12 13 12 0204 62337 26800 nndb member dda kandaras conspiring with wcpd leslie to abuse process with...

7/29/2019 12 13 12 0204 62337 26800 NNDB Member DDA Kandaras Conspiring With WCPD Leslie to Abuse Process With TP

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Lsli, Ji

From: Kadaras aSent husda December 202 020 ATo Lesie imSubject: E he hree Es wcpd aiure to povide essentia 9 ca cd discove o ad

7 202 to ouhin in rcr202-00

Impoance ih

im

I beieve that you shoud send this. Supreme Court Rue 104(a) authorizes State bar counse to investigate a mattersinvoving possibe attorney misconuct or incapacity caed to bar counses attention, whether by grievance or both

This potentiay invoves misconduct (vioation of aw) and incapacity.

Mary KandarasDeputy District Attorney Civi DivisionWashoe County

77 7 57 direct phone

-----Origina MessageFrom: Lesie, imSent: Wednesday, December 1, 01 5:11 PM

To: Kandaras, MarySubject: RE: The Three E's; wcpd faiure to provide essentia 911 ca cd discovery of /1 and /17, 01 to Coughin inrcr01-050

Thanks, pease do. e came to our office afer my emai to you and caused a disturbance We caed the poice, but hefed before they arrived

jim

-----Origina Message----From: Kandaras, MarySent: Wednesday, December 1, 01 :17 PM

To: Lesie imubject: RE: The Three Es; wcpd failure to provide essentia 911 ca cd discovery o 1 and /17, 1 to Coughin inrcr01-050

I wi have to review this tomorrow and get back to you.

Mary KandarasDeputy District Attorney Civi DivisionWashoe County

775 7 57 direct phone

-----Origina Message----From: Lesie, im

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Thebelowemail fromMr Coughlin containsa reference at the end of the firstparagraphtoa websitecontaininga videoclip fromthemovieCape Fear. Please advise whether any action isrequired of our office or yoursregardingthis

possible veiled or indirect threat of violenceagainst attorneysinthisofficeby Mr. Coughlin.

Sent Wedneday December 1 01 59 PMo Kandara MarySubject FW The hree E; wcpd faiure to provide eentia 911 ca cd dicovery of 8/13 and 8/17 0 to Coughin inrcr01-0530

Mary

Peae review my tranmitta to Patrick King at the bar beow and et me know if I houd do anything ee from a civi

perpective.

hank

Jame B Leie Eq.Chief Deputy Pubic DefenderWahoe County Pubic Defender Office350 South Center StreetFifth FoorReno NV 895091-800-7-8031Direct Dia 775-337-488Fax [email protected]

The content of thi communication and a accompanying document and attachment contain CONFIDENIALINFORMAION are egay privieged and are intended for ue and review ony by the party ending ame and theintended reipient. If you are not the intended recipient you are hereby notified that any dicoure copyingditribution ue or taking any action reiant on aid content are CONFIDENIAL and tricty prohibited If you receivedthi comunication in error peae immediatey noti u at 775-337-4800 to arrange return of the originatranmitta. Thank you.

-----Origina Meage-From Leie imSent Wedneday December 1 01 49 PM

To [email protected]

Subect: FW he hree E wcpd faiure to provide eentia 911 ca cd dicovery of 8/13 and 8/17 01 to Coughin inrcr010530

Mr. King

Thank you

Jame B. Leie Eq.Chief Deputy Pubic DefenderWahoe County Pubic Defender Office350 South Center Street

Fih FoorReno NV 89509

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mailto:[email protected]:[email protected]:[email protected]:[email protected]


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mailto:[email protected]:mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://tinyurl.com/bgmlfdr


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fudge he accouns of wha was conained herein or who handed wha o whom, or who failed o pick up his or ha

or Dogans sippery nonsense

From Jleslie@washoecounyus

To [email protected]

CC [email protected]

Subjec: 911 Case

Dae Fri 7 Dec 2012 170908 +0000

Mr. Coughlin:

Aached are he discovery maerials in he abovereferenced case ha you had requesed and we had made an

addional copy of for you in response o your reques. Please noe ha he July 27 2012 cover leer was for your pick

up and you never picked i up Noe also ha he July 272012 packe encloses a copy of he April 17 2012 hand

delivey ransmial of he vey same documens which you received.

Since we have been removed from he 911 case we are closing our file. The aached maerials were siing a our fron

desk Since you failed o rerieve hem we provide he aached couresy copy before final closure of ur file

No response o his ransmial is required from you.

James B. Leslie Esq.

So while Dogan saes on 7/27/12 in 65630 Your Honor I have never even spoken wih Judge Dorohy Nash

Holmes ... he coyly fails o indicae wheher he spoke wih anyone wih he RMC Marilyn Tognoni included r why his

2/28/12 fax o Coughlin was so nsisen ha i was Lakes Crossing's Bill Davis Ph.D." who mus conduc he

Compeency Evaluaion or how i was Judge Clifons 2/27/12 Order for Compeency Evaluaion could have possibly

known and included Judge Ellio as he randomly assigned judge o ha Compeency Case in CR12-0376 (Judge Ellio

on Commiee o Aid Abused Womens Board (CAAW).. .Judge Ellio presiding over Coughlins wrongful erminaion

lawsui agains WCDAs Ofce ECR Parner Washoe Legal Sevices is Execuive Direcor Paul Elcano and CAAW inCV01955...Judge Ellio fails o disclose conflic or recuse hiself Judge Ellio manages o randomy be assgned

Coughlins wo criminal appeals from RMC convicions (he Wal-Mat candy bar pey larceny leading o a 6 monhs so

far emporay suspension of Coughlins law license in 11 cr 22176 in he RMC hen cr-2064 in he appeal Judge Ellio

canned based upon a civil saue requring a down paymen for he preparaion of ranscrips and Ellitt conenion

ha he need no address he meris of Coughlins appeal given he lack of a wrien ranscrip (Coughlin paid for he

audio cd, and its not even clear that the RMC is a court of record anyways and he MC diibue o deendan

insrucions shees and enforces house rules regarding he preparaion of ranscrips ha require one uilizing he

services of RMC oicial ranscripionis Pam Longoni (whom hung up on Coughlin wice and refused prepare he

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mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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transcript in 11 cr 22176/cr1-2064, faied to return emails/faxes, etc.)" and where the RMC refused to even giveCoughlin the audio recording for some time, insisting Coughlin could merely have it made available to Longoni. .. Oh,Coughlin didnt get no continuance from Judge Howard in that 11 cr 22176 (even where he was wrongfully evicted inRev2011-001708 (now on appeal in 60331 and 61383) on 11/1/11, then wrongfuly arrested on 11/13/12 in 11 cr 26405(now feature in 61901, 62104, 54844, 60302, 60317, etc) and incarcerated between 11/13/12 and 11/15/12, nocontinuance for the 11/30/12 Trial in 11 cr 22176, despite an agreement in writing with City Attorney Pamela Roberts(whom put on perjured testimony by three witnesses where she possess a video an other evidence concusivelyproving that Coughlin did provide his drivers license to RSIC Oicer Crawford and where Robert's prosecuted based on

an arrest for a misdemeanor by tribal officers where NRS 178.1255 bars suc an arrest, and where WalMarts ThomasFrontino and Roberts hersef admit no citizen's arrest was effectuated so, about that RPC 3.8 vioation.) Then thereis the appeal in cr12-1262 that Judge Elliott, again, was "randomly" assigned from the conviction y RMC Judge WilliamGardner in 11 cr 26405 based upon the criminal trespass complaint signed by Richar G. Hill, Esq. (opposing counsel inthe summary eviction from Coughlin's former home law ofice in rjc rev2011001708, presided over by Judge Sferrazza,though Hil and his associate Casey D Baker, Esq fax, on October 17th, 2011 to Judge Clifton (who was not Chief Judgeat the time, or anything) an Emergency Ex Pae Motion for Inspection of Coughlin's Law Office, and where in hisOctoer 19th, 2011 Order in that matter 001708, Judge Cliton ruled as "moot" Coughlin 11/17/12 Motion to Set Asidethe 11/13/12 Order following Summa Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on10/25/12, on the condition that Coughlin deposit a rent escrow of $2,275 with the RJC (though Judge Sferrazza admittedlater on the record on 11/7/12 that the RJC Judges had a meeting wherein they all had to agree that Coughlin wasabsolutely correct that the RJC was violating Nevada law in having an unpublished "house rue" corollary to JCRLV 44requiring such rent escrow deposits in landlord tenants matter here JCRCP 83 had not been followed in that the RJC hadnot published and had approved by the N. S Ct any such deviation from the statutory remedies set forth in NRS 40 and118A Judge Elliott managed to torpedo that appea of the crimina trespass conviction stemming from the criminalcomplaint and custodial arrest at Coughlins former home law office by co-signing RMC Judicial Assistant Lisa Wagnersand the RMCs nonsense about not having received Coughlins Notice of Appeal timey under NRS 189010 The proof ofdelivery fax confirmation indicates otherwise, Lisa And regardless the conveniently timed arrest of Coughlin on6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion for New Tria in that matter, and the kited, dated 7/10/12

jailhouse Notice of Appeal by Coughlin, and the curiously failure to grant Coughin tier time in the interim while JudgeGardner manageed to push through his 7/11/12 Order Denying Coughlin's Motion for New Trial, is all the more reasonto apply consternation to udge Elliott's work on the appeal on CR12-01262 Then there is Judge Linda Garner eingJudge Peter Breen, MD's law clerk, and Breen kicking Coughin out of the Mental Health Court based upon Sharon

Dollarhid, Rene Biondo, and Breen and the MHCs own breach of contract (if they provide program materials,acceptance, and a contract that list certain medications as disallowed, how is it they can claim non-compliance or"failure to abide" by the rues for taking a medication not listed therein? Don't ask CPD Joe Goodnight or JenniferRains.. they know what side their bread is buttered on .. .MH12-0032.. so DDA Young tries to jam through a trial in063341 on May 7th, 2012, despite the manatory stay in NRS 178405 and the then still pending Order for CompetencyEvaluation in rjc 2012-065630 from the clandestine status conference Dogan and Young never quite seem to refutehappening on 2/27/12 h, and Judge Cliton, then DA Dorothy Nash Holmes, and Judge Linda Gardner were all coworkers once upon a time, working closey with then Sparks City Attorney/prosecutor Steven Elliott, whom worked forthe law irm o the ather o the anel Chair or Coughlins 11/14/12 SBN v. Coughlin ormal Disciplinary Hearing inNG12-0204, 0434, 0435 (the last two being grievances against Coughlin filed, in part, by RMC Judge William Gardner,prior to Gardner failing to recuse himself from the criminal trespass case against Coughlin before him in 11 CR26405even where Judge Gardners sister Judge Linda Gardners Apri 2009 Order sanctioning Coughlin was cited by

LSs Elcano as the sole basis for firing Coughlin, and where Coughlin filed a Mandamus Petition in 54844 challengingthose sanctions, and where ng120435 was one of three grievances forming the 8/23/12 SCR 105 Complaint againstCoughlin (strangely .the Wal-Mar "candy bar" petty larceny conviction and the formal hearing for the "sole purpose" ofdetermining Coughlins punishment for such required y SCR 111(8) and the Court's 6/7/12 Order got particularly shor

shrift in the 8/23/12 triple grievance numered SCR 105 Complaint y Bar Counsel Pat "Paty Ice" King, a/k/a Pat Salieri,whom wants no part o explaining his statements to Coughlin during the 3/26/12 appearance at the SBN by Coughlin, forth s pups f taking King up n his f t t Cughin viw th matias submitt ang with th givanc

(therein King caimed to have received grievances against Coughlin from three diferent Judges... though, by 3/26/12, itcouldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge Nash Homes and the WCSO and WCDA

o


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impermissibly coniscating Coughlins smart phone without a warrant or court order and wel ater the end o the periodto do a search incident to arrest (the arrest was 2/27/12 or soe pastiche o sumary plenary civil criminal conteptsstatuts that udge Nash Holmes whipped up ... though she avoid NRS 22.030 and deinitely there wasnt no aidavitsignin by 01' RMC Marshal Harley or alleged conduct in a restroom or restroom stal which assuredly was not underthe watchul eye o the court or in the immediate presence o the court .... so uch easier or Bar Counse to eed

Judge Nash Holmes the clear and convicing evidence standard rom Schaeer required to prove an etical violationhave here copy and paste some RPC's into a second bite at the apple and more than 10 days later (civil statute NRS22.010 NRCP and JCRCP 59 allow sua sponte amending within 10 days no 12 days ... 2/27/12 to 3/12/1....void rder o

3/1/1 by Judge Nas Holmes so sorry Patty Ice nice ty no SCR 111(5) an rder or conviction is conclusive proo oguilt and I don't recognize Claiborne as binding authority because it makes my job harder .... ..

Thank You Jim or continuing to prevaricate in writing your recent eail combined wit some uh otr materials tathave been culed will surely be helpul in exposing you or the raud that you are. And Biray Dogan too...h by th waythat 11/7/12 ax coniration page or proo o axing? How is that coming along because I need to se it rom you. Myrecords show absolutely no receipt o any ax o that sort not on that day not on any day .. which means the ball is inyour court to show how Dogan's representations to Judge Serrazza on 11/19/12 in court were not displaying a lack ocandor to the tribunal and How Leslie Tibbals' certiicate on seice therein is not raud

h attached is Goodnights 12 19 11 Request or Discovery which includes

REQUEST R DISCVERYCMES N the Deendant ZACHARY BARKER CUGHLIN by and through his attorney o record Joseph .Goodnight Deputy Public Deender and hereby requests the ollowing discovey pursuant to NRS 174.235 to NRS174.295 inclusive. 1. nspect and receive copies or photograph any written or recorded statements or conessions adeby the Deendant or any witness or copies thereo witin the posseion custody or control o the Stat the existnceo which is known or by the exercise o due diligence may become known to the prosecutor. NRS 174.235(1)(a). Thisrequest includes any video and audio recordings incuding those preseed on pocket recording devices 911emergency cas and any dispatch ogs written or recorded generated in connection with tis case

Jim then there is you chiming in in your role as standby counsel attempting to aid the Court and DDA Young incoercing rom me my ith Amendent rights at the 9:06 a mark on the transcript rom 11/20/12 (Your Honor I'llremind the Court that I am here to jump in in my role as standby counsel anytime the Court's eels he is dragging hiseet.... He is wasting County assets!...vey Atticus inch Jim).

So then there is Jims 10/3/12 subpoena to Ecom/Kelley ood... and given he was counse o record until 10/22/12yet copletey ailed to turn over anything (responsive or not) in relation to that subpoena and the act that the entireSuppression Motion turned on what inormation the RPD received rom dispatch and the act that te audio o theradio trac between the RPD and Dispatch on that night (or at least the portions o it I have been able to extract romthe powers that be) reveal one no report o a possible ight was received by RPD (tey were on the scene by the tiethe 112711 pm text was sent to the displays in their vehicles and the one audible radio traic recording contains nomention o anything beyond check or possible larceny o a cell phone that just occurred suspect still on the scene aso

reports o a loud verbal disturbance ... . Then there is Jim and Goodnight copetely whiing on the detainingargument in addition to the whole assuming we win on the pat down make sure to oppose the notation that therewas suicient probable cause or an arrest and search incident thereto.... not to mention that it was Coughlin (whoseilings Jim managed to cheeruly announce Th Public Deenders ice is not joining in on those ugitivedocuments... despite the 2/21/1 ilings by Goodnight that do just that.. .. ) that pointed out the whole NRS 171360basis or throwing out te search (which Jim managed to not cite to or quote rom in his cosing argument as theupprei Herig.. whre Ji did g t k Cry Gbl quti ss that w ene o o nongmore than establish a citizen's arrest suicient to rebut the NRS 171.360 basis or throwing out the arrest and ruitsculed thererom...).


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Oh, th thr is your oic lcki out th umrs of th cllrs o th disptch os d rfusi to tur ovr v rdctd vrsio of th lld victims cll rcords for th tim i qustio, thry compltly ostructi thdfdt's ility to impch th vrious lis tstifid to y ll th witsss Ad Coch DDA You c tll you llout his 40 miuts cochi sssios visil throuh th plxilss i th Justic Cou loy with rt, Gol,ichty, d Tmplto, d thir costt prroti (lo with RPD Durld) of proscutor uzzwords (willfullywithhld, rport from disptch of possil fiht, my trii d xpric, dtid, "I do't rmmr whomd th cll, I c't rmmr which o of my frids it ws who ws with m, tc, tc) Also, th WCPD prctic

of lcki out loctios d ddrsss sur mks it difficult to stlish icosistcis tw tstimoy d thrports/Witss Sttmts or othrwis utiliz thm for impchmt purposs

So, ow tody, w t this Jim sli mil with ll its rvisioist history ... which oly cotrdicts th positio sli dDo hv tk tht Couhli lrdy pickd up this 7/7/1 pckt (t first Do climd to hv prsolly hddit to Couhli, th chd his story miuts ltr d sid h sw sli prsolly hd it to Couhli d Dssrts to th Court t th 11/7/1 Hri i rcr01-065630 tht h hs vr spok with Jud Dorothy NshHolms (s mtrils rrdi cldsti sttus cofrc of /7/1 d susqut fllout with Jud NshHolms of /7/1 coup hours ftr Do scurd his /7/1 131 pm Ordr for Compty Evlutio i 065630from Jud Clifto).

Th SBN v. Couhli Complit of 8/3/1 spcificlly mtios th rrst of 1/14/1 tht this 065630 cs is sd o,i dditio to th 063341 iPho rrst, d RJC Judicil Scrtry ori Towsd st Couhlis /1/1 i 065630 toth SBN, d offrd to sd Couhli's /15/1 fili i 063341 to th SBN ..d Jud Nsh Holms 3/1/1 Ordr i11 TR 6800 mtios Couhli quoti rock lyrics i fili s sis for hr trsmorii simpl triccittio to forml discipliry hri o thics violtio whri sh quots th Schfr stdrd for thiclvioltio tht Br Cousl hd fd hr rlir i th dy...d tht widow tw th 1:00 pm oticd strt tim ofth trffic cittio tril i 11 tr 6800 d th 330 pm vtul st tim icluds th 15 pm courthous scturydoctri violti srvic upo Couhli (y RMC Mrshl Jol Hrly, o hlf of WCSO Dputy Mch, hird yRichrd G Hill, Esq., t whos offic Couhli ws rtlitd ist y RPD Srt Trtr with th thr trffic cittiosshortly ftr Couhli rportd to Trr th dmissios rrdi riry y Richrd G. Hill, Esq y RPD Offcr ChrisCrtr, Jr....d Mrshl Hly ws srvi th Ordr to Show Cus for th 3/3/1 Hri i th ppl of thsummry victio from Couhlis formr lw offic (whr RPD Crtr md th trspss rrst ow dtild i N. S.

Ct. cs 61901), o hlf of Dputy Mch, i th cofrc room withi th Courtroom B of th RMC, dspitCouhli, filr, hvi lrdy sd it). Howvr, th oly fili y Couhli tht could sid to quot rocklyrics is th /1/1 fili i Dos cs 065630 (th o whr Do hd pprd s ttory of rcord th fildto show up for hri o /13/1, th rtlitd ist Couhli for Couhlis /1/1 fili i 065630 y movifor Comptcy Evlutio d siclly doi solutly othi o th cs for th xt 9 moths sids rpifrom Couhli his mdicl privcy rihts lo with Jud Stv Elliot d DDA ch You t th 4/19/1 hri iCR1-0376 (o of 3 crimil ppls Jud Elliot ws rdomly ssid i which Couhli is prtyto o lowith th wroful trmitio suit y Couhli tht Jud Elliot prsidd ovr i CV11-01955 whri Couhli sudCAAW d W, dspit Jud Elliot iti o CAAW's Bord, d whr Jud Elliot, th Pl Chir t Couhli'sforml discipliry hri of 11/14/1, d Wsho l Srvics Pul Elco ll wt to Stford tothr, dwhr Jud Elliot workd for Pl Chir Joh Echvrris fthrs lw firm, Echvrri d Osor) Th thr isid Grdr i Jud Br's lw clrk, d Jud Br rmovi Couhli from Mtl Hlth Court i MH1

003, whr th MHCs R Biodo d Shro Dollrhid lid out wht mdictios wr listd s ccptd or oti th mtrils providd y Goodiht d or th MHC lo with th cotrct trd ito with Couhli, whom wsccptd ito th MHC. Th thr is WCPD Jo Goodiht d Jifr Ris rfusl to fil ythi dirctd towrdsforci th MHC's cotrct with Couhli, whri thy oth mostrtd thy kow wht sid thir rd isuttrd o d idictd thr just ist sis for ski rcosidrtio of Jud Brs Ordr. Jud PtrBr, MD

7


8/10

unny how ogan did not state to Judge Cion that he never soke with anyone else at the Reno Municial Court aboutCoughin including Marilyn Tognoni but rather ogan just indicated he never soke with Judge Nash Holmes in hisbest innocent ittle boy voice that he cos when he isnt busy tittering away with Jim Leslie in the sectator area duringthe 11/19 and 11/20 Trial in 063341 (where he failed to arise Judge Sferrazza of the fraud attendant to his earlierattestations regarding roof of service (by fax no ess) of his 11/7/12 Motion to Quash Coughlin's Suboena

Also its a bit strange how ogan and the WCPD redact or black out the names of the RPD Officers and Disatch

Oerators beginning on age 16 of the 56 age file Jim Leslie finally emailed me today titled "Coughlin Discovery 911Case" which as is their wont he and ogan have continued to change their stories about whether the had or had notrovided to me already until the last ossible minute before trial whereuon with a Trial date of ecember 11th 2012in rcr2012065630 Jim Leslie finally emails me a 56 age df urorting it to be my "file" One wonders where anyaudio recordings disatch recordings 911 call recordings or other media are any why Leslie and Dogan did not rovidethem Coughlin aeared at the WCPs Oice today and asked for the hard coy of his file yet was told by front deskrecetionist "Paula" (of course no last name rovided) that she "soke with an associate" and they told her that JimLeslie had already rovided Coughlin his file and that he therefore would not be given the hard coy "Paula"eventually seemed to have to admit that the misleading use of the term "associate" actually did not connote her havingsoken with an attorney about the matter but rather Linda Gray whom has been curiously silent as to the aarentmisconduct attendant to her admitting that she did not mail out any written notice to Coughlin of the August 6th 2012"combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over that fact by sending Coughlin a note abouthow he "saved the day" with his "advocacy"skiing ast the art about how the cient Coughlin was not noticed onthe hearing in any matter much less in writingLeslie later refused to indicate with any secificity whatsoever how he"knew" Coughin had been noticed on the 8/6/12 hearing in writingand RJC Judges are only to willing to "believe" JimLeslie Esq when he exlains away vaguely such things

Mr Leslie the thing is I have a Trial in this case rcr2012065630 You have continued in your way (similar to how youaroached the rcr2011-063341 case where Joe Goodnight Esq was counsel of record until you had him removed on7/16/12 the morning of Trial aer Mr Goodnight and I have comleted a video conference final trial rearation at4:30 m on riday July 13th 2012 while I was in custody (ursuant to an arrest on July 3rd 2012 ordered by RPSargent Kim Bradshaw she of the 1/12/12 custodial jaywalking arrest along with RPD Sargent Paul Sifre) . Things fall

through the cracks Mr Leslie when you lace a gag order on the associates you claim to suervise then stubbornlyetulantly and retaliatorily refuse to work the cases you have snatched back from your associatesSimiarly WCPDortier's email to me of ebruary 6th 2012 may have contributed to Mr Dogan's confusion in failing to attend theHearing on eburary 13th 2012 which begat my iling of ebruary 21st 2012 which begat Mr ogan's rocurring theebrury 27th 2012 Orer for Cmetency Evlutin which begat the y summry incarcertion forsummary/lenary/criminal/civil/transmogrified discilinary hearing on an ethics violation/what is jurisdiction? Order byRMC Judge Nash Holmes on 2/27/12 at 4:40 mwhich begat NG120434 and robably 0435 (the SBN v Coughlin SCR105 Comlaint of 8/23/12)

However Mr ogan you are not o the hook just because Jim Leslie laces a gag order on you Mr Leslie sent thisemail today with a 56 age df file urorting to be my "file" I, as now a former client hav rights to "my file" I have

requested my file in writing from your oice on numerous occasions and given your removal as counsel of record on11/22/12 (amazingly Mr gan robably managed to say 200 words on a case that he had been counsel of record on fornearly a year and had not managed to file a single document in that case RCR2012-065630 and had managed to getuset that a client would take issue with his missing the 2/13/12 Hearing even though WCP ortier's 2/6/12 emailmakes clear the matter was assigned to Mr ogan at that oint and he had already sat down and discussed the casewith Coughlin or over one hour on or about ebruary 8th 2012 where Coughlin went to check in with Mary Watsonwm ws en rereene by W rnell w rgge Wtn ver e r uie u ili ndemanded they breathalye her client They did she was taken into custdy

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9/10

So, afer sttng down wth ogan for at least an hour and dscussng arous thngs, some ncludng matters elated tothe case he was then attorney of record on RCR2012065630, the February 13th, 2012 cour date (ogan and Coughlnhae conflctng ews as to what was agreed upon and the applcatons of NRS 178388).

NRS 178.388 prodes that the defendant must be present at arragnment, tral, and sentencng and prodes that thedefendant may wae hs appearance when ceran condtons are met

Its knd of odd how Judge Clfton (whose attached bo ndcates he has deep and longstandng tes to the domestcolence ndusty nfrastructure) knew nstantaneous to sgnng the Order for Competency Ealuaton of 2/27/12 at 131pm that the matter would be randomy assgned to strct Cout Judge Steen Ellot (also a lfelong prosecutor wthdeep and longstandng tes to the domestc olence ndustral complex, and a member o the Commttee to Ad Abusedomens (CAA, one of the named defendants n the wrongful termnaton lawsut Coughln brought and oer whchJudge Steen Elot presded n CV1101955, where he faled to pont out hs per se conflct of nterest to plantffCoughln at any tme, and where he ultmately pulled out just about eery wrnkle n the nsufcency of serce and orprocess and or sece o process (a moe showng a non paty oer 18 years of age seng a senor paralegal atashoe Legal Seces, whose Execute rector Paul Elcano went to Stanford wth Judge Ellot and the Panel Char ofCoughlns 11/14/12 Formal scplnay Hearng before the State Bar of Neada, John Echeerra n the late 1960s andJudge Ellot worked at John Echeerras fathers law frm, Echeerra and Osborne Board o rectors, n addton tobeng a former ass

In CV101955, Coughln sued hs former employer ashoe Legal Serces, whose Execute rector Paul Elcano wentto Stanford n the late 1960s wth Judge Steen Ellot and John Echeerra, the Panel Char of Coughlns 11/14/12 Formalplnary Hearng before the State Bar of Neada and Judge Ellot worked at John Echeerras fathers law frm,Echeerra and Osborne, and Judge Elot sered on the Board for CAA, and was a prosecutor as the Sparks CtyAttorney.

Also, Mr Lesle, whle the 56 page pdf you fnally sent me (gosh, was t that hard to clck attach, load a 2 mb pd leand ht "send" on an emal to me? No debatn, no argung about whether Lesle and ogan lef the package at the desk,whether ogan already gae t to Coughln, or whether ogan then changed hs story and sad Lesle gae t to Coughln,whether Coughln already pcked t up, no clams by Jessca the Receptonst of anyone kckn furnturenothng lkethat, just a dgtally erfable means of ascertanng what you transmtted and whenwas that so hard? Heck, Jm, youcould probably just emal those ECOMM recordngs tooand f attachment sze s an ssue, sgn up for awwwoutlookcom(the new HoMaL allowng up to 300 mb attachments a the Skyre functonalty, and up to 100mb attachments a plan emal, and oer 25 free gb o storage on the Skydre, etc., etc ) But ts Lesle fnally sent the6 page "clents fle" on o about 12/7/12, yet he faled to nclude the nspd Moton of 11/26/12 by A Young(wheren, just afer Judge Clfton fnshes tellng Coughln at the 11/27/12 Hearng that Coughln s not allowed to eenthnk about the other two RJC shotgunnn style splatter pant prosecutons by A Young, as "they are just not releant

to ths proceedng" and anytme Coughln would pont out specfc bass for undertakng a recusal or conflct analyss sa s ether Judge Clfton, the RJC, A Young, the CP, or the CA, Judge Clfon would say "yourre losngme yourre losng me" as f Coughln was speakng n tongues all the sudden

So, whle Coughln s reportedly not een allowed to emal A Young about cases not een before Judge Clfon, oromhng k ha. .DDA Yong a o g an nno, x a, mgny Moon o Pho

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http:///reader/full/www.outlook.comhttp:///reader/full/www.outlook.com


10/10

Sincerely

Zach Coughlin1471 E 9th StReno, NV 891

Tel and Fax 949 7 740

ZachCoughlin@hotmailcom

FromJleslie@washoecountyusTo zachcoughlin@hotmailcomCC Bogan@washoecountyusSubject 911 Caseate Fri, 7 ec 01 170908 +0000

Mr Coughlin

Attached are the discovery materials in the above-referenced case that you had requested and we had made anadditional coy of for you in resonse to your request Please note that the July 7, 01, cover letter was for your icku and you never icked it u Note also that the July 7, 01, acket encloses a coy of the Aril 17, 01, handdelivery transmittal of the very same documents which you received

Since we have been reoved fro the 911 case, we are closing our file he attached aterials were sitting at our frontdesk Sinc you failed to retrieve the, we rovide the attached courtesy coy before final closure of our file

No resonse to this transmittal is required from you

James B Leslie, Esq

Chief euty Public efender

Washoe County Public efendes Ofice

30 South Center Street

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12 13 12 0204 62337 26800 nndb member dda kandaras conspiring with wcpd leslie to abuse process with...

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