DOUGLS W JONES

Cha/rman
Mr ZachCoughlin
1471 East Ninth StrCe
Reno, NV 8C512
Dear Mr Ccughlin:
11c L NcVL
COMMISSION ON JUDICIAL DISCIPLINE
PO. Box 48
Carson City, Nevada 89702
Telephone (775) 687-4017 Fax (775) 687-3607
Website: http://www.judicial.state.nv.us
December 19, 2012
DAvID F SARNOWSK|
Oenera/Conse/and
Exec0||zeDi|ec|or
You need to be aware that ''U are not able to accept complaint forms via facsimile or e
mail. Enclosed with this correspondence is a Verifed Statement of Complaint form that needs to
be completed, signed and forwarded via U.S. mail in order for this offce to open a complaint
against a judicial ofcer. Aiso crdosed is a brochure con
`
erning this Commission.
If you believe that your cornplaint properly lies within the Commission's jurisdiction,
please fil out the Statement of Cotnplaint form as clearly and concisely as possible, sign the
form, and complete the verification. Once yom verification is complete, please return the form to
this ot1ice at the above address. AdcFtionai inli.mition may be obtained on the Commission's
website by visiting www.judicial.statcO\.us.
Thank you for your interest the 1e\'ada judiciary.
SincCrely,
-'
David F. Sarnowski
(Jenerai Counsel and Executive Director
DF5/dai
Enclosures as statrd
(NSrORev. -Io) L 326 ..
NEVADA COMMISSION ON JUDICIAL DISCIPLINE
VERIFIED STATEMENT OF COMPLAINT
(Please Cleary Type fPrnt #Requird Inforation)
Par I: General Information
-

Date of This Form: _

L;
Name of Person Completing This Form: .'

Mailing Address of Person Completing This Form: -----
.
:.-

Dayime Telephone Number To Contact You: (
.
Part II: Specific Information Regarding C .l
Name of Nevada Judicial Officer (Only One

. .

Name of Court or Judicial District Involved:

Case Number (Please Include Al Lettem and Numbers):

This Case Is (Select One): _Pending In Trial Court _On Appeal Not Pending or Closed
Nature of Complaint (Select One): _I Have Attached My Own Explanation Page(s)
I Have Used The Standard Complaint Supplementary Form
Code of Judicial Conduct Section(s) Violated, If Known [(Example: Canon 38(4)]: ____ _
Part III: Qbligatlons Qf Complainant
hereby acknowledge the following agreements and/or waivers:
Consent To Investigate. expressly authorize the Commission, staf and contractors, to investigate my
complaint and take any and all actions, including interiewing any relevant witness or request by subpoena or
otherise of documentar evidence and to verify the statements have made herein to be true and correct (or
if stated to be on information and belief, that the statements are believed in good faith to be true and correct).
agree to promptly supplement and amend this complaint if learn that the facts have alleged are materially
incorrect. understand that deliberately misstating the truth of any material fact could subject me to various
sanctions including, but not limited to, dismissal of my complaint, contempt or a separate action for peury.
Full Cooprtion. agree to fully cooperate with the Commission, staf and its designated contractors with
regard to my complaint. understand that even if wish to withdraw my complaint that the Commission retains
independent grounds to pursue it ard that the information contained within and attached to the complaint
becomes the property of the Commission and the Commission may pursue the complaint even if seek to
withdraw it.
Part III Obligations Of Complainant (Con't)
Ap l Waring. understand that the Commission. its staf and contractors are not an appellate cour and
that my fling of a complaint does not stay or stop any time am provided to appeal a decision disagree with
or any decision that adversely afects me. understand that must timely fle an appeal to presere those rights.
acknowledge that fling a complaint with the Commission does not and cannot presere those rights.
Legal Advice. understand that the Commission, its Commissioners, Commission staf, investigators and
contractors are precluded from giving me legal advice regarding my case or actions should be taking in my
case and understand that should require advice will seek appropriate assistance apar from the
Commission, its Commissioners, Commission staf, investigators and contractors.
Par IV: Signature and Verification of Complaint
Af ter being duly sworn, I state under penalty of perjur that I am the above-referenced complainant whose
name appears in Par I and who submitted this complaint; I know the contents thereof; and the matters set
forth in this complaint are true and correct of my own knowledge, except as to matters stated to be on
information and belief, and as to those matters are believed to be true and correct by me. I request that the
conduct set forth above or referenced in the attachments and exhibits provided with the complaint be
investigated by the Nevada Commission on Judicial Discipline.
Signature of Complainant Dated
How Do I Submit My Complaint? Wher Can I Obtain Additional Assistance? This complaint, along with any
supporting materials you may wish to submit, should be sent by mail to the: Nevada Commission on Judicial
Discipline, P.O. Box 48, Caron City, Nevada 89702. If you have questions regarding the completion of this
form, please contact the Commission on Judicial Discipline at (775) 687-017 .In addition, if you have access
to the Internet, or can obtain access at a local library or other Internet facility, the Commission's web site
located at W.judlclal.state.nv.us provides additional information to help you prepare your complaint. The
web site also includes the full and current text of the Nevada Code of Judicial Conduct and other laws,
statutes and rules governing the Commission.
0m NCJO 01 (C)-0701
(revised 10/02112)
RICHARD G. /.L
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VIA EAL ONLY patrickk@nvbar.org
Patrick King, Esq.
Assistant Bar Counsel
State Bar of Nevada
9456 Double R. Blvd.
Reno, Nevada 89521
Mr. King:
Re: Zachar B. Cougl, Esq.
Nevada Bar No. 9473
January 14, 2012
(77J)J4/488
FAX (7$) J48-J858
You and I have previously discussed Mr. Coughlin. Mr. Coughlin, due to
his mental instability, lack of integrity, and complete incompetence, constitutes a danger
to the public if he is allowed to continue to practice law. This letter i written to
discharge my and my associate's reporting obligations under RPC 8.3. Please consider
the following:
1. Rissone v. Gssin, CID-Ol341. Although not among Mr. Coughlin's
most signifcant ethical violations, it presents a good microcosm of his derelictions. Mr.
Cessin was a client of our ofce. He defrauded the plaintif, as i his modus operandi in
dealing with women. Approximately one year after judgment was entered and the case
concluded, Mr. Coughlin interjected himself in the case on behalf of Gessin, trying to
collect on a sanction award against opposing counseL It turns out that because he had
filed bankruptc, Gessin no longer owns this claim. I you look at the fle, you will see
that Coughlin appeared and then filed a bizarre "partial withdrawal" document on
December 8, 2011.
Letter to Patrick King. Esq.
January 14,2012
Page 2
Subsequent to that time, Coughlin has ben ghostwriting documents that
purport to be from Cessin, individually, and e-fling them for Gessin. He is using the
"/s/" for Gessin's signature. These are clearly not documents that are signed or
prepared by Mr. Gessin, and the fact that somebody (Coughlin) e-fles them confrms he
is ghostwriting without the required disclosure. In addition, it appears that Coughlin
has facilitated the fling of what may be a fraudulent bankuptc on behalf of Gessin.
Coughlin's lack of competence is demonstrated in the Cessin case by the fact that he
does not understand the effect on the ownership of Gessin's potential claims from
Gessin having fled a bankruptcy, (i.e., the claims now belong to the bankruptcy trustee,
not Gessin.)
A with all of the matters referenced below, I strongly suggest that you
contact the Second Judical District Court and get e-fling access to the cases mentioned
so you can look at the documents yourself. Glade Han, Esq., is opposing counsel in that
case and may be of help to you.
2. I a informed and believe that Mr. Coughlin was rtly convicted of a
theft crime in Reno Municipal Court. I am frther informed that the matter arises out of
shoplifng at Walmat. That case is presently on appeal tu the district court in case
number CRu-2064. Mr. Coughlin is representing himself.
3. Mr. Coughlin is presently facing criminal charges regarding the theft of
an iPod. That is pending in Reno Justice Court as c number RCR2011-o63341. I
have reviewed the fle. Mr. Coughlin got into some SOit of argument with his public
defender. A a result, he was referred out for a competency evaluation.
4 We represent Dr. Matthew Merliss, a physican from Chico, Califoria.
Dr. Merliss owns the property at 121 River Rock Street, Reno. Nevada. Beginning in
March 2010, the property was leased to Mr. Coughlin and his then-girlfiend. The lease
expired in Februar 2011. The girlfiend lef the community in approximately May 2011.
Dr. Merliss contacted us in approximately August 20Il to assist in evicting Mr.
Coughlin. Coughlin had not paid rent or utilities since May. He contended that there
were habitability issues Wit1 the property that justife his withholding rent. All of his
claims were decided adversely to his position at the evicton hearing. Justice of the
Peace Peter Sferazza ordered Coughlin evicted from the premises efective November 1,
2011. On that date, the Washoe County Sherif's Department performed their normal
eviction procedure: locks were changed and the eviction notice was posted on the front
door. We videotapd the home and its cntents at that time. Upon inspecon over the
neA few days, it became apparent that "somebody" w breaking into the home on a
regular basis.
On Sunday, November 13, 2011, Dr. Merliss came to town, and 1 met him
at the home on River Rock Street. A we walked through the home, it was obvious that
Letter to Patrick King, Eq.
January 14, 2012
Page 3
someone had been in there since I had last been in several days before. Dr. Merliss
discovered that the basement door was barricaded (not locked) from the inside. The
Reno Pol icc Department was summoned. They tried to coax whoever was in the
basement out, without success. After Dr. Merliss had to kick the door down, it was
disovered that Mr. Coughlin had broken in and w living in the basement. He was
arrested and is presently facing criminal trespass charges in Reno Municipal Court. See
case no. 11 CR 2640521. He is also facing a contempt motion in front of Judge Sferazza
in the eviction case. Judge Sferazza has stayed that matter pending the resolution of the
criminal trial. That trial was scheduled for Januar 10, 2012, but was continued at the
request of Mr. Coughlin's new attorey.
5. The eviction order is now on appeal to the Second Judicial District
Court. See case Cu -03628, pending in Department 7. A part of the eviction process,
a lien was asserted against the personal property that Coughlin lef behind at the home.
On November 16, 2011. Coughlin fled a motion to contest the landJord's lien in the Reno
Justice Court. The court tried to promptly set a hearing, but Coughlin refused to
cooperate in setting the matter, and the court took it of calendar. Coughlin then re
initiated that process and a hearing was held in Decmber, at which tme the court heard
evidence of Coughlin's lack of cooperation in setting the November hearing. You may
also want to contact Reno Justice Court staf, and in particular, chief derk Karen Stancil,
about Mr. Coughlin's abusive treatment of her and her staf. Afer the hearing. the court
issued an Order granting Coughlin a two-day time window to remove his personal
propert. The frst day was Thursday, December 22, 2011. Aer Coughlin was allowed
into the home that first day, he sent out an e-mail to the efct that because he had
appealed Judge Sferazza's order, he was entitled to a stay of procedings and was going
to resume living in the home. A a result, he did ver little to remove any of his personal
property that day. On Friday, December 23. 2011, after he learned, again. that his stay
had been denied, Coughlin assembled a small crew and the were able to remove a
substantial amount of his personal property. (You need to understand that Mr.
Coughlin is a hoarder. We have the photos and videos if you would like to see them.)
However, Mr. Coughlin did not get aof his propert out. For example, I counted 13 c
seats that he had somehow managed to get down into the basement.
Having failed to remove all of his belongings, Mr. Coughlin then moved
before Judge Flanagan for a temporal' restraining order to prevent the disposal of his
abandoned property in accordance with Judge Sferazza's order. Attached is Mr.
Coughlin's motion, my ofce's opposition, and Mr. Coughlin's reply. These documents
demonstrate Mr. Coughlin's complete and utter incompetence as an attorey.
On January 11, 2012, Judge Fanagan denied Mr. Coughlin's request for a
temporary restraining order. On January 12, 2011, the contractor hired to dean the
house commence work. Mr. Coughlin fagged the contractor down in trafc when he
(the contractor) was on his way to the dump with the abandoned property fom the
home. Coughlin caned the police, who arrived at the transfer station. Coughlin was
falscly asserting that the contractor had tried to run him over. He also told the police
Letter to Patrick King, Esq.
January 14. 2012
Page 4
that the contractor had stolen his possessions. After I presented the court orders to the
police, the contractor was allowed to proceed. At their instruction, I have now had a TPO
issued against Coughlin by Reno Justce Court.
However, before the contractor could get back to the River Rock house,
Coughlin was there. He had his video camera and was walking up and down the street
screaming and yelling at the police, at the contractor, and at me, when I arrived. Mr.
Coughlin ended up being arrested and taken to jail. The police informed me that
because of the number and types of contacts they have had with him, he is no longer
eligible for citations in the event of infractions.
Enclosed you will fnd a cpy of a supplemental document fled by Mr.
Coughlin on January 13. 2012, and sent to my staf and I by email fom Coughlin that
morning. Please note that the attorey designation on the frst page indicates that it is
being fled by Coughlin as appl1ant. You will note that the caption is from a diferent
case. It is unclear in which case Mr. Coughlin intended to fle this document, although,
because of the case number and the caption, it appears to have ultimately been routed to
the Carpentier case (CV08-0l709) and not the evicton appeal case (CVll-03628). I am
told that counsel in the captioned case may also be in the process of filing a bar
complaint against Coughlin.
6. When the house was secured after Coughlin's arrest, we found a crack
pipe and a bag of what appeared to be marijuana. The contractor also reported fnding a
box of pil1s and a vial of some sort. We understand Coughlin has unsuccessfully tried
the Lawyers Concerned for Lawyers program, and that he has a history of substance
problems.
7. Mr. Coughlin has fled to lawsuits against his former employer,
Washoe Legal Services. He has sued all of the board of directors and the management of
the company. Both cases have now been dismissed. Both cases demonstrate his lack of
competence. I suggest you contact Joseph Garin, Esq., in L Vegas, as he was counsel
for the defendants in that case. You may want to cntact Paul Elcano, Esq., the director
of Washoe Legal Services.
8. Mr. Coughlin has a habit of initiating cases and asking to proceed in
forma pauperis. He has done s in cases against me, my offce, my client, and Washoe
Lega Services. You wl fnd them if you run a search for Coughlin Z on the Second
Judicial District Court website. The courts that have reviewed the documents have
generally denied his requests. What is of note is that his representations in the
applications to proceed infrma pauperis are inconsistent with and contrary to the
representations that he has made to Judge Flanagan in the context of seeking a
temporary retraining order. On the one hand. he tells the court he is broke and has no
property, and on the other hand, he is telling the court that he has a great deal of
valuable property at the home that needs to be protected. This demonstrates a gross
lack of candor with the tribunals with which he deals.
Ltter to Patrick Kng, Esq.
January 14, 2012
Page 5
9. Coughlin has also tried to file a case against me, my assocate, my client,
and others, including the Reno Justice Court. I is also to be found on the website.
Judge Steinheimer has ruled that he did not comply with NRCP 8.
10. Coughlin's behavior was unusual to start, and has become more and
more bizrre during the time we have been dealing with him. He serves papers be does
not fle, and fles papers he does not serve. He consistently signs certifcates of service
that he has maiJed to us, but we have never recived anng fom him by mail. He has
posted videos of the eviction service attempts and parts of the trial on YouTube,
including some recrdings he secretly made in court with his cell phone.
11. Another example of his incompetence i that he does not understand
what orders are, and a not, appealable. He does not understand that fling a notice of
appeal divests the lower court of jurisdiction.
I am confident that once you look into this matter, you will agree that Mr.
Coughlin should not be practicing law. He is a danger to the community.
Sincrely,
/S/
Richard C. Hill
RGH:kn
Enclosures:
-Coughlin Amended Emergenc Moton for Restraining Order
-Merliss Opposition to Motion for TRO
-Coughlin Reply to Opposition to Motion for TRO
-Supplemental Reply to Opposition dated 1/13/12