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Note by Coughlin: though this is the first page of Formal Hearing Exhibit (FHE1)
in the SBN's 2/13/13 version of the ROA (actually, this page is illegibly reporduced
therein...) there is not sticker or other indication marking such as Exhibit 1
(owing to the fact that such sticker had been placed on
a blank page thereof.
.,
1.1 Rule .Competence. A lawyer shall provide competent
representation to a client. Competent representation requires the legal
knowledge, skill, thoroughness and preparation reasonably necessary for
the representation.
1.2 Rule .Scope of Representation and Allocation of Authority
Between Client and Lawyer.
Subject to paragraphs (c) (a) and (d), a lawyer shall abide by a client's
decision concerning the objectives of representation and, as required by
Rule 1.4, shall consult with the client as to the means by which they are to
be pursued. A lawyer may take such action on behalf of the client as is
impliedly authorized to carry out the representation. A lawyer shall abide by
a client's decision whether to settle a matter. In a criminal case, the lawyer
shall abide by the client's decision, after consultation with the lawyer, as to
a plea to be entered, whether to waive jury trial and whether the client will
testify.
A lawyer's representation of a client, including (b) representation by
appointment, does not constitute an endorsement of the client's political,
economic, social or moral views or activities.
A lawyer may limit the scope of the representation (c) if the limitation is
reasonable under the circumstances and the client gives informed consent.
A lawyer shall not counsel a client to engage, or (d) assist a client, in
conduct that the lawyer knows is criminal or fraudulent, but a lawyer may
discuss the legal consequences of any proposed course of conduct with a
client and may counselor assist a client to make a good faith effort to
determine the validity, scope, meaning or application of the law.
3.1 Rule .Meritorious Claims and Contentions. A lawyer shall not
bring or defend a proceeding, or assert or controvert an issue therein,
unless there is a basis in law and fact for doing so that is not frivolous,
which includes a good faith argument for an extension, modification or
reversal of existing law. A lawyer for the defendant in a criminal
proceeding, or the respondent in a proceeding that could result in
incarceration, may nevertheless so defend the proceeding as to require
that every element of the case be established.
1700
( 3.3 Rule .Candor Toward the Tribunal.
A lawyer shall not knowingly: (a) Make a false statement of fact or law to a
(1) tribunal or fail to correct a false statement of material fact or law
previously made to the tribunal by the lawyer;
Fail to disclose to the tribunal legal (2) authority in the controlling
jurisdiction known to the lawyer to be directly adverse to the position of the
client and not disclosed by opposing counsel; or
Offer evidence that the lawyer knows to be (3) false. If a lawyer, the
lawyer's client, or a witness called by the lawyer, has offered material
evidence and the lawyer comes to know of its falsity, the lawyer shall take
reasonable remedial measures, including, if necessary, disclosure to the
tribunal. A lawyer may refuse to offer evidence, other than the testimony of
a defendant in a criminal matter, that the lawyer reasonably believes is
false.
A lawyer who represents a client in an adjudicative (b) proceeding and
who knows that a person intends to engage, is engaging or has engaged in
criminal or fraudulent conduct related to the proceeding shall take
reasonable remedial measures, including, if necessary, disclosure to the
tribunal.
The duties stated in paragraphs (a) and (b) continue (c) to the conclusion
of the proceeding, and apply even if compliance requires disclosure of
information otherwise protected by Rule 1.6.
In an ex parte proceeding, a lawyer shall inform the (d) tribunal of all
material facts known to the lawyer that will enable the tribunal to make an
informed decision, whether or not the facts are adverse.
3.4 Rule .Fairness to Opposing Party and Counsel. A lawyer shall
not:
Unlawfully obstruct another party's access to (a) evidence or unlawfully
alter, destroy or conceal a document or other material having potential
evidentiary value. A lawyer shall not counselor assist another person to do
any such act;
Falsify evidence, counselor assist a witness to (b) testify falsely, or offer
an inducement to a witness that is prohibited by law;
Knowingly disobey an obligation under the rules of a (c) tribunal except for
an open refusal based on an assertion that no valid obligation exists;
In pretrial procedure, make a frivolous discovery (d) request or fail to make
reasonably diligent effort to comply with a legally proper discovery request
by an opposing party;
1701
( In trial, allude to any matter that the lawyer does (e) not reasonably believe
is relevant or that will not be supported by admissible evidence, assert
personal knowledge of facts in issue except when testifying as a witness, or
state a personal opinion as to the justness of a cause, the credibility of a
witness, the culpability of a civil litigant or the guilt or innocence of an
accused; or
Request a person other than a client to refrain from (f) voluntarily giving
relevant information to another party unless:
The person is a relative or an employee or (1) other agent of a client; and
The lawyer reasonably believes that the (2) person's interests will not be
adversely affected by refraining from giving such information.
3.5 Rule .Impartiality and Decorum of the Tribunal and Relations
With Jury.
A lawyer shall not seek to influence a judge, juror, (a) prospective juror or
other official by means prohibited by law.
A lawyer shall not communicate ex parte with a (b) judge, juror,
prospective juror or other official except as permitted by law.
Subject to the limitations imposed by this Rule or (c) by law, it is a lawyer's
right, after the jury has been discharged, to interview the jurors to
determine whether their verdict is subject to any legal challenge. A lawyer
shall not communicate with a juror or prospective juror after discharge of
the jury if the juror has made known to the lawyer a desire not to
communicate, or the communication involves misrepresentation, coercion,
duress or harassment. The scope of the interview should be restricted and
caution should be used to avoid embarrassment to any juror or to influence
his or her action in any subsequent jury service.
A lawyer shall not engage in conduct intended to (d) disrupt a tribunal.
Before the jury is sworn to try the cause, a lawyer (e) may investigate the
prospective jurors to ascertain any basis for challenge, provided that a
lawyer or the lawyer's employees or independent contractors may not, at
any time before the commencement of the trial, conduct or authorize any
investigation of the prospective jurors, through any means which are
calculated or likely to lead to communication with prospective jurors of any
allegations or factual circumstances relating to the case at issue. Conduct
prohibited by this Rule includes, but is not limited to, any direct or indirect
communication with a prospective juror, a member of the juror's family, an
employer, or any other person that may lead to direct or indirect
communication with a prospective juror.
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3.5A Rule .Relations With Opposing Counsel. When a lawyer
knows or reasonably should know the identity of a lawyer representing an
opposing party, he or she should not take advantage of the lawyer by
causing any default or dismissal to be entered without first inquiring about
the opposing lawyer's intention to proceed.
4.1 Rule . Truthfulness in Statements to Others. In the course of
representing a client a lawyer shall not knowingly:
Make a false statement of material fact or law to a (a) third person; or
Fail to disclose a material fact to a third person (b) when disclosure is
necessary to avoid assisting a criminal or fraudulent act by a client, unless
disclosure is prohibited by Rule 1.6.
4.4 Rule .Respect for Rights of Third Persons.
In representing a client, a lawyer shall not use (a) means that have no
substantial purpose other than to embarrass, delay, or burden a third
person, or use methods of obtaining evidence that violate the legal rights of
such a person.
A lawyer who receives a document relating to the (b) representation of the
lawyer's client and knows or reasonably should know that the document
was inadvertently sent shall promptly notify the sender.
8.1 Rule .Bar Admission and Disciplinary Matters. An applicant for
admission to the bar, or a lawyer in connection with a bar admission
application or in connection with a disciplinary matter, shall not:
Knowingly make a false statement of material fact; (a) or
Fail to disclose a fact necessary to correct a (b) misapprehension known
by the person to have arisen in the matter, or knowingly fail to respond to a
lawful demand for information from an admissions or disciplinary authority,
except that this Rule does not require disclosure of information otherwise
protected by Rule 1.6.
8.2 Rule .Judicial and Legal Officials.
A lawyer shall not make a statement that the lawyer (a) knows to be false
or with reckless disregard as to its truth or falsity concerning the
qualifications or integrity of a judge, adjudicatory officer or public legal
officer, or of a candidate for election or appointment to judicial or legal
office.
A lawyer who is a candidate for judicial office (b) shall comply with the
applicable provisions of the Code of Judicial Conduct.
,
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8.4 Rule .Misconduct. It is professional misconduct for a lawyer to:
Violate or attempt to violate the Rules of (a) Professional Conduct,
knowingly assist or induce another to do so, or do so through the acts of
another;
Commit a criminal act that reflects adversely on the (b) lawyer's honesty,
trustworthiness or fitness as a lawyer in other respects;
Engage in conduct involving dishonesty, fraud, (c) deceit or
misrepresentation;
Engage in conduct that is prejudicial to the (d) administration of justice;
State or imply an ability to influence improperly a (e) government agency
or official or to achieve results by means that violate the Rules of
Professional Conduct or other law; or
Knowingly assist a judge or judicial officer in (f) conduct that is a violation
of applicable rules of judicial conduct or other law.
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'110 'I :1 !(O'Q ;
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AUG 2:3 2012
STATE
STATE BAR OF NEVADA
Case No: NG120204, NG120435 and NG120434
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,
Complainant,
vs.
ZACHARY B. COUGHLIN, ESa.,
Bar No. 9473
Respondent.
COMPLAINT
PLEASE TAKE NOTICE that pursuant to Supreme Court Rule ("SCR") 105(2) a
VERIFIED RESPONSE OR ANSWER to this Complaint must be filed with the Office of Bar
Counsel, State Bar of Nevada, 9456 Double R Boulevard, Ste. B, Reno, Nevada, 89521,
within twenty (20) days of service of this Complaint.
addressed in SCR 109.
Procedure regarding service is
Complainant, State Bar of Nevada ("State Bar"), by and through its Assistant Bar
Counsel Patrick O. King, is informed and believes as follows:
Zachery Coughlin ("Respondent"), Bar number 9473, is a member of the State Bar of
Nevada admitted on March 25, 2005. Respondent's date of birth is September 27, 1976.
The address that Respondent has on file with the State Bar of Nevada, in accordance with
Rule of Professional Conduct ("RPC") 79(1)(a) is Post Office Box 3961. Reno NV 89505.
Respondent engaged in acts of misconduct warranting the imposition of professional
discipline.
The State Bar alleges as follows:
1.
Multiple grievances were received by the Office of Bar Counsel between Ihe
period of January 14 and March 15, 2012. concerning Respondent
Due to the serious
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1 allegations of misconduct, grievance files were opened and an investigation was initiated by
2 Assistant Bar Counsel Patrick King.
3 2. Respondent was advised of the grievances via U.S. mail, e-mail and by a brief
4 meeting with Mr. King at the State Bar Office in Reno. Respondent did not cooperate with
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the investigation and rather than respond to the grievances as requested, Respondent sent
non-responsive and disparaging e-mails.
3. Respondent has not made a request to be placed on disability status, nor has
he acknowledged that he may have mental infirmity, illness, or addiction.
4. The investigation of the grievances against Respondent shows a serious
pattern of misconduct.
5. On September 9, 2011, Respondent shoplifted a candy bar and cough drops
from a Wal-Mart store with an approximate value of fourteen dollars ($14.00). On November
30, 2011, Municipal Court Judge Kenneth R. Howard found Respondent guilty of the offense
of Petit Larceny, a violation of RMC 8.10.040. Respondent appealed the judgment of
conviction. The judgment of conviction was affirmed on appeal. See Exhibit 1.
6. During the trial Respondent's conduct was so disruptive that Judge Howard
found Respondent in direct contempt of Court and sentenced him to serve three (3) days in
jail. See Exhibit 2.
7. On August 20,2011, Respondent was arrested on a second larceny charge for
allegedly stealing a cell phone. Those charges are currently pending in Reno Justice Court.
8. Respondent was again arrested on January 13, 2012, for allegedly abusing 911
emergency services, a gross misdemeanor.
9. On February 21, 2012, Respondent filed a document entitled. Notice of
Entry of Plea of Not Guiltv, Waiver of Right to Arraignment: Motion to Dismiss
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( 1 in one of his pending criminal matters, Case No. RCR-2012 065630, City of Reno v. Zachary
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Coughlin. The document clearly shows Respondent's unprofessional, disruptive conduct,
and lack of respect for the court and opposing counsel.
10. Respondent was arrested on November 13, 2011 by Reno Police Department
and charged with trespassing, a misdemeanor, for which he was later convicted.
11. The circumstances leading to the above-mentioned arrest are as follows: at an
eviction hearing Justice of the Peace Peter Sferrazza ordered that Respondent vacate the
home he was renting effective November 1, 2011. After the locks were changed and the
eviction notice was posted on the front door the owner, Dr. Merliss, discovered that someone
had broken into the home and was barricaded in the basement. The Reno Police tried to
coax whoever was in the basement to open the door. Dr. Merliss was forced to kick open the
door where the Reno Police found Respondent. Respondent had broken into the home and
determined to be without merit. The motion, on its face, demonstrates that Respondent lacks
competence to practice law.
13. Once Respondent was evicted, an order was obtained to remove his
belongings from the home. Respondent interfered with the contractor who was hired to
remove Respondent's personal belongings. The police were called and after talking with
Respondent they recommended that he find something else to do. Respondent refused to
follow their advice and was subsequently arrested by the Reno police.
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(1 14. In the case of City of Reno vs. Zachary Barker Coughlin, Case No. 11 TR
2 26800 21, a trial was held on a traffic citation issued to Respondent. The matter was called
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at approximately 3:00 p.m. and concluded without a verdict at about 4:30 p.m. after the court
held Respondent in criminal contempt of court for his behavior and activities committed in the
direct presence of the court during trial.
15. In a March 12, 2012 Order, Municipal Court Judge Dorothy Nash Homes found
by "clear and convincing evidence" that Mr. Coughlin committed numerous acts of attorney
misconduct. See Exhibit 3. Judge Holmes explained in her Order that after Respondent
served his five-day contempt of court sanction imposed by the court on February 27, 2012,
Respondent fax-filed to the court a 224-page document. Judge Holmes found that the
document contained rambling references to his personal life and was incoherent.
16. In her Order, Judge Homes found by clear and convincing evidence that
Respondent violated Rule of Professional Conduct ("RPC") 1.1(Competence), RPC 1.3
(Diligence), RPC 3.1 (Meritorious Claims and Contentions), RPC 3.2 (Expediting Litigation),
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RPC 3.3(a) (Candor toward the Tribunal), RPC 3.4(e) (Fairness to Opposing Party and
Counsel), RPC 8.4 (c) (Engaging in Dishonesty, Fraud, Deceit or Misrepresentation) and
RPC 8.4(d) Engage in conduct that is Prejudicial to the Administration of Justice).
17. Respondent filed Affidavits of Poverty in Support of his Motion to Proceed
Informa Pauperis, wherein he fails to disclose that he is a licensed attorney and instead
under Employment and Self-Employment he identifies himself as a "Jack of All Trades".
18. Despite a claim of poverty in the above mentioned affidavits, Respondent told
the Court that his incarceration for contempt would adversely affect his clients.
19. On March 22, 2012, Respondent appeared at the Reno Municipal Court
wearing (smiley face) nannel pajamas. Respondent became argumentative and Marshals
were called to ask him to leave.
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25. On April 10, 2009, District Judge Linda Gardner of the Second Judicial District
2 Court executed an "Order After Trial," in case No. DV08-01168. In that case, Respondent
3 represented the Defendant/Counter Claimant. In her Order Judge Gardner explained
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Respondent's inappropriate behavior in part as follows:
The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic and
disrespectful presentation at trial; Mr. Coughlin's inability to understand a balance
sheet; his failure to conduct discovery and his lack of knowledge with regard to
the rules of evidence and trial procedure. All of this was compounded with a
continuously antagonistic presentation of the case that resulted in a shift from a
fairly simple divorce case to a contentious divorce trial lasting an excessive
amount of time.
27. In light of the forgoing Respondent violated RPC 1.1 (Competence); RPC 1.2
(Diligence); RPC 3.1 (Meritorious Claims and Contentions); RPC 3.3 (Candor to the
Tribunal); RPC 3.4 (Fairness to Opposing Party and Counsel); RPC 3.5 (Impartiality and
Decorum of the Tribunal); RPC 4.1 (Truthfulness in Statements to Others); RPC 4.4
(Respect for the Rights of Third Persons); RPC 5A (Relations with Opposing Counsel); RPC
8.1 (Disciplinary Matters); RPC 8.2 (Judicial and Legal Officials); and RPC 8.4 (Misconduct).
WHEREFORE, Complainant prays as follows:
1. That a hearing be held pursuant to Nevada Supreme Court Rule 105;
2. That Respondent be assessed the costs of the disciplinary proceeding
pursuant to Supreme Court Rule 120(1); and
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3. That pursuant to Supreme Court Rule 1 02, such disciplinary action be taken by
2 the Northern Nevada Disciplinary Board against Respondent as may be deemed appropriate
3 under the circumstances.
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Respectfully submitted this 2 b day of August. 2011.
STATE BAR OF NEVADA
DAVID A. CLARK, BAR COUNSEL
By: -jJD
Patrick O. Bar Counsel
Nevada Bar No. 5035
9456 Double R. Blvd., Ste. B
Reno, NV 89521
6
0006
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IN TilE MUNICIPAL COURT OF THE CITY OF RENO
COUNTY OF WASHOE. STATE OF NEVADA
ONE SOUTII SIERRA STREET, RENO, NY 89505
P.O. nOI 1900, R.no, NY 89505 PIIONE (775)33"*-2190 FAX (715)33"*-J824
v.,
DEFENDANT: COUGHLIN, ZACHARY
Court C .. eM: II CR 11176 11
"lIencylll: RSICPIICII0617
DOB: 09117/ 1916
"ctidenllll:
Bookingi' : 15953
II ENCH TRIAL
8
RENell rRIAL
a
919/1011
FORMAL COMPLAINT FILED WITII TilE COURT
Sto!UJ: OP
Lanau.&e: ENG LI
10/1011011 TilE D[fE."fDANT ,\PPEARED, WAS EXPLAINED 1115IlIER RIGHTS BY TilE JUDGE AND INDICATED nlAT
ItElSItE UNDtRSTOOD Til EM COMPLETELY.
I I/JOII01 I CITY'S EXIIIBIT MARKED/AD.\fITTF.D I,
11IJ01l011 PRESENT IN COURT t'OR filE CITY or RENO: PAM ROBERTS AND FOR TilE DEFENSE: PRO PER
OITen"" 0<: 09/091101 I
Arr ... , Ot: 09/09/10 II
PI"&:
I IIJOII01 I rotal . rY
IIIJOII011 - GUII. rY
I
Fine
fee ( IIEM.DV.<l F.lIIV.l OF. rTP.wrrF) .. aI
,\Jlhllonll l r eel
'\'1pcrvm1 n r '\uh" lf.
f(ct " O'IC
n'IL ,, [r \r: 1I1JOO ca ,"" ,nly:
)1\0 00
--. --- -----.- ---
1
.. '

t., I, H" I
JJil Days:
0
Su' pcndcd O.y. : 0
J 6O.00
0
0
10.00
10.00
0
H' w) \111 ,
- - - - . ,,"- ,J ... __ r.
) i -. :, t t
" 'f' I I I" I I
'.. t I
1712
-'"
... 'd,(,'j'A
IPt.I.\N
C
E: n.
... ,,,now IS l.OCATED ON TilE fiRST Fl.oOR OF filE RENO MUNICIPAL
COlJRr, ONE soum
SIF.RRA ST. RENO. NV (71S11H.1l90, 01:
nalance:
6:01 .... 111/01:00 .... (lilturd.,)
1'1"", Proof 01:
nol"""c:
Completed 01:
. '0. Jo, 10 II
FAILURE TO COMPLY w
m
l TIlE CONDmON!! Of' RAil. AS DESCRIIIED IN nns ORDER W
ltL RF.sULT IN TIlE ISSlJA. ... CE OF A
FAILURE TO COMPLY W
i\RRANr OR IMMF.OIATf. ,\RRF.ST AND INCARCERATION FOR CONTEMP1' OF COlJRT AND/OR RAIL
REVOCAnON. FOR FIJRTIlER INFORM
AnON, CONT,\CT TIlE SF.NTF.NCE COMPLIANCE W
INDOW
LOCATED ON OlE fIRST
fLOOR OF 'OlE RENO MUNICIPAL COURT, ONE SOlJTII SIERRA ST. RENO. NV ('H
) JJ422?O.
nlE OEFENDM
n SIIALL APPEAR AS ORDF.RED FOR ALI. REVIF.W
S AND SHALL COOPERATE FIJI.!. Y w
m
l TIlE
RAII.lFFAA.MRSIIALS AND AtL COURT sr AFF.
TIlE DEFENDANT SIIAlL ATTEND AtL REVIEW
S. COURT APPP',\RANCES AND COlJRTORDERED PROGRAMS ON riM
E AND
,\I,COIIOt AND DRlJG FREP..
ntE DEFENOANT SIIA!.L KNOW
IIISIlIER COliRT DATE AND MMNTAIN CONT,\CT W
ITIllIISillER AITORNEY.
PRIOR TO CIIANGING 1IIs/IIF.R ADDRESS OR PIIONE NUMBER. TIlE DEFENOANl' SHALL NOnFIY TIlE COURT OF SUCH
CIIANGF..
I'll '111' Ill,:
\ ';"'f-;,-:Ti-t 1.-... p-
l'nnC 1)I,t.:
I"l\ ...
Ne .. , Pm"r 0.:

0
0
0
9
,
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",to IJI:H.NIlMH SII,II.I. IIU'ORT .. 1. Y. I JR IJPON REI.F.,ISE FRO.\( ).1/1.. \ ./rfrE" Sr."I'ENCI; CO.\IPI.I,INCE WI:'1DOW
FOR ORIE:'HMION ANU nlEIIEMTER ,IS OHEN ,IS IJIRliCfElJ IIY TilE RENO nl,IRSII"L DIVISION.
f ,III.liRIO TO no so WII.!. RESULT IN TilE ISSI/,\NCIi Of A f,IILlJRE ro COMI'L Y W,IRRM>IT ,IND INC,IRCERA nON fOR
OF COURT. rilE SENTF.NCE WINDOW IS LOCMED ON TilE FIRST FLOOR OF HIE RENO
COllRT. ONE soum SIERRA ST. RENO. NV (77') l1412'1O.
ruE DEFEND,IST 511,ILL ,IPPE,IR ,IS ORDERED FOR ,ILL REV IEWS ,IND SIIALL COOPERATE FIlLL Y WITII TIlE
IlAILlFFSJMARSIIALS AND ALL COURT ST,IFF.
HIE DEFENDANT SII,\LL AmND ,II.L RF.VIF.WS. COURT .IPPE,IRANCES ,IND COIlRTORDF.RED I'ROGRMIS ON TIME MID
ALCOIIOL ,IND DRUG FREE.
PRIOR TO CII,INGING IIISIIIER ,IDDRF.SS OR PIIONE NIlMIlER. TIlE DEFENDANT SIIALL NOTlFIY TilE COURT OF SUCH
CIIAN('E.
OBEY ALL LAWS.
..
,IDDITIONAL CASE INFORMA nON: l cilY wilnesse. had ""pcared (0' bench llial
ADDITIONAL CASE INFORMATION: DEFENDANT W,IS IN CUSTODY Ar TIME AND DATE OF IIENCH TRIAL;
DF.FENDANT WAS TRANSPORTED BUT NOT RROUGHT INTO COURT
,IDDITIONAL CASE INFORMATION: RAIL FORFEITURE CANCELLED
IIIJOl1011 ,IDDmONAL C,ISE INFORMATION: CITY REST ITS CASI!; DEFENSI! 1IF.IiINS illS 6:"
II/JOIZO II ,IIJOITIONAL CASF. INFORMA nON: DEFENDANT REFUSED TO STATE WIIETI IER OR NOT liE WOULD RE TESTIFIED;
IIIJO/ZOII ,IDDITIONAL C,ISE INFORMATION: CLUSING OY 110m PARTIES
I 011 OIZO I I .IDDITIONAL CASE INFORMATION: DF.FENDANT DID NOT WANT A COIlRT APPOINTF.D ATTORNEY.
TilE HONOR.IoLE
JIJOGES SIG:oI.ITURE:
o.Irf.:
You .Ire t>n":red by Ihe Cuurt to ;Irrivc tfnlWillcuhul rree and IJn lime for 1111 CtJlu1 and Court tcla.cd prog.un . F.lilure h)
"flPe:ar III CI1Ur1 \\Ii II fe,"" in rhe i'i11Ii,nce tH'il w.uranl (or )'1)1" ,Inc". ,\ny "inl.llion I,f,hi. inSI;)"1 order ,"OIY n: . lIh in (OIIlCr"p'
'1f1t1 rhe rilin" Iii .r.!dilillf1ul Irt,lccorthlOCe wl,h .'1RS n.oJt), ir i.'l il ftlr imy pcnon Il, liul,
) 'I( li..:gli!cI III wlrh rhe l..:nl1' nr" Illy order i"Hllcd by rhe ,\1unicipal ("tnrrt JIIJge. I hi) nrderm'. in (ffeet Ul7''lh. e
I COUll i"u", .lnouh<, "nl., 'lIp.""fing ;1.
, n . J liftl 3D {J
,11.1.'<llf.R.H.\."Il.\."D l'IIO.\IISf. ro fillS OROf.R. Of.rf.:oIo."'lr?"' ]?e.-ru.<:L t/1 . . 0l.-.3t- I
Il.I fE: X
I . If.: ____ _
i I. fllf. fl' 1.1. \" fI:IU'Hf.n:o ORDr.R fO !'IIf.
r:
n.1 n::
fI.\II':: ____ _
,lY.CI:IV.IlIIV IIHI'IV
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NOTE BY COUGHLIN NOTICE HOW THE MANNER THE SBN SCANS
OR COPIES DOCUMENTS MAKES THEM 15% SMALLER THAN THEY
ACTUALLY ARE...THAT IS NOT EASY TO DO, BUT IT SURE
MAKES THE READER FEEL A LOT LESS LIKE READING...
1 own behalf, that certain evidence should have been suppressed pursuant to the Fourth
2 Amendment of the United States Constitution, that his conviction Is not supported by
3 suffldent evidence, and that "[f]urther Improprieties and due process dellclencles-
4 occurred.
5 Unfortunatelv, Appellant neither supports his arguments with relevant authority nor
6 dtatlons to relevant portions of the record. Most Importantly, Appellant has railed to
7 provide this Court with a copy of the transcr1pt of relevant proceedings In the Reno
8 Munldpal Court. The Nevada Supreme Court has held that an "[a)ppellant has the ultlmat
9 responsibility to provide this court with 'portions of the record essential to determination of
10 Issues raised In appellant's appeal,' 71Ioma$ v. State, 120 Nev. 37 n. 4,83 P.3d 818
11 (2004) (dtlng NRAP 30(b)(3). Further, NRAP 28(e) provides that "[e)very assertion In
12 briefs regarding matters In the record shall be supported by a reference to the page of the
13 transcript or appendix where the matter relied on Is to be found,"
14 While Appellant did provide this Court with a Compact Disc containing a recording of
15 the Municipal Court proceedings, Appellant did not dte to the portions of the Compact Disc
16 that he felt supported his arguments, and It Is not the responsibility of this Court to guess
17 which portions of the Compact Disc might support Appellant's arguments. In short,
18 Appellant did not satisfy his responsibility to supply and cite to relevant portions of the
19 record merely bV producing a Compact Disc recording of the entire Municipal Court
20 proceeding.
21 In light of Appellant's failure to provide this Court with an adequate appellate
22 record, and Appellant's correspondent failure to cite to such a record, this Court Is unable
23 to conduct a meaningful review of Appellant's appeal. Thus, Appellant has failed to meet
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his burden In providing an adequate appellate record, and this Court must afflrm the ruling
of the Reno Munldpal Court. I
NOW, THEREFORE, IT IS HEREBY ORDERED that the ruling of the Reno
Municipal Court Is AFFIRMED.
IT IS FURTHER ORDERED that this matter Is remanded back to the Reno
Municipal Court for all further proceedings.
DATED ... J5LdoyotM",". 0 1 2 . ~ I-
EN P. EWOTT
DIstrict Judge
I It Is worth noting that. pursuant to NRS 4.410(2), "[t]he rees ror transcrIpts and caples [at munIcipal court
proceedIngs] must be paId by the party order1"9 them. In a civil case the preparatIOn or the transatpt need
not commence unttl the rees have bej!fl deposIted wIth the deputy clerk at the court. AccordIngly, NRS
189.0)0, whIch requIres the munIcipal court to transmIt various pape" to the dIstrict court upon appeal, does
not requIre action until such rees have been paid. Here, it .ppea" that Appellant never paid the requIsite
rees to secure the tranSCription or the proceedIngs. For thIs reason. the appellate record IS Incomplete.
. J.
00013
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CERUBCATI OF MAILING
1
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I hereby certify that I electronIcally filed the foregoing with the Oerk or the Court by
3 using the ECF system which served the following parties electronically:
4 ZACHARY COUGHUN, ESQ. ror ZACHARY COUGHUN
5 PAMELA ROBERTS, ESQ. for CITY OF RENO
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DATED this /5

E I HO N
Judicial Assistant
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RENO MUNICIPAL COURTF
WASIIOE COUNTY, NEVADA
,L E 0
NOV 3020\1
Reno M Court Dept. 4
CITY OF RENO,
Case No.
Plaintiff,
vs.
ZACHARY COUGIiLlN,
Oefendant.
Dept. 4
ORDER FOR SUMMARY
PUNISHMENT OF CONTEMPT
COMMITTED IN THE IMMEDIATE
VIEW AND PRESENCE
OFTHECOURT
,
--....,.,W"",..,.1E=RE"""'A""S ..... N"""'R':OS ... 2""6"'6""'.S"'7""0.,a,.-ec.,j-are-s municipal judge may punish for conlempt for
the same acts or omissions, in the same manner lllld with the same effects lIS provided for
judges in Chapter 22 of Nevada Revised Statute, and
WHEREAS NRS 22.030 declares that when a contempt is committed in the immediate
view and presence of the Court or judge at chambers, it may be punished summarily, for
which llll order shall be made, reciting the facts lIS occurring in such immediate view and
presence, adjudging that the person proceeded against is thereby guilty ofa contempt lllld Ihat
he/she be punished lIS Iherein preSCribed, and
WHEREAS, on the 30'h day of November, 20 II, the above nruned defendllllt appeared
belore this court.
NAME: ZACHERY COUGHLIN, who is II DEFENDANT
_____ Party; Witness; Spectator, lllld
WHEREAS such individual committed the following act(s) in the immediate view and
presence of the Court:
V Disorderly, contemptuous or insolent behavior toward Ihe judge while he is
holding court, or engaged in his judicial duties at chambers,
To wit: Refusing to ohey directives or the Judge,contlnulng lines of Inquiry after
heln advbed b Ihe Court 0 re rain from doin s i Oemeanln Ih Court with
stalements such as VO n response to court LaughIng during
lestlmony and (urlher questionIng the court and its adlhorlly, .
A breach of Ihe peace, boisterous conduct or violent dislurbllnce in the presence of Ihe
Court. or in ils immediate vicinity, lending 10 inh:mlpt due to the course of the trial or other
judicial proceeding,
Refusing to he sworn or answer as a witness,
____ Disobeying a lawful IHpy 01 I
cOhrunben" ami such 011
____ cmeaneu the ourt orlQ1nol'- and I/Il1t:un autlooril..t 10 make /Ilia C4rl11lcu*,\
__ v- __ the :Ollthorily of Ih.: Court
foIUHICI AT r

__ V- __ .IJminisrr.lti.lll .Jnd n:qllin:d
vinoli.:;,ti.JrI hy (',,"rt III .)(Iler .Ind rc,pc,t.
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Based upon the above linding ZACHARY COUGIiLiN is Guilty of Direct
Contempt.
The Contemnor, when asked if9she hnd anything to say as to why sentence should
not be pronounced, replied:
C.M\;J- /lcQOQ
Therefore, IT IS HEREBY ORDERED, ADJUDGED. and DECREED that the
contemnor is hereby sentenced to the following punishment:
A fine in the amount of ($500 or less).
Imprisonment for (25 dnys or less). NO ALTERNA TlVE SENTENCING.
';-8 f ......
DEFENDANT TO BE RELEASED on 11-- J, -II ,2011.
A fine in the amount of ____ ($500 or less) and imprisonment for __
DA YS WASHOE COUNTY JAIL - No alternative sentencing.
Release on Own Recognizance revoked, bail set at:
Defendant is hereby remanded into the custody and will be seen in video
arraignments on ___ -', 2011, at 8:30 a.m. NO flAIL HOLD PENDING
SENTENCING.
DATED this 30'h day of November, 2011.

Reno Municipal Court
00017
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:

Exhibit 3
0001'8
1722
NOTE BY COUGHLIN: NOTICE HOW
NON OF THE OTHER PAGES HERE HAVE TWO DIFFERENT SETS OF
THREE HOLE PUNCHES ON THE LEFT SIDE (WELL, THE OTHER TWO
EXHIBIT COVER PAGES ARE UPSIDE DOWN, BUT, WHATEVER),
NO SO COINCIDENTAL WHERE KING ALTERED THE 8/23/12
COMPLAINTS VERSION OF THE 3/12/12 NASH ORDER ATTACHED AS
EXHIBIT 3 TO ATTEMPT TO HIDE THE LEGIBILITY ISSUES THAT
RESULTED IN COUGHLIN'S LAWSUIT AGAINST ELCANO AND WLS
BEING THROUGH OUT IN 60302 AND 60317.
THIS VERSION OF THE SBN'S 2/13/13 ROA UTILIZES DIGITAL COPIES
WHEREVER POSSIBLE, WHICH INCREASES THE LEGIBILITY THEREOF
COMPARED TO THE DUBIOUSLY SCANNED SBN VERSION.
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'I ...
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,'-110'" I:"
elISe No. I I TR 26800 21
Depl. No.3
IN THE MUNICIPAL COURT OF HIE CITY OF RENO
COUNTY OF WASHOE STA TE OF NEVADA
CITY OF RENO,
Plainliff,
vs.
ZACHARY BARKER COUGHLIN,
Defendlll1l.
------------',
ORDER
Moreh 12, 2012 was lhe lime sel for the resumplion of lhe tromc cilalion lrial of
Defendlll1t ZACHARY DARKER COUGHLIN who,lIS member No. 9473 of the Nevada Oar,
is an allomey represenling himself, lhe defendlll1l. The lrial was continued on Febnonry 27,
2012, when, aller approximately 1111 hour and 8 half,lhe defendant was held in criminal
conlempt by lhe coun for his anlics and misconduct during lhallrial. His behavior is nOled in
delail in lhe coun's Order entered on February 27, 2010.
Today, Mr. Coughlin failed 10 appear 10 complele lhis lriol. He has nol conlaCled Ihis
coun to explain or exeuse his absence. Depuly Cily Allomey Alison Ormoos appeared and
was prepnrcd 10 proceed. She infomlcd Ihe coun lhlll she had no eonlaCl wilh Mr. Coul:hlin
olher lhan receiving voluminous faxed documents from him allhe Reno Cily Allomey's
Otnce. The dcfcndonl's failure 10 appt!1II' was nOled on lhe record.
Tlw cOlin makes Ihe following findings un lhe record:
00019
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After he served his five-day Contempt of Court sanction imposed by this court on
Febnuuy 27,2012, Mr. Coughlin fax-flied to this court I a 224-pagc document entitled "Notice
of Appeal of Summary Contempt Order; Motion to Return Personal Property Confiscated by
Reno Municipal Court and Its Marshall; Motion for New Trial and to Alter or Amend
Summary Contempt Order." The document purported to appeal this court's Order holding
him in direct criminal contempt. It contained a portion of one sentence on page 4 seeking a
continuance oftoday's hearins, but no further discussion of that topic. It also mentioned
being a "tolling" motion in an apparent afterthought. II did not address most of the other
topics listed in the caption. Instead, the document contained rambling references to his
personal life and this court's; his father's football career in college; dozens of pages of string
citations taken off the internet; documents from a prisoner online site; an article about a
"police state;" an article about Discovory; a website printout showing a police officer's salary;
and copy of court documents from a District of Columbia case.
II was a disjointed regurgitation of case low citations from a legal research online site
with little reference to, or argument about, the foclS of his instant "BoulevDrd Stop" traflic
cose. The document was an incoherent Dnd pathetic demonstration of what might once have
been legal and academic prowess that appears to now be greatly damaged. Mr. Coughlin fax-
filed another document in which he apparently took a Motion to Proceed Inforrnn Pauperis
[sic I in another case and typed over it "Request for Audio Recording ofFcbOlary 27'h, 2012
Trial and for Appt [sic] and to Waiv'c Filing fee and Transcript Fee for Appeal Counscl."lle
had that filed in Ihe instant case on MlI1Ch 7, 2012, even thou\:h it was dated November 12.
2011.
Whereas Mr. Coul!hlin's cflorts to conduct his own delimse in his traflic citali,lO Ifial ,m
I RMC Rule! dnl! f'wccdurc. , p..:nnil1 rJJl rlling ormolionl.
2
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February 27, 2012 disrupted Department 3 of this co un ond caused distress to this coun and
2
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its and mMshals, as well as the prosecutor nnd the witness, resulted in Mr. Cou!;hlin
4
being held in contempt of coun, his faxing nnd filing of these documents greatly disrupted the
5
operation of the entire Reno Municipal Coun system, including the clerk's ollice and the
6
other depanments, nnd necessitated that action be taken by the Coun Administrator and
7 Administrative Judge.
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Apparently begi'lIIinll on March 9,2012 at 12:38 p.m., Mr. Coughlin ngain undertook
9
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nnother massive fax-filing to Reno Municipal Court. This time it was a document that was
II
file-stomped by the clerk on March 12, 2012 at 8: 12 a.m. This second 218-page document
12
purported to he yet nnother motion in this case entitled "Motion to Return Cell Phones;
13 Motion to Set Aside Summary Contempt Order; und Notice of Appeal of Summary COOlempt
14
Order." With scant discussion of, or relevance to, the above-captioned maltcr, said document
15
mostly arllues allninst Judge Howard in 0 Depanment4 case and again contains more than
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200 pages or string lellol citations; lyrics to rocks songs; Mr. Coughlin's personal family
18
history; discussion eviction case and another contempt case; disjointed legal citations,
19
and other nonsensical molters that have no apparent relevance to his traffic citation case.
20
Ooth documents were massive and took up a great deal of time because the coun hnd to
21
review them to look for some connection to the case. This court has Ihe inherent to
22
main lain respect, order and decorum in the court, and 10 refuse to allow the coun to be used
23
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(IS n vehicle for the deranged rantings of a litigant.
25
The conJucl of Mr. Coughlin has been inappropriate, bizarre, dishonest, irrational anJ
26 disnlptive, 10 say the 10:.1st. He has not practiced law in this case in it manner that
27
Jemonstrates his competence, profeSSionalism, preparation, consideration li'r the court, the
211
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witness. or his "pposing counsel. lie has hecn Ji<rcspeetfultn the enun. has 1:,ilcJ to
\
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appear or explain his absence to the court. Inasmuch lIS the court has at least four dilTerent
addresses for him. it is unable to ascertain his exact whereabouts. He shows of mental
ifnot serious mental illness.
upon the total circumstances of this case. the in-court performance of the
defendant. lIS observed by this court. the written documents faxed to the court for tiling by
this defendant, the statements and behavior of this defendant and his overall conduct herein.
this court finds. by clear and convincing evidence, that Zachary Barker Coughlin. an attorney
licensed to pmctice law in the State of Nevado, has committed numerous acts ofnttomey
misconduct, including. but not limited to. violating the following Rules of Professional
Conduct:
8.4(c)-engaging in dishonesty, fraud, deceit or misrcpresentation;
8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
3.I-defending in a proceeding by asserting or controverting an issue without a basis in
fact and with matters that arc known to be frivolous;
3.2-failure to make rellSonoble efTorts to expedite litigation. and, in fact, tnking
extreme measures to delay litigation;
3.4(e}-being unfair to opposing counsel by continually alluding to matlers the lawyer
docs nut reasonably believe are relevant or supported by admissible evidence;
1.3-failing to uct with reasonable diligence and promptness; and
I. I-lack of competence in his practice and appearances before this court.
In addition. Zachary Darker Coughlin. likely "Iso violated Nevada Supreme Court Rule
229, section 2(b), as omended by ADKT 449 on August 1,2011, by surreptitiuusly reconJinK
the trallic citation trial of February 27,2012 without the advance permission of this court nnd
then Iyinillo this court ..... hen questioned IIbout it and dcnj'inl! th"t he had done so.
.\
00022
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NOTE BY COUGHLIN: SEE THE
SMOKING GUN? WHY IS THE "01901"
PORTION OF A BATES STAMP SERIES ONLY
PRESENT ON ONE PAGE OF THIS VERSION
OF THE 3/12/12 NASH ORDER...
WHY DOES THE EXHIBIT COVER PAGE TO
THIS HAVE TWO SETS OF THREE HOLE
PUNCHES ON THE LEFT SIDE
WHERE NO OTHER PAGES DO?
LINE UP THE STAMPEL HOLES IN THAT
ALLANGE.
NOTE BY COUGHLIN: NOTICE
FROM THE VERSION ON THE IMMEDIATELY PRECEDING PAGE THAT
EVEN WITH THE SBN'S CONVENIENT (AND, CURIOUSLY DIFFERENT
THAN THE BATES STAMPING UTILIZED FOR THE 11/7/12 SCR
105(2)(C) PLEATHER OF 3,100 PAGES IT PRODUCED TO
COUGHLIN)THAT NEITHER THE "01901" BATES STAMP, NOR THE
"00023" BATES STAMP (FROM THE SERIES AFFIXED TO THE ITEMS
IN KING'S FHE1 PACKET) SHOULD BE OBSCURED BY THE NEW
SERIES OF BATES STAMPING PLACE ON THE 2/13/13 ROA.
NOTE BY COUGHLIN. HERE IS THE VERSION OF EX 3 TO THE COMPLAINT THE
SBN INSERTED IN THE 11/7/12 SCR 105(2)(C) SPAM
\ ~
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1 Case No. NG12-0204, NG12-0435, NG12-0434
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STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,
)
)
Complainant, )
)
vs. ) FIRST DESIGNATION OF
) HEARING PANEL MEMBERS
ZACHARY B. COUGHLIN, ESQ., )
NEVADA BAR NO. 9473 )
)
Respondent. )
)
TO: Zachary B. Coughlin, Esq.
Post Office Box 3961
Reno, NV 89505
The following are members of the Disciplinary Board for the Northern District of
Nevada. Pursuant to Nevada Supreme Court Rule 105, you may issue peremptory
challenge to five (5) such individuals by delivering the same in writing to the Office of Bar
Counsel on or before the date a response to the Complaint is due. The Chair of the
Northern Nevada Disciplinary Board, J. Thomas Susich, Esq., will thereafter designate a
19
hearing panel of five (5) members of the Disciplinary Board, including at least one
20
21
member who is not an attorney, to hear the above captioned matter.
22
1. Kathleen Breckenridge, Esq. (flkla Kathleen Price)
23
2. Gregory Brower, Esq.
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3. Julie Cavanaugh-Bill, Esq.
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4. Trina Dahlin, Esq.
5. Linda Daykin, Esq .
. , -
0002
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55. Carolyn Vaught, Laymember
56. John White, Laymember
Dated this ;1...:3 day of August, 2012.
STATE BAR OF NEVADA
DAVID A. CLARK, BAR COUNSEL
By: --/J-d" 0 /<:::7'
Patrick O. King, KsSlStant Bar Counsel
9456 Double R Boulevard, Suite B
Reno, NV 89521
(775) 329-4100
ATTORNEY FOR COMPLAINANT
- 4 .
0002
1731
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1
2 STATE OF NEVADA )
)SS:
3 COUNTY OF WASHOE )
I,J
AFFIDAVIT OF MAILING
4 Laura Peters, under penalty of perjury, being first and duly sworn, deposes and
5 says as follows:
6 1. That Affiant is employed as a paralegal for the State Bar of Nevada. That in such
7 capacity, Affiant is Custodian of Records for the Discipline Department of the State Bar of
8 Nevada.
9 2. That Affiant States that the enclosed documents are true and correct copies of the
10 COMPLAINT and FIRST DESIGNATION OF HEARING PANEL MEMBERS in the
11 matter of the State Bar of Nevada v. Zachary B. Coughlin, Esq. Case No. NG12-0204.
12 NG12-0435 and NG12-0434.
13 3. That pursuant to Supreme Court Rule 109, the Complaint and First Designation of
14 Hearing Panel Members were served on the following by placing a copy in an envelope
15 which was then sealed and postage fully prepaid for first class, certified mail, and
16 deposited in the United States mail at Reno, Nevada to Zachary B. Coughlin, Esq., Post
17 Office Box 3961, Reno, NV 89505 .
.d
18 Dated this 1...3 day of August, 2012.
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SUBSCRIBED AND SWORN to
Before me this 23,d day of August, 2012.
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Lau a Peters, an Employee
Of the State Bar of Nevada
r-----.--____ . __

. JOAN T. NeUFElD
.", }, "0101')' Pubflo Sialo of NoWida
1 'I
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____ . .::.: r2 EJIIIn>o.u.1!, 2015
5-
0002
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I

( 1 Case No: NG12-0204, NG12-0435 and NG12-0434 ,_,
2 STAT OF NtVADA
STATE BAR OF NEVADA
3 NORTHERN NEVADA DISCIPLINARY BOARD
4
STATE BAR OF NEVADA,
5
6
vs.
Complainant,
NOTICE OF INTENT TO PROCEED ON
A DEFAULT BASIS
7
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ZACHARY B. COUGHLIN
Bar No. 9473
Respondent.
TO: Zachary B. Coughlin
Post Office Box 3961
Reno, NV 89505
12 PLEASE TAKE NOTICE THAT unless the State Bar receives a responsive pleading in
13 the above-captioned matter by October 24, 2012, it will proceed on a default basis and the
14 charges against you shall be deemed admitted. Supreme Court Rule 105(2) states in
15 relevant part:
16
A copy of the complaint shall be served on the attorney and it shall direct that
17 a verified response or answer be served on bar counsel within 20 days of
service ... ln the event the attorney fails to plead, the charges shall be
18 deemed admitted; provided, however, that an attorney who fails to respond
within the time provided may thereafter obtain permission of the appropriate
19 disciplinary board chair to do so, if failure to file is attributable to mistake,
inadvertence, surprise, or excusable neglect. (Emphasis added.)
20
11/
21
11/
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11/
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1733
(
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Another copy of the Complaint previously served upon you accompanies this Notice.
2 Dated this 9
th
day of October, 2012
3
STATE BAR OF NEVADA
David A. Clark, Bar Counsel
4
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6 By:
Bar Counsel
7
9456 Double R Blvd., Ste. B
(775) 329-4100
8
AHorney for State Bar of Nevada
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CERTIFICATE OF SERVICE BY MAIL
The undersigned hereby certifies that a true and correct copy of the foregoing Notice
of Intent to Proceed on a Default Basis was deposited in the United States Mail at Reno,
Nevada, postage fully pre-paid thereon for certified mail, addressed to: Zachary B. Coughlin,
Post Office Box 3961, Reno, Nevada 89505.
Dated this 9
th
day of October, 2012.
,
aura eters, an employee of
the State Bar of Nevada
3
000311
1735
Reno/Carson M .... enger Service.lnc.
185 Manin Streel
Reno .NV 89509
175.322.2424
Federo( T ... 10: 880306306
NV STATE
INVOICE FOR SERVICE;
600 Eo CH,\HI ON DO VAH
STATEDAHOF.
VEG,. 89104 I
Requeslor: L PETERS
Your COUGHLIN
;J
J
mi. RENO r&HS oNT. LAS sYEGAS
" * * *WE MAKI! OG.\OlINliS .. ,. ..
14600
Dme: 10/0612012
Amount Due: $0.00
Phone number: 1753294119
F ... number:
Email Address:LAURAP@NVBAR.ORG
Service ZACHARY B. COUGHlIN. ESQ .. BAR NO. 9473
Manner of Service: NON.SERVE
Service: D3Id1ime:10J06I201212:ooPM
Service oddrc: .. :94' W 1211l ST Rl!NONV 8950)
Served by:JOHNNO LAZIl11CH
DAH OF NEVADA NOHTIIEHN DISClPJ.lNAHV BOAND
STAll! BAR OF NEVADA Y. 7.AClfARY B. COUGHUN.ESQ .. BAR NO. 947)
Service Doeumen,.: COMPLAINT; FIRST DESIGNATION OF IfF.ARING PANEL MEMBERS CASEII: NG 120204. NG 12.(4)' AND
NGI204J4
Service Comments:
O9I18f20llll:22
0912312012 II:"
091211201211:19
09J2lnoI210;0,5
Siandard Service
TOTAL CHARGES:
DALANCE:
Scalee Noles
LEFT ANOmER MESSAOH wml VOICE MAIL
AOAIN CAIJ.EO. MR COUOIII.IN ANSWf.RED, TIleN HUNO UP. "'I-"FIANT
FOI.LQWPJ) WITH A TRXT Dl1I' RF.CI!JVRD NO Rf.SPONSB.
CAI.J.I!O AND lIlPT MESSAOH wml VOICP. MAil. A'.50TRX'Tf'D
SUBJl!CT.
IOHNNO CAU.P.D ClIBHr: ALSO CALLP.D AND IJ!PT MPSSAOB
$0.00
$0.00
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00032
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CASES NO'd. NGI20204; NG I 2-0435 and NR120434
2 STATE BAR OF NEVADA
J NORTHERN NEVADA DISCIPLINARY BOARD
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5 STATE BAR OF NEVADA, )
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Complainant, )
)
7 vs. ) ORDER APPOINTING
) FORMAL HEARING PANEL
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ZACHARY B. COUGHLIN, )
Bar No. 9473, )
9 )
Respondent. )
10 )
II PLEASE BE ADVISED that a Formal Hearing Panel of the Northern
12 Nevada Disciplinary Board has been scheduled for Wednesday, November 14, 2012, at
13 the hour of 9:00 a.m., to convene at the Reno office of the State Bar of Nevada, 9456
14 Double R Boulevard, Suite B, Reno, Nevada 89521.
15 IT IS HEREBY ORDERED that the following members of the Northern
16 Nevada Disciplinary Board have been designated as members of the hearing panel:
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1. John P. Echeverria, Esq., Chair;
2. Michael K. Johnson, Esq.;
3. Clark V. Vellis, Esq.;
4. Stephen Kent, Esq.; and,
5. Karen Pearl. Laymember.
DATED this 29
1h
day of October, 2012.
STATE BAR OF NEVADA
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By: --
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Nevada Disciplinary Board
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CERTIFICATE OF SERVICE
The undersigned hereby cenilies that a true and correct copy of the loregoing Order
Appoinling I'ormaillcaring Panel was deposited in the United States Mail at Reno, Nevada, postage
fully pre-paid thereon for cenilicd and first class mail addressed to the following:
Zachary B. Coughlin
1471 E. 9th St.
Reno NV !l9505
I an employee of
the State Bar of Nevada
.. u:s, POslal,Service".. " '.:' "., ,
"CERT,IFIED" MAIi::;u' R'ECEIPT '
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(OomesUc Moll OnlY;'No InsuroncB 'Coversgo P:.ovfdtlCl)"

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OCT 1 ? ,2gJ9 .
STA
STATE BAR OF NEVADA TE 'OF' NEVAD
Case No: NG12-0204, NG12-0435 and NG12-0434
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,
Complainant,
vs.
ZACHARY B. COUGHLIN
Bar No. 9473
Respondent
NOTICE OF FORMAL HEARING
PLEASE TAKE NOTICE that thc fonnal hcaring in the abovc-cntitlcd action has been
scheduled for Wednesday, Nuvember 14, 2012, beginning at the hour of 9:00 a.m. The hearing
will be conducted at the Reno office of the State Bar of Nevada. located at 9456 Double R Blvd., Stc.
B. Reno. Ncvada. You arc entitled to be represented by counsel. to cross-examine witnesses. and to
present evidencc.
DATED this I <- day of October. 2012.
STATE BAR OF NEVADA
DA VID A. CLARK. Bur Counsel
By: _____ _
Patrick O. King, AiSlant Bar Counsel
9456 Double R. IlIvd . Stc. B
Reno. Nevada 89521
(775) )211-1 JM2
Attorney li)r State liar of Nevada
0003
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( 1 Case No: NG12-0204, NG12-0435 and NG12-0434
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STATE DAR OF NEVADA
NORTHERN NEVADA DlSCIPLlNARV BOARD
STATE i)AI{ OF NEVADA,
Complainant,
\'s.
ZACHARY B. COUGHLIN
Bar No. 9473
)
)
)
)
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__________ _____________ )
DESIGNATION OF WITNESSES;
SUMMARV OF EVIDENCE
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PLF.ASE TAKE NO-riC.: that the following is a summary of evidence and list of witnesses
11
which may be olTered against Respondent at the time of the formal hearing on the above-entitled
12
complaint.
13 A.
I)oeumcnlury F.vidcnce
14
I.
Any and all documentation contained in the State Bar of Nevada's Ii!.: regarding
15 grleyance liles NG 12-0204, NG 12-0435 and NG 12-0434, except lor screening materials and Bar
16 Counsel work product. Pursuant to SCI{ 105 (2)(c) Respondent may inspect the State Bar lile up to
17 three (3) days prior to the hearing.
18 B. Witnesses und Brief Slulemenl or Faels
19
I.
Judge Dorothy Nash I-(ollnes will appear by phone to testify with regard to
20 Respondent's wnduct in connection with Case No. II-TR-26800 12 in Reno Municipal Court.
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2.
Judge Kenneth R. Howard is expected tn testify "bnut Respondent'S cnndllct in
22 connection with Case No. II CR 21176 21.
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3.
Dr. Matt Merliss is expected to testify about the situation leading lip to Respondent's
24 arrest I',r trespassing.
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4. Attorney Richard I(ill, Esl(., is expected to tcstimony with regard to Respondent's
conduct in conncction with ('''SI! No. CV (1-03628.
5. Scott Coppa, Marshall for thc Reno Municipal Court is expected to testify ahout
Respondent's disruptive behavior on March 22, 20(2.
6. Attorney Daniel Wong is expected to testify about Respondent's conduct in Reno
Justice Court.
7.
Steve Tuttle, Reno Justice Court employee, is expected to testify about Respondent's
conduct when visiting the court complex.
8. Karen Stanek, Reno Justice Court employee, is expected to testify about Respondent's
conduct when visiting the court complex. 10
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'>. Robin Baker, Rcno Justice Court employee, is expected to testify about Respondent's
conduct when visiting the court complex.
10.
Dr. Richard T. Bissett is expected to testify about the examination he perfonned on
14 Respondent in preparation for a competency hearing in Case No. 12-0376.
15
II.
Dr. M"ry R. Vieth is cxpected to testify "hout thc examination shc perfomlcd on
16 Respondent in preparation for a competency hearing in Case No. 12-0376.
17 12. A member of the slaff of the State Bar of Nevada Ethics Department is
18 expected to testify as Custodian of Records regarding documentation contained in the records of the
19 State Bar of Nevada and Respondent's discipline and licensure history.
20 III
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Zachary B. CUIIl,:hlin is expected to testify rCl,:arding the I:\cts :md circllmstances ill all
2 three disciplinary mailers.
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The State Bar of Nevada reserves the ril,:ht to supplement this disclosure.
DATED this ~ day ur October, 2012.
STATE OAR OF NEVADA
DAVID A. CLARK, Bar Counsel
By: -;O,..,d ~
I'atrick O. Killg, Assistant Bar Counsel
9456 Double R Blvd., Stc. B
RCIIO, Nevada 89521
(775) 328-I3K2
Allorney tor State Bar Ill' Nevada
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CERTIFICATE OF SF-RVleE
The undersigned hereby certifies that a true and correct copy of the foregoing Notice uf
Furmaillearing was deposited in the United States Mail at Reno. Nevada, postage fully pre paid
thereon for certified and !irst dass mail addressed to the following:
Zachary B. Coughlin
Post Ollice Box 3961
Reno, NV 89505
DATED this l2'h day of October, 2012.
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a ters, an employee of
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1743
1744
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1 PART AND DENIED IN PART. The Office of Bar Counsel will arrange for copies of the file
2
to be delivered to Mr. Coughlin at the address that he has provided to the State Bar at the
3
earliest opportunity.
4 The Motion to Bifurcate Hearing and the Motion to Dismiss for Complaint [sic) Failure
5
to Sufficiently State the Charges with Specificity and Support and for Utter Failure of Bar
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Counsel to Perform Reasonable Investigation are both DENIED.
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IT IS FURTHER ORDERED that the Formal Hearing in these matters will proceed on
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a default basis pursuant to the State Bar's Notice of Intent to Proceed on a Default Basis
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filed October 9.2012, unless Mr. Coughlin prepares and files a Verified Answer to the State
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Bar's Complaint by Friday, November 9, 2012. The State Bar is prepared to proceed with a
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full evidentiary hearing in the event that Mr. Coughlin does file a Verified Answer to the
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State Bar's Complaint and is present for the Formal Hearing scheduled to take place on
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Wednesday, November 14, 2012.
/ . ~
DATED this\ J I day of October, 2012.
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~ : ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ = = = =
ohn P. h !lerria, Esq., Chair
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Formal He ng Panel
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1 CERTIFICATE OF SERVICE
2 The undersigned hereby certifies that a true and com:ct copy of the foregoing Order was
3 depusited in the United States Mail at Reno. Nevada. postage fully pre-paid thereon lor certilied and
4 first class mail addressed tu the lolluwing:
5 Zachary B. Coughlin
1471 E.9thSI.
6 Reno NV 89505
7 DATED this 31" day of October, 2012.
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Laura Pe ers. an employee of
the State Bar of Nevada
PoslaI"Service',;. . ,', ' . . . .
'.'CERl'IFIEO',MAIL;,;RECEIRT " ,
. Mall Only: No Insufa'nCQ COllflf8gtl p,rovldadJ, :
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0004
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CASE NUMUER: ngI2-1J20-lng-O-l35 ng-0434
FILED
3 1
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STATE OF NEVADA
STATE OF NEVAIM
NORTHERN NEVADA DISCII'I.INARY BOARD
n Rc Mall.:r .,1':
.. ACHARY BARKER COUGIII.lN. ESQ.
c"ada 1.lar No: 9-173
)
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) ng 12-0204 ng-04J5 ng-0434 n1Ulion 10
) hil'urcalo: 10 15 12
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CIIIIl!hlin's I)ESI(;NATION OF WI'I'NESSES Ai'ih SUM I\It\ I( OF EVII)ENCE
PLEASE TAKE NOTICE that the following is a summary of evidence and list of witnesses which may
be offered against Respondent at the time of the formal hearing on the above-entitled complaint.
Coughlin reserves any and all objections to matters not included in the Complaint (or even in the
greivances themselves from being testfied to or evidence put on directedto, lack of notice. etc .... Dr.
Vieth. et al not reasonably related to any allegations)
A. Documentary Evidence 1. Any and all documentation contained in the State Bar of Nevada's tile
regarding gnevance tiles NGI2-0204. NG12-0435 and NGI2-0434. except for screening materials
and Bar Counsel work product. Pursuant to SCR 105 (2)(c) Respondent may inspect the State Bar
tile up to three (3) days prior to the hearing. Seet attached Exhibit 1 (cd/dvd of relevant materials.
that will be further supplemented later. and incorproated by reference everything previously sent to
anyone with the SBN. including emails and links to videos/skydrives. etc).
B Witnesses and Brief Statement of Facts
t. Judge Dorothy Nash Holmes will appear by phone to testify with regard to Respondent's conduct
in connection with Case No. 11- TR-26800 12 in Reno Municipal Court.
2.
Judge Kenneth R. Howard is expected to testify about Respondent's conduct in connection with
Case No. II CR 21176 21.
3. Dr. Matt Merliss is expected to testify about the situation leading up to Respondent's arrest for
trespassing and his lies before and after the face
'10
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1747
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4. Allorney Richard Hill, Esq., is expected to testimony with regard to Respondent's
conduct in connection with Case No. CVIt-03628.
5. Scott Coppa, Marshall for the Reno Municipal Court is expected to testify about
Respondent's disruptive behavior on March 22,201 2.
6. Reno City Allorney Daniel Wong, Pam Roberts, Allison ORmaas, and Chris Hazlett-STevens are
expected to testify about Respondent's conduct in Reno
Justice Court.
7. Steve Tuttle, Reno Justice Court employee, is expected to testify about Respondent's
conduct when visiting Ihe court compkx.
8. Karen Stancil, Reno Justice Court employee. is expected to testify about Respondent's
conduct when visiting the court complexand various matters related to Coughlin in the RJC ..
9. Robin Baker, Reno Justice Court employee, is expected to testify about Respondent's conduct
when visiting the court complex and various mailers related to Coughlin in the RJC.
10. Dr. Richard T. Bissell is expected to testify about the examination he performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
11. Dr. Mary R. Vieth is expected to testify about the examination she performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
12. A member of the staff of the State Bar of Nevada Ethics Department is
expected to testify as Custodian of Records regarding documentation contained in the records of the
State Bar of Nevada and Respondent's discipline and licensure history.
13. Zachary B. Coughlin is expected to testify regarding the facts and circumstances in all three
disciplinary matters. The State Bar of Nevada reserves the right to supplement this disclosure.
14. Steve Tuttle, RJC administrator is expected to testify about various matters related to Coughlin in
the RJC.
15. Dr. Bill Davis of Lake's Crossing expected to testify about the eX3mination he performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
16. Dr. Sally Farmer pected to testify about the examination he performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
17. Kevin Kelly, strip club ownin' Character and Fitness Committee Chairman is expected to testify
regarding the imperissible mailers related to Peter Christiansen's "representation" of Coughlin
between 2002-2005.
18. Mike Rowe, dillo what Kelly will to .
Dear 010 Judge Elliot, Judge Flanagan, and the Second Judicial District Court Clerk of Court Joey
Orduna Hasitings. WDC Custodian of Records, Associate Clerk of Court Julie Wise:
Included in the relevant materials and information sought is the legal basis for incarcerating in Cr12-
0376 (despite DDA Young violating NRS 178.405's mandatory stay. in his moving for a "Molion for
Revocation of Bail" (despite WDCR 19 requiring a hearing be set, Coughlin never got one in crl1-
2064, nor in cr12-1262 (both Judge Elliot appeals involving pro se Coughlin. nor did Coughlin get a
hearing in cvl1-03628, well, there was two hearings on Hill's fraudulent Motion for Order to Show
cause, but that it not what wdcr 19 is invoking)Coughlin between april19th, 2012 to April 26. 2012
(during which time the $40,050 attorneys fees molion resulting in an Order awarding it in CV11-
03628 was filed) for appealing a summary eviclion as a pro se lenant .apparently deemed residential
tenant with met of less than $1 K a month) also, despite Chief Civil Clerk kconstantly rejecllng
Coughlin'S filign under wdcr 10, Coughlin was actually sanctioned yet another $5K by his former
coworker
. Judge Flanagan (whom declined to recuse himself form the order to show cause hearings despite.
arguably. Coughlin requeting as much. in violation of nrs 22.030(3) ... but RCS/QLS in the Carpentier
v Aames case (that Richard hill copied Coughlin's January 13th, 2012 filing on in cv08-0 1709 in hills
1124112 grievance to bar counsel against Coughlin ... which Coughlin was subject to custodial arrest
for jaywalking by rpd and hill on 1112/12. and another arrest for "misuse of 91 t" on 1114/12.
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seemingly connected to filing in carpentier matter of 1/13/12 ... violated WDCR 18 and
38&#8194:Rule&#8194:&#8194:.Caption for all pleadings and other legal documents,
Every document submitted&#8194:&#8194: 1. for filing in the family division shall bear the
following caption:
"IN THE FAMILY DIVISION
OF THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
IN AND FOR THE COUNTY OF WASHOE"
Where there filings said "county of clark" ... Coughlin was the one attorney who pointed that out.. .. He
is sanctioned $5K? And the WDC continues to reject Coughlin's filings under WDCR 18 and 10 at a
remarkable rate?
Further, caplow 302 p.2d 755 made unnecessary the seemingly fraudulent 3/8/12 affidavit of service
by wcso machen, by way of rmc marshal harley (judge nash holmes 3/12112 comments in court
seem to indicate "summary criminal contempt" finding premised upon "peeping Tom" style peering
through restroom stall walls by RMC Marshal Harley (or some other Marshal, like Scott Coppa,
involved in the impermissible "search incident to arrest" by RMC a a full day after attorney's pro se
criminal defenant's smart phone and micro sd card booked into wCdc property on 2127112 ... violates
state v diaz ... anyways, no "summary contempt" finding based upon allegations of "dissessemblign"
smartphone in restroom stall, where no RMC Marshal, Harley or Coppa or otherwise, signed an
affidavit detailing facts supporting contempt. In re oliver requires such contempt be, in every
element, in the "immediate view and presence of the court" sixth amendment right violated, nrs
189.010-050 violated, etc .. etc.and m
ost of this ng12-0435 involves judge nash holmes denying Coughlin right to appeal final appealable
summary criminal contempt finding from 2/27/12., in re oliver, denied sixth amendment right to
counsel, and Cook, 267 us 517 at 536 (as did judge Flanagan in 3/23/12 contempt hearing of
Coughlin), notifying Coughlin of 3/23/12 hearing on hill's order to show cause motion in cvll-03628
before Judge Flanagan (nrcp 56(g) bad faith affidavits should result in expense awards and
contempt finding against hill, perhaps, baker, and stewart ... not $40K in attorneys fees against
Coughlin, de novo review and hearing required by wcdr 19 not provided .... plus in rmc 11 tr 26800
judge nash holmes violates nrs 189.010 by refusing to transmit record on appeal and transcript in
response to Coughlin filign a notice of appeal on 3/7/12 (rmc's garder, brother to Judge Linda
Gardner, whose April 2009 Order got Coughlin fired from Washoe Legal services (60301 60317 case
in n. s. ct.), she passed her order
to her brother, he passed it to Judge Nash Holmes, she filed ng 12-0435 on behalf of all rmc judges,
and apparently family court Judge L. Gardner (Coughlin filed mandamus to that order in 54844).
Also, why is Coughlin thrown in jail based upon "evaluation" filed on 4/18/12 by dr. bill davis (where
davis denies any responsibility for the letter he signed, saying he didn't write it, and didn't submit it
for filing? He SIGNED IT and Lakes filed it, arguably should'nt even be filed, and should be an
affidavity if Coughlin was incarcerated for contempt "not in court's presence" nrs. 22.040
Incarcerating Coughlin from april 19 to april 26th, 2011 in cr12-0376, and refusing to even look at the
authority Coughlin attempt to submit respecting tailoring competency orders, hipaa rights (also,
Order was not sufficiently clear, nor any violation thereof by Coughlin, under Houston v 8th judicial
dist4rict court to support 8 days in jail and wdcd denying Coughlin his medication and right to file
court documents. resulting in $40K attorney fees award by Judge Flanagan in cv1 t-03628 .... plus
MHC's biondo lied about basis for Coguhlin's removal in MH 12-0032 in her letters 10 RJC. Also nrcp
37(b)(2)(d) incarceration wrongful (civil rule, but perhaps instructive) In lieu of any of the foregoing
orders or in addition thereto, an order&#8194:(D) treating as a contempt of court Ihe failure to obey
any orders except an order to submit to a physical or mental examination"
Dated this 31 5t day of October, 2012:
OF WI !":"ESSES .\,'m Sl ,\I,\!'\WY IF E\II>E,\(E
-0 _____________ ________________ " " _________ _

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Zachary Barker Coughlin, Esq. (Nevada law license temporarily suspended, USPTO license in tact,
and given permission to issue subpoenas by SBN Chief Bar Counsel David Clark, Esq.)
1750