11 2 12 0204 Email To SBN SBN Still Has Not Provided Access Re Clarks Early Assurances Regarding Right To Issue Own Subpoenas See 11 2 12 Order Quashing On That Basis

SBN still has not provided Coughlin access to the materials he is entitled to to
prepare for 11/14/12 Hearing

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

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

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

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

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

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

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

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

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

Sincerely,

Sincerley,
skent@skentlaw.com, mike@tahoelawyer.com, nevtelassn@sbcglobal.net, patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org;
complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Subject: RE: Records
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
--Forwarded Message Attachment--
Print
Your Online Police Report T11005956 Has Been Submitted
From:
NvRenoPd@coplogic.com
Sent: Wed 9/07/11 9:36 PM
To: zachcoughlin@hotmail.com
****DO NOT RESPOND TO THIS E-MAIL****
Your online report has been successfully received and the
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You will be notified via email of any problems with your
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Your Online Police Report T11005956 Has Been Rejected
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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
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Thank you,
Officer WOZNIAK,
From:
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tracking number is T12000219.
system.
Online Officer
From:
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From:
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To: ZACHCOUGHLIN@HOTMAIL.COM
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From:
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Your Online Police Report 120100300 Has Been Approved
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Your report has been approved report and the permanent number of the case is
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the delicate information in his report has been replaced for *** to support isolation in this email.
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From:
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Your report has been approved supplemental report and the permanent number of the case is
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120100300.
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1 attachment
report-120103420-0.pdf (71.4 KB)
120103420.
system.
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From:
Sent: Mon 6/11/12 4:11 PM
1 attachment
report-120103420-1.pdf (70.9 KB)
120103420.
system.
Online Officer
From:
Sent: Fri 9/21/12 8:09 PM
system.
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From:
Sent: Fri 9/21/12 8:49 PM
Close
system.
Online Officer
From:
Sent: Thu 10/04/12 3:42 PM
1 attachment
report-120105605-0.pdf (10.8 KB)
120105605.
system.
Online Officer
From:
Sent: Thu 10/04/12 3:54 PM
1 attachment
report-120105605-1.pdf (8.6 KB)
120105605.
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Online Officer
Print
RE: release of information to my attorney
From:Goodnight, Joseph W (JGoodnight@washoecounty.us)This sender is in your safe list.
Sent: Wed 5/02/12 4:45 PM
Mr. Coughlin,
MHC has received your referral and diagnosis from Ascent NBI. The MHC coordinator indicated that your case will be added to Friday's staffing and
your application "looks fine." I take that to indicate that you'll likely be accepted. I have a call in to DDA Young to re-open negotiations. This is what I
intend to present for a global resolution:

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

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

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

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

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

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

E-mail works well for me.

Keith Loomis

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

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

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

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

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

Keith Loomis

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

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

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

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

Couple of questions:

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

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

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

What is relevance of personnel files of Carter or Lopez?

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

Keith Loomis

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

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

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

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

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

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

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

Thanks

Keith Loomis

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Keith Loomis

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

Dear Mr. Loomis,

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

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

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

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

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

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

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

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

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


Date: Mon, 12 Mar 2012 09:26:35 -0700
I can do that if there is a good reason to vacate the date. What is the reason?

Keith
Sent: Friday, March 09, 2012 6:28 PM

Please file something with the court seeking to vacate that trial date and explaining that you failed to even once
consult with your client prior to setting it.
Subject: Trial Date
Date: Fri, 9 Mar 2012 10:44:17 -0800
See attached
RE: i was evicted 3 15 12, i need a continuance
Sent: Wed 3/28/12 2:03 PM
Dear Mr. Coughlin:

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

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

Keith Loomis

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

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

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

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

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

No skin in the game.

Keith Loomis

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

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

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

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

Keith Loomis

Sent: Thursday, March 29, 2012 2:44 PM
Subject: FW: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross
examing RPD on bribery and retaliation
Importance: Low

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

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

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

Keith Loomis

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

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

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

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

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

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

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

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

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

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

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

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

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:...
(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;...
(g) When the person is already in custody as a result of another lawful arrest; or

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

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

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

Sincerely,

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

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

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

Are you refusing to file the motions o requested?
-----Original Message-----
From: Keith Loomis
Sent: 7 Aug 2012 16:55:44 GMT
To: 'Zach Coughlin'
Subject: RE: request for a pre trial motion and bail motion
Zach

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

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

Keith Loomis

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

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

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

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

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

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

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

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

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

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

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

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

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:...
(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;...
(g) When the person is already in custody as a result of another lawful arrest; or

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

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

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

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
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Online Officer
RE: respectfully submitted
Sent: Wed 8/08/12 2:43 PM
Zach:
I reviewed the file in the Krebs protective order application. It is interesting in that there is not one reference by Mr. Krebs to a belief that you were trying
to provoke him to engage in violence or a violation of law. Those appear to be solely the words of Office Weaver.
I subsequently received your 100 page e-mail and do not intend to review it at length as most of the material appears irrelevant. What I gather
from it is that you are once again not happy with my representation and want me to withdraw. I think there is merit to that request. It appears that our
relationship has broken down and that you are asking me to engage in conduct that will result in violations of the rules of professional conduct. Those
include Rules 3.1, 3.2 , 4.4 and possibly others. I also fundamentally disagree with some of your requested actions in that so far you have refused to
provide your description of what happened on July 3, 2012 with Mr. Krebs. It also appears that your repeated demands are making my representation
unreasonably difficult. It would be helpful; if I can represent in the motion to withdraw that you are willing to waive the 60 day rule for trial, so that a new
attorney can be appointed to represent you and have enough time to prepare your case. Please respond whether you will agree to that waiver. If not I will
simply file the motion without the representation and hope for the best.

Keith Loomis

Sent: Tuesday, August 07, 2012 11:01 PM
To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
Subject: FW: respectfully submitted

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

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

Keith Loomis

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

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

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

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

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

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

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

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

-Paul

11 2 12 0204 Email To SBN SBN Still Has Not Provided Access Re Clarks Early Assurances Regarding Right To Issue Own Subpoenas See 11 2 12 Order Quashing On That Basis

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