12 4 12 0204 63341 65630 67980 email to leslie formal written grievance against leslie

7/28/2019 12 4 12 0204 63341 65630 67980 Email to Leslie Formal Written Grievance Against Leslie

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formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911

calls missing from what was produced by City Attorney Skau

From: Zach Coughlin([email protected])

Sent: Tue 12/04/12 2:07 PM

To: [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] ([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]); [email protected] ([email protected]); [email protected]([email protected]); [email protected] ([email protected]); [email protected]([email protected]); [email protected] ([email protected])

12 attachments

CR11-2064-2676094 (Opposition to Motion to Dismiss CR11-2064-2676094.pdf).pdf (167.7 KB) , 11 7 12subpoenas 063341 gricela alvarez and hassett proof of service or waivers.pdf (10.4 MB) , CR11-2064MOTION FOR EXTENSION OF TIME (Mtn for Extension of Time).pdf (132.1 KB) , CR11-2064-2655401(Mtn to Dismiss ...).pdf (117.4 KB) , CR11-2064-2676094 (Exhibit 2).pdf (133.6 KB) , CR11-2064-2676094(Exhibit 3).pdf (48.0 KB) , 111912coughlin4.wmv (298.2 KB) , 111912coughlin6.wmv (3.6 MB) , 11 27 1211 29 12 and 12 3 12 emails to [email protected] and [email protected] in responseto Order to submit materials regarding Leslie's ineffective assistance 063341 0204.htm (245.1 KB) , 11 8 12Homer email and 11 9 12 Skau email 063341 0204.htm (121.3 KB) , 6 7 12 60838 Order temporarilysuspended Coughlin's law license scr 111 0204 12-17976.pdf (198.3 KB) , 12 1 30 notice that laura petersaffidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs attachment.pdf (327.9 KB)

Dear Office of Bar Counsel,

This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.

A portion of a recent email from City Attorney Skau reads:

"Fwd: FW: Case No. RCR2011-063341

From: Creighton C. Skau([email protected])

Sent: Fri 11/09/12 11:45 AM

To: [email protected]

Cc: Jeannie Homer ([email protected])1 attachment

photo[1].JPG (181.2 KB)

Dear Mr. Coughlin,

Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been

effected.

Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:

1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments.

However, they consisted mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to

obtain the documents, as set forth hereafter.

2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,

Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson


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Messanger Service again attempted to serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's

motion at the front of that address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these

items at that address.

3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.

Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been

effected.

Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:

1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments.

However, they consisted mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to

obtain the documents, as set forth hereafter.

2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,

Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno

Carson Messanger Service again attempted to serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the

City's motion at the front of that address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly, you can

obtain these items at that address.

3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."

But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau

fraudulently procurred Couglin's attendance at the 11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting

contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only Coughlin's formal disciplinary hearing but also the petty larceny trial of

11/19 and 11/20 and is a straight scum bag move by Creig Skau.

Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the

JAVS audio transwcript of the 10/22/12 Hearing in RCR2012-063341.

Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena in a criminal

misdemeanor case and he fails to inform the court of the waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez

(whom, somehow, Judge Sferrazza was apparently aware of and had opinions on....curiously).

Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341

(really, everything Jim Leslie did in this case or any other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is

dragging his feet, your honor...He's wasting county assets."...Really, Jim, this is a grievance against you for seeking to coerce a waiver of Coughlin's fifth

amendment rights incident to your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression Hearing or the Trial..and a

greivance against DDA Young for similarly coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the

first for 11/20 to get an idea of the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep

Coughlin's laptops over night...but there is some really bad audio on there with Judge Sferrazza and DDA Young getting completely coercive with respect to awaiver of Coughlin's Fifth Amendment rights and "you can't put on anything else or any evidence, YOU NEED TO TESTIFY!" and Young "you Honor, it was

my understanding that you let mr. Coughlin out of custody on the condition that he testify! If he won't do it TAKE HIM BACK INTO CUSTODY!"

add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive

any reports from dispatch of "a possible fight" where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and

therefore, such allegations of a report from dispatch of "a possible fight" did not bare on Duralde's probable cause/reasonable suspicion analysis. further young

put on perured testimony by Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when Young was provide a video wherein

Zarate admits he only inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant

Tibbals or anyone with the WCPD.

And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon

arriving...yet, every bit of video evidence and or testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to hearing "the man

with the six pack" threaten to throw the iPhone "in the river if someone doesn't claim it right now" was continually excluded as "hearsay"....

A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):

Dear Judge Sferrazza and DDA Young,

This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after thetrial directed to my issues with Mr. Leslie's representation (I am too tired to fully set those issues out at this point,but I will to some extent herein at least, and I am copying DDA Young on this just because it seems like the rightthing to do).


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Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement

more specific, particularized facts in support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney

whom dared to answer one of the officer's questions by asking a question seeking clarification as to Coughlin's constitutional rights....which clearly is not a

permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the Officer's did not receive the text from

dispatch reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year old

Austin Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 austin lichty templeton goble zarate

chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in length) lying in asserting

that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition to Goodnights

2/14/12 Motion to Suppress, both Goble, Lichty, and Zarate all have motivations apparent which preclude them

from being deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted to in his

testimony at trial to being aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and

double hearsay Duralde testified to at trial after "refreshing his recollection" upon a review of either his

"Supplemental Declaration" (an attachment to the probable cause sheet, DDA Young would allege) and or his

"Narrative". Which begs the question....how was it not misconduct by the State and prejudicial to the point of

declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on

But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to

(the password for the phone)...and when Goble alleges Duralde gave him back the phone...and the call into the

iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b

Perhaps the worst thing for the State and the RPD here is that two hostile witnesses (in addition to Coughlin'svarious statements related thereto, during his testimony and on the media admitted into evidence) testified that RPDOfficer Duralde committed misconduct by lying about the purported order or point in time in relation to the arrestand search of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralderemoved the phone from Coughlin's pocket and that Duralde had the phone with him when he first presented toGoble to ask question related to the phone and to verify ownership of the phone (which would include gathering thephone number for the iPhone, which necessarily would mean that Duralde's allegation of only searching Coughlinafter performing some call to the iPhone and hearsaying it vibrate (even though multiple witness (Templeton,Zarate, Goble, Lichty testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all)Goble testified that Duralde already had the iPhone prior to Goble conferring with Duralde or otherwise giving

Duralde any phone number to call in an attempt to verify the phone revealing an incoming call LED display screelight up alert (Goble's statements that the phone would "light up" and that he, as Duralde quotes him in theNarrative, "could not hear the phone

I have 30 days from the date of conviction to report a conviction to the State Bar of Nevada and the United StatesPatent and Trademark Office (USPTO) for these two convictions "possessing or receiving stolen property" and"petty larceny" under SCR 111(6) and 37 CFR 11.25(3).

I note that WCPD Jim Leslie, while still attorney of record for me on this cases RCR2011-063341, had served (seeattached) a subpoena on ECOMM and Kelley Odom on 10/03/12. Given that Mr. Leslie was not relieved as mycounsel until at the earliest 10/22/12 (so Judge Sferrazza's contention that Coughlin "has had forever to get hisdefense ready in this case" and that "no continuance will be granted on account of the formal disciplinary hearingbefore the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge Sferrazza indicated some canon preventing him from testifying at the formal disciplinaryproceeding...that didn't stop 063341 being specifically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v.Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary LoriTownsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 andoffering to send into the SBN Coughlin's 2/15/12 filing in 063341). Add to that the fact that Coughlin neverreceived from Leslie Goble's call records until Leslie finally released them o October 30th, 2012...and it really isnot accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in hisformal disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie,


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not 30 days notice of the hearing on 11/14/12 after service of the Complaint and Designation of Witnesses andSummary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point is, if the RJC and both ofyou want to be associate with a Schaeffer style Mirch-ing, then this may be your chance. But you won't be able tosay you didn't have plenty of opportunities to put this thing aside, because there are a multitude.

It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr.

Leslie's failure to turn over anything to me in the "hand off transmittal" he insisted upon (despite a digitaltransmission being required per the Order of Judge Sferrazza, I believe) requires some explanation.

So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faithattempt to comply with Judge Sferrazza ordering him to comply with the subpoena duces tecum and or turn overany relevant dispatch recordings pertinent to the arrest and events surround it of 8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin Lichty's cellular phone, 775 233 8593,which Goble is seen in the attached still frame picture culled from a video Coughlin took of the moments prior tothe arrival of the RPD, being handed by the "man with the gauged ears" Lichty referred to as "Peanut" despite Lichty,Goble, Zarate, and Templeton testifying that they do not know that man and did not know him prior to that night atall....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify ofthe "man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of theirhaving attacked him and attempting to steal his bike and or dog, reach into his pockets, and push him up againstoncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in the attached still frame, it is quiteclear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two911 calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) takingplace beginning at 11:22:52 pm (though the ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknownwhether the exact time a 911 call comes in is designated on the "Calls for Service Inquiry Response" Coughlin wasprovided recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number (belonging toAustin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law licenseaway from me for at least 5 years, if not forever....and DDA Young...over some alleged "skater sets his iPhone downon the concrete in the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in Reno, "man with a six

pack of beer" picks it up, offers it up, receiving no response threatens to "throw it in the river if someone doesn'tclaim it immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's Narrative ofunknown origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing fromGoble in his Narrative)

contain the 911 call by Coughlin

So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll beout on him" one can hear Officer Duralde indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in

the video Coughlin filmed of the arrest, title:

Then, Officer Rosa is proven to be on the bridge and not i n his squa d car reading texts from dispa tch n the foll owing time s tamped fil e: "PRIMARY RADIO TRAFFIC Start_Time =

Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end"

Further, Officer Duralde's arrival on the scene is notated in the dispatch log at the


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Its not at al l clea r why Goodnight onl y apparently received then forwarded to his clien t on November 30th, 2011 the "Original Supple mental" containi ng Officer Dural de's

Narrative, that is still of indeterminate date of origin (there are a number of "date of printing" variations...).

That I know of, there were three 911 calls(two by Goble, one by Coughlin, i n that order):

1. 082011 112252pm to 112530pm 911 by Goble dis patch Weese l og larc of phone sus ps os left on pos t lighting up i n sups pock RP screaming a t susp

2. 082011 112620pm to 112740pm 911 by Goble dis patch Montgomery logs rp cal l b ack re s omeone jus t socked a minor, waive that cop do wn 10 10 with ope n l ine

3. 082011 112645pm to 112752pm 911by Coughlin Dis patch Weese l ogs call from phone with open li ne yelli ng re steali ng phone peopl e cheering cops are here then call

disconnects

And Coughlin filmed three videosthat night of the arrest that are relevant, two just prior to the RPD arriving (a nd actuall y, whil e Rosa and Dural de were al ready on the scene a nd

out of their vehicles after teh 11:26:00 pm mark as i ndicated by the Ecomm recordings a nd di spa tch logs...

1. VID_20110820_232413 your all on tape now gobl e and friends .3gp 8 seconds l ong

2. VID_20110820_232423 austin l ichty temple ton goble zarate chan rpd i phone a ss aul ting and battery Coughlin jus rt prior to RPD rcr.3gp 46 seconds

3. VID_20110820_232801 offi cer dural de an d rosa 8 20 11 arres t.3gp 5 minutes 52 se conds l ong

And the AT&T call records for the i Phone reveal onl y four cal ls occurred in or out during the relevant time frame:

Goble's AT&T records:

44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440

45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440

46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440

47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726

Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..." Previous to that,DDA Young had successfully kept every single witness from specifically identifying who made what call and when andwhere to any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps hisfingers "Oh, that's Colton" 8 feet from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seekadmission of the misconduct of a prosecution witness....Goble, batterying Coughlin with a lit cigarette, that Coughlincapture on tape, on June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on6/7/12...and had his law license suspended in 60838 four hours later by a 3 Justice Panel (including Justice Hardesty,whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not likeme for that suit, but if you look at the circumstances of my firing therein (I was hurrying to finish a non-profit gets stuckwith the building's private landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a Trial before JudgeLinda Gardner in a divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty of research


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beforehand...I just had some issues printing it out and bringing it with me (my legal assistant couldn't figure that out...WLStook 6 weeks to cut a check for subpoena fees....the usual)...

Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence exclusively hearsay testimony (often unattributed to anyone in particular) to

support his win on the "sufficient probable cause to support a search incident to arrest" despite NRS 171.136 forbidding such an arrest (where Duralde obviously overcharged

the alleged crime as a "felony grand larceny"...even making smug commentary about the "certain benefits of charging this as a felony" and saying "oooh, that's a felony", both

matters that Lesl ie i nsi sted refraini ng from getting i nto while he was attorney of record, and further, despite Coughli n complying with NRS 174.345 (even spl urging on the return

receipt requested to go along with the certified mail for Duralde) Coughlin was denied the right to cross examine the arresting officer...which is too bad considering his

Narrative alternately claims that Goble told him they

DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing

stolen property charge.

COUNT II. POSSESSION OF STOLEN PROPERTY, a viol ation of NRS 205.275, a misd emeanor, i n the manner fol lowi ng, to wit:

That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully possess or

withhold stole n goods having a value l ess than Two Hundred Fi fty Doll ars ($250.00), to wit: an iPhone, at or nea r 1 North Center Street, Reno, Was hoe County, Nevada, such

property being o wned by CORY GOBLE, for his o wn gain o r to prevent the true owner from agai n pos ses si ng sa id property, knowing that the property was obtaine d by means of

larceny or under such circumstances as should have caused a reasonable man to know that such goods were s o obtained.

POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that the property was stolen by another. "

It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574. Must allege the good

were received from someone other than the defendant: Gaddis, 424 U.S. 544, Allen , 96 NE 2d 446, Polk, 749 SW

2d 813.

Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a),

(b), and (d) cannot also be convicted of receiving or possessing the robbery proceeds in violation of 2113(c). Heflin,

supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."

"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than

plaintiff in error, a...The next assignment of error is that the State failed to prove beyond all reasonable doubt that the

automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving

stolen property the proof must show (1) that the property has, in fact, been stolen by a person other than the one

charged with receiving it; (2) that the one charged with receiving it has actually received the property stolen or aided in

concealing it; (3) that the receiver knew the property was stolen at the time he received it and (4) that he received the

property for his own gain or to prevent the owner from possessing it. (People v. Piszczek,404 Ill. 465.) Proof of these

essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v.

Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96 N.E.2d 446.

PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that if a criminal conviction

is to be upheld,

[ 21 Ill. App.3d 980 ]

the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327

(1946)), and must contain the nature and elements of the offense in order that the defendant may fully prepare a defense


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and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-

433 (1967).) In the instant case, the indictment, drawn upon the conclusional premise that the property was stolen, fails to

allege that it was stolen by a person other than the one charged with receiving such property and, by this omission, creates

the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of

stolen property nor receive stolen property from himself, the fact that the property received was stolen by another was an

essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill.

446, 448-449 (1929); People v. Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949);People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the offense of

receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is

void. People v. Edge,406 Ill. 490 (1950).

The judgment is, therefore, reversed....

I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the

defendant. The omission of the words "stolen by another" in the indictment does not create the presumption that defendant

had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property *

* * under such circumstances that would reasonably induce him to believe that the property was stolen * * *" (emphasis

added) in the indictment clearly implies that when defendant obtained control of the property in question (in any manner

whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.

I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with

what may be implied from the clear phrasing of the indictment. At trial it is not

[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that

the defendant was in possession of that property in order to prove the offense of theft under 16-1(d) (the former offense of

receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplainedpossession of stolen property soon after a theft is evidence that the defendant stole the property himself but is not

evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1

Ill.App.3d 860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits

a reader of the indictment to find, even after only a cursory reading, the necessary elements of the offense, i.e., that the

property was already stolen by another when the defendant received it.

While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the

addition of these words would only be grammatically redundant and mere surplusage legally.

The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).

After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the

defendant guilty beyond a reasonable doubt. For this reason I, too, would reverse the defendant's conviction."

Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in

"larceny" and "theft" cases. He erroneously urges that the state failed to meet that standard under our holding in Cleveland

v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair

market value of the property at the time and place it was stolen if there be such a standard market." 85 Nev. at 637, 461


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P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).

SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the

commission of the burglary charged in Count 2. Since a thief cannot receive from himself the fruits of his larceny, the

jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People

v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553

(1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States,

418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but

the court declined to give it. This was error, and later acknowledged by the court to be such when it set aside the

receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner of handling the

error effectively cured it. The error was not cured by the setting aside of the receiving conviction since there is no way of

knowing whether a properly instructed jury would have found the defendant guilty of burglary, Count 2, or receiving,

Count 3. Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"

State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element

of the crime of receiving stolen goods..17. Criminal Law. In prosecution for receiving stolen goods, where

instruction given by court followed language of statute with reference to accused's intention to prevent the [61

Nev. 330, Page 336] owner from again possessing property, defendant was not entitled to instruction which told

jury that goods must have been received with fraudulent intent of depriving owner of theimmediate possession

thereof. Comp. Laws, sec. 10335."

BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a

preliminary examination, Henny Bernier was ordered to stand trial for possession of stolen property, a violation of NRS

205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was

insufficient to establish probable cause that she had committed the charged offense. The district court considered and

denied her petition and Bernier here reasserts the same contention.

Bernier does not deny having possessed the property; rather, she argues the proof did not show that she knew the property

was stolen and that such knowledge cannot be inferred from mere possession.

We agree that mere possession is insufficient to establish the requisite knowledge..."

"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a

conviction for possessing stolen property on the ground that the legislature did not intend to compound the punishment for

larceny or robbery by permitting a conviction for receipt or possession of the stolen property against the person who took

the property. Point v. State, 102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d

1358 (1994).

State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that for a charge


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of possession of stolen property to stand, there must be a showing of all the elements, and

that if even one e lement is missing, the charge cannot be maintained. State v. Pray, 30 Nev.

206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State , 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the

burden of proof of all three elements rests with the

attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.

Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.

Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though,

given the incarceration was served, it is a finally appealable order, see Gilman 275 V. Comm 474, 657 SE 2d 474.

Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss.

Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem 929 P.2d 634 Smith 85 P. 524 In re

Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re

Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596

SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala

Whether Goble had "ownership" in iphone matter 920 P.2d 112

Sheely 102 p.2d 96

Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).

26405 and 03628 trespass case:

unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,

Woods 19 NYS 2d 683

Regan 425 NYS 2d 725

Iorio, 410 NYS 2d 195

Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good

Leese v Horne, 47 P.2d 316

Burhams , 89 P.3d 629

Between the following two timestamped recordings finally provided by City Attorney Skau (WCPD Jim Leslie is too busy whistling during trail at Coughlin's

pointing out how he cautioned the youths prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just

blocks away approximately two months prior to the 8/20/11 arrest, incident to the theft of a purse, and Lelise prefers to spend his time chiming in, unprompted,

on the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet" incident to the inappropriat placement by Judge Sferrazza of

Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of

avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if

Coughlin, as he, in fact did, deposit a "rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer

action...until rich man's opposing counsel Casey Baker, Esq. coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your

Honor..." whereupon Judge Sferrazza . You are to his constituency by remixing is previous order regardless of the extent to which Coughlin was not noticed


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thereto with respect to that which would be involved on the October 25, 2011 trial they are and where only those aspects of a summary proceeding that in year

to the landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to

bring counterclaims were matters Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters

continued on with respect to the manner in which service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in

the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings Coughlin submitted online November

15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of

that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3

SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3

In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe

County public defender applying good nicely peers deciding that the night was doing too much to assist Coughlin in defending himself and or otherwise zealously

advocating on call Pat good night in Coughlin had a trial prep strategy session while Coughlin was in custody on July Friday, July 13 at approximately 430 man and

you good night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial on July 16, 2012 Monday morning at 9 AM and itwas only upon Coughlin arriving and being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication

Goodnight's December 19, 2011 file stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR

DISCOVERY COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public

Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or photograph any

written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of the State, the

existence of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This reques t includes any video and

audio recordings,including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded, generated in

connection with this case ." It is telling the extent to which on the record at that July 16 trial date Washoe County public defender Jeremy Bosler indicated that

Jim Leslie would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And that Leslie would be prepared to try the case by

Friday and that the court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have

completed all the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the case whether or not that evinced any sort of concern

for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim Leslie felt that the judges of the Reno Justice Court would

hold him to a standard of care a t all tending to indicate that Mr. Leslie has any skin in this game whatsoever.

Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and

malpractice and apparently willing disregard for the rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe

County District Attorney's Office and therein secure added boys from local law enforcement District Attorney's Office and perhaps the Reno justice court itself.

Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders office in connection with February

27, 2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted whether they they have been

sworn prior thereto or not an especially where Dogan's coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the confiscation

without a search warrant or court order of any kind (or at least one ever served on Coughlin in any manner) of Coughlin smart phone and micro SD card incident

Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on February 27,

2012 in RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict between that traffic

citation trial in the Reno Muni court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one

of the top 30 highest-paid city of Reno employees of and admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing

Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal trespass

conviction has now become the subject of a Nevada Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia

Lopez of the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that judge Sferrazza

presided over wherein judge Sferrazza purportedly controlled the civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December

26 submitted for filing December 26, 2011 was not file stamped by the civil division staff of the Reno justice court. This impropriety is further problematic where

Coughlin had served upon the Reno justice court's custodian of records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012

letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar of Nevada, which

ultimately became one of the three grievances depicted numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State

Bar stamped August 23, 2012 (in addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial in 11 TR 26800 held in

violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held

with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal

complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011,


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resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that

neither she nor Hill meritless or her partner officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial arrest on that day in where

Lopez also admits none of those individuals or anyone present that day identified themselves as law enforcement prior to landlord meritless kicking down the door to

a crawlspace about 5 feet high underneath the former home law office wherein Coughlin was found at a time when Coughlin still had not receive back from the

Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's admission that the

Reno justice court judges held a meeting wherein they admitted that Coughlin was correct and his assertion that the Reno justice court had no then corollary to Las

Vegas justice court rule 44 that may support the secret quote house rules been fact in the civil division of the Reno justice court wherein tenants were in summary

eviction matters were subject to forced rent escrow deposit in violation of justice court rules civil procedure 83 and that the Reno justice court had neither published

nor had approved by the Nevada Supreme Court any sort of corollary to justice court rule Las Vegas rule 44 (JCRLV 44). Further that criminal trespass conviction

and the wrongful arrest connected thereto occurred even where the Washoe County Sheriff's office deputy Machen filed a false affidavit on November 7, 2011

alleging to have personally served Coughlin with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of Law, and

Order of Summary Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner

refused to recuse himself despite the fact that his sister judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the "Clerk

of Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order sanctioning Coughlin incident to a divorce matter where and he was

representing a victim of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former prosecutor judge Linda Gardner in

comparison to the extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy district attorney Young's

repeated malfeasance misconduct violations stays pending competency or evaluations failure to turn over exculpatory materials failure to propound discovery failure

to respond reasonable discovery requests demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions of Coughlin this

year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint from

a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year

after the January 14, 2012 arrest in the matter to a charge that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort to

achieve a plea-bargain and resolve what is a messy case the city of Reno Police Department and emergency dispatch services and again the Reno justice court

incident to the eviction and RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand located at

1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in

the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's

fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to

RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of summary eviction matter in 1708 Barber which judge Sferrazza presided and

which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee award against Pro per appellant

Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by

Casey D Baker of Hill's office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay

required by NRS 178.405 and getting judge Elliot (whom "randomly" was assigned to Coughlin appeal of the petty larceny conviction of a candy bar and some

cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license incident to bar counsel's SCR 111(6)

Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a

misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should

especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at

which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard

just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that Walmart alleges to have

had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and where French

you admit that his supervisors had previously indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning some of Walmartspolicies and where John Ellis of the W. 7th St., Walmart in any as yet unknown loss prevention associate specifically and expressly threatening abuse of process

against Coughlin on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and customer service managers many of

whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from the policy

which Walmart holds out to the public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy

as stated at Walmart.com no matter what the convenient for getting in misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's

Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 affected a citizen"s arrest of Coughlin on that date in connection with the alleged

petty larceny by Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days after Coughlin filed a written

complaint detailing the police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on

August 20, 2011 in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint

throughout American jurisprudence that one cannot be charged with both petty larceny and receiving stolen property of the same item particularly where the

receiving of the item is alleged to have been from oneself after one had larceny is the item lending an inference that Joe Sferrazza seeking to sink his jurisdictional

hucksters deeply into Coughlin's light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in connection with its

numerous since is violating about law respecting the manner in which evictions are carried out and or the misconduct of local law enforcement and prosecutors in

carrying out retaliatory arrest and prosecution of Coughlin where the judiciary in Washoe County is off criticizes being overly influenced by the District Attorney'sOffice. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of

law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the Wal-Mart case, as judge Kenneth Howard denied

Coughlin a court appointed defender there despite his express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority

exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in

connection with that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing the

November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion of the hearing which are trial which judge Howard down such a matter

of public concern that he Five city of Reno employees at the courthouse until nine o'clock at night to get it done that in fact judge Howard admitted he was wrong

with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault that all and where the Reno Municipal Court had previously granted a

continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's criminal trespass

complaint (connected to the summary eviction matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the

product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that

same six-week vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge Sferrazza to denying Coughlin a hearing on his

motion to contest personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest personal property lien on


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November 17, 2011 even where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set

the hearing on November 17 as Janice admitted when judge Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally set (as

Richard Hill's e-mail wherein he threatened Coughlin that he would be able to control the justice court in his desired to prevent such a hearing been set until he

returned from his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge Sferrazza

ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed

to allow the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was

able to apparently without Coughlin's permission serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same

eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for something unrelated to bailiff Plamondon's desire to affect

service of some notice of the hearing upon Coughlin.

Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate

McGeorge school law along with wash County Dist. Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whomrecently granted 2004 graduate McGeorge school of law deputy district attorney Zach young in order taking away the ability to file by fax from Coughlin a privilege

that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 hearing at which

Coughlin's then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the

motion young alleged who filed on November 26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any

sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge Clifton's request that he provide judge Clifton something supportive of

Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote representation of

Coughlin" in 065630).

(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both

of the State Bar of Nevada communicated he and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court JudgeBeesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org) (former law practice partners with an individual from

Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed Coughlin's work before him and in

Nevada Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to

the hearing and in violation of Supreme Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of

judge Beesley in any matters relative to the ultimate Supreme Court rule 105 complaint against Coughlin for over six months at least and so in no way can be said to

just stuff I his last-minute supplementing judge Beesley and milquetoast attempts to provide Coughlin S supplemental designation of witness and summary of

evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY at the hearing (both of

those gentlemen attended McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions

disapproving of Coughlin's competency as an attorney at the hearing despite the fact that neither of them could provide anything in the way of specificity with

regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's department

in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal

disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some

$755,000 from his clients and using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge Beesley sees competency in Mr.

Harris and could overlook the $755,000 for my client where it be $14 worth of candy bars and cough drops from Coughlin and Coughlin's March 30, 2012 filing inCadle Co. v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at 2:30 pm in representing Mr. Keller that was

affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire

Brown judge Schroeder of the Reno justice court wherein the audio record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to

hurriedly move the case summary eviction case against Coughlin through despite Judge Schroeder admittedly having had a different order of hearing the cases

planned for that morning docket and despite the fact that the fax header on the summary eviction order that was hurriedly moved through indicates a time stamping

of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into

Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they entered with their guns

and/or pagers drawn in and immediately placed Coughlin in handcuffs and told him he was detained in contrast to the typical procedures carried out by the Sheriff's

office incident to evictions in Washoe County. Incident to that summary eviction (where the docket, at least, more review is necessary, indicates that Kern and

Western Nevada Management's Sue King switched up their basis for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly

changed the basis for seeking an eviction to one for non-payment of rent (seemingly in response to Coughlin Pre Hearing Brief pointing out the difficulties they

would face under Glazer in pursuing a No Cause, particularly against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the

Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to Coughlin). in the third grievance against

Coughlin forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.

Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw

Coughlin under the bus at Coughlin's 11/14/12 formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and

Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy bar conviction that resulted in the current now 5 month long suspension of

Coughlin's license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:

Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104

Entered: 3/30/2012 Brief


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Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of

SAMANTHA L. HALL, ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit

Affidavit of Counsel Coughlin for Keller in Support of Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court

Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26

12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7

12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)

In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in11 TR 26800 whereby she Order Coughlin's property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing"

the Washoe County Jail to release to Coughlin the property that it alternately admitted to having released to the City of Reno Marshals on 2/28/12, denied having the

micro sd card, denied the micro sd ever being booked into property, alleged to have given Judge Sferrazza's former tribal court Bailiff and former Coughlin client

Peter Eastman on 2/29/12 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys so Eastman could arrange for Coughlin's dog Jackson

Pawluck to be fed and cared for during Coughlin's summary 5 day incarceration).

Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and

micro sd card confiscating without a warrant/5 day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about

the Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's law office, where RPD Sargent John Tarter told Coughlin to leave after Coughlin

presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department officers and managing caught to get

Coughlin subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and

Coughlin reporting to Sargent John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in

response to Coughlin querying him as he too was on Richard Hill's payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot

of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia Lopez refused to undertake any

diligent inquiry response to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121 River rock

property for the month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises.

The lackluster failure to query Hill with any diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed

defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10, 2012 trial date in that criminal trespass matter wherein Reno

Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed a grievance

with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed

Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to

Judge Nash Holmes confiscating Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of a

search incident to arrest given Coughlin property had been booked into his personal property at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes

summarily sentencing Coughlin to 5 days in jail for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS 22.100, but

characterizing her Order as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt

statute, which is not summary in nature, and therefore requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her Marshal

Joel Harley (and its not clear Harley even said what Holme's alleged he did in rendering her "second bit at the apple" of 3/12/12 in comparision to her 2/28/12 Order

Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030 (which is civil in nature) for conduct not

committed in the immediate presence of the Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and

hiding some component part thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary

hearing, and which she included in the Order she rendered in that traffic citation case stemming from Coughlin being told to leave Hill's law office upon appearing

their demanding his keys, wallets, driver's license, and client's files shortly after being released from a 3 day custodial arrest stay in jail incident to Hill's criminal

trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter presided over by Judge Sferrazza). Like the

Order Judge Linda Gardner c laimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis FV11-03383 (see attached inExhibit 1), Judge Sferrazza attempted to characterize the Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th,

2011 filed stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to Contest Personal Property Lien" despite Coughlin clearly

indicating, on the record at that hearing that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza may

enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice

court bailiffs radius in chief bailiff Sexton as to the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents where

Reno justice court bailiffs had either as bailiff arrested told Coughlin that he would put his foot of Coughlin's ass or made commentary as chief Sexton did to

Coughlin respecting Sexton's indication of Coughlin on two different occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or

not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).

and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:


15/43

"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. Dr. Merliss owns the property at 121 River Rock Street, Reno, Nevada. Beginning in

March 2010, the property was leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately

May 2011. Dr. Merliss contacted us in approximately August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He

contended that there were habitability issues with the property that justified his withholding rent. All of his clahns were decided adversely to his position at the

eviction hearing. Justice of the Peace Peter Sferazza ordered Coughlin evicted from the premises effective November 1, 2011. On that date, the Washoe

County Sheriffs Department performed their normal eviction procedure: locks were changed and the eviction notice was posted on the front door.

We videotaped the home and its contents at that time . Upon inspection over the next few days, it became apparent that "somebody" was breaking into the

home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at the home on River Rock Street. As we walked through the

home, it was obvious that"

One, it is not true for Hill to write "The lease expired in February 2011." The Standard Rental Agreement utilized by the parties provided that the Lease renewed

upon its terms automatically in accordance with the NRS 118A holdover tenant provision. Further, it is not accurate for Hill to write "Coughlin had not paid rent or

utilities since May." One, the landlord assented to an arrangement with Coughlin's former co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make

installment payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011 and June 2011 and only

sent the landlord Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in

combination with Dr. Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty

larceny charges Coughlin faced shortly after Ms. Ulloa's secretly absconding with Coughlin's rental contributions (which Coughlin was only made aware, and

the concomitant rent due, upon an August 11th, 2011 email f rom the landlord Merliss) . Merliss admitted to assenting to the repayment plan wi th Ms. Ulloa

on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in violation of

NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an agreement with Coughlin for a rent deduction of $350 going forward in

exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artificial turf installation Coughlin had installed in

an enterprising approach which the l andlord's landscaper for the other property Merliss owned ne xt door and his quasi real estate broker property manager

Darlene Sharpe quickly grew unhappy wi th, given it was cutting in to the "$2,000" that Dr. Merliss e ventually claimed, under oath, at the 10/25/12 eviction"Trial" that he wound up paying Green Action Lawn Service to "deal with the weeds" at Coughlin's former home law office. "Dealing with the weeds", to

Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law office substantial losses lost

profits time away from work and expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not only

tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to landlord Merliss, who apparently did

not realize or remembe r that he had also assented to a $350 rent deduction with Coughl in on or about May 24th 2011 in exchange for Coughlin quote

dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior

to their tearing it up and leaving industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.

Hill's grievance of 1/14/12 to the SBN goes on to allege:

"Someone had been in there since I had last been in several days before. Dr. Merliss discovered that the basement door was barricaded (not locked) from the

inside. The Reno Police Department was summoned. They tried to coax whoever was in the basement out, without success. After Dr. Merliss had to kick the

door down, it "was discovered that Mr. Coughlin had broken in and was in the basement. He was arrested and is presently facing criminal trespass charges inReno Municipal Court. See case no. 11 CR 26405 21. He is also facing a contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed

that matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012, but was continued at the request of Mr. Coughlin's new

attorney.

5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process,

a lien was asserted against the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the

landlord's lien in the Reno Justice Court. The court tried to promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it

off calendar. Coughlin then reinitiated that process and a hearing was held in December, at which time the court heard evidence of Coughlin's lack of

cooperation in setting the November hearing. You may also want to contact Reno Justice Court staff, and in particular, chief clerk Karen Stancil ,

about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time window to remove

his personal property. The first day was Thursday, December 22, 20 11. After Coughlin was allowed into the home that first day, he sent out an e-mail to the

effect that because he had appealed Judge Sferazza's order, he was entitled to a stay of proceedings and was to resume in the home. As a result, he did very

little to remove any of his personal property that day. On Friday, December 23, 2011, after he learned, again, that his stay had been denied, Coughlin

assembled a small crew and they were able to remove a substantial amount of his personal property. (You need to understand that Mr. Coughlin is a hoarder.We have the photos and videos if you would like to see them.) However, Mr. Coughlin did not get all of his property out. For example, I counted 13 car seats

that he had somehow managed to get down into the basement.

Having failed to remove all of his belongings, Mr. Coughlin then moved before Judge Flanagan for a temporary restraining order to prevent the disposal of his

abandoned property in accordance with Judge Sferazza's order. Attached is Mr. Coughlin's motion, my office's opposition, and Mr. Coughlin's reply.

These documents demonstrate Mr. Coughlin's complete and utter incompetence as an attorney.

On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request for a temporary restraining order. On January 12, 2011, the contractor hired to clean the

house commenced work. Mr. Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned

property from the house. Coughlin called the police, who arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1


16/43

over. He also told the police "

The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:

PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and

center.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt

nexus.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty

three.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the

Center St. Bridge.wav

PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for

a male.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a

level b clear that in about 5 minutes.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station

break 151 unintelligible.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet

still one file.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav

PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4

break union 9 to reno.wav

SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav

SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav

SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female

dispatcher saying go ahead with that.wav

Zach Coughlin

1471 E. 9th St.

Reno, NV 89512

Tel and Fax: 949 667 7402

[email protected]

--Forwarded Message Attachment--

ClosePrint
mailto:[email protected]


17/43

in compliance with Judge Sferrazza Order of 9/5/12 FW: Zach Coughlin has shared a folder

with you

From:Zach Coughlin([email protected])

Sent: Tue 11/27/12 8:26 AM

To: [email protected] ([email protected]); [email protected] ([email protected])

re:rcr2011-063341

Dear Judge Sferrazza and DDA Young,

I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective

assistance of counsel claim and or the coerced waiver of my Fifth Amendment rights, especially incident to the representation by WCPD Jim

Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent faxing of numerous filings to the wrong fax

number by myself .

https://skydrive.live.com/redir?resid=43084638F32F5F28!5141&authkey=!APibWiVXTMSWkw0

Sincerely,

Zach Coughlin

1471 E. 9th St.

Reno, NV 89512Tel and Fax: 949 667 7402

[email protected]

in compliance with

Judge SferrazzaOrder of 9/5/12

View photos Download all

You are invited to view Zach's album. This album has 43 files.

11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf

4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215127&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215127&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215126&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215126&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215163&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215162&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215161&parid=43084638F32F5F28%215124&authkey=%21AOcn85-l7wSlqbA&Bpub=SDX.SkyDrive&Bsrc=SkyMailhttps://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&page=self&resid=43084638F32F5F28%215160&pari

12 4 12 0204 63341 65630 67980 email to leslie formal written grievance against leslie

Documents