1

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 1 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Document Code:
Zach Coughlin,Esq.
Nevada Bar No: 9473 (susp).
1471 E. 9
th
St.
Tel and Fax: 949 667 7402
Reno, NV 89512
Pro per suspended attorney.


IN THE SECOND J UDICIAL DISTRICT COURT
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA


Zachary coughlin;

appellant,

vs.
state of nevada;

respondent.
)
)
)
)
)
)
)
)
)
)


Case No: CR12-0376

Dept No: 8

NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY

Coughlin will try to keep this brief, and apologizes for the length of his last filing. Coughlin
is still requesting an englargement of time to file his Reply to Wongs 9/10/13 Opposition. Further,
for judicial economies sake it may be prudent to combine this case into the Petition for Writ Coughlin
is and or has filed as to the 6/18/12 conviction, which, of course, should not stand, for a multitude of
reasons, in addition to the fact that the 8/27/12 Order granting the Citys Motion to Dismiss should be
put asunder. Brahams is one of those cases. Everything sort of just congregated thereinfrom the
receipt concept so integral to the NRS 40.253(5)(a) requirement that a tenant have receipt of the
summary removal order for 24 hours prior to the lockout being conducted by the sheriff or
constable to the NRS 178.482 computation of time standard specifying that NRCP 6(a) and 6(e)
apply.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 2 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Also, especially with respect to cr11-2064 and the 3/15/12 order purporting affirm the rmc
ruling based on Coughlin allegedly failing to cite to the the transcript that the RMC fraudulently
failed to have prepared in the City of Renos con game where they pass an ordinance calling
themselves and NRS 5.010 court of record then fail to repeal those ordinances that conflict with the
requirements under Nevada law for so being a court of record, specifically with respect to NRS
189.030 and 189.035, where even Elliott had to admit NRS 4.14(a) and Brahams application thereof
are just worth mentioning, but not applicable in a criminal setting in his 3/15/12 order affiriming rmc
ruling in cr11-2064. http://www.scribd.com/doc/170863766/3-15-12-2J DC-J udge-Elliott-Order-
Affirming-Ruling-of-the-Reno-Municipal-Court-RMC-Violating-NRS-189-035-J udicial-Misconduct
Also, all this non-sense where RMC J udge W. Gardner, Holmes and Howard, and RJ C J udges
Clifton, Pearson, and Sferrazza openly violate NRS
NRS 189.070 Grounds for dismissal of complaint on appeal. Any complaint, upon motion of the defendant, may be
dismissed upon any of the following grounds:
1. That the justice of the peace did not have jurisdiction of the offense.
2. That more than one offense is charged in any one count of the complaint.
3. That the facts stated do not constitute a public offense.
Furtherm, both 2064 and 1262s complaints should be dismissed as the 11/14/11 complaint in
1262 fails to alleged facts constituting a public offense as there is no warning referenced anywhere
therein sufficient to notice-plead a criminal trespass under rmc 8.10.010, and where in 2064, there
was no jurisdiction established (the City and RMC completely failed to address Coughlins race and
whether he has any tribal blood for that arrest on tribal land by tribal police officers violative of NRS
171.1255 http://law.justia.com/codes/nevada/2010/title14/chapter171/nrs171-1255.html
But, to cut to the chase, this appeal must go forward because, even without a finding that
Coughlins 7/26/12 NRS 176.515 motion was on the newly discovered evidence basis (and Wong
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 3 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
provides no authority for just how such an analysis is conducted, whether it is subjective, objective,
whether a partys titling or mistitling a motion as such is dispositive as to whether such is a motion
for new trial based on newly discovered evidence sufficient to overcome the line of cases (and
there is a definite split in the authority on the point) that indicates an untimely tolling motion fails to
have a tolling effect as to the determination of whether the filing of a notice of appeal was timely.
http://www.scribd.com/doc/153537783/Rmc-Transcript-Rules-in-Violation-of-Nrs-Longioni-Ocrd-
and-Tagged-J big2-Lossy
This Court need not bother with that analysis. Brahams, NRS 178.482, J udge Elliotts own
3/15/12 Order in Cr11-2064 (and where WDCR 3(1) formed the dubious basis for assigning all of
Coughlins criminal cases to J udge Elliott (made all the more dubious by J udge Elliotts patent
misconduct in failing to divulge (never mind disqualify himself) the fact that he is on CAAWs
Executive Board while presiding over Coughlins wrongful termination suit in CV11-01955, where
CAAW is a named co-defendantsuch is tantamount to an NRCP 60(b)(4) void for lack of
jurisdiction basis for setting aside all orders by Elliott therein (and there is some horrid oneslike
granting attorneys fees premised upon Elliotts view of the merits of Coughlins Complaint when
his dismissal order admits it did not get to the merits but rather dismissed on the specious
insufficiency of service of process and or process). WDCR 3(1) does not justify Elliott sinking his
claws in every last criminal matter involving Coughlin (look at the shameful summary incarceration
of then practicing attorney Coughlin on 4/19/12 for 8 days in plain violation of the statutory notice
requirements for such a bail revocation (which is a form of summary contemptthe Lakes Crossing
letter was not an affidavit per NRS 22.030(2), etc, etc.).
Anyways, NRS 189 applies to municipal courts, well, at least to ones that are courts of
record (a de novo trial is required if the RMC is not a court of recordCoughlin can get a straight
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 4 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
answer one way or the other in that regard, ie, whether the RMC is a court of record), NRS
5.071and NRS 189 presents a minefield of problems for the City and the RMC (and coming
attraction, NRS 189.035 procedure when transcript defective makes J udge Elliotts 3/15/12 Order
Affirming Ruling of the RMC in CR11-2064 such clear error to be arguably a manifestation of
judicial misconductThe RMCs failure to abide by NRS 189.030 (Brahams speaks to a petition for
certiorari, which is different than a criminal case and the appeal thereofregardless, NRS 4.14(a)
and Brahams merely speak to whom has to pay for the transcript, (and does not apply to an indigent,
and the RMC never ruled that Coughlin was not indigent, rather, it tried an end run around
Aigersinger by indicating incarceration is not usually seen in similar cases (yet failed to specifically
rule such was not a possibility, and the Sixth Amendment and Aigersinger provide the mere
possibility of incarceration triggers the appointment of counsel) the specifically delineates between
criminal and civil matters in indicating that the preparation in a civil case shall not be ordered until a down
payment is madeie, such preparation must begin in a criminal case regardless, and the RMC grafts such civil rule onto
criminal matters, which is judicial misconduct.they do not absolve the RMCs willful Canon 1 Rule 1.1
violation in failing to abide by the requirements of NRS 189.030 in failing to order the transcript
prepared (especially with the exclusive CCR Longoni
(http://www.scribd.com/doc/153537783/Rmc-Transcript-Rules-in-Violation-of-Nrs-Longioni-Ocrd-
and-Tagged-J big2-Lossy ) hustle being perpetuated by the RMC), and Elliotts 3/15/12 Order
Affirming Ruling in CR11-2064 only compounds the RMCs misconduct in that regard. Coughlin
did not stipulate to anything relative to NRS 189.035, he was denied counsel in the appeal as well,
J udge Hardys 3/8/12 Order Denying indigent Coughlin his IFP veers into 2008 Indigent Defense
Order violative territory as wellThe transcript was defective in that the RMC flat out refused to
order it prepared as it is required to due under NRS 189.030, as such the case must be returned for
retrial in the justice court from whyich it came. Elliotts citation to authority indicating it is
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 5 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Coughlins responsibility to cite to the transcript in his brief is non-sense where the RMC willfully
refused to follow the law as to the preparation of transcript (soda and nuggets on a date with the RMC
apparently, as one doesnt get counsel, doesnt get a transcript, no continuance, doesnt get to even
save their trial notes on their laptop before the handcuffs come out).
And, actually, the pros at the City Attorneys office ran this same motion to dismiss hustle in
cr11-2064. Wheres the Canon 2. Rule 2.15 RMC D Nash Holmes 3/14/12 grievance against
Coughlin alleging violations of (amongst others) RPC 1.1, 1.2, 3.1, 3.3, 3.4, 4.4, 8.4, etc., etc.
especially RPC 3.1 meritorious contentions. In cr11-2064 roberts alleged Coughlins appeal not
timelyyet Howards own 12/15/11 order therein establishes that Coughlins 12/13/11 Motion for
New Trial therein was timely, such is a tolling motion, and regardless, such was double titled as a
notice of appeal anyways. Fine, RCA Roberts alleges she was not present for the additional three
minutes of rendition J udge Howard issue upon having Coughlin brought back into court in cuffs at
8:20 pm on 11/30/11 (at which point J udge Howard announce an NRS 178.476 enlargement (or he
delayed the rendition of his order until after Coughlins 3 day incarceration, either way, and Root
does not preclude that, especially the latter, but, regardless, Root presents no issue at all as to
Coughlins 12/13/11 NRS 176.515 motion for new trialproblem is, that means such order was
made in absentia, and to whatever extent rendition does not require entry the order, notice of
entry of order then becomes required, and the RMC never filed such a notice of entry of
ordermeaning, the 2J DC never rightfully had jurisdiction of cr11-2064, beyond the rubber
stamping of the signature on the 11/30/11 J udgment of Conviction and Court Order issue in cr11-
2064.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 6 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
November 15, 2011: Notice of Setting Bench Trial date of November 30, 2011, in cr11-2064 was
mailed to an outdate address for Coughlin, trial of 11/30/11 void for lack of notice.

December 13, 2011: Coughlins Notice of Appeal, Motion to Vacate and or Set Aside, J CRCP
59, J CRCP 60, Motion for Reconsideration; Motion for Recusal. (NOTE: this is a NRS 176.515
Motion for New Trial regardless of Coughlin invoking NRCP 59, 60, etcsee page 110 of 12/23/11
ROA from RMC in CR11-2064.)
December 15, 2011: Order denying Defendant's Motion to Proceed In Forma Pauperis, Motion for
Publication of Transcript at Public Expense, Motion to Vacate and/or Set Aside, Motion for
Reconsideration and Motion for Recusal.
December 15, 2011: Notice of Denial of Service filed by Reno City Attorney.
December 16, 2011: Defendant Coughlin's Supplemental to Notice of Appeal, Motion to Vacate and
or Set Aside, J CRCP 59, J CRCP 60, Motion for Reconsideration; Motion for Recusal; Motion to
Strike.
December 16, 2011: Defendant Coughlin's Notice of Denial of Service; Opposition City of Reno's
Notice of Denial of Service; Request for Clarification Regarding Deadline for Filing Motion for new
Trial, Other tolling Motions, etc., Application for Deferral or Waiver of court Fees and Cost.
Coughlins 12/16/11 Supplemental Notice of Appeal appealed the 12/15/11 Order Denying
Defenants .Motion to vacate and/or Set Aside (an NRS 176.515 Motion for New Trial, and an
order denying itself is an appealable orderyet the 2J DCs Elliott failed to adjudicate such appeal of
the 12/15/11 Order Denying Coughlins NRS 176.515 Motion for New Trial.
And RCA Wongs attempt to argue that RMC Rule 5 rule related to faxing of, allegedly, just
motions somehow overrides NRS 178.589
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 7 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
How reckless was Wal-Mart in its allegations, especially considering the availability of NRS
178.564. Surely Wal-Mart ought be made to have some skin in the game now that its lies have been
exposed. Same with Hill and Merliss, and the Reno City Attorneys Office. Play with someones law
license and reputation, chickens come home to roost when your lies and misconduct bawk that bawk.

There is no way J ordan v State allows for the RJ C and RMC judges to violated NRS
178.608, .610, .589, WDCR 10, J CRRT 10, J CRRT 2 (RJ C keeps asserting rules applicable only to
civil actions to justify its criminal conduct in refusing indigent criminal defendant Coughlins
filingsJ ustice Clifton abusing contempt power in order Coughlin not to fax the WCDAs Officer
filings, etc.
Note: Cf. Hill v. Sheriff, supra, and Stockton v. Sheriff, 87 Nev. 94, 482 P.2d 285 (1971). Neither is it a case
where the prosecutor willfully disregarded important procedural rules. Cr. Maes v. Sheriff, 86 Nev. 317, 468 P.2d
332 (1970). Nor is this a case where the prosecutor exhibited a conscious indifference to rules of procedure
affecting the accused's rights. Cf. State v. Austin, 87 Nev. 81, 482 P.2d 284 (1971).
Downey v. Sheriff, Clark Cnty., 88 Nev. 14, 15, 492 P.2d 989, 990 (1972) hicks 5 30 12 72 hours
Note: all the changing the rules vis a vis service faxing, deadline for pre-trial motions etc by rmc rjc
skau, Clifton no faxing on 11/27/12, gardner's altering pretrial 15 days and art 4 sec 21 fourteenth amendment,
WestlawNext - 3 full text Citing References for Stockton v. Sheriff, Clark County
WestlawNext - Stockton v. Sheriff, Clark County no juris criminal
J ordan no faxing for coughlin rmc rule 534.020. Writ may be granted by Supreme Court and district courts; when
writ may issue
Citation: NV ST 34.020
Sent On: September 24, 2013
Sent By: A WestlawNext Researcher
Client ID: PATRON ACCESS
Note: Elliott exceeded jurisdiction in his 3/15/12 order in 2064 where NRS 189.030 required him to not opine
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 8 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
upon the RMC's failure to transmit transcript, not to deny based upon Coughlin's alleged failure to
cite to such Braham v. Fourth J udicial Dist. Court
Citation: 103 Nev. 644
Item: 239.Importance and purpose of principle of separation of powers
Citation: 16A Am. J ur. 2d Constitutional Law 239
From: WestlawNext@westlawnext.Com Sent: Tue 9/24/13 12:57 PM To: zachcoughlin@hotmail.Com;
astege@da.Washoecounty.Us; zyoung@da.Washoecounty.Us; wongd@reno.Gov 1 attachment Willmes v Reno Mun
Court.Rtf (263.2 KB) A WestlawNext Researcher sent you content from WestlawNext. Please see the attached file. Item:
Willmes v. Reno Mun. Court Citation: 118 Nev. 831 Sent On: September 24, 2013 Sent By: A WestlawNext Researcher
Client ID: PATRON ACCESS Note: please consider dropping the various prosecutions (and join in seeking to set aside
the convictions) in light of the illegality of the various Administrative Orders and the, at least appearance of impropriety,
attendant to your office's garnering a competitive advantage incident thereto

From: WestlawNext@westlawnext.Com Sent: Tue 9/24/13 12:47 PM To: zachcoughlin@hotmail.Com;
astege@da.Washoecounty.Us; zyoung@da.Washoecounty.Us 1 attachment 178608 Rules of justice courts and district
courts not to be inconsistent with t.Rtf (36.6 KB) A WestlawNext Researcher sent you content from WestlawNext. Please
see the attached file. Item: 178.608. Rules of justice courts and district courts not to be inconsistent with this title Citation:
NV ST 178.608 Sent On: September 24, 2013 Sent By: A WestlawNext Researcher Client ID: PATRON ACCESS Note:
Dear Mr. Young and Mr. Stege, I am writing to inquire with you as to whether you believe your office's countenancing
(and prosecuting based upon) the 12/20/12 Administrative Order 2012-01 in RCR2013-071437, and the 8/14/13
Administrative Order 2013-06 Mr. Stege referenced in court today in RCR2013-072675

N.R.S. Const. Art. 3, 1
1. Three separate departments; separation of powers; legislative review of administrative regulations
sions (1) 178.610.?Where no procedure specifically prescribed court may proceed in lawful manner NV ST 178.610
Effective [See Text Amendments] Enacted Legislation Added by Laws 1967, p. 1458 Citing References (1) Title Date
NOD Topics Type 1. Woerner v. J ustice Court of Reno Tp. Ex rel. County of Washoe 1 P.3D 377, 381 , Nev.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 9 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
CRIMINAL J USTICE - Competency to Stand Trial. Refiling of murder charge against petitioner previously found
incompetent to stand trial was not barred. J un. 05, 2000 - Case Context and Analysis (3) Library References
(3) Courts 78. Westlaw Key Number Search: ?106K78. C.J .S. Courts ?7, 124 To 127.

TITLE 14PROCEDURE IN CRIMINAL CASES
TIME
NRS 178.472 Computation.
NRS 178.476 Enlargement.
NRS 178.478 Motions; affidavits.
NRS 178.482 Additional time after service by mail.

MOTIONS
NRS 178.552 Form; contents.

SERVICE AND FILING OF PAPERS
NRS 178.582 Service: When required.
NRS 178.584 Service: How made.
NRS 178.586 Notice of orders.
NRS 178.588 Filing of papers.
NRS 178.589 Use of facsimile machine.
CALENDARS
NRS 178.592 Calendar of criminal actions: Preparation by clerk.
NRS 178.594 Order of disposing of issues on calendar.
EXCEPTIONS
NRS 178.596 Exceptions unnecessary.
ERROR
NRS 178.598 Harmless error.
NRS 178.602 Plain error.
RECORDS
NRS 178.606 Docket kept by deputy clerk of justice court; contents.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 10 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
RULES OF COURT
NRS 178.608 Rules of justice courts and district courts not to be inconsistent with this title.
NRS 178.610 Where no procedure specifically prescribed court may proceed in lawful manner.
CHAPTER 189 - J USTICE COURTS
PROCEDURE IN JUSTICE COURTS
NRS 189.005 Applicability of other provisions of title.
NRS 189.007 Grounds for dismissal of complaint.
APPEALS TO DISTRICT COURT
Appeal by Defendant
NRS 189.010 Appeal must be taken within 10 days.
NRS 189.020 Notice of intention to appeal: Filing and service; stay of judgment pending appeal.
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court.
NRS 189.035 Procedure where transcript defective.
NRS 189.050 Action to be judged on record.
NRS 189.060 Grounds for dismissal of appeal; enforcement of judgment.
NRS 189.065 Dismissal for failure to set or reset appeal for hearing.
NRS 189.070 Grounds for dismissal of complaint on appeal.





Also, the extremely dubious meeting between RCA Hazlett, RMC J udge W. Gardner, and
Coughlins then co-counsel Loomis, as all three admit to, the morning of the 4/10/12 trial date/motion
hearing, without any advance notice to Coughlin whatsoever thereof (Coughlin was a license attorney
at such point whom filed a notice of appearance, substitution in as co-counsel, as such RMC J udge
W. Gardner had absolutely not right to preclude Coughlin from so appearing or choosing himself as
his counsel) requires a mistrial.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 11 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Courts have held that the constitutional or statutory rights of an accused are infringed where
he or she is excluded or absent when the court and attorneys are discussing questions of law. Wilson
v. State, 212 Ga. 73, 90 S.E.2D 557 (1955); Webb v. State, 161 Tex. Crim. 442, 278 S.W.2D 158
(1955).

J udge Stiglichs Orders in CR12-2025, CR12-1262, CR11-2064, etc. apparently denying
Coughlins Motion for Writ may conceivably be asserted as an Order denying a post-conviction
petition for writ of habeas corpus or something similar.
Coughlin filed Notices of Appeal of such Orders, though its not entirely clear what they are
denying, and the effect of such on the 2J DCs filing offices Unit Manager Michelle Purdy and Asst.
Clerk of Court J ulie Wise (whom dodged Coughlins SCR 110 subpoena in 62337 and should be held
in contempt in light thereof) refusal to file in multiple different submission by Coughlin over since
the 11/30/11 conviction in cR11-2064, including one on 7/22/13 that apparently remains, apparently
unfiled, and which Coughlin characterized to J udge Stiglich at an 8/19/13 status conference as a
desperate act by Coughlin that the 2J DC was committing a criminal violation in refusing to file in
(Purdy continues her wanton assault on WDCR 18, apparently with no remonstrance by either J udge
Stiglich or Chief J udge Hardy). (1) The notice of appeal appeared to be untimely as to the order
denying a post-conviction petition for a writ of habeas corpus, see NRS 34.575(1);
The RMC refused to allow Coughlin to inspect the 11/30/11 J udgment of Conviction and Court Order as well
as the 11/30/11 Order Punishing Summary Contempt at all, much less in the clerks office. In fact, the RMCs Ballard
and others therein have informed Coughlin repeatedly that his files are located in the various departments his cases are in
and remain there and that Coughlin will not be able to view them through the Clerks office. Coughlins requests to view
such with the Departments go unresponded to. The Administrative Order 2013-01 forbids Coughlin to even call or speak
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 12 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
with any individual employee of the RMC other than Marshals, much to the prejudice of not only Coughlins defense in
criminal prosecutions, but in 62337 and the formal disciplinary matter at issue therein.
A judgment is entered or recorded only when the document is filed for public inspection in the clerk's
office. See State v. Petrich, 94 Wn.2d 291, 616 P.2d 1219 (1980) (criminal cases).
In a non-jury trial, the J udges verdict is his or her finding of the facts. 46 Am.J ur.2d Judgments 4 (1969).
However, a judgment is the determination or sentence of the law, pronounced by a competent judge or court, as the
result of an action or proceeding instituted in such court, affirming that, upon matters submitted for its decision, a legal
duty or liability does or does not exist. State v. Siglea,196 Wn. 283, 82 P.2d 583; State v. King, 18 Wn.2d 747, 140 P.2d
283.
In re Clark, 24 Wn.2d 105, 110, 163 P.2d 577 (1945). See generally 46 Am.J ur.2d Judgments 4, 8 (1969).
Further, there is no judgment in a criminal case until sentence is pronounced. In re Clark, supra; State v. King, 18
Wn.2d 747, 140 P.2d 283 (1943); State v. Siglea, 196 Wn. 283, 82 P.2d 583 (1938). The failure to file a judgment and
sentence means there has been no final adjudication of a case, Malott v. Randall, supra; Thompson v. Seattle Park
Co., 94 Wn. 539, 162 P. 994 (1917).
.A. Motions for new trial. NRS 176.515 B. Motions to arrest judgment. NRS 176.525 C. Post-conviction motions
for a judgment of acquittal. NRS 176.165. D. Post-conviction motions to withdraw pleas. NRS 176.165 E. Motions to
correct illegal sentences. NRS 176.555

2J DC J udge Elliots 3/15/12 CR11-2064 (conviction at issue in 60838 and 62337) reads: ORDER DENYING
MOTION TO DISMISS APPEAL Pursuant to NRS 189.010, An appellant has ten days following the entry of a
judgment of conviction to file a notice of appeal.... That J udge Elliott referenced the entry of judgment of such
judgment of conviction is important, as it alters any apparent import of the use of the term rendition anywhere in
NRS 189 and NRS 178.
Coughlin is entitled to Reply on J udge Stiglichs predecessor the consolidation of of Coughlins
criminal matter in one department, J udge Elliotts statement of how such will apply NRCP to criminal law:
http://www.scribd.com/doc/169383303/3-15-12-0204-22176-2064-Order-Denying-Motion-to-Dismiss-
Appeal-Applying-NRCP-6-e-Ocr-No-Numbers (see page 2 of such 3/15/12 Order in CR11-2064: Pursuant to
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 13 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
NRS 189.010, An appellant has ten days following the entry of a judgment of conviction to file a notice of appealAs
applied to the instant case, Respondent reasons that because Appellant filed his appeal more than ten calendar
days after the entry of judgment, Appellant's appeal is untimely. Respondent's approach ignores Nevada Rule
of Civil Procedure 6(a), which governs the computation of time. That rule provides that "[w]hen the period
of time prescribed or allowed is less than 11 days, intermediate Saturdays, Sundays, and nonjudicial days
shall be excluded in the computation." NRCP 6(a). In other words, NRS 189.010'S ten day rule does not refer
to calendar days, but is calculated based on the passage of judicial days. Thus, Appellant had until December
14, 2011 to file his Notice of Appeal. Because Appellant filed his Notice of Appeal on December 13, 2011, his
appeal was timely and this Court will deny Respondent's Motion to Dismiss.)
Such pronouncement by J udge Elliott operates to make the 6/26/12 filing by Coughlin timely: Courts of appeal
have occasionally excused untimely filings in "unique circumstances."52 Under the "unique circumstances" doctrine, a
late appeal may be deemed timely by the court of appeals "only where a party has performed an act which, if properly
done, would postpone the deadline for filing his appeal and has received specific assurance by a judicial officer that
this act has been properly done."53 Such a situation is most likely to arise when a party was late in filing a motion which
will toll the appeal period under Fed. R. App. P. 4(A)(4)(A), but the trial court has assured the party that the motion was
accepted as timely. Under such circumstances, the court of appeals may permit the filing of a notice of appeal at a time
that would have been proper when treating the tardy trial court motion as if it had been timely filed.54...
50. Fed. R. App. P. 4 And 26(b). See also Torres v. Oakland Scavenger Co., 487 U.S. 312, 315 (1988). 51.
Hernandez-Rivera v. Immigration & Naturalization Serv., 630 F.2D 1352, 1354 (9th Cir. 1980), Citing United States v.
Robinson, 361 U.S. 220, 229 (1960).
Footnotes: 52. The "unique circumstances" doctrine has been criticized in the Seventh Circuit. See Fogel v.
Gordon & Glickson, P.C., 393 F.3D 727, 731-32 (7th Cir. 2004). 53. Osterneck v. Ernst & Whinney, 489 U.S. 169, 179
(1989). 54. The Seventh Circuit seems to have further narrowed the availability of relief, stating that "[i]n our view, the
unique circumstances exception is available only when there is a genuine ambiguity in the rules to begin with, and the
court resolves that ambiguity in the direction of permitting additional time to appeal." Prop. Unltd., Inc. V. Cendant
Mobility Serv., 384 F.3D 917, 922 (7th Cir. 2004)...

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 14 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Also, its not exactly clear that pursuant to NRS 5.010 the RMC is a court of record. If it is not, then its a de
novo trial that is required, period, and the 3/15/12 Order Affirming Ruling of the RMC in cr11-2064 must be set aside.
Further, the Reno Municipal Code is violates the Art 4 Sec 21 of the Nev Const. where it purports to override
and alter NRS 189.030 and NRS 189.035, not to mention NRS 178.589. Its a slippery J ordan v. State the RMC and RJ C
J udges are going down, full of separation of powers concerns, loss of judicial immunity where pursuing a prosecutorial
function themselves, and willfully exceeding their jurisdiction, etc., et. Plus 2J DC J udge Elliots 3/15/12 Order
Affirming in Cr11-2064 failed to comply with NRS 189.050 Action to be judged on record. An appeal duly
perfected transfers the action to the district court to be judged on the record.
[Part 1911 Cr. Prac. 666; RL 7516; NCL 11313](NRS A 1979, 1512)
J udge Elliots 3/15/12 Order Affirming Ruling of the RMC in cr11-2064 indicates, wrongfully,

Although Appellant's arguments on appeal are unclear, Appellant raises a wide variety of issues, including, inter
alia: that he was denied his Sixth Amendment Right to Counsel, that the Municipal Court erred in failing to grant him a
continuance, that the prosecution engaged in misconduct, that he was refused an opportunity to testify on his own behalf,
that certain evidence should have been suppressed pursuant to the Fourth Amendment of the United States Constitution,
that his conviction is not supported by sufficient evidence, and that "[f]urther improprieties and due process deficiencies"
occurred.
Unfortunately, Appellant neither supports his arguments with relevant authority nor citations to relevant
portions of the record. Most importantly, Appellant has failed to provide this Court with a copy of the transcript of
relevant proceedings in the Reno Municipal Court. The Nevada Supreme Court has held that an "[a]ppellant has the
ultimate responsibility to provide this court with 'portions of the record essential to determination of issues raised in
appellant's appeaL'" Thomas v. State, 120 Nev. 37 N. 4, 83 P.3D 818 (2004) (citing NRAP 30(b)(3). Further, NRAP
28(e) provides that "[e]very assertion in briefs regarding matters in the record shall be supported by a reference to the
page of the transcript or appendix where the matter relied on is to be found." While Appellant did provide this Court
with a Compact Disc containing a recording of the Municipal Court proceedings, Appellant did not cite to the portions
of the Compact Disc that he felt supported his arguments, and it is not the responsibility of this Court to guess which
portions of the Compact Disc might support Appellant's arguments. In short, Appellant did not satisfy his responsibility to
supply and cite to relevant portions of the record merely by producing a Compact Disc recording of the entire Municipal
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 15 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Court proceeding. In light of Appellant's failure to provide this Court with an adequate appellate record, and Appellant's
correspondent failure to cite to such a record, this Court is unable to conduct a meaningful review of Appellant's appeal.
Thus, Appellant has failed to meet his burden in providing an adequate appellate record, and this Court must affirm the
ruling of the Reno Municipal Court.! NOW, THEREFORE, IT IS HEREBY ORDERED that the ruling of the Reno
Municipal Court is AFFIRMED. IT IS FURTHER ORDERED that this matter is remanded back to the Reno Municipal
Court for all further proceedings. /s/ Steven P. Elliott, District J udge
Which ruling? Coughlin appeal three different rulings, the 11/30/11 J udgment of Conviction and Court
Order.the 11/30/11 Order Punishing Summary Contemptand the 12/15/11 Order denying Defendant's Motion to
Proceed In Forma Pauperis, Motion for Publication of Transcript at Public Expense, Motion to Vacate and/or Set Aside,
Motion for Reconsideration and Motion for Recusal.
Further, Thomas v. State does not even apply to what J udge Elliotts purports it to: As a preliminary matter,
we note that Thomas's counsel did not adequately cite to the record in his briefs or provide this court with an adequate
record.
3

4
4





Uh, hes crafty. Its just that J udge Elliott is not that ethical, some might say. Puttin in big work for the
City of Reno and RMC in excusing their fraudulent end run around NRS 5.010s uncomfortable confluence with NRS
189.030, and NRS 189.035 and the big bidness that overlooking that awkward Indian colony tribal police wal-mart petty
larceny accusations fourth amendment violations roller coster that Pamela Roberts, Esq. finds so profitable, right Dan
Wong?
Andwait..NRAP? What up wit that? So, waitElliott indicates NRCP 6(a) applies in his 3/15/12 Order
Denying RCAs Motion to Dismissbut in his 3/15/12 Order Affiriming Ruling of the RMC in cr11-2064 he identifies
NRS 189.010 as running from entry of judgment which is different than rendition of judgmentand the RMCs own
rules indicate one cannot file by fax after 4:30 pm, and not after the posted closing time, apparently when not filing by
fax.regardless. the rubber stamped signature on the 11/30/11 J udgment of Conviction fails to sat9isfy the entry of
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 16 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
judgment requirement. Where is the five page limit for your briefs found in NRAP? Its 30 pages in NRAP. And
even in the WDCRs the five page limit is only in civil appeals. Courts and judges and court staff in Washoe County
really dont get it. When something involves a liberty interest (like ones freedomor even a Fourteenth Amendment
right like a law licenseits different than a lawsuit between two businesses fighting about widgets (not that thats not
important too, but)\
If NRAP applies to appeals from the RMC or RJ C to 2J DCthen Coughlins 3/26/12 filing is the functional
equivalent of a petition for rehearing or something similarbut its really not very clear that NRAP applies
Additionally, the order at page 193 (the 5/8/12 Notice Setting Hearing which, just like the Orders flowing from
the 4/10/12 trial/motion hearing, are void as they were violative of NRS 178.405, Marsden, Stankewitz, etc. ) of the
7/25/12 roa in 1262 from the roa demonstrates rmc judge w. gardners continual violations of NRS 189
0510812011 ADDITiONAL CASE INFORMATION: NO MOTIONS WILL BE NOT ACCEPTED BY FAX
FROM DEFENDANT OR CITY ATIURNEY. ALL PRE TRIAL MOTIONS MUST BE FILED 15 DAYS PRIOR TO
TRIAL DATE OF 6-18-12 IN PERSON BY ALL PARTIES. 0510812011 ADDmONAL CASE INFORMATION:
PROCEEDINGS NO LONGER SUSPENDED, DEFENSE ATTORNEY TO OBTAIN WRITTEN ORDER FROM
DISTRICT COURT FINDING DEFENDANT COMPE1ENT PRIOR TO TRIAL DATE 03/0511012 MISe NOTES:
SENDING MOTION UP TO 0-2 VIA BLACK FOLDER. TinS IS HIS 2ND REQUEST FOR SAME MOTION TODAY.
0411012012 ADDmONAL CASE INFORMATION: PROCEEDINGS SUSPENDED UNTIL COMPETENCY EV AL
HAS BEEN COMPLETED IN DISlRICT COURT MATTER 03/0512012 MISC NOTES: D-2 HAS FILE. SENDING
MOTION UP TO DEPT VIA BLACK F

83 P.3d 818, 822 n.4 (2004)
737. Form and contents of judgment West's Key Number Digest West's Key Number Digest, Criminal Law
k990.1 Forms Federal Procedural Forms 20:926, 20:297 (judgment and statement of reasons in criminal case) Federal
Procedural Forms 20:932 et seq. (J udgments and particular sentences) Under the Federal Rules of Criminal Procedure,
a judgment of conviction must set forth the plea, the verdict or findings, the adjudication, and the sentence.[FN1] If the
defendant is found not guilty or for any other reason is entitled to be discharged, the court must so order.[FN2] Similar
requirements may be imposed by state law.[FN3] It is generally not necessary that the offense be described with technical
precision or that the particular statute that defines the offense and prescribes the penalty be specified,[FN4] as the nature
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 17 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
of the offense may be discerned by reference to the rest of the record.[FN5] [FN1] Fed. R. Crim. P. 32(K)(1). [FN2] Fed.
R. Crim. P. 32(K)(1). [FN3] Palmer v. Com., 269 Va. 203, 609 S.E.2D 308 (2005). [FN4] In re Clark, 24 Wash. 2D 105,
163 P.2D 577 (1945). [FN5] Borders v. Alexander, 183 Or. 488, 194 P.2D 414 (1948)..... 738. Entry of judgment West's
Key Number Digest West's Key Number Digest, Criminal Law k994(1) to 994(4) Guilty pleas or verdicts become
convictions only after the judgment is recorded.[FN1] The rendition of a sentence or judgment is the judicial act, as
distinguished from the entry of the judgment, which is a ministerial act.[FN2] While the general rule is that a sentence is
not entered until it has been reduced to writing and signed by the court,[FN3] and there is some authority that a judge may
modify the sentence before entry of the judgment,[FN4] it has also been held that a judge is not authorized to increase an
orally pronounced sentence,[FN5] and doing so violates the defendant's right to be present at sentencing.[FN6] There is
still other authority that the judgment and sentence do not derive their effectiveness from the journal entry, but are
effective when pronounced,[FN7] and if a written sentencing order is inconsistent with the trial court's oral
pronouncement, the oral pronouncement controls.[FN8] Observation: While primarily ministerial, docket entries mark
critical dates for appeal and other post-judgment procedures.[FN9] Under the Federal Rules of Criminal Procedure, the
judgment must be signed by the judge and entered by the clerk.[FN10] However, there is state authority that the validity
of a judgment is not affected by the trial judge's failure to sign the minutes of the court[FN11] or a draft order.[FN12] A
court may correct a criminal judgment nunc pro tunc,[FN13] and its failure to do so indicates that a claimed omission was
not merely a result of a clerical mistake.[FN14] CUMULATIVE SUPPLEMENT Cases: Where orally-imposed sentence
conflicts with written judgment, court of appeals generally remands and directs the court to amend the written judgment
to conform to the oral pronouncement; however, if there is merely an ambiguity between the oral and written sentences,
court of appeals reviews the entire record to determine the sentencing court's intent. U.S. V. Garcia, 604 F.3D 186 (5th
Cir. 2010). Trial court was obliged to execute a written sentencing document that conformed to the oral pronouncement of
sentence, notwithstanding its concern that the originally announced sentence was illegal. Odum v. State, 74 So. 3D 1098
(Fla. Dist. Ct. App. 5Th Dist. 2011). Oral pronouncement of sentence, crediting defendant with credit for 461 days served,
"plus any and all Florida state time" would control over written sentence that granted credit for 461 days served without
mentioning "any and all Florida state time." Allwine v. State, 42 So. 3D 291 (Fla. Dist. Ct. App. 4Th Dist. 2010). In a
criminal case, the judgment and sentence are effective upon pronouncement from the bench. State v. Howard, 287 Kan.
686, 198 P.3D 146 (2008). A journalized entry is merely a record of the sentence imposed, and the actual sentencing
occurs when the court pronounces the sentence from the bench. State v. Howard, 287 Kan. 686, 198 P.3D 146 (2008). The
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 18 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
oral pronouncement of sentence is the legally effective sentence. State v. Clark, 2008 MT 317, 346 Mont. 80, 193 P.3D
934 (2008). An orally pronounced sentence does control over the written judgment; however, if the verbal sentence is not
clear, the intent of the sentencing court may be construed from the entire record. Brant v. South Dakota Bd. Of Pardons
and Paroles, 2012 SD 12, 809 N.W.2D 847 (S.D. 2012). It is the pronouncement of sentence that is the appealable event,
and the written sentence or order simply memorializes it and should comport therewith. Vernon's Ann.Texas C.C.P. Art.
42.01, 1; Art. 42.03, 1(A). Keys v. State, 340 S.W.3D 526 (Tex. App. Texarkana 2011). [END OF SUPPLEMENT]
[FN1] State v. Hoelzel, 639 N.W.2D 605 (Minn. 2002). [FN2] Ainsworth v. State, 367 Ark. 353, 2006 WL 2781356
(2006); State v. Harbour, 240 Iowa 705, 37 N.W.2D 290 (1949). [FN3] Hewitt v. State, 362 Ark. 369, 208 S.W.3D 185
(2005); State v. Wright, 904 P.2D 1101 (Utah Ct. App. 1995). [FN4] Bradford v. State, 351 Ark. 394, 94 S.W.3D 904
(2003). [FN5] Harp v. State, 228 Ga. App. 473, 491 S.E.2D 923 (1997). [FN6] 744. [FN7] U.S. V. Werber, 51 F.3D 342
(2d Cir. 1995) (Written entry is just evidence of the judgment); Love v. State, 280 Kan. 553, 124 P.3D 32 (2005). [FN8]
State v. Thompson, 750 So. 2D 643 (Fla. 1999). [FN9] Lyles v. U.S., 920 A.2D 446 (D.C. 2007). [FN10] Fed. R. Crim. P.
32(K)(1). [FN11] State v. Atkins, 242 N.C. 294, 87 S.E.2D 507 (1955). [FN12] J efferson v. Com., 269 Va. 136, 607
S.E.2D 107 (2005). [FN13] Ainsworth v. State, 367 Ark. 353, 2006 WL 2781356 (2006). [FN14] Rose v. Commonwealth,
265 Va. 430, 578 S.E.2D 758 (2003).
Instead, J udge Elliott blamed the RMCs willfull failure to comply with NRS 189.030, and 189.035, and the
Reno Municipal Codes attempt to sneak into law the policies detailed in the CCR Pam Longoni handout given to
Coughlin and all others appealing their conviction in 2011 and 2012 in the RMC, which is patently in violation of Nevada
law.
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.
[1911 Cr. Prac. 664; RL 7514; NCL 11311](NRS A 1973, 631; 1979, 1512)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 19 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
NRS 189.035 Procedure where transcript defective.
1. Except as provided in subsection 2, if the district court finds that the transcript of a case which was
recorded by sound recording equipment is materially or extensively defective, the case must be returned for retrial in the
justice court from which it came.
2. If all parties to the appeal stipulate to being bound by a particular transcript of the proceedings in the
justice court, or stipulate to a particular change in the transcript, an appeal based on that transcript as accepted or changed
may be heard by the district court without regard to any defects in the transcript. (Added to NRS by 1979, 1512)
Elko knows it has to repeal all ordinances that are in conflict the laws of the State of Nevada if it wants to enact
an ordinance under NRS 5.010 pronouncing its municipal court a court of record.

The RMC wants to have its cake and eat it to, and wrecked coughlins law career in the process, and now it and
the Reno City Attorney want to play coverup because they have built up this beast that needs to be fed (three marshals
standing around during Coughlins last hearing, two judicial assistants, budget crisis whatever, J udge Howard keeping at
least six staff on overtime until 8:30 pm on 11/30/11 to run his ego trip.
http://www.ci.elko.nv.us/administration/Agenda/V-D%20-%20719.pdf


https://law.resource.org/pub/us/code/city/nv/Reno,%20NV%20%23%20Republication%20thru%20Supp%20%23%2026.
pdf
Reno MUNICIPAL COURT
GENERAL PROVISIONS
NRS 5.010 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.
[35:19:1865; B 940; BH 2454; C 2535; RL 4855; NCL 8397](NRS A 1983, 899; 1985,
671; 1991, 161)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 20 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY


Sec. 2.16.040. Court of record; recording.
The Reno Municipal Court is hereby designated as a court of record in accordance with NRS
5.010. Proceedings in the municipal court may be recorded by any method recognized by the
Nevada Supreme Court.
(Ord. No. 4199, 1, 3-24-92)
Editors noteOrd. No. 3099, 1, adopted J une 27, 1983, repealed former 2.16.040
2.16.060, concerning the office of the marshal, which sections derived from Code 1966,
2.32.0102.32.030.
Sec. 2.16.050. Recording; operation of equipment; transcription of
recordings; use of transcript.
(a) Each judge shall appoint a suitable person, who need not be a certified shorthand reporter
and may have other responsibilities in the court to operate the recording equipment. The
person so appointed shall subscribe to an oath that he or she will so operate it as to record
all of the proceedings.
(b) The municipal court may designate any certified person to transcribe the recording into a
written transcript. The person so designated shall subscribe to an oath that he or she has
correctly transcribed it. The transcript may be used for all purposes for which transcripts
are used and is subject to correction in the same manner as other transcripts.
(Ord. No. 4199, 1, 3-24-92)
Sec. 2.16.060. Recording; preservation; destruction.
The recording of each proceeding in municipal court must be preserved until at least 30 days
after the time for filing an appeal expires. If no appeal is taken, the judge may order the
destruction of the recording at any time after that date. If there is an appeal to the district court,
the recording must be preserved until at least 30 days after final disposition of the case on
appeal. The municipal court may order the destruction of the recording at any time after that
date.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 21 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
(Ord. No. 4199, 1, 3-24-92)
Sec. 2.16.070. Filing of appeals.
An appeal in a civil or criminal case must be taken and perfected in the same manner as the
same type of appeal from the justice's courts, as provided in the Nevada Revised Statutes.
(Ord. No. 4199, 1, 3-24-92)
Sec. 2.16.080. Recording; payment of fees.
(a) The fees for transcripts, processing an appeal, and copies must be paid by the party
ordering them in accordance with the municipal court procedures.
(b) In a civil case the preparation of the transcript need not commence until the fees have been deposited.
(c) In a civil case, upon a finding of a party's indigency by the court, such fees shall be waived
or paid by the court.
(Ord. No. 4199, 1, 3-24-92)
Sec. 2.16.090. Transmission of transcript, other papers, recording
and copy of docket to district court.
(a) The court shall transmit to the clerk of the district court the recording and/or transcript of
the case, all other papers relating to the case and a certified copy of his or her docket in
accordance with the Nevada Revised Statutes, District Court Rules, and the Washoe
County District Court Rules.
(b) The judge shall give notice to the appellant or his or her attorney and to the other party that the recording
and/or transcript, all other papers relating to the case, and a certified copy of
the docket have been filed with the clerk of the district court.
(Ord. No. 4199, 1, 3-24-92)

So, Reno Municipal Code Sec 2.16.080 becomes pretty important, huh? Sec. 2.16.080. Recording; payment of
fees.
(a) The fees for transcripts, processing an appeal, and copies must be paid by the party
ordering them in accordance with the municipal court procedures.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 22 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
This is true, especially considering that the RMC provided Coughlin in obstructing his attempts to get the
transcript made and even to obtain a copy of the audio from this alleged court of record a handout on RMC letterhead
that reads: RENO MUNICIPAL COURT
TRANSCRIPTS ON APPEAL/OTHERS
If you wish to order a transcript of your proceedings in the Reno Municipal Court, you
may do so by contacting Pam Longoni at (775) 530-5251.
The following information is provided to assist you in placing an order for a transcript:
I. Orders will require the date of the court appearance, type of proceeding, (trial,
arraignment, etc.), department number in which the proceeding was held, and also
include the appropriate deposit as indicated below. Payment may be made by check or
money order. No transcript will be prepared until the required deposit is received.

3. Deposits. Deposits required are as follows: $75.00 for arraignment/sentencing; a
minimum deposit of$200.00 for any trial transcript; and a minimum deposit of$500.00
for very lengthy trials (those lasting more than three hours). NO TRANSCRIPT IS
CONSIDERED TO BE OFFICIALLY ORDERED, AND COMMENCEMENT OF
TRANSCRIPTION WILL NOT BEGIN, UNTIL RECEIPT OF THE REQUIRED
DEPOSIT.
5. Questions. Pan Longoni will be happy to answer any questions you may have
regarding the above information.
P.O. BOX~cn,l, Nevada 89505 (715) 3342290, Fax (775) 3343824

See how the City of Calient deals with it: http://nvcmedia.com/cityofcaliente/wp-
content/uploads/2012/04/ORDINANCE-140.pdf
Yet, the RMC and the City of Reno whether in print or off the record as practical matter, continue to violate
Nevada law
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 23 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
And Boulder City gets into the act:
http://webcache.googleusercontent.com/search?q=cache:http://weblink.bcnv.org:81/PUBLICWEBLINK/0/doc/12875/Pag
e1.aspx
December 8, 1999

TO:

J ohn Sullard, City Manager
Mayor Ferarro and Members of Boulder City Council
Victor L. Miller, Municipal J udge
J udi Bourbeau, Court Administrator

Dave Olsen, City Attorney>G.0

c::........

FROM:

REGARDING:

Proposed Ordinance Designating the Municipal Court of the City of
Boulder City as a Court of Record

---------------------------------------------------------------------
---------------------------------------------------------------------

Backeround:

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 24 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
Shortly after beginning my service as City Attorney, I was dismayed to discover that our
Municipal Court was not a court of record. In our Municipal Court, once a matter is tried before
the J udge and a judgment is entered, the defendant has ten days within which to file an appeal. If
the defendant files the appeal within the time frame, the matter is referred to District Court in Las
Vegas and is treated as a trial de novo (new trial). In essence, every defendant can go to trial in
Municipal Court and ifhe or she loses, an appeal means a brand new trial. In some jurisdictions,
although I haven't experienced it here yet, defense counsel use the Municipal Court as a "dress
rehearsal" for the trial they plan to put on in District Court.

The above process is costly, both in resources and time.

An alternative is to designate the Municipal Court as a court of record. Then, if a defendant
appeals, there is no trial de novo. The District Court considers the transcript of the case in
Municipal Court and determines if the defendant received ajust and procedurally proper trial.
The defendant doesn't get a "second bite of the apple." NRS 5.010(2) states, in pertinent part,
that a municipal court "may by ordinance be designated as a court of record."

There are some logistical aspects that must be worked out in changing to a court of record, such
as how the Municipal Court will maintain a legally valid record. There are also incidental costs
associated with the change, such as recording and transcription equipment and the cost of hiring
someone to actually do the transcription in those cases that actually go to appeal.

In my personal experience, once we designated the Ely Municipal Court as a court of record, the
number of appeals dropped off dramatically. I would guess that Boulder City could realize
savings of several thousand dollars in the first year after the change.

"Clean Green Boulder City"
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 25 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
But Reno just has to try to have its cake and eat it to, huh? J ust like in the MIrch v. State Bar of Nevada Case
wherein the attacked attorney complained about the same Reno City Attorney Don Christensen whose misconduct
contributed to the SCR 110 subpoena dodging by the RMC J udges, and a void order by one lacking jurisdiction to rule on
it, where he ruled on it ex parte in 62337Christensen failed to recuse himself from Mirchs screening panel where
MIrch was representing some client developers who alleged the city of reno lost or couldnt find money that had been
given to it to develop parkssort of along the lines of hey, I knowlets pass an ordinance calling ourselves a court of
record thereby avoiding those de novo trialsthen we will cheat around the actual requirements of being a court of
record including this nifty hustle with Pam Longoni where we violate Nevada law in apply the down payment or deposit
only permissible in civil cases to criminal cases! Deal? Lets hire some more Marshals and get more luxury sedans for o
urselves! Score! Oh, man, I feel great, Im going to celebrate by typing up another hit piece grievance letter against some
solo practitioner for the State Bar. City Bidness is Family Bidness and Family Bidness is City BidnessI love you guys!
Allison Ormaas, you too Chrissy HazlettRoberto Puentes is my teddy bearlets call a secret meeting with the judge
and Keith Loomis before the trial to get our lines down, okay? something like that
http://www.thelaw.com/forums/showthread.php?t=49800
1. [PDF]
11-36708 - Case Search
caseinfo.nvsupremecourt.us/document/view.do?csNameID...
Feb 19, 2011 - I first express my appreciation for the efficiency and hard work put in by the Official
Court Records. Subcommittee in developing a Standard of ...
https://docs.google.com/viewer?url=https%3A%2F%2Flaw.resource.org%2Fpub%2Fus%2Fcode%2Fcity%2Fnv
%2FReno%2C%2520NV%2520%2523%2520Republication%2520thru%2520Supp%2520%2523%252026.pdf
ADKT 4110 J udge Ken Howard, Reno Municipal Court I first express my appreciation for the efficiency and
hard work put in by the Official Court RecordsSubcommittee in developing a Standard of Operation and Best Practices
Manual for making the official record.I fully understand and appreciate the many challenges existing not only to the
Supreme Court, but all courts,in ensuring an accurate and timely court record. That said, I would like to strongly echo the
comments of mycolleague J udge J ohn Tatro in his letter of April 18, 2011, wherein he expresses concerns with the
practicalimplementation of the standards and best practices as it relates to the lower courts of this state.The Reno
Municipal Court, like many others, has used the digital recording device method for recording ourcourt proceedings for
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 26 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
many years without issue. Adoption of the new Standards of Operation will bring about aconsequent change in our court
operation.The Tier Implementation Table of the proposed standards suggests that all municipal court bench trials wherean
enhanceable offense is charged would be conducted by either a court reporter or court recorder. No longerwould we be
able to utilize our currently existing digital recording system in these proceedings.There are numerous violations that
carry enhanceable penalties in our court including the following: (1)Domestic Battery (NRS 200.485), (2) Harassment
(NRS 200.571), (3) Stalking (NRS 205.575), (4) Unlawfuloperation of audio/visual recording function in motion picture
theater (NRS 205.216), (5) Graffiti (NRS206.330), (6) Possession of an ounce or less of marijuana (NRS 453.336), (7)
Reckless Driving (NRS484b.653), (8) DUI (NRS 484c.110), (9) Child Restraint violations (NRS 484b.157). To require
the lowercourts to utilize either a court reporter or court recorder would be, as J udge Tatro has alluded,
"extremelyburdensome and costly" to our courts.The Reno Municipal Court faces a 30% reduction in our budget this
fiscal year. When we say we are doingmore with less, we mean that earnestly. It's not a soundbite! It will be extremely
difficult to assign personnelinto the court to function as a court recorder. It will be extremely difficult for our courts to
comply with thesestandards of operation purely from an economic standpoint.If the current system of digital recording
utilized in our court proceedings is working efficiently, why is there aneed to correct our current method of recordation? I
respectively recommend that the lower courts be allowedto continue utilization of digital recording devices in all
proceedings.
TIME
NRS 178.472 Computation. In computing any period of time the day of the act or event from which the
designated period of time begins to run shall not be included. The last day of the period so computed shall be included,
unless it is a Saturday, a Sunday, or a nonjudicial day, in which event the period runs until the end of the next day which is
not a Saturday, a Sunday, or a nonjudicial day. When a period of time prescribed or allowed is less than 7 days,
intermediate Saturdays, Sundays and nonjudicial days shall be excluded in the computation.
(Added to NRS by 1967, 1451)
NRS 178.476 Enlargement. When an act is required or allowed to be done at or within a specified time,
the court for cause shown may at any time in its discretion:
1. With or without motion or notice, order the period enlarged if request therefor is made before the
expiration of the period originally prescribed or as extended by a previous order; or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 27 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
2. Upon motion made after the expiration of the specified period permit the act to be done if the failure to
act was the result of excusable neglect,
but the court may not extend the time for taking any action under NRS 176.515or 176.525 except to the extent
and under the conditions stated in those sections.
(Added to NRS by 1967, 1451; A 1969, 10; 1985, 63)
NRS 178.478 Motions; affidavits.
1. A written motion, other than one which may be heard ex parte, and notice of the hearing thereof must be
served not later than 5 days before the time specified for the hearing unless a different period is fixed by rule or order of
the court. For cause shown such an order may be made on ex parte application.
2. When a motion is supported by affidavit, the affidavit must be served with the motion; and opposing
affidavits may be served not less than 1 day before the hearing unless the court permits them to be served at a later time.
3. A certificate of service must accompany each motion filed.
(Added to NRS by 1967, 1451; A 1991, 303)
NRS 178.482 Additional time after service by mail. Whenever a party has the right or is required to do
an act within a prescribed period after the service of a notice or other paper upon the party and the notice or other paper is
served by mail, 3 days shall be added to the prescribed period.
(Added to NRS by 1967, 1451)
MOTIONS
NRS 178.552 Form; contents. An application to the court for an order shall be by motion. A motion
other than one made during a trial or hearing shall be in writing unless the court permits it to be made orally. It shall state
the grounds upon which it is made and shall set forth the relief or order sought. It may be supported by affidavit.
(Added to NRS by 1967, 1456)

SERVICE AND FILING OF PAPERS
NRS 178.582 Service: When required. Written motions other than those which are heard ex parte,
written notices, designations of record on appeal and similar papers shall be served upon each of the parties.
(Added to NRS by 1967, 1457)
NRS 178.584 Service: How made.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 28 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
1. Whenever under this Title or by an order of the court service is required or permitted to be made upon a
party represented by an attorney, the service must be made upon the attorney unless service upon the party is ordered by
the court.
2. Except as otherwise provided in NRS 178.589, service upon the attorney or upon a party must be made
in the manner provided in civil actions.
(Added to NRS by 1967, 1457; A 1999, 52)
NRS 178.586 Notice of orders. Immediately upon the entry of an order made on a written motion
subsequent to arraignment the clerk shall mail to each party a notice thereof and shall make a note in the docket of the
mailing. Lack of notice of the entry by the clerk does not affect the time to appeal or relieve or authorize the court to
relieve a party for failure to appeal within the time allowed.
(Added to NRS by 1967, 1457)
NRS 178.588 Filing of papers. Papers required to be served must be filed with the court. Except as
otherwise provided in NRS 178.589, papers must be filed in the manner provided in civil actions.
(Added to NRS by 1967, 1457; A 1999, 52)
NRS 178.589 Use of facsimile machine.
1. Except when personal service of a person is ordered by the court or required by specific statute, a person
who is represented by an attorney may be lawfully served with any motion, notice or other legal document by means of a
facsimile machine if:
(a) The document is transmitted to the office of the attorney representing the person; and
(b) The facsimile machine is operational and is maintained by the attorney representing the person or the
employer of that attorney.
2. In addition to any other document required by the court, a person who uses a facsimile machine pursuant
to subsection 1 to serve any motion, notice or other legal document that is required to be filed with the court shall attach
to or include with the original document filed with the court a copy of the confirmation report or other comparable
evidence of the transmittal of the legal document.
3. Service of any motion, notice or other legal document by facsimile machine after 5 p.m. on the day that
the document is transmitted shall be deemed delivered on the next judicial day. The time of transmittal set forth in this
subsection is determined according to the time at the location of the recipient of the legal document.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 29 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
4. Service of any motion, notice or other legal document by facsimile machine as authorized by this section
is supplemental to and does not affect the validity of any other manner of service authorized by law.
5. As used in this section:
(a) Facsimile machine means a device that sends or receives a reproduction or facsimile of a document or
photograph which is transmitted electronically or telephonically by telecommunications lines.
(b) Person includes, without limitation, a government, governmental agency or political subdivision of a
government.
(Added to NRS by 1999, 51)
SERVICE AND FILING OF PAPERS
NRS 178.582 Service: When required. Written motions other than those which are heard ex parte,
written notices, designations of record on appeal and similar papers shall be served upon each of the parties.
(Added to NRS by 1967, 1457)
NRS 178.584 Service: How made.
1. Whenever under this Title or by an order of the court service is required or permitted to be made upon a
party represented by an attorney, the service must be made upon the attorney unless service upon the party is ordered by
the court.
2. Except as otherwise provided in NRS 178.589, service upon the attorney or upon a party must be made
in the manner provided in civil actions.
(Added to NRS by 1967, 1457; A 1999, 52)
NRS 178.586 Notice of orders. Immediately upon the entry of an order made on a written motion
subsequent to arraignment the clerk shall mail to each party a notice thereof and shall make a note in the docket of the
mailing. Lack of notice of the entry by the clerk does not affect the time to appeal or relieve or authorize the court to
relieve a party for failure to appeal within the time allowed.
(Added to NRS by 1967, 1457)
NRS 178.588 Filing of papers. Papers required to be served must be filed with the court. Except as
otherwise provided in NRS 178.589, papers must be filed in the manner provided in civil actions.
(Added to NRS by 1967, 1457; A 1999, 52)
NRS 178.589 Use of facsimile machine.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 30 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
1. Except when personal service of a person is ordered by the court or required by specific statute, a person
who is represented by an attorney may be lawfully served with any motion, notice or other legal document by means of a
facsimile machine if:
(a) The document is transmitted to the office of the attorney representing the person; and
(b) The facsimile machine is operational and is maintained by the attorney representing the person or the
employer of that attorney.
2. In addition to any other document required by the court, a person who uses a facsimile machine pursuant
to subsection 1 to serve any motion, notice or other legal document that is required to be filed with the court shall attach
to or include with the original document filed with the court a copy of the confirmation report or other comparable
evidence of the transmittal of the legal document.
3. Service of any motion, notice or other legal document by facsimile machine after 5 p.m. on the day that
the document is transmitted shall be deemed delivered on the next judicial day. The time of transmittal set forth in this
subsection is determined according to the time at the location of the recipient of the legal document.
4. Service of any motion, notice or other legal document by facsimile machine as authorized by this section
is supplemental to and does not affect the validity of any other manner of service authorized by law.
5. As used in this section:
(a) Facsimile machine means a device that sends or receives a reproduction or facsimile of a document or
photograph which is transmitted electronically or telephonically by telecommunications lines.
(b) Person includes, without limitation, a government, governmental agency or political subdivision of a
government.
(Added to NRS by 1999, 51)
CALENDARS
NRS 178.592 Calendar of criminal actions: Preparation by clerk.
1. The clerk must prepare a calendar of all criminal actions pending in the court, enumerating them
according to the date of filing of the indictment, information or complaint, specifying opposite the title of each action
whether such action is for a felony or misdemeanor, and whether the defendant is in custody or on bail.
2. Preference shall be given to criminal proceedings as far as practicable.
(Added to NRS by 1967, 1457)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 31 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
NRS 178.594 Order of disposing of issues on calendar. The issues on the calendar must be disposed of
in the following order, unless for good cause the court directs an action to be tried in a different order:
1. Prosecutions for felony, when the defendant is in custody.
2. Prosecutions for misdemeanor, when the defendant is in custody.
3. Prosecutions in which the State, upon determining that the physical, emotional or mental condition of the
victim of, or a material witness to, an alleged felony or gross misdemeanor is deteriorating because of age, an illness or an
injury to himself or herself or his or her spouse, has demanded a trial within 60 days after the arraignment of the person
accused of the felony or gross misdemeanor pursuant to NRS 174.511.
4. Prosecutions for felony, when the defendant is on bail.
5. Prosecutions for misdemeanor, when the defendant is on bail.
(Added to NRS by 1967, 1458; A 1983, 1671)
EXCEPTIONS
NRS 178.596 Exceptions unnecessary. Exceptions to rulings or orders of the court are unnecessary and
for all purposes for which an exception has been necessary prior to J anuary 1, 1968, it is sufficient that a party, at the time
the ruling or order of the court is made or sought, makes known to the court the action which the party desires the court to
take or the partys objection to the action of the court and the grounds therefor; but if a party has no opportunity to object
to a ruling or order, the absence of an objection does not thereafter prejudice the party.
(Added to NRS by 1967, 1458)
ERROR
NRS 178.598 Harmless error. Any error, defect, irregularity or variance which does not affect
substantial rights shall be disregarded.
(Added to NRS by 1967, 1458)
NRS 178.602 Plain error. Plain errors or defects affecting substantial rights may be noticed although
they were not brought to the attention of the court.
(Added to NRS by 1967, 1458)
RECORDS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 32 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
NRS 178.606 Docket kept by deputy clerk of justice court; contents. A docket must be kept by the
deputy clerk of the justice court, in which the deputy clerk shall enter each action, and the minutes of the proceedings of
the court therein.
(Added to NRS by 1967, 1458; A 1985, 53)
RULES OF COURT
NRS 178.608 Rules of justice courts and district courts not to be inconsistent with this title. Rules
made by justice courts and district courts for the conduct of criminal proceedings shall not be inconsistent with this title.
(Added to NRS by 1967, 1458)
NRS 178.610 Where no procedure specifically prescribed court may proceed in lawful manner. If
no procedure is specifically prescribed by this title, the court may proceed in any lawful manner not inconsistent with this
title or with any other applicable statute.
(Added to NRS by 1967, 1458
AFFIRMATION Pursuant to NRS 239B.030
The undersigned does hereby affirm that the preceding document does not contain
the social security number of any person.
DATED this 9/24/13


_/s/ Zach Coughlin
Zach Coughlin
Appellant/Petitioner

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28




- 33 -
NOTICE THAT COUGHLIN IS STILL REQUESTING AN EXTENSION OF TIME TO FILE
REPLY
PROOF OF SERVICE

I, Zach Coughlin, declare:

I, Mr. Zach Coughlin served the foregoing electronically by efiling on efiler dan wong of the
rca.

DATED THIS 9/25/13
BY


/s/ zach coughlin
Zach Coughlin
Appellant/petitioner