Leslie, Jim

From: Kandaras, Mar

Sent: Thursday, December 13, 2012 10:20 AM
To: Leslie, Jim
Subject: RE: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and
8/17, 2012 to Coughlin in rcr2012-065630
Imporance: High
Jim:
I believe that you should send this. Supreme Court Rule 104(a) authorizes State bar counsel to investigate all matters
involving possible attorney misconduct or incapacity called to bar counsel's attention, whether by grievance or both.
This potentially involves misconduct (violation of law) and incapacity.
Mary Kandaras
Deputy District Attorney Civil Division
Washoe County
775 - 337 - 5723 direct phone
-----Original Message----
From: Leslie, Jim
Sent: Wednesday, December 12, 2012 5:11 PM
To: Kandaras, Mary
Subject: RE: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012 -065630
Thanks, please do. He came to our office after my email to you and caused a disturbance. We called the police, but he
fled before they arrived.
jim
-----Original Message----
From: Kandaras, Mary
Sent: Wednesday, December 12, 2012 3:17 PM
To: Leslie, Jim
Subject: RE: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012-065630
I will have to review this tomorrow and get back to you.
Mary Kandaras
Deputy District Attorney Civil Division
Washoe County
775 - 337 - 5723 direct phone
-----Original Message----
From: Leslie, Jim
1
The below email from Mr. Coughlin contains a reference at the end of the first paragraph to a website containing a video
clip from the movie Cape Fear. Please advise whether any action is required of our office or yours regarding this
possible veiled or indirect threat of violence against attorneys in this office by Mr. Coughlin.
Sent: Wednesday, December 12, 2012 2:59 PM
To: Kandaras, Mary
Subject: FW: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012-065630
Mary:
Please review my transmittal to Patrick King at the bar, below, and let me know if I should do anything else from a civil
perspective.
Thanks,
James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defender's Office
350 South Center Street
Fifth Floor
Reno, NV 89509
1-800-762-8031
Direct Dial: 775-337-4828
Fax: 775-337-4856
Email: jleslie@washoecounty.us
The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL
INFORMATION, are legally privileged, and are intended for use and review only by the party sending same and the
intended reCipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly prohibited. If you received
this communication in error, please immediately notif us at 775-337-4800 to arrange return of the original
transmittal. Thank you.
-----Original Message----
From: Leslie, Jim
Sent: Wednesday, December 12, 2012 2:49 PM
To: 'patrickk@nvbar.org'
Subject: FW: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012 -065630
Mr. King:
Thank you,
James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defender's Office
350 South Center Street
Fifh Floor
Reno, NV 89509
2
1-800-762-8031
Direct Dial: 775-337-4828
Fax: 775-337-4856
Email: jleslie@washoecounty.us
The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL
INFORMATION, are legally privileged, and are intended for use and review only by the party sending same and the
intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly prohibited. If you received
this communication in error, please immediately notify us at 775-337-4800 to arrange return of the original
transmittal. Thank you.
-----Original Message----
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Wednesday, December 12, 2012 2:35 PM
To: Leslie, Jim; Bosler, Jeremy; Dogan, Biray; Goodnight, Joseph W; Fortier, Chris; Tuttle, Steve; Kandaras, Mary; Young,
Zach; skauc@reno.gov; wongd@reno.gov; kadlicj@reno.gov; complaints@nvbar.org; cvellis@bhfs.com;
je@eloreno.com; patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; laurap@nvbar.org; skent@skentlaw.com;
mike@tahoelawyer.com; eifert.nta@att.net; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com;
fflaherty@dyerlawrence.com
Subject: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012 -065630
The Trial yesterday in RCR2012-065630 featured extended discussions regarding the failure of the WCPD, Dogan, and
Leslie, to turn over discovery propounded by DDA Young in the form of cd's featuring 911 calls DDA Young provided to
the WCPD on 8/13/12 and 8/17/12 ... And the heavy hitters were there, too (Elliot Sattler) ..... despite numerous written
requests from Coughlin that the WCPD do so, and multiple trips to the WCPD personally by Coughlin to pick such
materials up, and despite more flip flopping on their story by Leslie and Dogan regarding whether they ever gave
Coughlin some package of materials responsive to Coughlin's request for his "file" ... But, Jim Leslie is stuck with the
7/27/12 date he mentions in his email, then he is stuck with what his recent email wherein he purports to have therein
digitally transmitted Coughlin his "file", which obviously does not include the cd's of 911 calls (the one's DDA Young took
up an enormous amount of court time playing, over and over (well, Young only played over and over the paricular calls
he felt were strongest for his case and most prejudicial, claiming some "cutting room floor mishap" for the reoccurrence
of certain calls, arguing that such a "happy accident" justified playing them again and again, at ever increasing volumes,
etc., etc.). Apparently, I am here to subsidize Young's baby making, just like I was with Ms. Gorman, as a continuance of
prejudicial length of afforded to the State where none was forthcoming to Coughlin, despite Leslie and Dogan's
obstructionist tantrums, ones of a quality that would. I remember when my life featured happy moments like the birth
of twins ... but that was before your leviathan legal system wrecked shop on my existence. What, sir, shall be my
compensation? Do you mind if I put my arm around .... http:/tinyurl.com/bgmlfdr
This is a formal grievance against Dogan, Leslie, Bosler, Young ... etc.
If Svengali/Diann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order them, he
better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of 911 calls DDA
Young gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-065630, and clearly, any packet from 7/27/12 wouldn't have
them (not to even get into the flip flopping contradictory accounts by Leslie and Dogan as to who gave Coughlin the
packet, or who didn't or blah blah blah) ... and certainly Leslie email below only contained a 57 page pdf...way to close to
the 12/11/12 trial date, and containing materials Coughlin had never been given before .... so much easier, Jimmy Sleazy
to email the client a "digital transmittal" proving what you gave and when" .... but, no, that would make it so hard to
3
fudge the accounts of what was contained therein, or who handed what to whom, or who failed to pick up this or that,
or Dogan's slippery nonsense:
"From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:
Attached are the discovery materials in the above-referenced case that you had requested and we had made an
additional copy of for you in response to your request. Please note that the July 27, 2012, cover letter was for your pick
up and you never picked it up. Note also that the July 27,2012, packet encloses a copy of the April 17, 2012, hand
delivery transmittal of the very same documents which you received.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front
desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of our file.
No response to this transmittal is required from you.
James B. Leslie, Esq."
So, while Dogan states on 7/27/12 in 65630 "Your Honor, I have never even spoken with Judge Dorothy Nash
Holmes" ... he coyly fails to indicate whether he spoke with anyone with the RMC, Marilyn Tognoni, included, or why his
2/28/12 fax to Coughlin was so insistent that it was "Lake's Crossing's Bill Davis, Ph.D." who must conduct the
"Competency Evaluation", or how it was Judge Clifton's 2/27/12 Order for Competency Evaluation could have possibly
known and included Judge Elliott as the "randomly assigned judge" to that Competency Case in CR12-0376 (Judge Elliott
on Committee to Aid Abused Women's Board, (CAAW) .. .Judge Elliott presiding over Coughlin's wrongful termination
lawsuit against WCDA's Office ECR Partner, Washoe Legal Services, its Executive Director Paul Elcano, and CAAW, in
CVll-01955.. .Judge Elliott fails to disclose conflict or recuse himself, Judge Elliott manages to "randomly" be assigned
Coughlin's two criminal appeals from RMC convictions (the Wal-Mart "candy bar" petty larceny leading to a 6 months, so
far, temporary suspension of Coughlin's law license in 11 cr 22176 in the RMC, then crll-2064 in the appeal Judge Elliott
canned based upon a civil statute requiring a down payment for the preparation of transcripts and Elliott's contention
that he need not address the merits of Coughlin's appeal given the lack of a written transcript (Coughlin paid for the
audio cd, and its not even clear that the RMC is a court of record anyways, and the RMC distributes to defendants
instructions sheets and enforces "house rules" regarding the preparation of transcripts that require one utilizing the
services of RMC "oficial transcriptionist Pam Longoni (whom hung up on Coughlin twice, and refused to prepare the
4
transcript in 11 cr 22176/crl1-2064, failed to return emails/faxes, etc.)" and where the RMC refused to even give
Coughlin the audio recording for some time, insisting Coughlin could merely have it made available to Longoni. ... Oh,
Coughlin didn't get no continuance from Judge Howard in that 11 cr 22176 (even where he was wrongfully evicted in
Rev2011-001708 (now on appeal in 60331 and 61383) on 11/1/11, then wrongfully arrested on 11/13/12 in 11 cr 26405
(now feature in 61901, 62104, 54844, 60302, 60317, etc .. ) and incarcerated between 11/13/12 and 11/15/12, no
continuance for the 11/30/12 Trial in 11 cr 22176, despite an agreement in writing with City Attorney Pamela Roberts
(whom put on perjured testimony by three witnesses where she possess a video and other evidence conclusively
proving that Coughlin did provide his driver's license to RSIC Oficer Crawford ... and where Robert's prosecuted based on
an arrest for a misdemeanor by tribal officers where NRS 178.1255 bars such an arrest, and where Wal-Mart's Thomas
Frontino and Roberts herself admit no citizen's arrest was effectuated .... so, about that RPC 3.8 violation ... ). Then there
is the appeal in cr12-1262 that Judge Elliott, again, was "randomly" assigned from the conviction by RMC Judge William
Gardner in 11 cr 26405 based upon the criminal trespass complaint signed by Richard G. Hill, Esq. (opposing counsel in
the summary eviction from Coughlin's former home law office in rjc rev2011-001708, presided over by Judge Sferrazza,
though Hill and his associate Casey D. Baker, Esq. fax, on October 17th, 2011 to Judge Clifton (who was not Chief Judge
at the time, or anything) an Emergency Ex Pare Motion for Inspection of Coughlin's Law Office, and where in his
October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as "moot" Coughlin' 11/17/12 Motion to Set Aside
the 11/13/12 Order following Summar Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on
10/25/12, on the condition that Coughlin deposit a rent escrow of $2,275 with the RJC (though Judge Sferrazza admitted
later on the record on 11/7/12 that the RJC Judges had a meeting wherein they all had to agree that Coughlin was
absolutely correct that the RJC was violating Nevada law in having an unpublished "house rule" corollary to JCRLV 44
requiring such rent escrow deposits in landlord tenants matter here JCRCP 83 had not been followed in that the RJC had
not published and had approved by the N. S. Ct. any such deviation from the statutory remedies set forth in NRS 40 and
118A. Judge Elliott managed to torpedo that appeal of the criminal trespass conviction stemming from the criminal
complaint and custodial arrest at Coughlin's former home law office by co-signing RMC Judicial Assistant Lisa Wagner's
and the RMC's nonsense about not having received Coughlin's Notice of Appeal timely under NRS 189.010. The proof of
delivery fax confirmation indicates otherwise, Lisa. And regardless. the conveniently timed arrest of Coughlin on
6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion for New Trial in that matter, and the kited, dated 7/10/12
jailhouse Notice of Appeal by Coughlin, and the curiously failure to grant Coughlin tier time in the interim while Judge
Gardner manageed to push through his 7/11/12 Order Denying Coughlin's Motion for New Trial, is all the more reason
to apply consternation to Judge Elliott's work on the appeal on CR12-01262.. Then there is Judge Linda Gardner being
Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out of the Mental Health Court based upon Sharon
Dollarhid, Rene Biondo, and Breen and the MHC's own breach of contract (if they provide program materials,
acceptance, and a contract that list certain medications as disallowed, how is it they can claim non-compliance or
"failure to abide" by the rules for taking a medication not listed therein? Don't ask WCPD Joe Goodnight or Jennifer
Rains ... they know what side their bread is buttered on .... MH12-0032 ... so DDA Young tries to jam through a trial in
063341 on May 7th, 2012, despite the mandatory stay in NRS 178.405 and the then still pending Order for Competency
Evaluation in rjc 2012-065630 from the clandestine status conference Dogan and Young never quite seem to refute
happening on 2/27/12 ... 0h, and Judge Clifton, then DA Dorothy Nash Holmes, and Judge Linda Gardner were all co
workers once upon a time, working closely with then Sparks City Attorney/prosecutor Steven Elliott, whom worked for
the law firm of the father of the Panel Chair for Coughlin's 11/14/12 SBN v. Coughlin formal Disciplinary Hearing in
NG12-0204, 0434, 0435 (the last two being grievances against Coughlin filed, in part, by RMC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal trespass case against Coughlin before him in 11 CR
26405 ... even where Judge Gardner's sister Judge Linda Gardner's April 2009 Order sanctioning Coughlin was cited by
WLS's Elcano as the sole basis for firing Coughlin, and where Coughlin filed a Mandamus Petition in 54844 challenging
those sanctions, and where ng12-0435 was one of three grievances forming the 8/23/12 SCR 105 Complaint against
Coughlin (strangely ... the Wal-Mar "candy bar" petty larceny conviction and the formal hearing for the "sole purpose" of
determining Coughlin's punishment for such required by SCR 111(8) and the Court's 6/7/12 Order got particularly short
shrift in the 8/23/12 triple grievance numbered SCR 105 Complaint by Bar Counsel Pat "Patty Ice" King, a/k/a Pat Salieri,
whom wants no part of explaining his statements to Coughlin during the 3/26/12 appearance at the SBN by Coughlin, for
the sole purpose of taking King up on his offer to let Coughlin review the materials submitted along with the grievances
(therein King claimed to have received grievances against Coughlin from three different Judges .... though, by 3/26/12, it
couldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge Nash Holmes and the WCSO and WCDA
o
impermissibly confiscating Coughlin's smart phone without a warrant or court order and well after the end of the period
to do a search incident to arrest (the arrest was 2/27/12 for some pastiche of summary plenary civil criminal contempts
statuts that Judge Nash Holmes whipped up ... though she avoid NRS 22.030 and definitely there wasn't no affidavit
sign in' by 01' RMC Marshal Harley for alleged conduct in a restroom or restroom stall, which assuredly was not "under
the watchful eye of the court" or "in the immediate presence" of the court .... so much easier for Bar Counsel to feed
Judge Nash Holmes the "clear and convicing evidence" standard from Schaefer required to prove an ethical violation,
have here copy and paste some RPC's into a second bite at the apple and more than 10 days later (civil statute, NRS
22.010, NRCP and JCRCP 59 allow sua sponte amending within 10 days, no 12 days ... 2/27/12 to 3/12/12 .... void Order of
3/12/12 by Judge Nash Holmes, so, sorry Patty Ice, nice try, no SCR 111(5) "an Order or conviction is conclusive proof of
guilt and I don't recognize Claiborne as binding authority because it makes my job harder .... " .. ..
Thank You Jim for continuing to prevaricate in writing, your recent email combined with some, uh, other materials that
have been culled, will surely be helpful in exposing you for the fraud that you are. And Biray Dogan too ... Oh, by the way,
that 11/7/12 fax confirmation page or proof of faxing? How is that coming along, because I need to see it from you. My
records show absolutely no receipt of any fax of that sort, not on that day, not on any day ... which means the ball is in
your court to show how Dogan's representations to Judge Sferrazza on 11/19/12 in court were not displaying a lack of
candor to the tribunal and How Leslie Tibbals' certificate on serice therein is not fraud.
Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
"REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W.
Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS
174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or confessions made
by the Defendant or any witness, or copies thereof, within the posseSSion, custody or control of the State, the existence
of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This
request includes any video and audio recordings, including those presered on pocket recording devices, 9-1-1
emergency calls, and any dispatch logs, written or recorded, generated in connection with this case."
Jim, then there is you chiming in, in your role as "standby counsel", attempting to aid the Court and DDA Young in
coercing from me my Fifth Amendment rights at the 9:06 am mark on the transcript from 11/20/12 ("Your Honor, I'll
remind the Court that I am here to jump in in my role as standby counsel anytime the Court's feels he is dragging his
feet .... He is wasting County assets!" ... very Atticus Finch, Jim).
So, then there is Jim's 10/3/12 subpoena to Ecomm/Kelley Wood ... and given he was counsel of record until 10/22/12,
yet completely failed to turn over anything (responsive or not) in relation to that subpoena, and the fact that the entire
Suppression Motion turned on "what information the RPD received from dispatch", and the fact that the audio of the
"radio traffic" between the RPD and Dispatch on that night (or at least the portions of it I have been able to extract from
the powers that be) reveal, one, no report of a possible fight was received by RPD (they were on the scene by the time
the 11:27:11 pm text was sent to the displays in their vehicles, and the one audible "radio traffic" recording contains no
mention of anything beyond "check for possible larceny of a cell phone that just occurred, suspect still on the scene, also
reports of a loud verbal disturbance ... ". Then there is Jim and Goodnight completely whiffing on the detaining
argument, in addition to the whole "assuming we win on the pat down, make sure to oppose the notation that there
was sufficient probable cause for an arrest and search incident thereto .... ", not to mention that it was Coughlin (whose
filings Jim managed to cheerfully announce "The Public Defender's Ofice is not joining in on those fugitive
documents ... ", despite the 2/21/12 Filings by Goodnight that do just that.. .. ) that pointed out the whole NRS 171.360
basis for throwing out the search (which Jim managed to not cite to or quote from in his closing argument as the
Suppression Hearing ... where Jim did manage to ask Cory Goble questions on cross that were designed to do nothing
more than establish a citizen's arrest suficient to rebut the NRS 171.360 basis for throwing out the arrest and fruits
culled therefrom ... ).
Oh, then there is your ofice blacking out the numbers of the callers on the dispatch logs and refusing to turn over even
a redacted version of the alleged victim's call records for the time in question, thereby completely obstructing the
defendant's ability to impeach the various lies testified to by all the witnesses. And "Coach" DDA Young can tell you all
about his 40 minutes coaching sessions visible through the plexiglass in the Justice Cour lobby with Zarate, Goble,
Lichty, and Templeton, and their constant parroting (along with RPD Duralde) of "prosecutor buzzwords" ("willfully
withheld", "report from dispatch of a possible fight", "my training and experience", "detained", "I don't remember who
made the call", "I can't remember which one of my friends it was who was with me", etc., etc.) Also, the WCPD practice
of blacking out locations and addresses sure makes it difficult to establish inconsistencies between testimony and the
reports/Witness Statements or otherwise utilize them for impeachment purposes.
So, now today, we get this Jim Leslie email with all it's revisionist history ... which only contradicts the position Leslie and
Dogan have taken that Coughlin already picked up this 7/27/12 packet (at first Dogan claimed to have personally handed
it to Coughlin, then changed his story 2 minutes later and said he saw Leslie personally hand it to Coughlin .... and Dogan
asserts to the Court at the 11/27/12 Hearing in rcr2012-065630 that he has never spoken with Judge Dorothy Nash
Holmes (see materials regarding clandestine status conference of 2/27/12 and subsequent fallout with Judge Nash
Holmes of 2/27/12 a couple hours after Dogan secured his 2/27/12 1:31 pm Order for Competeny Evaluation in 065630
from Judge Clifton).
The SBN v. Coughlin Complaint of 8/23/12 specifically mentions the arrest of 1/14/12 that theis 065630 case is based on,
in addition to the 063341 iPhone arrest, and RJC Judicial Secretary Lori Townsend sent Coughlin's 2/21/12 in 065630 to
the SBN, and offered to send Coughlin's 2/15/12 filing in 063341 to the SBN ... and Judge Nash Holme's 3/12/12 Order in
11 TR 26800 mentions Coughlin quoting "rock lyrics" in a filing as a basis for her transmogrifing a "simple trafic
citation" to a "formal disciplinary hearing on an ethics violation" wherein she quotes the Schaefer standard for an ethical
violation that Bar Counsel had fed her earlier in the day ... and that window between the 1:00 pm noticed start time of
the traffic citation trial in 11 tr 26800 and the 3:30 pm eventual star time includes the 1:25 pm courthouse sanctuary
doctrine violating service upon Coughlin (by RMC Marshal Joel Harley, on behalf of WCSO Deputy Machen, hired by
Richard G. Hill, Esq., at whose office Coughlin was retaliated against by RPD Sargent Tarter with the three traffic citations
shortly after Coughlin reported to Tarter the admissions regarding bribery by Richard G. Hill, Esq. by RPD Officer Chris
Carter, Jr .... and Marshal Harley was serving the Order to Show Cause for the 3/23/12 Hearing in the appeal of the
summary eviction from Coughlin's former law office (where RPD Carter made the trespass arrest now detailed in N. S.
Ct. case 61901), on behalf of Deputy Machen, in the conference room within the Courtroom B of the RMC, despite
Coughlin, an efiler, having already been sered it). However, the only filing by Coughlin that could be said to quote "rock
lyrics" is the 2/21/12 filing in Dogan's case 065630 (the one where Dogan had appeared as attorney of record then failed
to show up for a hearing on 2/13/12, then retaliated against Coughlin for Coughlin's 2/21/12 filing in 065630 by moving
for a Competency Evaluation and basically doing absolutely nothing on the case for the next 9 months besides raping
from Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach Young at the 4/19/12 hearing in
CR12-0376 (one of 3 criminal appeals Judge Elliot was "randomly" assigned in which Coughlin is a party ... to go along
with the wrongful termination suit by Coughlin that Judge Elliot presided over in CV11-01955 wherein Coughlin sued
CAAW and WLS, despite Judge Elliot Sitting on CAAW's Board, and where Judge Elliot, the Panel Chair at Coughlin's
formal disciplinary hearing of 11/14/12, and Washoe Legal Service's Paul Elcano all went to Stanford together, and
where Judge Elliot worked for Panel Chair John Echeverria's father's law firm, Echeverria and Osborne). Then there is
Linda Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from Mental Health Court in MH12
0032, where the MHC's Rene Biondo and Sharon Dollarhide lied about what medications were listed as accepted or not
in the materials provided by Goodnight and or the MHC along with the contract entered into with Coughlin, whom was
accepted into the MHC. Then there is WCPD Joe Goodnight and Jennifer Rains refusal to file anything directed towards
enforcing the MHC's contract with Coughlin, wherein they both demonstrated they know what side their bread is
buttered on and indicated "there just isn't a basis for seeking reconsideration of Judge Breen's Order". Judge Peter
Breen, MD.
7
Funny how Dogan did not state to Judge Clifon that he never spoke with anyone else at the Reno Municipal Court about
Coughlin .... including Marilyn Tognoni ... but, rather Dogan just indicated he never spoke with Judge Nash Holmes, in his
best innocent little boy voice that he cops when he isn't busy tittering away with Jim Leslie in the spectator area during
the 11/19 and 11/20 Trial in 063341 (where he failed to apprise Judge Sferrazza of the fraud attendant to his earlier
attestations regarding proof of service (by fax no less) of his 11/7/12 Motion to Quash Coughlin's Subpoena ....
Also, its a bit strange how Dogan and the WCPD redact or black out the names of the RPD Officers and Dispatch
Operators beginning on page 16 of the 56 page file Jim Leslie finally emailed me today titled "Coughlin Discovery 911
Case", which, as is their wont, he and Dogan have continued to change their stories about whether they had or had not
provided to me already until the last possible minute before trial, whereupon, with a Trial date of December 11th, 2012
in rcr2012-065630, Jim Leslie finally emails me a 56 page pdf purporting it to be my "file". One wonders where any
audio recordings, dispatch recordings, 911 call recordings or other media are any why Leslie and Dogan did not provide
them. Coughlin appeared at the WCPD's Office today and asked for the hard copy of his file, yet was told by front desk
receptionist "Paula" (of course, no last name provided) that she "spoke with an associate" and they told her that Jim
Leslie had already provided Coughlin his file and that he, therefore, would not be given the hard copy. "Paula"
eventually seemed to have to admit that the misleading use of the term "associate" actually did not connote her having
spoken with an attorney about the matter ... but rather Linda Gray, whom has been curiously silent as to the apparent
misconduct attendant to her admitting that she did not mail out any written notice to Coughlin of the August 6th, 2012
"combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over that fact by sending Coughlin a note about
how he "saved the day" with his "advocacy" ... skipping past the part about how the client, Coughlin, was not noticed on
the hearing in any matter, much less in writing .... Leslie later refused to indicate with any specificity whatsoever how he
"knew" Coughlin had been noticed on the 8/6/12 hearing in writing ... and RJC Judges are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things ...
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have continued in your way (similar to how you
approached the rcr2011-063341 case where Joe Goodnight, Esq. was counsel of record until you had him removed on
7/16/12, the morning of Trial. .. afer Mr. Goodnight and I have completed a video conference final trial preparation at
4:30 pm on Friday, July 13th, 2012 while I was in custody (pursuant to an arrest on July 3rd, 2012, ordered by RPD
Sargent Kim Bradshaw, she of the 1/12/12 custodial jaywalking arrest along with RPD Sargent Paul Sifre) .... Things fall
through the cracks, Mr. Leslie, when you place a gag order on the associates you claim to supervise, then stubbornly,
petulantly, and retaliatorily refuse to work the cases you have snatched back from your associates .... Simiiarly, WCPD
Fortier's email to me of February 6th, 2012 may have contributed to Mr. Dogan's confusion in failing to attend the
Hearing on Feburary 13th, 2012, which begat my filing of February 21st, 2012, which begat Mr. Dogan's procurring the
February 27th, 2012 Order for Competency Evaluation, which begat the 5 day summary incarceration for
summary/plenary/criminal/civil/transmogrified disciplinary hearing on an ethics violation/what is jurisdiction? Order by
RMC Judge Nash Holmes on 2/27/12 at 4:40 pm ... which begat NG12-0434, and probably 0435 (the SBN v. Coughlin SCR
105 Complaint of 8/23/12).
However, Mr. Dogan, you are not of the hook just because Jim Leslie places a gag order on you. Mr. Leslie sent this
email today with a 56 page pdf file purporting to be my "file". I, as now a former client, have rights to "my file". I have
requested my file in writing from your office on numerous occasions, and given your removal as counsel of record on
11/22/12 (amazingly Mr. Dogan probably managed to say 200 words on a case that he had been counsel of record on for
nearly a year, and had not managed to file a single document in that case, RCR2012-065630, and had managed to get
upset that a client would take issue with his missing the 2/13/12 Hearing, even though WCPD Fortier's 2/6/12 email
makes clear, the matter was assigned to Mr. Dogan at that point, and he had already sat down and discussed the case
with Coughlin for over one hour on or about February 8th, 2012, where Coughlin went to check in with Mary Watson,
whom was then represented by WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and
demanded they breathalyze her client. They did, she was taken into custody.
8
So, after sitting down with Dogan for at least an hour and discussing various things, some including matters related to
the case he was then attorney of record on RCR2012-065630, the February 13th, 2012 court date (Dogan and Coughlin
have conflicting views as to what was agreed upon and the applications of NRS 178.388).
NRS 178.388 provides that the defendant must be present at arraignment, trial, and sentencing and provides that the
defendant may waive his appearance when certain conditions are met.
Its kind of odd how Judge Clifton (whose attached bio indicates he has deep and longstanding ties to the domestic
violence industry infrastructure) knew instantaneous to signing the Order for Competency Evaluation of 2/27/12 at 1:31
pm that the matter would be randomly assigned to District Court Judge Steven Elliot (also a lifelong prosecutor with
deep and longstanding ties to the domestic violence industrial complex, and a member of the Committee to Aid Abused
Women's (CAAW, one of the named defendants in the wrongful termination lawsuit Coughlin brought and over which
Judge Steven Elliot presided in CV11-01955, where he failed to point out his per se conflict of interest to plaintiff
Coughlin at any time, and where he ultimately pulled out just about every wrinkle in the insufficiency of service and or
process and or serice of process (a movie showing a non party over 18 years of age sering a senior paralegal at
Washoe Legal Serices, whose Executive Director Paul Elcano went to Stanford with Judge Elliot and the Panel Chair of
Coughlin's 11/14/12 Formal Disciplinary Hearing before the State Bar of Nevada, John Echeverria in the late 1960s ... and
Judge Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne Board of Directors, in addition to
being a former ass
In CVI1-01955, Coughlin sued his former employer Washoe Legal Services, whose Executive Director Paul Elcano went
to Stanford in the late 1960s with Judge Steven Elliot and John Echeverria, the Panel Chair of Coughlin's 11/14/12 Formal
DiSCiplinary Hearing before the State Bar of Nevada .. and Judge Elliot worked at John Echeverria's father's law firm,
Echeverria and Osborne, and Judge Elliot served on the Board for CAAW, and was a prosecutor as the Sparks City
Attorney.
Also, Mr. Leslie, while the 56 page pdf you finally sent me (gosh, was it that hard to click "attach", load a 2 mb pdf file
and hit "send" on an email to me? No debatin', no arguing about whether Leslie and Dogan left the package at the desk,
whether Dogan already gave it to Coughlin, or whether Dogan then changed his story and said Leslie gave it to Coughlin,
whether Coughlin already picked it up, no claims by Jessica the Receptionist of anyone kickin' furniture ... nothing like
that, just a digitally verifiable means of ascertaining what you transmitted and when ... was that so hard? Heck, Jim, you
could probably just email those ECOMM recordings too ... and if attachment size is an issue, sign up for a
www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive functionality, and up to 100
mb attachments via plan email, and over 25 free gb of storage on the Skydrive, etc., etc ... ). But its Leslie finally sent the
S6 page "client's file" on or about 12/7/12, yet he failed to include the insipid Motion of 11/26/12 by DDA Young
(wherein, just after Judge Clifton finishes telling Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even
think about the other two RJC shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just not relevant
to this proceeding" ... and anytime Coughlin would point out specific basis for undertaking a recusal or conflict analysis vis
a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or the WCDA, Judge Clifton would say "your're losing
me ... your're losing me ... " as if Coughlin was speaking in tongues all the sudden ...
So, while Coughlin is reportedly not even allowed to email DDA Young about cases not even before Judge Clifton, or
something like that .. . DDA Young is able to get an unnoticed, ex parte, emergency Motion to Prho
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Sincerely.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail,com
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:
Attached are the discovery materials in the above-referenced case that you had requested and we had made an
additional copy of for you in response to your request. Please note that the July 27, 2012, cover letter was for your pick
up and you never picked it up. Note also that the July 27, 2012, packet encloses a copy of the April 17, 2012, hand
delivery transmittal of the very same documents which you received.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front
desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of our file.
No response to this transmittal is required from you.
James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defenders Office
350 South Center Street
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