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August 2rth, 2012 grievance against Jim Leslie,

WCPD
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 9/05/12 12:11 PM
To: davidc@nvbar.org; patrickk@nvbar.org; complaint@nvbar.org;
complaints@nvbar.org
Dear Bar Counsel,

Please file this as a grievance or formal complaint.

The WCPD has refused many reasonable requests I have made so far.
Additionally, I believe there is a basis for moving for a dismissal in rcr2011-
063341 given Mr. Goble's failure to show up at the last Trial Date in this
matter. Mr. Leslie continues to refuse preserve the issues for appeal.
I am that the WCPD has refused to respond in writing to my inquiries
regarding any February 27th, 2012 communication with the Reno Municipal
Court or Judge Nash Holmes. "...Also, please respond to my inquiries with
respect to whether you or anyone with your office (including Biray Dogan)
ever communicated with anyone with the Reno Municipal Court (including
Judge Nash Holmes, especially on February 27th, 2012 at or around 1:00pm,
despite the fact that your client, me, was noticed that the Status Conference
previously scheduled for that time was vacated....and despite the fact that on
that very date your associate Biray Dogan and moved for a second competency
evaluation ordered of me, apparently after meeting with DDA Young and
another person or two....and neither you nor anyone with your office has
responded to my inquiries in that regard, vis a vis, whether Judge Nash
Holmes (whom could not be found by her staff in court at that time, which
was the time schedule for the traffic trial in 11 TR 26800 on 2/27/12 at which
I was found in criminal contempt and sentenced to 5 days in jail, and for which
I have had to report that conviction to the State Bar of Nevada and the
USPTO). How is it that Mr. Dogan could get an Order signed requiring me to
have a District Court competency hearing, yet I was permitted to stand trial in
RMC 11 TR 26800? Mr. Leslie has continually jumped in on cases assigned
to Joe Goodnight or Biray Dogan and indicated to me that his supervisory
capacity allows him to do so. He has argued to the Court that my behavior in
these various cases precluded a successful Faretta canvas, then argues his
behavior for a conflict analysis is limited to just rcr2-11-0633441. That is not
just. Now, if anyone with the RMC, particularly Judge Nash Holmes or
anyone in communication with Her Honor, was present at or aware of the
import of the February 27th, 2012 clandestine Status Conference between
DDA Young and Deputy Public Defender Biray Dogan, I would like to know
about it...
On numerous occasions now I have requested, verbally and in writing, for the
WCPD to provide me whatever part of my file in RCR11-065630 that I am
permitted to have. Mr. Dogan, just recently made inconsistent statements to
me regarding whether I was ever provided such materials. In the WCPD
lobby, in person, Mr. Dogan at first indicated he was sure he himself provided
me those materials, then scoffed at the idea of providing them again, if by
chance I never actually received them. Then, Mr. Dogan shortly thereafter
changed his account, and insisted Jim Leslie provided me those materials, in
person no less..."
Please note, I filed a grievance against Mr. Leslie on August 24th, 2012, and
Mr. Leslie has had communication today with the State Bar of Nevada
indicating the Bar is unaware of that, at least to some extent.
That complaint or greivance read, in part:

"Subject:WLS Let Taitel, conflict, professional misconduct, criminal
misconduct
8/24/12
Zach Coughlin
To complaints@nvbar.org, complaint@nvbar.org
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 8/24/12 11:31 AM
To: complaints@nvbar.org; complaint@nvbar.org
Dear Bar Counsel, (omitted irrelevant material) ...Also, please add
WCPD Jim Leslie to the complaint as he has continually refused to
gather the audio cd from Milan Kreb's Protection Order extension
hearing in the July 3rd, 2012 arrest matter RCR 2012-067980, in
addition to failing to gather the July 16th, 2012 audio from the Trial
in RCR 2012-063341 to determine whether the August 29th, 2012
court date is a hearing on pre-trial motions or, in fact, a Trial, in
addition to the other misconduct Leslie has committed in my
represenation, and add Biray Dogan, whom, along with Leslie
apparently asserted to the RJC that I filed to show to a hearing in
RCR2012-065630 on August 22th, 2012, despite WCPD staff
Linda Gray admitting that she did not mail out the notice of the
hearing to me as her office had marked my PO BOX 3961 Reno
89503 address as "no longer good" and, accordingly, failed to mail
the notice, only to have Dogan assert that is was mailed, and
provide a fax of the purported notice, baring the initials "LG" at the
bottom, which Linda Gray confirmed was an indication that she
prepared the letter. Dogan has refused to apprise the Court of his
error and undue the prejudice to me brought by making me appear
to be negligent and absentee. Further, Dogan and Leslie continue
to try to combine hearings in these three cases to an impermissible
extent."

Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmail.com

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