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Zach Coughlin, Esq.

(law license in Nevada temporarily suspended)

141 E. !th "t.
#eno, N$ %!&1'
)el and *a+, !4!.--.4.'
/cto0er '-th, '.1',
Cassandra 1ac2son
#3C 4dministrator
send via 6" 3ail, *a+ and Email
7ear 3s. 1ac2son,
8lease 9ind enclosed the attached "u0poena and or "u0poena 7uces )ecum and or Notice o9
7eposition and or Notice o9 #ecords 7eposition (please note a su0poena 9or records or su0poena duces
tecum is 0eing porivded to each deponent 9or productiono9 documents. 4 copy o9 each su0poena is
attached to this N/tice. :n the event the request records are produced to Zach Coughlin prior to the
date set out a0ove, the deposition will 0e vacated. )he depositions will 0e ta2en upon oral
e+amionation pursuatn to *#C8 #ule '-. )he depositions will continue 9rom day to day until
/n /cto0er ''nd, '.1' in #C#'.1';.-<<41 1udge "9erra==a rendered an /rder
allowing me to serve su0poenas and su0poena duces tecums without 9irst paying the
statutory 9ees. :t is unclear whether : will ultimately 0e responsi0le 9or them, 0ut the
1udge was clear that : could served them without ma2ing the payments (an :*8, :
8lease 9ind those su0poena and su0poena duces tecums attached. )he )rial is set to
resume Novem0er 1!th, '.1', so time is o9 the essence and : appreciate your o99ices
cooperation in this regard. 8lease note that o9 material relevance is what the #87 was
told 0y the dispatchers>emergency services personnel. 4dditionally, upon in9ormation
and 0elie9, not all o9 the !11 calls have 0een propounded, despite previous su0poena and
or requests 0y my 9ormer pu0lic de9ender, 3r. ?oodnight.
:n the videos : too2 o9 the arrest and the moments prior thereto, it appears that a )anner
Chan is ma2ing what : 0elieve to 0e a !11 call, and : 0elieve others did that night as
well, 4ugust '.th, '.11 0etween appro+imately 11,1% pm and midnight in relation to the
purported larceny o9 a cell phone at the s2ate pla=a in 9ront o9 City @all in downtowan
#eno, 1. N. Center "t., #eno N$.
4dditionally, none o9 the dispatch recordings have 0een propounded and : am requesting
that you do so now. : am requesting, 0ut not limiting my request to, all recordings and or
documentation related to what any o9 the o99icerAs involved in my arrest in #C#'.11;
.-<<41 communicated or had communicated to them concerning the arrest and events
leading thereto, and those events occurring a9terwards, on 4ugust '.th, '.11.
4lso, : would li2e all recordings and documentation related to my arrest on Novem0er
1<th, '.11 in relation to #3C case 11 C# '-4.&, a criminal trespass arrest involving
#87 /99icer Chris Carter 1r. and "argent 3arcia Bope=. *urther, : would li2e any and all
recordings or documentation related to me in any way whatsoever. : would pre9er that
they 0e transmitted to me digitally, via email, drop0o+, s2ydrive or some other digitally
veri9ia0le means as to the date and content o9 the transmission.
8lease 0e sure to include all materials related to my arrests in rcr'.1';.-&-'. (5anuary
14th, '.1'), rmc 1' C# ..-!- (1anuary 1'th, '.1' custodial arrest 9or petty larceny at
appro+imately <pm at 1'1 #iver #oc2 "t., #eno %!&.1), 1une '%th, '.1' arrest at 1-%.
"2y 3ountain 7rive 0y CC"/, 1uly <rd, '.1' arrest at appro+imately 11 am 0y #87 in
#3C 1' C# 1'4'., "eptem0er !th, '.11 arrest at appro+imately 1. pm in #3C 11 C#
''1-, tra99ic citation on Novem0er 1&th, '.11 0y "argent )arter et all near "t. Baurence
and *orrest in 11 )# '-%.. ( 11 )# '-%.., Case num0er CC 1';1%.& and re9erred to
under Control D C;4!&1).
4nd any other incidents involving Zachary Ear2er Coughlin (might 0e mispelled
Cuoghlin) do0 !>'>1!- (do0 might 0e listed incorrectly is some places). 8lease also
include any o9 this 0usiness with the City o9 #eno 3arshals.
Zach Coughlin
please 9ind ver9ication that this is my email address a0ove
Zach Coughlin