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"investigator" Peters putting the blindfold on herselfFW: Undeliverable:

From: Zach Coughlin (zachcoughlin@hotmail.com)


Sent: Tue 11/06/12 8:25 PM
To: complaints@nvbar.org (complaints@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); patrickk@nvbar.org
(patrickk@nvbar.org)
This is ridiculous that Clerk of Court/Investigator Peters has admitted to adding me to her blocked senders list. Why doesn't she add herself to the "blocked paycheck" list?
Please forward this on to her. Plus, she added me to that least WAY too late to excuse the lack of investigation and due diligence her, considering all the materials I can
proved she and the SBN received.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
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To: zachcoughlin@hotmail.com
Date: Tue, 6 Nov 2012 19:45:32 -0800
Subject: Undeliverable:
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From: Zach Coughlin <zachcoughlin@hotmail.com>
To: "laurap@nvbar.org" <laurap@nvbar.org>, "patrickk@nvbar.org"
<patrickk@nvbar.org>
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
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x-doc-filename2: supplemental to Coughlin's designation fo witnesses and
summary and production of evidence and notice of objection 0204 CORRECTED
CAPTION.pdf
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x-doc-filename5: 0204 subpoena all.pdf
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--Forwarded Message Attachment--
From: zachcoughlin@hotmail.com
To: laurap@nvbar.org; patrickk@nvbar.org
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
Dear Bar Counsel King and Clerk of Court/Investigator Peters and Chairman Echeverria,
There is a big problem with respect to when the State Bar of Nevada actually sent the Respondent, Coughlin the Designation of
Witnesses and Summary of Evidence (DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE.
Further, Coughlin has never received any Notice of Intent to Take Default (NoITD) from the SBN. As such, the notice and
other procedural safeguards attendant to the Hearing set for 11/14/12 are severely deficient. This is just the 13th chime of the
clock, and I have had as many "get right with Jesus" (or any other number of nondenominational Saviors) talks with Bar Counsel
King and Clerk Peters as anyone deserves. Add to that this new thing where first Bar Counsel says, as required by SCR 105(2)
(c)'s:
"The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the names of the witnesses bar counsel intends to call for other than impeachment,
together with a brief statement of the facts to which each will testify, all of which may be inspected up to 3 days prior to the hearing. "
See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from under Respondent's feet suddenly and claim to be "copying" only certain
things, and refusing to allow inspection of others (even where the SCR 105 Complaint specifically invokes such non copied materials), and then cut short the time up to which Respondnet may
inspect. Let's say Bar Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows Coughlin to go to the SBN and inspect "up to 3 days prior"...so Coughlin may
go to the SBN tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is a violation of SCR 105, right? Please advise in writing.
Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel and the Panel's failure to follow these rules "may
result in contempt of the appropriate disciplinary board or hearing panel having jurisdiction..." Please note there has already been a Motion for Order to Show
Cause filed against Bar Counsel and or the Board or Panel in 60838 and 61426. Additionally, please be aware that SCR 119(3) holds: 3.Other rules of
procedure.Except as otherwise provided in these rules, the Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in
disciplinary cases.
In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for procedural safeguards in that it was issued prior to the expiration of five
judicials days from the constructive service upon Coughlin, under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used do to
a recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the SBN outgoing mail box two certified letter to myself that Clerk of Court Peters
admitted would not be picked up that day by the regular postal carrier to the SBN, despite what they certificates of mailing therein might state. It is particularly
troubling to me that the Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence included with it, and therefore, my right to have the
DoWSoE 30 days prior to the hearing, and to receive it from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up with less
than the required notice (and jam the Panel up to for the matter, though there has been little indication so far that the Panel cares or has much an intent to do
anything more than let Bar Counsel King lead them down the same primrose path that Clerk Peters can tell you about...). It is a path that Richard G. Hill, Esq. often
takes people down too...
I would be very interest to know who was on the screening Panel...which Bar Counsel King promised to tell me, though, like most all of Pat's promises, he has
broken...could it have been David Hamilton, Esq.? Richard G. Hill's best friend, David Hamilton? Was it WCDA Mary Kandaras? The one included in the
correspondences about my smartphone and micro sd data card being searched and or seized illegally and or outside any lawful search incident to arrest given the
hand of an booking it into Coughlin's property on 2/27/12, only for the RMC Marshals to return on 2/28/12 (at the soonest) to take it back to Judge Nash Holmes?
What's next, Judges showing up in our bedrooms reading our diaries out of the blue?
It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas and granted me indigent status as to witness fees...if this is not
within the power of Bar Counsel or is otherwise against the Orders of the Panel or Board, please let me know very soon. Please See SCR 110 and in that regard, I
am requesting a prehearing conference for the purpose of gathering admissions from Bar Counsel and narrowing the issues, and in that regard, I recently sent Bar
Counsel and at least Panel Chair Echeverria materials related to what I see as a frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's
client, John Gessin.

Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have voiced to President of the State Bar of Nevada Flaherty, in that
light:
Rule120.Costs; bar counsel conflict or disqualification
2.If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of governors shall appoint an attorney, ad hoc, to act in the place of bar
counsel.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
11 6 12 0202 Objection and Notice.pdf
supplemental to Coughlin's designation fo witnesses and summary and production of evidence and notice of objection 0204 CORRECTED CAPTION.pdf
0204 notice of non service of purported notice of intent to take default.pdf
0204 SUBPOENA WITH DISCLAIMER.pdf
0204 subpoena all.pdf
Download all

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