Zach Coughlin

945 W. 12th St.

Reno, NY 89503
Tele: (775}338-8118

The State Bar of California

Office of the Chief Trial Counsel
Susan I. Kagan, Esq., Deputy Trial Counsel
180 Howard Street

San Francisco, California, 94105

February 15,2007,

RE. Update for Moral Character Application of Zachary B. Coughlin

Dear California Bar Examiners and Ms. Kagan,

Please accept this correspondence as an update for my Moral Character Application, filed
September 28th, 2002. I have previously indicated to Ms. Kagan that there were several
matters to which I need to update my previously filed moral character application.

Section 1.5- My original application listed 2612 Burton, Las Vegas, Nevada., 89102 as
my mailing address. Since that time I have had several mailing addresses and residences.
1 will list the mailing addresses with the corresponding time for which they were my
mailing address, to the best of my knowledge and recollection.
September 2002- December 2002- 1228 S. Casino Center Blvd., Las Vegas, Nevada,
89104
Early January 2003- Early March 2003- 2104 Madera, Sacramento, California, 95825.
Mid-March 2003- June 2003- 1044 W. I" St, Reno, Nevada, 89503.

June--October 2003- 631 Humboldt St., Reno, Nevada, 89503.

November 2003- April 2004- 4263 Greenhorn Ct., Reno, Nevada 89509.
Apri12004-0ctober 2004- 1044 W. I" St, Reno, Nevada, 89503.
October 2004- April 2006- 1255 Jones #132, Reno, Nevada 89503.
May 2006- February 2007- 945 W. 12 St., Reno, Nevada, 89503.

Section 16- DAYTIME TELEPHONE- (775)338-8118. An alternate telephone number

for me is (775) 747-4346.

SecIioo 3.3- RESIDENCE IDSTORY-

-.3
.JODI

September
2002- D ecember 2002- 1228 S. Casino Center Blvd., Las Vegas, Nevada,
89104
2003- ElM
Early
January
Mid-March
2003
ary arch 2003- 2104 Madera, Sacramento, California, 95825.
- June 2003- 1044 W. I" St Reno Nevada 89503
'
,
,
.
J une-0 ctobe 2003
November 2~03 - 631 Humboldt St. FRT, Reno, Nevada, 89503 .
April 2004 0 - April 2004- 4263 Greenhorn Ct., Reno, Nevada 89509.
- ctober 2004- 1044 W. I" St, Reno, Nevada, 89503.
~ctober 2004- April 2006- 1255 Jones #132, Reno, Nevada 89503 .
ay 2006- February 2007- 945 W. 12ili St., Reno, Nevada, 89503.
Section 4.2-EMPLOYMENT HlSTORYI am not currently employed. 1 am looking for work as of February 15th, 2007.
Employment that lasted longer than six. months which was not law-related:
Name of Business: Zachary Coughlin's Memory Foam Mattresses and Pillows

Supervisor: Zachary Coughlin

Street Address: 1044 W. I" St.
City: Reno
State: NV
Zip: 89503
Business Telephone: (775)338-8118
Your Position: Owner and operator.
Length of time employed, from and to: I ran this business off and on from approximately
October 2003 until early 2005. This business was not always actively conducting business

during this time.

Reason for leaving: 1 sought more consistent employment
Updated law-related employment since my eighteenth birthday:

rn the Committee of Bar Examiners' "Response To Application For Admission" it is

written that I failed to disclose my law school employment and termination. I did not feel
that working as a front desk attendant at the law library, where my duties included
checking in and out books and shelvi?8 ~ook~ consti!uted law re~ated employment, as
described in the moral character apphcauons mstructlons to Section 4.2. Further, it was
lief that ] had not worked at the law library for "'onger than six months" (the
be
my
< I' .
instructions
for this section callIor
Istmg em~loyment that" ... lasted longer than six
") J was not employed at the law hbrary for an extended period during the
mon ths.. .
.
winter
break. from classes in Dece.m~er 19?9 through January 2000: I ~o not believe the
'ption of the change drawer inCident In the Response To Application For Admission
. put an 'I owe you " note m t he lib rary ' s change drawer at the end
d. escnt;< Iy accurate 1 did
Isenue
'.
.
.
.
of my closing shift one rught.tbat expla..med that I was borrowmg $10.00 overnight. 1
retUrned early the next .morrung and gave the front ~esk clerk back the $10.00. I rea1ize
this showed very poor Jud~ent. ho.w~ver. I d~ beli~e the facts.show that this incident
w not described in suffiCient detall In the Cahfonua Bar Exarruner's Response. I believe
I
let go from the library due to this incident and poor perfonnance in general of my

:as

l.

daily duties.
I my original moral charac ter app I"IcatlOn I hsted
Perry & Spann as my current employer.
In
.
Ewas employed there from June 2002 through early September 2002. Alan Westbrook,
. sq., my supervisor there, told me 1 was let go due to the unexpected delay in becoming
licensed to practice law in Nevada. Mr. Westbrook told me that I had done a good job

and that he would provide a good reference for me.

Name of Business: Law Offices of Thomas J. Hall, Esq.
Supervisor: Thomas J. Hall, Esq.
Street Address: 305 South Arlington Avenue, P.O. Box 3948
City: Reno
State: Nevada
Zip: 89505
Business Telephone: 775-348-701\

Your
Position: Legal researcher
Length oftime employed, from and to: 1 have performed legal research and writing for
Mr. Hall at a variety of times between May 2003 to the present.
Reason for leaving: I have been an independent contractor to my knowledge, as such, I
cannot say that I ever 'left'.

Name of Business: Hale Lane Peek Dennison and Howard

supervisor: Matt Hippler, Esq.
Street Address: 5441 Kietzke Lane, Second Floor
City: Reno
State: Nevada
Zip: 89511
Business Telephone: (775) 327-3000

Your position: Associate Attorney in Litigation Group

Length of time employed, from and to: July 17,2005 to December 6", 2005
Reason for leaving: I was told by Tim Lukas, Esq., Hale Lane's managing shareholder,

that I was being let go because 'it is not a good fit' .

Name ofBusiness: Schuering Zimmerman & Scully LLP

Supervisor: Robert Zimmerman, Esq.
Street Address: 400 University Avenue

City: Sacramento
State CA
Zip 95825
Business Telephone: (916) 567-0400

Your position: I was hired to be an attorney, but my Nevada license was delayed, so 1

worked as a law clerk.

Length oftime employed, from and to: January 6", 2003-February 14"',2003

li

Reason
leaving' Leo Sc huenng',Esq.,
.
told me I was being let go due to the unexpected
delay in for
becomin

g censed to practice law in Nevada.

~ame of Business: Anderson & Morishita, L.L.C.
upervtsor: Robert Ryan Morishita, Esq.
Street Address: 2725 S. Jones Blvd., Suite 102
Ctty: Las Vegas
State: Nevada
Zip'. 89146
Business Telephone: (702)222-2113

Your Position: Legal researcher.

Length of time employed, from and to: 1 worked on an independent contractor basis on
several assignment between October 2002 and December 2002.

Reason for leaving: 1 took a fuJI-time position in Sacramento CaJifornia with Schuering
Zimmerman & Scully.
'

Section 6.1- Have you ever been in business for yourself'?

Name of Business: Zachary Coughlin's Memory -Foam Mattresses and Pillows
Supervisor: Zachary Coughlin
Street Address: \044 W . I" St.
City: Reno
State: NY
Zip: 89503
Business Telephone: (775)338-8118
Your position: Owner and operator.
Length aftime employed, from and to: 1 ran this business off and on from approximately
October 2003 until early 2005. This business was not always actively conducting business
during this time.
Reason for leaving: J sought more consistent employment.
Name and Address of person who can verify such employment: Coe Swobe, Esq.,
(775)322-2154 ,3 Bret Harte St., Reno, Nevada, 89509.
Section 8.1 Credentials and Licenses:
Issuing Authority: Unit~ ~tates Patent and Trademark Office
Mailing Address: Commissioner for Patents, P.O. Box 1450 Alexandria, VA 22313-1450
Licensed as a patent agent since May of 2003 (though upon becoming an attorney that
may noW be classified as a patent attorney.
License or agent#: 53,905. I am listed as an active agent on the USPTO.gov website.

Please note: the instructions for the section do not setm to call for listing my mattress
business license, as the procurement of it did not require proof of good character and or
examination.

section 9.1 A: The California Bar Examiners denied my application to practice law 2006.
The reasoning for this and the explanation of the circumstances of this denial is known to

.; (l 0 4

the body 10 which lhis updale is being sent.

Section
"1 action
. In
. connection with shipping charges related to
m mattr9.1 C'
b" I was sed'
U
In a elYI
y
ess usmess (Washoe County Case NO. REV 2005-000301). Smalls claims
acbon agamsl applicant fo r non-payment 0 f shippmg
..
'
' 'ff'In
services.
Judgment Iior PIamtl
Iheamounlof$5,161.00.
Section 9 .1 E:
Washoe County Dist Court Clerk
75 Court SI
Reno, NY 89501
Date of Charge: 2005 (I have not been able to ascertain the exact month this suit was
filed).

Section 11.2 and 11.3-ClVIL ACTIONS AND ADM1N1STRATrvE

PROCEEDINGS/nJDGMENTS FILED AGAINST APPLICANT
Yes, I have been a party to a small claims action against myself. I was sued in a civil
action in connection with shipping charges related to my mattress business (Washoe
County Case NO. REV 2005-000301). Smalls claims aclion against applicant for nonpayment of shipping services. Judgment for pJaintiffin the amount of$5, 161.00.
Also, I bad two apparently simultaneous unlawful detainer actions filed against me for my
apartment at 1255 Jones #132, Reno, Nevada 89503. Washoe County Cases No REV
2006-000909 Gudgment for Plaintiff for $660.00) and Rev 2006-001396 Gudgment for
Plaintiff for $720.00)
Section 13 . I Scholastic Discipline
I did not believe being let go from my position as a check out clerk at the UNL V Law
Library qua1ifjed as having been "dropped, suspended, expelled, or otherwise disciplined"
as described in the instructions to this section.
Section 13.5 Past due debts:
1 incurred debts in addition to the unlawful detainer actions mentioned in Section 11.2.
Steps taken to address the debt: I have tried to get my law licenses in California and
Nevada so that] can repay these debts and to work my program of recovery towards the
same goal A description of each debt follows:
AARGON AGENCY INC
Address:
3025 W sAHARA AVE
LAS VEGAS, NY 89102

Account Number'

[1 (j

2010014403
Original Creditor
SIERRA PACIFIC POWER
Status' Coli '
COMPANY
,
eelton account, $470 past due as of Oct 2006

AFNl, INC
Address:
PO BOX 3427
BLOOMINGTON, 1L 61702
Account Number'
2010830230
Original Creditor'
CHARTER COMMUNICATIONS
Status Collection account. $148 past due as orOCI 2006.
CHASE
Address
800 BROOKSEDGE BLVD
WESTERVILLE, OH 43081
(800) 955-9900
Account Number:
441716302291

Status: Account charged offi'Past due 180 days. $824 written off'. $824 past due as of Jan

2007
COLLECTION SERVICEiNE VDA

Address:
777 FOREST ST
RENO, NY 89509
No phone number available
Account Number'
4170660000329713
Original Creditor'
DIGESTIVE HEALTH CENTER
'on account $133 past due as of Dee 2006.
.
Status: C 0 Ilectl
COLLECTION SERVICE/NEVADA
Address
777 FOREST ST
RENO, NY 89509
Account Number

006

IZ....

4170660000336519

Original Creditor:
DIGESTIVE HEALTH ASSOCIATES
Status: Collection account. $419 past due as of Jan 2007.
COLLECTION SERVICElNEVDA
Address:
777 FOREST ST
RENO, NY 89509

Account Number:
5200660000319051

Original Creditor:
RIVER ARMS APT (This represents the same debts as those in the unlawful detainer
judgments)
Status: Creditor cannot locate individuaVColiection account. $1 ,532 past due as ofNoy
2006.
CRED PROTECTIONS ASSOC

Address:
1355 NOEL RD SUITE 2100
DALLAS, TX 75240
No phone number available
Account Number"
1307143532
Ongina1 Creditor:
CHARTER COMMUNICATIONS

Status: Collection account. $267 past due as of Jan 2007.

MACYS
Address
9111 DUKEBLVD
MASON, OH 45040

Account Number"
450306229 .
Status: Closed/Past due 150 days_ $55 past due as of Oct 2005.
NCO FlN/99
Address
507 PRUDENTIAL RD
HORSHAM. PA 19044

--~---

No phone number

_ _,"",- ." ... Itl '1'/1, ... _

Account N b aVailable
1365
urn er'

Original Creditor:
NCOI ASGNE OF

Status Collectio WELLS FARGO

n account ' $1 ,845 past due as of Jan 2007
REVCARE, INC
Address:

5400 ORANGE AVE STE 200

CYPRESS, CA 90630
No phone number available
Account Number"
REVPW ASO 166844883
Original Creditor:

RENOWN REGIONAL MED CTR

Status: Collection account $1,200 past due as of Jan 2007

WELLS FARGO BANK

Address
POBOX 5445
PORTLAND, OR 97228
(877) 778-5697
Account Number"

549095000591 .

Status: Account charged offJPast due 150 days. $1,497 written off $836 past due as of

Nov 2005.
Section 16.1- Accounting for time:
The periods that are not accounted for are due to being unemployed and seeking work.

have had many jobs that were not law-related and lasted less than six months.
This concludes my update to my original moral character application. For your

consideration, I am enclosing a packet of signature pages that detail some of my

attendance at meetings directed towards my recovery_ This list is not entirely complete as
some pages were damaged and many meeti~gs were attended without gathering a
signature. f apologize for the lateness of this update.
Sincerely,

Zachary

COUghlin~ I'

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