this complaint in 4#5 6argent #aul 6ifre's
emplo-ment*personnel file( 2lso, dear cit- clerk, i /ould like a date to dispute all parking tickets or
traffic citations outstanding and 7 0elieve the parking ticket from 1*12*12 shoudl 0e rescinded given it
occured /hile i /as in custod- on the .a-/alking arrest 0- 4#5 6argent 6ifre, the one /ho .ust lost m-
dog, and /ho also arrested me for misues of 11 incident to a 1*1!*12 /herein i called to report further
domestic violence against me, including the m-sterious disappearance of m- dog and /here 6ifre made
sarcastic statements a0out me and m- dog(
t" Z coughlin's dog Jackson is gone8/d" 9e/ voicemail from (775) 762-155 at !"27 #$
7 received a call from someone claiming the found Jackson, 0ut that the- then took off his
collar*harness /hich had his dog tag on it /hich had m- phone num0er engraved in it 775 )): :11:(
+his )(5 -ear old #ekingnese has a micro chip identifier em0edded in it( #lease help me find him(

m- dog Jackson /as adopted from the spca /ith an adoption id of 1)1!2(
his microchip num0er of ;22261)1; /ith the dhpp of )*1;*11 and 00 of )*1;*11 he has all his
vaccinations and is a cream colored pekingnese /hose collar*harness /as removed 0- the people /ho
found them /hose phone num0er is included herein
7+he /a- the 4eno #5 treated the 11 call of )*27*12 and allo/ed m- dog, Jackson, to escape is
reminiscent of the 4#5 approach to situations /here 4ichard <( =ill, >s?( makes a report of some
criminal violation, in comparision to /hen someone reports a criminal violation 0- 4ichard <( =ill,
>s?( 6ome might sa- /hen =ill's files a report or signs a criminal complaint, the 4#5 treats it as a
@violation fo criminal la/, a police matter@, 0ut that /hen an-one points out =ill's attempts at eAtortion,
0ri0er-, a0use of process, larcen-, /ithholding one's state issued identification, per.ur-, etc(, etc(, the
4#5 simpl- /ashes their hands clean of the complainants re?uest, indicating, @sorr-, 0udd-, that's a
civil matter, -our remed- is /ith the courts(((@( 6o, /hen =ill /ants a +emporar- #rotection 1rder
against Zach %oughlin, 0ecause, gosh darn it, %oughlin is fimliming and collectding evidence of the
personal propert- that =ill's contractor, #hil 6te/art's cre/ is thro/ing a/a- from %oughlin's former
home la/ office, in anticipation of a /rongful eviction la/suit against =ill and his Beverl- =ill's =igh
6chool graduate %alifornia 9eurosurgeon landlord client, $att $erliss (no/ on appeal in %311-;)62:,
/herein Judge 8lanagan of 5epartment 7 recentl- denied one of =ill's @?uadruple .eopard-@ cheap
shots at %oughlin, 0- den-ing =ill's $otion for 1rder to 6ho/ %ause (no/ that .ust leaves the 0aseless
6tate Bar of 9evada grievance =ill filed on 0ehalf of individuals /hom are not even his clients,
/herein he cites unattri0uted hearsa- and for /hich he failed to attach an actual signature thereto, and
/hich consists chiefl- of innuendo and complaining that %oughlin dared to actuall- re?uest a fee
1*5
/aiver from the 5istrict %ourt to file a complaint, despite doing so 0eing an accepta0le practice as set
forth in statute in 946 12(;15)( 6o, /here %oughlins peacefull- filming on a side/alk, the 4#5
doesn't tell 4ichard =ill, >s?( that @its a civil matter, sorr- -our remed- is /ith the courts@, 0ut rather,
6argent #aul 6ifre orders a -oung trainee , 1fficer Ceed-, to /alk up to %oughlin unprovoked, gra0 the
video camera out of his hand prior to making an- sort of attempt to engage %oughlin or other/ise
eAplain /h- the 4#5 /ould 0e, in a matter of t/o seconds, appl-ing eAcessive force to %oughlin's 0ent
0ack /rists and o0structing .ustice 0- turning off his video camera despite %oughlin's eApress
insistance that 6argent #aul 6ifre refrain from doing so(

7ncidentall-, the 4#5 6argent /hom charged me /ith the @misuse of 11@ gross misdemeanor that 7 am
currentl- facing, plagued /tih the representation of one Bira- 5ogan in, actuall- managed to lose m-
dog on )*27*12, /hen 6argent 6ifre /as responding to a true instance of misuse of 11, /here Zach
%oughlin's @sister@ %arl- 9oel %oughlin, called 11 to report that $r( %oughlin had arrived at %arl-'s
house, /here she had invited him to drop of his pekingnese dog, Jackson #a/luck, if he ever /anted
$s( %oughlin's @friend@ to /atch Jackson again( $s( %oughlin indicated that @the peopel /ho /atched
him last time cried /hen 7 /ent to go get him, so 7 don't reall- /anna do this again@ despite her earlier
indication that she /ould( $s( %oughlin, gre/ anno-ed /ith $r( %oughlin's re?uest and renegged on
her offer to transport the dog to the disa0led /oman to /hom it 0rought so much .o-, and her daughter(
$r( %oughlin /alked 0ack to his car /ith his dog to leave, 0ut his car /as apparentl- to lo/ on gas to
start( $s( %oughlin continued to regale $r( %oughlin /ith her h-pocritical, saturnine approach to
human relations (this despite her /orking in the mental health care field, apparentl-, and perhaps, most
trou0ling)( $s( %oughlin threatened to call 11 if $r( %oughlin did not leave immediatel-, $r(
%oughlin said he /ould, asked /hat on earth she /ould 0e calling 11 a0out, and promptl- attempted
to start his car to leave( 7t /ould not, and $s( %oughlin drove off( $r( %oughlin, kno/ing full /ell that
his sister /ould in fact 0e calling 11, and that she /as /ell a/are of $r( %oughlin's recent trials and
tri0ulations /ith local la/ enforcement in light of $r( %oughlin's a0errant 0elief that people in this
count- actuall- do have rights and that /e do not live in a police state), and that she, in fact, sought to
further cause $r( %oughlin discord /ith la/ enforcement, somethign /hich should /ould, of course,
later @remiA@ as her @concern@ for his @/elfare@( 6argent 6ifre, /hom for some reason /as assigned to
ans/er this call 0- the 4#5, echoed these sentiments to $r( %oughlin and provided his professional
opinion that $s( %oughlin did @care so ver- deepl-@ a0out $r( %oughlin( 2pparentl-, this profound
concern /as also eAhi0ited in $s( %oughlin calling 11 a second time the night of )*27*12 /hen $r(
%oughlin returned some t/o hours laters to his vehicle, parked on Deele 6t(, on a pu0lic street, /ith a
gas can /ith half a gallon of gas, intending to place it in his care and drive of, hopefull- 0efore, once
again, 0eing a0used 0- local la/ enforcement, like 6argnet 6ifre, /hom /as laughing on 1*1!*12 /hen
he arrested %oughlin and charged him /ith a gross misdemeanor, @misuse of 11@( $s( %oughlin of
course sought to have $r( %oughlin arrested for nothing and to further involve $r( %oughlin /ith local
la/ enforcement, though that pro0a0l- has nothing to do /ith her various 0itter statements over the
-ears a0out ho/ 7t has not 0een found and ma- /ell 0e dead given the proAimit- of traffic and the
dog's ineAperience in dealing /ith it( =o/ 6argent 6ifre could possi0l- lecture $r( %oughlin for over
an hour, perhaps causing %oughlin to miss an electronic filing deadline in an important legal matter is
unclear, particularl- /here 6argent 6ifre admitted to %oughlin that $s( %oughlin admitted $r(
%oughlin did not touch her, harm her, or threaten her in an- /a-( =o/ it is that $s( %oughlin is not
guilt- of @misuse of 11@ /hereas $r( %oughlin /as su0.ect to a custodial arrest for the ver- same
charge, 0- the ver- same 4#5 6argent, #aul 6ifre, is .ust not ver- clear( (( 2n-/a-s, 6argent #aul 6ifre
had to admit to Zach %oughlin, on )*27*12, that he and his 4#5 associate had allo/ed $r( %oughlin's
dog Jackson, to escape from $s( %oughlins unlocked residence, /here $r( %oughlin had placed the
2*5
dog immediatel- 0efore attempting to go /alk to a gas station and get gas, given $r( %oughlin's
reasona0le 0elieve that if he left his dog in his parked car, outside $s( %oughlin's house, he /ould 0e
arrested 0- the 4#5 for @dog endangerment or neglect or animal cruelt-@((((2ma&ingl-, even after
letting $r( %oughlin's dog escape from $s( %oughlin's house, and perhaps 0e hit 0- a car, 6argent 6ifre
still sa/ fit to lecture $r( %oughlin and point out the 0enevolence of the police state 6argent 6ifre and
those like him currentl- have in place in Eashoe %ount- and the %it- of 4eno( But, 4#5 6argent 6ifre
/as sure to point out to attorne- %oughlin ho/ ver- profoundl- deep 5r( %oughlin and %arl- 9(
%oughlin's concern /as for attorne- %oughlin( =o/ever, their concern is apparentl- not so significant
as to allo/, sa-, attorne- to store a plastic gar0age 0ag full of eApensive suits under 5r( %oughlin's
%aughlin 4anch home, /hich has 5 empt- 0edrooms and a @mudroom@ the si&e of an aircraft hanger
under the home for storing things( 2fter the 0ag of suits 0eing 0eneath 5r( %oughlin's home for
approAimatel- a /eek the- out/ore their /elcome, prompting 5r( %oughlin and his /ife, $onica
$orelli %oughlin to in?uire as to /hen attorne- %oughlin might 0e a0le to remove such 0ag from the
@mudroom@ underneath their home, /hich, again, has 5 empt- 0edrooms( 5r( %oughlin previousl-
telephone the 5ean of the F9C3 Bo-d 6chool of la/ to defame his son, /hereupon 5ean 4ichard
$organ, ever the risk minimi&er middle managing, 0usiness attorne-, cutthroat, educator that is he,
promptl- called up the 6tate Bar to report as much( 2nd /ould %arl- 9oel %oughlin 0e alright /ith
allo/ing her 0rother, attorne- %oughlin to store, sa-, a guitar or a 0oA of papers at her home for a little
/hileG 1f course she /ouldn't( +hough, $iss %arl- sure /ill put on a sho/ of @concern@ for 6argent
6ifre /hen he sho/s up, t/ice(((((1h, 0ut ho/ ver- much the- /ant to @help@( Just onl- /ith
ps-cho0a00le and fauA concern and self serving po/er hungr-, manipulative ego trips, rather than an-
discerni0le, tangi0le 0enefit to the tasks at hand( 5r( %oughlin is 4eno %it- 2ttorne- John Dadlic's
personal ph-sician, and Dadlic is godfather to the daugther 5r( %oughlin had /ith $onica $orelli
%oughlin, of $orelli v( $orelli fame"
http"**///(leagle(com*Aml4esult(aspAG
AmldocH1:61!2!72;#2d7;!I11!1(AmlJdoc0aseH%6CE242-1:6-2;;6
7n $orelli v( $orelli, 9evada's first 7talian 9eurosurgeon /as sued 0- his no/ attorne- 1: -ear old
daugther for the cost of her college and la/ school tuition, /hich /as eApressl- set forth as a
stipulation in the marital settlement agreement in that matter( +he daughter /as a/arded the tution and
father and daughter never spoke again during 5r( $orelli's lifetime, some 2; more -ears(
7ronicall-, the @misuse of 11@ charged stemmed from m- calling a0out the m-sterious and menacing
disappearance of m- dog (/hom 7 appeared /ith in the 5ecem0er 2;12 issue of the 9evada Ca/-er),
/hich occured in the conteAt of a continuous 0arrage of domestic violence to /hich 7 /as eAposed,
thorugh the first siA /eeks of 2;12, 0- the actions of m- then housemates, and for /hich 7 attempted to
o0tain protection or .ustice from 0- contacting the 4#5, including 6argent Zach +he/ (allegedl-, 7 /as
arrested /hile allegedl- attempting to contact 6argent +he/, in accordance /ith 6argent +he/'s
eApress instructions that 7 do so
http"**///(-outu0e(com*/atchGvHoF)tIk44;42
)*5
((((/hich Bira- 5ogan kno/s, 0ut for /hich $r( 5ogan has refused to file an- $otion to 5ismiss or
other action on m- 0ehalf, rather, $r( 5ogan seeks to retaliate against me and to em0arass me /ith -et
another retaliator- @competenc-@ evaluation, despite the fact that 7 passed, /ith fl-ing colors, the one
administered 0- Ci00- =ei.ne after 5eput- Eashoe %ount- #u0lic 5efendenr %ar- =-lin ordered one
(su0se?uent filings 0- the E%#5 indicated that a @hearing@ took place /herein such an evaluation /as
re?uested 0- =-lin and orderd 0- Judge Jack 6chroeder, -et no such @hearing@ took place)K
4#5 6argent 6ifre (/hom actuall- makes more mone- through his pu0lic emplo-ment than most
5istrict %ourt Judges) arrested me another time, making it t/ice in t/o da-s, on Januar- 12th, 2;12 for
@.a-/alking, then he o0structed .ustice 0- turning off m- video camera /hile 4#5 1fficer Cook and
1fficer Ceed- /ere using eAcessive force (completel- out of the 0lue and /ith &ero .ustification for
doing so, as evinced 0- the video itself) on me(
http"**///(-outu0e(com*/atchGvHgBu&fl<2C>JfeatureHrelated
5eput- 5istrict 2ttorne- Zach 9ifong, er, Zach Loung, >s?(, has 0een eAtremel- resistant to an- sort of
plea 0argaining in either case, as he has 0een in the matter for /hich 5eput- #u0lic 5efender Joe
<oodnight, >s?( is @representing@ me as m- @attorne-@( +hat matter 4%4 also included police
misconduct 0- the 4eno #olice 5epartment, 0- 1fficers 4on 4osa and 9ick 5uralde( Ehere /ould
4eno attorne- Zach %oughlin, >s?( 0e if there /as not video tape of all of this police misconductG
http"**///(-outu0e(com*/atchGvH5#47?!1750;JfeatureHrelated
5espite having this video, 52 Zach Loung retaliated against %oughlin for %oughlin's filing a 94%# 11
$otion against 0oth <oodnight and Loung 0- amending the criminal complaint to overcharge some
more( 9o, rather 52 Zach Loung and the 4#5 see the /itness tampering and attempts to dissuade
9icole Eatson from offering an- insight into the /rongful arrest of :*2;*12 0- 9icholas 5uradle as @a
civil matter@, not a @criminal one@( =eck, the 4#5 doesn't even see 0atter-, assault, aggravated assault,
or domestic violence as @criminal in nature@ /hen these things happen to pesk- 8irst 2mendment
attorne- Zachar- Barker %oughlin, >s?(, (((no, rather, those are matters of a @civil nature@ and
%oughlin's @remed- is /ith the court's@, so sa-eth 4#5 1fficer 6tace- <ardner, 6argent $onica Cope&,
1fficer $c?uattr-, 1fficer Cook and Ceed- and 5elvecchio, 1fficer Earren, etc(, etc(,
7ncidentall-, it /ould 0e helpful if an entit- like Eashoe Cegal 6ervices took an aggresive approach to
advocating on 0ehalf of tenants'(((((Eashoe Cegal 6ervices >Aecutive 5irector #aul >lcano has
reportedl- call 5r( %oughlin in an attempt to influence attorne- %oughlin to close the case %oughlin
has against EC6 for /rongful termination(
!*5
7ts a good thing 9evada has so man- 0rave 8irst 2mendment attorne-'s like J$ 5evo- and his
associate $arc 4anda&&a, neither of /hom have an- association /ith $r( %oughlin( 7, $r( %oughlin
am a/are that it is slightl- a/k/ard to /rite this s/itching 0et/een the first and third person, ho/ever,
the eAigencies and economics of solo la/ practice /ere at plain doing so(
2t least there isn't much of a societal cost to the legall- ?uestiona0le manner in /hich evictions are
decided and carried out in Eashoe %ount-"
http"**///(-outu0e(com*/atchGvHss>;8E=89>L
http"**///(-outu0e(com*/atchGvHD.<2a>.slr!
Zach %oughlin, >s?(, #1 B1M 6;52, 4>91, 93, :5;6, tel" 775 )): :11:, faA" ! 667 7!;2K
Zach%oughlin'hotmail(com 9evada Bar 9o" !7)

5ate" +hu, 2 $ar 2;12 1:"2"1: -;7;;
6u0.ect" Z coughlin's dog Jackson is gone8/d" 9e/ voicemail from (775) 762-155 at !"27 #$
+o"

---------- 8or/arded message ----------
8rom" <oogle 3oice Nvoice-norepl-'google(comO
5ate" +hu, $ar 2, 2;12 at !")1 #$
6u0.ect" 9e/ voicemail from (775) 762-155 at !"27 #$
3oicemail from" (775) 762-155 at !"27 #$
+ranscript not availa0le
#la- message
5*5
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
Name J OEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Name J USTIN 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: Thu 3/29/12 2:05 PM
To: renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com;
defense@freeman-law.com
19 attachments
11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED.pdf (2.6 MB) , 2 24 20 fax to
rmc regarding deficiency in record on appeal - Copy.pdf (55.6 KB) , 3 19 12 fas to rmc marshals regarding property
wcso - Copy.pdf (40.0 KB) , 3 26 12 fax to rmc regarding address emails and car sleeping allegations - Copy.pdf
(51.9 KB) , J AMES MENZEL TransparentNevada rmc marshal menzel 2009 does not include health benefits.htm (3.6
KB) , J OEL HARLEY TransparentNevada RMC Marshal Harley.htm (3.3 KB) , J USTIN ROPER TransparentNevada
rmc chief marshal justin roper 2010 base pay 109K.htm (3.3 KB) , motion to set aside RMC 11 CR 22176 faxed 2 22
12 - Copy.pdf (196.5 KB) , Pages from mary barker rmc 11 tr 26800 order denying motion for return of bond -
Copy.pdf (508.2 KB) , cr11-2064 motion for extension fo tiem.pdf (133.2 KB) , CR11-2064-2676094 (Opposition to
Mtn ...).pdf (167.7 KB) , CR11-2064-2682479 (Supplemental ...).pdf (149.7 KB) , CR11-2064-2682487 (Supplemental
...).pdf (75.3 KB) , ex 44 pages all emails to renomunirecords@reno.gov from ZachCoughlin@hotmail.com.pdf (288.8
KB) , Motion_for_Continuance_to_Reno_City_Atty_Roberts_RMC.pdf (448.9 KB) , 2 24 20 fax to rmc regarding
deficiency in record on appeal.pdf (55.6 KB) , 3 19 12 fax to reno marshal division.pdf (193.0 KB) , chief marshal
justin roper roperj@reno.gov emails.pdf (155.9 KB) , complaint or grievance by J udge Dorothy Nash Holmes against
Reno attorney Coughlin with State Bar of Nevada 3 14 12.pdf (737.8 KB)
Dear City of Reno and Mr. J eanney,
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 J udge 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 J udge 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.
No: 9473
Name J AMES MENZEL
Position
Marshal
Reno
Notice
Year 2009
Base Pay $60,609.42
Overtime and
Callback Collected
$622.67
Name J OEL HARLEY
Position
7821 - Marshal
Reno
Year 2010
Base Pay $85,323.07
Overtime and
Callback Collected
$6,755.56
Other Pay $478.65
Name J USTIN ROPER
i was evicted 3 15 12, i need a continuance
Position
Reno
Year 2010
Base Pay $107,914.00
Overtime and
Callback Collected
$0.00
Other Pay ($2,697.89)
Total Pay $105,216.11
Sent: Mon 3/26/12 10:32 PM
To: keithloomis@earthlink.net; stermitz@sbcglobal.net; jmd@randazza.com; jboles@callatg.com;
kristiemanning@yahoo.com; kadlicj@reno.gov
2 attachments
65-main.pdf (159.6 KB) , 65-1.pdf (248.3 KB)
Dear Mr. Loomis,
I was wrongfully evicted on 3 15 12, and I need a continuance in the criminal trespass matter that you set
overly quickly against my express wishes anyway. My ability to collect evidence necessary to my defense
and otherwise prepare has been adversely affected. Additionally, I don't feel as though you are performing in
an appropriate manner as defense counsel, but rather you seem stuck in your prosecutorial ways, too quick to
look for any excuse whatsoever to bury one's case, so I think you have forced a split here, which further
prejudices my case and augers towards a continuance. Please move for one immediately and copy me on my
entire file by email and fax please. Additionally, please seek clarification from the RMC as to whether I am
allowed to ever send an email to renomunicrecords@reno.gov. Please note, today, J udge Flanagan denied
Richard Hill's latest frivolous motion.
Did you know that Kevin Kelly, of the State Bar of Nevada's Character and Fitness Committee for at least the
last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
http://www.reviewjournal.com/lvrj_home/2002/Mar-06-Wed-2002/news/18241452.html
I know I always like my three hour tours of heavy handed moralizing from someone who runs a monolithic
strip club in Las Vegas.
You are on the State Bar of Nevada's fee dispute committee, aren't you Mr. Loomis? Do you own any strip
clubs?
Mr. Loomis, which of the elements of the trespass charge RMC 8.10.040 do you feel are weakest
for Deputy City Attorney J ill Drake, whom I informed about the admission by Reno PD Officer
please note my new address, SOLACE PROGRAM REQUEST?
3/!/"
Reply ?
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Fear Fep&ty 7as%oe Co&nty P&)l($ Fe0ender =(ray Fo'an, EsN+, et al,
M&st C &se La.eMs Cross(n' 0or t%(s se$ond $ompeten$y e/al&at(on? Fo yo& %a/e some sort o0 0(nan$(al
arran'ment w(t% La.eMs Cross(n'? Please pro/(de a wr(tten answer as to w%om else C may &t(l(-e 0or
s&$% an e/al&at(on and t%e reN&(rements, $ert(0($at(ons, or standards, w%($% t%ey m&st meet (n order to
)e el('()el to per0orm s&$% an e/al&at(on+ Gonet%eless, C %a/e yet to re$e(/e anyt%(n' 0rom La.eMs
Cross(n', )&t C w(ll $all t%em now and $opy t%em on t%(s ema(l (n an attempt to $omply w(t% t%e
e/al&at(on reN&(rement+ Ms+ :e,ny o0 La.es Cross(n', C was a)le to $%e$. my /o($e ma(ls desp(te
0ormer pr(son warden or adm(n(strator RMC D&d'e Gas% :olmes s&mmar(ly se(-(n' my, an attorneyMs,
$ell&lar and smartp%one (n $o&rt on /</", and st(ll re0&s(n' to release t%em, desp(te :er :onor 0(l(n'
a 'r(e/an$e a'a(nst Co&'%l(n w(t% t%e State =ar o0 Ge/ada t%at ne'le$ts to ment(on t%at se(-&re at
all++++nonet%eless, a d(00($&lt to d(s$ern messa'e so&nd l(.e (t was 0rom a Fr+ =rown w(t% La.es
Cross(n'+++Ms+ :e,ny, wo&ld yo& 0orward t%(s on to %(m w(t% a messa'e t%at C am try(n' to meet %(m
and $omply w(t% all s$%ed&l(n' reN&(rements (mposed &pon me?
Please $opy me /(a ema(l and 0aJ on my ent(re 0(le+ T%e domest($ /(olen$e atta$.s a'a(nst me (n 3;"@
22"!! and 3;"@22"!< res&lted (n (nter0eren$e w(t% re$e(pt o0 my USPS ma(l+ C %a/e ta.en all
reasona)le steps to $o&ntera$t t%at, %owe/er, (n an a)&ndan$e o0 $a&t(on, C as. t%at yo& $opy me on
e/eryt%(n' /(a ema(l and 0aJ and %a/e La.es Cross(n' do so as well+ Add(t(onally, D&d'e Gas% :olmes
$on0(s$ated my p%ones on /</" and st(ll %as not released t%em or pro/(ded 5as 0ar as C .now6 any
(nd($at(on 0or %er )as(s 0or do(n' so, et$+
Mr+ Fo'an, please eJpla(n yo&r pos(t(on /(s a /(s yo&r m(ss(n' t%e Arra('nment (n my $ases, (n$l&d(n'
spe$(0($ re0eren$e to t%e approJ(mately I2 m(n&te meet(n' yo& and C %ad (n ad/an$e o0 t%at
arra('nment+ 3&rt%er, please pro/(de an (nd($at(on (n wr(t(n' as to w%y yo& 0elt t%(s more (n/as(/e,
more (n/ol/ed $ompeten$y e/al&at(on yo& mo/ed 0or was a reN&est )ased (n law or 0a$t, (n$l&d(n'
spe$(0($ deta(ls and do$&mentat(on (n s&pport t%ereo0+ O%, t%atMs r('%t, =(ray Fo'an and Doe Goodn('%t
o0 t%e 7CPF only )el(e/e t%at GRCP "" appl(es to $r(m(nal matters w%ere t%ey need to le/era'e (t as
an eJ$&se not to 0(le a Mot(on to F(sm(ss or some ot%er pre@tr(al mot(on++++Fo'an and Goodn('%tMs
pos(t(on on Ge/ada R&le o0 C(/(l Pro$ed&re "" (n a $r(m(nal $onteJt, t%o&'%, (n t%e $onteJt o0 0(l(n'
any Mot(on 0or San$t(ons a'a(nst Goodn('%tMs or'an($ 0ree trade $o00ee s%op )&ddy FA #a$% Oo&n' (s
t%at PGRCP "" does not apply (n a $r(m(nal $onteJtP+ Cts rem(n(s$ent o0 t%e RPF approa$% to s(t&at(ons
w%ere R($%ard G+ :(ll, EsN+ ma.es a report o0 some $r(m(nal /(olat(on, (n $ompar(s(on to w%en
someone reports a $r(m(nal /(olat(on )y R($%ard G+ :(ll, EsN+ Some m('%t say w%en :(llMs 0(les a report
or s('ns a $r(m(nal $ompla(nt, t%e RPF treats (t as a P/(olat(on 0o $r(m(nal law, a pol($e matterP, )&t t%at
/"
w%en anyone po(nts o&t :(llMs attempts at eJtort(on, )r()ery, a)&se o0 pro$ess, lar$eny, w(t%%old(n'
oneMs state (ss&ed (dent(0($at(on, per,&ry, et$+, et$+, t%e RPF s(mply was%es t%e(r %ands $lean o0 t%e
$ompla(nants reN&est, (nd($at(n', Psorry, )&ddy, t%atMs a $(/(l matter, yo&r remedy (s w(t% t%e $o&rts+++P+
So, w%en :(ll wants a Temporary Prote$t(on Order a'a(nst #a$% Co&'%l(n, )e$a&se, 'os% darn (t,
Co&'%l(n (s 0(ml(m(n' and $olle$td(n' e/(den$e o0 t%e personal property t%at :(llMs $ontra$tor, P%(l
StewartMs $rew (s t%row(n' away 0rom Co&'%l(nMs 0ormer %ome law o00($e, (n ant($(pat(on o0 a wron'0&l
e/($t(on laws&(t a'a(nst :(ll and %(s =e/erly :(llMs :('% S$%ool 'rad&ate Cal(0orn(a Ge&ros&r'eon
landlord $l(ent, Matt Merl(ss 5now on appeal (n C;""@23E!, w%ere(n D&d'e 3lana'an o0 Fepartment <
re$ently den(ed one o0 :(llMs PN&adr&ple ,eopardyP $%eap s%ots at Co&'%l(n, )y deny(n' :(llMs Mot(on
0or Order to S%ow Ca&se 5now t%at ,&st lea/es t%e )aseless State =ar o0 Ge/ada 'r(e/an$e :(ll 0(led on
)e%al0 o0 (nd(/(d&als w%om are not e/en %(s $l(ents, w%ere(n %e $(tes &nattr()&ted %earsay and 0or
w%($% %e 0a(led to atta$% an a$t&al s('nat&re t%ereto, and w%($% $ons(sts $%(e0ly o0 (nn&endo and
$ompla(n(n' t%at Co&'%l(n dared to a$t&ally reN&est a 0ee wa(/er 0rom t%e F(str($t Co&rt to 0(le a
$ompla(nt, desp(te do(n' so )e(n' an a$$epta)le pra$t($e as set 0ort% (n stat&te (n GRS "+2"16+ So,
w%ere Co&'%l(ns pea$e0&lly 0(lm(n' on a s(dewal., t%e RPF doesnMt tell R($%ard :(ll, EsN+ t%at P(ts a
$(/(l matter, sorry yo&r remedy (s w(t% t%e $o&rtsP, )&t rat%er, Sar'ent Pa&l S(0re orders a yo&n'
tra(nee , O00($er Leedy, to wal. &p to Co&'%l(n &npro/o.ed, 'ra) t%e /(deo $amera o&t o0 %(s %and pr(or
to ma.(n' any sort o0 attempt to en'a'e Co&'%l(n or ot%erw(se eJpla(n w%y t%e RPF wo&ld )e, (n a
matter o0 two se$onds, apply(n' eJ$ess(/e 0or$e to Co&'%l(nMs )ent )a$. wr(sts and o)str&$t(n' ,&st($e
)y t&rn(n' o00 %(s /(deo $amera desp(te Co&'%l(nMs eJpress (ns(stan$e t%at Sar'ent Pa&l S(0re re0ra(n
0rom do(n' so+
3&rt%er, please eJpla(n w%at eJa$tly yo& meant w%en yo& told me, a0ter we d(s$&ssed my pre/(o&s
wor. eJper(en$e at :ale Lane, t%at yo& $o&ld ne/er do $(/(l law (n t%e pr(/ate se$tor w%at w(t% all t%at
%ard wor. and t%e )(lla)le %o&rs reN&(rements )e(n' demand(n' o0 yo&r t(me and e00ort, and t%at yo&
0o&nd t%e p&)l($ de0ender l(0estyle m&$% more to yo&r l(.(n'+ Please also eJpla(n w%y yo& 0o&nd (t
ne$essary to po(nt o&t %ow )(tterly d(sappo(nted yo& were w(t% t%e la$. o0 d(/ers(ty (n RenoMs ,&d($(ary
and Reno (n 'eneral, and %ow m&$% yo& sympat%(-ed w(t% t%e pl('%t o0 poor D&d'e :oward 5w%om %as
ne/er de0eated anyone (n an ele$t(on desp(te )e(n' on t%e )en$% s(n$e "II!6 (n %a/(n' to deal w(t% me
(n "" $r "<E, w%ere(n %e senten$ed Reno attorney Co&'%l(n to 3 days (n ,a(l 0or a 0(nd(n' o0 s&mmary
$ontempt &nder GRS +2"2 0or -ealo&sly ad/o$at(n' on )e%al0 o0 a de0endant (n a $r(m(nal matter
w%ere pol($e m(s$ond&$t was alle'ed+ Mr+ =osler, C am %ere)y reN&est(n' t%at a $opy o0 t%(s and all
ot%er $orresponden$es )etween =(ray Fo'an and mysel0 and my $omplete 0(le (n t%e matter 0or w%($%
Mr+ Fo'an (s represent(n' me )e pla$ed (n Mr+ Fo'anMs 0(le and t%at a 0ormal $ompla(nt (n/est('at(on
a'a(nst Mr+ Fo'an 0or %(s ne'l('en$e (n represent(n' me so 0ar and %(s retal(atory approa$% 5%a/(n' a
psy$%e e/al&at(on ordered t%at (s d(splayed on t%e www+$$was%oe+$om $o&rt$onne$t do$.et (n $lose
proJ(m(ty to my $ompla(n(n' o0 Mr+ Fo'anMs 0a(l&re to appear at my arra(n'ment and %(s N&est(ona)le
statements to me, as well as t%e pra$t($e %e and Fep&ty PF Doe Goodn('%t attempted to employe
pre/(o&sly were t%ey (ns(sted &pon tal.(n' to me on t%e p%one as a pa(r, (n a s&rpr(se approa$% manner+
Cn$(dentally, t%e RPF Sar'ent w%om $%ar'ed me w(t% t%e Pm(s&se o0 I""P 'ross m(sdemeanor t%at C am
$&rrently 0a$(n', pla'&ed wt(% t%e representat(on o0 one =(ray Fo'an (n, a$t&ally mana'ed to lose my
do' last n('%t, w%en Sar'ent S(0re was respond(n' to a tr&e (nstan$e o0 m(s&es o0 I"", w%ere #a$%
Co&'%l(nMs Ps(sterP Carly Goel Co&'%l(n, $alled I"" to report t%at Mr+ Co&'%l(n %ad arr(/ed at CarlyMs
%o&se, w%ere s%e %ad (n/(ted %(m to drop o0 %(s pe.(n'nese do', Da$.son Pawl&$., (0 %e e/er wanted
Ms+ Co&'%l(nMs P0r(endP to wat$% Da$.son a'a(n+ Ms+ Co&'%l(n (nd($ated t%at Pt%e peopel w%o wat$%ed
%(m last t(me $r(ed w%en C went to 'o 'et %(m, so C donMt really wanna do t%(s a'a(nP desp(te %er earl(er
(nd($at(on t%at s%e wo&ld+ Ms+ Co&'%l(n, 'rew annoyed w(t% Mr+ Co&'%l(nMs reN&est and rene''ed on
%er o00er to transport t%e do' to t%e d(sa)led woman to w%om (t )ro&'%t so m&$% ,oy, and %er da&'%ter+
3/"
Mr+ Co&'%l(n wal.ed )a$. to %(s $ar w(t% %(s do' to lea/e, )&t %(s $ar was apparently to low on 'as to
start+ Ms+ Co&'%l(n $ont(n&ed to re'ale Mr+ Co&'%l(n w(t% %er %ypo$r(t($al, sat&rn(ne approa$% to
%&man relat(ons 5t%(s desp(te %er wor.(n' (n t%e mental %ealt% $are 0(eld, apparently, and per%aps, most
tro&)l(n'6+ Ms+ Co&'%l(n t%reatened to $all I"" (0 Mr+ Co&'%l(n d(d not lea/e (mmed(ately, Mr+
Co&'%l(n sa(d %e wo&ld, as.ed w%at on eart% s%e wo&ld )e $all(n' I"" a)o&t, and promptly attempted
to start %(s $ar to lea/e+ Ct wo&ld not, and Ms+ Co&'%l(n dro/e o00+ Mr+ Co&'%l(n, .now(n' 0&ll well t%at
%(s s(ster wo&ld (n 0a$t )e $all(n' I"", and t%at s%e was well aware o0 Mr+ Co&'%l(nMs re$ent tr(als and
tr()&lat(ons w(t% lo$al law en0or$ement (n l('%t o0 Mr+ Co&'%l(nMs a)errant )el(e0 t%at people (n t%(s
$o&nty a$t&ally do %a/e r('%ts and t%at we do not l(/e (n a pol($e state6, and t%at s%e, (n 0a$t, so&'%t to
0&rt%er $a&se Mr+ Co&'%l(n d(s$ord w(t% law en0or$ement, somet%('n w%($% s%o&ld wo&ld, o0 $o&rse,
later Prem(JP as %er P$on$ernP 0or %(s Pwel0areP+ Sar'ent S(0re, w%om 0or some reason was ass('ned to
answer t%(s $all )y t%e RPF, e$%oed t%ese sent(ments to Mr+ Co&'%l(n and pro/(ded %(s pro0ess(onal
op(n(on t%at Ms+ Co&'%l(n d(d P$are so /ery deeplyP a)o&t Mr+ Co&'%l(n+ Apparently, t%(s pro0o&nd
$on$ern was also eJ%()(ted (n Ms+ Co&'%l(n $all(n' I"" a se$ond t(me t%e n('%t o0 3/</" w%en Mr+
Co&'%l(n ret&rned some two %o&rs laters to %(s /e%($le, par.ed on Keele St+, on a p&)l($ street, w(t% a
'as $an w(t% %al0 a 'allon o0 'as, (ntend(n' to pla$e (t (n %(s $are and dr(/e o0, %ope0&lly )e0ore, on$e
a'a(n, )e(n' a)&sed )y lo$al law en0or$ement, l(.e Sar'net S(0re, w%om was la&'%(n' on "/"8/" w%en
%e arrested Co&'%l(n and $%ar'ed %(m w(t% a 'ross m(sdemeanor, Pm(s&se o0 I""P+ Ms+ Co&'%l(n o0
$o&rse so&'%t to %a/e Mr+ Co&'%l(n arrested 0or not%(n' and to 0&rt%er (n/ol/e Mr+ Co&'%l(n w(t% lo$al
law en0or$ement, t%o&'% t%at pro)a)ly %as not%(n' to do w(t% %er /ar(o&s )(tter statements o/er t%e
years a)o&t %ow Ct %as not )een 0o&nd and may well )e dead '(/en t%e proJ(m(ty o0 tra00($ and t%e
do'Ms (neJper(en$e (n deal(n' w(t% (t+ :ow Sar'ent S(0re $o&ld poss()ly le$t&re Mr+ Co&'%l(n 0or o/er
an %o&r, per%aps $a&s(n' Co&'%l(n to m(ss an ele$tron($ 0(l(n' deadl(ne (n an (mportant le'al matter (s
&n$lear, part($&larly w%ere Sar'ent S(0re adm(tted to Co&'%l(n t%at Ms+ Co&'%l(n adm(tted Mr+
Co&'%l(n d(d not to&$% %er, %arm %er, or t%reaten %er (n any way+ :ow (t (s t%at Ms+ Co&'%l(n (s not
'&(lty o0 Pm(s&se o0 I""P w%ereas Mr+ Co&'%l(n was s&),e$t to a $&stod(al arrest 0or t%e /ery same
$%ar'e, )y t%e /ery same RPF Sar'ent, Pa&l S(0re, (s ,&st not /ery $lear+ =&t, one s%o&ldnMt %old oneMs
)reat% wa(t(n' 0or any sort o0 -ealo&s ad/o$a$y )y one =(ray Fo'an, Fep&ty 7as%oe Co&nty P&)l($
Fe0ender, or any 'reat eJ%()(t(on o0 restra(nt )y Fep&ty F(str($t Attorney #a$% Oo&n'+ Mr+ Co&'%l(n
was a)le to 0(nally lea/e and $ont(n&e w(t% %(s le'al wor. w%en lo$al PD&d'e 7%(spererP Fr+ T(mot%y
F+ Co&'%l(n, MF arr(/ed w(t% a 'as $an at t%e s$ene and pla$e a 'allon o0 'as (n Mr+ Co&'%l(nMs
/e%($le+ T%at represented t%e 0(rst eJpend(t&re )y Fr+ Co&'%l(n towards P%elp(n'P %(s son t%at was not
$ond(t(oned &pon some )(-arre, M&n$%a&sen )y ProJy, Power and Control 7%eel 5F&l&t% Model6
em)ody(n' p%ys($(an $ontrol 0rea./lawyer en/y (ns(sten$e t%at Mr+ Co&'%l(n )e s&),e$t to some
eJper(emental treatment t%at Fr+ Co&'%l(n 0o&nd reN&(red '(/en Fr+ Co&'%l(nMs )el(e0 %(s son, Reno
Attorney (s a00l($ted w(t% a $ond(t(on w%ere(n a PdemonP res(des (ns(de o0 %(s son+ Fr+ Co&'%l(n le0t %(s
son, Reno Attorney #a$% Co&'%l(n as /o($e ma(l (n t%e last year w%ere(n %e state to %(s son, PC tr&ly
)el(e/e yo& %a/e a demon (ns(de o0 yo& P w%ere&pon Fr+ Co&'%l(n demanded &pon some sort o0
)a$.woods eJor$(sm )e(n' per0ormed &pon attorney Co&'%l(n, w%om re'&larly re0ers to %(s 0at%er as
PT(mP or PFr+ Co&'%l(nP, )&t only /ery rarely, anymore, as PFadP+ Fr+ Co&'%l(n (s re0erred to )y some
as t%e PD&d'e 7%(spererP '(/en %(s stat&s as t%e p%ys($(an o0 $%o($e to &t(l(-e (n t%e s%ame )ased
sled'%ammer role d&r(n' (nter/ent(ons w(t% mem)ers o0 t%e Ge/ada D&d($(ary w%om alle'edly %a/e
s&)stan$e a)&se pro)lems+++ And (ts not &n%eard o0 0or mem)ers o0 t%e ,&d($(ary to approa$% attorney
#a$% Co&'%l(n and as. w%ere t%ey may 0(nd Fr+ Co&'%l(n, as t%ey wo&ld l(.e to p&n$% %(m sN&are (n
t%e mo&t%+ Anyways, Sar'ent Pa&l S(0re %ad to adm(t to #a$% Co&'%l(n, on 3/</", t%at %e and %(s
RPF asso$(ate %ad allowed Mr+ Co&'%l(nMs do' Da$.son, to es$ape 0rom Ms+ Co&'%l(ns &nlo$.ed
res(den$e, w%ere Mr+ Co&'%l(n %ad pla$ed t%e do' (mmed(ately )e0ore attempt(n' to 'o wal. to a 'as
8/"
stat(on and 'et 'as, '(/en Mr+ Co&'%l(nMs reasona)le )el(e/e t%at (0 %e le0t %(s do' (n %(s par.ed $ar,
o&ts(de Ms+ Co&'%l(nMs %o&se, %e wo&ld )e arrested )y t%e RPF 0or Pdo' endan'erment or ne'le$t or
an(mal $r&eltyP++++Ama-(n'ly, e/en a0ter lett(n' Mr+ Co&'%l(nMs do' es$ape 0rom Ms+ Co&'%l(nMs %o&se,
and per%aps )e %(t )y a $ar, Sar'ent S(0re st(ll saw 0(t to le$t&re Mr+ Co&'%l(n and po(nt o&t t%e
)ene/olen$e o0 t%e pol($e state Sar'ent S(0re and t%ose l(.e %(m $&rrently %a/e (n pla$e (n 7as%oe
Co&nty and t%e C(ty o0 Reno+ =&t, RPF Sar'ent S(0re was s&re to po(nt o&t to attorney Co&'%l(n %ow
/ery pro0o&ndly deep Fr+ Co&'%l(n and Carly G+ Co&'%l(nMs $on$ern was 0or attorney Co&'%l(n+
:owe/er, t%e(r $on$ern (s apparently not so s('n(0($ant as to allow, say, attorney to store a plast($
'ar)a'e )a' 0&ll o0 eJpens(/e s&(ts &nder Fr+ Co&'%l(nMs Ca&'%l(n Ran$% %ome, w%($% %as 1 empty
)edrooms and a Pm&droomP t%e s(-e o0 an a(r$ra0t %an'er &nder t%e %ome 0or stor(n' t%(n's+ A0ter t%e
)a' o0 s&(ts )e(n' )eneat% Fr+ Co&'%l(nMs %ome 0or approJ(mately a wee. t%ey o&twore t%e(r wel$ome,
prompt(n' Fr+ Co&'%l(n and %(s w(0e, Mon($a Morell( Co&'%l(n to (nN&(re as to w%en attorney
Co&'%l(n m('%t )e a)le to remo/e s&$% )a' 0rom t%e Pm&droomP &nderneat% t%e(r %ome, w%($%, a'a(n,
%as 1 empty )edrooms+ Fr+ Co&'%l(n pre/(o&sly telep%one t%e Fean o0 t%e UGL; =oyd S$%ool o0 law
to de0ame %(s son, w%ere&pon Fean R($%ard Mor'an, e/er t%e r(s. m(n(m(-er m(ddle mana'(n',
)&s(ness attorney, $&tt%roat, ed&$ator t%at (s %e, promptly $alled &p t%e State =ar to report as m&$%+
And wo&ld Carly Goel Co&'%l(n )e alr('%t w(t% allow(n' %er )rot%er, attorney Co&'%l(n to store, say, a
'&(tar or a )oJ o0 papers at %er %ome 0or a l(ttle w%(le? O0 $o&rse s%e wo&ldnMt+ T%o&'%, M(ss Carly
s&re w(ll p&t on a s%ow o0 P$on$ernP 0or Sar'ent S(0re w%en %e s%ows &p, tw($e+++++O%, )&t %ow /ery
m&$% t%ey want to P%elpP+ D&st only w(t% psy$%o)a))le and 0a&J $on$ern and sel0 ser/(n' power
%&n'ry, man(p&lat(/e e'o tr(ps, rat%er t%an any d(s$ern()le, tan'()le )ene0(t to t%e tas.s at %and+ Fr+
Co&'%l(n (s Reno C(ty Attorney Do%n Kadl($Ms personal p%ys($(an, and Kadl($ (s 'od0at%er to t%e
da&'t%er Fr+ Co&'%l(n %ad w(t% Mon($a Morell( Co&'%l(n, o0 Morell( /+ Morell( 0ame4
%ttp4//www+lea'le+$om/JmlRes&lt+aspJ?
Jmldo$Q"I!E"88<2Pd<28L""8"I+JmlRdo$)aseQCSL7AR@"I!E@22E
Cn Morell( /+ Morell(, Ge/adaMs 0(rst Ctal(an Ge&ros&r'eon was s&ed )y %(s now attorney "! year old
da&'t%er 0or t%e $ost o0 %er $olle'e and law s$%ool t&(t(on, w%($% was eJpressly set 0ort% as a
st(p&lat(on (n t%e mar(tal settlement a'reement (n t%at matter+ T%e da&'%ter was awarded t%e t&t(on and
0at%er and da&'%ter ne/er spo.e a'a(n d&r(n' Fr+ Morell(Ms l(0et(me, some 2 more years+
Cron($ally, t%e Pm(s&se o0 I""P $%ar'ed stemmed 0rom my $all(n' a)o&t t%e myster(o&s and mena$(n'
d(sappearan$e o0 my do' 5w%om C appeared w(t% (n t%e Fe$em)er 2" (ss&e o0 t%e Ge/ada Lawyer6,
w%($% o$$&red (n t%e $onteJt o0 a $ont(n&o&s )arra'e o0 domest($ /(olen$e to w%($% C was eJposed,
t%or&'% t%e 0(rst s(J wee.s o0 2", )y t%e a$t(ons o0 my t%en %o&semates, and 0or w%($% C attempted to
o)ta(n prote$t(on or ,&st($e 0rom )y $onta$t(n' t%e RPF, (n$l&d(n' Sar'ent #a$% T%ew 5alle'edly, C was
arrested w%(le alle'edly attempt(n' to $onta$t Sar'ent T%ew, (n a$$ordan$e w(t% Sar'ent T%ewMs
eJpress (nstr&$t(ons t%at C do so
%ttp4//www+yo&t&)e+$om/wat$%?/QoU3tL.RR2RA
++++w%($% =(ray Fo'an .nows, )&t 0or w%($% Mr+ Fo'an %as re0&sed to 0(le any Mot(on to F(sm(ss or
ot%er a$t(on on my )e%al0, rat%er, Mr+ Fo'an see.s to retal(ate a'a(nst me and to em)arass me w(t% yet
anot%er retal(atory P$ompeten$yP e/al&at(on, desp(te t%e 0a$t t%at C passed, w(t% 0ly(n' $olors, t%e one
adm(n(stered )y L())y :e(,ne a0ter Fep&ty 7as%oe Co&nty P&)l($ Fe0endenr Cary :yl(n ordered one
5s&)seN&ent 0(l(n's )y t%e 7CPF (nd($ated t%at a P%ear(n'P too. pla$e w%ere(n s&$% an e/al&at(on was
reN&ested )y :yl(n and orderd )y D&d'e Da$. S$%roeder, yet no s&$% P%ear(n'P too. pla$e69
RPF Sar'ent S(0re 5w%om a$t&ally ma.es more money t%ro&'% %(s p&)l($ employment t%an most
F(str($t Co&rt D&d'es6 arrested me anot%er t(me, ma.(n' (t tw($e (n two days, on Dan&ary "t%, 2" 0or
P,aywal.(n', t%en %e o)str&$ted ,&st($e )y t&rn(n' o00 my /(deo $amera w%(le RPF O00($er Loo. and
O00($er Leedy were &s(n' eJ$ess(/e 0or$e 5$ompletely o&t o0 t%e )l&e and w(t% -ero ,&st(0($at(on 0or
1/"
do(n' so, as e/(n$ed )y t%e /(deo (tsel06 on me+
%ttp4//www+yo&t&)e+$om/wat$%?/Q'=&I-0lGALER0eat&reQrelated
Fep&ty F(str($t Attorney #a$% G(0on', er, #a$% Oo&n', EsN+, %as )een eJtremely res(stant to any sort o0
plea )ar'a(n(n' (n e(t%er $ase, as %e %as )een (n t%e matter 0or w%($% Fep&ty P&)l($ Fe0ender Doe
Goodn('%t, EsN+ (s Prepresent(n'P me as my PattorneyP+ T%at matter RCR also (n$l&ded pol($e
m(s$ond&$t )y t%e Reno Pol($e Fepartment, )y O00($ers Ron Rosa and G($. F&ralde+ 7%ere wo&ld
Reno attorney #a$% Co&'%l(n, EsN+ )e (0 t%ere was not /(deo tape o0 all o0 t%(s pol($e m(s$ond&$t?
%ttp4//www+yo&t&)e+$om/wat$%?/Q1PR<N8OC1)2R0eat&reQrelated
Fesp(te %a/(n' t%(s /(deo, FA #a$% Oo&n' retal(ated a'a(nst Co&'%l(n 0or Co&'%l(nMs 0(l(n' a GRCP ""
Mot(on a'a(nst )ot% Goodn('%t and Oo&n' )y amend(n' t%e $r(m(nal $ompla(nt to o/er$%ar'e some
more+ Go, rat%er FA #a$% Oo&n' and t%e RPF see t%e w(tness tamper(n' and attempts to d(ss&ade
G($ole 7atson 0rom o00er(n' any (ns('%t (nto t%e wron'0&l arrest o0 !/2/" )y G($%olas F&radle as Pa
$(/(l matterP, not a P$r(m(nal oneP+ :e$., t%e RPF doesnMt e/en see )attery, assa&lt, a''ra/ated assa&lt,
or domest($ /(olen$e as P$r(m(nal (n nat&reP w%en t%ese t%(n's %appen to pes.y 3(rst Amendment
attorney #a$%ary =ar.er Co&'%l(n, EsN+, +++no, rat%er, t%ose are matters o0 a P$(/(l nat&reP and
Co&'%l(nMs Premedy (s w(t% t%e $o&rtMsP, so sayet% RPF O00($er Sta$ey Gardner, Sar'ent Mon($a Lope-,
O00($er M$N&attry, O00($er Loo. and Leedy and Fel/e$$%(o, O00($er 7arren, et$+, et$+,
Cn$(dentally, (t wo&ld )e %elp0&l (0 an ent(ty l(.e 7as%oe Le'al Ser/($es too. an a''res(/e approa$% to
ad/o$at(n' on )e%al0 o0 tenantsM+++++7as%oe Le'al Ser/($es EJe$&t(/e F(re$tor Pa&l El$ano %as
reportedly $all Fr+ Co&'%l(n (n an attempt to (n0l&en$e attorney Co&'%l(n to $lose t%e $ase Co&'%l(n
%as a'a(nst 7LS 0or wron'0&l term(nat(on+
Cts a 'ood t%(n' Ge/ada %as so many )ra/e 3(rst Amendment attorneyMs l(.e DM Fe/oy and %(s
asso$(ate Mar$ Randa--a, ne(t%er o0 w%om %a/e any asso$(at(on w(t% Mr+ Co&'%l(n+ C, Mr+ Co&'%l(n
am aware t%at (t (s sl('%tly aw.ward to wr(te t%(s sw(t$%(n' )etween t%e 0(rst and t%(rd person, %owe/er,
t%e eJ('en$(es and e$onom($s o0 solo law pra$t($e were at play (n do(n' so+
At least t%ere (snMt m&$% o0 a so$(etal $ost to t%e le'ally N&est(ona)le manner (n w%($% e/($t(ons are
de$(ded and $arr(ed o&t (n 7as%oe Co&nty4
%ttp4//www+yo&t&)e+$om/wat$%?/QssE237:3GEO
%ttp4//www+yo&t&)e+$om/wat$%?/QK,GaE,slr8
7ell, Mr+ Loom(s, t%(n.s my ar'&ments a)o&t t%e (ns&00($(en$y o0 ser/($e o0 t%e S&mmary E/($t(on
OrderMs (s P0r(/olo&sP, )&t, %ey, %e (s ,&st 'ett(n' pa(d to -ealo&sly ad/o$ate on my )e%al0, so++++
And ,&st )e$a&se =ar Co&nsel Patr($. K(n', EsN+, 0eels t%e 're(/an$es C 0(led are not wort% p&rs&(n'
w%ereas t%ose 0(led )y R($%ard G+ :(ll, EsN+ are de0(nately wort%y o0 lots and lots o0 0ollow &p 5e/en
w%ere %e la$.s stand(n' to so 0(le or (s o00er(n' only &nattr()&ted %earsay (n s&pport o0 %(s $ontent(ons,
et$+6 does not mean =ar Co&nsel Patr($. K(n' (s a$t(n' as an atta$. do' 0or t%e r($%, t%at wo&ld not )e
an a$$&rate statement, (n all l(.el(%ood+
S(n$erely,
#a$% Co&'%l(n, EsN+, PO =OH E2I1, REGO, G;, !I12E, tel4 <<1 33! !""!, 0aJ4 I8I EE< <829
#a$%Co&'%l(n*%otma(l+$om Ge/ada =ar Go4 I8<3
Fear Mr+ Co&'%l(n4
T%(s messa'e (s sent to address (ss&es ra(sed (n t%e e@ma(l yo& sent on 3@E@"+
"+ Please note t%at yo& are 0ree to send t%e $omm&n($at(ons yo& send to me, to anyone else yo& des(re+
Oo& s%o&ld )e aware t%at send(n' yo&r $omm&n($at(ons to ot%er part(es w(ll $a&se yo&r
$omm&n($at(ons to me to lose t%e(r attorney@$l(ent $on0(dent(al(ty+
+ 3or w%at spe$(0($ p&rposes do yo& need a $ont(n&an$e? A $ont(n&an$e p&rely 0or t%e p&rpose o0
delay (s not a proper reason 0or a $ont(n&an$e+
3+ 7%et%er yo& are ent(tled to e@ma(l t%e Reno M&n($(pal Co&rt (s not my $on$ern+ T%at (s a pro)lem to
E/"
)e addressed )etween yo& and t%e Co&rt+
8+ Ms+ Fra.e (s no lon'er t%e attorney %andl(n' yo&r $ase 0or t%e Reno C(ty AttorneySs O00($e+ Oo&r
$ase (s now )e(n' %andled )y C%r(stop%er :a-lett@Ste/ens, EsN+
1+ Cn response to yo&r N&est(on re'ard(n' t%e wea.nesses o0 t%e trespass(n' $ase C o00er t%e 0ollow(n'4
a+ T%e $ompla(nt (s de0($(ent (n t%at (0 0a(ls to set 0ort% t%e elements o0 t%e $r(me o0 trespass+ Ct 0a(ls to
(dent(0y w%et%er yo&r presen$e on t%e prem(ses was 0or t%e p&rpose to /eJ or annoy t%e owner or
o$$&pant o0 t%e prem(ses or w%et%er (t was an entry onto t%e prem(ses a0ter a warn(n' not to so
trespass+ T%(s (s pro)a)ly eas(ly remed(ed )y an amendment at t%e t(me o0 tr(al+ Ge/ert%eless t%ese are
alternat(/e t%eor(es on w%($% a trespass $ase $an )e p&rs&ed and t%e de0endant (s ent(tled to .now on
w%($% t%eory or t%eor(es a $ase (s )e(n' prose$&ted (n ad/an$e o0 s%ow(n' &p 0or tr(al+
)+ Oo& 0(led an appeal on O$to)er "I, 2"", apparently, o0 t%e order made )y D&st($e o0 t%e Pea$e
S0erra--a on O$to)er "3, 2""+ T%at order den(ed yo&r reN&est 0or a $ont(n&an$e and 'ranted s&mmary
e/($t(on &nless yo& 0(led a depos(t w(t% t%e $o&rt+ Typ($ally t%e $o&rts lose ,&r(sd($t(on to r&le on ot%er
matters (n t%e $ase on$e an appeal (s ta.en+ Ct (s $lear 0rom t%e $o&rt re$ords t%at t%(s appeal was
pend(n' )e0ore t%e Se$ond D&d($(al F(str($t Co&rt at t%e t(me t%e $o&rt %eld a %ear(n' on t%e &nlaw0&l
deta(ner on O$to)er 1, 2""+ Ct may well )e t%at t%e D&st($e Co&rt lost ,&r(sd($t(on to %old t%e e/($t(on
%ear(n' w%(le t%e appeal was pend(n'+
$+ C am wor.(n' on some ot%er t%o&'%ts+
E+ C0 yo& are d(ssat(s0(ed w(t% t%e way C am represent(n' yo&, yo& rema(n 0ree to see. a new attorney+
<+ Anot%er $%&$.le re'ard(n' my owners%(p o0 str(p $l&)s+ C donSt own or %a/e any owners%(p (nterest
(n any str(p $l&)s, )rot%els, ad&lt )oo. stores or mo/(e %o&ses+ C '&ess t%at lea/es me 0ree to moral(-e+
!+ C st(ll donSt see t%e (mportan$e o0 Fr+ Merl(ss+ T%e reN&est 0or payment o0 an amo&nt eN&al to rent,
was 0or stora'e o0 yo&r personal property+ Oo& are ent(tled to $ontest t%e amo&nt o0 t%e stora'e 0ee,
w%($% yo& d(d+ T%ere (s no $red()le e/(den$e anyw%ere w%($% s&''ests t%at anyone (ntended to reopen
or $reate a new tenan$y allow(n' yo& to reta(n possess(on o0 t%e prem(ses+
I+ Fr+ Merl(ss (s an o&t o0 state w(tness+ Cn order to $ompel %(s appearan$e, %(s test(mony m&st )e
mater(al+ GRS "<8+815"6+ Ct does not appear t%at %(s test(mony (s mater(al &nder t%e (n0ormat(on yo&
%a/e pro/(ded 3&rt%er, &nder GRS "<8+8156 %e (s ent(tled to )e pa(d %(s s&)s(sten$e and tra/el
eJpenses (n$&rred (n $om(n' to Ge/ada+ Are yo& prepared to pay t%ose eJpenses (n ad/an$e o0 %(s
$om(n' to Ge/ada?
"2+ C donSt (ntend to 0aJ or e@ma(l to yo&, yo&r 0&ll 0(le (n t%(s $ase+ Oo& already %a/e e/eryt%(n' w(t%
t%e eJ$ept(on o0 a $o&ple o0 (tems w%($% C ma(led to yo&r old address+ C w(ll send t%em a'a(n to yo&r
new address+ C0 yo& want to re/(ew t%e 0(le yo& are wel$ome to do so at my o00($e+ C0 yo& want $op(es
o0 anyt%(n' (n t%e 0(le yo& may mar. t%e (tems+ A0ter '(/(n' yo& a $ost est(mate, 0or w%($% C reN&(re
payment (n ad/an$e, we w(ll pro/(de yo& w(t% $op(es o0 t%e mar.ed (tems+
Ke(t% Loom(s
3rom4 #a$% Co&'%l(n Tma(lto4-a$%$o&'%l(n*%otma(l+$omU
Sent4 Monday, Mar$% E, 2" "2433 PM
To4 .e(t%loom(s*eart%l(n.+net9 sterm(t-*s)$'lo)al+net9 ,md*randa--a+$om9 ,)oles*$allat'+$om9
.r(st(emann(n'*ya%oo+$om9 .adl($,*reno+'o/
S&),e$t4 ( was e/($ted 3 "1 ", ( need a $ont(n&an$e
Fear Mr+ Loom(s,
C was wron'0&lly e/($ted on 3 "1 ", and C need a $ont(n&an$e (n t%e $r(m(nal trespass matter t%at yo&
set o/erly N&($.ly a'a(nst my eJpress w(s%es anyway+ My a)(l(ty to $olle$t e/(den$e ne$essary to my
de0ense and ot%erw(se prepare %as )een ad/ersely a00e$ted+ Add(t(onally, C donMt 0eel as t%o&'% yo& are
per0orm(n' (n an appropr(ate manner as de0ense $o&nsel, )&t rat%er yo& seem st&$. (n yo&r
prose$&tor(al ways, too N&($. to loo. 0or any eJ$&se w%atsoe/er to )&ry oneMs $ase, so C t%(n. yo& %a/e
</"
0or$ed a spl(t %ere, w%($% 0&rt%er pre,&d($es my $ase and a&'ers towards a $ont(n&an$e+ Please mo/e
0or one (mmed(ately and $opy me on my ent(re 0(le )y ema(l and 0aJ please+ Add(t(onally, please see.
$lar(0($at(on 0rom t%e RMC as to w%et%er C am allowed to e/er send an ema(l to
renom&n($re$ords*reno+'o/+ Please note, today, D&d'e 3lana'an den(ed R($%ard :(llMs latest 0r(/olo&s
mot(on+
F(d yo& .now t%at Ke/(n Kelly, o0 t%e State =ar o0 Ge/adaMs C%ara$ter and 3(tness Comm(ttee 0or at
least t%e last de$ade owns and r&ns t%e Spearm(nt R%(no str(p $l&) (n Las ;e'as4
%ttp4//www+re/(ew,o&rnal+$om/l/r,L%ome/22/Mar@2E@7ed@22/news/"!8"81+%tml
C .now C always l(.e my t%ree %o&r to&rs o0 %ea/y %anded moral(-(n' 0rom someone w%o r&ns a
monol(t%($ str(p $l&) (n Las ;e'as+
Oo& are on t%e State =ar o0 Ge/adaMs 0ee d(sp&te $omm(ttee, arenMt yo& Mr+ Loom(s? Fo yo& own any
str(p $l&)s?
Mr+ Loom(s, w%($% o0 t%e elements o0 t%e trespass $%ar'e RMC !+"2+282 do yo& 0eel are wea.est 0or
Fep&ty C(ty Attorney D(ll Fra.e, w%om C (n0ormed a)o&t t%e adm(ss(on )y Reno PF O00($er C%r(s
Carter t%at R($%ard G+ :(ll, EsN+ )r()es %(m, )&t 0or w%($% Ms+ Fra.e (nd($ated a $omplete la$. o0
(nterest and eJpressed t%at s%e wo&ld not )e 0ollow(n' &p on t%at report o0 )r()ery o0 a RPF O00($er+
Mr+ Kadl($, please pla$e a $opy o0 t%(s $orresponden$e (n D(ll Fra.eMs personnel 0(le+ Add(t(onally
please pla$e one (n All(son OrmaasMs personnel and employment 0(le too, (n add(t(on to Fep&ty C(ty
Attorney Fan 7on'Ms employment 0(le, as all t%ree o0 t%ose Fep&ty C(ty AttorneyMs were pro/(ded t%at
report and all t%ree (nd($ated t%ey d(d not $are and %ad no (ntent(on o0 0ollow(n' &p or ot%erw(se
(n/est('at(n' t%e adm(ss(on )y RPF O00($er C%r(s Carter t%at R($%ard G+ :(ll, EsN+ )r()ed %(m+ C t%(n.
t%e 0a(l&re to 0ollow &p )y any o0 t%ese 3 Fep&ty C(ty AttorneyMs relates to any 0&t&re ne'l('ent %(r(n',
tra(n(n', and s&per/(s(on $la(ms t%at t%e Reno C(ty Attorney may need to de0end a'a(nst w%en
represent(n' t%e Reno PF l(.e (t d(d (n t%e Eeo0 /+ P(tsno'le $ase4
%ttp4//www+l/r,+$om/news/reno@o00($(al@a$$&sed@o0@w(tness@tamper(n'@""E1!E1!+%tml
Oo& .now, Fep&ty C(ty Attorney OrmaasMs de$(s(on to p&s% on 0or t%at V<2 tra00($ t($.et (s loo.(n'
more and more (nterest(n'+ BB
O%, and, Mr+ Loom(s, Fr+ Merl(ss presen$e (s ne$essary )e$a&se %(s &nderstand(n' o0 t%e eJtent to
w%($% %(s attorney, R($%ard G+ :(ll, EsN+ %ad e00e$t(/ely res$(nded any e/($t(on Order )y send(n' a )(ll
0or t%e same amo&nt as 0&ll &se and o$$&pany o0 t%e lo$at(on at "" R(/er Ro$. St+ 'oes to t%e
s&)stan$e o0 t%e elements 0o&nd (n RMC !+"2+282 as well as t%e $red()(l(ty o0 )ot% Merl(ss and :(ll+
S(n$erely,
Close Pr(nt
3&ll /(ew
W
W
=a$. to messa'es
RE4 rm$ "" $r E821 yo& are appo(nted $o&nsel? 0or p&entes ne ta(tel??
/</"
Ke(t% Loom(s
To M#a$% Co&'%l(nM
3rom4 Ke(t% Loom(s 5.e(t%loom(s*eart%l(n.+net6
Sent4 Mon /</" 34< PM
!/"
To4 M#a$% Co&'%l(nM 5-a$%$o&'%l(n*%otma(l+$om6
Mr+ Co&'%l(n4
E@ma(l wor.s well 0or me+
Ke(t% Loom(s
Sent4 Monday, 3e)r&ary <, 2" <41E AM
To4 .e(t%loom(s*eart%l(n.+net
S&),e$t4 rm$ "" $r E821 yo& are appo(nted $o&nsel? 0or p&entes ne ta(tel?
%(, ( '&ess Mr+ Loom(s was appo(nted as my 3rd de0ense attorney (n RMC $ase "" $r E821+ C %a/e not
%eard anyt%(n' a)o&t t%(s $ase, and t%e RMC (nd($ated t%ey %ad not%(n' s$%ed&led+ Please
$omm&n($ate w(t% me only /(a ema(l or 0aJ please, %a/(n' (ss&es w(t% my ma(l (n$(dent to domest($
/(olen$e $omm(tted a'a(nst me my 0aJ (s I8I EE< <82+ t%an.s,
#a$% Co&'%l(n
3&ll /(ew
W
W
=a$. to messa'es
$o&rt date?
3/21/"
Ke(t% Loom(s
To M#a$% Co&'%l(nM
Sent4 Mon 3/21/" 842I PM
Mr+ Co&'%l(n4
C %a/e reN&ested t%at $o&rt set yo&r trespass $ase 0or tr(al (n a)o&t 32 days+ C w(ll let yo& .now t%e date
and t(me as soon as C .now+
Ke(t% Loom(s
3&ll /(ew
W
W
=a$. to messa'es
RE4 $o&rt date?
3/2</"
Ke(t% Loom(s
To -a$%$o&'%l(n*%otma(l+$om
Sent4 7ed 3/2</" 843E PM
To4 -a$%$o&'%l(n*%otma(l+$om
Mr+ Co&'%l(n4
On w%at 'ro&nds, ot%er t%an t%ose already set 0ort% (n yo&r eJ(st(n' mot(on, do yo& )el(e/e a mot(on to
d(sm(ss s%o&ld )e 0(led?
Ke(t% Loom(s
Sent4 7ednesday, Mar$% 2<, 2" "481 AM
S&),e$t4 RE4 $o&rt date
I/"
Mr+ Loom(s,
Please $opy me on any and all $orresponden$es, 0(l(n', or ot%er do$&mentat(on or /er)al reN&ests,
$orresponden$es, et$+ t%at yo& s&)m(t to t%e Co&rt, (n$l&d(n' t%e one yo& re0eren$e )elow+ Please do
not 0ollow Ta(telMs ta$t o0 a'ree(n' to reN&ests or 0a(l(n' to oppose mot(ons w(t%o&t e/en attempt(n' to
o)ta(n my perm(ss(on to (n ad/an$e t%ereo0+
C wo&ld l(.e 0or yo& to dra0t a Mot(on to F(sm(ss (n t%(s $ase 0or me re/(ew+
T%an.s,
#a$% Co&'%l(n, EsN+, "8 E+ It% St+ A, REGO, G; !I1", tel4 <<1 33! !""!, 0aJ4 I8I EE< <829
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
3rom4 .e(t%loom(s*eart%l(n.+net
S&),e$t4 $o&rt date
Fate4 Mon, 1 Mar 2" "E42I4"I @2!22
Mr+ Co&'%l(n4
Ke(t% Loom(s
3&ll /(ew
W
W
=a$. to messa'es
RE4 $o&rt date?
3/2I/"
Ke(t% Loom(s
Sent4 3r( 3/2I/" "24"8 AM
Go worr(es+ Made me la&'%+
Co&ple o0 N&est(ons4
F(d yo& 0(le an appeal 0rom D&st($e o0 t%e Pea$e S0erra--aSs e/($t(on order?
C0 yes, %as (t )een resol/ed?
F(d S0erra--a anno&n$e at t%e $lose o0 t%e %ear(n' on t%e 1t% t%at %e was 'rant(n' t%e e/($t(on and as.
:(ll/=a.er to pro/(de a wr(tten order?
F(d yo& e/er see t%e e/($t(on order posted )y 7CSO
C0 yes, w%en?
7%at (s rele/an$e o0 personnel 0(les o0 Carter or Lope-?
:ow (s Fr+ Merl(ssS test(mony mater(al to t%e de0ense o0 t%(s $ase?
Ke(t% Loom(s
Sent4 T%&rsday, Mar$% 2!, 2" "48E AM
Fear Mr+ Loom(s,
C apolo'(-e S(r 0or w%at C am s&re $omes a$ross as r&deness on my part+ Oo& seem l(.e a 'ood '&y, and
yo& %a/e 'reat %a(r+ C s(mply donMt %a/e t(me, money or ener'y to do any o0 t%(s t%e pol(te way '(/en
"2/"
t%e P&n(N&enessP o0 t%(s s(t&at(on++++Please ,&st .now C mean yo& no d(srespe$t+
7o&ld yo& please 0(le a reN&est or Mot(on 0or t%e Personnel 3(le o0 RPF O00($er C%r(s Carter and
Sar'ent Mon($a Lope- as well as s&p)oena 0rom t%e RPF all t%e /ol&mns o0 $rap R($%ard :(ll %as
'(/en t%em on t%(s (n add(t(on to not($(n' t%e $o&rt and C(ty Atty as to R($%ard :Cll )e(n' a w(tness,
s&)poena %(m 5t%o&'% t%e earl(er $ont(n&an$e wo&ld appear to (mply %e already (s6 AGF SU=POEGA
T:E OLF CALC3ORGCA GEUROSURGEOG 7:O CAG GET :CS OUT FO7G :ERE 3OR T:E
TRCAL AGF A FEPOSCTCOG PRCOR T:ERETO, ETSPECCALLO COGSCFERCGG T:AT T:E
;ARCOUS POLCCE REPORTS AGF MOTCOGS 3OR ORFERS TO S:O7 CAUSE QUOTE
MERLCSS AS SAOCGG :E 7AS AT T:E PROPERTO CG T:E P7EEKS PRECEEFCGGP T:E
ARREST, ETC+, ETC+ 5T:E STU33 =O==O PUEGTES GOT OOU 7:EG :E COPCEF OOU MO
3CLE, CE MO 3AHES TO =O==O, SET T:CS OUT CLEARLO6+ (3 T:ESE 3OOLS 7AGT TO
:A;E ME ARREST AGF ATTEMPT TO RUG A TRACG OG ME, T:EG T:EO CAG PUT T:E
TCME AGF 7ORK CG AGF GOT P:OGE CT CG 3ROM CALC AGF :A;E T:ECR REGT@A@
LOCAG rCC:ARF :CLL FO CT+
ALSO PLEASE 3CLE A MOTCOG TO d(sm(ss )ased &pon den(al o0 r('%t to a speedy tr(al, spol(at(on
o0 e/(den$e, et$++++
PEACE
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
3&ll /(ew
W
W
=a$. to messa'es
Tr(al Fate?
3/2I/"
Ke(t% Loom(s
Sent4 3r( 3/2I/" "2488 AM
" atta$%ment
Co&'%l(n Tr(al Sett(n'+pd0 5<<"+! K=6
See atta$%ed
3&ll /(ew
W
W
=a$. to messa'es
RE4 Tr(al Fate?
3/"/"
Ke(t% Loom(s
Sent4 Mon 3/"/" I4E AM
C $an do t%at (0 t%ere (s a 'ood reason to /a$ate t%e date+ 7%at (s t%e reason?
Ke(t%
""/"
Sent4 3r(day, Mar$% 2I, 2" E4! PM
S&),e$t4 RE4 Tr(al Fate
Please 0(le somet%(n' w(t% t%e $o&rt see.(n' to /a$ate t%at tr(al date and eJpla(n(n' t%at yo& 0a(led to
e/en on$e $ons&lt w(t% yo&r $l(ent pr(or to sett(n' (t+
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
S&),e$t4 Tr(al Fate
Fate4 3r(, I Mar 2" "24884"< @2!22
See atta$%ed
3&ll /(ew
W
W
=a$. to messa'es
RE4 $o&rt date?
3/"/"
Ke(t% Loom(s
Sent4 Mon 3/"/" "242 AM
T%(s e@ma(l (s sent to address t%e 'ro&nds yo& (dent(0(ed as 0orm(n' t%e )as(s o0 a mot(on to d(sm(ss+ As
yo& .now t%ere (s )ot% a $onst(t&t(onal r('%t and a stat&tory r('%t to a speedy tr(al+ T%(s $ase (s now%ere
$lose to a /(olat(on o0 t%e $onst(t&t(onal r('%t to a speedy tr(al+ T%e stat&te does pro/(de 0or a r('%t to
tr(al w(t%(n E2 days o0 arra('nment (n m&n($(pal $o&rt+ GRS "<!+11E56+ Cn t%(s $(r$&mstan$e t%e $o&rt
XmayY d(sm(ss t%e $ompla(nt+ T%e stat&te reN&(res, %owe/er, t%at t%e tr(al not %a/e )een postponed at
t%e reN&est o0 t%e de0endant+ Ct (s my &nderstand(n' t%at t%e Dan&ary "2, 2", tr(al date, was postponed
at yo&r reN&est+ C0 t%at (s tr&e t%en t%ere are not 'ro&nds to d(sm(ss on t%e )as(s o0 a /(olat(on o0 a r('%t
to speedy tr(al+
F(sm(ssal )ased on spol(at(on (s a $(/(l $on$ept+ Ct %as not )een appl(ed to $r(m(nal $ases (n Ge/ada as
o0 yet+ See :(''s /+ State, "E Ge/+ Ad/+ Opn " 52"26+ Rat%er de0endants (n $r(m(nal $ases are
prote$ted 0rom t%e loss o0 e/(den$e (n t%e %ands o0 t%e prose$&t(on )y t%e do$tr(ne o0 d&e pro$ess+
ConseN&ently yo& m('%t %a/e a )as(s to reN&est d(sm(ssal (0 t%e C(ty AttorneySs O00($e lost e/(den$e, (n
(ts possess(on mater(al to t%e $ase+ Cn s&$% $ase (0 t%e C(ty a$ted (n )ad 0a(t% or w(t% $onn(/an$e or (0
yo& were pre,&d($ed )y t%e loss t%en t%ere may )e 'ro&nds on w%($% to )ase a d(sm(ssal+ Please ad/(se
as to w%at e/(den$e was lost and %ow (t was lost+
Oo& %a/e not (dent(0(ed any ot%er 'ro&nds as a )as(s 0or d(sm(ssal+ C0 yo& )el(e/e t%ere are ot%er
'ro&nds, let me .now+
T%an.s
Ke(t% Loom(s
Sent4 T%&rsday, Mar$% 2!, 2" "48E AM
"/"
Fear Mr+ Loom(s,
C apolo'(-e S(r 0or w%at C am s&re $omes a$ross as r&deness on my part+ Oo& seem l(.e a 'ood '&y, and
yo& %a/e 'reat %a(r+ C s(mply donMt %a/e t(me, money or ener'y to do any o0 t%(s t%e pol(te way '(/en
t%e P&n(N&enessP o0 t%(s s(t&at(on++++Please ,&st .now C mean yo& no d(srespe$t+
7o&ld yo& please 0(le a reN&est or Mot(on 0or t%e Personnel 3(le o0 RPF O00($er C%r(s Carter and
Sar'ent Mon($a Lope- as well as s&p)oena 0rom t%e RPF all t%e /ol&mns o0 $rap R($%ard :(ll %as
'(/en t%em on t%(s (n add(t(on to not($(n' t%e $o&rt and C(ty Atty as to R($%ard :Cll )e(n' a w(tness,
s&)poena %(m 5t%o&'% t%e earl(er $ont(n&an$e wo&ld appear to (mply %e already (s6 AGF SU=POEGA
T:E OLF CALC3ORGCA GEUROSURGEOG 7:O CAG GET :CS OUT FO7G :ERE 3OR T:E
TRCAL AGF A FEPOSCTCOG PRCOR T:ERETO, ETSPECCALLO COGSCFERCGG T:AT T:E
;ARCOUS POLCCE REPORTS AGF MOTCOGS 3OR ORFERS TO S:O7 CAUSE QUOTE
MERLCSS AS SAOCGG :E 7AS AT T:E PROPERTO CG T:E P7EEKS PRECEEFCGGP T:E
ARREST, ETC+, ETC+ 5T:E STU33 =O==O PUEGTES GOT OOU 7:EG :E COPCEF OOU MO
3CLE, CE MO 3AHES TO =O==O, SET T:CS OUT CLEARLO6+ (3 T:ESE 3OOLS 7AGT TO
:A;E ME ARREST AGF ATTEMPT TO RUG A TRACG OG ME, T:EG T:EO CAG PUT T:E
TCME AGF 7ORK CG AGF GOT P:OGE CT CG 3ROM CALC AGF :A;E T:ECR REGT@A@
LOCAG rCC:ARF :CLL FO CT+
ALSO PLEASE 3CLE A MOTCOG TO d(sm(ss )ased &pon den(al o0 r('%t to a speedy tr(al, spol(at(on
o0 e/(den$e, et$++++
PEACE
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
RE4 Tr(al Fate?
3/"8/"
Ke(t% Loom(s
Sent4 7ed 3/"8/" 431 PM
Fear Mr+ Co&'%l(n4
My o)l('at(on &nder Ge/ada R&le o0 Pro0ess(onal Cond&$t "+ (s to a)(de )y a $l(entSs de$(s(on
$on$ern(n' t%e o),e$t(/es o0 representat(on and, as reN&(red )y R&le "+8 to $ons&lt w(t% t%e $l(ent as to
t%e means )y w%($% t%e o),e$t(/es o0 representat(on are to )e p&rs&ed+ Z Cn a $r(m(nal $ase t%e lawyer
s%all a)(de )y t%e $l(ents de$(s(on, a0ter $ons&ltat(on w(t% t%e lawyer, as to plea to )e entered, w%et%er
to wa(/e ,&ry tr(al w%et%er t%e $l(ent w(ll test(0y+
Under R&le "+8 5a6516 a lawyer s%all $ons&lt w(t% t%e $l(ent a)o&t any rele/ant l(m(tat(ons on t%e
lawyers $ond&$t w%en t%e lawyer .nows t%at t%e $l(ent eJpe$ts ass(stan$e not perm(tted )y t%e R&les o0
Pro0ess(onal Cond&$t or ot%er law+
Under R&le +"+ Cn represent(n' a $l(ent, a lawyer s%all eJer$(se (ndependent pro0ess(onal ,&d'ment and
render $and(d ad/($e+ Cn render(n' ad/($e, a lawyer may re0er not only to law )&t to ot%er
$ons(derat(ons s&$% as moral e$onom($, so$(al and pol(t($al 0a$tors, t%at may )e rele/ant to t%e $l(entSs
s(t&at(on+
Under R&le 3+"+ A lawyer s%all not )r(n' or de0end a pro$eed(n', or assert or $ontro/ert an (ss&e
t%ere(n, &nless t%ere (s a )as(s (n law and 0a$t 0or do(n' so t%at (s not 0r(/olo&s, w%($% (n$l&des a 'ood
0a(t% ar'&ment 0or an eJtens(on, mod(0($at(on or re/ersal o0 eJ(st(n' law+ A lawyer 0or a de0endant (n a
"3/"
$r(m(nal pro$eed(n' t%at $o&ld res&lt (n (n$ar$erat(on, may ne/ert%eless so de0end t%e pro$eed(n' as to
reN&(re t%at e/ery element o0 t%e $ase )e esta)l(s%ed+
Under R&le 3+5a6 and 5)6+ A lawyer s%all ma.e reasona)le e00orts to eJped(te l(t('at(on $ons(stent w(t%
t%e (nterests o0 t%e $l(ent+
T%e d&ty stated (n para'rap% 5a6 does not pre$l&de a lawyer 0rom 'rant(n' a reasona)le reN&est 0rom
oppos(n' $o&nsel 0or an a$$ommodat(on, s&$% as an eJtens(on o0 t(me, or 0rom d(sa'ree(n' w(t% a
$l(entSs w(s%es on adm(n(strat(/e and ta$t($al matters, s&$% as s$%ed&l(n' depos(t(ons, t%e n&m)er o0
depos(t(ons to )e ta.en, and t%e 0reN&en$y and &se o0 wr(tten d(s$o/ery reN&ests+
Under R&le !+85d6 Ct (s m(s$ond&$t 0or a lawyer to en'a'e (n $ond&$t w%($% (s pre,&d($(al to t%e
adm(n(strat(on o0 ,&st($e+
T%ese, and ot%ers, are t%e pro0ess(onal r&les C operate &nder (n pro/(d(n' le'al representat(on to yo& (n
$ase n&m)er "" CR E821, a $ase (n w%($% yo& are $%ar'ed w(t% t%e $r(me o0 trespass+ Ct (s my
&nderstand(n' t%at yo&r o),e$t(/e (n t%(s $r(m(nal $ase (s t%at yo& )e a$N&(tted o0 t%e $r(me o0 trespass+
T%at (s my p&rpose (n represent(n' yo&+ C am %appy to wor. towards t%at o&t$ome to t%e )est o0 my
a)(l(ty+ Ct (s my op(n(on, %owe/er, t%at m&$% o0 w%at yo& as. to )e done (s not (n $ompl(an$e w(t% t%e
a)o/e r&les+ A$$ord(n'ly, C w(ll not )e 0(l(n' a mot(on to d(sm(ss )ased &pon GRCP E5a6 and 5)6, C see
t%at ar'&ment as 0r(/olo&s+ C w(ll not )e pro$eed(n' w(t% t%e s&mmon(n' o0 an o&t@o0@state w(tness
5Merl(ss6 &nless yo& $an esta)l(s% %(s mater(al(ty to t%e de0ense+ Gor w(ll C )e s&)poena(n' t%e
personnel re$ords o0 law en0or$ement personnel &nless yo& $an esta)l(s% to my sat(s0a$t(on w%y t%ey
are rele/ant to t%(s $ase+ C %a/e no (ntent(on at t%(s t(me o0 $ond&$t(n' any depos(t(ons (n t%e $ase or
send(n' reN&ests 0or prod&$t(on o0 do$&ments or (nterro'ator(es (n t%e $ase+ C see t%ese a$t(ons as
&nd&ly )&rdensome on t%e ,&d($(al system, and &nwarranted )y anyt%(n' yo& %a/e pro/(ded to t%(s
po(nt+ C also see t%em as 0r(/olo&s and an attempt to &t(l(-e t%e $r(m(nal ,&st($e system to a$$ompl(s%
o),e$t(/es not rele/ant to my p&rpose (n represent(n' yo&+
C0 yo& are d(ssat(s0(ed w(t% t%e l(m(tat(ons C per$e(/e to eJ(st re'ard(n' my representat(on o0 yo&, yo&
are wel$ome to term(nate my representat(on o0 yo&+ Oo& may t%en as. t%e Co&rt to appo(nt a new
lawyer to represent yo&+
Ct (s my &nderstand(n' t%at Fep&ty Ma$%em w(ll )e test(0y(n' (n t%e $ase alon' w(t% R($%ard :(ll and
Casey =a.er+
C do t%(n. t%at t%ere are some (nterest(n' an'les to t%e $ase &pon w%($% a de0ense $an )e )ased and C
w(ll )e p&rs&(n' t%ose an'les+ C %a/e as.ed yo& (n pre/(o&s e@ma(ls to pro/(de (n0ormat(on w%($% C
)el(e/e w(ll )e %elp0&l to t%e de0ense o0 yo&r $ase+
C ad/(se yo& t%at t%e C(ty %as o00ered to re$ommend t(me@ser/ed as a senten$e (0 yo& enter a no@$ontest
plea to trespass+ Ct (s also my &nderstand(n' t%at yo& %a/e ot%er $r(m(nal $ases pend(n' (n )ot% Reno
D&st($e Co&rt and (n t%e Se$ond D&d($(al F(str($t Co&rt o0 t%e State o0 Ge/ada+ Ct (s my &nderstand(n'
0&rt%er t%at all o0 t%e $r(m(nal $ases $an )e resol/ed (n a s(n'le plea to a m(sdemeanor o00ense (0 yo&
w(ll o)ta(n psy$%olo'($al $o&nsel(n'+ Ct (s my o)l('at(on to (n0orm yo& o0 t%e a/a(la)(l(ty o0 t%ese
resol&t(ons to t%e present $r(m(nal $ase (n w%($% C pro/(de representat(on+ C w(ll, o0 $o&rse, a)(de )y
yo&r de$(s(on as to w%et%er to a$$ept t%ese resol&t(ons or not+
C note t%at t%ere (s a psy$%(atr($ e/al&at(on s$%ed&led 0or yo& (n nd D&d($(al F(str($t Co&rt Case Go+
CR"@23<E on Apr(l 3, 2"+ T%e o&t$ome o0 t%at e/al&at(on $o&ld %a/e an (mportant (mpa$t on t%(s
$ase+ C am as.(n' t%at yo& a&t%or(-e a release o0 t%e (n0ormat(on $onta(ned (n t%e e/al&at(on to me so
t%at C may determ(ne w%at (mpa$t (t $o&ld %a/e on yo&r )e%al0 (n t%(s $ase+
C rema(n prepared to represent yo& (n t%e trespass $ase+ C t%(n. t%at a tr(al o0 t%e $ase w(ll )e (nterest(n'+
My representat(on, %owe/er, (s $(r$&ms$r()ed )y t%e Ge/ada R&les o0 Pro0ess(onal Cond&$t+
Ke(t% Loom(s
"8/"
Sent4 T&esday, Mar$% "3, 2" 84I PM
Fear Mr+ Loom(s,
Cn yo&r mot(on to d(sm(ss, C wo&ld l(.e yo& to really 0o$&s on and set 0ort% to t%e $o&rt t%e 0a$t t%at t%e
e/($t(on order needed to )e ser/ed (n $ompl(an$e w(t% GRCP E5a6 and E5e6+ GRS 82+822 R&les o0
pra$t($e+ T%e pro/(s(ons o0 GRS, Ge/ada R&les o0 C(/(l Pro$ed&re and Ge/ada R&les o0 Appellate
Pro$ed&re relat(/e to $(/(l a$t(ons, appeals and new tr(als, so 0ar as t%ey are not (n$ons(stent w(t% t%e
pro/(s(ons o0 GRS 82+2 to 82+82, (n$l&s(/e, apply to t%e pro$eed(n's ment(oned (n t%ose se$t(ons+
T%e lan'&a'e a)o&t Premo/(n' t%e tenant w(t% (n 8 %o&rs o0 re$e(pt o0 t%e orderP (s only appl($a)le to
t%ose s(t&at(ons w%ere t%e tenant does not 0(le a TenantMs Answer or TenantMs A00(da/(t+ C d(d 0(le s&$% a
TenanMts A00(da/(t, and l(t('ated t%e matter t%oro&'%ly+ Cn t%ose s(t&at(ons, GRS 82+822 reN&(res GRCP
to apply, spe$(0($ally GRCP E5a6 and E5e6, and $learly 7CSO Ma$%em 5please s&)poena and (dent(0y
as w(tnesses Mary Kandaras, EsN+ o0 t%e 7CFA C(/(l F(s/(s(on, 7CSO Fep&ty Ma$%em, and 7CSO
C(/(l F(/(s(on s&per/(sor L(- St&$%ell 0or t%e tr(al (n t%(s matter, and 0&rt%er send o&t a reN&est 0or
prod&$t(on and s&)poena d&$es te$&m to t%e 7CFA and t%e 7CSO as.('n t%em to spe$(0y, (n wr(t(n'
and (n deta(l, t%e eJa$t pro$ed&res and pol($(es (n pla$e w(t% respe$t to t%e ser/($e and $ond&$t(n' o0
s&$% lo$.o&ts 5(e, not de0a&lt lo$.o&ts w%ere t%ere (s not a s&mmary e/($t(on %ear(n', )&t oneMs l(.e t%e
present one, w%ere t%ere was a TenantMs Answer and %ear(n' %eld, et$++++6+ =e s&re to as. w%et%er t%e are
aware o0 w%at Ppersonally ser/edP means, and w%et%er t%ey ma(l t%e Orders on top o0 merely post(n'
t%em to t%e door+ 3&rt%er, C %a/e )een told t%at t%e 7CSO %as a pol($y or penatly system (n pla$e
w%ere)y t%e dep&t(es m&st 'et t%ese lo$.o&ts per0ormed Pw(t%(n 8 %o&rs o0 re$e(pt o0 t%e orderP t%e
re$e(pt )e(n' t%e 7CSOMs re$e(pt, and not t%e tenantMs re$e(pt+ C donMt n$essar(ly read t%e stat&te t%at
way, )&t++++t%e 7CSO pol($y and p&n(s%ment system wo&ld )e at least some (nd($at(on o0 w%at t%e
le'(slat&re meant 5C '&ess, )&t C dontM really t%(n. so, t%o&'%, yo& w(ll note t%at :(ll was le0t w(t%
not%(n' )&t $(t(n' to t%e P&s&al and $&stomary pra$t($e o0 t%e 7CSOP (n ser/(n' t%e E/($t(on ORders
and per0orm('n lo$.o&ts, C )el(e/e, )e$a&se t%e law does not $onta(n m&$% to s&pport :(llMs $ontent(on
and t%ere0ore %e w(s%es to see t%e 7CSO P$&stomary pra$t($esP )e(n' '(/en t%e we('%t o0 law+
Please see some spe$(0($ sele$t(ons atta$%ed 0rom t%e e/($t(on matter+ C .now, C .now, yo& want to
$&rta(l t%e s$ope o0 yo&r representat(on to an (mma$&late de'ree++++)&t :(ll $an $learly )e seen (n %(s
/ar(o&s Mot(on to S%ow Ca&se, State =ar Gr(e/an$es, Temproary Prote$t(on Order Appl($at(ons, et$+,
et$+, to )e a p&n. w%o doesnMt m&$% l(.e $ompet(n' on an e/en play(n' 0(eld, l(.e any 'ood pr(/ate
s$%ooler, %e wo&ld rat%er s($. an atta$. do' on some)ody t%an 'et (n t%e o$to'on and 'o toe to toe
mentally+ Re'ardless, :(ll s%ows a $ont(n&al des(re to s&)/ert GRCP E5e6, w%($% appl(es to ser/($e o0
do$&ments 0(led ele$ron($ally (n t%e Se$ond D&d($(al F(str($t Co&rt+ :e wo&ld rat%er w(t%%old oppos(n'
$o&nsels $omp&ters, laptops, $l(ent 0(les, dr(/erMs l($ense, et$+ T%e last t%(n' %e wants (s to 'o ar'&ment
0or ar'&ment, resear$% 0or resear$%, wr(t(n' 0or wr(t(n'+ Pr(/ate s$%ool and daddyMs plead(n' )an.+ :(ll
0(les a Mot(on to S%ow $a&e alle'e(n' Co&'%l(n s&)/reted an Order t%at was 0(led on Dan&ary ""t%,
2" w(t% Co&'l(nMs a$t(on o0 Dan&ary "t%, 2"+ Under GRCP E5e6, t%e Order Feny(n' t%e TRO %ad
not e/en )een ser/ed yet, and t%ere %as )een no (nd(d$at(on t%at :(ll 'a/e t%e Order at t%e town d&mp
to anyone ot%er t%an an RPF O00($er+
3&rt%er, (t (s not all t%at $lear w%y :(lls Mot(on 0or ORder to S%ow Ca&se deser/es a 0&ll )lown
%ear(n' w%en F< does not (nd($ate a %ear(n' w(ll )e a$$orded to t%e appeal+ T%(s (s part($&larly s&spe$t
'(/en t%at An/&( sets 0ort% t%at appeals (n s&mmary e/($t(on matters are done on a tr(al de no/o )as(s+
T%ere are a n&m)er, )&t %ow a)o&t yo&r $omplete la$. o0 $omm&n($at(on w(t% me pr(or to so sett(n'
t%at date+ :ow a)o&t Mr+ Ta(tel and Mr+ P&entesMs 0a(l&re (n t%(s matter and t%e pre,&d($e to my $ase so
$reated? :ow a)o&t yo&r 0a(l(n' to (dent(0y yo&rsel0 as t%e p&)l($ de0ender to a room 0&ll o0 de0endants
"1/"
(n ,a(l at t%e arra('nment?
T%ere are ot%er reasons as well, (n$l&d(n', )&t not l(m(ted to, yo&r res(stan$e to s&)poena t%e mater(als
C %a/e and am reN&est(n'+
C w(s% 0or yo& to s&)poena t%e personnel 0(les o0 )ot% RPF Sar'ent Mon($a Lope- and O00($er C%r(s
Carter+ C w(s% 0or yo& to l(st Fr+ Merl(ss as a w(tness and s&)poena %(s appearan$e and appropr(ately
not($e t%e C(ty o0 Reno (n t%at re'ard, same 'oes 0or R($%ard :(ll and Casey =a.er 5=a.er, )y letter
dated Go/em)er "2t%, 2"" demands t%e 0&ll rental /al&e 0or t%e property as Pstora'eP &nder GRS
82+13, w%(le also assert(n' %e w(ll 'o a0ter mo/(n' and (n/entory $osts, (n add(t(on to :(llMs $ontra$tor
P%(l Stewarts later r(d($&lo&s $%ar'es and per,&ry+ Please s&)poena Stewart as well+
Most (mportantly s&)poena 7as%oe Co&nty S%er(00Ms O00($e Fep&ty Ma$%em to test(0y and ser/e a
s&)poena d&e$es te$&m, reN&ests 0or prod&$t(on, and (nterro'ator(es see.(n' re$ords and responses
0rom t%e 7CSO as set 0ort% (n t%e letter C sent L(- St&$%ell 5see atta$%ed6 on or a)o&t 3e)r&ary "2t%,
2"+ Oo& see, t%e 7CSO and Fep&ty Ma$%em may )e $omm(tt(n' a 0ra&d &pon t%e p&)l($ )y
repeatedly 0(l(n' a00(da/(ts o0 ser/($e t%at attest to personal ser/($e w%ere L(- St&$%ell, o0 t%e 7CSO
adm(ts t%at t%ey $learly do not .now, or $%oose to Prem(JP t%e le'al mean(n' o0 Ppersonally ser/eP+
3&rt%er, please (n0orm t%e C(ty o0 Reno and appropr(ately not($e t%e same as to t%e eJ(sten$e and (ntent
to o00er (nto e/(den$e a /(deo o0 R($%ard :(ll, EsN+, adm(tt(n' t%at %e and %(s 0(rm, on )e%al0 o0 Fr+
Merl(ss, were w(t%%old(n' t%e a$$&sed personal property, (n add(t(on to t%e $l(entMs 0(les 0rom t%e
0ormer $ommer$(al lease %ome law o00($e o0 t%e a$$&sed and assert(n' a l(en, &nder GRS 82+13 0or
Pstora'eP, %owe/er, as t%e /(deo tape s%ows, :(ll adm(ts to $%ar'(n' t%e &nders('ned t%e same VI22 per
mont% rent as was $%ar'ed 0or t%e P0&ll &se and o$$&pan$yP o0 t%e prem(ses at "" R(/er Ro$. St+,
Reno, G; !I1"+ :(ll 0&rt%er demands t%at property )e remo/ed (n a $erta(n order, re'ardless o0
w%et%er %(s art($(0($ally (n0lated l(en was pa(d or not+ Add(t(onally, :(ll $omm(tted 0ra&d &pon t%e $o&rt
(n a n&m)er o0 (nstan$es and 0(led 0alse pol($e reports w%ere(n %e alle'es t%at %e a'reed to or ot%erw(se
made a/a(la)le to t%e a$$&sed (tems s&$% as t%e a$$&sedMs $l(ents 0(les 5and 0or a t(me wallet and state
(ss&ed dr(/erMs l($ense6 w%ere, $learly, w(t%o&t reN&(r(n' any payment )y t%e a$$&sed, %owe/er, $learly,
t%e 0a$ts s%ow t%at :(ll ne/er a$t&ally l(/ed &p to t%ose assert(ons and repeatedly 0a(led to s%ow
pro/(de s&$% (tems a)sent payment o0 %(s art(0($ally (n0lated l(en+
3&rt%er, C w(s% 0or yo& to d(/&l'e and pro/(de not($e t%at (t (s a/a(la)le 0or p($.&p and t%at we (ntent to
(ntrod&$e (nto e/(den$e a /(deo o0 RPF Sar'ent Mon($a Lope- adm(tt(n' t%at s%e and RPF O00($er
Carter d(d not (dent(0y t%emsel/es as pol($e o00($ers or ot%erw(se as. t%e a$$&sed to lea/e "" R(/er
Ro$. St+ on t%e date o0 t%e arrest pr(or to Merl(ss open(n' t%e door to t%e )asement+ T%(s (s apparently
(n d(re$t $ontrad($t(on to t%e sworn 0(l(n's made )y R($%ard :(ll, EsN+ (n %(s a00(da/(ts atta$%ed to %(s
/ar(o&s Mot(ons to S%ow Ca&se, t%e Reply to Oppos(t(on t%ereto, Oppos(t(on to TRO, et$+, et$+ 5(n RDC
Re/2""@22"<2! and t%e appeal (n C;""@23E!6+ 3or t%at reason alone Merl(ssM presen$e (s reN&(red+
:e was a pre$(p(ent w(tness and yo& are as.(n' me w%y %e s%o&ld )e t%ere? Oo& %a/e a d&ty to
-ealo&sly ad/o$ate on my )e%al0, Mr+ Loom(s+ Oo& are pa(d, )y t%e p&)l($, to do so+ Please d(/&l'e any
pr(or asso$(at(ons yo& %a/e w(t% anyone employed )y or wor.('n as an (ndependent $ontra$tor w(t% t%e
RMC and or t%e Reno C(ty Attorney, (n$l&d(n' anyone yo& went to law s$%ool w(t% or attended t%e
same law s$%ool as, w(t%(n a 1 year per(od+
3&rt%er, C w(s% 0or yo& to 0(le a mot(on see.(n' a m(str(al or ot%erw(se reN&(r(n' t%e re$&sal o0 t%e RMC
and 0&rt%er d(s$los(n' w%y (t (s t%at D&d'e Gardner seem(n'ly %as re$&sed D&d'e F(lwort% 5w%y
wo&ldnMt D&d'e F(lwort% re$&se D&d'e F(lwort%?6 (n one $ase, w(t%o&t deta(l(n' w%y eJa$tly, w%(le
D&d'e Gardner apparently (s (ntent on rema(n(n' on (n "" CR E821, desp(te t%e 0a$t t%at an apparent
$on0l($t eJ(sts, one w%($% %e only d(s$losed &pon prompt(n' 0rom t%e a$$&sed, w(t% respe$t to D&d'e
GardnerMs /ery re$ent employment w(t% t%e Reno C(ty AttorneyMs o00($e and t%e eJ(st(n' and or )rew(n'
l(t('at(on 5or, at least, poss()le l(t('at(on6 )etween t%e a$$&sed and t%e C(ty o0 Reno, Reno C(ty
"E/"
Attorney, and poss()ly, t%e RMC+
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
Fate4 Mon, " Mar 2" 2I4E431 @2<22
C $an do t%at (0 t%ere (s a 'ood reason to /a$ate t%e date+ 7%at (s t%e reason?
Ke(t%
Sent4 3r(day, Mar$% 2I, 2" E4! PM
Please 0(le somet%(n' w(t% t%e $o&rt see.(n' to /a$ate t%at tr(al date and eJpla(n(n' t%at yo& 0a(led to
e/en on$e $ons&lt w(t% yo&r $l(ent pr(or to sett(n' (t+
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
S&),e$t4 Tr(al Fate
Fate4 3r(, I Mar 2" "24884"< @2!22
See atta$%ed
3&ll /(ew
W
W
=a$. to messa'es
RE4 ( was e/($ted 3 "1 ", ( need a $ont(n&an$e?
423 PM
Ke(t% Loom(s
Sent4 7ed 3/!/" 423 PM
Fear Mr+ Co&'%l(n4
T%(s messa'e (s sent to address (ss&es ra(sed (n t%e e@ma(l yo& sent on 3@E@"+
"+ Please note t%at yo& are 0ree to send t%e $omm&n($at(ons yo& send to me, to anyone else yo& des(re+
Oo& s%o&ld )e aware t%at send(n' yo&r $omm&n($at(ons to ot%er part(es w(ll $a&se yo&r
$omm&n($at(ons to me to lose t%e(r attorney@$l(ent $on0(dent(al(ty+
+ 3or w%at spe$(0($ p&rposes do yo& need a $ont(n&an$e? A $ont(n&an$e p&rely 0or t%e p&rpose o0
delay (s not a proper reason 0or a $ont(n&an$e+
3+ 7%et%er yo& are ent(tled to e@ma(l t%e Reno M&n($(pal Co&rt (s not my $on$ern+ T%at (s a pro)lem to
)e addressed )etween yo& and t%e Co&rt+
8+ Ms+ Fra.e (s no lon'er t%e attorney %andl(n' yo&r $ase 0or t%e Reno C(ty AttorneySs O00($e+ Oo&r
$ase (s now )e(n' %andled )y C%r(stop%er :a-lett@Ste/ens, EsN+
1+ Cn response to yo&r N&est(on re'ard(n' t%e wea.nesses o0 t%e trespass(n' $ase C o00er t%e 0ollow(n'4
"</"
a+ T%e $ompla(nt (s de0($(ent (n t%at (0 0a(ls to set 0ort% t%e elements o0 t%e $r(me o0 trespass+ Ct 0a(ls to
(dent(0y w%et%er yo&r presen$e on t%e prem(ses was 0or t%e p&rpose to /eJ or annoy t%e owner or
o$$&pant o0 t%e prem(ses or w%et%er (t was an entry onto t%e prem(ses a0ter a warn(n' not to so
trespass+ T%(s (s pro)a)ly eas(ly remed(ed )y an amendment at t%e t(me o0 tr(al+ Ge/ert%eless t%ese are
alternat(/e t%eor(es on w%($% a trespass $ase $an )e p&rs&ed and t%e de0endant (s ent(tled to .now on
w%($% t%eory or t%eor(es a $ase (s )e(n' prose$&ted (n ad/an$e o0 s%ow(n' &p 0or tr(al+
)+ Oo& 0(led an appeal on O$to)er "I, 2"", apparently, o0 t%e order made )y D&st($e o0 t%e Pea$e
S0erra--a on O$to)er "3, 2""+ T%at order den(ed yo&r reN&est 0or a $ont(n&an$e and 'ranted s&mmary
e/($t(on &nless yo& 0(led a depos(t w(t% t%e $o&rt+ Typ($ally t%e $o&rts lose ,&r(sd($t(on to r&le on ot%er
matters (n t%e $ase on$e an appeal (s ta.en+ Ct (s $lear 0rom t%e $o&rt re$ords t%at t%(s appeal was
pend(n' )e0ore t%e Se$ond D&d($(al F(str($t Co&rt at t%e t(me t%e $o&rt %eld a %ear(n' on t%e &nlaw0&l
deta(ner on O$to)er 1, 2""+ Ct may well )e t%at t%e D&st($e Co&rt lost ,&r(sd($t(on to %old t%e e/($t(on
%ear(n' w%(le t%e appeal was pend(n'+
$+ C am wor.(n' on some ot%er t%o&'%ts+
E+ C0 yo& are d(ssat(s0(ed w(t% t%e way C am represent(n' yo&, yo& rema(n 0ree to see. a new attorney+
<+ Anot%er $%&$.le re'ard(n' my owners%(p o0 str(p $l&)s+ C donSt own or %a/e any owners%(p (nterest
(n any str(p $l&)s, )rot%els, ad&lt )oo. stores or mo/(e %o&ses+ C '&ess t%at lea/es me 0ree to moral(-e+
!+ C st(ll donSt see t%e (mportan$e o0 Fr+ Merl(ss+ T%e reN&est 0or payment o0 an amo&nt eN&al to rent,
was 0or stora'e o0 yo&r personal property+ Oo& are ent(tled to $ontest t%e amo&nt o0 t%e stora'e 0ee,
w%($% yo& d(d+ T%ere (s no $red()le e/(den$e anyw%ere w%($% s&''ests t%at anyone (ntended to reopen
or $reate a new tenan$y allow(n' yo& to reta(n possess(on o0 t%e prem(ses+
I+ Fr+ Merl(ss (s an o&t o0 state w(tness+ Cn order to $ompel %(s appearan$e, %(s test(mony m&st )e
mater(al+ GRS "<8+815"6+ Ct does not appear t%at %(s test(mony (s mater(al &nder t%e (n0ormat(on yo&
%a/e pro/(ded 3&rt%er, &nder GRS "<8+8156 %e (s ent(tled to )e pa(d %(s s&)s(sten$e and tra/el
eJpenses (n$&rred (n $om(n' to Ge/ada+ Are yo& prepared to pay t%ose eJpenses (n ad/an$e o0 %(s
$om(n' to Ge/ada?
"2+ C donSt (ntend to 0aJ or e@ma(l to yo&, yo&r 0&ll 0(le (n t%(s $ase+ Oo& already %a/e e/eryt%(n' w(t%
t%e eJ$ept(on o0 a $o&ple o0 (tems w%($% C ma(led to yo&r old address+ C w(ll send t%em a'a(n to yo&r
new address+ C0 yo& want to re/(ew t%e 0(le yo& are wel$ome to do so at my o00($e+ C0 yo& want $op(es
o0 anyt%(n' (n t%e 0(le yo& may mar. t%e (tems+ A0ter '(/(n' yo& a $ost est(mate, 0or w%($% C reN&(re
payment (n ad/an$e, we w(ll pro/(de yo& w(t% $op(es o0 t%e mar.ed (tems+
Ke(t% Loom(s
Sent4 Monday, Mar$% E, 2" "2433 PM
To4 .e(t%loom(s*eart%l(n.+net9 sterm(t-*s)$'lo)al+net9 ,md*randa--a+$om9 ,)oles*$allat'+$om9
.r(st(emann(n'*ya%oo+$om9 .adl($,*reno+'o/
S&),e$t4 ( was e/($ted 3 "1 ", ( need a $ont(n&an$e
Fear Mr+ Loom(s,
C was wron'0&lly e/($ted on 3 "1 ", and C need a $ont(n&an$e (n t%e $r(m(nal trespass matter t%at yo&
set o/erly N&($.ly a'a(nst my eJpress w(s%es anyway+ My a)(l(ty to $olle$t e/(den$e ne$essary to my
de0ense and ot%erw(se prepare %as )een ad/ersely a00e$ted+ Add(t(onally, C donMt 0eel as t%o&'% yo& are
per0orm(n' (n an appropr(ate manner as de0ense $o&nsel, )&t rat%er yo& seem st&$. (n yo&r
prose$&tor(al ways, too N&($. to loo. 0or any eJ$&se w%atsoe/er to )&ry oneMs $ase, so C t%(n. yo& %a/e
0or$ed a spl(t %ere, w%($% 0&rt%er pre,&d($es my $ase and a&'ers towards a $ont(n&an$e+ Please mo/e
0or one (mmed(ately and $opy me on my ent(re 0(le )y ema(l and 0aJ please+ Add(t(onally, please see.
$lar(0($at(on 0rom t%e RMC as to w%et%er C am allowed to e/er send an ema(l to
renom&n($re$ords*reno+'o/+ Please note, today, D&d'e 3lana'an den(ed R($%ard :(llMs latest 0r(/olo&s
"!/"
mot(on+
F(d yo& .now t%at Ke/(n Kelly, o0 t%e State =ar o0 Ge/adaMs C%ara$ter and 3(tness Comm(ttee 0or at
least t%e last de$ade owns and r&ns t%e Spearm(nt R%(no str(p $l&) (n Las ;e'as4
%ttp4//www+re/(ew,o&rnal+$om/l/r,L%ome/22/Mar@2E@7ed@22/news/"!8"81+%tml
C .now C always l(.e my t%ree %o&r to&rs o0 %ea/y %anded moral(-(n' 0rom someone w%o r&ns a
monol(t%($ str(p $l&) (n Las ;e'as+
Oo& are on t%e State =ar o0 Ge/adaMs 0ee d(sp&te $omm(ttee, arenMt yo& Mr+ Loom(s? Fo yo& own any
str(p $l&)s?
Mr+ Loom(s, w%($% o0 t%e elements o0 t%e trespass $%ar'e RMC !+"2+282 do yo& 0eel are wea.est 0or
Fep&ty C(ty Attorney D(ll Fra.e, w%om C (n0ormed a)o&t t%e adm(ss(on )y Reno PF O00($er C%r(s
Carter t%at R($%ard G+ :(ll, EsN+ )r()es %(m, )&t 0or w%($% Ms+ Fra.e (nd($ated a $omplete la$. o0
(nterest and eJpressed t%at s%e wo&ld not )e 0ollow(n' &p on t%at report o0 )r()ery o0 a RPF O00($er+
Mr+ Kadl($, please pla$e a $opy o0 t%(s $orresponden$e (n D(ll Fra.eMs personnel 0(le+ Add(t(onally
please pla$e one (n All(son OrmaaMs personnel and employment 0(le too, (n add(t(on to Fep&ty C(ty
Attorney Fan 7on'Ms employment 0(le, as all t%ree o0 t%ose Fep&ty C(ty AttorneyMs were pro/(ded t%at
report and all t%ree (nd($ated t%ey d(d not $are and %ad no (ntent(on o0 0ollow(n' &p or ot%erw(se
(n/est('at(n' t%e adm(ss(on )y RPF O00($er C%r(s Carter t%at R($%ard G+ :(ll, EsN+ )r()ed %(m+ C t%(n.
t%e 0a(l&re to 0ollow &p )y any o0 t%ese 3 Fep&ty C(ty AttorneyMs relates to any 0&t&re ne'l('ent %(r(n',
tra(n(n', and s&per/(s(on $la(ms t%at t%e Reno C(ty Attorney may need to de0end a'a(nst w%en
represent(n' t%e Reno PF l(.e (t d(d (n t%e Eeo0 /+ P(tsno'le $ase4
%ttp4//www+l/r,+$om/news/reno@o00($(al@a$$&sed@o0@w(tness@tamper(n'@""E1!E1!+%tml
Oo& .now, Fep&ty C(ty Attorney OrmaasMs de$(s(on to p&s% on 0or t%at V<2 tra00($ t($.et (s loo.(n'
more and more (nterest(n'+ BB
O%, and, Mr+ Loom(s, Fr+ Merl(ss presen$e (s ne$essary )e$a&se %(s &nderstand(n' o0 t%e eJtent to
w%($% %(s attorney, R($%ard G+ :(ll, EsN+ %ad e00e$t(/ely res$(nded any e/($t(on Order )y send(n' a )(ll
0or t%e same amo&nt as 0&ll &se and o$$&pany o0 t%e lo$at(on at "" R(/er Ro$. St+ 'oes to t%e
s&)stan$e o0 t%e elements 0o&nd (n RMC !+"2+282 as well as t%e $red()(l(ty o0 )ot% Merl(ss and :(ll+
S(n$erely,
Close Pr(nt
3&ll /(ew
W
W
=a$. to messa'es
RE4 rm$ "" $r E821 yo& are appo(nted $o&nsel? 0or p&entes ne ta(tel??
/</"
Ke(t% Loom(s
To M#a$% Co&'%l(nM
Sent4 Mon /</" 34< PM
Mr+ Co&'%l(n4
E@ma(l wor.s well 0or me+
Ke(t% Loom(s
Sent4 Monday, 3e)r&ary <, 2" <41E AM
"I/"
S&),e$t4 rm$ "" $r E821 yo& are appo(nted $o&nsel? 0or p&entes ne ta(tel?
%(, ( '&ess Mr+ Loom(s was appo(nted as my 3rd de0ense attorney (n RMC $ase "" $r E821+ C %a/e not
%eard anyt%(n' a)o&t t%(s $ase, and t%e RMC (nd($ated t%ey %ad not%(n' s$%ed&led+ Please
$omm&n($ate w(t% me only /(a ema(l or 0aJ please, %a/(n' (ss&es w(t% my ma(l (n$(dent to domest($
/(olen$e $omm(tted a'a(nst me my 0aJ (s I8I EE< <82+ t%an.s,
#a$% Co&'%l(n
3&ll /(ew
W
W
=a$. to messa'es
$o&rt date?
3/21/"
Ke(t% Loom(s
To M#a$% Co&'%l(nM
Sent4 Mon 3/21/" 842I PM
Mr+ Co&'%l(n4
Ke(t% Loom(s
3&ll /(ew
W
W
=a$. to messa'es
RE4 $o&rt date?
3/2</"
Ke(t% Loom(s
Sent4 7ed 3/2</" 843E PM
Mr+ Co&'%l(n4
On w%at 'ro&nds, ot%er t%an t%ose already set 0ort% (n yo&r eJ(st(n' mot(on, do yo& )el(e/e a mot(on to
d(sm(ss s%o&ld )e 0(led?
Ke(t% Loom(s
Sent4 7ednesday, Mar$% 2<, 2" "481 AM
Mr+ Loom(s,
Please $opy me on any and all $orresponden$es, 0(l(n', or ot%er do$&mentat(on or /er)al reN&ests,
$orresponden$es, et$+ t%at yo& s&)m(t to t%e Co&rt, (n$l&d(n' t%e one yo& re0eren$e )elow+ Please do
not 0ollow Ta(telMs ta$t o0 a'ree(n' to reN&ests or 0a(l(n' to oppose mot(ons w(t%o&t e/en attempt(n' to
o)ta(n my perm(ss(on to (n ad/an$e t%ereo0+
C wo&ld l(.e 0or yo& to dra0t a Mot(on to F(sm(ss (n t%(s $ase 0or me re/(ew+
2/"
T%an.s,
@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@
S&),e$t4 $o&rt date
Fate4 Mon, 1 Mar 2" "E42I4"I @2!22
Mr+ Co&'%l(n4
Ke(t% Loom(s
3&ll /(ew
W
W
=a$. to messa'es
RE4 $o&rt date?
3/2I/"
Ke(t% Loom(s
Sent4 3r( 3/2I/" "24"8 AM
Go worr(es+ Made me la&'%+
Co&ple o0 N&est(ons4
F(d yo& 0(le an appeal 0rom D&st($e o0 t%e Pea$e S0erra--aSs e/($t(on order?
C0 yes, %as (t )een resol/ed?
F(d S0erra--a anno&n$e at t%e $lose o0
"/"
traffic/ parking citations
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 J ill 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,
No: 9473
Sent: Wed 3/21/12 9:18 AM
To: cityclerk@reno.gov; kadlicj@reno.gov; vj@npri.org; mkandaras@da.washoecounty.us
4 attachments
PAUL SIFRE TransparentNevada city of reno failed to report cost of health care benefits.htm (3.6 KB) , KIMBERLY
BRADSHAW TransparentNevada.htm (3.3 KB) , J OHN TARTER TransparentNevada tarter 2010.htm (3.3 KB) ,
MARCIA LOPEZ TransparentNevada sergeant monica lopez 2010.htm (3.3 KB)
Dear City Clerk,
I prefer if you communicate to me in writing, by email only. I have a ticket from 1/12/12 that I believe should be dismissed.
Issue NO 020148154. I was wrongfully arrested by the "community oriented policing" Reno Police Department shortly before
that ticket was, apparently issued. Yes, a custodial arrest for "jaywalking" of an attorney, myself. I do not believe I should be
charged for the ticket under these circumstances. Further, upon being released from jail in 25 degree cold late that night, right
after the last RTC bus for the night had left (what a coincidence). Sargent Sifre admitted to me at the scene of the wrongful
arrest that he ordered it done by fresh face training cop Officer Leedy. I was literally attacked by the Reno Police Department,
my camera taking out of my hands. I told Sargent Sifre not to turn the camera off, but he did so, gleefully. You think a
young sargent making more than some of the top litigation attorneys in town (and more than District Court J udges make)
would be a bit more cheerful, but you would be wrong. See, I was at my former home law office filming Richard G. Hill's
crew taking the personal property in it that I believe I will ultimately be entitled to sue for damages to, to the town dump.
Now, RPD Officer Hollingsworth did tell me that, because I was just peacably there on public property, on the sidewalk, that I
was not breaking any laws....but, see...Richard G. Hill didn't like that, probably because I was gathering evidence that will
ultimately make the "wrong site surgery" he did on behalf of his Californian nuerosurgeon landlord client, something for
which Hill will be liabile for (Hill decided to bill his client somewhere in the neighborhood of $40K to attempt to remove me,
a commercial tenant, from the property via the summary eviction procedures found in NRS 40.253, based only on a No Cause
Eviction notice, which is expressly forbidden (one cannot summarily evict a commercial tenant unless the non-payment of rent
is alleged...and Hill didn't want to get into that because the facts were so poor on habitability and retaliation, etc., etc. So,
Hill also gets a TPO issued by the Reno J ustice Court, in record time, within forty minutes of filing it that day....And RPD
Officer Look practicaly broke into the Washoe County jail trying to serve it on me within an hour of Hill filing it. Gosh,
those RPD Officers sure work hard when Richard G. Hill, Esq. is involved! But just you try to get them to arrest anyone
from Nevada Court Services for trespassing, even though someone posted a video of them doing just that on youtube:
http://www.freeexistence.org/police_state.html
http://www.youtube.com/watch?v=zbNoYqK_ZU4

Then there is Sargent Tarter, would retaliated against me for reporting to him that RPD Officer Chris Carter admitted to me to
taking bribes from Richard G. Hill, Esq. in connection with my 11/12/11 arrest for trespass (apparently I am never eligible for
a citation from the Reno PD or for an OR release from the WCSO, how convenient for everyone...) by issuign me three traffic
citations minutes after he demanded I leave Richard G. Hill's vicinity (or the area near Hill's law office at 652 Forrest St.)
where I had gone upon being released from jail on 11/15/11 to retrieve my wallet and Nevada driver's license from Hill, whom
refused to give me those items for another 7 days, and who further withheld my client's files from me and them for another 6
weeks. Then, RMC J udge Nash Holmes had me arrested for summary contempt in court when I dared to cross examine
Sargent Tarter about his retaliatory citations. While having me arrested, J udge Holmes apparently decided the court was
entitled to keep both of my cell phones and my electric shaver.

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
Detail page for PAUL SIFRE
Name PAUL SIFRE
Position
Sergeant
Reno
Notice
Year 2009
Base Pay $89,019.87
Overtime and
Callback Collected
$7,595.10
Total Pay $108,955.53
Detail page for KIMBERLY BRADSHAW
Name KIMBERLY BRADSHAW
Position
7555 Sergeant
Reno
Year 2010
Base Pay $109,225.10
Overtime and
Callback Collected
$5,644.98
Total Pay $153,371.72
Detail page for J OHN TARTER
Name J OHN TARTER
Position
7555 Sergeant
Reno
Year 2010
Base Pay $109,225.10
Overtime and
Callback Collected
$7,733.14
Total Pay $134,494.05
Detail page for MARCIA LOPEZ
Name MARCIA LOPEZ
Position
7555 Sergeant
Reno
FW: City Clerk's Office
Year 2010
Base Pay $92,481.00
Overtime and
Callback Collected
$7,012.04
Total Pay $116,409.24
Sent: Thu 3/08/12 4:22 AM
To: cityclerk@reno.gov
Dear Sharon and Reno City Clerk's Office,

I have not heard or received anything on the request I sent below. Please respond only by email or fax as I have been a victim
of domestic violence recently that has faced tampering with his mail...
No: 9473

Subject: City Clerk's Office
Date: Wed, 8 Feb 2012 08:14:04 -0800
Dear City Clerk and Sharon,

Hello, I am writing again about these tickets. I was told that when you go to court at the RMC and you get a ticket while there
for a court date that you will be given a voucher that will take care of that ticket. I went to Court on November 30th, 2011. I
was told there was not possibility of jail time, however, J udge Howard sentenced me to a summary three days in jail on the spot,
so my car was parked there and I was in jail when the ticket came on December 3rd, 2011. May I please have that ticket
excused under the policy I mention above? Please let me know if there is anythind I need to do in that regard.

With respect to the other ticket, from 11/3/11, I wish to dispute it and have not been able to get any information from the City
Clerk's Office with respect to getting a court date or why fines accrue prior to such an opportunity for judicial review. Should not
the additional fines be stayed until an opportunity for review? Please communicate with my by email, in writing.

Thanks,
Zach Coughlin
PS. I am indigent.
Subject: RE: debt validation documentation request and dispute letter under FDCPA to City of Reno et al
Date: Mon, 9 J an 2012 19:01:22 -0800
Dear Reno City Clerk's Office,
Hello, I hope you are having a nice day.
I have called several times and keeping leaving messages about disputing the following parking tickets, and do not believe any "additional
fines" should have attached to the base fine where I have communicated that I am disputing them and have not receive a response with regard
to the date and time of my hearing to dispute them:
Citation Details
Citation Number: 020146724
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
Plate Number: 838NER
State: NV
Related Citations
We have found the following additional outstanding citations for this license plate number. Please check the box next to each
additional citation that you would like to pay for at this time.
Citation Number Issue Date Amount Due
020145322 11/03/2011 03:20:00 $55.00

To: renodirect@reno.gov; renomunirecords@reno.gov
Subject: debt validation documentation request and dispute letter under FDCPA to City of Reno et al
Date: Mon, 9 J an 2012 18:09:30 -0800
Dear City of Reno,
This writing is written notice to you that I dispute the debt your office and the City of Reno and or the Reno Municipal Court
has recently sent me, alleging that I owe some debt for either parking tickets and or traffic citations. Further, I request
verification and documentation in support of your contention that I owe such a debt pursuant to the Fair Debt Collection
Practices Act.

Sincerely,
Zach Coughlin1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
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To: renomunirecords@reno.gov; renodirect@reno.gov

Subject: proof of insurance and registration Affidavit/Declaration and supporting documentation
Date: Mon, 9 J an 2012 17:58:47 -0800
Dear Reno Municipal Court Clerk's Office,

My name is Zachary B. Coughlin.
My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for my USAA automobile insurance at the
time of both Traffic Citations No's: 544281 and R47190389731. Copies of both citations are attached as well. My vehicle, at the time of both
citations, was in compliance with Nevada law with regard to vehicle registration. A true and correct copy of this Affidavit and the attached
copies of Traffic Citations No's: 544281 and R47190389731 and a true and correct copy of the Proof of Insurance for the time of both
citations from my USAA automobile insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury pursuant to NRS 199.145.

Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the two citations and the proof of insurance
at the time and date of both citations and the same for the registration for the vehicle. I am disputing the "failure to come to a complete stop"
part of the citation in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in that regard, please
correct me if that is not the correct date and time.

Also, I have called several times and keeping leaving messages about disputing the following parking tickets, and do not believe any
"additional fines" should have attached to the base fine where I have communicated that I am disputing them and have not receive a response
with regard to the date and time of my hearing to dispute them:
Citation Details
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
State: NV
Related Citations
We have found the following additional outstanding citations for this license plate number. Please check the box next to
each additional citation that you would like to pay for at this time.
020145322 11/03/2011 03:20:00 $55.00
Notice of Appeal and MOtion for....

please find motion to dismiss attached for 11 cr 26405

Sincerely,

Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Sent: Wed 3/07/12 10:44 AM
To: ormaasa@reno.gov; kadlicj@reno.gov
1 attachment
3 7 12 11 TR 26800 rmc NOTICE OF APPEALS ETC MOTION.pdf (2.6 MB)
Please see attached
No: 9473
Sent: Sat 3/03/12 3:11 PM
To: drakej@reno.gov; keithloomis@earthlink.net
1 attachment
FW: City Clerk's Office
final motion to dismiss 11 cr 26405 3 3 12.pdf (698.4 KB)
No: 9473
Sent: Wed 2/22/12 8:11 PM
1 attachment
Zach Coughlin license plate 838NER proof of insurance and registration for citations 544281 and r47190389731.pdf
(1737.4 KB)
Dear Sharon and Reno City Clerk's Office,

I have not heard or received anything on the request I sent below. Please respond only by email or fax as I have been a victim
of domestic violence recently that has affected my receipt of mail through the us mail.

Sincerely,
No: 9473

Subject: City Clerk's Office
Date: Wed, 8 Feb 2012 08:14:04 -0800
Dear City Clerk and Sharon,

Hello, I am writing again about these tickets. I was told that when you go to court at the RMC and you get a ticket while there
for a court date that you will be given a voucher that will take care of that ticket. I went to Court on November 30th, 2011. I
was told there was not possibility of jail time, however, J udge Howard sentenced me to a summary three days in jail on the spot,
so my car was parked there and I was in jail when the ticket came on December 3rd, 2011. May I please have that ticket
excused under the policy I mention above? Please let me know if there is anythind I need to do in that regard.

With respect to the other ticket, from 11/3/11, I wish to dispute it and have not been able to get any information from the City
Clerk's Office with respect to getting a court date or why fines accrue prior to such an opportunity for judicial review. Should not
the additional fines be stayed until an opportunity for review? Please communicate with my by email, in writing.

Thanks,
Zach Coughlin
PS. I am indigent.
Subject: RE: debt validation documentation request and dispute letter under FDCPA to City of Reno et al
Date: Mon, 9 J an 2012 19:01:22 -0800
Dear Reno City Clerk's Office,
Hello, I hope you are having a nice day.
I have called several times and keeping leaving messages about disputing the following parking tickets, and do not believe any "additional
fines" should have attached to the base fine where I have communicated that I am disputing them and have not receive a response with regard
to the date and time of my hearing to dispute them:
Citation Details
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
State: NV
Related Citations
We have found the following additional outstanding citations for this license plate number. Please check the box next to each
additional citation that you would like to pay for at this time.
020145322 11/03/2011 03:20:00 $55.00

To: renodirect@reno.gov; renomunirecords@reno.gov
Subject: debt validation documentation request and dispute letter under FDCPA to City of Reno et al
Date: Mon, 9 J an 2012 18:09:30 -0800
Dear City of Reno,
This writing is written notice to you that I dispute the debt your office and the City of Reno and or the Reno Municipal Court
has recently sent me, alleging that I owe some debt for either parking tickets and or traffic citations. Further, I request
verification and documentation in support of your contention that I owe such a debt pursuant to the Fair Debt Collection
Practices Act.

Sincerely,
Zach Coughlin1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402

To: renomunirecords@reno.gov; renodirect@reno.gov
Subject: proof of insurance and registration Affidavit/Declaration and supporting documentation
Date: Mon, 9 J an 2012 17:58:47 -0800

Dear Reno Municipal Court Clerk's Office,

My name is Zachary B. Coughlin.
My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for my USAA automobile insurance at the
time of both Traffic Citations No's: 544281 and R47190389731. Copies of both citations are attached as well. My vehicle, at the time of both
citations, was in compliance with Nevada law with regard to vehicle registration. A true and correct copy of this Affidavit and the attached
copies of Traffic Citations No's: 544281 and R47190389731 and a true and correct copy of the Proof of Insurance for the time of both
citations from my USAA automobile insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury pursuant to NRS 199.145.

Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the two citations and the proof of insurance
at the time and date of both citations and the same for the registration for the vehicle. I am disputing the "failure to come to a complete stop"
part of the citation in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in that regard, please
correct me if that is not the correct date and time.

Also, I have called several times and keeping leaving messages about disputing the following parking tickets, and do not believe any
"additional fines" should have attached to the base fine where I have communicated that I am disputing them and have not receive a response
with regard to the date and time of my hearing to dispute them:
Citation Details
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
State: NV
Related Citations
We have found the following additional outstanding citations for this license plate number. Please check the box next to
each additional citation that you would like to pay for at this time.
020145322 11/03/2011 03:20:00 $55.00
NOTICE OF APPEAL MOTION TO SET ASIDE WITHDRAWAL

Sincerely,

Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Sent: Wed 2/15/12 3:21 AM
To: puenteslaw@aol.com; drakej@reno.gov
1 attachment
2 13 12 nOTICE OF APPEAL PUENTES DEAL WITH ATTACHED EXHIBIT 1.pdf (415.9 KB)
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
Close Print
RMC 11 CR 22176 part four Exhibit 1 pages 701-794 of Motion for New
trail from 12 12 2011 ey
Sent: Mon 12/12/11 8:29 PM
To: fiskm@reno.gov; renomunirecords@reno.gov
1 attachment
RMC 11 CR 22176 part four Exhibit 1 pages 701-794 of Motion for New trail from 12 12 2011
ey.pdf (14.4 MB)
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.

Subject: Motion for New Trial Etc. in RMC 11 CR 22176
Date: Mon, 12 Dec 2011 19:57:50 -0800
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New
trail from 12 12 2011 ey
fax: 949 667 7402

Sent: Mon 12/12/11 8:23 PM
1 attachment
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New trail from 12 12 2011
ey.pdf (11.8 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Motion for New Trial Etc. in RMC 11 CR 22176
Motion for New Trial Etc. in RMC 11 CR 22176
Sent: Mon 12/12/11 7:57 PM
1 attachment
RMC 11 CR 22176 part three Exhibit 1 pages 301-600 of Motion for New trail from 12 12 2011.pdf
(9.7 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Sent: Mon 12/12/11 7:40 PM
1 attachment
RMC 11 CR 2217 part two Exhibit 1 pages 1-300 of Motion for New trail from 12 12 2011.pdf (8.6
MB)
I received approval to file by email from RMC
This is the second file in the filing. Please note, the file name of the attachment should actually have the correct
case number of RMC CR 22176. It is missing the 6 on the end in the file name of the attachment
FW: RMC said I could file this by email
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Mon 12/12/11 7:34 PM
To: fiskm@reno.gov
1 attachment
12 11 11 final motion for new trial city of reno v coughlin RMC 11 CR 22176.pdf (12.9 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
signed REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER
DOCUMENTATION URGENT PLEASE
Subject: RMC said I could file this by email
Date: Mon, 12 Dec 2011 19:27:57 -0800
Dear RMC,
I called an wrote earlier and received approval to file the attached pdf and media files
by email rather than fax or other submission. This filing is large, as such, it must be
broken down into segments. this is part one, part two will be in the next email. I will
pay whatever filing fee or bond or whatever I have to pay to access justice in this here
case.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 8950
fax: 949 667 7402
Sent: Thu 12/08/11 5:56 PM
1 attachment
RECORD_REQUEST_FORM_2010[1] trial cd and orders to RMC 12 8 11 signed.pdf (446.2 KB)
I am resending the Records and REcording of Trial request form, SIGNED, just in case that is necessary.

Thank You,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Subject: REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER DOCUMENTATION URGENT
PLEASE
Date: Thu, 8 Dec 2011 17:45:27 -0800
Please let me know right away if there is any problem opening the attached pdf
containing my URGENT records request. Please find attached my urgent request for
a tape of the trial held on November 30, 2011 (exigent concerns related to my ability to
filed relief from judgment motions with 10 days of the Order, which was apparently
made on 11/30/11 dictate that I be provided a copy of the tape or cd/dvd of the hearing
very quickly, please), any order or findings in this case, the entire docket, any Contempt
Order stemming from the 11/30/11 trial, etc. I will pay all charges required, though I
believe my indigent status should yield an IFP or fee waiver, however, time is of the
essence and I cannot wait more than half a day to have an IFP ruled on, so please
proceed as though I will pay. Please let me know immediately, via email preferably,
or by fax (but not by phone or USPS mail) when these materials are ready, in addition
to providing me a written estimation of how long it will be before they will be ready
and made available to me.

Sincerely,
RE: your failure to propound discovery
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Thu 12/08/11 5:14 PM
To: hazlett-stevensc@reno.gov
Chris,
I am engaging you in relation to 11 CR 22176 an your failure to provide me access to or
copies of the discovery from the arrest of September 9, 2011, not the trespass case.
We will deal with the trespass case later. For now, please just address your failure ot
provide copies of the discovery when I requested. Can you check your phone
records? Would you like me to check mine? How about your fax records. Mine?
I think you will find that we definately did speak. Anyways, can you indicate your
offices standard operating procedure when a defendant or accused calls and writes your
office up requesting discovery within a day after the arrest? Must you provide
something within 48 hours of the arrest? What about if the arraignment is set out one
month from the arrest? Must an arraignment occur prior to that? It seems rather
suspect to assert that your office does not have any records or discovery incident to the
an arrest of September 9, 2011, when the accused calls and writes requesting
documentation incident to the arrest on approximately September 13th, 201l and again
soon thereafter, and again somewhat later, when discovery subsequently provided by
Pam Roberts shows a fax (only a partial portion of which, apparently, was included in
the discovery) from Sargent Avansino to your office dated September 12,
2011...Further, you did not indicate that your office had something but wouldn't provide
it, you indicated that your office simply did not have anything. You made remarks
about how you weren't going to tell this and that person how to do their job,
etc...Remember? It seems patently unfair for the prosecutor to be provided access to
this documentation over one month prior to the defendant being afforded access to it,
and sufficient time to do who knows what with it (several pages of Sargent Avansino's
fax appear missing and the Probable Cause sheet does not appear to be reviewed and
signed off on for a probable cause finding by any Magistrate, the form is simply blank),
particularly were a continuance was at first agreed to by Roberts in writing (only to
have her weasel out of that at trial while making jokes about the defendant's need to use
the restroom in open court). Please indicate, further, in writing, if your office received
any faxed or emailed records request from me, Zach Coughlin, at any time, including
the period of time prior to the Oct 10th, 2011 arraignment.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Date: Thu, 8 Dec 2011 16:05:11 -0800
From: Hazlett-StevensC@reno.gov
Subject: RE: your failure to propound discovery
Mr. Coughlin. I have never spoken to you and have never denied discovery to a defendant in any matter. Again you seek to
engage me in a convesation about the pending trespassing. I cannot speak with you. You are represented by counsel.

Thank you,

Chris
Christopher Hazlett-Stevens
City of Reno
Tel: 326-6628
Fax: 334-4226

ATTORNEY-CLIENT PRIVILEGED

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.
To: <hazlett-stevensc@reno.gov>, <robertsp@reno.gov>
Date: Thu, 8 Dec 2011 15:44:36 -0800
Subject: RE: your failure to propound discovery
Mr. Hazlett-Stevens,

We did definately talk on the phone regarding the matter to which I do not have
representation, the RSIC arrest case 11 DR 22176 2I for which Deputy City Attorney
Pam Roberts is the prosecutor. I was denied my Sixth Amendment right to court
appointed defense counsel in that matter, and represented myself. As such, there is
no rule precluded you from communicating with me about 11 DR 22176 2I. You did
speak with me about that. I called you within a couple days of the September 9th,
2011 arrest in that matter describing my exigent desire to obtain a copy of the
discovery. I was transferred to you and we spoke at length about it, you describing
why you could not give it to me. Is it your contention that your office or the State
does not have a duty to provide the defendant a copy of certain pieces of discovery
within 48 hours of arrest?

Regarding the matter for which Mr. Puentes took the baton from Mr. Taitel, is it clear
to you how Mr. Taitel was somehow, apparently, able to assent to a continuance, only
to, apparently, find some need to pass the baton to Mr. Puentes very, very shortly
thereafter? Why did Mr. Taitel's status as attorney of record change? Was it due
to a conflict? Why didn't that conflict prevent Mr. Taitel from abstaining from
assenting to the continuance in the trespass case, which was scheduled for trial
December 13, 2011?

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
** 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.

Date: Wed, 7 Dec 2011 07:34:25 -0800
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded with you, and
your statement that you spoke with me is false. I have never spoken with you. You may have your attorney, Roberto
Puentes, contact me with any discovery issues or issues regarding the City's Motion to Continue. Please do not correspond
with me regarding this case in the future. As an attorney, you are fully aware that I cannot communicate with a you as a
represented party. Do not contact me without your counsel.

Thank you,

Chris
City of Reno
Tel: 326-6628
Fax: 334-4226


To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery

Dear Mr. Hazlett-Stevens,

I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for which Lew
Taitel was apparently my court appointed attorney, but whom no longer is. Further, I wish to be
copied on everything past and present in any way related to this matter until and after I procure
another attorney. I did not agree to the continuance you sought, nor was I informed you
were seeking it. I find it particularly troubling that a continuance was granted in the trespass
case to the same man who is applying an unlawful rent distraint on both my client files, personal
property, AND THE EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE
PETIT LARCENY CASE FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST
YOU AND YOUR OFFICE'S HANDLING BELOW. NO CONTINUANCE WAS GRANTED
OR AGREED TO AT TRIAL BY THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO
BUSY ALLEGEDLY SUBORNING THE PERJURY OF RSIC OFFICER KAMERON
CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted against
me there is a fax from the RSIC to you that has a fax heading for what appears to be "page 1"
followed by pages without that heading...then a heading with "page 4" etc... I want the entire
contents of anything provided by the RSIC and Walmart to you or anyone connected with the
Reno City Attorney or the Reno Municipal Court. Further, I want all media provided by
Walmart, and I question why you needed 45 minutes with the three witness who testified at the
November 30th, 2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a NRCP
11 motion requiring you to correct the perjury you suborned in court with respect to the patently
contradictory testimony of Officer Crawford vis a vis the video evidence you yourself provided in
discovery.

Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest in this
matter demanding a copy of all documentation or discovery that I had any right to. I was told I
would not have any opportunity to review such materials prior to the arraignment, which was not
set for a full 30 days out from the arrest. Do I not have a right to a copy of the pc sheet, arrest
report, and witness statements within 48 hours of the arrest? The fax to your office from the
RSIC is dated 9/12/2011, yet my written demands and requests for such discovery and
request of cd of trial in 11 CR 22176 2I
documentation were met with refusals to provide such materials, and, in some case, claims that
your office did not even have such materials and would not get them until after the
arraignment. Further, I spoke with and provided written requests to RSIC Sargent Avansino
within 2 days after the arrest and he refused to provide the materials, as did the Reno Municipal
Court. Please alert the court to any wrongdoing on your's or the Reno City Attorney or the
RSIC part in this regard in prejudicing my ability to defend my case by delaying the production
of essential discovery, then refusing to agree to a continuance at trial, after earlier providing a
written agreement to such a continuance.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient
or an ag ent responsible for delivering it to the intended recipient, y ou 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.

Sent: Thu 12/08/11 4:00 PM
Hello, I am writing to request a copy of the cd of the record of trial in 11 CR 22176 2I in addition to a copy of the
Contempt Order and any other orders made in that matter, in addition to a copy of the docket.

Please email these to me if possible. I will agree to pay the copying costs or the paper documents or the audio
cd/dvd. I need these as soon as possible please.
Zach Coughlin, Esq.
RE: your failure to propound discovery
Reno, NV 89501
fax: 949 667 7402
Sent: Thu 12/08/11 3:44 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov
Mr. Hazlett-Stevens,

We did definately talk on the phone regarding the matter to which I do not have
representation, the RSIC arrest case 11 DR 22176 2I for which Deputy City Attorney
Pam Roberts is the prosecutor. I was denied my Sixth Amendment right to court
appointed defense counsel in that matter, and represented myself. As such, there is no
rule precluded you from communicating with me about 11 DR 22176 2I. You did
speak with me about that. I called you within a couple days of the September 9th,
2011 arrest in that matter describing my exigent desire to obtain a copy of the
discovery. I was transferred to you and we spoke at length about it, you describing
why you could not give it to me. Is it your contention that your office or the State
does not have a duty to provide the defendant a copy of certain pieces of discovery
within 48 hours of arrest?

Regarding the matter for which Mr. Puentes took the baton from Mr. Taitel, is it clear to
you how Mr. Taitel was somehow, apparently, able to assent to a continuance, only to,
apparently, find some need to pass the baton to Mr. Puentes very, very shortly
thereafter? Why did Mr. Taitel's status as attorney of record change? Was it due to
a conflict? Why didn't that conflict prevent Mr. Taitel from abstaining from assenting
to the continuance in the trespass case, which was scheduled for trial December 13,
2011?

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Date: Wed, 7 Dec 2011 07:34:25 -0800
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded with you, and
your statement that you spoke with me is false. I have never spoken with you. You may have your attorney, Roberto
Puentes, contact me with any discovery issues or issues regarding the City's Motion to Continue. Please do not correspond
with me regarding this case in the future. As an attorney, you are fully aware that I cannot communicate with a you as a
represented party. Do not contact me without your counsel.

Thank you,

Chris
City of Reno
Tel: 326-6628
Fax: 334-4226


To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery


I am writing to request a copy of any and all discovery, pleadings, documentation, correspondences,
or media in any way connected to the trespass case against me for which Lew Taitel was apparently
my court appointed attorney, but whom no longer is. Further, I wish to be copied on everything
past and present in any way related to this matter until and after I procure another attorney. I did
not agree to the continuance you sought, nor was I informed you were seeking it. I find it
particularly troubling that a continuance was granted in the trespass case to the same man who is
applying an unlawful rent distraint on both my client files, personal property, AND THE
EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT LARCENY CASE
FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S
HANDLING BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL
BY THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY
SUBORNING THE PERJURY OF RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted against
me there is a fax from the RSIC to you that has a fax heading for what appears to be "page 1"
followed by pages without that heading...then a heading with "page 4" etc... I want the entire
contents of anything provided by the RSIC and Walmart to you or anyone connected with the Reno
City Attorney or the Reno Municipal Court. Further, I want all media provided by Walmart, and I
question why you needed 45 minutes with the three witness who testified at the November 30th,
2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a NRCP 11 motion
requiring you to correct the perjury you suborned in court with respect to the patently contradictory
testimony of Officer Crawford vis a vis the video evidence you yourself provided in discovery.

would not have any opportunity to review such materials prior to the arraignment, which was not
set for a full 30 days out from the arrest. Do I not have a right to a copy of the pc sheet, arrest
report, and witness statements within 48 hours of the arrest? The fax to your office from the
RSIC is dated 9/12/2011, yet my written demands and requests for such discovery and
documentation were met with refusals to provide such materials, and, in some case, claims that
your failure to propound discovery
your office did not even have such materials and would not get them until after the arraignment.
Further, I spoke with and provided written requests to RSIC Sargent Avansino within 2 days after
the arrest and he refused to provide the materials, as did the Reno Municipal Court. Please alert
the court to any wrongdoing on your's or the Reno City Attorney or the RSIC part in this regard in
prejudicing my ability to defend my case by delaying the production of essential discovery, then
refusing to agree to a continuance at trial, after earlier providing a written agreement to such a
continuance.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
an agent responsible for delivering it to the intended recipient, y ou are hereby notified that you have received this document in error and
privilege.

Sent: Wed 12/07/11 1:48 AM
To: hazlett-stevensc@reno.gov


I am writing to request a copy of any and all discovery, pleadings, documentation, correspondences,
or media in any way connected to the trespass case against me for which Lew Taitel was apparently
my court appointed attorney, but whom no longer is. Further, I wish to be copied on everything
past and present in any way related to this matter until and after I procure another attorney. I did
not agree to the continuance you sought, nor was I informed you were seeking it. I find it
particularly troubling that a continuance was granted in the trespass case to the same man who is
applying an unlawful rent distraint on both my client files, personal property, AND THE
EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT LARCENY CASE
FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S
HANDLING BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL BY
THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY SUBORNING
THE PERJURY OF RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted against me
there is a fax from the RSIC to you that has a fax heading for what appears to be "page 1" followed
by pages without that heading...then a heading with "page 4" etc... I want the entire contents of
anything provided by the RSIC and Walmart to you or anyone connected with the Reno City
Attorney or the Reno Municipal Court. Further, I want all media provided by Walmart, and I
question why you needed 45 minutes with the three witness who testified at the November 30th, 2011
trial, from 1pm to 1:45pm. Additionally, you are hereby served a NRCP 11 motion requiring you
to correct the perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.

would not have any opportunity to review such materials prior to the arraignment, which was not set
for a full 30 days out from the arrest. Do I not have a right to a copy of the pc sheet, arrest report,
and witness statements within 48 hours of the arrest? The fax to your office from the RSIC is dated
9/12/2011, yet my written demands and requests for such discovery and documentation were met
with refusals to provide such materials, and, in some case, claims that your office did not even have
such materials and would not get them until after the arraignment. Further, I spoke with and
provided written requests to RSIC Sargent Avansino within 2 days after the arrest and he refused to
provide the materials, as did the Reno Municipal Court. Please alert the court to any wrongdoing
on your's or the Reno City Attorney or the RSIC part in this regard in prejudicing my ability to
defend my case by delaying the production of essential discovery, then refusing to agree to a
continuance at trial, after earlier providing a written agreement to such a continuance.

Sincerely,
discovery request;
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Wed 12/07/11 1:16 AM
To: robertsp@reno.gov; kadlicj@reno.gov
Dear Ms. Roberts,

In the discovery you provided in this matter there is a fax from the RSIC to you that has
a fax heading for what appears to be "page 1" followed by pages without that
heading...then a heading with "page 4" etc... I want the entire contents of anything
provided by the RSIC and Walmart to you or anyone connected with the Reno City
Attorney or the Reno Municipal Court. Further, I want all media provided by
Walmart, and I question why you needed 45 minutes with the three witness who
testified at the November 30th, 2011 trial, from 1pm to 1:45pm. Additionally, you are
hereby served a NRCP 11 motion requiring you to correct the perjury you suborned in
court with respect to the patently contradictory testimony of Officer Crawford vis a vis
the video evidence you yourself provided in discovery.

Further, I spoke with Mr. Hazlett-Stevens shortly after the September 9, 2011 arrest in
this matter demanding a copy of all documentation or discovery that I had any right
to. I was told I would not have any opportunity to review such materials prior to the
your cop lying, see your video drivers license produce ap overview at
6:49 mark
arraignment, which was not set for a full 30 days out from the arrest. Do I not have a
right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of
the arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written
demands and requests for such discovery and documentation were met with refusals to
provide such materials, and, in some case, claims that your office did not even have
such materials and would not get them until after the arraignment. Further, I spoke
with and provided written requests to RSIC Sargent Avansino within 2 days after the
arrest and he refused to provide the materials, as did the Reno Municipal Court.
Please alert the court to any wrongdoing on your's or the Reno City Attorney or the
RSIC part in this regard in prejudicing my ability to defend my case by delaying the
production of essential discovery, then refusing to agree to a continuance at trial, after
earlier providing a written agreement to such a continuance.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Sun 12/04/11 4:05 AM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org; robertsp@reno.gov
pgoins@rsic.org, lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
We spend half the "trial" arguing about whether your lying cops had enough
"information" (their definition included personally identifiable information to identify
the accused sufficiently to issue a citation, A CURRENT NEVADA'S DRIVERS
LICENSE WOULD DO JUST FINE ON THAT ACCOUNT) to issue a citation, and
how, because they didn't, they had to conduct a search incident to arrest, yet YOUR
OWN DAMN VIDEO (OR RATHER, WALMART'S, BUT ITS HARD TO SEE
WHERE YOU GUYS END AND WALMART BEGINS), THAT YOU EFFING
PRODUCED (OR RATHER THE RENO CITY ATTORNEY PRODUCED AFTER
THE BOYS AT WALMART "COMPILED" VIDEO, WHICH CURIOUSLY DID
CONTAIN A FUCKING SECOND OF VIDEO SHOWING ANY OF THE ALLEGED
CONCEALING OR CONSUMING THE ITEMS IN QUESTION! SHOWS THE
ACCUSED HANDING THEM A DRIVERS LICENSE AND THEM CALLING IT IN
TO CHECK FOR PRIORS (THAT WILL SHOW UP IN DISPATCH REPORTS AND
OTHER DOCUMENTATION). THESE KEYSTONE COP EFFUPS HAVE
DEFAMED ME AND YOU SPONSORED IT, CULTIVATED IT.
I CAN GIVE YOU UNTIL TUESDAY TO MAKE A STRONG EFFORT TO
CORRECT THIS, AFTER THAT, I HAVE TO MAKE MY MOVES AND FILE MY
MOTIONS. JUDGE VAN WALRAVEN WOULD BE ASHAMED OF HOW THIS
HAS BEEN HANDLED.
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS A FAR
MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT THAT
WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS "PARTICIPATION", AND
ITS ALL ON TAPE.
I want you to move for, OR ASK THE CITY ATTORNEY TO MOVE FOR, a Rule
59 Motion to Set Aside or some other motion to have the Judgment Set Aside. Your
cop witness clearly had a driver's license produced to him at the 6:49 mark of
WALMART'S OWN DAMN VIDEO! And you suborned his perjury on the witness
stand in violation of many of the POLICE CODES YOU ARE HELD TO. Further,
what are you going to say when the UPC from the alleged receipt appears on the
purchased receipt, in combination with Frontino's adamant assertion that they wouldn't,
FW: your cop lying, see your video drivers license produce ap overview
at 6:49 mark
in combination with the same from Crawford, in combination with Frontino admitting
he couldn't hear what was said between the accused and the cashier, in combination
with the "same UPC, hit the quantity number" practice common at Walmart? Further,
your Officer Crawford, as a witness, admitted on tape at the trial that "he didn't have
enough EVIDENCE to issue a citation so he arrested and did a search incident to arrest"
to get more evidence before Reno City Attorney Roberts and Judge Howard could
jump in and cut him off. That's gametime. Frontino, Crawford, and Braunworth,
sat around joking like goofy frat boys the preceeding 30 minutes in the hallway in front
of the court room, like a group of 3 buddies who hang out all the time, except, 2 get
paid by you, and one gets paid by Wal-Mart, who pay the people who pay you. Then
all three of them wait around the hear the verdict at 8 pm hours after Frontino and
Crawford finished testifying. Maybe the don't realize Judge Howard wasn't ruling
on the Appeal, the Rule 59, 60 motions, Motion for Reconsideration, defamation,
wrongful arrest, false imprisonment lawsuits, etc. Fix it now while you can. Wait
till I get the video from Walmart that Frontino is hiding from you, and don't you just
want to know if some "other" audio or video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Sun 12/04/11 3:45 AM
To: robertsp@reno.gov; kadlicj@reno.gov; kadlicj@ci.reno.nv.us
We spend half the "trial" arguing about whether your lying cops had enough
"information" to issue a citation, and how, because they didn't, they had to conduct a
search incident to arrest, yet YOUR OWN DAMN VIDEO, THAT YOU EFFING
PRODUCED! SHOWS THE ACCUSED HANDING THEM A DRIVERS LICENSE
AND THEM CALLING IT IN TO CHECK FOR PRIORS (THAT WILL SHOW UP
IN DISPATCH REPORTS AND OTHER DOCUMENTATION). THESE
KEYSTONE COP EFFUPS HAVE DEFAMED ME AND YOU SPONSORED IT,
CULTIVATED IT, AND SMUGLY TALK SMACK TO ME IN COURT ABOUT
MY NEEDING TO USE THE BATHROOM AND HOW YOU HAVE "HAD TWO
KIDS AND CAN HOLD MY BLADDER" GENDER SEXUAL HARRASSMENT. I
GET EVICTED (WRONGLY, COMMERCIAL LEASES PRECLUDE SUMMARY
EVICTION WHERE NO CAUSE EVICTION NOTICES ARE ALL THAT IS
SERVED) BY THE RICHARD G. HILL GANGBANG EXPRESS, WHILE BEING
ASSAULTED BY NEVADA COURT SERVICES, WHICH LISTS MY COURT
APPOINTED ATTORNEY LEW TAITEL AS "ASSOCIATED WITH" ON THE
NEVADA COURT SERVICES WEB SITE, LEW AGREES TO A CONTINUANCE
OF THE TRESPASS TRIAL BECAUSE RICHARD HILL NEEDS TO GO ON A
VACATION, BUT I CAN'T GET A FUCKING CONTINUANCE WHERE RICHARD
HILL IS APPLYING AN UNLAWFUL RENT DISTRAINT TO MY EVIDENCE TO
DEFEND AGAINST THIS BULLSHIT FUCKING WALMART FIASCO! THEN
AFTER TAITEL AGRESS TO A CONTINUANCE, ONLY THEN AFTER
REVIEWING MY PERSONAL FILE, HE FIGURES OUT I AM SUING HIM, OR AT
LEAST NEVADA COURTS SERVICES. SOMEBODY PUT A NICE
COLLECTION OF VIDEOS UP ON YOUTUBE ABOUT IT, SOME CRAZY
DOCUMENTARY FILMMAKER. YOU OUGHT TO BE ASHAMED.

I CAN GIVE YOU UNTIL TUESDAY, AFTER THAT, I HAVE TO MAKE MY
MOVES AND FILE MY MOTIONS.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
Date: Sun, 4 Dec 2011 03:37:24 -0800
I want you to move for a Rule 59 Motion to Set Aside or some other motion to have the
Judgment Set Aside. Your cop witness clearly had a driver's license produced to him
at the 6:49 mark of YOUR OWN DAMN VIDEO! And you suborned his perjury on
the witness stand in violation of many of the prosecutorial codes you are held to and
NRCP 11. Furher, what are you going to say when the UPC from the alleged receipt
appears on the purchased receipt, in combination with Frontino's adamant assertion that
they wouldn't, in combination with the same from Crawford, in combination with
Frontino admitting he couldn't hear what was said between the accused and the cashier,
in combination with the "same UPC, hit the quanity number" practice common at
Walmart? Further, your own witness admitted on tape at the trial that "he didn't have
before you and Judge Howard could jump in and cut him off. That's gametime. I
will avalanche you with motion and lawsuits if you don't fix this defamation you
funded and supported, what with you little 30 minutes witness coaching session that
kept all the other litigants waiting from 1:00 to 1:30 while you called in Frontino,
Crawford, and Braunworth. Wait till I get the video from Walmart that Frontino is
hiding from you, and don't you just want to know if some audio exists of the
interrogation.

Sincerely,

your cop lying, see your video drivers license produce ap overview at
6:49 mark
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Sun 12/04/11 3:37 AM
I want you to move for a Rule 59 Motion to Set Aside or some other motion to have the
Judgment Set Aside. Your cop witness clearly had a driver's license produced to him
at the 6:49 mark of YOUR OWN DAMN VIDEO! And you suborned his perjury on
the witness stand in violation of many of the prosecutorial codes you are held to and
NRCP 11. Furher, what are you going to say when the UPC from the alleged receipt
appears on the purchased receipt, in combination with Frontino's adamant assertion that
they wouldn't, in combination with the same from Crawford, in combination with
Frontino admitting he couldn't hear what was said between the accused and the cashier,
in combination with the "same UPC, hit the quanity number" practice common at
Walmart? Further, your own witness admitted on tape at the trial that "he didn't have
before you and Judge Howard could jump in and cut him off. That's gametime. I
will avalanche you with motion and lawsuits if you don't fix this defamation you
funded and supported, what with you little 30 minutes witness coaching session that
kept all the other litigants waiting from 1:00 to 1:30 while you called in Frontino,
Crawford, and Braunworth. Wait till I get the video from Walmart that Frontino is
RE: Attached Image / Subpoena
hiding from you, and don't you just want to know if some audio exists of the
interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Tue 11/29/11 4:29 PM
To: ballardd@reno.gov
1 attachment
RMC various walmart subpoenasreno v coughlin 11 cr 22176 2I.pdf (56.9 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Date: Tue, 29 Nov 2011 15:53:46 -0800
From: BallardD@reno.gov
Subject: RE: Attached Image / Subpoena
I am so sorry, I must have misunderstood.
These must be served and the affidavit portion completed before they can be file stamped in.
Thank you,
Donna
To: <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 15:48:31 -0800
Subject: RE: Attached Image / Subpoena
Dear Ms. Ballard,
Thank you sending these and agreeing to stamp and emal them back to me today,
very, very much appreciate.
Sincerely,
Zach Coughlin
email is the best way to contact me, having phone issues today.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
RE: Attached Image / Subpoena
privilege.

Date: Tue, 29 Nov 2011 15:22:14 -0800
Subject: Fwd: Attached Image / Subpoena

From: "MUNI CT 1st Floor Clerks" <canon@reno.gov>
To: "DONNA" <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 16:14:15 -0800
Subject: Attached Image

Donna Ballard
Senior Court Specialist
1 South Sierra Street
Reno, Nevada 89501
(775)334-3101
Donna Ballard
Reno, Nevada 89501
(775)334-3101
Sent: Tue 11/29/11 3:48 PM
To: ballardd@reno.gov
4 attachments
RMC subpoena Ellis Walmart Manager and loss prevention manager.pdf (42.7 KB) , RMC subpoena
Janice store clerk walmart arrest receipt cashier 2nd St. 89501 Walmart.pdf (44.3 KB) , RMC
subpoena Store Manager Brian Bain 2nd st Walmart Reno and LP supervisor 2nd St. 89501
Walmart.pdf (43.3 KB) , RMC subpoena fill in the blank for name stylein city of reno v coughlin 11
cr 22176 2I.pdf (43.7 KB)
Dear Ms. Ballard,
Thank you sending these and agreeing to stamp and emal them back to me today, very,
very much appreciate.
Sincerely,
Zach Coughlin
email is the best way to contact me, having phone issues today.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Date: Tue, 29 Nov 2011 15:22:14 -0800
Subject: Fwd: Attached Image / Subpoena

From: "MUNI CT 1st Floor Clerks" <canon@reno.gov>
To: "DONNA" <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 16:14:15 -0800
Subject: Attached Image

Donna Ballard
Reno, Nevada 89501
(775)334-3101
FW: temporary address change and instruction to pursue a continuance
Sent: Tue 11/29/11 3:14 PM
To: robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may be
punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights under
color of state law and all those other things your office and Hartshorn, et all have been sued for over the years.

Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
Dear Judge Howard,

My apologies Your Honor. I have had an unlawful rent distraint applied to all my
RE: motion for continuance
office equipment and the files necessary to defend this case and produce motions,
incident to a summary eviction stemming from a lease that was at least in part
commercial, had a rent escrow deposit forced upon me in violation of Nevada Law, had
all my computers printers, everything subject to the distraint. I have a netbook it
won't accept a printer and on and on. I apologize. I do note that the RMC rules
allow for filing by facsimile, though I gather not to the fax number listed for yoru
chambers at www.nvbar.org.

Sincerely,
Zach Coughlin,
Sent: Tue 11/29/11 1:33 PM
To: robertsp@reno.gov
Dear Ms. Roberts,

The opposing attorney in the Summary Eviction Proceeding against me in my home law office/business is
asserting a lien against my office, law practice files, and materials necessary to discovery production and
defending the case that you are the prosecutor on. I believe a continuance is absolutely necessary in the interests
of justice. Additionaly, you have been informed that Walmart previous to the arrest in this matter became upset
at the accused and made threats of malicious prosecution and abuse of process incident to the accused questioning
various Wal-mart personnel and managers about Wal-Marts curious practice of remixing and forgetting the
Return Policy stated in writing at Walmart.com (and expressly made applicable to purchases made in Wal-Mart
stores). A manager named "Ellis", though who may have identified himself as "John" and a Loss prevention
associate at the West 7th Street Wal-Mart in Reno allegedly told the accused that they would have him banned
from all Wal-Marts in retaliation for the accused seeking to do something to which he was legally entitled to do,
return and item at a Wal-Mart stores in accordance with Wal-Mart's stated and written Return Policy. There are
other retaliatory aspects to the conducts and statements made by both Wal-Mart and RSIC personnel in this
case.

Additionally, the video "evidence" that you provided is shameful. It consists of two short clips in some Wal-
Mart back room where 5-6 people, including 2 RSIC officers acting under color of state law on land their
employer owns and leases to Wal-Mart attempt to coerce not only a confession, but a consent to search. There
is no audio of the video, at least not the video you provided, that is. Where is the video of the alleged acts?
How you can maintain a case such as this stemming from the accused acts in a store like Wal-Mart, that has
hundreds of cameras and only provide video from some backroom that proves nothing and, in the words of
"Jeannie" the contact person at your office "doesn't show anything", I am not sure, and whether that is violative of
your duties as a prosecutor, Nifong, NRCP 11 (see Schumacher's application of that civil rule to the DA) is not
clear. You have been informed that the RSIC officer committed police misconduct and yet you brazenly
announce in writing that you do not intend to follow up on that, nor do you feel compelled to.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Date: Tue, 22 Nov 2011 07:59:37 -0800
From: robertsp@reno.gov
Subject: RE: motion for continuance
Dear Mr. Coughlin, you will need to file a motion to continue in compliance with Reno Municipal Court procedures. As I
have stated in a previous email, I do not object to your motion to continue, however, it is up to the J udge whether or not he
will grant your motion. Regarding the video which I obtained at your previous court date, I have told you that you can come
to our office and view the video. If you still want a copy, I believe our staff will be able to make one for you. NRS 174.235
does not require me to do more than what I have already done. We have provided you with the reports we have, listed the
witnesses we will call and made the video available to you. Pam Roberts, Deputy City Attorney.
To: <robertsp@reno.gov>
Date: Mon, 21 Nov 2011 13:05:28 -0800
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby shortly hoping
to be provided one. Please respond to me regarding my request from a continuance.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart employee) and
Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the video at the first trial date
from the Walmart employee and it is available for you to view or get a copy. You may want to view it at the City Attorney's
Office as the CD doesn't seem to work on everyone's computer. Penie Colter will be able to assist you. I am not clear
on what you think my duty is, but I know what my duty is and I will not debate it via email. Pam Roberts, Deputy City
Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
Can you tell me who the three witnesses are that showed up on November 14th, 2011
for trial at 1pm? I did obtain a copy of the "discovery" about the second day it was
made available to me from your office in person. At that time, no video evidence
was made available to me. Is there now some video or audio recording to which I
may be provided access? Would you mind just emailing me the names of the
intended witnesses. Do you believe you do not have a duty to make a reasonably
diligent inquiry of either Walmart or RSIC do assess the validity of the matters
mentioned in my last email, ie the retaliatory motive vis a vis Walmart and or the
impermissible search/ 42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error

Date: Wed, 16 Nov 2011 17:12:21 -0800
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
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
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
records request
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.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
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.

Sent: Mon 11/28/11 2:30 PM
1 attachment
RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11-22185.pdf (20.8
KB)
Reno Municipal Court appointment of counsel
Zach Coughlin, 817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Sent: Mon 11/28/11 11:42 AM
To: ltaitel@sbcglobal.net; renomunirecords@reno.gov
Dear Mr. Taitel,
I understand you have been assigned to represent me in the Reno Municipal Court trespass Complaint against
me. Please note that my address has recently changed to:
Zach Coughlin
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

I have recently been evicted and it has caused enormous upheaval to my life, and I am indigent, as such, I believe a continuance is necessary
and ask that you seek one for the December 13th, 2011 "trial" that I only became aware of through calling the Reno Municipal Court. Also,
please provide me a copy of any motions or pleadings you have filed on my behalf and any documentation that you have been provided by the
court, opposing counsel, or anyone else. I prefer such documentation be emailed, but I realize that may not be possible. I would like to
obtain a copy of the Complaint and Discovery, including the probable cause sheets and any witness statements as soon as possible.

Sincerely,

Zach Coughlin
RE: temporary address change and instruction to pursue a continuance
verint user agreement
Sent: Tue 11/22/11 5:22 PM
To: howardk@reno.gov
Dear Judge Howard,

My apologies Your Honor. I have had an unlawful rent distraint applied to all my
office equipment and the files necessary to defend this case and produce motions,
incident to a summary eviction stemming from a lease that was at least in part
commercial, had a rent escrow deposit forced upon me in violation of Nevada Law, had
all my computers printers, everything subject to the distraint. I have a netbook it
won't accept a printer and on and on. I apologize. I do note that the RMC rules
allow for filing by facsimile, though I gather not to the fax number listed for yoru
chambers at www.nvbar.org.

Sincerely,
Zach Coughlin,
Sent: Mon 11/21/11 8:40 PM
Hi Ms. Roberts,
Sorry, don't mean to be a pain, but I DON'T AGREE to this Verint software
policy...its calls for allowign them to inspect my office and paying them for their
inspection fees and all this other stuff that is so unduly oppressive. Its just an AVI
file, its as though they disable it just for the purpose of preventing you from watching
the movie unless you agree to their oppressive, onerous, contract terms, and how does
this benefit taxpayers? Authentication issues can be addressed through the traditional
means, I don't see the value add.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
Sent: Mon 11/21/11 7:18 PM
Ms. Roberts, the opposing attorney's unlawful rent distraint is preventing me from providing all the discovery I
would like to provide you with or ascertain the need to do, and further is preventing me from having access to the
materials and information I need to litigate this case.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Mon, 14 Nov 2011 10:36:45 -0800
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.


Date: Fri, 11 Nov 2011 01:40:53 -0800
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
temporary address change and instruction to pursue a continuance
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.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
privilege.

Sent: Mon 11/21/11 4:06 PM
To: howardk@reno.gov; robertsp@reno.gov

Dear Judge Howard Deputy City Attorney Roberts,

I have been evicted and perhaps subject to an illegal lockout and unlawful rent distraint
by an attorney representing my Beverly Hills High School graduate California
Neurosurgeon landlord, who has spent approx $30,000 in attorneys fees pursuing a
summary eviction, and whose attorney is withholding my state issued indentification,
wallet, and all materials necessary to my law practice all in an unlawful rent distraint
prohibited by NRS 40.460 and 40.520. I am pursuing a continuance of the upcoming
hearing/trial, I cannot even access when that hearing is. I have informed opposing
counsel Roberts of some of the issues which will require extensive discovery, a jury
trial, and more time to afford myself a legitimate opportunity to defend this case. I
have not been served any Order responding to my request for appointment of counsel,
as I believe it is required even if the State does not "intend" to seek jail time, where
any incarceration is a possibility, the Sixth Amendment guarantees it.

Please note that my temporary address for now is:
Zach Coughlin, Esq.
c/o Silver Dollar Motel
817 N. Virginia St., Unit # 2
Reno, NV 89501

The opposing counsel in the summary eviction matter is withholding my phone as
well and refusing to allow me to access any mail that may remain at the property from
those times when the USPS was processing my official Change of Address. Email is
the best way to get in contact with me during this transition period.

For instance, I am unware whether my Motion for Appointment of Counsel was granted
or not. I called Judge Howard's assistant and requested that she email me the docket
in this case and any pleadings or orders filed, including any order that may have
stemmed form any of my previous motions, as I am not sure how those were ruled
on. I believe my internet based fax service will allow me to receive those materials at
my number 949 667 7402, though I would prefer email, but I know many governmental
entities prefer to fax such items. I am requesting a jury trial, a substantial
continuance, and the appointment of counsel. I object to the RMC's practice of
refusing to tell litigants who the 4 "house" appointed defenders are upon questioning.
Further, it has become clear that some of these "former prosecutors" who are now the
gang of four "house" defenders, do not even announce to accused arraignees that they
are, in fact, the defender or an attorney or that they may be representing the
arraignees. I am hereby filing a motion in limine regarding any materials or
information gleaned from the unlawful search by the RSIC Officer, who clearly
announced that they would base their probable cause to arrest and conduct a search
incident to arrest upon any failure to consent to a search by the accused. Further, the
alleged conduct did not occur in the Officer's presence, and I believe there exists
authority preventing a minor misdemeanor arrest and transport under those
circumstances. Additionally, more time is needed to conduct discovery in this matter,
especially in light of allegations that Walmart had previously threatened individuals,
including, perhaps, the accused, with retaliatory action, including illicit abuse of
process, for the purported attempts by someone to have the Walmart Return Policy
enforced, and to hold accountable all Walmart employees and managers, some of whom
have over a decade experience in their positions, who curiously "forget" they Return
Policy Walmart holds out to the public when it is convenient to do so, the same Return
Policy that Walmart used to drive out of business so many competitors. Further, this
case is likely to get extremely complicated given the apparent conflict of interest
stemming from the fact that the Walmart in question is on land owned by the RSIC,
which may own or employ the RSIC police, and which is rented or owned in part by
Walmart.

I know Opposing Counsel Roberts may appreciate a continuance as well and the
opportunity it would afford her to fulfill her NRCP 11 duty and other prosecutorial
duties to conduct a reasonably diligent inquiry into these matters.

Sincerely,
Zach Coughlin
Sent: Mon 11/21/11 1:05 PM
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby shortly hoping to
be provided one. Please respond to me regarding my request from a continuance.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart employee) and
Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the video at the first trial date
from the Walmart employee and it is available for you to view or get a copy. You may want to view it at the City Attorney's
Office as the CD doesn't seem to work on everyone's computer. Penie Colter will be able to assist you. I am not clear
on what you think my duty is, but I know what my duty is and I will not debate it via email. Pam Roberts, Deputy City
Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
made available to me from your office in person. At that time, no video evidence
was made available to me. Is there now some video or audio recording to which I
may be provided access? Would you mind just emailing me the names of the
intended witnesses. Do you believe you do not have a duty to make a reasonably
diligent inquiry of either Walmart or RSIC do assess the validity of the matters
mentioned in my last email, ie the retaliatory motive vis a vis Walmart and or the
impermissible search/ 42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Wed, 16 Nov 2011 17:12:21 -0800
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
Ms. Roberts,
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
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.


Date: Fri, 11 Nov 2011 01:40:53 -0800
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
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
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.

Sent: Thu 11/17/11 3:37 PM
NRCP Rule 11 and duty to make reasonably diligent
inquiry/exculpatory evidence/prosecutors
Dear Ms. Roberts,

I do not mean to suggest you do not know what your duty it. Believe me, I am well aware that you could mop
up the court room with a neophyte attorney such as myself. I was merely hoping to get some direction from you
regarding trial practice approaches in general.

Sincerely,

Zach
Sent: Wed 11/16/11 5:53 PM
Dear City Attorney Kadlic,

I am writing about a criminal matter in Reno Municipal Court pending against myself.
I write inquire as to whether Ms. Robert's statements (included in the email below) are in line with the policy of the Reno City
Attorney's Office with respect to whether Ms. Robert's has any duty to make a reasonably diligent inquiry to ascertain whether some
impermissible actions or motives stem from either Walmart or the RSIC?

I believe both civil and criminal law attorneys in Nevada are subject to NRCP Rule11 and other
rules related to professional responsibility. I know both you and
Nev.,2000, Office of Washoe County Dist. Atty. v. Second Judicial Dist. Court ex rel. County of Washoe, 116
Nev. 629, 5 P.3d 562. The DA absolutely is subject to NRCP 11, and so is Mr. Hylin and the rest of the
WCPD's Office. "In a case brought by the district attorney to enforce a Washington child support order in
Nevada, the district court imposed NRCP 11 sanctions against the district attorney for failing to discontinue
enforcement of the support order after the district court's previous ruling that Washington had continuing exclusive
jurisdiction to adjudicate the arrearage amount." District attorney's office, as a non-party in underlying
proceedings to enforce out-of-state child support order, did not have right to appeal district court's order imposing
Rule 11 sanctions against the office, and thus writ of mandamus was an available remedy. Office of Washoe
County Dist. Atty. v. Second Judicial Dist. Court ex rel. County of Washoe, 2000, 5 P.3d 562, 116 Nev. 629.
District judge abused his discretion in imposing $2,500 sanctions against city manager and city attorney for their
alleged failure to participate in good faith in settlement conference and, therefore, petition for writ of mandamus to
prevent district court from enforcing sanctions would be granted; sanctions levied did not fit purported violations
at issue. City of Sparks v. Second Judicial Dist. Court In and For County of Washoe, 1996, 920 P.2d 1014, 112
Nev. 952.

See Gentile v. County of Suffolk, 926 F.2d 142 (2d Cir. 1991) (holding that a county district attorney's long
practice of ignoring evidence of police misconduct and sanctioning and covering up wrongdoing could make the
county liable); Claude H. v. County of Oneida, 626 N.Y.S.2d 933 (App. Div. 1995) (holding that district attorney's
command that plaintiff be unlawfully arrested could support action against county for false imprisonment).

Nevada Rules of Professional Conduct, Rule 3.8. Special Responsibilities of a Prosecutor.
" The prosecutor in a criminal case shall: (a) Refrain from prosecuting a charge that the prosecutor knows is not
supported by probable cause; (b) Make reasonable efforts to assure that the accused has been advised of the right
to, and the procedure for obtaining, counsel and has been given reasonable opportunity to obtain counsel; (c) Not
seek to obtain from an unrepresented accused a waiver of important pretrial rights, such as the right to a
preliminary hearing; (d) Make timely disclosure to the defense of all evidence or information known to the
prosecutor that tends to negate the guilt of the accused or mitigates the offense, and, in connection with
sentencing, disclose to the defense and to the tribunal all unprivileged mitigating information known to the
prosecutor, except when the prosecutor is relieved of this responsibility by a protective order of the tribunal; (e)
Not subpoena a lawyer in a grand jury or other criminal proceeding to present evidence about a past or present
client unless the prosecutor reasonably believes: (1) The information sought is not protected from disclosure by
any applicable privilege; (2) The evidence sought is essential to the successful completion of an ongoing
investigation or prosecution; and (3) There is no other feasible alternative to obtain the information; (f) Except for
statements that are necessary to inform the public of the nature and extent of the prosecutors action and that
serve a legitimate law enforcement purpose, refrain from making extrajudicial comments that have a substantial
likelihood of heightening public condemnation of the accused and exercise reasonable care to prevent
investigators, law enforcement personnel, employees or other persons assisting or associated with the prosecutor in
a criminal case from making an extrajudicial statement that the prosecutor would be prohibited from making under
Rule 3.6 or this Rule."

Under Brady v. Maryland, 373 U.S. 83, 87 (1963), the suppression by the prosecution of evidence favorable to
an accused ... violates due process where the evidence is material either to guilt or to punishment....United
States v. Shaygan, 661 F.Supp.2d 1289, 1325 (S.D. Fla. 2009) (judge reserved the right to impose any further
sanctions and/or disciplinary measures as may be necessary against [the federal prosecutors] after reviewing the
results of the Justice Departments investigation.); United States v. Jones, No. CR 07-10289- MLW, 2010
WL 565478 (D.Mass. 2010) (court determined that imposition of sanctions against AUSA or government for
failure to adequately train AUSA based on failure to disclose plainly material exculpatory evidence were neither
necessary nor appropriate where, since violation disclosure, AUSA, US Attorneys Office and DOJ officials
took actions such as participating in discovery training programs, which obviated need for sanctions).

Sincerely,

Zach Coughlin, Esq.

Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
made available to me from your office in person. At that time, no video evidence was
made available to me. Is there now some video or audio recording to which I may be
provided access? Would you mind just emailing me the names of the intended
witnesses. Do you believe you do not have a duty to make a reasonably diligent
inquiry of either Walmart or RSIC do assess the validity of the matters mentioned in my
last email, ie the retaliatory motive vis a vis Walmart and or the impermissible search/
42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Wed, 16 Nov 2011 17:12:21 -0800
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
Ms. Roberts,
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
continue.



Date: Fri, 11 Nov 2011 01:40:53 -0800
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
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
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118

Sent: Wed 11/16/11 5:30 PM
Thanks Ms. Roberts,
made available to me from your office in person. At that time, no video evidence was
made available to me. Is there now some video or audio recording to which I may be
provided access? Would you mind just emailing me the names of the intended
witnesses. Do you believe you do not have a duty to make a reasonably diligent
inquiry of either Walmart or RSIC do assess the validity of the matters mentioned in my
last email, ie the retaliatory motive vis a vis Walmart and or the impermissible search/
42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Wed, 16 Nov 2011 17:12:21 -0800
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
Ms. Roberts,
of your duty to provide exculpatory information to ascertain whether the RSIC police
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.

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
continue.



Date: Fri, 11 Nov 2011 01:40:53 -0800
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
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
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118

Sent: Wed 11/16/11 3:35 PM
Ms. Roberts,
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
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.

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
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.



Date: Fri, 11 Nov 2011 01:40:53 -0800
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
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
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
Sincerely,
motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
privilege.

Sent: Fri 11/11/11 1:40 AM
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
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
records request
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.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
Sent: Tue 10/04/11 4:41 PM
2 attachments
RMC subpoena.pdf (67.8 KB) , RECORD_REQUEST_Zach Coughlin to RMC.pdf (20.2 KB)
October 4, 2011
Dear Reno Municipal Court Records Division,
My name is Zach Coughlin. I have now been informed by both the Reno Municipal
Court and the Reno City Attorney's officer, and the Reno Sparks Indian Colony none of
these entities can provide my requested records. You have them, I believe I have a
constitutional right to them. If you feel differently, please explain in writing why that is
the case.
I wish to obtain any and all records available incident to IC110627 at the E. 2nd St.
Walmart by the Reno Sparks Indian Colony Police on or about Saturday October 10th,
2011 at between approximately 9pm and 10:30pm. I want any and all records, video,
audio, paper documentation or otherwise that I have a right to. I am representing
myself. I have sought these records from the Reno Municipal Court's Records Office
and they kept telling me they didn't have them yet and that I should return sometime
soon. Finally, they admitted they do not keep these records and they must be obtained
from your the Reno City Attorney's Office. At the RMC records window I spoke with a
supervisor named Karen. She denied my request for these records today. This delay
has unduly prejudiced my case and I request that you provide these records to me at
once, with no delay, please. The RS Indian Colony Police refused to give me a copy
of these records today when I spoke with Sargent Avansino, who was polite and helpful
otherwise. I believe this case should be dismissed.
Signed electronically and signed in a signed attached PDF. I can come pick the
records up with identification if that is required or I hereby give you permission to
email them to me or mail them to the address below:
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
Zach Coughlin
records request for incident report urgent please
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, 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.
Sent: Tue 10/04/11 3:10 PM
1 attachment
records request to reno city attorneys office oct 4.pdf (66.5 KB)
RenoMuniRecords@reno.gov
Dear Reno City Attorney Records Department.
My name is Zach Coughlin. I wish to obtain any and all records available incident to
an arrest at the E. 2nd St. Walmart by the Reno Sparks Indian Colony Police on or
about Saturday October 10th, 2011 at between approximately 9pm and 10:30pm. I
want any and all records, video, audio, paper documentation or otherwise that I have a
right to. I am representing myself. I have sought these records from the Reno
Municipal Court's Records Office and they kept telling me they didn't have them yet
and that I should return sometime soon. Finally, they admitted the do not keep these
records and they must be obtained from your office. The RSIC Police refused to give
me a copy of these records. This delay has unduly prejudiced my case and I request
that you provide these records to me at once, with no delay, please. I believe this case
should be dismissed.
Sincerely,
Zach Coughlin signed electronically and signed in attached PDF. I can come pick the
records up with identification if that is required or I hereby give you permission to
email them to me or mail them to the address below:
Re: Your Online Police Report T11005956 Has Been Rejected
Zach Coughlin
121 River Rock St.
Reno, NV 89501
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, 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.
From: ZC (zachcoughlin@hotmail.com)
Sent: Fri 9/09/11 12:29 AM
To: coplogicalerts@reno.gov
I want mirandized ever. His report contains voluminous inaccuracies. Cops thretened me with
stuff to coerce divulging my name. Didn't call phone and hear any vibrate as report says.
Baggy clothes terry stop search an obvious pretext. However, cop added an inaccurate statement
on. Top of that pretext to justify actions such as subsequent arrest, ie, said he called
phone and identified it by vibrating. That is not true.
NvRenoPd@coplogic.com wrote:
>****DO NOT RESPOND TO THIS E-MAIL****
>
>
>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,
>Reno Police Department
>
>
From: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Sent: Thu 9/08/11 10:06 PM
Which part of the report was accepted and which was rejected. Which supervisor. Name? Its a battery by duralde
why cant i file a police report about it...tell me that.
From: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Sent: Thu 9/08/11 10:05 PM
What about the others thingsa involving dawson and the hispanic female attacker and zarate

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INDEX OF EMAILS FROM COUGHLIN TO @RENO.

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To: renomunirecords@reno.gov; renodirect@reno.gov

Notice of Appeal and MOtion for....

Date: Mon, 9 J an 2012 17:58:47 -0800

NOTICE OF APPEAL MOTION TO SET ASIDE WITHDRAWAL

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