12 13 11 Final 0204 60838 RMC 11 CR 22176 Notice of Appeal, Motion To Vacate, Motion For Reconsid and Motion For Recusal Stamped With Exhbit and Pic of DVD Attached

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Notice o) ,''eal, >otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or
Recon<i*eration5 >otion )or Recu<al5 >otion #or &u?lication 1) Tran<cri't at &u?lic 0$'en<e,
&etition )or /n #or@a &au'eri< Statu<
&1/NTS ,N( ,.T31R/T/0S
C,S0 ,&&0,: ST,T0>0NT
(e)en*ant+,''ellant, Zach Coughlin, here?A )ile< thi< Notice o) ,''eal, >otion to Vacate an*
or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or Recon<i*eration5 >otion )or Recu<al5 >otion #or
&u?lication 1) Tran<cri't at &u?lic 0$'en<e, &etition )or /n #or@a &au'eri< Statu<.
&1/NTS ,N( ,.T31R/T/0S
,N,:4S/S
/NC1R&1R,T0 74 R0#0R0NC0 ,:: :,2 ,N( ,SS0RT/1NS /N ,TT,C30(
&,&0RS ,N( &:0,(/N9S ,N( 2R/T/N9S /N 0B3/7/T 1:
R.:0 59. N02 TR/,:S5 ,>0N(>0NT 1# -.(9>0NTS
(a) Grounds. , ne= trial @aA ?e grante* to all or anA o) the 'artie< an* on all or 'art o) the i<<ue< )or anA o) the
)ollo=ing cau<e< or groun*< @ateriallA a))ecting the <u?<tantial right< o) an aggrie6e* 'artA: C1; /rregularitA in the
'rocee*ing< o) the court, DurA, @a<ter, or a*6er<e 'artA, or anA or*er o) the court, or @a<ter, or a?u<e o) *i<cretion ?A
=hich either 'artA =a< 're6ente* )ro@ ha6ing a )air trial5 C2; >i<con*uct o) the DurA or 're6ailing 'artA5 C"; ,cci*ent or
<ur'ri<e =hich or*inarA 'ru*ence coul* not ha6e guar*e* again<t5 C%; Ne=lA *i<co6ere* e6i*ence @aterial )or the 'artA
@aEing the @otion =hich the 'artA coul* not, =ith rea<ona?le *iligence, ha6e *i<co6ere* an* 'ro*uce* at the trial5 C5;
>ani)e<t *i<regar* ?A the DurA o) the in<truction< o) the court5 C!; 0$ce<<i6e *a@age< a''earing to ha6e ?een gi6en un*er
the in)luence o) 'a<<ion or 'reDu*ice5 or, C7; 0rror in la= occurring at the trial an* o?Decte* to ?A the 'artA @aEing the
@otion. 1n a @otion )or a ne= trial in an action trie* =ithout a DurA, the court @aA o'en the Du*g@ent i) one ha< ?een
entere*, taEe a**itional te<ti@onA, a@en* )in*ing< o) )act an* conclu<ion< o) la= or @aEe ne= )in*ing< an* conclu<ion<,
an* *irect the entrA o) a ne= Du*g@ent.
(b) Time for Motion. , @otion )or a ne= trial <hall ?e )ile* no later than 10 *aA< a)ter <er6ice o) =ritten notice o) the
entrA o) the Du*g@ent.
(c) Time for Serving Affidavits. 2hen a @otion )or ne= trial i< ?a<e* u'on a))i*a6it< theA <hall ?e )ile* =ith the @otion.
The o''o<ing 'artA ha< 10 *aA< a)ter <er6ice =ithin =hich to )ile o''o<ing a))i*a6it<, =hich 'erio* @aA ?e e$ten*e* )or
an a**itional 'erio* not e$cee*ing 20 *aA< either ?A the court )or goo* cau<e <ho=n or ?A the 'artie< ?A =ritten
<ti'ulation. The court @aA 'er@it re'lA a))i*a6it<.
(d) On Courts Initiative; Notice; Secif!ing Grounds. No later than 10 *aA< a)ter entrA o) Du*g@ent the court, on it<
o=n, @aA or*er a ne= trial )or anA rea<on that =oul* Du<ti)A granting one on a 'artAF< @otion. ,)ter gi6ing the 'artie<
notice an* an o''ortunitA to ?e hear*, the court @aA grant a ti@elA @otion )or a ne= trial )or a rea<on not <tate* in the
@otion. 2hen granting a ne= trial on it< o=n initiati6e or )or a rea<on not <tate* in a @otion, the court <hall <'eci)A the
groun*< in it< or*er.
(e) Motion to A"ter or Amend a #udgment. , @otion to alter or a@en* the Du*g@ent <hall ?e )ile* no later than 10 *aA<
a)ter <er6ice o) =ritten notice o) entrA o) the Du*g@ent.
G,< a@en*e*5 e))ecti6e -ulA 1, 2005.H
Recon<i*eration5 >otion )or Recu<al
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R.:0 !0. R0:/0# #R1> -.(9>0NT 1R 1R(0R
(a) C"erica" Mista$es. Clerical @i<taEe< in Du*g@ent<, or*er< or other 'art< o) the recor* an* error< therein ari<ing )ro@
o6er<ight or o@i<<ion @aA ?e correcte* ?A the court at anA ti@e o) it< o=n initiati6e or on the @otion o) anA 'artA an*
a)ter <uch notice, i) anA, a< the court or*er<. (uring the 'en*encA o) an a''eal, <uch @i<taEe< @aA ?e <o correcte* ?e)ore
the a''eal i< *ocEete* in the a''ellate court, an* therea)ter =hile the a''eal i< 'en*ing @aA ?e <o correcte* =ith lea6e o)
the a''ellate court.
(b) Mista$es; Inadvertence; %&cusab"e Neg"ect; Ne'"! (iscovered %vidence; )raud* %tc. 1n @otion an* u'on <uch
ter@< a< are Du<t, the court @aA relie6e a 'artA or 'artAF< legal re're<entati6e )ro@ a )inal Du*g@ent, or*er, or 'rocee*ing
)or the )ollo=ing rea<on<: C1; @i<taEe, ina*6ertence, <ur'ri<e, or e$cu<a?le neglect5 C2; ne=lA *i<co6ere* e6i*ence =hich
?A *ue *iligence coul* not ha6e ?een *i<co6ere* in ti@e to @o6e )or a ne= trial un*er Rule 59C?;5 C"; )rau* C=hether
hereto)ore *eno@inate* intrin<ic or e$trin<ic;, @i<re're<entation or other @i<con*uct o) an a*6er<e 'artA5 C%; the
Du*g@ent i< 6oi*5 or, C5; the Du*g@ent ha< ?een <ati<)ie*, relea<e*, or *i<charge*, or a 'rior Du*g@ent u'on =hich it i<
?a<e* ha< ?een re6er<e* or other=i<e 6acate*, or it i< no longer eIuita?le that an inDunction <houl* ha6e 'ro<'ecti6e
a''lication. The @otion <hall ?e @a*e =ithin a rea<ona?le ti@e, an* )or rea<on< C1;, C2;, an* C"; not @ore than ! @onth<
a)ter the 'rocee*ing =a< taEen or the *ate that =ritten notice o) entrA o) the Du*g@ent or or*er =a< <er6e*. , @otion
un*er thi< <u?*i6i<ion C?; *oe< not a))ect the )inalitA o) a Du*g@ent or <u<'en* it< o'eration. Thi< rule *oe< not li@it the
'o=er o) a court to entertain an in*e'en*ent action to relie6e a 'artA )ro@ a Du*g@ent, or*er, or 'rocee*ing, or to <et
a<i*e a Du*g@ent )or )rau* u'on the court. 2rit< o) cora@ no?i<, cora@ 6o?i<, au*ita Iuerela, an* ?ill< o) re6ie= an* ?ill<
in the nature o) a ?ill o) re6ie=, are a?oli<he*, an* the 'roce*ure )or o?taining anA relie) )ro@ a Du*g@ent <hall ?e ?A
@otion a< 're<cri?e* in the<e rule< or ?A an in*e'en*ent action.
(c) (efau"t #udgments+ (efendant Not ,ersona""! Served. 2hen a *e)ault Du*g@ent <hall ha6e ?een taEen again<t anA
'artA =ho =a< not 'er<onallA <er6e* =ith <u@@on< an* co@'laint, either in the State o) Ne6a*a or in anA other
Duri<*iction, an* =ho ha< not entere* a general a''earance in the action, the court, a)ter notice to the a*6er<e 'artA, u'on
@otion @a*e =ithin ! @onth< a)ter the *ate o) <er6ice o) =ritten notice o) entrA o) <uch Du*g@ent, @aA 6acate <uch
Du*g@ent an* allo= the 'artA or the 'artAF< legal re're<entati6e< to an<=er to the @erit< o) the original action. 2hen,
ho=e6er, a 'artA ha< ?een 'er<onallA <er6e* =ith <u@@on< an* co@'laint, either in the State o) Ne6a*a or in anA other
Duri<*iction, the 'artA @u<t @aEe a''lication to ?e relie6e* )ro@ a *e)ault, a Du*g@ent, an or*er, or other 'rocee*ing
taEen again<t the 'artA, or )or 'er@i<<ion to )ile an an<=er, in accor*ance =ith the 'ro6i<ion< o) <u?*i6i<ion C?; o) thi<
rule.
(d) (efau"t #udgments+ Modification Nunc ,ro Tunc. 2hene6er a *e)ault Du*g@ent or *ecree ha< ?een entere*, the
'artA or 'artie< in *e)ault therein @aA at anA ti@e therea)ter, u'on =ritten con<ent o) the 'artA or 'artie< in =ho<e )a6or
Du*g@ent or *ecree ha< ?een entere*, enter general a''earance in the action, an* the general a''earance <o entere* <hall
ha6e the <a@e )orce an* e))ect a< i) entere* at the 'ro'er ti@e 'rior to the ren*ition o) the Du*g@ent or *ecree. 1n <uch
a''earance ?eing entere* the court @aA @aEe an* enter a @o*i)ie* Du*g@ent or *ecree to the e$tent onlA o) <ho=ing <uch
general a''earance on the 'art o) the 'artA or 'artie< in *e)ault, an* it <hall ?e entere* nunc 'ro tunc a< o) the *ate o) the
original Du*g@ent or *ecree5 'ro6i*e*, ho=e6er, that nothing herein containe* <hall 're6ent the court )ro@ @o*i)Aing
<uch Du*g@ent or *ecree a< <ti'ulate* an* agree* in =riting ?A the 'artie< to <uch action, an* in accor*ance =ith the ter@<
o) <uch =ritten <ti'ulation an* agree@ent.
R.:0 !2. ST,4 1# &R1C00(/N9S T1 0N#1RC0 , -.(9>0NT
(a) Automatic Sta!. 0$ce't a< <tate* herein, no e$ecution <hall i<<ue u'on a Du*g@ent nor <hall 'rocee*ing< ?e taEen )or
it< en)orce@ent until the e$'iration o) 10 *aA< a)ter <er6ice o) =ritten notice o) it< entrA.
(b) Sta! on Motion for Ne' Tria" or for #udgment. /n it< *i<cretion an* on <uch con*ition< )or the <ecuritA o) the
a*6er<e 'artA a< are 'ro'er, the court @aA <taA the e$ecution o) or anA 'rocee*ing< to en)orce a Du*g@ent 'en*ing the
*i<'o<ition o) a @otion )or a ne= trial or to alter or a@en* a Du*g@ent @a*e 'ur<uant to Rule 59, or o) a @otion )or relie)
)ro@ a Du*g@ent or or*er @a*e 'ur<uant to Rule !0, or o) a @otion )or Du*g@ent in accor*ance =ith a @otion )or a
Du*g@ent a< a @atter o) la= @a*e 'ur<uant to Rule 50, or o) a @otion )or a@en*@ent to the )in*ing< or )or a**itional
)in*ing< @a*e 'ur<uant to Rule 52C?;.
(c) -eserved.
(d) Sta! .on Aea". 2hen an a''eal i< taEen the a''ellant ?A gi6ing a <u'er<e*ea< ?on* @aA o?tain a <taA. The ?on*
@aA ?e gi6en at or a)ter the ti@e o) )iling the notice o) a''eal. The <taA i< e))ecti6e =hen the <u'er<e*ea< ?on* i< )ile*.
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(e) Sta! in )avor of t/e State or Agenc! T/ereof. 2hen an a''eal i< taEen ?A the State or ?A anA countA, citA or to=n
=ithin the State, or an o))icer or agencA thereo) an* the o'eration or en)orce@ent o) the Du*g@ent i< <taAe*, no ?on*,
o?ligation, or other <ecuritA <hall ?e reIuire* )ro@ the a''ellant.
(f) -eserved.
(g) ,o'er of Ae""ate Court Not 0imited. The 'ro6i<ion< in thi< rule *o not li@it anA 'o=er o) an a''ellate court or o)
a Du*ge or Du<tice thereo) to <taA 'rocee*ing< *uring the 'en*encA o) an a''eal or to <u<'en*, @o*i)A, re<tore, or grant an
inDunction *uring the 'en*encA o) an a''eal or to @aEe anA or*er a''ro'riate to 're<er6e the <tatu< Iuo or the
e))ecti6ene<< o) the Du*g@ent <u?<eIuentlA to ?e entere*.
(/) Sta! of #udgment as to Mu"ti"e C"aims or Mu"ti"e ,arties. 2hen a court ha< or*ere* a )inal Du*g@ent un*er the
con*ition< <tate* in Rule 5%C?;, the court @aA <taA en)orce@ent o) that Du*g@ent until the entering o) a <u?<eIuent
Du*g@ent or Du*g@ent< an* @aA 're<cri?e <uch con*ition< a< are nece<<arA to <ecure the ?ene)it thereo) to the 'artA in
=ho<e )a6or the Du*g@ent i< entere*.
G,< a@en*e*5 e))ecti6e -ulA 1, 2005.H
'ro<ecutorial @i<con*uct C<uch a< the (.,. =ithhol*ing Je$cul'atorAJ e6i*ence that coul*F6e hel'e* Aour *e)en<e;
Du*icial error< C<uch a< the Du*ge 'er@itting e6i*ence that <houl*F6e ?een e$clu*e* or 6ice 6er<a;
erroneou< a''lication o) a la= or regulation i@'ro'er DurA in<truction<
ine))ecti6e a<<i<tance o) coun<el or other @al'ractice the e6i*ence *i* not 'ro6e Aour guilt ?eAon* a rea<ona?le *ou?t
/ =ent to the )iling o))ice at the R>C a cou'le ti@e< recentlA, inclu*ing to*aA, an* <ent in another =ritten reIue<t <eeEing
an au*io ta'e o) the Trial in R>C 11 CR 2217! /C 110!27 RS/C ?ut =a< tol* ?A a ClerE that / =oul* nee* to 'aA )or
the entire Trial to ?e tran<cri?e*, an* onlA then =oul* / ?e allo=e* to rea* it, an* that / =oul* not ?e allo=e* to acce<<
the au*io o) the hearingK /< thi< correctK / nee* to ha6e the au*io o) the Trial to )ini<h @A Rule 59, !0, an* >otion )or
Recon<i*eration >otion<..../ =ill 'aA )or the au*io. / ha6e recei6e* @anA au*io c*+*6*L< )ro@ ?oth Reno -u<tice Court
an* 2a<hoe (i<trict Court, an* it =a< announce* in court that the trial =a< ?eing au*io recor*e*, a< <uch, / ho'e Aou =ill
a))or* @e a co'A. To*aA, / calle* the R>C an* <'oEe =ith Veronica, =ho <oun*e* 6erA angrA =ith @e an* *i<@i<<i6e. /
=a< <u@@arilA <entence* to " *aA< in Dail at the en* o) the trial in thi< @atter, e6en =here / ha* ?een *enie* @A Si$th
,@en*@ent Right To Coun<el, a)ter a Conte@'t co@@itte* in the courtL< 're<ence )in*ing =a< announce*, in a**ition to
a guiltA 6er*ict in the un*erlAing action. Veronica in)or@e* @e that <he =a< at the trial an* that the R>C ha* )aile* to
@ail @e or other=i<e <er6e @e =ith a co'A o) the =ritten 1r*er, either )or the guiltA con6iction in the un*erlAing ca<e or
the conte@'t or*er. / =a< )orce* into han*cu))< <o IuicElA ater -u*ge 3o=ar* conclu*e* i<<uing hi< oral ruling that / =a<
not e6en a?le to <a6e @A note< on @A co@'uter, it =a< literallA a''arentlA that e$igent a <ituation to han*cu)) @e....Then
a )e= >ar<hall< 'lace <o@e 'iece< o) 'a'er in )ront o) @e an* *e@an*e* / <ign the@, an* ?eca@e angrA, liEe Veronica
an* liEe >ar<hall >onte, / ?elie6e, =a< at the arraing@ent, =hen / a<Ee* a <i@'le Iue<tion relate* to *ue 'roce<<,
<o@ething @anA at the R>C *o not <ee@ all that ena@ore* =ith. / a<Ee* i) / coul* e6en rea* the 'a'er< theA =ere
*e@an*ing / <ign right then an* there. The curtlA an* lou*lA <ai* no, then *ragge* @e a=aA ?e)ore / coul* rea* the
'a'er<, @uch le<< <ign the@. Veronica <narle* at @e that that =a< all the <er6ice o) the 1r*er o) Conte@'t an* 9uiltA
Ver*ict that / =oul* get, ?ut that <he @ight )a$ it to @e, ho=e6er, no )a$ ha< arri6e*, *e<'ite @A illu<trating the
e$igencie< o) recei6ing the 1r*er in 're'aring @A Relie) #ro@ -u*g@ent >otion<. Veronica continue to curtlA re)u<e to
'ro6i*e @e anA co'A o) anA o) the 're6iou<lA )ile* 1r*er< o) the Court unle<< / 'ai* )or the@, *e<'ite @A a''arentlA not
ha6ing ?een 'ro6i*e* a co'A o) <uch or*er< in the )ir<t 'lace. / ha6e no i*ea =hat tho<e 'a'er< =ere CtheA certainlA =ere
not in the 'ro'ertA gi6en to @e u'on @A relea<e )ro@ Dail; an* ha6e recei6e* nothing in the @ail, *e<'ite u'*ating the
R>C =ith @A ne= a**re<< o): 817 N. Virginia St. #2, Reno NV 89501 an* )iling an o))icial Change o) ,**re<< =ith the
.S&S <hortlA a)ter / =a< <u@@arilA e6icte* C*e<'ite there ?eing onlA a No Cau<e Su@@arA 06iction notice again<t @A
co@@ercial lea<e, <o@ething entirelA 'ro?i?ite* again<t un*er NRS %0.25". Not onlA =a< / *enie* @A Si$th ,@en*@ent
Right to Coun<el =here Dail ti@e =a< a 'o<<i?ilitA Can* =here, /, in )act =a< Daile*, i@@e*iatelA;. / =a< *enie* a
continuance in thi< @atter *e<'ite a =ritten a<<ent to one ?A Reno CitA ,ttorneA &a@ Ro?ert< an* *e<'ite the )act that the
%
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Reno CitA ,ttorneA =a< gi6en one ?A @A <u''o<e* a''ointe* coun<el :e= Taitel C=ho@ i< Ja<<ociate* =ithJ
C htt':++===.ne6c<.co@+attorneA.ht@l ; an entitA that / ha''en to ?e <uing Ne6a*a Court Ser6ice<, inci*ent to the <a@e
e6iction 'rocee*ing )or =hich >r. Taitel *i* grant, an* the R>C *i* grant, a continuance in the other R>C ca<e again<t
@e, the tre<'a<< action that =a< <et )or trial on (ece@?er 1"th, ?ecau<e Richar* 9. 3ill, =ho / a@ al<o <uing in
connection =ith the =rong)ul e6iction again<t, =a< going to ?e on 6acation an* the R>C a''arentlA )oun* that a goo*
rea<on )or a continuance, co@'are* to the R>C )eeling @A ?eing e6iction on or aroun* No6e@?er 1"th, then =rong)ullA
arre<te* in connection =ith the e6iction, un*er a tre<'a<< charge, an* incarcerate* )or a nu@?er o) *aA<, all =hile Richar*
3ill a''lie* an unla=)ul rent *i<traint u'on @anA e$cul'atorA @aterial< that =oul* <'eaE to a <tate* an* e$'re<<
retaliatorA @oti6e on the 'art o) 2al@art an* the RS/C, an* other e$cul'atorA @aterial< ?eing =rong)ullA =ithhel* un*er
an unla=)ul rent *i<traint ?A Richar* 9. 3ill, 0<I., the <a@e 'er<on >r. Taitel, the Reno CitA ,ttorneA, an* the R>C
*eci*e* *e<er6e* <uch <anctitA a''lie* to hi< @onthlong 6acation )ro@ ThanE<gi6ing to Ne= 4earL< to grant a
continuance, =ith no in'ut )ro@ @e.
#,/:.R0 T1 ,##1R( S/BT3 ,>0N(>0NT R/93T T1 C1.NS0: 1R 9R,NT (0>,N( #1R -.R4 TR/,:5
another (0>,N( #1R -.R4 TR/,: 30R074 >,(0 /N 0V0NT 1# N02 TR/,:, S/>/:,R:4 R0M.0ST #1R
/N #1R>, &,.&0R/S ST,T.S 30R074 >,(0 ,N( S.&&1RT0( 74 ,TT,C30( /#& &0T/T/1N
C1NC:.S/1N
(e)en*ant+,''elant Coughlin here?A re<'ect)ullA reIue<t< all 1r*er<, Con6iction<,
-u*g@ent<, Conte@'t #in*ing<, =hate6er, <te@@ing )ro@ the No6e@?er "0
th
, 2011 Trial ?e Vacate*
or Set ,<i*e or Recon<i*ere*..
,##/R>,T/1N &ur<uant to NRS 2"97.0"0
The un*er<igne* *oe< here?A a))ir@ that the 'rece*ing *ocu@ent *oe< not contain
the <ocial <ecuritA nu@?er o) anA 'er<on.
(,T0( thi< 12
th
(aA o) (ece@?er, 2011
N+<+ Zach Coughlin
Zach Coughlin
(e)en*ant
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&R11# 1# S0RV/C0
/, Zach Coughlin, *eclare:
1n (ece@?er 12, 2011, /, >r. Zach Coughlin <er6e* the )oregoing Notice o) ,''eal,
>otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or Recon<i*eration5 >otion )or
Recu<al ?A e@ailing an* )a$ing an* or 'lacing in the @ail a true co'A thereo) to:
&a@ela 9 Ro?ert< Co@'anA: Reno CitA ,ttorneAL< 1))ice Cri@inal (i6i<on ,**re<<: &.1. 7o$
1900 Reno , NV 89505 &hone Nu@?er: 775""%2050 #a$ nu@?er: 775""%2%20 0@ail:
ro?ert<'Oreno.go6
(,T0( T3/S12th *aA o) (ece@?er, 2011 74:
Zach Coughlin
(e)en*ant
!

Print Close
Here is service of the Motion for a New Trial, Set Aside, Va
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 12/12/11 9:52 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov
Is it about time for you to get that CD/DVD that Walmar'ts AP guy Faustino handed the
two Reno Sparks Indian Colony officers when they were leading the suspect away in
cuffs...not the video you gave me of sling blade badgering the lawyer I got those two
videos you gave me which just the badgering in the interrogation room. I am talking
about the cd/dvd that Walmart's guy gave them as they were walking out....Doesn't it
seem like you really need to get that now, to stay on the right side of Nifong? You
remember Nifong, don't you. Walmart ap guy sit there on the stand, under penalty of
perjury and testify that no video was collected in any way related to me or this case
aside from the 2 interrogation room videos you provided (with a highly suspect 14mb
"codec" program required to view the videos....can you indicate why that is necessary to
watch a simple old .avi file?).
why did you suborn the perjury of both the walmart guy and the officers regarding no
other video existing? I can't figure that one out. Ms. Roberts, don't you practice in
RMC quite a bit? Maybe I am confused, but doesn't the RMC rules permit serving a
government attorney such as yourself via email? What do you have against email? It is
economical for those of use who don't have such public largesse to work with. Here is
service of the Motion for a New Trial, Set Aside, Vacate, etc., etc:
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root
Its only something like 1,000 pages.
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-
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Gmail
I nqui r e Wi t hi n <r enoat t or ney@gmai l .c om>
Out bound f ax r epor t
9 messages
Vox ox <noreply@voxox.com> Tue, Dec 13, 2011 at 10:27 PM
To: renoattorney@gmail.com
Hi zachcoughlin,
Your Fax was successfully sent to unknown ( 17753342290).
Your Fax was delivered @ 06:27:56 AM on 2011-12-14.
xoxo,
The Voxox Team
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Hi zachcoughlin,
Your Fax was successfully sent to unknown ( 17753480858).
[Quoted text hidden]
Hi zachcoughlin,
Your Fax was successfully sent to unknown (19496677402).
Vox ox <noreply@voxox.com> Wed, Dec 14, 2011 at 12:08 AM
Hi zachcoughlin,

Hi zachcoughlin,
Hi zachcoughlin,
Hi zachcoughlin,
Hi zachcoughlin,
Hi zachcoughlin,
Your Fax was delivered @ 01:42:30 PM on 2011-12-14.
https://skydrive.live.com/redir.aspx?
cid=43084638f32f5f28&resid=43084638F32F5F28!
1031&parid=root
https://skydrive.live.com/redir.aspx?
cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root

Print Close
Here is service of the Motion for a New Trial, Set Aside, Va
Sent: Mon 12/12/11 9:52 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov
Is it about time for you to get that CD/DVD that Walmar'ts AP guy Faustino handed the
two Reno Sparks Indian Colony officers when they were leading the suspect away in
cuffs...not the video you gave me of sling blade badgering the lawyer I got those two
videos you gave me which just the badgering in the interrogation room. I am talking
about the cd/dvd that Walmart's guy gave them as they were walking out....Doesn't it
seem like you really need to get that now, to stay on the right side of Nifong? You
remember Nifong, don't you. Walmart ap guy sit there on the stand, under penalty of
perjury and testify that no video was collected in any way related to me or this case
aside from the 2 interrogation room videos you provided (with a highly suspect 14mb
"codec" program required to view the videos....can you indicate why that is necessary to
watch a simple old .avi file?).
why did you suborn the perjury of both the walmart guy and the officers regarding no
other video existing? I can't figure that one out. Ms. Roberts, don't you practice in
RMC quite a bit? Maybe I am confused, but doesn't the RMC rules permit serving a
government attorney such as yourself via email? What do you have against email? It is
economical for those of use who don't have such public largesse to work with. Here is
service of the Motion for a New Trial, Set Aside, Vacate, etc., etc:
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root
Its only something like 1,000 pages.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Close Print

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

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named
recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
Date: Thu, 8 Dec 2011 16:05:11 -0800
From: Hazlett-StevensC@reno.gov
To: zachcoughlin@hotmail.com
Subject: RE: your failure to propound discovery
Mr. Coughlin. I have never spoken to you and have never denied discovery to a defendant in any matter. Again you seek to
engage me in a convesation about the pending trespassing. I cannot speak with you. You are represented by counsel.
Thank you,
Chris
Christopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226
ATTORNEY-CLIENT PRIVILEGED
This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are confidential and
are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person
responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying,
dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY
PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the
sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
-----Original Message-----
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: <hazlett-stevensc@reno.gov>, <robertsp@reno.gov>
Date: Thu, 8 Dec 2011 15:44:36 -0800

Subject: RE: your failure to propound discovery
Mr. Hazlett-Stevens,
We did definately talk on the phone regarding the matter to which I do not have
representation, the RSIC arrest case 11 DR 22176 2I for which Deputy City Attorney
Pam Roberts is the prosecutor. I was denied my Sixth Amendment right to court
appointed defense counsel in that matter, and represented myself. As such, there is no
rule precluded you from communicating with me about 11 DR 22176 2I. You did
speak with me about that. I called you within a couple days of the September 9th,
2011 arrest in that matter describing my exigent desire to obtain a copy of the
discovery. I was transferred to you and we spoke at length about it, you describing
why you could not give it to me. Is it your contention that your office or the State
does not have a duty to provide the defendant a copy of certain pieces of discovery
within 48 hours of arrest?
Regarding the matter for which Mr. Puentes took the baton from Mr. Taitel, is it clear
to you how Mr. Taitel was somehow, apparently, able to assent to a continuance, only
to, apparently, find some need to pass the baton to Mr. Puentes very, very shortly
thereafter? Why did Mr. Taitel's status as attorney of record change? Was it due to a
conflict? Why didn't that conflict prevent Mr. Taitel from abstaining from assenting to
the continuance in the trespass case, which was scheduled for trial December 13,
2011?
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an
agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that
any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This
message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney
work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that
any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this
information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s),
please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt
by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable

privilege.
Date: Wed, 7 Dec 2011 07:34:25 -0800
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded with you, and
your statement that you spoke with me is false. I have never spoken with you. You may have your attorney, Roberto
Puentes, contact me with any discovery issues or issues regarding the City's Motion to Continue. Please do not correspond
with me regarding this case in the future. As an attorney, you are fully aware that I cannot communicate with a you as a
represented party. Do not contact me without your counsel.
Thank you,
Chris
City of Reno
Tel: 326-6628
Fax: 334-4226
To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for which Lew
Taitel was apparently my court appointed attorney, but whom no longer is. Further, I wish to be
copied on everything past and present in any way related to this matter until and after I procure
another attorney. I did not agree to the continuance you sought, nor was I informed you were
seeking it. I find it particularly troubling that a continuance was granted in the trespass case to the
same man who is applying an unlawful rent distraint on both my client files, personal property,
AND THE EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT
LARCENY CASE FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST YOU

AND YOUR OFFICE'S HANDLING BELOW. NO CONTINUANCE WAS GRANTED OR
AGREED TO AT TRIAL BY THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO
BUSY ALLEGEDLY SUBORNING THE PERJ URY OF RSIC OFFICER KAMERON
CRAWFORD.
In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted against
me there is a fax from the RSIC to you that has a fax heading for what appears to be "page 1"
followed by pages without that heading...then a heading with "page 4" etc... I want the entire
contents of anything provided by the RSIC and Walmart to you or anyone connected with the
Reno City Attorney or the Reno Municipal Court. Further, I want all media provided by Walmart,
and I question why you needed 45 minutes with the three witness who testified at the November
30th, 2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a NRCP 11 motion
requiring you to correct the perjury you suborned in court with respect to the patently
contradictory testimony of Officer Crawford vis a vis the video evidence you yourself provided in
discovery.
Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest in this
matter demanding a copy of all documentation or discovery that I had any right to. I was told I
would not have any opportunity to review such materials prior to the arraignment, which was not
set for a full 30 days out from the arrest. Do I not have a right to a copy of the pc sheet, arrest
report, and witness statements within 48 hours of the arrest? The fax to your office from the
RSIC is dated 9/12/2011, yet my written demands and requests for such discovery and
documentation were met with refusals to provide such materials, and, in some case, claims that
your office did not even have such materials and would not get them until after the arraignment.
Further, I spoke with and provided written requests to RSIC Sargent Avansino within 2 days after
the arrest and he refused to provide the materials, as did the Reno Municipal Court. Please alert
the court to any wrongdoing on your's or the Reno City Attorney or the RSIC part in this regard
in prejudicing my ability to defend my case by delaying the production of essential discovery,
then refusing to agree to a continuance at trial, after earlier providing a written agreement to such
a continuance.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

ag ent responsible for delivering it to the intended recipient, y ou are hereby notified that you have received this document in error and
that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This
work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified
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motion for continuance
Sent: Fri 11/11/11 1:40 AM
To: robertsp@reno.gov
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

RE: motion for continuance
Sent: Wed 11/16/11 3:35 PM
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.
To: <robertsp@reno.gov>
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
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

privilege.
Sent: Wed 11/16/11 5:30 PM
Thanks Ms. Roberts,
Can you tell me who the three witnesses are that showed up on November 14th, 2011
for trial at 1pm? I did obtain a copy of the "discovery" about the second day it was
made available to me from your office in person. At that time, no video evidence was
made available to me. Is there now some video or audio recording to which I may be
provided access? Would you mind just emailing me the names of the intended
witnesses. Do you believe you do not have a duty to make a reasonably diligent inquiry
of either Walmart or RSIC do assess the validity of the matters mentioned in my last
email, ie the retaliatory motive vis a vis Walmart and or the impermissible search/ 42
USC Sec 1983 police misconduct of the RSIC officers?
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Wed, 16 Nov 2011 17:12:21 -0800
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for reciprocal
discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to copies of all the reports and
witness statements and video we may have on this case. Since I am not calling any additional witnesses that are not already
mentioned in the reports/statements, I am not obligated to send you an additional list of witnesses. I am also not obligated to
do any further investigation or interviews. Pam Roberts.
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any Walmart
employees had, previous to this incident, made any threats respecting maliciously
having the accused banned from Walmart's incident to a disagreement over Walmart
staff and managers curious practice of "forgetting" their return policy, despite some
individuals having worked there over 10 years....Further, I believe it relevant and part
of your duty to provide exculpatory information to ascertain whether the RSIC police
officer made statements wherein he attempted to coerce a consent to an impermissible
search and further buttressed his probable cause finding to conduct a search incident
to arrest, expressly, in words, to the accused, upon the accused's failure to consent to
such a search.
Please provide a list of any witnesses you intend to call at trial, including a summation
of the matters the will testify to, in addition to producing a copy or making available
for reproduction any documentation, audio, video, or other materials intended to be
used in any way at trial.
Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800

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.
Date: Fri, 11 Nov 2011 01:40:53 -0800
believe is still set for trial on November 14th, I think at 1pm. I am not totally sure
that there is a duty to serve you on such a thing, but I filed a Motion for Continuance
and a Motion for Appointment of Counsel sometime within about the last 10 days, I
would say. I believe I attempted to copy you on it, but have recently been evicted
and its been a very difficult time in terms of coordinating paperwork, etc., etc. I
apologize for any inconvenience this may have cause you. I am unsure of whether
the November 14th trial is still set to take place. I believe fairness dictates that it be
continued to a later date. I have request counsel but have yet to receive any, or wait,
I was denied a request to receive counsel because Judge Howard said there is not a
6th amendment right to counsel where, even though jail time is technically a
possibility, the state does not anticipate seeking jail time...or something like that,
however, I found some cases that say I should still get counsel appointed, especially
where I show I am indigent, and I believe I qualify as indigent rather easily. Can and
would you agree to a continuance? I believe I tried to contact about this prior to
filing my Request for a Continuance. I maintain my innocence in this case and feel
any sort of 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
agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and
privilege.
Sent: Thu 11/17/11 3:37 PM
Dear Ms. Roberts,
I do not mean to suggest you do not know what your duty it. Believe me, I am well aware that you
could mop up the court room with a neophyte attorney such as myself. I was merely hoping to get
some direction from you regarding trial practice approaches in general.
Sincerely,
Zach
Sent: Mon 11/21/11 1:05 PM
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby shortly hoping to
be provided one. Please respond to me regarding my request from a continuance.
Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart employee) and
Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the video at the first trial date from
the Walmart employee and it is available for you to view or get a copy. You may want to view it at the City Attorney's
Office as the CD doesn't seem to work on everyone's computer. Penie Colter will be able to assist you. I am not clear on what
you think my duty is, but I know what my duty is and I will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
made available to me from your office in person. At that time, no video evidence was
made available to me. Is there now some video or audio recording to which I may be
provided access? Would you mind just emailing me the names of the intended
witnesses. Do you believe you do not have a duty to make a reasonably diligent
inquiry of either Walmart or RSIC do assess the validity of the matters mentioned in
my last email, ie the retaliatory motive vis a vis Walmart and or the impermissible
search/ 42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.
Date: Wed, 16 Nov 2011 17:12:21 -0800
discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to copies of all the reports
and witness statements and video we may have on this case. Since I am not calling any additional witnesses that are not
already mentioned in the reports/statements, I am not obligated to send you an additional list of witnesses. I am also not
obligated to do any further investigation or interviews. Pam Roberts.
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
having the accused banned from Walmart's incident to a disagreement over Walmart
staff and managers curious practice of "forgetting" their return policy, despite some
individuals having worked there over 10 years....Further, I believe it relevant and part
of your duty to provide exculpatory information to ascertain whether the RSIC

police officer made statements wherein he attempted to coerce a consent to an
impermissible search and further buttressed his probable cause finding to conduct a
search incident to arrest, expressly, in words, to the accused, upon the accused's
failure to consent to such a search.
Please provide a list of any witnesses you intend to call at trial, including a
summation of the matters the will testify to, in addition to producing a copy
or making available for reproduction any documentation, audio, video, or other
materials intended to be used in any way at trial.
Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800
Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in Courtroom B of the
Reno Municipal Court. We can discuss your case further at that time and if we are unable to resolve the case, you can ask
the Court again for a continuance and I won't object. However, it is the Court's decision to grant your motion to continue.
Date: Fri, 11 Nov 2011 01:40:53 -0800
that there is a duty to serve you on such a thing, but I filed a Motion for
Continuance and a Motion for Appointment of Counsel sometime within about the
last 10 days, I would say. I believe I attempted to copy you on it, but have recently
been evicted and its been a very difficult time in terms of coordinating paperwork,
etc., etc. I apologize for any inconvenience this may have cause you. I am unsure
of whether the November 14th trial is still set to take place. I believe fairness
dictates that it be continued to a later date. I have request counsel but have yet to

receive any, or wait, I was denied a request to receive counsel because Judge
Howard said there is not a 6th amendment right to counsel where, even though jail
time is technically a possibility, the state does not anticipate seeking jail time...or
something like that, however, I found some cases that say I should still get counsel
appointed, especially where I show I am indigent, and I believe I qualify as indigent
rather easily. Can and would you agree to a continuance? I believe I tried to
contact about this prior to filing my Request for a Continuance. I maintain my
innocence in this case and feel any sort of 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
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C.
2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended
recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information is
strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information
that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended
recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or
are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies
in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
temporary address change and instruction to pursue a
continuance
Sent: Mon 11/21/11 4:06 PM
To: howardk@reno.gov; robertsp@reno.gov
Dear Judge Howard Deputy City Attorney Roberts,

I have been evicted and perhaps subject to an illegal lockout and unlawful rent distraint
by an attorney representing my Beverly Hills High School graduate California
Neurosurgeon landlord, who has spent approx $30,000 in attorneys fees pursuing a
summary eviction, and whose attorney is withholding my state issued indentification,
wallet, and all materials necessary to my law practice all in an unlawful rent distraint
prohibited by NRS 40.460 and 40.520. I am pursuing a continuance of the upcoming
hearing/trial, I cannot even access when that hearing is. I have informed opposing
counsel Roberts of some of the issues which will require extensive discovery, a jury
trial, and more time to afford myself a legitimate opportunity to defend this case. I
have not been served any Order responding to my request for appointment of counsel,
as I believe it is required even if the State does not "intend" to seek jail time, where any
incarceration is a possibility, the Sixth Amendment guarantees it.
Please note that my temporary address for now is:
Zach Coughlin, Esq.
c/o Silver Dollar Motel
817 N. Virginia St., Unit # 2
Reno, NV 89501
The opposing counsel in the summary eviction matter is withholding my phone as well
and refusing to allow me to access any mail that may remain at the property from those
times when the USPS was processing my official Change of Address. Email is the best
way to get in contact with me during this transition period.
For instance, I am unware whether my Motion for Appointment of Counsel was granted
or not. I called Judge Howard's assistant and requested that she email me the docket in
this case and any pleadings or orders filed, including any order that may have stemmed
form any of my previous motions, as I am not sure how those were ruled on. I believe
my internet based fax service will allow me to receive those materials at my number
949 667 7402, though I would prefer email, but I know many governmental entities
prefer to fax such items. I am requesting a jury trial, a substantial continuance, and the
appointment of counsel. I object to the RMC's practice of refusing to tell litigants who
the 4 "house" appointed defenders are upon questioning. Further, it has become clear
that some of these "former prosecutors" who are now the gang of four "house"
defenders, do not even announce to accused arraignees that they are, in fact, the
defender or an attorney or that they may be representing the arraignees. I am hereby
filing a motion in limine regarding any materials or information gleaned from the

unlawful search by the RSIC Officer, who clearly announced that they would base their
probable cause to arrest and conduct a search incident to arrest upon any failure to
consent to a search by the accused. Further, the alleged conduct did not occur in the
Officer's presence, and I believe there exists authority preventing a minor misdemeanor
arrest and transport under those circumstances. Additionally, more time is needed to
conduct discovery in this matter, especially in light of allegations that Walmart had
previously threatened individuals, including, perhaps, the accused, with retaliatory
action, including illicit abuse of process, for the purported attempts by someone to have
the Walmart Return Policy enforced, and to hold accountable all Walmart employees
and managers, some of whom have over a decade experience in their positions, who
curiously "forget" they Return Policy Walmart holds out to the public when it is
convenient to do so, the same Return Policy that Walmart used to drive out of business
so many competitors. Further, this case is likely to get extremely complicated given the
apparent conflict of interest stemming from the fact that the Walmart in question is on
land owned by the RSIC, which may own or employ the RSIC police, and which is
rented or owned in part by Walmart.
I know Opposing Counsel Roberts may appreciate a continuance as well and the
opportunity it would afford her to fulfill her NRCP 11 duty and other prosecutorial
duties to conduct a reasonably diligent inquiry into these matters.
Sincerely,
Zach Coughlin
Sent: Mon 11/21/11 7:18 PM

Ms. Roberts, the opposing attorney's unlawful rent distraint is preventing me from providing all the
discovery I would like to provide you with or ascertain the need to do, and further is preventing me
from having access to the materials and information I need to litigate this case.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
Date: Mon, 14 Nov 2011 10:36:45 -0800
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation from the Court
that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in Courtroom B of the Reno
Municipal Court. We can discuss your case further at that time and if we are unable to resolve the case, you can ask the Court
again for a continuance and I won't object. However, it is the Court's decision to grant your motion to continue.
Date: Fri, 11 Nov 2011 01:40:53 -0800

there is a duty to serve you on such a thing, but I filed a Motion for Continuance and
a Motion for Appointment of Counsel sometime within about the last 10 days, I would
say. I believe I attempted to copy you on it, but have recently been evicted 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
privilege.
verint user agreement
Sent: Mon 11/21/11 8:40 PM

Hi Ms. Roberts,
Sorry, don't mean to be a pain, but I DON'T AGREE to this Verint software policy...its
calls for allowign them to inspect my office and paying them for their inspection fees
and all this other stuff that is so unduly oppressive. Its just an AVI file, its as though
they disable it just for the purpose of preventing you from watching the movie unless
you agree to their oppressive, onerous, contract terms, and how does this benefit
taxpayers? Authentication issues can be addressed through the traditional means, I
don't see the value add.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
Re: temporary address change and instruction to pursue a
continuance
From: Ken Howard (HowardK@reno.gov) You moved this message to its current location.
Sent: Tue 11/22/11 7:01 AM
To: Zach Coughlin (zachcoughlin@hotmail.com); robertsp@reno.gov
Mr. Zach Coughlin
There is an appropriate manner in which to tender "motions" to the court. They are to be properly prepared and
filed. Do not use this e-mail address to communicate directly with the judge.
Ken Howard

Reno Municipal Court Judge
Department 4
(775) 326-6673
To: <howardk@reno.gov>, <robertsp@reno.gov>
Date: Mon, 21 Nov 2011 16:06:32 -0800
Subject: temporary address change and instruction to pursue a continuance
Dear Judge Howard Deputy City Attorney Roberts,
I have been evicted and perhaps subject to an illegal lockout and unlawful rent
distraint by an attorney representing my Beverly Hills High School graduate California
Neurosurgeon landlord, who has spent approx $30,000 in attorneys fees pursuing a
summary eviction, and whose attorney is withholding my state issued indentification,
wallet, and all materials necessary to my law practice all in an unlawful rent distraint
prohibited by NRS 40.460 and 40.520. I am pursuing a continuance of the upcoming
hearing/trial, I cannot even access when that hearing is. I have informed opposing
counsel Roberts of some of the issues which will require extensive discovery, a jury
trial, and more time to afford myself a legitimate opportunity to defend this case. I
have not been served any Order responding to my request for appointment of counsel,
as I believe it is required even if the State does not "intend" to seek jail time, where
any incarceration is a possibility, the Sixth Amendment guarantees it.
Please note that my temporary address for now is:
Zach Coughlin, Esq.
c/o Silver Dollar Motel
817 N. Virginia St., Unit # 2
Reno, NV 89501
The opposing counsel in the summary eviction matter is withholding my phone as
well and refusing to allow me to access any mail that may remain at the property from
those times when the USPS was processing my official Change of Address. Email is
the best way to get in contact with me during this transition period.
For instance, I am unware whether my Motion for Appointment of Counsel was
granted or not. I called Judge Howard's assistant and requested that she email me the
docket in this case and any pleadings or orders filed, including any order that may

have stemmed form any of my previous motions, as I am not sure how those were
ruled on. I believe my internet based fax service will allow me to receive those
materials at my number 949 667 7402, though I would prefer email, but I know many
governmental entities prefer to fax such items. I am requesting a jury trial, a
substantial continuance, and the appointment of counsel. I object to the RMC's
practice of refusing to tell litigants who the 4 "house" appointed defenders are upon
questioning. Further, it has become clear that some of these "former prosecutors" who
are now the gang of four "house" defenders, do not even announce to accused
arraignees that they are, in fact, the defender or an attorney or that they may be
representing the arraignees. I am hereby filing a motion in limine regarding any
materials or information gleaned from the unlawful search by the RSIC Officer, who
clearly announced that they would base their probable cause to arrest and conduct a
search incident to arrest upon any failure to consent to a search by the accused.
Further, the alleged conduct did not occur in the Officer's presence, and I believe there
exists authority preventing a minor misdemeanor arrest and transport under those
circumstances. Additionally, more time is needed to conduct discovery in this matter,
especially in light of allegations that Walmart had previously threatened individuals,
including, perhaps, the accused, with retaliatory action, including illicit abuse of
process, for the purported attempts by someone to have the Walmart Return Policy
enforced, and to hold accountable all Walmart employees and managers, some of
whom have over a decade experience in their positions, who curiously "forget" they
Return Policy Walmart holds out to the public when it is convenient to do so, the same
Return Policy that Walmart used to drive out of business so many competitors.
Further, this case is likely to get extremely complicated given the apparent conflict of
interest stemming from the fact that the Walmart in question is on land owned by the
RSIC, which may own or employ the RSIC police, and which is rented or owned in
part by Walmart.
I know Opposing Counsel Roberts may appreciate a continuance as well and the
opportunity it would afford her to fulfill her NRCP 11 duty and other prosecutorial
duties to conduct a reasonably diligent inquiry into these matters.
Sincerely,
Zach Coughlin

any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message
is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or
exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be
unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a
waiver of any attorney-client, work product, or other applicable privilege.
Sent: Tue 11/29/11 1:33 PM
Dear Ms. Roberts,
The opposing attorney in the Summary Eviction Proceeding against me in my home law office/business
is asserting a lien against my office, law practice files, and materials necessary to discovery production
and defending the case that you are the prosecutor on. I believe a continuance is absolutely necessary
in the interests of justice. Additionaly, you have been informed that Walmart previous to the arrest in
this matter became upset at the accused and made threats of malicious prosecution and abuse of
process incident to the accused questioning various Wal-mart personnel and managers about Wal-Marts
curious practice of remixing and forgetting the Return Policy stated in writing at Walmart.com (and
expressly made applicable to purchases made in Wal-Mart stores). A manager named "Ellis", though
who may have identified himself as "J ohn" and a Loss prevention associate at the West 7th Street Wal-
Mart in Reno allegedly told the accused that they would have him banned from all Wal-Marts in
retaliation for the accused seeking to do something to which he was legally entitled to do, return and
item at a Wal-Mart stores in accordance with Wal-Mart's stated and written Return Policy. There are
other retaliatory aspects to the conducts and statements made by both Wal-Mart and RSIC personnel in
this case.
Additionally, the video "evidence" that you provided is shameful. It consists of two short clips in some
Wal-Mart back room where 5-6 people, including 2 RSIC officers acting under color of state law on land
their employer owns and leases to Wal-Mart attempt to coerce not only a confession, but a consent to
search. There is no audio of the video, at least not the video you provided, that is. Where is the video
of the alleged acts? How you can maintain a case such as this stemming from the accused acts in a
store like Wal-Mart, that has hundreds of cameras and only provide video from some backroom that
proves nothing and, in the words of "J eannie" the contact person at your office "doesn't show
anything", I am not sure, and whether that is violative of your duties as a prosecutor, Nifong, NRCP 11
(see Schumacher's application of that civil rule to the DA) is not clear. You have been informed that the
RSIC officer committed police misconduct and yet you brazenly announce in writing that you do not
intend to follow up on that, nor do you feel compelled to.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118

fax: 949 667 7402
Date: Tue, 22 Nov 2011 07:59:37 -0800
Dear Mr. Coughlin, you will need to file a motion to continue in compliance with Reno Municipal Court procedures. As I have
stated in a previous email, I do not object to your motion to continue, however, it is up to the J udge whether or not he will
grant your motion. Regarding the video which I obtained at your previous court date, I have told you that you can come to our
office and view the video. If you still want a copy, I believe our staff will be able to make one for you. NRS 174.235 does not
require me to do more than what I have already done. We have provided you with the reports we have, listed the witnesses
we will call and made the video available to you. Pam Roberts, Deputy City Attorney.
Date: Mon, 21 Nov 2011 13:05:28 -0800
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby shortly hoping
to be provided one. Please respond to me regarding my request from a continuance.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

privilege.
Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart employee) and
Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the video at the first trial date from
the Walmart employee and it is available for you to view or get a copy. You may want to view it at the City Attorney's
Office as the CD doesn't seem to work on everyone's computer. Penie Colter will be able to assist you. I am not clear on
what you think my duty is, but I know what my duty is and I will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
made available to me from your office in person. At that time, no video evidence
was made available to me. Is there now some video or audio recording to which I
may be provided access? Would you mind just emailing me the names of the
intended witnesses. Do you believe you do not have a duty to make a reasonably
diligent inquiry of either Walmart or RSIC do assess the validity of the matters
mentioned in my last email, ie the retaliatory motive vis a vis Walmart and or the
impermissible search/ 42 USC Sec 1983 police misconduct of the RSIC officers?
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and
privilege.
Date: Wed, 16 Nov 2011 17:12:21 -0800
discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to copies of all the reports
and witness statements and video we may have on this case. Since I am not calling any additional witnesses that are not
already mentioned in the reports/statements, I am not obligated to send you an additional list of witnesses. I am also not
obligated to do any further investigation or interviews. Pam Roberts.
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
having the accused banned from Walmart's incident to a disagreement over
Walmart staff and managers curious practice of "forgetting" their return policy,
despite some individuals having worked there over 10 years....Further, I believe it
relevant and part of your duty to provide exculpatory information to ascertain
whether the RSIC police officer made statements wherein he attempted to coerce a
consent to an impermissible search and further buttressed his probable cause
finding to conduct a search incident to arrest, expressly, in words, to the accused,
upon the accused's failure to consent to such a search.
Please provide a list of any witnesses you intend to call at trial, including a
summation of the matters the will testify to, in addition to producing a copy
or making available for reproduction any documentation, audio, video, or other
materials intended to be used in any way at trial.

Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800
Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in Courtroom B of the
Reno Municipal Court. We can discuss your case further at that time and if we are unable to resolve the case, you can
ask the Court again for a continuance and I won't object. However, it is the Court's decision to grant your motion to
continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the Court is
not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor case.
Date: Fri, 11 Nov 2011 01:40:53 -0800
that there is a duty to serve you on such a thing, but I filed a Motion for
Continuance and a Motion for Appointment of Counsel sometime within about
the last 10 days, I would say. I believe I attempted to copy you on it, but have
recently been evicted and its been a very difficult time in terms of coordinating
paperwork, etc., etc. I apologize for any inconvenience this may have cause you.
I am unsure of whether the November 14th trial is still set to take place. I believe
fairness dictates that it be continued to a later date. I have request counsel but
have yet to receive any, or wait, I was denied a request to receive counsel because
Judge Howard said there is not a 6th amendment right to counsel where, even
though jail time is technically a possibility, the state does not anticipate seeking
jail time...or something like that, however, I found some cases that say I should
still get counsel appointed, especially where I show I am indigent, and I believe I
qualify as indigent rather easily. Can and would you agree to a continuance? I
believe I tried to contact about this prior to filing my Request for a Continuance. I
maintain my innocence in this case and feel any sort of 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
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C.
2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended
recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information
is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information
that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended
recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or
are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-
client, work product, or other applicable privilege.
FW: temporary address change and instruction to pursue a
continuance
Sent: Tue 11/29/11 3:14 PM
To: robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to J udge Howard in response to his remonstration responding to
my email to him, in an abundance of caution to avoid ex parte communications with the court, outside
your presence. Please also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I
am hereby serving on you, invoking the 21 day safe harbor, with a reservation that any misconduct you
commit in the court's presence may be punished sua sponte or subject to contemporaneous sanctions
requests, particular with regard to you blase dismissal of the official misdoncut, malicious prosecution,
42 USC Sec 1983 deprivations of civil rights under color of state law and all those other things your
office and Hartshorn, et all have been sued for over the years.
Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
From: zachcoughlin@hotmail.com
To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
Dear Judge Howard,
My apologies Your Honor. I have had an unlawful rent distraint applied to all my office
equipment and the files necessary to defend this case and produce motions, incident to a
summary eviction stemming from a lease that was at least in part commercial, had a
rent escrow deposit forced upon me in violation of Nevada Law, had all my computers
printers, everything subject to the distraint. I have a netbook it won't accept a printer
and on and on. I apologize. I do note that the RMC rules allow for filing by facsimile,
though I gather not to the fax number listed for yoru chambers at www.nvbar.org.
Sincerely,
Zach Coughlin,
your cop lying, see your video drivers license produce ap
overview at 6:49 mark
Sent: Sun 12/04/11 3:37 AM
To: robertsp@reno.gov; kadlicj@reno.gov; kadlicj@ci.reno.nv.us

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

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

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
From: zachcoughlin@hotmail.com
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
Date: Sun, 4 Dec 2011 03:37:24 -0800
I want you to move for a Rule 59 Motion to Set Aside or some other motion to have the
Judgment Set Aside. Your cop witness clearly had a driver's license produced to him at
the 6:49 mark of YOUR OWN DAMN VIDEO! And you suborned his perjury on the
witness stand in violation of many of the prosecutorial codes you are held to and NRCP
11. Furher, what are you going to say when the UPC from the alleged receipt appears
on the purchased receipt, in combination with Frontino's adamant assertion that they
wouldn't, in combination with the same from Crawford, in combination with Frontino
admitting he couldn't hear what was said between the accused and the cashier, in
combination with the "same UPC, hit the quanity number" practice common at
Walmart? Further, your own witness admitted on tape at the trial that "he didn't have
before you and Judge Howard could jump in and cut him off. That's gametime. I will
avalanche you with motion and lawsuits if you don't fix this defamation you funded and
supported, what with you little 30 minutes witness coaching session that kept all the
other litigants waiting from 1:00 to 1:30 while you called in Frontino, Crawford, and
Braunworth. Wait till I get the video from Walmart that Frontino is hiding from you,
and don't you just want to know if some audio exists of the interrogation.
Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
your cop lying, see your video drivers license produce ap
Sent: Sun 12/04/11 4:05 AM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org; robertsp@reno.gov
pgoins@rsic.org, lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
We spend half the "trial" arguing about whether your lying cops had enough
"information" (their definition included personally identifiable information to identify
the accused sufficiently to issue a citation, A CURRENT NEVADA'S DRIVERS
LICENSE WOULD DO JUST FINE ON THAT ACCOUNT) to issue a citation, and
how, because they didn't, they had to conduct a search incident to arrest, yet YOUR
OWN DAMN VIDEO (OR RATHER, WALMART'S, BUT ITS HARD TO SEE
WHERE YOU GUYS END AND WALMART BEGINS), THAT YOU EFFING
PRODUCED (OR RATHER THE RENO CITY ATTORNEY PRODUCED AFTER
THE BOYS AT WALMART "COMPILED" VIDEO, WHICH CURIOUSLY DID
CONTAIN A FUCKING SECOND OF VIDEO SHOWING ANY OF THE ALLEGED
CONCEALING OR CONSUMING THE ITEMS IN QUESTION! SHOWS THE

ACCUSED HANDING THEM A DRIVERS LICENSE AND THEM CALLING IT IN
TO CHECK FOR PRIORS (THAT WILL SHOW UP IN DISPATCH REPORTS AND
OTHER DOCUMENTATION). THESE KEYSTONE COP EFFUPS HAVE
DEFAMED ME AND YOU SPONSORED IT, CULTIVATED IT.
I CAN GIVE YOU UNTIL TUESDAY TO MAKE A STRONG EFFORT TO
CORRECT THIS, AFTER THAT, I HAVE TO MAKE MY MOVES AND FILE MY
MOTIONS. JUDGE VAN WALRAVEN WOULD BE ASHAMED OF HOW THIS
HAS BEEN HANDLED.
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS A FAR
MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT THAT
WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS "PARTICIPATION", AND
ITS ALL ON TAPE.
I want you to move for, OR ASK THE CITY ATTORNEY TO MOVE FOR, a Rule 59
Motion to Set Aside or some other motion to have the Judgment Set Aside. Your cop
witness clearly had a driver's license produced to him at the 6:49 mark of
WALMART'S OWN DAMN VIDEO! And you suborned his perjury on the witness
stand in violation of many of the POLICE CODES YOU ARE HELD TO. Further,
what are you going to say when the UPC from the alleged receipt appears on the
purchased receipt, in combination with Frontino's adamant assertion that they wouldn't,
in combination with the same from Crawford, in combination with Frontino admitting
he couldn't hear what was said between the accused and the cashier, in combination
with the "same UPC, hit the quantity number" practice common at Walmart? Further,
your Officer Crawford, as a witness, admitted on tape at the trial that "he didn't have
to get more evidence before Reno City Attorney Roberts and Judge Howard could jump
in and cut him off. That's gametime. Frontino, Crawford, and Braunworth, sat around
joking like goofy frat boys the preceeding 30 minutes in the hallway in front of the
court room, like a group of 3 buddies who hang out all the time, except, 2 get paid by
you, and one gets paid by Wal-Mart, who pay the people who pay you. Then all three
of them wait around the hear the verdict at 8 pm hours after Frontino and Crawford
finished testifying. Maybe the don't realize Judge Howard wasn't ruling on the Appeal,
the Rule 59, 60 motions, Motion for Reconsideration, defamation, wrongful arrest, false
imprisonment lawsuits, etc. Fix it now while you can. Wait till I get the video from
Walmart that Frontino is hiding from you, and don't you just want to know if some
"other" audio or video exists of the interrogation.
Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
discovery request;
Sent: Wed 12/07/11 1:16 AM
To: robertsp@reno.gov; kadlicj@reno.gov
Dear Ms. Roberts,
In the discovery you provided in this matter there is a fax from the RSIC to you that has
a fax heading for what appears to be "page 1" followed by pages without that
heading...then a heading with "page 4" etc... I want the entire contents of anything
provided by the RSIC and Walmart to you or anyone connected with the Reno City
Attorney or the Reno Municipal Court. Further, I want all media provided by Walmart,
and I question why you needed 45 minutes with the three witness who testified at the
November 30th, 2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a
NRCP 11 motion requiring you to correct the perjury you suborned in court with
respect to the patently contradictory testimony of Officer Crawford vis a vis the video
evidence you yourself provided in discovery.
Further, I spoke with Mr. Hazlett-Stevens shortly after the September 9, 2011 arrest in
this matter demanding a copy of all documentation or discovery that I had any right to.
I was told I would not have any opportunity to review such materials prior to the
arraignment, which was not set for a full 30 days out from the arrest. Do I not have a

right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of
the arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written
demands and requests for such discovery and documentation were met with refusals to
provide such materials, and, in some case, claims that your office did not even have
such materials and would not get them until after the arraignment. Further, I spoke with
and provided written requests to RSIC Sargent Avansino within 2 days after the arrest
and he refused to provide the materials, as did the Reno Municipal Court. Please alert
the court to any wrongdoing on your's or the Reno City Attorney or the RSIC part in
this regard in prejudicing my ability to defend my case by delaying the production of
essential discovery, then refusing to agree to a continuance at trial, after earlier
providing a written agreement to such a continuance.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
RE: your failure to propound discovery
Sent: Thu 12/08/11 3:44 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov

Mr. Hazlett-Stevens,
We did definately talk on the phone regarding the matter to which I do not have
representation, the RSIC arrest case 11 DR 22176 2I for which Deputy City Attorney
Pam Roberts is the prosecutor. I was denied my Sixth Amendment right to court
appointed defense counsel in that matter, and represented myself. As such, there is no
rule precluded you from communicating with me about 11 DR 22176 2I. You did speak
with me about that. I called you within a couple days of the September 9th, 2011 arrest
in that matter describing my exigent desire to obtain a copy of the discovery. I was
transferred to you and we spoke at length about it, you describing why you could not
give it to me. Is it your contention that your office or the State does not have a duty to
provide the defendant a copy of certain pieces of discovery within 48 hours of arrest?
Regarding the matter for which Mr. Puentes took the baton from Mr. Taitel, is it clear to
you how Mr. Taitel was somehow, apparently, able to assent to a continuance, only to,
apparently, find some need to pass the baton to Mr. Puentes very, very shortly
thereafter? Why did Mr. Taitel's status as attorney of record change? Was it due to a
conflict? Why didn't that conflict prevent Mr. Taitel from abstaining from assenting to
the continuance in the trespass case, which was scheduled for trial December 13, 2011?
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Date: Wed, 7 Dec 2011 07:34:25 -0800

Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded with you, and your
statement that you spoke with me is false. I have never spoken with you. You may have your attorney, Roberto Puentes,
contact me with any discovery issues or issues regarding the City's Motion to Continue. Please do not correspond with me
regarding this case in the future. As an attorney, you are fully aware that I cannot communicate with a you as a represented
party. Do not contact me without your counsel.
Thank you,
Chris
City of Reno
Tel: 326-6628
Fax: 334-4226
To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
I am writing to request a copy of any and all discovery, pleadings, documentation, correspondences,
or media in any way connected to the trespass case against me for which Lew Taitel was apparently
my court appointed attorney, but whom no longer is. Further, I wish to be copied on everything
past and present in any way related to this matter until and after I procure another attorney. I did
not agree to the continuance you sought, nor was I informed you were seeking it. I find it
particularly troubling that a continuance was granted in the trespass case to the same man who is
applying an unlawful rent distraint on both my client files, personal property, AND THE
EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT LARCENY CASE
FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S
HANDLING BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL BY
THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY SUBORNING
THE PERJURY OF RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted against me
there is a fax from the RSIC to you that has a fax heading for what appears to be "page 1" followed
by pages without that heading...then a heading with "page 4" etc... I want the entire contents of
anything provided by the RSIC and Walmart to you or anyone connected with the Reno City
Attorney or the Reno Municipal Court. Further, I want all media provided by Walmart, and I
question why you needed 45 minutes with the three witness who testified at the November 30th,
2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a NRCP 11 motion requiring
you to correct the perjury you suborned in court with respect to the patently contradictory testimony
of Officer Crawford vis a vis the video evidence you yourself provided in discovery.
Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest in this
matter demanding a copy of all documentation or discovery that I had any right to. I was told I
would not have any opportunity to review such materials prior to the arraignment, which was not
set for a full 30 days out from the arrest. Do I not have a right to a copy of the pc sheet, arrest
report, and witness statements within 48 hours of the arrest? The fax to your office from the RSIC
is dated 9/12/2011, yet my written demands and requests for such discovery and documentation
were met with refusals to provide such materials, and, in some case, claims that your office did not
even have such materials and would not get them until after the arraignment. Further, I spoke with
and provided written requests to RSIC Sargent Avansino within 2 days after the arrest and he
refused to provide the materials, as did the Reno Municipal Court. Please alert the court to any
wrongdoing on your's or the Reno City Attorney or the RSIC part in this regard in prejudicing my
ability to defend my case by delaying the production of essential discovery, then refusing to agree
to a continuance at trial, after earlier providing a written agreement to such a continuance.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
agent responsible for delivering it to the intended recipient, y ou are hereby notified that you have received this document in error and that

privilege.

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11 cr 22176 2I
x
Judge Howard
Zachary Barker Coughlin
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
"Ellis" or "John", Customer Service Manager or ASM W. 7th St. Walmart 89503
Loss prevention manager and
2:06-cv-10887-GCS-VMM Doc # 1 Filed 02/28/06 Pg 1 of 19 Pg ID 1
6 again, that is rmc 11 cr 22176

RENO MUNICIPAL COURT
P.O. Box 1900
Reno, NV 89501
(775) 334-2290
Fax (775) 334-3824
E-mail address: RenoMuniRecords@reno.gov
RECORD REQUEST
INSTRUCTIONS: Request Date: ______________
1. Print out this request form.
2. Fill the form out completely.
3. Mail, fax or email your request to the Court.
4. You will be notified when your records are ready for pick up.
Copies may take 3-4 weeks
File Information:
Defendants Name: ______________________________________ Date of Birth: _______________________
Reno Police Case/Citation Number: ____________________________________________________________
(If you do not have this number you can contact Reno Police Department at 775-334-2175)
Charge(s):_________________________________________________________________________________
Charge Date: ______________________________________________________________________________
Requestor:
Name: ____________________________________________________________________________________
Mailing Address: ___________________________________________________________________________
Phone Number: ___________________________ Fax Number: ____________________________________
E-mail address: _____________________________________________________________________________
CHECK ONE:
Computer printout: This includes case history and disposition. ($0.30 per page)
Certified computer printout: This includes case history and disposition, all copies certified. ($3.00 per page)
I.N.S. Certified copies: ($3.00 per page)
Other documents: (Please specify) __________________________________________________________
You will be notified by phone or e-mail of the cost and when to pick up your records
11 28 2011
Zach Coughlin
9/27/1976
trespass
November 13th, 2011
Zach Coughlin
817 N. Virginia St
775 338 8118
949 667 7402
zachcoughlin@hotmail.com
x
x
and and all documents, and audio/video materials
pc sheet, witness statements, related police reports
dispatch recordings, 911 calls or other phone calls
Reno Police #11-22185
Page 1of 3 City of Reno : Court Rules and Procedures
11/29/2011 http://www.reno.gov/Index.aspx?page=211

Court Rules and Procedures

Rule 1: Applicability of Rules
A. These rules may be referred to as the Reno Municipal Court rules and
may be abbreviated as R.M.C.R. These rules are intended to supercede
the rules promulgated and made effective on January 1, 1980 by the
Reno Municipal Court.
B. Whenever it appears that a particular situation does not fall within the
purview of a rule, or that a literal application of a rule would cause a
hardship or injustice in a case, the court may make such order as the
interests of justice require.
Rule 2: Organization of the Court
A. The Municipal Court consists of a number of departments designated by
City Council resolution, each presided over by a judge duly elected or
appointed to that position. Judges pro tem may sit in each department
from time to time as authorized by law. A judge pro tem duly appointed
and authorized by the presiding judge of a particular department to sit in
that department shall have the same jurisdiction as the presiding judge,
except that the judge pro tem has jurisdiction only over matters to be
heard on his or her assigned docket. Judges pro tem are not permitted to
act on any motion filed in any case, except those requiring resolution
before a case can proceed on the docket to which the pro tem judge is
assigned.
B. All cases set for trial or other post-arraignment proceeding, except a
sentencing set by the arraigning judge, shall be randomly or sequentially
assigned to one of the departments. Insofar as is practical, all cases
pertaining to a defendant shall be assigned to the same judge. In the
event a judge must recuse himself or herself, the matter shall be sent to
the administrative judge for reassignment to another department.
C. The elected or appointed judges of each department may act for one
another by mutual agreement as circumstances dictate.
D. Each year, the elected or appointed judges shall select one of their
number to act as administrative judge for the upcoming fiscal year. The
administrative judge shall handle all court administrative matters and
shall be authorized to speak publicly for the court on matters of court
policy.

Rule 3: Authorization to Represent

A. Attorneys representing defendants shall promptly serve written notice of
their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the
court and serve the City Attorney with the same. The court may rule on
the motion or set a hearing.
Rule 4: Motions
A. Except for good cause shown, all motions shall be accompanied by
affidavit, and, when appropriate, by points and authorities. All motions
must be served on the opposing party and must be file stamped along
with accompanying proof of service.
B. The opposing party may file and serve answering points and authorities
on the moving party within 10 days after service of a motion.
C. The moving party may file and serve reply points and authorities within 5
days thereafter.
D. Upon the expiration of any time period set for response by this rule,
either party may file and serve a written request for submittal of the
motion, or the court may consider the motion submitted.
E. An opposition to a motion must state the reason(s) for objection.
F. Motions shall be decided without oral argument unless oral argument is
ordered by the court.
Rule 5: Motions by Facsimile
A. All rules and procedures that apply to motions filed in person at the
court shall also apply to motions filed by facsimile, except as otherwise
specified in this rule.
B. All persons are eligible to use motion-by-facsimile procedures.
C. All motions filed by facsimile must be accompanied by a cover sheet
which must include the persons name, address, fax number and
telephone number.
D. All facsimile motions filed by an attorney must include the attorney's
name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
E. All motions filed by facsimile must be accompanied by proof of service.

Service may be accomplished by facsimile when the receiving party is a

governmental agency, an attorney, or with the consent of the receiving
party. If service of the motion is accomplished by facsimile the 3-day
allowance for mailing shall not be computed into the time for response.
F. A defense attorney filing a motion in the first instance must also file a
proper authorization to represent.
G. Any motion received by the court after 4:30 p.m. or on a non-court day
shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except
for good cause. A motion or stipulation for continuance must state the reason
therefore and whether or not any continuance has previously been sought or
granted.
Rule 7: Corporations
Except with the permission of the court, a corporation or other business entity
shall not appear in propria persona.
Rule 8: Courtroom Conduct and Attire
Proceedings in court should be conducted with dignity and decorum. All
persons appearing in the court must be appropriately attired. All attorneys
must wear appropriate business attire.
Rule 9: Appeals to District Court
Except as otherwise provided in NRS 177.015 a defendant in a criminal action
tried before a Municipal Court Judge may appeal from the final judgment
therein to the Second Judicial District Court, at any time within 10 days from
the date that judgment is rendered.
Effective January 1, 2000
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
Janice store clerk walmart arrest receipt cashier 2nd St. 89501 Walmart
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
Brian Bain 2nd st Walmart Reno and LP supervisor 2nd St. 89501 Walmart
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
faxed to or
asdfsadf Declaration
29th
NOvember, 2011
29th
November 2011
/s/ zach coughlin, signed electroncially
29th
dsafsdfaasdffdasfsafds
df
under penalty of perjury NRS
Janice cashier
, Brian Bain Store Manager; LP manager, 2nd ST. Walmart
John Ellis and ASM "Connie" 7th St. Walmart
emailed
NOvember 2011 notary not required where
Declaration under penalty
of perjury made NRS
and subpoena duces tecum
please appear and further bring any evidence including media related to
retaliatory threats by walmart staff or lp personnel
QUERY- "CIVILRECOVERY"W/255 DATABASE(S)-
WAL-MART ALLCASES,ST-ANN-ALL,NV-RULES,NV-AD
C,ALR,AMJUR,LAWREV-PRO
1. Odorv.Wal-MartStoresEast,Ltd.Partnership,
SlipCopy,2011WL3203760,E.D.Ky.,July07,2011(NO.CIV.A.
10-287-WOB)
...endangermentintheseconddegreeisaClassAmisdemeanor.FN4.KRS
446.070provides:Penaltynobartocivil recovery:(1)Apersoninjuredbythe
violationofanystatutemayrecoverfromtheoffendersuchdamagesashesus-
tained...
...Defendantviolatedthesestatutes.Infact,theonlyfactsassertedarethat
PlaintiffwasstruckbyanautomobilewhileinWalMart's parkinglotandthat
WalMart failedtouseappropriateandreasonablemeanstoproperlycontrol,
operateand/ormanageitspremises.(R.141,...
2. Whitev.Wyeth,
227W.Va.131,705S.E.2d828,2010WL5140048,W.Va.,December17,2010
(NO.35296)
...applicabletoacommon-lawfraudclaimapplied,theSupremeCourtnotedthat
[r]elianceisnotagenerallimitationoncivil recovery intort.Id.at655,128
S.Ct.2131.TheCourtwentontosayinBridgethatwhileitmay...
...must,ifpossible,begiventoeverysection,clause,wordorpartofthestatute.
Syl.Pt.3,Meadowsv.WalMart Stores,Inc.,207W.Va.203,530S.E.2d676
(1999)Werecognizethatsomestatesrequirerelianceonthedeceptive...
3. Crouchv.Johnson&JohnsonConsumerCo.,Inc.,
SlipCopy,2010WL1530152,D.N.J.,April15,2010(NO.
CIVA09-CV-2905(DMC))
...construedtolimitaperson'srighttoseekpunitivedamageswhereappropriate.
FN4.K.R.S.446.070Penaltynobartocivil recovery.Apersoninjuredbythe
violationofanystatutemayrecoverfromtheoffendersuchdamagesashesus-
tainedby...
...2006to2008purchasedDefendants'products.J&JisaNewJerseycorpora-
tionengagedinbusinessthroughouttheUnitedStates.Wal-Mart isanArkansas
corporationengagedinbusinessthroughouttheUnitedStates.Therefore,the
KentuckyStatecontactsintheinstantmatter...
4. Kellyv.Palmer,Reifler,&Associates,P.A.,
681F.Supp.2d1356,2010WL111492,22Fla.L.WeeklyFed.D599,S.D.Fla.,
2011ThomsonReuters.NoClaimtoOrig.USGov.Works.
January11,2010(NO.08-21843-CIV)
...witheitheroftheseclaimssufficienttosendthemtothejury.18FN18.
Plaintiffsfocusontheallegedlydeceptivecivil recovery practicesemployedby
thePalmerLawFirmbutdonotclaimtheamountofmoneySimonandBaum
paidwas...
...pursueciviltheftclaimsagainstthem.NotwithstandingPlaintiffSimon'stesti-
monythatshedidnotbelievehersonstoleanythingfromWal-Mart andshe
onlypaidbecauseshewantedtoavoidbeingsuedandincuradditionallegalex-
penses[D.E.165-3at...
...ofthesePlaintiffscanlegitimatelyclaimthattherewasnopossiblebasisforre-
coveryunder772.11,whichcontemplatescivil recovery forattempted
shoplifting.See772.11(1)Anypersonwhoprovesbyclearandconvincing
evidencethatheor...
5. Robinsonv.RootoCorp.,
617F.Supp.2d748,2008WL1999325,W.D.Tenn.,May06,2008(NO.07-2543)
...E.D.Pa.2007)IadopttheviewofthosecourtsthattheFHSAhasnoprivate
rightofactionGibsonv.WalMart Stores,Inc.,189F.Supp.2d443,449
(W.D.Va.2002)TheFHSAprovidesfornoprivaterightofactionStatetort...
...precedentsoutsidetheThirdCircuit,IfindthattheFHSAdoesnotcontaina
privatecauseofaction.Isgettv.WalMart Stores,Inc.,976F.Supp.422,429
(S.D.Miss.1997)Insum,exceptforthefirstCortinquiry,alloftheother...
...Crossv.Bd.ofSupervisors,326F.Supp.634(N.D.Cal.1968)(holding,seven
yearsbeforetheSupremeCourtdecidedCort,that[c]ivil [r]ecovery underthe
FHSAmaybeappliedunderappropriatecircumstances[2]Afewcourtshave
alsoappliedthereasoningofRiegel...
6. Stringerv.Wal-MartStores,Inc.,
151S.W.3d781,2004WL2363767,150Lab.Cas.P59,920,21IERCases1682,
Ky.,October21,2004(NO.2001-SC-0262-DG)
...aclaimforcommonlawinvasionofprivacy,thetrialcourtappearstohave
treatedAppellants'claimasoneforcivil recovery foraviolationofastatute.Ac-
cordingly,we,liketheCourtofAppealsbelow,willevaluatetheclaimasAppel-
lants...
...TheCourtofAppealsheldthat:(1)thetrialcourterredwhenitgrantedpartial
summaryjudgmentforAppellantsbecauseWalMart's conductinrecording
conversationintheclaimsareaasamereincidentoftheirintenttovideothearea
fall[s]shortofintent[W]eareconvincedthattheactsofWalMart werenotof-
fensivetotheeavesdroppingstatute;and(2)Appelleeswereentitledtoadirec-
tedverdictattrialbecauseAppellants...
...sufferedasaresultoftherecordedconversations,andwethinkitincumbent
uponappelleestodemonstrateinjuryresultingfromWalMart's audiosurveil-
lance.Hence,weareoftheopinionthatappelleesfailedtoprovedamagesflow-
ingfromtheillegallyrecordedconversations...

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