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RE: response to grievance from NV Attorney

From: Patrick King (PatrickK@nvbar.org)
Sent: Mon 3/12/12 9:15 AM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Cc: David Clark (DavidC@nvbar.org); Glenn Machado (GlennM@nvbar.org)
March 12, 2012

To: Zach Coughlin

Dear Mr. Coughlin,

I am in receipt of your e-mail below, requesting additional time to respond. Please be advised that your response to the
grievance, including the e-mail letter below, become part of the record and may eventually be reviewed by a disciplinary
panel. With that said, it is important that we receive your response. Pursuant to your request, you are granted until
Friday, March 16, 2012 by 3:00pm to deliver your written response to the State Bar Office in Reno.

Thank you for your cooperation.

Patrick King, Assistant Bar Counsel

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Friday, March 09, 2012 5:45 PM
To: Patrick King; Glenn Machado; David Clark
Subject: response to grievance from NV Attorney

Zach Coughlin, Esq.
Nevada Bar No: 9473
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
775 328 6045 fax: 949 667 7402
ZachCoughlin@hotmail.com

State Bar of Nevada
P.O. Box 50
Las Vegas, NV 89125-0050
600 E. Charleston Blvd.
Las Vegas, NV 89104

sent by fax and email only to:
Reno Office: 775 329 0522
Las Vegas Office: 702 385 2878
DavidC@nvbar.com, PatrickK@nvbar.com, GlennM@nvbar.com

March 9, 2012,

Dear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
I only just now received the letter, dated February 14th, 2012 that Assistant Bar Counsel King sent me, wherein the
grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please respond in writing to this grievance within ten
(10) days from the date of this letter."
I am requesting an extension of time to respond to this matter. I literally just received this mailing from you within the
last hour, and was unaware of this prior to that. Further, I hope I can demonstrate to you and the State Bar of Nevada
that circumstances at least somewhat beyond my control have prevented me from receiving my mail in an orderly and
consistent fashion. These circumstances resulted in two different Domestic Violence Protection Orders being granted to
Contact
me against my former housemates by Master Edmondson of the Second Judicial District Court in FV12-00188 and FV12-
00187. Further, the electricity to my location was interrupted from one week (though I attempted to get NV Energy to
accept payment from me for services) from February 3rd to February 20th, 2012, incident to one of the individuals
against whom a protection order was issued attempting to prevent me from obtaining electrical service. Additionally, the
same individuals against whom these protection orders were issued interfered with my access to my mail from the USPS,
and it has taken some time to get the USPS Postal Inspectors to release my mail to me and or allow me to receive mail at
my location.
Please note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn Machado a written request
that the State Bar of Nevada please help me in remaining aware of any correspondence being sent me from the State Bar
while I work to get my mailbox situation settled (please see below):
On February 22nd, 2012 I wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that "I had to move recently and
moved in with two individuals who I ultimately wound up getting Protection Orders against, and they have interfered
with my ability to receive my mail with absolute certainty (I have received much of my mail, and have pending
correspondences/requests with the Postmaster for Reno, NV to obtain a permanent and newly rekeyed lock and key to
access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister that if I fax him proof of my
location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call him again
tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an
electronic filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any
correspondences/notices etc. that you or the State Bar of Nevada may have for me or may have mailed to me be, if
possible, copied to me via my fax number or email address."

I feel strongly that Mr. Hill's allegations are ones I will wish to contest vigorously, and I hope I am afforded an opportunity
to do so. There is a lot more to this situation than Mr. Hill indicates.
Sincerely,
Zach Coughlin
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473
RE: Contact
From: Patrick King (PatrickK@nvbar.org) This message is in your inbox because you've indicated
interest in this sender.
Sent: Fri 3/16/12 9:09 AM

March 16, 2012

Zachary Coughlin

Dear Zach,

Thank you for sending me your reply to the grievance filed by Richard Hill. From your
explanation it is clear that things are not as they should be. Please call me ASAP so that we can
take the appropriate action to help you and to stop these types of disturbing complaints.

Patrick King, Assistant Bar Counsel (775) 328-1384

Sent: Fri 3/16/12 2:42 PM
Dear Zach,

Thank you for your e-mail. I really need for you to call me. Please call me so we can setup a time to meet.

Thank you.

Patrick King, Assistant Bar Counsel 775-328-1384

To: Patrick King; clarkd@nvbar.org; Glenn Machado
Subject: RE: Contact

Mr. King,

I have not sent you my Reply to the Grievance. You gave me until today, and I am finishing it up.
Additionally, I was subject to what I believe is a wrongful eviction yesterday, and would like
additionaly time to respond to Richard HIll's grievance, which he appears to be filing on behalf of
various third parties, and his associate, who doesn't bother to sign it. Basically, Mr. HIll constantly
seeks to leverage courts, police, and now, Bar Counsel, to further his nefarious approach to
litigation, rather than roll up his sleeves and find some law in favor of his positions and apply actual
facts to them, rather than make up things or quote to third parties and other hearsay (I never made
contact with or touched Mr. Hill, I never climbed on anyone's truck, Mr. Hill is not a licensed mental
health professional, yet he sounds like a walking DSM-IV when he writes of me). I will submit
something to you today in response to Hill's grievance, with the caveat that I am requesting more
time, in part due to the fact that the Washoe County Sheriff's Deputies have just yesterday, minutes
before my hearing in Judge Beesley's courtroom, unlawfully stormed into my location at 1422 E. 9th
St, #2, with guns drawn and pointed at me, without previously identifying themselves as law
enforcement in any way, and demanding I grab a few things in a couple minutes and leave. This
unlawful eviction was pursuant to an eviction hearing held that morning by Reno Justice Court Judge
Jack Shroeder, the same Judge who screamed at me "do you want to go to jail" when I attempted to
address in any way whatsoever Richard Hill's abuse of process in getting a Order of Protection from
Judge Schroeder in a scant 40 minutes, and having me arrested on 1/12/12 (two days before Hill's
grievance was sent to you), at the extension hearing on January 31, 2012, where Hill admitted he
didn't have a good reason for seeking an extension and withdrew his application. I wanted to
address Hill's abuse of process for the record, Judge Schroeder decided to scream at me instead. It
was reminscent of Judge Nash Holmes telling me, on the record, in Reno Municipal Court case 11 TR
26800 that she would have me arrested and placed in jail if I said Richard G. Hill's name one more
time. I cross examined RPD Sargent Tarter about whether he had a retaliatory motive in ticketing
me outside Hill's office on 11/15/11 after Hill refused to give me my driver's license, and I reported
to Sargent Tarter that RPD Officer Chris Carter had admitted to taking bribes from Richard Hill.

Actually, there is some footage of the "terror" Richard G. Hill was exposed to that necessitated him
seeking a Protection Order (the "RPD made him" do it, honest): http://www.youtube.com/watch?
v=gBu9zflGALE

I don't know why Sargent Sifre (whom makes more money than a District Court Judge) should be so
upset with lawyers like me, who work in the foresclosure defense field (you might see if Geof Giles,
Esq. thinks I am quite the "Yosemite Sam" caricature of a cartoon villian that Richard G. Hill paints
me to be, or if Thomas J. Hall thinks that much of Rich and his "tactics", which are like those of a
malignant frat boys armed with daddy's pleadings). After all, Sargent Sifre has benefitted from
foresclosure defense work: http://stopforeclosurefraud.com/2011/01/29/nevada-dist-court-quiet-
title-viable-sifre-v-wells-fargo-bank/

Regardless, I have not "ghostwritten" any pleadings for Mr. Gessin or anybody else. I am listed as
attorney of record on adversary proceedings for Gessin, though the only things I ever filed for him
clearly indicated that I was not appearing as attorney of record and that the Answers to the
Complaints in those two adversary proceedings were being submitted on an "unbundled services"
arrangement. The bankruptcy court nonetheless listed me as attorney of record and I have been
and am in the process of having that changed. I have communicated with clerk Holly Estes and filing
office supervisore Debbie Gallagher in those regards.

I need more time to research and investigate the other allegations Hill makes, though I do not wish
you to infer and admission on my part to any allegation by Hill.

I have researched this service of eviction Order issues extensively, it relates to the Hill matter, and I
believe the WCSO and Hill are not following the law.

I am not sure why you wrote what you did at 9:09 am this morning considering you granted me until
3:00pm today to file my response, which I intend to along with a request for more time to
supplement it:
From:Patrick King (PatrickK@nvbar.org)
Sent: Mon 3/12/12 9:15 AM
Cc: David Clark (DavidC@nvbar.org); Glenn Machado (GlennM@nvbar.org)
March 12, 2012

To: Zach Coughlin

Dear Mr. Coughlin,

I am in receipt of your e-mail below, requesting additional time to respond. Please be advised that your response to the
grievance, including the e-mail letter below, become part of the record and may eventually be reviewed by a disciplinary
panel. With that said, it is important that we receive your response. Pursuant to your request, you are granted until
Friday, March 16, 2012 by 3:00pm to deliver your written response to the State Bar Office in Reno.

Thank you for your cooperation.


Subject: response to grievance from NV Attorney

Zach Coughlin, Esq.
Nevada Bar No: 9473
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
775 328 6045 fax: 949 667 7402

State Bar of Nevada
P.O. Box 50
Las Vegas, NV 89125-0050
600 E. Charleston Blvd.
Las Vegas, NV 89104

sent by fax and email only to:
Reno Office: 775 329 0522
Las Vegas Office: 702 385 2878
DavidC@nvbar.com, PatrickK@nvbar.com, GlennM@nvbar.com

March 9, 2012,

Dear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
I only just now received the letter, dated February 14th, 2012 that Assistant Bar Counsel King sent
me, wherein the grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please respond
in writing to this grievance within ten (10) days from the date of this letter."
I am requesting an extension of time to respond to this matter. I literally just received this mailing
from you within the last hour, and was unaware of this prior to that. Further, I hope I can
demonstrate to you and the State Bar of Nevada that circumstances at least somewhat beyond my
control have prevented me from receiving my mail in an orderly and consistent fashion. These
circumstances resulted in two different Domestic Violence Protection Orders being granted to me
against my former housemates by Master Edmondson of the Second Judicial District Court in FV12-
00188 and FV12-00187. Further, the electricity to my location was interrupted from one week
(though I attempted to get NV Energy to accept payment from me for services) from February 3rd to
February 20th, 2012, incident to one of the individuals against whom a protection order was issued
attempting to prevent me from obtaining electrical service. Additionally, the same individuals
against whom these protection orders were issued interfered with my access to my mail from the
USPS, and it has taken some time to get the USPS Postal Inspectors to release my mail to me and or
allow me to receive mail at my location.
Please note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn
Machado a written request that the State Bar of Nevada please help me in remaining aware of any
correspondence being sent me from the State Bar while I work to get my mailbox situation settled
(please see below):
On February 22nd, 2012 I wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that "I had
to move recently and moved in with two individuals who I ultimately wound up getting Protection
Orders against, and they have interfered with my ability to receive my mail with absolute certainty (I
have received much of my mail, and have pending correspondences/requests with the Postmaster
for Reno, NV to obtain a permanent and newly rekeyed lock and key to access my mailbox...I have
been informed by USPS Reno Postmaster agent named Mr. Heister that if I fax him proof of my
location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof
and will call him again tomorrow to see how much longer I must wait....if its much longer I will make
alternate arrangments, however, I am an electronic filer in both courts that I am appearing in (NVB
and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State Bar
of Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax
number or email address."

I feel strongly that Mr. Hill's allegations are ones I will wish to contest vigorously, and I hope I am
afforded an opportunity to do so. There is a lot more to this situation than Mr. Hill indicates.
Sincerely,
Zach Coughlin"

No: 9473
No: 9473

From: zachcoughlin@hotmail.com
To: lstuchell@washoecounty.us; mkandaras@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov;
cdbaker@richardhillaw.com; jboles@callatg.com; bbuckley@lacsn.org; daolshan@yahoo.com; jsoderlund@nlslaw.net;
jdelikanakis@swlaw.com; jgoodnight@washoecounty.us; jbosler@washoecounty.us; bdogan@washoecounty.us;
mechols@maclaw.com; mclarkson@puc.nv.gov
Subject: Evictions RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Fri, 10 Feb 2012 12:14:01 -0800

Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Tue, 7 Feb 2012 11:40:39 -0800
From: LStuchell@washoecounty.us
To: zachcoughlin@hotmail.com
CC: mkandaras@da.washoecounty.us

Mr. Coughlin

Our records indicate that the eviction conducted on that day was personally served by Deputy
Machen by posting a copy of the Order to the residence. The residence was unoccupied at the time.

Liz Stuchell, Supervisor
WCSO Civil Section

Sent: Monday, February 06, 2012 2:58 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov;
fourthestate@gmail.com; jamesandreboles@msn.com
Subject: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011

Dear IA Supervisor Stuchell and DDA Kandaras,

I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order on
me at 121 River Rock St., Reno 89501 on November 1, 2011 at 4:30 pm, in connection with
performing the lockout. It is my position that I was not "personally served" and I am trying to figure
out whether Deputy Machem is lying or whether the phrase "personally served" means something
other than what I believe it means, etc., etc. I appreciate your attention to this.

I am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
WCSO Deputy Machem with respect to the service of a Order Granting Summary Eviction against me
(in my law office where non-payment of rent was not alleged, no less in violation of NRS 40.253 and
where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6), especially where
a stay of eviction was not granted even while the RJC held on to most all my money...).
My issue with the WCSO is that Machem's Affidavit of Service indicates that he "personally served"
me, which kind of reminds me of all that robo-signing and MERS fraud I come across in my day job
(and do you wonder how many attorneys in the foreclosure defense game I am in constant contact
with who are watching and witness the potential RICO violations this writing mentions?), which
includes being a foreclosure defense attorney. So which is it? Did Machem "personally serve" me the
Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was "served" in compliance with
all time related rules because it was done in the "usual custom and practice of the WCSO. What,
exactly, is the "usual custom and practice of the WCSO? I hear a lot about this "within 24 hours"
stuff. So, I go hunting for some black letter law to support what those at the RJC and in the clueless
community at large (which often includes Nevada Legal Services and Washoe Legal Services, the
people you guys had such trouble actually serving in the lawsuits I filed, which may have actually
helped improved legal services in this community, if they were not dismissed due to insufficiency of
service of process, even where the IFP required the WCSO to served the defendants....). Anyway,
back to the "within 24 hours" phraseology: "
This whole business about The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order... is
inapplicable to this situation, where an Order Granting Summary Eviction was signed by October
27th, 2011. That language is only found in situations inapplicable to the current one. NRS
40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of NRS 40 where this within 24 hours
language occurs, and those situations only apply where, in:
40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
(2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue
a summary order for removal of the tenant or an order providing for the nonadmittance of the
tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours after
receipt of the order
and,
40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords agent may
apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
apartment, mobile home or commercial premises are located or to the district court of the county in
which the dwelling, apartment, mobile home or commercial premises are located, whichever has
jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order. The way
these summary eviction proceedings are being carried out in Reno Justice Court presently shocks the
conscience and violates Nevada law. There is not basis for effectuating a lockout the way WCSO's
Deputy Machem did in this case. The above two sections containing the within 24 hours of receipt
language are inapplicable, as those situations do not invoke the present circumstances, where the
Tenant did file an Affidavit and did contest this matter to a degree not often seen. To require
Nevada's tenants to get up and get out within 24 hours of receipt of the order (what does that
even mean? The use of terms like rendition, rendered, notice of entry, pronounced, is
absent here, and this receipt of the order language is something rarely found elsewhere in Nevada
law-see attached DMV statutory citations, and in employment law litigations where one must file a
Complaint within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b),
and NRCP 6(e) in imputing receipt of such a letter, when actual receipt is not shown, by applying a
constructive notice standard that relies upon the days for mailing extension of time for items
served in the mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st
Cir. 2009), the record did not reflect when the plaintiff received his right-to-sue letter. The letter
was issued on November 24, 2006. The court calculated that the 90-day period commenced on
November 30, 2006, based on three days for mailing after excluding Saturdays and Sundays. In order
to bring a claim under either Title VII or the ADA, a plaintiff must exhaust administrative remedies
and sue within 90 days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin
County Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196
(1984)(granting plaintiff an additional three days for mailing pursuant to Rule 6).... ...

Dear Washoe County Sheriff's Office,

http://en.wikipedia.org/wiki/Service_of_process
"Substituted service

When an individual party to be served is unavailable for personal service, many jurisdictions allow
for substituted service. Substituted service allows the process server to leave service documents
with another responsible individual, called a person of suitable age and discretion, such as a
cohabiting adult or a teenager. Under the Federal Rules, substituted service may only be made at
the abode or dwelling of the defendant.[4] California, New York,[5] Illinois, and many other United
States jurisdictions require that in addition to substituted service, the documents be mailed to the
recipient.[5] Substituted service often requires a serving party show that ordinary service is
impracticable, that due diligence has been made to attempt to make personal service by delivery,
and that substituted service will reach the party and effect notice.[5]"

I am pretty sure "personally served" means you served the person in person, not that a person
named Machem went and posted a notice on a door, personally himself. See, I think you guys are
thinking of the "person" in the word personally as applying to the server, when in all instances I have
ever seen it used in the law, the "person" part of "personally" applies to the person being served.
Help me out here, Mary.

https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1897&parid=root

Also, does the WCSO have a position on what type of service is required of eviction orders prior to
the WCSO or whoever does it, being able to conduct a lockout?

http://www.leg.state.nv.us/courtrules/nrcp.html

NRCP RULE 60. RELIEF FROM JUDGMENT OR ORDER... (c) Default Judgments: Defendant Not
Personally Served. When a default judgment shall have been taken against any party who was not
personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, and who has not entered a general appearance in the action, the court, after notice to
the adverse party, upon motion made within 6 months after the date of service of written notice of
entry of such judgment, may vacate such judgment and allow the party or the partys legal
representatives to answer to the merits of the original action. When, however, a party has been
personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, the party must make application to be relieved from a default, a judgment, an order, or
other proceeding taken against the party, or for permission to file an answer, in accordance with the
provisions of subdivision (b) of this rule.

Okay, so, really, you guys do this for a living, right...you serve people things....and sign Affidavits
under penalty of perjury and stuff, and you are telling me you believe "personally served" can
included situations where the person was not there? Okay.....You do know that, like, a Summons and
Complaint need to be "personally served" in the sense that, say Machem, would need to see that
person and serve it on them (I don't think they have to take the paper, they don't need to agree to
accept service, but Machem does need to see that person, in person, personally when he is swearing
under penalty of perjury that he "personally served" somebody. Usually "personally served" is only
done in the case of the first thing filed (unless there is an IFP) in a case, the Summons and
Complaint. Thereafter, typically, people just effect "substituted service" because its cheaper, less of
a hassle, and "personal service" is only required for serving the pleadings that start a case, the
Summons and Complaint. Wow....Okay, so this is my whole point, these state sponsored lockouts
under color of state law should not be being done so fast, unless you guys "personally serve" the
tenant, I feel the law is quite clear, you have to effect "substituted service" which, under NRCP 6(a)
and NRCP 6(e) and NRCP 5(b)(2) (and NRCP, not JCRCP is applicable to eviction matters according to
NRS 118A) the tenant cannot be deemed to have received or constructively received the Order until
the 3 days for mailing has passed.

Personal service by process server

Personal service is service of process directly to the (or a) party named on the summons, complaint
or petition. In most lawsuits in the United States, personal service is required to prove service. Most
states allow substituted service in almost all lawsuits unless you are serving a corporation, LLC, LLP,
or other business entity; in those cases, personal service must be achieved by serving (in hand) the
documents to the "Registered Agent" of a business entity. Some states (Florida) do not require that
the documents actually be handed to the individual. In California and most other states, the
documents must be visible to the person being served, i.e., not in a sealed envelope. If the individual
refuses to accept service, flees, closes the door, etc., and the individual has been positively
identified as the person to be served, documents may be "drop" served, and it is considered a valid
service. Personal service of process has been the hallmark for initialing litigation for nearly 100 years,
primarily because it guarantees actual notice to a defendant of a legal action against him or her.
Personal service of process remains the most reliable and efficacious way to both ensure compliance
with constitutionally imposed due process requirements of notice to a defendant and the
opportunity to be heard. [2]^ The National Law Review: The Continuing Relevance of Personal
Service of Process

And even if something indicates Coughlin "knew" about the Order, much like in the case of
Coughlin's that was dismissed where the Washoe County Sheriff's didn't manage to get the
"personal service" of the Summons and Complaint done in time, or "sufficiently", opposing counsel
in that matter could tell you that "actual notice" is not a substitute for compliance with the service
requirements.

Which is nice because folks like Richard G. Hill, Esq. have less of an opportunity to game the system
and swoop in with lockout then assert a bunch of hooey about NRS 118A.460 "reasonable storage,
moving, and inventorying expenses" subjecting the tenant's personal property to a lien. Richard G.
Hill insisted on throwing away the last thing my beloved grandmother gave me before she died 2
years ago in the town dump. He and his contractor lied about so many things, including the fact that
they used my own damn plywood to board up the back porch of the property, then submitted a bill
to the court in an exhibit for $1,060 for "securing" the property (which doesn't really apply to NRS
118A.460's "reasonable storage moving and inventorying expenses" like it is required to...further,
the charged me $900 a month for storage and sent me a bill for such prior to my arrest for
trespassing at the 121 River Rock location,...well if they charged me $900 to have a home law office
there, then how is it someone could be trespassing if they are being charged the full rental value for
"use and occupancy of the premises"? Further, even if it was a storage situations, there are sections
of NRS 118A devoted to evicting someone from a storage facility, not arresting them for trespass,
and certainly not a custodial arrest where the RPD Officer Carter and Sargent Lopez admit they never
issued a warning to me or asked me to leave prior to conducting a custodial arrest (which required
$800 of bail, great!, and 3 days in jail, no less). This is especially poor form where Officer Carter
admitted to me that he takes bribes from Richard Hill. Hey, if Officer Carter did not say that to me,
go ahead and sue me, my man....I'm waiting.....that's what I thought.

He can say he was joking all he wants, but it ain't no joking ass situation to me when you are
arresting me and causing a google search result for my name to show an arrest....that's damaging
the only thing I have of monetary value (my professional reputation and name). It ain't no stand up
hour when you are putting me in cuffs, bro. And Officer Carter and Sargent Lopez refused to
properly query Hill as to whether he had sent me, prior to the trespassing arrest, a bill for the "full
rental value" of the property, a value that, at $900, was the same charge for the full "use and
occupancy" of the premises. And Richard G. HIll, Esq. was too busy chortling and filling out the
Criminal Complaint to bother setting them straight, despite my cues, I guess.

Now, add to that malfeasance the fact that Judge Sferrazza let Casey Baker, Esq. prepare the Order,
which means faithfully put to writing what the Judge announced, not attempt to steal $2,275 for
your Californian Beverly Hills High School graduate neurosurgeon client by slipping in something the
judge never said, ie, that the neurosurgeon gets to keep the $2,275 that Judge Sferrazza order the
tenant to pay into the Reno Justice Court as a "rent escrow" deposit required to preserve the right to
litigate habitability issues. Now, nevermind the fact that Judge Sferrazza actually did not have the
jurisdiction to require that (there is not JCRLV 44 in Reno, that's a Vegas rule, and if Reno wants a
rule like that of its own JCRCP 83 requires the RJC to publish it and get it approved by the Nevada
Supreme Court first....period.). Okay, so, to take it a step even further, Baker's order goes on to say
"but the $2,275 won't be released to the neurosurgeon yet, "instead that sum shall serve as security
for Coughlin's cost on appeal, pursuant to Nevada JCRCP 73...". But wait, doesn't that mean Coughlin
then gets a Stay of Eviction during the pendency of the Appeal? Isnt' that was a security that large
must be for? Because the "Appeal Bond" is set by statute at only a mere $250....so holding on to 10
times that much of Coughlin's cash must have been for the "Supersedeas Bond" mentioned a
yielding one a Stay of Eviction in NRS 40.380 and 40.385.

I know, I know, its confusing because actually those sections force the landlord, his attorneys and
the RJC to choose between viewing Coughlin as a residential tenant whose rent is less than $1,000,
and whom therefore is only required to post a measly supersedeas bond of $250 (and remember, a
supersedeas bond equals a stay of eviction equals not trespassing) or the the other choice is to view
Coughlin as a commercial tenant, which would allow charging a higher supersedeas bond (except for
that pesky part about his rent being under the $1,000 required by the statute to do so, his rent
being only $900), except, darn it, old Richard G. Hill, Esq. and Casey Baker, Esq. elected to pursue
this summary eviction proceeding under a No Cause Eviction Notice, which is not allowed against a
commercial tenant (ie, you can't evict a commercial tenant using the summary eviction procedures
set forth in NRS 40.253 unless you alllege non payment of rent and serve a 30 Day Non Payment of
Rent Notice To Quit, which they didn't because they "are just taking the path of least resistance
here, Your Honor (insert their smug chuckling and obnoxious/pretentious "can you believe this guy?"
laughter and head shaking...).

NRS 40.380 Provisions governing appeals. Either party may, within 10 days, appeal from the
judgment rendered. But an appeal by the defendant shall not stay the execution of the judgment,
unless, within the 10 days, the defendant shall execute and file with the court or justice the
defendants undertaking to the plaintiff, with two or more sureties, in an amount to be fixed by the
court or justice, but which shall not be less than twice the amount of the judgment and costs, to the
effect that, if the judgment appealed from be affirmed or the appeal be dismissed, the appellant will
pay the judgment and the cost of appeal, the value of the use and occupation of the property, and
damages justly accruing to the plaintiff during the pendency of the appeal. Upon taking the appeal
and filing the undertaking, all further proceedings in the case shall be stayed.

So, why on earth is the City Attorney's Office still trying to try Coughlin on the trespass charge for
which he endured a custodial arrest and for which old Richard Hill is still filing Motion's to Show
Cause on in the appeal of the summary eviction matter in CV11-03628? Why, oh why? Does the
Reno City Attorney's Office have some sort of vested interest in keeping Coughlin down, busy,
besotted, encumbered, or otherwise? It, why, it couldn't be because Coughlin has a really good
wrongful arrest cause of action against the Reno Police Department, could it?
http://www.youtube.com/watch?v=5PR7q4OI5b0

And, well, yeah the Washoe County Sheriff's Office didn't quite get those Summons and Complaints
served in that one case Coughlin was suing his former employer in, the one where Coughlin was
granted an Order to Proceed In Forma Pauperis, which required the Washoe County Sheriff's Office
to serve the Summons and Complaints....But what does that have to to with the 6 days Coughlin
spent in jail on the arrest shown in the youtube video above? Its not like the Washoe County jailed
videotaped a scene where they were forcing Coughlin to get naked and put on a green dress. What's
that? It is? They did do that? Really? No...What? They also forced him to simulate oral and anal sex
with deputies, in the guise of some ridiculous "procedure" necessary to insure Deputy safety? Oh,
wow. And they retaliated against him for failing to answer their religious preference interrogation
questions by placing him in an icy cold cell for hours at a time, refusing him medical care despite his
plaintive cries for help, while wearing a thin t-shirt? Wow. They didn't jam a taser needle in his spine
for extended periods of time, though, did they? Your kidding! Whats next, your going tell me
Sargent Sigfree of the Reno PD ordered a custodial arrest on Coughlin for "jaywalking" while
Coughlin was peacefully filming, from a public spot, Richard G. Hill's fraudulent contractor Phil
Howard destroying and taking to the town dump items of enormous sentimental value to Coughlin
that he was prevented from retrieving from the property during the scant time he was allowed to
(after he paid $480 worth of a lien for what he knew not, because, despite, ol' Contractor Phil's
fraudulent $1,060 bill for "securing" the back porch (with screws facing the outside, inexplicably, and
a window unit a/c left in the window facing the sidewalk near the Lakemill Lodge, secured by
nothing but duct tape

It is kind of a combo neon sign that says "Burglarize this Place, Everybody!"), Coughlin's former
home law office was burglarized on December 12, 2011 while Richard G. Hill was holding its contents
(including, tackily, Coughlin's client's files, like the ones for the foreclosure defense actions, etc.),
asserting his "lien". A lien for "storage" where the charge for storage, $900, was the same as the
charge for "full use and occupany" was. However, that $900 a month for "storage" also included
another $1,060 charge for "securing" (and that bill actually listed "fixing a leak in the
basement...neither of which seem to have much to do with the "reasonable storage, moving, and
inventorying" expenses such a lien is provided for under NRS 118A.460....). Jeez, your probably going
to tell me Sargent Sigfree ordered another custodial arrest on Coughlin just two days after the
jaywalking arrest, for the same fact pattern that Master Edmondson granted Coughlin's applications
for Protections Orders against based upon the battery and assaults that his former housemates
committed. Because, Sargent Sigfree thinks its "misuse of 911" for Coughlin to call when he returns
home at night and his dog has mysteriously disappeared, and his housemates make menacing
commentary about it. Surely, Coughlin, a former domestic violence attorney would have nothing
helpful to add to Sargnet Sigfree's expert opinion that "animal abuse is not domestic violence" (tell
that to NRS 33.010, Sarge) and that its, rather, "a matter for animal control" and that Sargent Sigfree
was "trying to help" Coughlin by arresting him, again, and necessitating the $1,500 bail associated
with the gross misdemeanor charge, "Misuse of 911" because, as Sargent Sigfree told Coughlin "you
keep putting yourself in situations where you are victimized" so it was necessary to arrest Coughlin
in that regard.

But hey, at least NV Energy hasn't refused to let Coughlin get any electrical service for the past week
since those with the Protection Orders against them cancelled the service and NV Energy shut it off,
without providing any notice to Coughlin, right. Nevermind. But...but surely when NV Energy shut of
the power to Coughlin's home law office on October 4th, 2011, just hours prior to the bad faith
"inspection" with videographer of Coughlin' s home law office that Casey Baker, Esq. thought so very
necessary one day before Coughlin's Tenant Answer was due...surely NV Energy did not leave the
back gate to Coughlin's home law office open and speed off, Coughlin's beloved mountain bike
suddenly missing (the one the parents of his girlfriend of 5 years gave him)? Well, NV Energy is
probably not retaliating against Coughlin for complaining about that by refusing him electric service
for the past seven days, you would have to assume....

NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of premises to pay
rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253:

1. Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with
the trial court a bond in the amount of $250 to cover the expected costs on appeal. A surety upon
the bond submits to the jurisdiction of the appellate court and irrevocably appoints the clerk of that
court as the suretys agent upon whom papers affecting the suretys liability upon the bond may be
served. Liability of a surety may be enforced, or the bond may be released, on motion in the
appellate court without independent action. A tenant of commercial property may obtain a stay of
execution only upon the issuance of a stay pursuant to Rule 8 of the Nevada Rules of Appellate
Procedure and the posting of a supersedeas bond in the amount of 100 percent of the unpaid rent
claim of the landlord.

2. A tenant who retains possession of the premises that are the subject of the appeal during the
pendency of the appeal shall pay to the landlord rent in the amount provided in the underlying
contract between the tenant and the landlord as it becomes due. If the tenant fails to pay such rent,
the landlord may initiate new proceedings for a summary eviction by serving the tenant with a new
notice pursuant to NRS 40.253.

NRS 40.390 Appellate court not to dismiss or quash proceedings for want of form. In all cases of
appeal under NRS 40.220 to 40.420, inclusive, the appellate court shall not dismiss or quash the
proceedings for want of form, provided the proceedings have been conducted substantially
according to the provisions of NRS 40.220 to 40.420, inclusive; and amendments to the complaint,
answer or summons, in matters of form only, may be allowed by the court at any time before final
judgment upon such terms as may be just; and all matters of excuse, justification or avoidance of the
allegations in the complaint may be given in evidence under the answer.

NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and Nevada
Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not
inconsistent with the provisions of NRS 40.220 to 40.420, inclusive, apply to the proceedings
mentioned in those sections.

But, back to the Sheriff's Office. And, I am not really buying the idea that you guys don't know NRCP
4 through 6 like the back of your hand, but....hell, maybe you don't. But, clearly the language in NRS
40 about how the Sheriff may "remove tenant from the property within 24 hours of receipt of the
Order" do not apply where the Tenant filed a Tenant's Answer and showed up to the Hearing and
litigated the matter. Especially where, as here the lease had not terminated, by its terms, but was
rather renewed. This is particularly true where NRS 118A prevents so terminating a holdover
tenant's lease for a retaliatory or discriminatory purpose.

I would hate to see people start to think the Washoe County Sheriff's Office is cutting corners on the
whole "personally served" thing (just so a landlord could get what they want quicker), just like I
would hate for people to think the Reno Municipal Court is letting the bottom line get in the way of
providing that whole Sixth Amendment Right To Counsel where jail time is even a possibility thing.
And, hey, if the RMC denies an indigent attorney the Sixth Amendment Right To Counsel, the finds
him guilty of NRS 22.030, Summary Contempt Commited in the Presence of the Court, and the puts
him in cuffs when the Trial ends, summarily sentencing him to 3 days in jail for violating NRS 22.030,
well....that's no big deal, right, I mean, the RMC technically kept its promise that the underyling
charge, though technically it could result in incarceration would not...because the incarceration was
for a whole dang different charge, ie, Summary Contempt in the presence of the Court....and so what
if the whole zealous advocate thing and the denying the Sixth Amendment Right to Counsel thing
and the Summary Contempt thing don't go so well together....Or if 6 court employees had to stay til
9pm getting paid overtime at the RMC to get 'r done...

NRCP 4: "(d) Summons: Personal Service. The summons and complaint shall be served together. The
plaintiff shall furnish the person making service with such copies as are necessary. Service shall be
made by delivering a copy of the summons attached to a copy of the complaint as follows:...(6)
Service Upon Individuals. In all other cases to the defendant personally, or by leaving copies thereof
at the defendants dwelling house or usual place of abode with some person of suitable age and
discretion then residing therein, or by delivering a copy of the summons and complaint to an agent
authorized by appointment or by law to receive service of process. [As amended; effective January 1,
2005.] (e) Same: Other Service. (1) Service by Publication. (i) General. In addition to methods of
personal service, when the person on whom service is to be made resides out of the state, or has
departed from the state, or cannot, after due diligence, be found within the state, or by
concealment seeks to avoid the service of summons, and the fact shall appear, by affidavit, to the
satisfaction of the court or judge thereof, and it shall appear, either by affidavit or by a verified
complaint on file, that a cause of action exists against the defendant in respect to whom the service
is to be made, and that the defendant is a necessary or proper party to the action, such court or
judge may grant an order that the service be made by the publication of summons. Provided, when
said affidavit is based on the fact that the party on whom service is to be made resides out of the
state, and the present address of the party is unknown, it shall be a sufficient showing of such fact if
the affiant shall state generally in such affidavit that at a previous time such person resided out of
this state in a certain place (naming the place and stating the latest date known to affiant when such
party so resided there); that such place is the last place in which such party resided to the
knowledge of affiant; that such party no longer resides at such place; that affiant does not know the
present place of residence of such party or where such party can be found; and that affiant does not
know and has never been informed and has no reason to believe that such party now resides in this
state; and, in such case, it shall be presumed that such party still resides and remains out of the
state, and such affidavit shall be deemed to be a sufficient showing of due diligence to find the
defendant. This rule shall apply to all manner of civil actions, including those for divorce"

I guess it don't matter much to me which one of you pays me my damages for the wrongful eviction,
illegal lockout, whether its the landlord, his attorney, or the Sheriff's Office. Your money is always
good with me.

Zach Coughlin, Esq.

Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Tue, 7 Feb 2012 11:40:39 -0800
From: LStuchell@washoecounty.us
CC: mkandaras@da.washoecounty.us

Mr. Coughlin,

Our records indicate that the eviction conducted on that day was personally served by Deputy
Machen by posting a copy of the Order to the residence. The residence was unoccupied at the time.

Liz Stuchell, Supervisor
WCSO Civil Section

Sent: Monday, February 06, 2012 2:58 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov;
fourthestate@gmail.com; jamesandreboles@msn.com
Subject: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011

Dear IA Supervisor Stuchell and DDA Kandaras,

I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order on
me at 121 River Rock St., Reno 89501 on November 1, 2011 at 4:30 pm, in connection with
performing the lockout. It is my position that I was not "personally served" and I am trying to figure
out whether Deputy Machem is lying or whether the phrase "personally served" means something
other than what I believe it means, etc., etc. I appreciate your attention to this.

I am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
WCSO Deputy Machem with respect to the service of a Order Granting Summary Eviction against me
(in my law office where non-payment of rent was not alleged, no less in violation of NRS 40.253 and
where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6), especially where
a stay of eviction was not granted even while the RJC held on to most all my money...).
My issue with the WCSO is that Machem's Affidavit of Service indicates that he "personally served"
me, which kind of reminds me of all that robo-signing and MERS fraud I come across in my day job
(and do you wonder how many attorneys in the foreclosure defense game I am in constant contact
with who are watching and witness the potential RICO violations this writing mentions?), which
includes being a foreclosure defense attorney. So which is it? Did Machem "personally serve" me the
Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was "served" in compliance with
all time related rules because it was done in the "usual custom and practice of the WCSO. What,
exactly, is the "usual custom and practice of the WCSO? I hear a lot about this "within 24 hours"
stuff. So, I go hunting for some black letter law to support what those at the RJC and in the clueless
community at large (which often includes Nevada Legal Services and Washoe Legal Services, the
people you guys had such trouble actually serving in the lawsuits I filed, which may have actually
helped improved legal services in this community, if they were not dismissed due to insufficiency of
service of process, even where the IFP required the WCSO to served the defendants....). Anyway,
back to the "within 24 hours" phraseology: "
This whole business about The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order... is
inapplicable to this situation, where an Order Granting Summary Eviction was signed by October
27th, 2011. That language is only found in situations inapplicable to the current one. NRS
40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of NRS 40 where this within 24 hours
language occurs, and those situations only apply where, in:
40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
(2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue
a summary order for removal of the tenant or an order providing for the nonadmittance of the
tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours after
receipt of the order
and,
40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords agent may
apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
apartment, mobile home or commercial premises are located or to the district court of the county in
which the dwelling, apartment, mobile home or commercial premises are located, whichever has
jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order. The way
these summary eviction proceedings are being carried out in Reno Justice Court presently shocks the
conscience and violates Nevada law. There is not basis for effectuating a lockout the way WCSO's
Deputy Machem did in this case. The above two sections containing the within 24 hours of receipt
language are inapplicable, as those situations do not invoke the present circumstances, where the
Tenant did file an Affidavit and did contest this matter to a degree not often seen. To require
Nevada's tenants to get up and get out within 24 hours of receipt of the order (what does that
even mean? The use of terms like rendition, rendered, notice of entry, pronounced, is
absent here, and this receipt of the order language is something rarely found elsewhere in Nevada
law-see attached DMV statutory citations, and in employment law litigations where one must file a
Complaint within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b),
and NRCP 6(e) in imputing receipt of such a letter, when actual receipt is not shown, by applying a
constructive notice standard that relies upon the days for mailing extension of time for items
served in the mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st
Cir. 2009), the record did not reflect when the plaintiff received his right-to-sue letter. The letter
was issued on November 24, 2006. The court calculated that the 90-day period commenced on
November 30, 2006, based on three days for mailing after excluding Saturdays and Sundays. In order
to bring a claim under either Title VII or the ADA, a plaintiff must exhaust administrative remedies
and sue within 90 days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin
County Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196
(1984)(granting plaintiff an additional three days for mailing pursuant to Rule 6).

Further, despite what the inaccurate handouts of Nevada Legal Services may say about this 24
hours and the applicability of the JCRCP to cases like these, NRS 40.400 Rules of practice, holds that
:The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate Procedure
relative to civil actions, appeals and new trials, so far as they are not inconsistent with the provisions
of NRS 40.220 to 40.420, inclusive, apply to the proceedings mentioned in those sections. As such
NRCP 6(a),(e) applies to the Order of Summary Eviction that WCSO Deputy Machem alleged, under
penalty of perjury, that he "personally served" upon me on November 1, 2011. That is a lie by Mr.
Machem, unless "personally served" is defined in a rather impersonal way and or Machem and I
have totally different understanding of the definition of "personally served", which may be the case.
Or, perhaps the Sheriff's Office is busy and doesn't want to wait around to "personally serve" every
tenant it wishes to evict. Fine, then just use the "mail it and allow three days" rule in NRCP 6(e)...the
landlord's might not like it, but they can use that frustration as an incentive not to jump to litigating
every disagreement about habitability that a tenant brings to them. You may not realize how
ridiculous some landlord's get. In my case, I offered to fix basic things that clearly implicated the
habitability rules in NRS 118A.290 and the Californian neurosurgeon, Beverly Hill High School
graduate landlord balked and complained then hired and attorney four days into a dispute.....at
which point the rules against contacting represented parties prevented much in the way of real
settlement discussion, particularly where opposing counsel has continuously demonstrated a
complete indifference to pursuing settlement (why would he at the rates he bills hours at?). I just
don't think the Sheriff's Office needs to sully its image or damage the citizen tenants of Washoe
County in the name of pleasing people like Dr. Matt Merliss or Richard G. Hill, Esq.
I AM REQUESTING, IN WRITING, THAT BOTH OF YOUR OFFICES INVESTIGATE THIS AND PROVIDE A
SWORN AFFIDAVIT FROM MR. MACHEM THAT ADMITS THAT I WAS NOT PERSONALLY PRESENT
WHEN HE SERVED THE ORDER FOR SUMMARY EVICTION IN RJC REV2011-001708 ON 11/1/12 AT
4:30 PM (ACCORDING TO HIS AFFIDAVIT OF SERVICE). YOU NEVER KNOW, I MIGHT HAVE
IRREFUTABLE PROOF THAT I WAS SOMEWHERE ELSE AT THAT TIME, SO, BE CAREFUL. There simply is
not anything specific in Nevada law addressing how such Summary Eviction Orders are to be served
and carried out. The sections dealing with

NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant
for default in payment of rent....
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the
information contained in the affidavit, and the filing by the landlord of the affidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the
hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice
provided for in this section. If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a summary
order for removal of the tenant or an order providing for the nonadmittance of the tenant....
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a
motion, file a motion with the court, on a form provided by the clerk of the court, to dispute the
amount of the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 for the
inventory, moving and storage of personal property left on the premises. The motion must be filed
within 20 days after the summary order for removal of the tenant or the abandonment of the
premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed from the premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the
motion. The hearing must be held within 10 days after the filing of the motion. The court shall affix
the date of the hearing to the motion and order a copy served upon the landlord by the sheriff,
constable or other process server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 and
any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges determined to be
due or if no charges are determined to be due...."
I also want to know why NRS 40. 253(8) was not followed with respect to my November 17th, 2011
filing of a Motion to Contest Personal Property Lien. Why didn't the WCSO serve notice, as required
by NRS 40.253(8) upon the landlord's attorney Richard Hill? Why didn't I get a hearing within the 10
days called called for by that section (to get back my client's files no less), but rather, I had to wait a
full 33 days to get a hearing, and service of notice of the hearing was not effectuated, as required by
NRS 40.235(8), by the WCSO. Why?
Please provide an indication, in writing, of the names and case numbers for the last 20 incidences
when the WCSO has served notice of a hearing set pursuant to NRS 40.253(8). What's that? The
WCSO has NEVER served such notice? Yet the WCSO is there with bells on (or Machem is) to lie in
Affidavits of Service to lock out the citizen tenants of Washoe County impermissilby early vis a vis
NRCP 5(b)(2) and NRCP 6(e)? Why is that? Is it a conspiracy? Does money talk? When I was arrested
for trespassing on November 12th, 2011 by RPD Officer Chris Carter and Sargent Lopez, Carter
admitted to me that "Richard Hill pays him a lot of money and therefore he arrests whom Richard
Hill says to and does what Richard Hill says to do...." Both Carter and Sargent Lopez refused to
investigate, despite prompting, whether Richard Hill has sent the tenant/arrestee a bill or demand
letter in bill for the full rental value of the property, $900 per month, under some interpretation of
the "reasonable storage, moving, and inventorying expenses" collectable by a landlord under a
personal property line set forth in NRS 118A.460 (one could also interpret such a bill as Hill's
withdrawing or eradicating the Order of Summary Eviction itself, which was not "personally served"
by the Washoe County Sheriff (despite what their Affidavit of Service says...I wasn't even there at the
time they changed the locks...and so the Summary Eviction Order was not properly served under
NRCP 6, and despite the Reno Justice Court impermissibly converting $2300 of my money under a
"rent escrow" Order its required I comply with in order to litigate habitability issues in a summary
eviction proceeding under NRS 40.253, despite NRS 40.253(6)'s express dicate against such an Order
(unless, pursuant to JCRCP 83, a justice court gets such a rule, like Justice Court Rule of Las Vegas
(JCRLV) Rule 44, published and approved by the Nevada Supreme Court, which the RJC has not,
rather, the RJC applies all these insidious secret "house rules" (like forcing tenants to deliver
themselves to the filing office to submit to personal service notice of a summary eviction hearing
within, like, 12 hours of the Tenant filing a Tenant's Answer or Affidavit in response to an eviction
Notice, rather than the service requirements of such notice following NRCP 6 (days for mailing, etc.,
etc., in other words, in the RJC everything is sped up imperissilby to help landlord's out, and the NV.
S. Ct ruling in Glazier and Lippis clearly contemplate personal liability against the Court and or Judges
themselves for so doing)....A Qui Tam action or something a la Mausert's in Solano County, I believe,
in California, would be very interesting...Still haven't heard anything from the Reno PD about the
various complaints I have filed with them in writing related to the wrongful arrests, excessive force
and other misconduct committed against me, though they did arrest me the other day for calling
911incident to some domestic violence for which I was granted to Extended Protection Orders
against my former housemates....old Sargent Sigfree ordered that arrest, as he did two days prior
when he ordered a custodial arrest of me for "jaywalking".

Funny thing, I never heard anything back from the RPD about complaints like the following one:

From:

NvRenoPd@coplogic.com

Sent:
Wed 9/07/11 10:51 PM
****DO NOT RESPOND TO THIS E-MAIL****
We're sorry the following problem was found during review
of your submitted report T11005956:
THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS REPORT WAS PRINTED AND
PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL BE ADDRESSED.
Thank you,
Officer WOZNIAK,
Reno Police Department
What is interesting there is that at least I was provided the name of an officer, a "Wozniak" (though I
have been unable to confirm the existence of
such an RPD Officer...
or whether " THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS REPORT WAS
PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL BE
ADDRESSED."

What is more strange is that I submitted several online police reports to the Reno PD (a couple of
which asserted complaints against various Reno PD officers, or asked why RDP Officer Carter, whom
admitted taking bribes from Richard G. Hill, Esq. at the time of my custodial arrest for trespassing
(the one where Richard Hill signed a Criminal Complaint for trespass, then Officer Carter and Sargent
Lopez refused to follow up on my imploring them to ask Hill whether he has recently sent me a bill
for the "full rental value" of the property, the same amount that had been charged for the "use and
enjoyment" of the premises, $900, in comparision to what NRS 118A.460 may deem "reasonable
storage" expenses for which a lien is available to a landlord, though NRS 118A.520 has outlawed rent
distraints upon tenant's personal property....Regardless, between January 8 - 12th, 2012, and was
arrested twice by the Reno PD shortly after submitting these written complaints to the Reno PD.

Actually, upon being released from jail on November 15th, 2011, incident to the custodial trespass
arrest, I went to Richard HIll's office to get my wallet and driver's license. He refused to provide it to
me until late November 22nd, 2011. Hill called the Reno PD on the 15th (or maybe I did because he
was withholding my state issued ID, the one I would need to rent a room, drive my car, and my
wallet, which is kind of useful in such situations....). Anyways, Sargent Tarter of the Reno PD showed
up, he went inside Hill's office with Hill for quite some time and the result was Tarter telling me to
leave. I did, but while driving down St. Laurence towards S. Virginia (Hill's office is at 652 Forrest St.
89503 and would have required turning down the wrong way of a one way street, Forrest, to go back
to Hill's Office (so clearly I was not headed to Hill's office) Sargent Tarter began tailing me, then he
pulled me over, then he gave me a ticket, in retaliation if you ask me for reporting RPD Officer Carter
admitting that he takes bribes from Hill to Sargent Tarter minutes earlier. Uh, well, anyways, another
Sargent calls me later that night, taking the "good cop" role. But upon informing him of what RPD
Officer Carter told me about Hill paying him money to arrest people during the 11/12/11 trespassing
arrest, that Sargent immediately informed me that, despite this being the first he heard of that, he
was sure that was not happening....I guess RPD Officer Carter is trying to explain away his comments
about Richard Hill paying him money to arrest people by dismissing them as sarcasm, a joke, said in
jest, whatever....but I don't see how that situation (a license attorney getting arrested for a crime, a
conviction for which would result in that attorney being required to report said conviction to the
State Bar of Nevada under SCR 111, etc., and possibly resulting in a suspension of that attorney's
license to practice law, or worse...) is all that jocular of a situation. Combine that with the too quick
to dismiss my reports of bribery by Richard Hill to officer Carter to the RPD Sargent who called me
on 11/15/11 regarding the retaliation by Sargent Tarter that I complained of, and I don't think it is all
that unreasonable for anyone to take RPD Officer Carter at his word regarding Richard G. Hill, Esq.
paying him money to arrest whom Hill says to arrest. Add to that Sargent Sigfree ordering my arrest
for jaywalking (by a trainee RPD Officer) on January 12th, 2011 (custodial arrest, bail of $160
emptied my bank account out, or pretty close to it) while I was peacefully filming from a public spot
Richard G. Hill, Esq's contractor Phil Howard, whom had submitted bills in courts records and filings
under the lien for "reasonable storage moving and inventorying" found in NRS 118A.460, even
where old Phil used my own plywood at the property to board up the back porch (curiously leaving
the screws holding up the plywood exposed to exterior of the property where anyone could easily
unscrew them, and also leaving in a window unit ac secured only by ducttape in a window facing a
sidewalk by the LakeMill Lodge....which resulted in $8,000 at least of my personal property being
burglarized from my former home law office on Decmeber 12th, 2011 while Hill was asserting a lien
on all my personal property found therein (and my client's files, which arguably are not even my
property, but rather, the client's property). Hill went on to place what he believes to be my social
security number in court records, on purpose, despite his signing an Affirmation pursuant to NRS
239B.030 that that was not the case (attaching a two page report to the RPD as an Exhibit). Then Hill
and his contractor Phil Howard both committed perjury when the signed Declarations attesting that I
had climbed on the contractors truck or ever touched Hill. Hill lies constantly, whether under penalty
of perjury or now, so I don't have time to rebut every little lie he makes (he makes me out to comes
across as a Yosemite Sam caricature of a human being in his filings when he describes me...).

Further, why am I arrested for trespassing and not those from Nevada Court Services where they
went behind closed gate the the backyard of my home law office and banged on window extremely
loudly for 40 minutes at a time 3 times a day, one guy ringing the doorbell, one guy moving around
all other sides of the property banging on the windows, peering in closed blinds, and affecting a
phony "color of law" tone, resemblance, and verbal communications, misleadingly announcing that
they were "Court Services, come out now!", wearing their pretend Sheriff outfits, big equipment
saddled belts (including firearms, I believe, and radios), etc. ,etc.
http://www.youtube.com/watch?v=jQ132q2O7DY

Add to that that Nevada Court Services Jeff Chandler drives by in his Monster Truck baring his
personalized "NCS" license plate while I am in the RPD squad car, handcuffed, outside my former law
office at 121 River Rock, at the time of the 1/12/12 jaywalking arrest and the appearances are
troubling. Now, add to that that Lew Taitel, Esq. was my court appointed public defender in the
Reno Municipal Court in the trespass case, and that Judge Gardner had refused to provide me the
names of prospective appointed defense counsel (I wanted to run a conflicts check) at my
arraignment (where Marshal Mentzel barked at me in a threatening tone, using menacing language),
whereupon Taitel was appointed as my defense attorney and filed a notice of appearance, and
received my confidential file, pc sheet, arrest reports, ssn, etc....only its turns out that Taitel shares
and office and a receptionist with Nevada Court Services and they list him and his picture on their
website as "associated with" their Process Server corporation, despite the prohibition lawyers face
against fee sharing with non-lawyers. Then, Taitel somehow manages to get out of defending my
case without filing a Motion to Withdraw as Counsel, despite that being required by the Reno
Municipal Court Rule 3(B):
RMCR Rule 3(B): Authorization to Represent (B): An attorney desiring to withdraw from a case shall
file a motion with the court and serve the City Attorney with the same. The court may rule on the
motion or set a hearing.

But, perhaps most troubling of all is the implication that the Reno City Attorney's Office, which
defends actions against the City of Reno Police Department and its Officers, has a vested interest in
discrediting me in advance of the wrongful arrest lawsuit that the Reno City Attorney's office knew
was imminent at the time of all of the above incidents, relating to the following August 20th, 2011
wrongful arrest by RPD Officer's Duralde and Rosa. http://www.youtube.com/watch?
v=5PR7q4OI5b0 So, that's what attempting to coerce a suspect's consent to an impermissible search
sounds like? Add to that that the trespassing case is before Judge Gardner, whom most recently was
employed with the Reno City Attorney's Office.

And, you know what is funny? Officer Del Vecchio cuffed me and placed me in his squad car last
summer after he terrified me and another gentleman who had bicycles. He veered across the road
and screeched his squad car to a halt, jumped out, and did some other stuff, then demanded my
name and ID...and the lawyer in me didn't like that that much, and he didn't like me not wanting to
give it to him. This occurred right in front of my home law office in the summer of 2011. He cuffed
me and told me I was going to jail for something about a light on the front of my bicycle (the one NV
Energy likely stole when the shut off my power, unnoticed, on October 4, 2011) despite my bike
actually having such a light....but then Del Vecchio's partner did him a solid and talked some sense
into him, and I humbled it up for Del Vecchio and we both let it go, and I didn't go to jail....Until Del
Vecchio was present supervising some Officer's training at the scene of my custodial (9 hour)
jaywalking arrest) on 1/12/12. But Del Vecchio, I guess either didn't want to or wasn't able to talk
some sense into Sargent Sigfree.....and then Sargent Sigfree (the spelling is likely off) had me
arrested and charged with a gross misdemeanor, "Misuse of 911" just two days later, on January
14th, 2011 when I called 911 to report that my roommates were laughing menacingly when I asked
them why my dog was missing (I had also been chased up to my room numerous times since moving
in with these people, something I had to do because so much of my money had been taken up with
bail or lost earnings due to all these wrongful arrests and abuse of processes mentioned above...also
these housemates had chased me with a ten inch butcher knife, two of my tires were slashed, I was
locked out all night on New Years Even when these changed the locks at around midnight, had my
furniture thrown in the street, property stolen, coffee thrown on me, destroying my smart phone in
the process, etc., etc...And despite the housemate having an outstanding arrest warrant, and animal
abuse being listed amongst the elements of domestic violence, Sargent Sigfree told me he was
arresting me because I "keep putting yourself in these situations", like, where I am a victim, and that
he was "trying to help you", he said with a smirk and a laugh to his fellow RPD Officers, whom then
proceeded to use excessive force against me. I guess he was helping me by saddling me with a gross
misdemeanor with a $1,500 bail, especially where its been arranged for Court Services, or pre-Trial
Services to forever deny me an OR, despite my meeting the factors for such set forth in statute (30
year resident, entire immediate family lives here, licensed to practice law in Nevada, etc., etc)...I
guess it should not be too much of a surprise to me that Reno City Attorney Pam Roberts failed to
address the perjury of all three of her witnesses or that her fellow Reno City Attorney Christopher
Hazlett-Stevens lied to me about whether or not the Reno City Attorney's Office even had any
documentation related to my arrest or whether it would in the month before my arraignment,
despite that fact that subsequent productions of discovery tend to indicate that the Reno City
Attorney's Office did have those materials at the time. I could be wrong about some of this...But that
would require and awful lot of coincidences.

Sincerely,

Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473

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From: PatrickK@nvbar.org
Subject: Contact
Date: Fri, 16 Mar 2012 16:10:24 +0000

March 16, 2012

Zachary Coughlin

Dear Zach,

Thank you for sending me your reply to the grievance filed by Richard Hill. From your
explanation it is clear that things are not as they should be. Please call me ASAP so
that we can take the appropriate action to help you and to stop these types of
disturbing complaints.

Patrick King, Assistant Bar Counsel (775) 328-1384
RE: more on the way
RE: Gessin ghostwriting issue

Sent: Fri 3/16/12 3:15 PM
Dear Zach,

I would appreciate it if you would simply call me.

Patrick King, Assistant Bar Counsel 775-328-1384

To: Patrick King; David Clark; Glenn Machado
Subject: more on the way

No: 9473
Sent: Mon 3/19/12 9:28 AM
Cc: David Clark (DavidC@nvbar.org)
Goof Morning Mr. Coughlin,

Yes, I did suggest some urgency in having a meeting with you. I would like to have an opportunity to sit down and talk
with you. Please let me know if you are agreeable to meet with me on an informal basis so we can talk about the process
that has been initiated.

Patrick King, Assistant Bar Counsel (775) 328-1384.

Sent: Monday, March 19, 2012 3:25 AM
To: Patrick King
Subject: Gessin ghostwriting issue

Dear Mr. King,
I do not understand. I provided you a ton of information and documentation in my Response to Hill's grievance, and, after
emailing me six hours prior to the deadline to do so saying you already received my Response (which you had not, and which I
had informed you that you had not but would be recieving it), you know call and or write me less than a day after receiving my
voluminous Response and want to meet urgently. This sends a strong message that you did not put much time into analyzing
my response, which would tend to indicate such a meeting would lack traditional due process protections, would it not? I
have already been attacked by a Character and Fitness Committee member while he owned the Spearmint Rhino strip club in
Las Vegas, and where the Committee promised to get me the names of "three attorneys who will handle your case on a pro se
basis" but where only one name was provided, and that name wound up being and attorney would extracted soem
approximately $7,000 i his fees and the fees of a gambling addiction specialist (both of whom admitted to being extremely close
personal friends of Character and Fitness Committee member Kevin Kelly, Esq. who then owned the Spearmint Rhino strip club.
Next, Christiansen and Sanft bungled several deadlines and client confidences related to extremely sensitive information,
whereupon, finally, Director of Admissions Eichman made the unilateral decision to refrain from submitting my case for review,
despite her receipt of my Request for Reconsideration. Finally, Christiansen's legal assistant Kelly Huff wrote me explaing that I
had failed to provide their office with the Request for Reconsideration that I sent it on 9/15/03, despite my having fax
confirmation proof of this and despite a subsequent copy of the file provided by Christiansen's office proving they had recieved
such a Request, and that is was received by them on 9/15/03. I do not mean to be standoffish, Mr. King, but it is what it is.
How Ms. Eichman's rationale for her action is different than what any attorney might say upon blowing some deadline or
otherwise having a client's file fall behind a filing cabinet for a couple years, is really not at all clear to me.
As to my official address with the State Bar and receiving my mail, the USPS is likely going to be sued for the handling of my
mail, should it become clear that any client matters where prejudiced in light of what has been deplorable conduct by the
station involved.
Further, as to Hill's Motion for Order To Show Cause, please see the attached copy of Hill's application for an Order of
Protection, then compare it to Hill's other filings wherein he suddenly backs off his assertion that I was "climbing on the
contractor's truck". Hill lied when he wrote that. I did not climb on anybody's truck. Hill merely did not want me to film all that
he was throwing away, especially given that he was throwing away unique items that had both monetary and sentimental value
and because he had no good reason for refusing to allow me to take those items other than spite and an attempt to get me to
sign away my security deposit, which Hill still has not returned. Further, Hill is not licensed under the FDCPA as a debt collector
yet attempts to so practice, as such, this grievance should focus on that as well. Hill needs to answer for his lies about me
allegedly "making contact" with him, about me allegedly "climbining on the contractors truck", about his abusing the TPO
process to gain advantage in a litigation (ie, to prevent evidence collection and discovery), about his abuse of process in
seeking to get me arrested and signing a criminal complaint where service of the evictio order was insufficient, and regardless,
Hill had vitiated its import anyway by billing me for the same amount as the "full use and occupancy" (and I have a video of
Hilll admitting to this and his firms 11/10/11 letter admits to that as well. Further, as for his Motion for Order to Show Cause,
as it relates to an alleged contempt on my part in failing to abide by the 1/11/12 Order from in CV11-03628, well, NRCP 6(e)
requires that 3 days for mailing be accorded even for electronic filings. As such, any activity on my part of 1/12/12 clearly is
irrelevant as service was not effectuated at that point and there is not allegation that any "personal service" was undertaken.
That being the case, here is another basis for grievance against Hill, especially his continually filing documents not based in fact
or law, as here.
Some more regarding Hill's grievance. Hill clearly attempts to mislead when he suggest that the Supplemental I filed in the
Carpentier's foreclosure defense matter was incorrectly filed there. Clearly, I intended to file it there and the attached email I
sent to Hill explains clearly why I copied him on it (because I foresaw Hill filign a Bar grievance for "ex parte communications"
based upon some idea that arguments made in one case that bare some connection to another case would be a basis for Hill
crying foul, and, as seen in Hill's "ghostwriting" grieviance, its a very low standard for crying foul that Richard has, which is
typical of all the most feckless attorneys. That email indicated to Hill and his staff:
One, I would like to reserve my objection to "Good Samiritan" Richard G. Hill purporting to file grievances on behalf of the
public in general or Mr. Gessin, or whoever it is Richard is doing this for. I suspect Richard is doing this for the same reason he
does so many other things: to keep opposing counsel busy with responding to all spineless paper pushing that Richard G. Hill is
so very well known for throughout Northern Nevada legal circles. Nonetheless, important issues are brought up in Mr. Hill's
grievance. To a great extent, I foresaw these issues long ago and attempted to address them appropriately. I often get clients
who are on their third or fourth attorney. Mr. Gessin was one such client. By that time they all want to sue their former
attorneys, and feel quite burned by the fees they have paid. Mr. Gessin was a good example of this and he wished to proceed
on an unbundled services arrangement, or a flat fee per motion/opposition/pleading basis, etc. From the very, very long time
that went by between my passing the J uly 2001 Nevada Bar Examination and being admitted to practice in March of 2005, the
issue of the legality of ghostwriting for pro se litigants was something I was somewhat aware of, but I don't believe I ever did.
I am somewhat disappointed that I was not industrious enough to get anywhere close to doing such a thing but mostly I was
just so demoralized by not having a license and from the rape that the character and fitness committee and Kelly, and
Christiansen and Eichman et al committed upon me that I mostly just worked for Thomas J . Hall, Esq. for about $0.89 per hour
(just kidding, I love Tom) doing legal research in the Washoe County Law Library while the librarians glared at me and let me
know how very disappointed they were that I, or any member of the public, really, had interrupted their solitude.
So now it seems there is a tough situation where, on one hand, as a now licensed attorney, there is some taboo to
"ghostwriting" (necessitating such lucrative activities as responding to grievances filed by opposing counsel like Richard G. Hill,
Esq.....and I sure hope you will countenance the grievances I am filing against Hill, Christiansen, Sanft, Kevin Kelly, Eichman,
etc, with the same seriousness that your are taking Richard G. Hills. I notice Richard G. Hill, Esq. has a funny way of being
able to get the police (and some others that I probably shouldn't mention) to take his complaints just a little bit more seriously
than they take others. I would also like to file a grievance against all three of the public defenders I have been appointed in
the trespass case in Reno Municipal Court for 11 CR 26405, Lew Taitel, Roberto Puentes, and Keith Loomis. Each have
thoroughly failed to zealously advocate on my behalf, with Loomis calling my arguments vis a vis the procedural requirements
for serving eviction orders in thoroughly contested summary eviction proceedings "frivolous" despite being provided the
attached 22 page memorandum detailing those arguments and despite the procedures requiring as much set forth in the Anvui
decision of the Nevada Supreme Court. I would also like to file a greivance against Deputy Reno City Attorney Ormaas for her
blase indication that she cared not about any admission of bribery on the part of Reno Police Officer Chris Carter, and that she
would not be following up on that, even where it bared some relation to the citation in 11 TR 26800 issued by Sargent Tarter,
for which I cross examined Sargent Tarter as to whether he did so in retaliation for my reporting Officer Carters admission of
accepting bribes from Richard G. Hill. Instead, I believe Deputy City Attorney Ormaas and City of Reno Marshal Hiney (the
spelling might be a bit off) conspired to have J udge Nash Holmes have me arrested for summary contempt in Order to obtain
my cell phones, which upon information and belief, Ormaas and Hiney believe might contain "evidence" of misconduct on both
of their parts. Hiney attempted to serve me Notice of Hearing on Motion for Order to Show Cause in the appeal of the Richard
G. Hill, Esq. eviction matter (one of three instances of "triple jeopardy" Hill has me facing here....this Bar grievance, the criminal
complaint in 11 CR 26405, and, actually, multiple Orders to Show Cause (one in the Trial Court in RJ C Rev201--001708 and
one in the associated Appeal in CV11-03628). However, the actual Affidavit of Service that the WCSO filed for the Notice of
Hearing Marshal Hiney attempted to serve me (please inquire with Chief Marshal Roper, perhaps?) was actually signed by the
same WCSO Deputy Machem that swore, under oath, in his 11/7/11 Affidavit of Service in the eviction case RJ C REv2011--
001708 that he "personally served" the Order of Summary Eviction. The attached 22 page memorandum sent to various
individuals and the admission of WCSO Civil Section Supervisor Liz Stuchell that, in their mind, "personally served" can mean a
lot of things that it has never meant in any legal settings, is provided for background. I also wish this to begin a grievance
against Deputy Reno City Attorney Pam Roberts for what I believe may be several violations on her part of the rules relative to
prosecutorial misconduct, especially those involving suborning perjury, including that of Officer Kameron Crawfor saying in 11
CR 22176, that I did not provide him my drivers license, and therefor issuing me a citation would not be an option, but rather,
my failure to provide my driver's license buttressed his proable cause finding justifying a search incident to arrest. However,
Roberts, in 11 CR 22176 and later on appeal in CR11-2064, had in her possession Wal-Mart AP video from the interrogation
room clearly showing me providing Officer Kameron Crawford my driver's license and other evidence supports a finding that he
had it (including dispatch reports and the information culled by Officer Kameron from the driver's license and placed on the
arrest report, which Officer Crawford later lied about, saying he got that information at the WCSO, which is clearly contrary to
established protocol and privacy policies). One more grievance against Reno City Attorney Christopher Hazlett-Stevens for
lying to me on the phone about whether the City of Reno had the arrest report from the September 9, 2011 arrest at Wal-mart
from the Reno Sparks Indian Colony in 11 CR 22176. I wish for all of these grievances to go forward now, but I may provide
supplementary materials in support thereof later. Additionally, she has the "purchased receipt" that showed it had the very UPC
number that both Frontino and Crawford swore under oath that it did not.
Barrie Althoff, Limiting the Scope of Your Representation: When Your Client Wants, or Can Afford, Only Part of You, Washington
State Bar News (J un. 1997).
Anthony P. Capozzi, Responding to the Pro Per Crisis, California Bar J ournal (Feb 2004).
Alicia M. Farley, An Important Piece of the Bundle: How Limited Appearances Can Provide an Ethically Sound Way to Increase
Access to J ustice for Pro Se Litigants, The Georgetown J ournal of Legal Ethics, Vol. 20, No. 3 (Summer 2007).
Kim Prochnau, Slicing the Onion: Rules of Professional Conduct and Court Rules Make It Easier for Private and Non-Profit Legal
Practitioners to Provide "Unbundled" Legal Services, Washington State Bar News (Apr. 2003).
Bradley A. Vauter, Unbundling: Filling the Gap, Michigan Bar J ournal, Vol. 79, at 1688 (2000).
Books and Reports
Caught in the Middle: 2003 Report and Recommendations of the North Carolina Bar Association Pro Se Task Force (Dec. 2003).
Challenge to J ustice: A Report on Self-Represented Litigants in the New Hampshire Courts, New Hampshire Supreme Court
Task Force on Self-Representation (J an. 2004).
Ethics Issues Regarding the Concept of Unbundled Legal Services (Memorandum), Rob Bare, Nevada State Bar (Mar. 31, 1999).
Family Law Limited Representation Risk Management Materials, Limited Representation Committee, California Commission on
Access to J ustice (J anuary 12, 2004).
Handbook on Limited Scope Legal Assistance, ABA Section of Litigation (2003).
Pro Se Litigants: The Challenge of the Future, Massachusetts Probate and Family Court Department Pro Se Committee Report
(Dec. 1999).
Report and Recommendations on "Unbundled" Legal Services, Commission on Providing Access to Legal Services for Middle
Income Consumers, New York State Bar Association (Dec. 2002).
Report of the Unbundled Legal Services Special Committee II , Florida Bar Association (J ul. 26, 2002).
Report on Limited Scope Legal Assistance with Initial Recommendations, Limited Representation Committee of the California
Commission on Access to J ustice (Oct. 2001). Appendix
Self Represented Litigants in the Virginia Court System, Supreme Court of Virginia Pro Se Litigation Planning Committee,
Enhancing Access to J ustice Report (Sept. 2002).
Unbundling Legal Services: A Guide to Delivering Legal Services a la Carte, Forrest S. Mosten, American Bar Association (2000).
Cases
Melvin Finance, Inc. v. Artis, 157 N.C. App. 716, 2003 WL 21153426 (N.C.App.)
Defendant retained an attorney on a limited basis, following an action filed by the plaintiff to recover costs on a defaulted loan.
Limited representation attorney agreed to file responsive pleadings and negotiate a settlement agreement, and filed a notice of
limited appearance. While the defendant received notice of a scheduled hearing and forwarded it to his limited representation
attorney, neither defendant nor attorney appeared at the hearing and, consequently, an arbitration award was entered for the
plaintiff. Defendant filed a motion to set aside judgment, which was denied. On appeal, the defendant claimed the limited
representation attorneys failure to appear at the hearing amounted to excusable neglect and that the judgment should be set
aside. The court found that since the defendant received notice of the hearing and had retained the attorney on a limited basis,
that the limited representation attorneys conduct did not constitute excusable neglect. The lower court decision was affirmed.
J ohnson v. Board of County Comm'rs, 868 F.Supp. 1226 (D. Colo. 1994)
Former sheriff department workers bring sexual harassment suit against county sheriff in his individual and official capacities.
Attorney representing sheriff enters limited appearance on behalf of his official capacity. Court finds that attorney cannot enter
limited appearance on behalf of sheriff's official capacity. Attorney representing sheriff must act for the entire person, including
individual and official capacities. Entering such limited appearance is not competent and zealous representation as required by
ethical rules as it leaves officer undefended on individual capacity claims. Court further finds that ghostwriting of documents for
pro se litigants may subject lawyers to contempt of court. Ghostwriting gives litigants unfair advantage in that pro se pleadings
are construed liberally and pro se litigants are granted greater latitude in hearings and trials. Ghostwriting also results in
evasion of obligations imposed on attorneys by statute, code, and rule, and involves lawyers in litigants' misrepresentation of
pro se status in violation of ethical rules.
Ricotta v. California, 4 F.Supp.2d 961 (S.D. Cal. 1998)
Attorney licensed in the State of California did not violate procedural, substantive, and professional rules of a federal court by
lending some assistance to friends, family members, and others with whom she shared specialized knowledge. Attorney
performed research and prepared rough drafts of portions of pro se litigant's pleadings in an action against various official
defendants, but did not sign the documents. Because attorney did not gather and anonymously present legal arguments with
the actual or constructive knowledge that plaintiff would use them in court, and because attorney did not engage in extensive,
undisclosed participation that permitted plaintiff to falsely appear as being without professional assistance, attorney had not
violated any rules.
Sharp v. Sharp, 2006 WL 3088067 (Va.Cir.Court)
Complainant and respondent were co-tenants of real estate property. The respondent appeared pro se during a hearing before
the commissioner in chancery, but then hired an attorney who appeared in a limited capacity at several other hearings. On
appeal, the court sought to determine whether or not the attorney could appear in a limited capacity and whether the
attorneys appearance qualified him as official "attorney of record". The court found that it was not bound by agreements
made between client and attorney and that a court may "require more of an attorney than mere compliance with the ethical
constraints of the Rules of Professional Conduct". The court found that the attorney could make a motion to withdraw once he
completed the tasks agreed upon, but that the court had ultimate discretion in granting the withdrawal.
Streit v. Covington & Crowe, 82 Cal.App. 4th 441 (2000)
In a lawsuit, plaintiffs counsel of record requested that another firm make a "special appearance" at a summary judgment
motion, appearing on behalf of counsel of record. Plaintiff filed a legal malpractice suit after a summary judgment was entered
against her, arguing that the special appearance created an attorney-client relationship. The appellate court found that an
attorney making a special appearance represents the clients interests and has a professional attorney-client relationship with
the client. Further, the voluntary appearance created a limited representation status and not a true "special appearance".
Court Rules
Alaska
Alaska Rule of Civil Procedure 81, expressly permits limited appearances and governs attorney withdrawal.
Arizona
Arizona Rules of Family Law Procedure 9(B), governs limited representation and attorney withdrawal in family law proceedings.
Arizona Rules of Civil Procedure 5.2, governs limited representation and attorney withdrawal in vulnerable adult exploitation
actions. California
California Family and J uvenile Rules 5.71, governs application to be relieved as counsel.
California Civil Rule 3.36, governs notice and application to be relieved as attorney.
Colorado
Colorado Rule of County Court 311(b), requires lawyers to disclose assistance in document preparation but clarifies that such
disclosure does not create an entry of appearance.
Delaware
Delaware Family Court Rule of Civil Procedure 5(b)(2), governs limited appearance, service and attorney withdrawal in family
law matters.
Florida
Florida Family Law Rules of Procedure, Rule 12.040, governs Limited Appearance, Withdrawal or Limiting Appearance, Scope of
Representation, Preparation of Pleadings or Other Documents, Notice of Limited Appearance, and Service.
Florida Family Law Rules of Procedure 12.750, governs the operation of self-help programs within family courts.
Iowa
Iowa Rules of Civil Procedure enabling unbundled services include:
RCP 1.404(3), expressly permitting limited appearances so long as the court is notified;
RCP 1.404(4), governing termination of limited appearance;
RCP 1.423, requiring lawyers who prepare pleadings in limited representation to sign them and clarifying that signing a
pleading does not constitute an appearance;
RCP 1.442(2), establishing the requirements for service on attorney who has made a limited appearance.
Maine
Maine Rule of Professional Conduct 1.2(c), explicitly allows limited representation and allows a lawyer to file a limited
appearance if the client consents in writing.
Maine Rule of Civil Procedure 11 governs limited appearances.
Missouri
Missouri Rules of Professional Conduct 1.16 (c), governs attorney withdrawal for limited representation.
Missouri Rules of Civil Procedure 55.03, permits a lawyer to draft pleadings without disclosure and clarifies appearance and
withdrawal of attorney in limited representation.
Nebraska
Nebraska RPC 501.2, governs limited representation, attorney assisted document preparation and attorney withdrawal.
Nevada
Rules of Practice of the Eighth J udicial District Court of the State of Nevada, Rule 5.28 requires signed pleadings, notice of the
limited representation to the court and governs the procedure for withdrawal.
New Hampshire
New Hampshire Rules of Civil Procedure enabling unbundled services include:
RCP 3, requiring that pleadings and communication be furnished to both client and limited representation attorney until
withdrawal of limited appearance;
RCP 17, governing appearance, attorney withdrawal and document preparation assistance.
New Mexico
New Mexico Rules of Professional Conduct 16-303(E), requires lawyer to disclose scope of representation to court.
Utah
Utah Rules of Civil Procedure 74(b), governs attorney withdrawal following limited appearance.
Utah Rules of Civil Procedure 75, expressly permits limited appearances after client consents in writing.
Vermont
Vermont Rules of Civil Procedure 79.1(1), governs appearance, withdrawal and service.
Vermont Rule of Family Procedure 15(h) governs limited appearances, withdrawal and service in family law matters.
Washington
Washington Civil Rule 4.2, expressly permits a limited entry of appearance.
Washington Civil Rule of Limited J urisdiction 4.2, governs limited appearances.
Washington Civil Rule 11, permits a lawyer who assists with drafting to rely on the self-represented party's representation of
facts.
Washington Civil Rule of Limited J urisdiction 11, permits a lawyer who assists with drafting to rely on the self-represented
party's representation of facts.
Washington Civil Rule 70.1, expressly allows limited appearances in litigation.
Washington Civil Rule of Limited J urisdiction 70.1, expressly allowing limited appearances in litigation.
Wisconsin
Milwaukee County Family Division Rule 5.6 expressly permits limited appearances.
Wyoming
The Uniform Rules of the District Court of the State of Wyoming, Rule 102 governs appearance and withdrawal for unbundled
representation.
Ethics Opinions
Los Angeles Cnty Bar Ass'n Prof. Resp. and Ethics Comm. Ethics Op. 483
An attorney may limit the attorney's services by agreement with a pro per litigant to consultation on procedures and
preparation of pleadings to be filed by the client pro per. A litigant may be either self-represented or represented by counsel,
but not both at once, unless approved by the court. In order for attorney to specially appear on behalf of the litigant before the
court for a limited purpose, the attorney should comply with all applicable court rules and procedures of the particular tribunal.
Delaware State Bar Assn Op 2006-1
A lawyer may be required to perform beyond the term of a limited scope representation agreement if the Court requested, or
the Clients circumstance warranted such action. In most circumstances, an agreement to withdraw from representation would
not violate any ethics requirement, as long as the lawyer provides adequate advice to Client concerning the scope of
representation. In family court, the Courts permission may be needed to withdraw from simple divorce petitions in certain
circumstances.
D.C. Bar Op. 330 (2005)
Unbundling of legal services is permissible under D.C. Rule 1.2 ( c ), provided the client is fully informed of the limits on the
scope of the representation and these limits do not prevent the provision of competent service. If a party is proceeding pro se,
opposing counsel should treat that party as unrepresented unless and until that counsel receives reasonable notice of
representation from the party or her lawyer.
Illinois State Bar Ass'n Prof. Conduct Comm. Op. 849 (1983; Affirmed 1991)
An attorney may agree in advance with his or her client to limit the scope of the attorney's representation and draft pleadings
without appearing or taking any part in any of the proceeding itself, provided that the client gives his or her fully informed
consent to such limitation of employment and the attorney takes whatever steps may be necessary to avoid foreseeable
prejudice to the client's rights.
Maine State Bar Ethics Opinion No. 89 (1988)
A lawyer is not required to sign a complaint or enter an appearance as counsel of record when representation is solely limited
to preparation of the complaint.
Missouri Bar Ass'n Advisory Op. 940161
It is impermissible for a lawyer to draft responsive pleadings to an unrepresented opposing party in a divorce. However, a
lawyer may draft an entry of appearance if the lawyer includes a letter indicated that he or she represents the opposing party
and that the unrepresented party should obtain counsel.
New York State Bar Ass'n Op. 613 (1990)
A lawyer who does not appear as counsel of record for a pro se litigant may prepare responsive pleadings and demands for
financial disclosure, provided the lawyer investigates the matter adequately.
North Carolina State Bar RPC 114 (1991)
Legal services attorneys may provide legal advice and drafting assistance to pro se litigants without appearing as counsel of
record. If court approved pleading forms exist, attorneys may make them available to individuals wishing to proceed pro se.
Bd. of Prof. Resp. of the Sup. Ct. of Tenn. Op. 2005-F-151
Attorneys may offer limited representation through a pro se clinic if they obtain clients consent, preferably in writing.
Attorneys may draft proceedings for clients, if the attorney notifies the Court that counsel has assisted a pro se litigant. The
phrase "Prepared with Assistance of Counsel" is recommended for inclusion on such pleadings in a prominent manner.
Attorneys who draft proceedings need not appear and represent the client.
Utah State Bar Ethics Advisory Op. Comm. Op. 08-01 (2008)
A lawyer may provide legal assistance to litigants appearing before tribunals pro se and help them prepare written submissions
without disclosing or ensuring the disclosure to others of the nature or extent of such assistance. Undertaking to provide limited
legal help does not generally alter any other aspect of the attorneys professional responsibilities to the client.
As to the ghostwriting, its tough, because, for clients who want to pay very little (after, say, in Gessin's case he paid McKenna
allegedly $15K to wind up with an Order from an Arbitrator and District Court J udge denying a Trial De Novo based upon a bad
faith failure to participate in litigation in one case, then in the other, Gessin paid Hill something like $20K only to be slammed
car crash style into settlement by Hill's advice when Gessin couldn't stomach paying anymore of HIll's fees, settling for the
amount originally sought by Mr. Hall's client). So, clients like that want a deal, want to pay piece meal or go the unbundled
route, but filing all those Motions to Withdraw, and Proposed Orders, and Affidavits, add to the costs where the fee is not really
being increased any. There is much literature dealing with this:

Please accept this as a supplement to the grievance filed by Richard Hill, Esq. My recollection of my involvement with Gessin is
that I filed two Answers to very similar Adversary Complaints in NVB and two Motions to Dismiss in those same cases, involving
the two women represented by Glade Hall, Esq., both on an "unbundled services" basis, and the pleadings themselves indicated
the were filed as an "unbundled service". This was my first filign in NVB, and I was not registered or trained as an electronic
filer at that point. Further, Gessin hired me to provide other unbundled services, inlcuding writing (and, to my understanding
at the time, filing under my own signature) something in the vein of a NRCP Rule 60(b) Motion for Relief from J udgment from
judgments in cases involving the same two women Taitano ne Moore, and Rissone, both, again, represented by Glade Hall,
Esq.

It may be the case that Richard Hill is correct that I was goign against some rule or law by sending one demand letter to Glade
Hall concerning an outstanding $500 sanction aware. I believe I drafted an Order To Show Cause for this, but am not sure it
was filed by me. About the time I provided Gessin my signed final draft of that and a few other closely related motions, he
pretty much wanted to part ways, I believe. I think this was around mid-November and there was some issues with Richard
HIll withholding my client files, some of which may have included Gessin's, then Hill would say he would give me my client files
without any demands or lien needing satisfying prior to doing so, and that he would do the same with my wallet and
identification, but then he would change his mind and demand what to me seems that I satisfy a rent distraint that has been
outlawed by NRS 118A.520 (though there is a very old BK case, circa 1980 or so that may suggest such distraints are still
permissible against commercial tenants, and my hybrid, home law office situation, plus the fact that I do still have a business
license for Zachary Coughlin's Memory Foam Mattresses (something I started during the 4 years I was hoping to get a law
license and finding employment very, very difficult to obtain, during which Mike Rowe wrote me stern letters, Pete Christiansen
and Mike Sanft -ignored me and shewed me to their legal assistant Kelly Huff, and Director of Admissions Patrice Eichmann
made the unilateral decision to ignore the Request for Reconsideration of my Application for Admission that I timely submitted
on 9 15 03 in connection with the end of the deferment period set forth in the Court's December 2002 Order....) and at least
some research and development was ongoing in that regard. Whether I was a commercial or residential tenant was an
important issue in the eviction matter and the mixed use of the property likely only made the statute all the more difficult to
interpret.

However, I do recall that Gessin told me he withdrew his bankruptcy, so that may negate Hill's assertion that I was wrongful in
sending a demand letter to Hall regarding the old sanction and or filing a Motion for Order To Show Cause. Gessin is a crafty
guy, though I am not sure I entirely share Hill's view of him. However, Hill apparently received about $20-25K in attorney's
fees from Gessin in a case that the plaintiff was only seeking about $25K in to begin with, and upon Gessin ceasing to be
willing to pay Hill and Baker for more litigating, they promptly suggested he settle for something near $30K (which, of course,
was upsetting to Gessin, in a manner that is similar to how Dr. Merliss seems to feel in the eviction matter). But, to be fair to
Hill, those parties likely bare some responsibility for choosing to take the risky path that is litigation.

Gessin also became a registered efiler about the time he basically terminated my representation of him. My email to Gessin
below shows that I was somewhat suspicious of the fact that he seemed to all the sudden want to go our separate ways after I
had been working on these very involved (to me at the time they seemed really involved) NRCP 60(b) Motions, and it is ironic,
somewhat that Hill accuses me of ghostwriting because my email to Gessin essentially anticipates that, and, to some extent, my
later filing Notices of Appearance as Attorney of Record in several of Gessin's various cases involving these two women was
done to attempt to counteract any appearance of that. Gessin seemed upset that I filed those appearances, and actually got
very pushy about me trying to undo them, and eager to avoid prejudicing his ability to file timely 60(b) motions, I undertook to
do what I could to make it so he could file on his own (ie, having an Attorney of Record on one's case often results in the filing
office refusing to let them file anything on their own...).

On Wed, Dec 7, 2011 I wrote to J ohn Gessin's email address the following:

"To: J ohn Gessin <jd.gman@yahoo.com>
John,
Here is Van Lydegraf's voice message. Again, I have not talked to him and I forwarded you the only email or writing I ever sent him. I
am leaning towards filing an Errata on your cases today to get it so I am not attorney of record. Which do you prefer? I am not sure
which would accomplish your goals quicker, but keep in mind, I believe a Motion to Withdraw is the typical thing, not a Notice of
Withdrawal? Have you found any research in this regard? Please indicate in writing which you prefer or the preferred manner you
would like to see me pursue accomplishing your goals, which, to my understanding, include being in pro per on this case. I sense you
are uncomfortable, but please know I maintain extremely high fidelity to my clients, unbundled or otherwise, okay? I am unsure how
RE: hello from Zach Coughlin
me filing the 60b's etc would have been much different with respect to what you seem upset about...did you never intend for me to
file? Were you looking for a "ghost writer"? I was not of the understanding that I was being hired as a "ghostwriter" and I do recall
some indication that such a thing is either prohibited or discouraged by the Rules of Professional Responsibility....Regardless, the most
important thing is to avoid prejudicing your case, and I feel I have made great efforts to achieve that. If you want to file something,
just do it, don't wait for any withdrawal, etc. I will make all reasonable efforts to see that you are allowed to file whenever and
whatever you want, and not be weighed down by any attorney of record designation.
Sincerely,"
I currently have a Motion to Withdraw pending in the two Adversary Proceedings where I believe I was incorrectly listed as Attorney
of Record for Gessin.
No: 9473
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Wed 3/21/12 11:35 AM
Dear Mr. Coughlin,

The allegations against you are serious and put into question your competence to practice law. I would like to meet with
you so that I can talk with you about the allegations and see if there is a way
to assist you.

If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of
actually getting to sit down and talk with you.

Patrick King, Assistant Bar Counsel.

Sent: Wednesday, March 21, 2012 8:31 AM
To: Patrick King
Subject: hello from Zach Coughlin
RE: hello from Zach Coughlin

Dear Mr. King,

The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can
check voice mail by email, such as:

"Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some
emails. I would like to hear from you, so we can talk on the phone if you could please call me at
(775) 328-1384 Thanks a lot. Bye. "

Until then, could we communicate in writing please. I provided you a great deal of material in
response to Hill's grievance, and I feel that should take you more than one hour to appropriately
review, so....

Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition,
though I don't really know what in the hell that matters or why Richard Hill is able to leverage your
office to make busy work for me by making completely unsupported "ghostwriting" accusations,
etc., etc.

Sincerely,

No: 9473
Sent: Thu 3/22/12 10:50 AM
Good Morning Mr. Coughlin,

I sorry to hear that you are having to deal with some extremely tough circumstances. Please come see me as soon as you
can.

Sincerely,

Patrick King

Sent: Thursday, March 22, 2012 2:31 AM
To: Patrick King
Subject: RE: hello from Zach Coughlin

Dear Mr. King,

I appreciate the seriousness of the process and want to show it the respectd it deserves. I take what
I do very, very seriously. If you can give me some time, it would help. Due to the recent eviction
(and that is an area of law where I am doing important work that often goes neglected...the societal
cost to Nevadans subject to this ultra fast summary evictions, on top of the procedurally
questionable manner in which they are carried out and served, is immense...sure it might help pay
some RPD Sargents more than District Court Judges, but its done on the backs of real human beings
suffering, etc....).

I had a hearing today where I represented a client in a UIFSA matter. He needs me. My
representation is very important to his life. He is a committed father who has been dealt some
extremely tough circumstances. I think I have only received something like $500 from this client so
far, and have done enough work to make that less than minimum wage, etc..

I do want to meet with you. It would be most prudent though, for my clients and myself, if you and
the State Bar could afford me some time to tend to the immediate need to get a new living space
and office, attend and defend the "quadruple jeopardy" abuse of process that Richard Hill is
orchestrating, and otherwise protect my client's interests. I am not refusing to speak with you on
the phone or meet in person. My two phones are still being held by the Washoe County jail, under
an Order by RMC Judge Nash Holmes, so....The USPS Golden Valley Station has retaliated against me
by interferring with my mail, though I have taken all reasonable steps to counter that, including
securing a new PO BOX, which I added as my public address on the Bar's online portal days ago, but
for which I still do not see a change reflected. The Federal Torts Claims act has likely been violated
by USPS Golden Valley Station supervisors Terry James and Buck Hyde, whom took it upon
themselves to play judge and jury incident to a complicated eviction process that I have recently
been litigating against Park Terrace Townhomes HOA and Western Nevada Management and Gayle
Kern, LTD. It involves respondeat superior liability, etc., etc. Western Nevada Management knew of
and orchestrated, and received approval from the Park Terrace HOA to have the two individuals who
I rented from live at the 1422 E. 9th St. 89512 location. This involved a Robyn Badalato, then a
property manager at Park Terrace. For some reason, when her boss found out about this, she
started crying, saying she was going to be fired, etc., etc.. Then she apparently resigned. This was
litigated in an interruption of essential services (electricity) complaint I filed recently. The HOA and
Sue King admitted these things, yet they want to turn right around and disclaim an responsibility for
anything, pursue a summary eviction despite the facts not lining up with the Glazier case sufficient to
allow such, etc., etc.

I can sit down and talk with you whenever you want. However, I am writing to explain why this
week or the immediate future would prevent a hardship for me with regard to scheduling such a
meeting. Please no that is not a reflection upon my respect for you, the State Bar, your office, or
this process, but rather indicative of the realities faced by businesses subject to summary evictions
where the non payment of rent is NOT alleged, something which the law is supposed to forbid under
NRS 40.253, but for which the Reno Justice Court has now subjected me to TWICE in three or four
months....

I hope you can understand though, that deadlines are running, Richard Hill has me facing quadruple
jeopardy via his abuse of processes, etc. I have a hearing on that this week. But I am not some
young punk who is going to come in and let Jon Bailey blow a lot of intimidation and hot air at him
for his millionaire buddy Mark Tratos (whom had to admit under oath, that he had previously "lost"
other student's papers in his illustrious career as an adjunct professor. And that was also confirmed
by Anderson and Morishita, two former patent attorney associates for Mr. Tratos. Also, Mr. Tratos
lost or "failed to receive" Jessica Wolf's paper in that 2002 Cyber Law course, but I don't recall the
State Bar of Nevada raping her. Further, Tratos wrote me asking for "another copy of your paper",
which implies he received one. Then he went on to ask for detail about the paper, what it was
about etc., clearly implying he did have possession of the one I turned in with only my "blind
grading" social security number, etc. (he had a student in the class who worked for his firm,
he probably interpreted my adherence to the "blind grading" setup that was utilized in every other
course I took at Boyd as a personal affront, etc....To me it is disturbing that the State Bar of Nevada
had allowed Mark Tratos to so leverage the resources of the State Bar to wreck shop on my life,
while, apparently, no real inquiry has ever been made as to whether Tratos did so inappropriately.
He was "on vacation in Europe" according to my "pro bono" attorney Pete Christiansen (and so did
not appear at the June 2002 conclusion of the hearing before the C&F Committtee, whom was
referred by Character and Fitness Committee member Kevin Kelly, whom owns the strip club, The
Spearmint Rhino, or did at the time. I believe in Senator Grassley's "sunshine and transparency" in
government, and in this grievance process too.

Sincerely,

No: 9473

Subject: RE: hello from Zach Coughlin
Date: Wed, 21 Mar 2012 18:36:13 +0000
Dear Mr. Coughlin,

The allegations against you are serious and put into question your competence to practice law. I would like to meet with you so that I can
talk with you about the allegations and see if there is a way
to assist you.

If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of actually getting to sit
down and talk with you.


Sent: Wednesday, March 21, 2012 8:31 AM
To: Patrick King
Subject: hello from Zach Coughlin

Dear Mr. King,

The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can
check voice mail by email, such as:

"Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been
RE: does Richard Hill have standing to file a grievance
sharing some emails. I would like to hear from you, so we can talk on the phone if you
could please call me at (775) 328-1384 Thanks a lot. Bye. "

Until then, could we communicate in writing please. I provided you a great deal of material
in response to Hill's grievance, and I feel that should take you more than one hour to
appropriately review, so....

Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to
Opposition, though I don't really know what in the hell that matters or why Richard Hill is
able to leverage your office to make busy work for me by making completely unsupported
"ghostwriting" accusations, etc., etc.

Sincerely,

Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
Sent: Fri 3/23/12 10:17 AM
Dear Mr. Coughlin,

I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal research.

You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a
grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I have explained to
you, the grievances against you came not only from Mr. Hill but also from Judges from different Courts. These grievances,
and the evidence attached with them, rather clearly puts into question your competence to practice law. As I have
explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I
will not send you reports or document, especially since you claim your mail is being compromised.

As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters. As
such, at this time we have not opened any files based on the information you have submitted.

Sincerely,

Patrick King

Sent: Friday, March 23, 2012 9:12 AM
To: Patrick King; cdbaker@richardhillaw.com
Subject: does Richard Hill have standing to file a grievance

American Jurisprudence Trials
Database updated April 2011
Defending Lawyers in Disciplinary Proceedings
31 Am. Jur. Trials 633 (Originally published in 1984)
III Attorney-Client Grievances
10 In general
11 Sources of complaints and grievances; checklist
12 Former criminal clients
13 Particular problem clients
14 Fee disputes; checklist of factors of reasonableness
15 Arbitration; forms
16 Fee dispute committee hearings; illustrative testimony

Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
filed documents which he or someone in his office generated to falsely certify debtors' completion of
required credit counseling course and which he knew, or should have known, that debtors did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).

Mr. King, could you please update me on that status and progress of the various grievances I filed
recently in addition to providing a detailed summary of the content of all of your correspondences,
written or otherwise, and telephone communciatiosn with Richard Hill or anyone with his office.
Further, please state whether Casey Baker is part of the grievance, as Hill asserts he is filing it on Mr.
Baker's behalf.

Sincerely,

Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for
opposing counsel?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473
Sent: Fri 3/23/12 10:56 AM
Dear Mr. Coughlin,

Please come to see me and I will show you the letter and documents from the Court.

Patrick King

To: Patrick King
Subject: RE: does Richard Hill have standing to file a grievance

Mr. King,
This is the very first time you allege anyone other than Mr. King filed or alleged a
grievance. Please provide any documentation or proof related to these apparent
communications from judges that you are only now bringing up.
Sincerely,
No: 9473
Date: Fri, 23 Mar 2012 17:18:34 +0000
Dear Mr. Coughlin,




Sincerely,

Patrick King


American J urisprudence Trials
31 Am. J ur. Trials 633 (Originally published in 1984)
10 In general

Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining
professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in
bad faith,
filed documents which he or someone in his office generated to falsely certify debtors'
completion of
required credit counseling course and which he knew, or should have known, that debtors
did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11
U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
2010).

Mr. King, could you please update me on that status and progress of the various grievances
I filed recently in addition to providing a detailed summary of the content of all of your
correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
anyone with his office. Further, please state whether Casey Baker is part of the grievance,
as Hill asserts he is filing it on Mr. Baker's behalf.

Sincerely,

Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
work" for opposing counsel?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
Sent: Fri 3/23/12 12:08 PM
March 23, 2012

Dear Mr. Coughlin,

Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She
said that you appeared wearing pajamas over your clothes and were demanding and
argumentative. Apparently I will be receiving a report from the Marshals. As Assistant Bar
Counsel I would like to help you. However, my primary responsibility is to protect the public
and the administration of justice by insuring that Nevada Lawyers are complying with standards
required of the profession. It appears that you are not. I believe that there are ways to get you
assistance that may protect your license to practice law. I would sure appreciate the
opportunity to talk with you about resources and assistance that may help you through this
difficult time.


To: Patrick King

Mr. King,
This is the very first time you allege anyone other than Mr. King filed or alleged a
grievance. Please provide any documentation or proof related to these apparent
communications from judges that you are only now bringing up.
Sincerely,
No: 9473
Date: Fri, 23 Mar 2012 17:18:34 +0000
Dear Mr. Coughlin,




Sincerely,

Patrick King


American J urisprudence Trials
31 Am. J ur. Trials 633 (Originally published in 1984)
10 In general
RE: my attempt to be provided access to the grievances filed

Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining
professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in
bad faith,
filed documents which he or someone in his office generated to falsely certify debtors'
completion of
required credit counseling course and which he knew, or should have known, that debtors
did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11
U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
2010).

Mr. King, could you please update me on that status and progress of the various grievances
I filed recently in addition to providing a detailed summary of the content of all of your
correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
anyone with his office. Further, please state whether Casey Baker is part of the grievance,
as Hill asserts he is filing it on Mr. Baker's behalf.

Sincerely,

Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
work" for opposing counsel?
Nevada Bar No: 9473
today
Sent: Tue 3/27/12 9:24 AM
March 27, 2012

Dear Mr. Coughlin,

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

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

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

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

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

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

I will keep you advised of the panels determination.

Sincerely,

Patrick King

Sent: Monday, March 26, 2012 5:35 PM
Subject: my attempt to be provided access to the grievances filed today

Dear Mr. King,
This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted
to be provided access the the various "other different judges" grievances that I, prior to last Friday, was completely unaware
of. I have sent you several written correspondences detailing the tampering and other problems with my USPS mail incident to
the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
correspondences or document production via email and fax. Today, you showed me a two page letter from J udge Nash
Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any
other judges from whom you have received any other similar such materials and further refused to allow me to view and such
items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told
me you didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters,
grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am
considering different attorneys to represent me right now, and indicated I need these materials to prepare for any future
meeting with you. My records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on
that letter via email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
Sincerely,
No: 9473
today
Sent: Thu 3/29/12 4:10 PM
Dear Mr. Coughlin,

My information regarding the criminal convictions and the contempt orders against you is limited. I understand
you were sentenced to jail on more than one occasion for contempt of court. I also understand that you were
convicted of a crime on more than one occasion. You are obviously aware of these convictions and contempt
orders. Please provide me with an explanation of each conviction and of each contempt order.

Thank you.


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

Mr. King,

I recall you making no request for a written response to anything incident to my appearing at the
Double R location of the State Bar of Nevada to view the grievances from the "other different
judges". The only one you allowed me to view was the two page letter from Judge Nash Holmes.
You did not indicate if Judge Nash Holmes attached the copy of the 2009 Order for Sanctions by
Judge Gardner to Judge Holmes' letter, or whether that was a separate complaint, and if so, by
whom was it submitted. Please do so in writing and provide a date by which I must submit a
response. Please also copy me via email and or fax on any other materials submitted with those
Complaints, grievances, or letters (it seems patently unfair for you to say those are confidential and
of limits to me, really). You know as well as I do that I was not hostile or intimidating to you and that
we did not have a "meeting". I indicated to you at the outset of my appearing at your offices that I
was only there to view the grievances or complaints, and that I would not be able to undertake any
meeting with you that day. I am 6 foot 4 inches tall and 250 pounds. If you think this is the first
time somebody has tried to play the old "oh you were trying to intimidate me" card on me, you are
mistaken. I have been socialized to be docile and calm given my size, and really, the idea that my
size has any real effecdt on any legal proceeding is just silly, but, nonetheless, I have always gone
out of my way to avoid the appearance of being "the big bullying guy". Many, many people who
have known me for the 30 some odd years I have lived in this community attest to that, in and out
of legal circles. I realize you wanted to get more accomplished then and there, and that you have
previously expressed disatisfaction at the idea that I would have actually done any research in
preparation for any future meeting with you, but I assure you, I don't subscribe to the coerced
confession approach that is so favored by so many prosecutors and Bar Counsel. I will be litigating
this fully. And I will not be forced into hiring for $5,000 a "lawyer Kevorkian" hand picked by a strip
club owning Character and Fitness Committee bully, whom appears at the hearing and brags about
how he is doing it "pro bono".

Sincerely,
No: 9473

Date: Tue, 27 Mar 2012 16:26:11 +0000
March 27, 2012

Dear Mr. Coughlin,



you received the


response to those



Sincerely,

Patrick King

today

Dear Mr. King,
Sincerely,
Nevada Bar No: 9473
Sent: Fri 3/30/12 8:56 AM
Dear Mr. Coughlin,

You ask that I be more careful with the facts and yet you will not respond or discuss the facts with me. Please explain
what extremely important facts we have wrong. I was aware that your phone and cell phone had been taken as evidence.

Sent: Thursday, March 29, 2012 6:53 PM

Mr. King,
I only know of one conviction for a crime, which I reported. Please explain your statement with respect to more than one
conviction.
Please try to be more careful with the facts, you have misstated several extremely important facts so far, and it is very
alarming. Further, do you make every attorney who is found in contempt of court explain such a finding? Is there any duty
to? Does a summary contempt finding come within the purview of SCR 111? Doesn't Mr. Machado have jurisdiction over the
criminal conviction which I reported to him months ago? Are you not somewhat alarmed that J udge Nash Holmes'
complaint/letter to you fails to mention her seizure of the attorney's smart phone, other cell phone, and other personal
property? Or the fact that she makes extremely prejudicial assertions based upon unattributed hearsay?

Sincerely,

No: 9473

Date: Thu, 29 Mar 2012 23:11:41 +0000
Dear Mr. Coughlin,


Thank you.



Mr. King,

I recall you making no request for a written response to anything incident to my appearing
at the Double R location of the State Bar of Nevada to view the grievances from the "other
different judges". The only one you allowed me to view was the two page letter from
J udge Nash Holmes. You did not indicate if J udge Nash Holmes attached the copy of the
2009 Order for Sanctions by J udge Gardner to J udge Holmes' letter, or whether that was a
separate complaint, and if so, by whom was it submitted. Please do so in writing and
provide a date by which I must submit a response. Please also copy me via email and or
fax on any other materials submitted with those Complaints, grievances, or letters (it seems
patently unfair for you to say those are confidential and of limits to me, really). You know
as well as I do that I was not hostile or intimidating to you and that we did not have a
"meeting". I indicated to you at the outset of my appearing at your offices that I was only
there to view the grievances or complaints, and that I would not be able to undertake any
meeting with you that day. I am 6 foot 4 inches tall and 250 pounds. If you think this is
the first time somebody has tried to play the old "oh you were trying to intimidate me" card
on me, you are mistaken. I have been socialized to be docile and calm given my size, and
really, the idea that my size has any real effecdt on any legal proceeding is just silly, but,
nonetheless, I have always gone out of my way to avoid the appearance of being "the big
bullying guy". Many, many people who have known me for the 30 some odd years I have
lived in this community attest to that, in and out of legal circles. I realize you wanted to
get more accomplished then and there, and that you have previously expressed
disatisfaction at the idea that I would have actually done any research in preparation for
any future meeting with you, but I assure you, I don't subscribe to the coerced confession
approach that is so favored by so many prosecutors and Bar Counsel. I will be litigating
this fully. And I will not be forced into hiring for $5,000 a "lawyer Kevorkian" hand picked
by a strip club owning Character and Fitness Committee bully, whom appears at the hearing
and brags about how he is doing it "pro bono".

Sincerely,
Nevada Bar No: 9473

Date: Tue, 27 Mar 2012 16:26:11 +0000
March 27, 2012

Dear Mr. Coughlin,



you received the


response to those



Sincerely,

Patrick King


Dear Mr. King,
Sincerely,
Nevada Bar No: 9473
today
Sent: Fri 3/30/12 12:00 PM
Dear Mr. Coughlin,

I understand that there is one conviction. I also understand that there are other criminal charges pending that have not
been resolved. One is set for a trial on April 12, 2012, a trespass charge. I am also aware of contempt of Court Orders.
This behavior on your part appears to be contrary to the commitment you made when you were conditionally admitted.
Do you think you need and would benefit from treatment? If so, perhaps we could discuss a stipulation pursuant to SCR
117 2 for you go on a disability status while you obtain treatment. Such an agreement might be beneficial for you. Please
let me know if you want to discuss a stipulation.



Dear Bar Counsel,
Just quickly (ie, not an exhaustive list as I have a deadline to meet) the facts that you
seem to have confused so far include:
1. Mr. King wrote a 9 am on 3/16/12 to indicate my time to reply to Hill's grievance
had passed or that he has received my reply, when, in fact, Mr. King had, in writing
given me until 3 pm on 3/16/12 and had been given notice in writing that I would be
submitting further materials in reply.
2. Mr. King asserted that multiple convictions are at issue here. As far as I know
there is one conviction, in 11 CR 22176, which I report to Bar Counsel Clark and
Assistant Bar Counsel Machado prior to ever having any involvement with Mr. King.
As far as I know, a finding of civil contempt under NRS 22.010(3) (summary contempt
for conduct committed in the court's presence) does not require reporting under SCR
111 and is not criminal in nature. I could be wrong about that, Judge Flanagan
recently expressed that there was some uncertainty in the judiciary on that point, but
regardless, nothing in either Summary Contempt Order contains mention of any
conduct that, in my opinion, comes within the purview of SCR 111(6), or is
tantamount to a "serious offense" containing any of the elements cited therein. Its
not that I do not take such a thing seriously, however, I just do not read SCR 111 or
Mr. Machado's Nevada Lawyer article explicating that rule to require reporting, and
therefore, be relevant to Mr. King's inquiry. That is a theme here. Mr. King's inquiry
seems to be about as broad and open ended as could me and containing nothing in
the way of jurisdictional restrictions, much less procedural protection (Mr. King did
say he didn't care if I received notice of the Judge Holmes grievance, and there was a
real troubling tone to the way he said it and the look on his face when making that
statement). How Hill can file a grievance on behalf of Gessin or someone other than
Hill has not been made clear. Further problematic is the varying standard of proof
seemingly applied to the grievances I filed and those filed by Hill and Judge Holmes
(unattributed hearsay goes a long way when coming from Hill and Judge
Holmes.....written documentation and transcripts of hearing supporting my
contentions don't even result in any investigation from Mr. King given his quick draw
determination that the "clear and convincing" standard would not be met....".
Further, this is the first Mr. King has made any mention of knowing of the seizure of
my personal property (including a smart phone) by Judge Holmes (something I would
hope the Bar would take some offense to given the implications of such a practice
and for which the Bar may have a duty to report to the Judicial Discipline
Commission, according to my research). Just today is the first I have ever heard of
Mr. King asserting he knew, independently of the materials I provided him, that Judge
Holmes had seized my phone. Richard Cornell, Esq. seemed to think that was
tantamount to a "seizure", not entering, or booking it into evidence.
3. Another fact Mr. King seems to have confused is whether, on 3/16/12, as his letter
indicates, he actually had a copy of his letter of that date emailed to me. It certainly
was not faxed, despite my requesting it be and despite my having and providing a fax
number for my office. I wrote all Bar Counsel requesting to be sent any notices or
correspondences via fax or email in light of my status as a victim of domestic violence
and regarding the misconduct of the USPS supervisors at my postal station and the
interference with my mail by the domestic abusers and negligent property manager
(whom did admit, under oath, that one of her managers had received approval from
the HOA for my former housemates to be at the 1422 E. 9th St. #2 townhome, where
they were for over 9 months before this Owner of the property management
company apparently coaxed a resignation out of the former manager (on January 5th,
2012) who entered such an arrangement found out. Suddenly, this owner of
Western Nevada Management, Sue King, apparently wants everyone to drop
everything, excuse her negligence and alleged lack of knowledge of that arrangment,
and countenance her allegedly imploring NV Energy to refuse to allow me to have
power turned on one the domestic abuser former housemates had it shut off (NV
Energy did wait 7 days before finally agreeing to let me have the power turned on in
my name....so I did not have power for from February 3 to February 10, thanks to Ron
Jones, of NV Energy, and, apparently, the influence of HOA resident agent Gayle Kern,
Esq., LTD and her property manager, Sue King, owner of Western Nevada
Management), then King allegedly implores the USPS to refuse me a mailbox key,
which they respond to by informing me they are "feds" and "don't have to follow
state laws" (like NRS 118A.160 and 118A.190, etc.) and "aren't going to put up with
any more of your garbage" and "don't care if you are a lawyer", etc., etc., because
(Golden Valley Station employees Buck Hyde, Terri James and "Ms." Passot) "we think
you are a squatter anyways and aren't going to waste our time going out an changing
the lock since you will probably just get evicted anyhow...". It would be great if the
State Bar of Nevada may be able to provide some help in getting these monolithic
entities to follow the law rather than retaliate against a lawyer.
4. Mr. King seems to have confused what occurred on 3/23/12. I appeared at the
State Bar Offices to view the "other different judges" grievances that Mr. King would
only let me view by so appearing in person. I informed him I would not consent to or
be able to meet with him at that time, but was appearing only to view the
documentation in the only manner being afforded me by Mr. King's approach. Mr.
King now seeks to categorize my appearance to view such documentation as a
"meeting" along the lines of those traditionally held in the informal stage of an
inquiry like this. It was not. Further, Mr. King's characterization of my document
viewing on that date is intellectually dishonest, overly hostile and aggressive, and in
line with much of the prosecutorial misconduct that I have written of recently. There
are a number of other such instances where material facts have been "confused" by
Mr. King, but those will need to be addressed at a later date.
Sincerely,
Zach Coughlin, Esq.
No: 9473
Date: Fri, 30 Mar 2012 15:58:14 +0000
Dear Mr. Coughlin,



Mr. King,
conviction.

Sincerely,

Nevada Bar No: 9473

Date: Thu, 29 Mar 2012 23:11:41 +0000
Dear Mr. Coughlin,


Thank you.



Mr. King,


Sincerely,
Nevada Bar No: 9473

Date: Tue, 27 Mar 2012 16:26:11 +0000
March 27, 2012

Dear Mr. Coughlin,



you received the


response to those


today

Sincerely,

Patrick King


Dear Mr. King,
Sincerely,
Nevada Bar No: 9473
Sent: Mon 4/02/12 8:54 AM
Dear Mr. Coughlin,

That is why it is so important for you to cooperate and to respond to the
grievances. I did not know for example, until I investigated, that your
admission to the Bar had been delayed and that you were ordered by a
character and fitness committee to undergo counseling.

Now I understand that you suffer from a mental condition. Apparently you
were arrested for prior to being admitted to the Bar. Since being admitted,
you have been arrested on more than one occasion. It is apparent to me
that your mental issues are not resolved. Have you considered getting back
into treatment?

Sincerely,

Patrick


Dear Bar Counsel,
Why did you earlier mention more than one conviction? That is exactly what I mean
by "getting confused about material facts". Similarly, Mr. King was confused about
whether any email is sent from a web site or an email address and whether anyone
from the State Bar of Nevada emailed me Mr. Kings 3/16/12 letter (that was when
Mr. King indicated he did not care if I received that letter or not in an alarming
delivery). Why would you bring up anything about a conditional admission when the
conditions expired in 2008? It is this alarmingly loose approach to maintaining some
fidelity to traditional notions of due process and fair play that Mr. King exhibits that
troubles me the most. For instance, he blanket refusal to provide anything in
response to my FOIA and other requests. How could that possibly be fair? I have
provided additioanl documentation in support of the grievances against the
Christiansens, Sanft, Kevin Kelly and Eichman. Do you still contend that there is no
basis for any further inquiry? Further, you mention a disability approach, however,
you fail to cite with any specificity why you suggest that approach. Please do so.
Please explain to me how your stance is anything other than "well, these powerful
people are asking me to mash on you and that generally is in my best interest and
helps me avoid having any skin in the game, and, yeah, I know, ideals, ideals, stand up
for brave lawyers, bar counsel duties, etc., but really, come on, why should I stick out
my neck", etc., etc.

When and how did you become aware that Judge Nash Holmes seized my phones and
other property. Seizing a smart phone is like seizing 10 filing bins. But I am not sure
you understand that because you seem confused over whether an email is sent from
an email address or from a website, as indicated in your statements while I was
viewing the documentation. I ask that you understand some of what I have been
through with the Bar. You really cannot imagine what I have been through unless
you lived it. It completely raped my life and it didn't stop when getting admitted in in
2005. It carried on for several more years, especially in California. $5K for
Christiansen was an outrage, then to have him appear at the hearing and say he was
doing it "pro bono", especially after Kevin Kelly's statements about providing me "the
names of three attorneys who will do you case pro bono" is further alarming. How in
the world Kevin Kelly can be on the Character and Fitness Committee for a decade
while owning the Spearmint Rhino truly mystifies. Its nots the ownership, its the
alarming Nifong approach he took with me, especially vis a vis his democratic party
buddy Mark Tratos. Clearly, Tratos received my paper and he and LaFrance were just
playing kick the can with me. I swear to god on mine and everyone in my families life
I turned in that paper, and that guy knows it. He swore under oath at the California
hearing that he had lost other students papers previously. I know legion of people
who loath him. Whatever, I don't like to embrace hate. Life is short.

Mr. King, I do get a sense about you that you are interested in fairness in your heart.
However, I recognize when a scenario is stacked in a way that is likely to affect one's
judgment. This is such a scenario. But you know what? Judge Flanagan told Richard
Hill to put the clown makeup down the other day. Judge Sferrazza seemed to be
tiring of how flagrant Hill was beign with thing, especially with the reputations of
those he was dragging into hsi chicanery. I destroyed Hill's contractor on cross
examinatino on March 23, 2012. Judge Flanagan actually lauged and smiled a couple
times at how ridiculous Phil Stewart's testimony got. First it was he "assumed I
climbed on the truck because he felt a depression occur on the vehicle when allegedly
the 240 pound Coughlin supposedly climbed up on the truck, depsite the fact that
Stewart had to admit that the modified 2 ton dumptruck had approximately 1500
pounds of a "luxury sedan car seat collection" and other personal property...then it
was, that "he felt the depression lift from the truck after he got out to look in the
blind spot behind the truck to see what Coughlin was doing....then it was, oh wait, he
felt the depression of weight lift before he alighted from the vehicle", that he
misspoke, then it was "well, I know you climbed on the truck because I saw your head
atop the contents of the dumptruck in the middle of the area above the tailgate in my
rear view mirror"....Really? Why go into all that about alighting, and depressions of
weight, and "assuming"....Why not just say you saw a guy's head in the rear view
mirror in a place that would indicate he had climbed on the truck rather than
demonstrated an ability to levitate? Judge Flanagan was done with the whole matter
after that. He ruled for me and Hill and Baker knew they better not be stupid
enough to even try to put on any more evidence, and it didn't seem like Judge
Flanagan was much interested in their doing so at that point anyway.

I saw Mr. Clark speak at the Family Law conference in Ely in 2008, I believe, and spoke
with him on the phone about a year and a half ago when I had a question about
whether there is a respository of contempt orders issued against attorneys. I
honestly feel sanctions under NRS 18.010(2)(b) and NRS 22.010(3) are becoming very
big problems in our field. The access to justice is being curtailed through a bullying
approach to applying such mechanisms. Rather than allowing market forces dicate
that rich powerful parties engage in legitimate settlement discussion when the law is
not on their side (ie, when Merliss and Hill wish to ran a summary eviction procedure
through a court where doing so is per se impermissible in light of the tenant beign a
commercial one and the notice failing to allege nonpayment of rent).

But at my core, what really drives me is a belief in competition. If Hill and Merliss
can run that game on most people, it is what it is. But I suited up and showed up and
battled and I deserve to have those skills, efforts, energies, guts, and passions that I
displayed in doing so translate into something tangible in a court of law, particularl
where the law and facts were as favorable to my case as they were. I don't deserve
some compassion fascism witch trial.

Sincerely
No: 9473
Date: Fri, 30 Mar 2012 19:01:56 +0000
Dear Mr. Coughlin,

I understand that there is one conviction. I also understand that there are other criminal charges pending that have not
been resolved. One is set for a trial on April 12, 2012, a trespass charge. I am also aware of contempt of Court Orders.
This behavior on your part appears to be contrary to the commitment you made when you were conditionally admitted.
Do you think you need and would benefit from treatment? If so, perhaps we could discuss a stipulation pursuant to SCR
117 2 for you go on a disability status while you obtain treatment. Such an agreement might be beneficial for you. Please
let me know if you want to discuss a stipulation.



Dear Bar Counsel,
J ust quickly (ie, not an exhaustive list as I have a deadline to meet) the facts
that you seem to have confused so far include:
1. Mr. King wrote a 9 am on 3/16/12 to indicate my time to reply to Hill's
grievance had passed or that he has received my reply, when, in fact, Mr. King
had, in writing given me until 3 pm on 3/16/12 and had been given notice in
writing that I would be submitting further materials in reply.
2. Mr. King asserted that multiple convictions are at issue here. As far as I
know there is one conviction, in 11 CR 22176, which I report to Bar Counsel
Clark and Assistant Bar Counsel Machado prior to ever having any involvement
with Mr. King. As far as I know, a finding of civil contempt under NRS
22.010(3) (summary contempt for conduct committed in the court's presence)
does not require reporting under SCR 111 and is not criminal in nature. I
could be wrong about that, J udge Flanagan recently expressed that there was
some uncertainty in the judiciary on that point, but regardless, nothing in
either Summary Contempt Order contains mention of any conduct that, in my
opinion, comes within the purview of SCR 111(6), or is tantamount to a
"serious offense" containing any of the elements cited therein. Its not that I
do not take such a thing seriously, however, I just do not read SCR 111 or Mr.
Machado's Nevada Lawyer article explicating that rule to require reporting, and
therefore, be relevant to Mr. King's inquiry. That is a theme here. Mr. King's
inquiry seems to be about as broad and open ended as could me and
containing nothing in the way of jurisdictional restrictions, much less
procedural protection (Mr. King did say he didn't care if I received notice of
the J udge Holmes grievance, and there was a real troubling tone to the way
he said it and the look on his face when making that statement). How Hill can
file a grievance on behalf of Gessin or someone other than Hill has not been
made clear. Further problematic is the varying standard of proof seemingly
applied to the grievances I filed and those filed by Hill and J udge Holmes
(unattributed hearsay goes a long way when coming from Hill and J udge
Holmes.....written documentation and transcripts of hearing supporting my
contentions don't even result in any investigation from Mr. King given his quick
draw determination that the "clear and convincing" standard would not be
met....". Further, this is the first Mr. King has made any mention of knowing
of the seizure of my personal property (including a smart phone) by J udge
Holmes (something I would hope the Bar would take some offense to given
the implications of such a practice and for which the Bar may have a duty to
report to the J udicial Discipline Commission, according to my research). J ust
today is the first I have ever heard of Mr. King asserting he knew,
independently of the materials I provided him, that J udge Holmes had seized
my phone. Richard Cornell, Esq. seemed to think that was tantamount to a
"seizure", not entering, or booking it into evidence.
3. Another fact Mr. King seems to have confused is whether, on 3/16/12, as
his letter indicates, he actually had a copy of his letter of that date emailed to
me. It certainly was not faxed, despite my requesting it be and despite my
having and providing a fax number for my office. I wrote all Bar Counsel
requesting to be sent any notices or correspondences via fax or email in light
of my status as a victim of domestic violence and regarding the misconduct of
the USPS supervisors at my postal station and the interference with my mail
by the domestic abusers and negligent property manager (whom did admit,
under oath, that one of her managers had received approval from the HOA for
my former housemates to be at the 1422 E. 9th St. #2 townhome, where they
were for over 9 months before this Owner of the property management
company apparently coaxed a resignation out of the former manager (on
J anuary 5th, 2012) who entered such an arrangement found out. Suddenly,
this owner of Western Nevada Management, Sue King, apparently wants
everyone to drop everything, excuse her negligence and alleged lack of
knowledge of that arrangment, and countenance her allegedly imploring NV
Energy to refuse to allow me to have power turned on one the domestic
abuser former housemates had it shut off (NV Energy did wait 7 days before
finally agreeing to let me have the power turned on in my name....so I did not
have power for from February 3 to February 10, thanks to Ron J ones, of NV
Energy, and, apparently, the influence of HOA resident agent Gayle Kern, Esq.,
LTD and her property manager, Sue King, owner of Western Nevada
Management), then King allegedly implores the USPS to refuse me a mailbox
key, which they respond to by informing me they are "feds" and "don't have
to follow state laws" (like NRS 118A.160 and 118A.190, etc.) and "aren't going
to put up with any more of your garbage" and "don't care if you are a
lawyer", etc., etc., because (Golden Valley Station employees Buck Hyde, Terri
J ames and "Ms." Passot) "we think you are a squatter anyways and aren't
going to waste our time going out an changing the lock since you will probably
just get evicted anyhow...". It would be great if the State Bar of Nevada may
be able to provide some help in getting these monolithic entities to follow the
law rather than retaliate against a lawyer.
4. Mr. King seems to have confused what occurred on 3/23/12. I appeared
at the State Bar Offices to view the "other different judges" grievances that
Mr. King would only let me view by so appearing in person. I informed him I
would not consent to or be able to meet with him at that time, but was
appearing only to view the documentation in the only manner being afforded
me by Mr. King's approach. Mr. King now seeks to categorize my appearance
to view such documentation as a "meeting" along the lines of those
traditionally held in the informal stage of an inquiry like this. It was not.
Further, Mr. King's characterization of my document viewing on that date is
intellectually dishonest, overly hostile and aggressive, and in line with much of
the prosecutorial misconduct that I have written of recently. There are a
number of other such instances where material facts have been "confused" by
Mr. King, but those will need to be addressed at a later date.
Sincerely,
Zach Coughlin, Esq.
Nevada Bar No: 9473
Date: Fri, 30 Mar 2012 15:58:14 +0000
Dear Mr. Coughlin,



Mr. King,
conviction.

Sincerely,

Nevada Bar No: 9473

Date: Thu, 29 Mar 2012 23:11:41 +0000
Dear Mr. Coughlin,


Thank you.



Mr. King,


Sincerely,
Nevada Bar No: 9473

Date: Tue, 27 Mar 2012 16:26:11 +0000
March 27, 2012

Dear Mr. Coughlin,



you received the


response to those



Sincerely,

Patrick King


Dear Mr. King,
today
Sincerely,
Nevada Bar No: 9473
Sent: Mon 4/02/12 2:02 PM
Sent: Monday, April 02, 2012 10:15 AM

Mr. King,
Now you appear to be bringing an allegedly conditional admission that would have expired over four years ago into this arena.
Is there no jurisdictional limit to your inquiry? Are there no rules of evidence that apply? Further, if one review Chairman
Rowe's assertions as my Character and Fitness hearings, they go completely counter to your attempts to make a conditional
admission a lifetime black mark on one's record. Additionally, you have so far failed to expressly, specifically identify one thing
that troubles you and explicate the basis for it doing so. Mostly, you have given me a "it speaks for itself" approach. Which
leaves a lot wanting in the way of due process. This is the same sort of thing Geof Giles complained about you doing when he
sued you in the foreclosure mediation context. Curiously, the briefs in that case that address your misconduct have
disappeared from the Nevada Supreme Court's website. Do you know why? Can you give me an indication of how the J oey
Gilbert matter was handled incident to his boxing affairs, for which J ohn Bailey was involved, he having a role both with the Bar
and with the boxing commission.
As for standards of proof, you seem to find Richard Hill meets his rather easily, based only upon unattributed hearsay (same for
J udge Nash Holmes assertions). Further, please clarify who the "other different judges" are who filed grievances or complaints
against me. So far, you have only identified J udge Nash Holmes. While J udge Nash Holmes apparently purports to speak on
behalf of other RMC J udges, none of them have signed anything submitted to the State Bar of Nevada, further, J udge Nash
Holmes letter to you is littered with inconsistencies, misstatements, and material omissions, particularly in matters for which she
purports to comment on behalf of other RMC judges. Please indicate when and where you became aware of J udge Nash
Holmes remarkable seizure of my personal property in court, including a smart phone.
Please indicate whether J udge Nash Holmes attached the April 2009 sanctions Order by J udge Gardner. As far as I know, Glenn
Machado has jurisdiction over the 11/30/11 conviction in RMC 11 CR 22176. Until I have something in writing from the State
Bar of Nevada indicating otherwise, that is what I was left with upon reporting that conviction pursuant to SCR 111. Please
confirm that you have accessed confidential Character and Fitness Committee records for any alleged conditional admission of a
member of the Bar during a time period after the expiration of any such conditional admission.
Further, Mr. King, you seem to take quite a few liberties as far as offering your own mental health diagnosis, ostensibly based
primarily upon the unattributed hearsay of a former prison warden become judge and an attorney known throughout the bar for
engaging in vexatious litigation tactics (Richard Cornell, Thomas J . Hall, Geof Giles, etc., etc. have all commented on Mr. Hill's
reputation preceding him to one extent or another). Mr. King, I wish to know the sources of your alleged "information",
including your assertions that I was ever "in treatment" and, by implication, you assertion that I am now "out of treatment"
given you mentioning that I might get "back into treatment".
Sir, I think you need to ask yourself whether you are selling yourself out and attempting to leverage medicine, law, and
psychiatry, in a attempt to please rich people like Richard G. Hill, J udge Nash Holmes, etc., etc. You take an Oath as an
attorney and as Bar Counsel. While you mention that Oath including protecting the public, you see to fail to understand that a
large part of protecting the public includes working towards maintaining the health of the legal profession. Being an attack dog
for the rich, seeking to stifle the voice of dissent, and otherwise making a mockery of fundamental notions of due process and
fair play, whilst leveraging in a malevolent manner both the recovery and psychiatric communities, all so Richard G. Hill, Esq.
can buy his eleventh Porsche is beyond dangerous and objectionable. These are the days of transparency, and there is nothing
written to suggest that Bar Counsel shall be immune from that.
Sincerely,
No: 9473
Date: Mon, 2 Apr 2012 15:56:08 +0000
Dear Mr. Coughlin,

today

into treatment?

Sincerely,

Patrick

Nevada Bar No: 9473
Sent: Mon 4/02/12 2:13 PM
Dear Mr. Coughlin,

Am I correct in taking from your e-mail that you are not interested in considering a joint petition, pursuant to SCR
117 3 ?

Patrick

Sent: Monday, April 02, 2012 10:15 AM

Mr. King,
Now you appear to be bringing an allegedly conditional admission that would have expired over four years ago into this arena.
Is there no jurisdictional limit to your inquiry? Are there no rules of evidence that apply? Further, if one review Chairman
Rowe's assertions as my Character and Fitness hearings, they go completely counter to your attempts to make a conditional
admission a lifetime black mark on one's record. Additionally, you have so far failed to expressly, specifically identify one thing
that troubles you and explicate the basis for it doing so. Mostly, you have given me a "it speaks for itself" approach. Which
leaves a lot wanting in the way of due process. This is the same sort of thing Geof Giles complained about you doing when he
sued you in the foreclosure mediation context. Curiously, the briefs in that case that address your misconduct have
disappeared from the Nevada Supreme Court's website. Do you know why? Can you give me an indication of how the J oey
Gilbert matter was handled incident to his boxing affairs, for which J ohn Bailey was involved, he having a role both with the Bar
and with the boxing commission.
As for standards of proof, you seem to find Richard Hill meets his rather easily, based only upon unattributed hearsay (same for
J udge Nash Holmes assertions). Further, please clarify who the "other different judges" are who filed grievances or complaints
against me. So far, you have only identified J udge Nash Holmes. While J udge Nash Holmes apparently purports to speak on
behalf of other RMC J udges, none of them have signed anything submitted to the State Bar of Nevada, further, J udge Nash
Holmes letter to you is littered with inconsistencies, misstatements, and material omissions, particularly in matters for which she
purports to comment on behalf of other RMC judges. Please indicate when and where you became aware of J udge Nash
Holmes remarkable seizure of my personal property in court, including a smart phone.
Please indicate whether J udge Nash Holmes attached the April 2009 sanctions Order by J udge Gardner. As far as I know, Glenn
Machado has jurisdiction over the 11/30/11 conviction in RMC 11 CR 22176. Until I have something in writing from the State
Bar of Nevada indicating otherwise, that is what I was left with upon reporting that conviction pursuant to SCR 111. Please
confirm that you have accessed confidential Character and Fitness Committee records for any alleged conditional admission of a
member of the Bar during a time period after the expiration of any such conditional admission.
Further, Mr. King, you seem to take quite a few liberties as far as offering your own mental health diagnosis, ostensibly based
primarily upon the unattributed hearsay of a former prison warden become judge and an attorney known throughout the bar for
engaging in vexatious litigation tactics (Richard Cornell, Thomas J . Hall, Geof Giles, etc., etc. have all commented on Mr. Hill's
reputation preceding him to one extent or another). Mr. King, I wish to know the sources of your alleged "information",
including your assertions that I was ever "in treatment" and, by implication, you assertion that I am now "out of treatment"
given you mentioning that I might get "back into treatment".
Sir, I think you need to ask yourself whether you are selling yourself out and attempting to leverage medicine, law, and
psychiatry, in a attempt to please rich people like Richard G. Hill, J udge Nash Holmes, etc., etc. You take an Oath as an
attorney and as Bar Counsel. While you mention that Oath including protecting the public, you see to fail to understand that a
large part of protecting the public includes working towards maintaining the health of the legal profession. Being an attack dog
for the rich, seeking to stifle the voice of dissent, and otherwise making a mockery of fundamental notions of due process and
fair play, whilst leveraging in a malevolent manner both the recovery and psychiatric communities, all so Richard G. Hill, Esq.
can buy his eleventh Porsche is beyond dangerous and objectionable. These are the days of transparency, and there is nothing
written to suggest that Bar Counsel shall be immune from that.
Sincerely,
No: 9473
Date: Mon, 2 Apr 2012 15:56:08 +0000
Dear Mr. Coughlin,


today
into treatment?

Sincerely,

Patrick

Nevada Bar No: 9473
Sent: Mon 4/02/12 3:57 PM

Dear Mr. Coughlin,

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

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

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

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

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

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

Sincerely,


Sent: Monday, April 02, 2012 2:39 PM
To: Patrick King

Mr. King,
I need for basic procedural due process protections to be afforded before any
consideration of any arrangement you have in mind would be appropriate. It is my
understanding that we are still in the stage of the process where you are providing
me indication of the allegations against me and documentation in support and
RE: Mr. King's assertion in his 3/ 16/ 12 letter
explanation thereof, and that there is still additional materials and complaints which
you have so far chosen not to allow me access to, even to view upon my responding
to your stipulation that I could only so view such materials upon visiting the Reno
office of the State Bar of Nevada in person. Such as, please answer the questions I
have posed you in my recent emails, especially with regard to providing copies of and
information related to these "other different judges" supposedly submitting written
complaints about me to you. Further, please explain whether you requested
materials from Judge Nash Holmes, as her letter to you appears to indicate, in her
statements that she "apologizes for taking two days to get these materials to you"
that you requested such materials rather than she sending them to you on her own
accord? Please explain.
Sincerely,
Nevada Bar No: 9473

Sent: Thu 4/19/12 2:28 PM
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,

A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the
grievances filed against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be
preparing a formal Complaint.

I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at
Wal-Mart and that you should not have been found in contempt of Court. However, it must concern you that you were
found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of or
obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at
my request, pursuant to my investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and
why you were held in contempt of Court. You may be well served to explain what remedial measures you are taking to
make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest you
cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge
Holmes and Richard Hills grievance letters to the office of Bar Counsel.

Patrick King
Subject: Mr. King's assertion in his 3/16/12 letter

Dear Bar Counsel,
One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months
worth of my portion of our rent from me (our arrangement was I would give her the money, she would forward it on to the
landlord) in the period between May-J uly 2011. I sacrificed a great deal and paid lots of her tuition, and she broke up with me
and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her graduation from UNR. I
did not know about her stealing my portion of the rent or failing to pay her own portion until August 2011, as the landlord was
on an extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the eviction in RJ C
REV2011-001708 from my former home law office ensued within less than a week of his communicating this deficiency. He
and his counsel, Richard G. Hill, Esq. and Casey Baker pursued a No Cause Notice of Eviction because there was a wealth of
support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in addition to personal
property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such,
indicated it would "be the path of least resistance" to simply seek a No Cause Eviction. The only problem in their attempt to
circumvent the law (even though they still threatened to seek back rent in another forum after getting their No Cause,
summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a commercial law office there, and
NRS 40.253 makes impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice,
which, of course Baker and Hill chose not to do....and it was about the time that Hill started to understand that his "wrong site
surgery" for his neurosurgeon landlord client might subject Hill and his firm to some malpractice liability, that Hill started
writing letters to bar counsel attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable
when Gessin was Hill's client and Hill was milking over $20K from Gessin) for "ghostwriting" even though I was listed as
Attorney of Record on several different Gessin cases, etc., etc.
Anyway, I deny guilt on each an every allegation made against me by Hill, J udge Nash Holmes, and whoever else has filed a
grievance or complaint and also with respect to any criminal charge against me, including that which resulted in a conviction in
11 CR 22176, which, I think will ultimately reveal was replete with prosecutorial misconduct, lying by the Wal-Mart loss
prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other errors by J udge
Howard.
I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on
that 3/16/12 letter from Assistant Bar Counsel King (please see attached picture of the letter and envelope) indicates it was
mailed 3/16/12, and the letter indicates it was not faxed to me (despite my numerous written requests that such a practice be
done in consideration of the problems I have encountered in the USPS violations of the Federal Torts Claims Act and incident to
the domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which included interference with my mail).
I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden
Valley USPS Station and the Downtown Reno Post Office in and attempt to make every diligent effort to receive my mail. I
have been threatened by and lied to by the supervisors of the Golden Valley Station USPS Station. I had a hearing related to a
landlord tenant dispute on 3/15/12 (which makes J udge Nash Holmes assertion, in her 3/14/12 letter that I was living in my car
at that time rather suspect, given my home law office was located at the property which was the subject of that hearing and
which I was still located at on 3/14/12...of course, J udge Nash Holmes provides no attribution for such hearsay in her
extremely reckless assertion) in RJ C REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked
even a law license to litigate on her behalf, or on that of the HOA which Kern has now decided to appear for, despite her being
listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in RJ C Rev2012-
000374.
My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to
respond to it. Additionally, I note that Mr. King, in that 3/16/12 letter, writes "I am enclosing with this letter copies of a
grievance letter, from the Municipal Court and a copy of an Order from District court....I will make available for your review and
inspection the supporting documents and audio recordings."
However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting
documents and audio recordings". I wish to have a copy of all such "supporting documents and audio recordings", and failing a
copy being provided, I wish to be allowed the access to conduct a "review and inspection" of "the supporting documents and
audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such access. In addition, Mr.
King now informs me that he has opened a grievance on behalf of J udge Linda M. Gardner, incident to a Order for Sanctions
she entered in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or otherwise provided
it to Bar Counsel as a Complaint or Grievance or otherwise. I believe someone necessarily must file the complaint or
grievance. Further, I believe I am entitled to know whom that is, and when such was filed. Additionally, Mr. King has, so failed
to provide a copy or any access to any purported complaint by the City of Reno Marshal's division incident to my accessing
justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord
tenant hearing set for March 15th, 2012, and further, in response to hostility, retaliation, lies, and threats made by the USPS
Golden Valley Station supervisors Buck Hyde, Terri J ames, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12 letter to me,
was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other, on it by the USPS),
however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me, but rather, apparently,
returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for J udge Nash Holmes 3/14/12
RE: Update and a Request
letter to Mr. King, as such, I have no idea what J udge Nash Holmes is referring to when she describes difficulty contacting me
(the attempts by J udge Nash Holmes and the RMC apparently did not included either email or fax or a phone call, however....).
There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the
RMC dated 3/14/12) and which mailings it ultimately forwarded on to me (at my then PO BOX 60952, please note, I have a
new PO BOX, that I intened to keep for a substantial period of time, it is PO BOX 3961, Reno 89505...), such as a 3/13/12
mailing from the Reno J ustice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope has 3 yellow
stickers stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then next sticker
indicating a hold, and the final sticker atop the stack indicating a forwarding date of 3/28/12....).
I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former
home law office, and there was difficulties in filing a Change of Address incident to that given that the Address being changed
from was permanently assigned to a business, a motor lodge. Further, some problem cause Bank of America to temporarily
deny my attempts to change my address on file online, and rather require that I mail Bank of America a signed letter
requesting as much, all the way to Florida. That resulted in delays in filing an online Change of Address with the USPS, given
the USPS demands the online changes be made with one's own debit card, and that they debit card bare the same billing
address as the location one is filing a change of address from, or else, the USPS, will process such a request, but it will add 7-
10 days to tohe processing time. I chose that option given mailign a letter to Bank of America in Florida would have taken
just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and the supervisor,
beyond calling me a "squatter" in advance of the hearing in RJ C REv2011-000374 (and refusing to divulge whom had been
providing information to them resulting in such a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed
me that while my Change of Address to my then PO Box 60952 was being processed, my mail would be held at the Golden
Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the following days, a supervisor
named Buck Hyde literally assaulted me, and he and two other supervisors there, Terri J ames and "Ms. Passot" informed me
they were "Feds" and didn't have to put up with any crap from an attorney related to state laws like NRS 118A.190, though
they couldn't cite specifically to any section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my
former home law office at 1422 E. 9th St. #2.
Sincerely,
No: 9473
Sent: Fri 4/27/12 9:54 AM
Dear Mr. Coughlin,

Please do not add other e-mail addresses or cc to the correspondence you send to me. I see that your e-mails are being
sent to several people, some of them I do not know.

You may certainly communicate with anyone you want, but when you send information to Bar Counsel, please send it to
my address only. I am the assistant bar counsel responsible for your cases. Thank you.

I was advised you were in custody. Do you have any idea when you will be released?

Patrick King

Sent: Friday, April 27, 2012 12:13 AM
To: Patrick King; David Clark; Glenn Machado; coe@gbis.com; keith@leelawoffice.net
Subject: Update and a Request

Dear Bar Counsel,
I was never afforded an informal meeting or an opportunity to view the materials
submitted in conjunction with the various grievances or other types of complaints
against me, nor was I given a deadline to respond for any such matters outside the
deadline related only to the Hill "grievance". I ask that the process be paused and
that those procedural safeguards be afforded me. Further, I have met with Coe
Swobe recently and discussed this matter and ask that all avenues available to me be
held available, until I have had a a legitimate chance to explore them. I apologize for
what may seem an overly adversarial tone so far on my behalf and pledge to work
with you from hereon in addressing these matters of concern.
Sincerely,
Zach Coughlin, Esq.
No: 9473
Subject: RE: Mr. King's assertion in his 3/16/12 letter
Date: Thu, 19 Apr 2012 21:29:10 +0000
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,




Patrick King

Dear Bar Counsel,
Howard.
000374.
Sincerely,
RE: Update and a Request
Nevada Bar No: 9473
Sent: Fri 4/27/12 10:46 AM
Please let me know when you would like to meet to discuss options that are available. If you get a chance, please read
Supreme Court Rule 117.

Patrick King

Sent: Friday, April 27, 2012 12:13 AM
To: Patrick King; David Clark; Glenn Machado; coe@gbis.com; keith@leelawoffice.net
Subject: Update and a Request

Dear Bar Counsel,
I was never afforded an informal meeting or an opportunity to view the materials
submitted in conjunction with the various grievances or other types of complaints
against me, nor was I given a deadline to respond for any such matters outside the
deadline related only to the Hill "grievance". I ask that the process be paused and
that those procedural safeguards be afforded me. Further, I have met with Coe
Swobe recently and discussed this matter and ask that all avenues available to me be
held available, until I have had a a legitimate chance to explore them. I apologize for
what may seem an overly adversarial tone so far on my behalf and pledge to work
with you from hereon in addressing these matters of concern.
Sincerely,
Zach Coughlin, Esq.
No: 9473
Subject: RE: Mr. King's assertion in his 3/16/12 letter
Date: Thu, 19 Apr 2012 21:29:10 +0000
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,




Patrick King

Dear Bar Counsel,
Howard.
000374.
From Assistnat Bar Council, Patrick King
Sincerely,
Nevada Bar No: 9473
Sent: Tue 6/26/12 2:52 PM
June 26, 2012

RE: Recordings of Court proceedings

Dear Mr. Coughlin,

I spoke with David Clark regarding your request that we provide you with copies of
the CD discs of Court proceedings.

David Clark authorized me to provide you with copies.

Please let me know the address to use to send you the copies. There is a total of 5
disks.
recordings of court proceedings.
RE: request for consideration of global resolution


Sent: Thu 6/28/12 11:20 AM
June 28, 2012

Dear Mr. Coughlin,

You have requested that I provide you with copies of the recordings of court proceedings that I received from the
Court.

I spoke with David Clark, Bar Counsel , regarding your request and Mr. Clark said I could provide you with copies.

I am, therefor, asking for an address where I can mail you the copies.

Sent: Wed 8/01/12 9:31 AM
To: Zach Coughlin (zachcoughlin@hotmail.com)
Dear Mr. Coughlin,

I received your e-mails. Thank you for the information. I appreciated the opportunity to sit down with you and to have a
constructive and pleasant conversation. I understand how stressful this is for you. As we discussed, I hope you are able
to find the help and support you need to resolve any health issues.

Sincerely,


Sent: Tuesday, J uly 31, 2012 6:59 PM
To: zyoung@da.washoecounty.us; mkandaras@da.washoecounty.us; keithloomis@earthlink.net; jleslie@washoecounty.us;
kadlicj@reno.gov; christensend@reno.gov; chaset@reno.gov; Patrick King; David Clark; stuttle@washoecounty.us;
askrpd@reno.gov
Subject: request for consideration of global resolution

Dear Madams and Sirs.

I hope you not find it untoward for me to contact you in this manner. I do not know to what extent it is permissible to mix
discussions of potential civil causes of actions with
"pending or still subject to being set aside under something like a NRCP 60(b) analysis" criminal matters...if doing so is
impermissible, then I do not wish to engage any of you in that regard, and my apologies.

I am deeply humbled by all the various charges and sanctions I have incurred this year, and realize I have made big mistakes,
only to compound them with bigger mistakes and ever more greater showings of ill advised instransigence. I apologize for
those actions.

I am doing my best to make sure I do not go back to jail or otherwise upset anyone in the judicial branch or l I realize the DA,
WCSO, or the Reno City Attorney or the RPD may find it laughable to think that I would have any reasonable basis for bringing
suit....but for whatever it is worth, I would jump at an opportunity to sign away any such potential claims should it assist me in
resolving my outstanding criminal charges (in the RJ C, there is a misuse of 911 services charge from J anuary 14th, 2012 before
J udge Pearson, the iPhone petty larceny matter from August 20th, 2011 before J udge Sferrazza, and this new
obstructing/resisting charge incident to a misunderstanding related to an eviction on J une 27th, 2012; in the Reno Municipal
Court there remains a jaywalking charge from J anuary 12th, 2012 and a traffic "failure to come to a complete stop" charge from
November 15th, 2011, both before J udge Nash Holmes, the latter of which resulted in an accusation or even, perhaps, a
conviction of summary contempt, perhaps even criminal summary contempt incident to the still suspended Trial that was held
on February 27th, 2012, and lastly, before J udge Dilworth is the "disturbing the peace" charge stemming from my J uly 3rd,
2012 arrest by the RPD).

Additionally, two convictions of criminal law violations were entered against me in the last year. One in RMC 11CR22176 by
J udge Howard for petty larceny of a candy bar and cough drops from Wal-Mart incident to a September 9th, 2011 arrest,
folliwng the November 30th, 2011 Trial in that matter, and, two, a criminal trespass conviction in 11CR26405 from a November
12th, 2011 arrest, following the Trial on J une 18th, 2012.

With respect to the two criminal convictions and the appeals thereto, as well as the summary eviction proceeding and appeal of
that matter (RJ C rev2011-001708 and CV11-03628) I have some 60(b) Motions filed the WDC, RMC, and RJ C, and should they
be granted and these convictions, sanctions, etc. be set aside, then under SCR 111(7)-(8), that may auger towards my having
a more probable path to regaining my law license.

I realize many of you may feel that I lack any leverage here, and that may well be true, regardless of the import of cases like
Glazier or Lippis v J ustice Court, Soldal v Cook County, Wheeler v Cross, etc., etc.

I cannot find anything very clear on whether it is permissible to seek a "global resolution" that may, to some extent, implicate
the resolution of both criminal and civil matters, and should that be tantamount to an ethical violation, I do not wish to do so
here, and, in that case, please forget I mentioned anything in that regard.
As a side note, that criminal trespass conviction stemmed from my being at the location of my former home law office after an
Order of Summary Eviction was signed (but perhaps not appropriately served prior to any lockout in accordance with NRCP
6(e), considering NRS 40.400's mandate that the NRCP apply to landlord tenant mattters, and therefore vitiating any such
lockout. Further, the validity of that Order of Summary Eviction in RJ C Rev2011-001708 (subsequently appealed to the District
Court in CV11-03628 and resulting in $42,500 in attorney's fees being awarded against me, for which I am personally
responsible) is perhaps up for debate given some of the jurisdictional bars to such an order (please see attached Motions)

There are a few 60b type basis for setting aside the Wal-Mart candy bar/cough drops petty theft conviction in 11 cr 22176:
newly discovered proof that a drivers license was provided to the arresting officer (jail property intake form and Wal-mart video
shows Coughlin providing his drivers license, however, the RSIC Officer testfied that Coughlin's failure to provide his license was
the basis for effectuating a custodial arrest, and therefore, a search incident to arrest, which resulted in a finding of some
cough drops, allegedly. However, the testimony of both the Wal-Mart LP associate and the RSIC Officers (ie, that a upc for
such cough drops did not appear on Coughlin's receipt) was expressly contradicted by the receipt provided by Coughlin (clear
error, failure to meet burden?); additionaly the failure to provide counsel required by the Sixth Amendement, where even the
merest possibility of jail time exists, may provide a void for lack of jurisdiciton basis for setting aside the candy bar/cough drop
conviction...if it is set aside, I don't want to sue Wal-Mart or anybody else, I just want to try to get my license back, mend
some fences, and move on with life while taking care to learn from my mistakes, and asking for foregiveness.

Mr. Loomis pointed out the argument that the Notice of Appeal I filed in the eviction matter Rev2011-001708 likely divesting
the RJ C of jurisdiciton to enter the summary eviction Order, and therefore, the criminal trespass case conviction may similarly
FW: Mr Coughlin
be vulnerable to a set aside, as both case involve my former home law office (and occured shortly after what was essentially a
divorce from a 5 year relationship).

Thank you for any consideration you may give this writing.

I am fairly opposed to resolutions of the criminal matters that include any "obey all laws" and "180 days suspended sentence"
types of conditions, not because I think the prosecutors or the system is unreasonable, but...well, I have upset a good number
of members of law enforcement and I may wish to leave the area for an extended time (only if legally allowed to do so), and
for the same reasons (and because I already have two convictions) I would prefer not to go into Mental Health Court (though I
greatly respect J udge Breen), in addition to some other more personal reasons that relate to my father, whom I love.
However, my whole life has been somewhat of a Mental Health Court or diversion program with my Dad in it, as he has been
involved in physician diversion programs for those with mental health problems and substance abuse issues, and that has
resulted in a tough love approach for years, taken to an extreme, which, at times, has seemed to complicate, if not derail
entirely, my attempts to address the various issues that I face.

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 8/30/12 1:46 PM
1 attachment
Order (8-28-12).pdf (147.4 KB)
Good Af t er noon Mr . Coughl i n,
At t ached i s an Or der t hat per t ai ns t o you.
I have not yet r ecei ved an answer t o t he Compl ai nt t hat I f i l ed agai nst you. Coul d you l et me
know when you expect t o f i l e an Answer ?
Thank you.
RE: Motion to Dismiss SBN v. Coughlin
Pat r i ck Ki ng
Sent: Mon 9/24/12 3:10 PM
Dear Mr. Coughlin,

You have an ongoing obligation to cooperate with the State Bar. Your refusal to provide the state bar with your present
address for service of process is not acceptable. I understand you have a copy of the Complaint filed against you. You
are required to file a verified Answer to the complaint. If you do not have a copy of the complaint you may pick up a copy
of the complaint at the Northern State Bar Center. If you refuse or fail to file an Answer the matter may proceed against
you on a default basis.

If the matter proceeds against you on a default basis, the allegation in the Compliant may be accepted as true. I would
encourage you to take this matter seriously.

Sincerely,


Sent: Monday, September 24, 2012 2:50 PM
To: Laura Peters; Patrick King; David Clark; tsusich@nvdetr.org
Subject: FW: Motion to Dismiss SBN v. Coughlin

Dear Clerk of the Court of the State Bar of Nevada Peters,

Please note the forwarded Motion to Dismiss SBN v Coughlin filed on September 17th, 2012 (I also will forward the one I sent
just prior to midnight of the 17th, of Setpember 2012. Please let me know anything I should know about the Hearing
RE: citation to legal authority?
tomorrow, September 25th, 2012 on and only on the matters limited to those set forth in the N,. S. Ct ORder of june 7th, 212
in 60383 and pursuant to my SCR102(4)(3) Petition 61426. Please make sure Bar counsel is aware of the extent to which you
previously guaranteed me that no service of any Complaint in SBN V Coughlin sent by certified mail would be deemed
effectuated by the SBN where based merely upon the return to sender of the first attempt to so serve me under SCR 109 such
a Complaint, which you indicated you had just received as returned to sender on September 10th, 2012, and where you further
indicated that I could serve any filings on my behalf thereafter upon the SBN via electronic means including fax or email.

Sincerley,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: tsusich@nvdetr.org; patrickk@nvbar.org; davidc@nvbar.org
Subject: Motion to Dismiss SBN v. Coughlin
Date: Tue, 18 Sep 2012 00:02:54 -0700

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Tue 9/25/12 10:49 AM
September 25, 2012


This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG 12-
0434.
A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada, 9456
Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR 109.

The reason I have requested your physical address is to facilitate our ability to contact you. The mail that was
sent to you via certified mail was returned to the State Bar as unclaimed.


To: Patrick King
Subject: citation to legal authority?

Mr. King, this is the first I have heard of you wanting a physical address for me. Can you indicate, in writing, when, if ever the
SBN has requested as much and whether it was in writing or verbal? Do you have an legal citation for your contentions.

Thanks,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Tue 9/25/12 11:34 AM
Cc: David Clark (DavidC@nvbar.org); Laura Peters (LauraP@nvbar.org)
9-25-2012

Dear Mr. Coughlin,

Please be advised that the State Bar of Nevada will not accept or file any documents submitted by you via e-
mail. Further, if you intend to send or serve me with a copy of a document it will not be accepted if sent via e-mail.

Sincerely,


To: Patrick King


Thanks,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Mon 10/01/12 9:31 AM

Please file an Answer to the Disciplinary Complaint that was filed against you. I do not want to move forward on a default
basis. However, if you do not file an Answer, I will have no other option.

Thank you.


To: Patrick King

RE: Notification of Electronic Filing in IN RE: DISCIPLINE OF
ZACHARY COUGHLIN, No. 60838

Thanks,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Mon 10/08/12 9:42 AM
Important !!!

Dear Mr. Coughlin

Please understand that you were personally served with the Complaint on September 25, when you came to office of the

state bar, in Reno. As such, you are required to file a verified answer to that Complaint within 20 days from the date you
were

served.

If you fail to Answer the Complaint, I will move the matter forward to a Formal Disciplinary Panel on a default basis. If
that

Occurs the panel will accept all of the allegations in the Complaint as true. In your latest e-mail you acknowledge the

Complaint by asserting that it is combo package.. I encourage you to file your answer to the

Complaint.


Sent: Saturday, October 06, 2012 5:02 AM
To: Patrick King; Laura Peters; tsusich@nvdetr.org
Subject: FW: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: patrickk@nvbar.org; davidc@nvbar.org; laurap@nvbar.org; barcounseloversightcommission@gmail.com; tsusich@nvdetr.org
Date: Sat, 6 Oct 2012 04:48:59 -0700
Dear Bar Counsel, Clerk of Court of the SBN, and Chairman Susich,

Please let me know if you must have my physical address ( I have indicated that due to my being a domestic violence victim (I
was granted two protection orders) and the fact that local law enforcement obviously enjoys playing "kick the can" with me
(and given the complete paucity of support from the SBN, etc., I would rather just meet your process server somewhere or
have you sent whatever it is you want to serve via certified mail. However, Bar Counsel King has already, in writing, stipulated
to an extension to file and answer or response to whatever it the SBN wishes to serve as far out as 20 days from the
September 25th, 2012 date that Mr. King purports to have served my on (Please see that written indication below, which I am
relying upon, in addition to the various statements made by Clerk of Court Peters), and provide me an indication, via email, or
fax, preferably (I prefer communications that bare digital stamping and content reproduction and do not understand why the
SBN is not an electronic filer) if my understanding is incorrect. Please note again my request that the hearing called for by the
Court's J une 7th, 2012 ORder and SCR 111(8) and SCR 102(4)(d) and any Proceeding/Hearing?Trial that would stem from a
SCR 102 or SCR 105 Complaint by the SBN, as a complainant, be bifurcated, and not consolidated, given the basic due process
notions of fairness that would be violated by so consolidating such. Please provide a response in writing detailing the SBN and
NNDB's position with respect to the legal foundation for your claim that either the Court's J une 7th, 2012 Order or something in
the SCR's allows for such a "consolidation".

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Date: Fri, 5 Oct 2012 09:43:15 -0700
From: efiling@nvcourts.nv.gov
Subject: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
Supreme Court of Nevada
NOTICE OF ELECTRONIC FILING
Notice is given of the following activity:
Date and Time of Notice:
Oct 05 2012 09:43 a.m.

Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
Docket Number: 60838
Case Category: Original Proceeding
Document Category: Proof of Service
Submitted by: Zachary Barker Coughlin, Esq.
Official File Stamp: Oct 05 2012 09:42 a.m.
Filing Status: Accepted and Filed
Docket Text: Filed Proof of Service Proof of Service of Petition on Bar Counsel and the NNDB
The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-Filing website.
Click here to log in to Eflex and view the document.
Electronic service of this document is complete at the time of transmission of this notice. The time to respond to
the document, if required, is computed from the date and time of this notice. Refer to NEFR 9(f) for further
details.
Clerk's Office has electronically mailed notice to:
Zachary Coughlin
No notice was electronically mailed to those listed below; counsel filing the document must serve a copy of the
document on the following:
Patrick King
This notice was automatically generated by the electronic filing system. If you have any questions, contact the
Nevada Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.

otification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
10/05/12
Reply

efiling@nv courts.nv.g ov

Add to contacts
To zachcoughlin@hotmail.com
Sent: Fri 10/05/12 9:43 AM
Date and Time of Notice: Oct 05 2012 09:43 a.m.

Clickhere to log in to Eflex and view the document.
details.
Zachary Coughlin
Patrick King

To see messages related to this one, group messages by conversation.
9/25/12
Reply

RE: Notification of Electronic Filing in IN RE: DISCIPLINE OF
ZACHARY COUGHLIN, No. 60838

Patrick King

Add to contacts
To Zach Coughlin, David Clark
Sent: Tue 9/25/12 10:49 AM
September 25, 2012


This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG 12-
0434.
A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada, 9456
Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR 109.



Sent: Mon 10/08/12 9:56 AM
To: Zach Coughlin (zachcoughlin@hotmail.com); David Clark (DavidC@nvbar.org); Laura Peters
(LauraP@nvbar.org); barcounseloversightcommission@gmail.com
(barcounseloversightcommission@gmail.com); tsusich@nvdetr.org (tsusich@nvdetr.org)
Mr. Coughlin was served with the Complaint by regular and by certified mail. In an abundance of caution Mr. Coughlin
was personally served with the Complaint on September 25, 2012 when he came to the office of the state bar. Mr.
Coughlin has not yet filed a verified Answer to the Complaint.


To: Patrick King; David Clark; Laura Peters; barcounseloversightcommission@gmail.com; tsusich@nvdetr.org

Dear Bar Counsel, Clerk of Court of the SBN, and Chairman Susich,

Please let me know if you must have my physical address ( I have indicated that due to my being a domestic violence victim (I
was granted two protection orders) and the fact that local law enforcement obviously enjoys playing "kick the can" with me
(and given the complete paucity of support from the SBN, etc., I would rather just meet your process server somewhere or
have you sent whatever it is you want to serve via certified mail. However, Bar Counsel King has already, in writing, stipulated
to an extension to file and answer or response to whatever it the SBN wishes to serve as far out as 20 days from the
September 25th, 2012 date that Mr. King purports to have served my on (Please see that written indication below, which I am
relying upon, in addition to the various statements made by Clerk of Court Peters), and provide me an indication, via email, or
fax, preferably (I prefer communications that bare digital stamping and content reproduction and do not understand why the
SBN is not an electronic filer) if my understanding is incorrect. Please note again my request that the hearing called for by the
Court's J une 7th, 2012 ORder and SCR 111(8) and SCR 102(4)(d) and any Proceeding/Hearing?Trial that would stem from a
SCR 102 or SCR 105 Complaint by the SBN, as a complainant, be bifurcated, and not consolidated, given the basic due process
notions of fairness that would be violated by so consolidating such. Please provide a response in writing detailing the SBN and
NNDB's position with respect to the legal foundation for your claim that either the Court's J une 7th, 2012 Order or something in
the SCR's allows for such a "consolidation".

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

Date: Fri, 5 Oct 2012 09:43:15 -0700
Subject: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
Date and Time of Notice:
Oct 05 2012 09:43 a.m.

10/05/12
Reply

Click here to log in to Eflex and view the document.
details.
Zachary Coughlin
Patrick King

otification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
efiling@nv courts.nv.g ov

Add to contacts

To zachcoughlin@hotmail.com
Sent: Fri 10/05/12 9:43 AM
Date and Time of Notice: Oct 05 2012 09:43 a.m.

Clickhere to log in to Eflex and view the document.
9/25/12
Reply

details.
Zachary Coughlin
Patrick King

To see messages related to this one, group messages by conversation.
Patrick King

Add to contacts
To Zach Coughlin, David Clark
Sent: Tue 9/25/12 10:49 AM
September 25, 2012

RE: motion to dismiss attached

This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG
12-0434.
A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada,
9456 Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR
109.



Sent: Mon 10/08/12 11:39 AM
Dear Mr. Coughlin,

As I have explained, the Complaint against you has been served. Your verified answer is due by Tuesday September 9,
2012. You should file a verified answer to the complaint.


To: Patrick King; Laura Peters; tsusich@nvdetr.org
Subject: FW: motion to dismiss attached

Dear Bar Counsel,

Please note that the Motion to Dismiss that I filed in SBN v. Coughlin, on September
17th, 2012, has gone unopposed, and therefore, should be granted...Mr. King was
telling me the other day: "Zach, you don't take responsibility for your actions and that
is why things don't work out for you..." I wonder, does Mr. King take responsibility
for his actions here, or lack thereof, in failing to oppose my Motion to Dismiss? It will
be interesting to see.

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

To: patrickk@nvbar.org; tsusich@nvdetr.org
Subject: motion to dismiss attached
Date: Mon, 17 Sep 2012 23:59:42 -0700

Zach Coughlin
PO BOX 3961
Reno, NV 89505
RE: pending final disposition of disciplinary
proceedings....language SCR 111(7) versus SCR 111(8) and
the J une 7th, 2012 Order of the NV. S. Ct.
Tel 775 338 8118
Fax 949 667 7402
Sent: Wed 10/10/12 9:44 AM
Dear Mr. Coughlin,

When you met with me and David Clark to discuss the Complaint and the process. Mr. Clark explained that since there
was a conviction, the sole issue to be determined was the extent of the discipline. Not if you committed the crime,
since that was already determined beyond a reasonable doubt. It is that context that we are reading the rule. Not that
the state bar is precluded from bringing additional allegations against you. Any additional allegations that have not
already resulted in criminal convictions will need to be proved by clear and convincing evidence. As such, at the
hearing, on the issue of your criminal convictions, the only issue for the panel to decide is the appropriate discipline.
However, I will be providing evidence as to the other allegations in the Complaint. The Panel will decide if the state bar
has met its burden of proof as to those allegations in the complaint, other than the criminal convictions, and will decide
the appropriate discipline on the totality of the case, including mitigating and aggravating factors that may be presented
at the hearing.

As such, I do not intend bifurcate these proceedings. I think to do so would cause unnecessary confusion, undue time and
expense and would be prejudicial to the administration of justice.

I am advised that you have not yet filed an Answer to the Complaint. I have sent you a notice of intent to proceed on a
default basis. The hearing date is expected to be Wednesday November 14, 2012. I will be sending you a notice of
hearing, along with a list of witness, and evidence that I intend to introduce at the hearing.


Sent: Wednesday, October 10, 2012 6:18 AM
To: tsusich@nvdetr.org; David Clark; Laura Peters; Patrick King
Subject: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and the J une 7th,
2012 Order of the NV. S. Ct.

Dear Chairman Susich, Bar Counsel, and Clerk Peters,

I am writing formally request a bifurcation of sorts, consiering:
SCR 111(7). Suspension on certification. Upon the filing with the supreme court of a petition with a certified copy of proof of the
conviction, demonstrating that an attorney has been convicted of a serious crime, the court shall enter an order suspending the attorney,
regardless of the pendency of an appeal, pending final disposition of a disciplinary proceeding, which shall be commenced by the
appropriate disciplinary board upon referral by the supreme court. For good cause, the court may set aside its order suspending the
attorney from the practice of law.

I think Bar Counsel's argument that the "proceeding" call for in the Court's J une 7th, 2012 Order (which quotes SCR 111(7)
may include some SCR 105 Complaint (ie, a SBN v. Zachary B. Coughlin Complaints bringin in all sorts of matters, including
pending criminal actions, and wearing pajamas, and Orders by J udges purporting to take away this or that right of Coughlin's to
practice this or that in some court (an Order which Patrick King reference to me and Chief Bar Counsel Clark, and, apparently,
to a client of mine in early May 2012 (the client is the only other place I have ever heard of such an unpublished "Order"
purporting to have said effect) despite the dictate against Bar Counsel's doign so in SCR 121 (the SCR 11 Petition was not even
filed at that point, and one has to wonder if some deal between that client, Bar Counsel, and the new attorney that client can
now magically afford was worked out, with nothing said of any torts that client committed against Coughin, etc., etc., much
less criminal law violations, which Coughlin just put up with).

But my point is, Bar Counsel King points ot the "pending final disposition of a disciplinary proceeding" language of SCR
111(7)...which is quoted in the Court's J une 7th, 2012 ORder (though I feel Bar Counsel is taking the quote out of context and
ignoring the express language of SCR 111(7) in making this argument that the "pending final disposition of the disciplinary
proceedings" language in the Court's J une 7th, 2012 Order entitles Bar Counsel to file a SBN v. Coughlin Complaint deny
Coughlin that afforded under SCR 111(8) (which the J Une 7th, 2012 Order cites to as well), and, given Coughlin's Petition in
61426, filed and served on August 13th, 2012 (the service of which was consented to or waived by Bar Counsel King and Clark
where they directed Clerk Laura Peters to sign "Proof of Receipt" thereof on August 13th, 2012...), Coughlin is now entitled to
an "immediate hearing" pursuant to SCR 102(4)(d), and SCR 111(10).

The Court's J une 7th, 2012 Order reads, in relevant part: "Pursuant to SCR 111, temporary suspension and referral to the
appropriate disciplinary board are mandatory when an attorney has been convicted of a "serious" crime, which includes theft.
SCR 111 (6)-(8). Accordingly, pursuant to SCR 111 (8), we refer this matter to the appropriate disciplinary board for
the institution of a formal hearing before a hearing panel in which the sole issue to be determined shall be the extent of the
discipline to be imposed. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend Zachary B. Coughlin from the
practice of law in Nevada, pending final disposition of the disciplinary proceedings." Note that the Order says "pending
final disposition of the disciplinary proceedings" . It does not say "pending final disposition of an SCR 105 Complaint filed by
SBN as the complainant (see Ching). And, in fact, SCR 111(8) clear that up further,

I give Patrick King credit for making a crafty argument, but its just not colorable. I am so used to this with Pat by now, he
plays dumb in a way that screw one out of their due process, but it is clear he knows exactly what he is doing, that crafty
sum'itch.

SCR 111(8): "8. Referral to disciplinary board. Upon receipt of a petition filed under subsection 4 of this rule, demonstrating that an
attorney has been convicted of a serious crime, the supreme court shall, in addition to suspending the attorney in accordance with the
provisions of subsection 7 of this rule, refer the matter to the appropriate disciplinary board for the institution of a formal hearing
before a hearing panel in which the sole issue to be determined shall be the extent of the discipline to be imposed."

But the clearest expression of authority to defeat Bar Counsels stated goal of "combining" the Hearing required by the Court's
J une 7th, 2012 Order and the Supreme Court Rules with some SCR 105 (or SCR 102, natch) style SBN v. Coughlin Complaint
that Bar Counsel wishes to file is found in SCR 111(7): "the court shall enter an order suspending the attorney...pending final
disposition of a disciplinary proceeding, which shall be commenced by the appropriate disciplinary board upon
referral by the supreme court."

And, right there, Bar Counsel's attempt to combine these affairs must fail. That's the thing, though...the phrase "commenced
by the appropriate disciplinary board". It does not say "commenced by the State Bar of Nevada as a complainant, under
Ching, filing an SCR 105 Complaint...It just does not say that. SCR 111(7), rather, reads "which shall e commenced by the
appropriate disciplinary board".

So, to sum it up Bar Counsel's attempts combine these must fail in light of the following:
"SCR 111(8): "the supreme court shall...refer the matter to the appropriate disciplinary board for the institution of a formal hearing
before a hearing panel in which the sole issue to be determined shall be the extent of the discipline to be imposed."

SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a disciplinary proceeding,
which shall be commenced by the appropriate disciplinary board upon referral by the supreme court."

However, Bar Counsel and the Disciplinary Board should recognize the import of SCR 111(7)-(8) and refuse to allow Bar
Counsel to "combine" or consolidate, or "fail to bifurcate. What Bar Counsel is thinking of is SCR 105(2):. "Commencement of
formal proceedings. Formal disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar.
Records
The complaint shall be sufficiently clear and specific to inform the attorney of the charges against him or her and the underlying conduct
supporting the charges."

However, SCR 111(7) and SCR 105(2) are entirely different animals. In one, SCR 111(7) calls for: "the court shall enter an order
suspending the attorney...pending final disposition of a disciplinary proceeding, which shall be commenced by the
appropriate disciplinary board..."

In the other, it is Bar Counsel doing the "commencing" of SCR 105(2):. "Commencement of formal proceedings. Formal disciplinary
proceedings are commenced by bar counsel filing a written complaint in the name of the state bar...."

The distiction and diferences are revealed in the Supreme Court Rules by whom is doing the "commencing" and just what it is they are
"commencing", ie, a "formal proceeding (in the case of SCR 105(2), or a "dsiciplinary proceeding",

There is a difference, and that difference entails bifurcating things or refusing to consolidate these affairs, and I am formally making
that request upon the Board here now.

Sincerely,

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
Sent: Thu 11/01/12 9:03 AM
Hearing

Your disciplinary file is being sent to the printer to be copied. I am having the documents bate stamped and the
printing company will mail them to you.

Formal proceeding are taking place at the state bar office so you will not be permitted in the building.

Sent: Tue 11/13/12 2:41 PM

November 13, 2012

Good Afternoon Mr. Coughlin,

Please be advised that your response to the Bar Complaint and motion was received and filed in this morning.

I look forward to seeing you at the hearing tomorrow.

Sincerely,


3 13 12 To 11 13 12 0204 All Emails From Patrickk@Nvbar - Org King SBN

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