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liON. OOROnlY NASIIIIOL~n:S OepanmcI"" 1 .

liON. KENN~'l1 R.IIOWARD Dcpanmtnl4

Mr. David Clark, Esq. Office of Bar Counsel State Bar of Nevada

RENO MUNICIPAL COURT

March 14,2012

CASSANORAJACKliON Court AdminiWDtOr

RECEI~~~:::. or Allcnm:lrvc Scntcncina

MAR 1 .: 21112

STATE BAR OF NEVADA RENO OFFICE

9456 Double R Blvd., Suitc B Reno, NV 89521 CONFIDENTIAL

Re: Zachary Barker Coughlin, Nevada Bar No. 9473

Dear Mr. Clark:

This leuer constitutes a fonnal complaint of allomey misconduct and/or disability against Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this auomey being experienced by myself and the other three judgcs in Reno Municipal Court. My two most recent Orders in what should be a simple troffic citation case are self-explanatory and an: included, together with copies of massive documenls Mr. Coughlin has fax-filed to our courl in this case. Audio recordings of two of my hearings in this mailer are also included. lie failed to appear for the second one this past Monday.

I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge being out for surgery. We have mUltiple addresses for Mr. Coughlin and can't seem to locate him between cases very easily. We are selling that case for trial and allempting to serve him at the most recent address we have (1422 E. 9'" SI. 112, Reno NV 89512), nllhough I heard today he may be living in his vehicle somewhere. We do have an address for his mother, however, as she recently posted part of a fine for him.

Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to the Second Judicial District Courl. Judge Bill Gardner, Department 2, also has a mailer currcntly pending in his co uri with Mr. Coughlin os the defendant I have enclosed some copies of documents from those mauers, in chronological order, simply because they appear to demonstrate that he is quickly decompensating in his mental status. Our statTalso made you some audio tapes of COUll hi in hearings in Departments 2 and 4 so you can hear for yourself how this allomey acts in courl. You can sec his behavior in my traffic citation case does nol appear to be an isolated incident.

P.O. 80_ 1900. Rft10, NV 89505-1900. t Soulh Slur. Sired .. Reno. NV ~I Telephone: 77!1-JJf-U90. FacsImile: 77S-JJ.a..18Z4

www,[f"gmun!slp.'rgun·rnm EXHIBIT

t? 02959

1782

Mr. David Clark March 14,2012 Page 2

It is my understanding that Reno Justice Court also has a maller pending on this attorney. My Judicial Assistant was contacted by the Washoe Public Defender in Fehruary when I had Mr. Coughlin jailed for Contempt of Court and they stated that they represent him in a Gross Mistlemeanor mailer in RJC. I have no uther information on thaI.

You will have the full cooperation uf myself, the other judges, and the staff of Reno Municipal Court in your pursuit of this maller. Mr. Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff WId even our pro temp judges on the mosl simple traffic and misdemeanor mullers. I do think this is aeuse of some urgency, WId I apologize for taking two days to get this package to you; our IT person was ill and could nol make the copies of the audios of Mr. Coughlin's hearings until today, and I felt it was importanl that the audios he included in the materials 10 be considered by Ihe Slate Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had appointments with clients. I do not know if that was true, but if so, he could be causing serious harm to Ihe practice of law in Northern Nevada and could be jeopardizing someone's freedom or property interests.

Please contact me if vou need any other information. My direct line is and my cell phone is . '.not for public dissemination). My email is HolmesD@reno.gov My Judicial Assistant is Marilyn Tognoni and she can reach me at any time. Her number is 775-334-3822 and her email is TogniniM@reno.!!ov .

encs.

Thank you for your allention to this mailer. Yours truly,

~?~~#-L~ The Hon. Dorothy Nosh Holmes Reno Municipal J udlle

P.O. On 1900. Reno. NV 89~1900. I Soulb Sinn Slru •• Rrno. ; .. V Rq~1 Trltphone: 77~-JJ.a...2l90. FIt'!JlmiJe: 115-JJ4.J81.c

www ... nomunlcfp •• c9urt.(Om

02960

1783

NOTE: IF THIS IS THE LETTER KING SENT TO COUGHLIN REGARDING THE

HOLMES GRIEVANCE OR THE 2JDC L. GARDNER GRIEVANCES ITS OBVIOUS WHY

KING FELT HE COULD NOT PUT IT INTO

EVIDENCE.

RE: my attempt to be provided access to the

grievances filed today

From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.Sent: Mon 4/02/12 3:57 PMTo: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)

Dear Mr. Coughlin,

I have opened 3 disciplinary files against you. They are identified by number below:

NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill

NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes

NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner

You have received the grievance from Mr. Hill and also the grievance from JudgeHolmes. The Grievance from Judge Gardner relates to her “Order After Trial” in thecase of Ashwin Joshi v Barti Joshi, Case Number DV08-01168, wherein she describesyour conduct at pages 12 and 13. I have received certified copies of the contemptorders, a certified copy of the conviction at Wal-Mart, and an incident report fromMarshals Thompson and Coppa regarding your conduct on March 22, 2012. I alsohave the recordings of the court proceedings at issue.

At this time, I do not expect to be providing you with any additional information. Ifyou have additional information that you want me to be made aware of in responseto the grievances identified above please feel free to mail them to me.

Sincerely,

Patrick King, Assistant Bar Counsel

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Monday, April 02, 2012 2:39 PM

To: Patrick King

Subject: RE: my attempt to be provided access to the grievances filed today

Mr. King,

I need for basic procedural due process protections to be afforded before anyconsideration of any arrangement you have in mind would be appropriate. It ismy understanding that we are still in the stage of the process where you areproviding me indication of the allegations against me and documentation insupport and explanation thereof, and that there is still additional materials andcomplaints which you have so far chosen not to allow me access to, even toview upon my responding to your stipulation that I could only so view suchmaterials upon visiting the Reno office of the State Bar of Nevada in person. Such as, please answer the questions I have posed you in my recent emails,especially with regard to providing copies of and information related to these"other different judges" supposedly submitting written complaints about me toyou. Further, please explain whether you requested materials from JudgeNash Holmes, as her letter to you appears to indicate, in her statements that

she "apologizes for taking two days to get these materials to you" that yourequested such materials rather than she sending them to you on her ownaccord? Please explain.

Sincerely,

Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;

ZachCoughlin@hotmail.com Nevada Bar No: 9473

RE: my attempt to be provided access to the

grievances filed today

From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.Sent: Tue 3/27/12 9:24 AMTo: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)

March 27, 2012

Dear Mr. Coughlin,

Perhaps you are not fully aware of your behavior. At our brief meeting yesterday Iperceived you as very hostile and even threatening. Under those circumstances Ifelt it better to terminate the meeting.

If it was not your intent to appear hostile or to attempt to intimidate me then youmight consider how I perceived your conduct. I had intended to try to listen to youand determine how my office could best

help you address the grievances that I have received. You said you did not havetime and simply wanted to argue about your receipt of e-mail or mail. I did not saythat I did not care if you received the

information I sent to you, I said I did not care how your received it, so long as youreceived it. I do care that you receive the information that I send to you. As Iattempted to explain, I will be meeting with a panel

to have them make a determination about the grievances that have been madeagainst you by Mr. Hill and the Judge from Department 3 that you read at my office. I have asked for a written response to those

grievances. In response I received many e-mails with attachments. I will soon besharing the grievances with a disciplinary panel and will advise them of yourresponses to date.

I will keep you advised of the panel’s determination.

Sincerely,

Patrick King

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Monday, March 26, 2012 5:35 PM

To: Patrick King; Glenn Machado; David Clark

Subject: my attempt to be provided access to the grievances filed today

Dear Mr. King,

This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today

and attempted to be provided access the the various "other different judges" grievances that I, prior to last

Friday, was completely unaware of. I have sent you several written correspondences detailing the tampering

and other problems with my USPS mail incident to the two domestic abuser attacks I have been subject to since

approximately 1/1/12, and ask that you copy my on all correspondences or document production via email and

fax. Today, you showed me a two page letter from Judge Nash Holmes. Did you interpret it to be a

"grievance"? How is that designation arrived at? You refused to identify the names of any other judges from

whom you have received any other similar such materials and further refused to allow me to view and such

items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused.

Further, you told me you didn't care I received anything you sent me and stated that I did not have a right to

review such complaint letters, grievances, or other materials, prior to being questioned by you and before any

such meeting. I informed you that I am considering different attorneys to represent me right now, and indicated

I need these materials to prepare for any future meeting with you. My records incidate that your letter of

3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let

me know if you received any sort of "return to sender" letter for that mailing.

Sincerely,

Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;

ZachCoughlin@hotmail.com Nevada Bar No: 9473

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01698

1784

NOTE BY COUGHLIN: THIS IS ONE OF THE BIGGEST EXAMPLES OF THE SBN'S FRAUD

CONSIDER THE EXCISING OF PAGE 1 OF THIS

3/7/12 FILING BY COUGHLIN, AND THAT

ALLEGATIONS BEING DONE BY A

REVIEW OF SUCH PAGE 1

FOLLOWING THIS

VERSION OF

THAT FILING

ESPECIALLY WHERE

SUCH BARES THE

SBN'S BATES

STAMPING FROM

THE 11/7/12

SCR 105(2)(c)

fiasco.

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CERTIFICATE OF SERVICE

Pursuant to NRCP 5(b), I certify that I am an employee of the Reno Municipal

Court, Reno, Nevada, that I am over thlt age of 18 years and not a party to the above

action, end that on this date, 8ltrved a true end correct copy of the attached document

10 Ihe following as set forth below:

Alllaon Orma .. Deputy City Attorn.y PO BOil 1900 Reno NV 89S0S

Zachary Barker Coughlin, lI.q, 1422 E. 9'" Street .2 Reno NV 89812

X Placing said document In a .ealed envelope and placed for collecting and mailing by Unites States mall In Reno, Nevada, postage prepaid following ordinary business practices.

Washoe County Jail Court Services

Facsimile (FFAX)

Electronic Mail (E-mail)

Inner-office mail following ordinary business practices

Personal Delivery.

DATED: March 13,2012.

01700

1786

NOTE BY COUGHLIN: NOW, HOW FRAUDULENT IS SBN KING'S FHE9 UPON VIEWING

THIS COMPLETE COPY OF RMC HOLMES' 3/13/12 ORDER (WHICH IS A REAL PIECE

OF WORK ITSELF) WHERE THE PAGE 1 OF 3 OF COUGHLIN'S FILING DISPROVES THE

SBN'S

ALLEGATIONS

NOTE BY COUGHLIN: THE BATES STAMPING IS FROM THE 3,100 PAGE PRODUCTION

OF DOCUMENTS BY THE SBN TO COUGHLIN ON 11/7/12 IN LIEU OF SCR 105(2)(c)

NOTE BY COUGHLIN: HAVING THIS PAGE 1 OF 3

INCLUDED REALLY STEALS THE SBN COMPLAINT'S

THUNDER, WHERE IT CLEARLY REVEALS COUGHLIN IS

AN ATTORNEY, WHICH THE RMC KNEW FULL WELL

ANYWAYS, BUT

WHATEVER, ITS SANDBOX TIME WITH

THE SBN, JUICEBOXES FOR EVERYONE.

NOTE BY COUGHLIN: WHAT COURT FILE STAMPES

ALL THREE PAGES OF A THREE PAGE

FILING? THE RMC.

Municipal Court Fit ED RE.t\J t�UNIClpn COURT

P.O. B x 1900 Reno, evad a 89505 ZOIZ R 22 Pl112: 26

016H26501533

$OO.42� 0311412012

........ From 89501 US POSTAGE

RETURN 5 RVI E REQUESTED

•

L Zachary Barker Coughlin,. Esq. 1422 E. 9th Street #2 Reno NV 89512

T e9� NFE � S�2C 00 OS/2�/l2 RETURN oro SENOER

COUGHLIN ESO'ZACHARY e TEMPORARILY AWAY

RETURN TO SENDER Be: GSSOS:l90000 1"0941-05'23:1-115-23

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