2 13 12 0204 62337 26405 Stamped Digital Notice Appeal Motion Vacate Order Withdrawal For Puentes, Motion Recuse 61901 1262

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--r- ,t'",....
IV'!
Document Code: cLttft:)
Zach Coughlin,Esq.
Nevada Bar No: 9473
1422 E. 9th St., #2 LED
tel: 715 229 6737 ,
fax: 949 6677402
Reno, NV 89512
Co-counsel for Defendant Coughlin
Reno

IN THE JUSTICE COURT OF RENO TOWNSHIP Deputy Clerk
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA
STATE OF NEVADA;
Plaintiff,
)
)
) Case No: 11 CR 26405
)
VS.
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) Dept No: Judge Gardner
)
13 ZACHARY COUGHLIN; )
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DefendMt. )
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Notice of ARPeal. Motion to Vacate and or Set Aside . !CRCP 59. JCRCP 60. Motion for
Reconsideration: Motion for Recusal: Motion For Publication Of Transcript at Public Expense.
Petition for In Fonna PauReris Status
POINTS AND AUTHORITIES
FACTS
Bobby Puentes threw me under the bus, rather thM reveal the fact that he had a conflict. He whined
about how the case was "hard" rather than do some lawyering. The man doesn't know how to bum a ,
cd. He attempted to shift the job of burning a cd for discovery onto me, yet he is the one taking home
the money to do the job. Jill Drake talked in court about how Puentes is beloved by all throughout
the RJC, especially the prosecutors for the Reno City Attorney, as he is just a teddy bear to
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Notice of AppeaL Motion to vacate and or Set Aside. JCRCP 59. JCRCP 60. Motion for
Reconsideration; Motion for Recusal; Motion For Publication Of Transcript at Public Expense.
Petition for In FOnnR Pauperis Status
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<rosecutors liBe DraBe D?ho reminded the undersigned that she ?as the # <la>er on the )eno /igh
9irls .ennis .eam in high school a&ter the /earing on 3e=ruar> !, !(!;...Being a tedd> =ear is &ine,
- guess, =ut not e'actl> the &irst thing - looB &or in de&ense counsel. Eoral o& the stor>, donAt thro?
client under the =us instead o& disclosing im<ermissi=le con&lict that >our con&lict checBs should have
revealed <rior to entering the sanctit> o& the attorne> client relationshi<, something that should =e
sacred, not Cust something 5uentes enteres to get a <a>checB and dum<s once it =ecomes
inconvenient.
De&endantF6<<ellant, Zach Coughlin, here=> &iles this Notice o& 6<<eal, Eotion to *acate and
or "et 6side, 0C)C5 $9, 0C)C5 %(, Eotion &or )econsideration8 Eotion &or )ecusal8 Eotion 3or
5u=lication 2& .ranscri<t at 5u=lic E'<ense, 5etition &or -n 3orma 5au<eris "tatus.
3urther no one has e'<lained .aitels m>sterious a=ilit> to 4ithdra? as Counsel ?ithout
com<l>ing ?ith )EC )ule $ or e'<laining ?h> he ?ithdre?. Not sure there is an 2rder allo?ing
.aitelAs ?ithdra?. 5uentes Eotion to 4ithdra argued:
@.he instant matter ?as set &or trial on 0anuar> (, !(!, /o?ever, a de&ense
motion to continue ?as &iled on 0anuar> 3,!(!, not o<<osed, and granted. 6 ne?
trial date is <ending. 1nder "u<reme Court )ule 4%, the attorne> in an action ma>
=e changed at an> time =e&ore Cudgment u<on the consent o& the attorne>,
a<<roved => the client, or u<on order o& the court or Cudge thereo& on the
a<<lication o& the attorne> or client. "C) 4%. 3urther, under N)5C , %D=;, a
la?>er ma> ?ithdra? &rom re<resenting a client i& the same can =e accom<lished
?ithout material adverse e&&ect on the interests o& the client8 a client insists u<on
taBing action the la?>er considers re<ugnant, or ?ith ?hich the la?>er has
&undamental disagreement8 the re<resentation has =een rendered unreasona=l>
di&&icult => the client8 or other good cause &or ?ithdra?al e'ists. "ee N)5C ,
%D=;D;, D4;, D%;, D7;. .he undersigned regret&ull> maBes this motion as continued
re<resentation o& the de&endant in this matter has =een rendered unreasona=l>
di&&icult and the de&endant ?ill =e =etter served => having an alternative legal
de&ender a<<ointed to re<resent him.@
6ctuall> 5uentes does not state ?ith su&&icient <articularit> ?h> or ho? his ?ithdra? @can
=e accom<lished ?ithout material adverse e&&ect on the interests o& the client@. -ndeed, having his
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Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59, JCRCP 60, Motion for
Reconsideration; Motion for Recusal; Motion For Pulication !f "ranscript at Pulic #$pense,
Petition for %n For&a Pauperis Status
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<rivate and con&idential case &ile <assed around liBe a hot <otato => )EC @&ormer <rosecutor@
de&enders is not in clientAs =est interest. 5uentes is required to detail Cust ho? @the re<resentation
has =een rendered unreasona=l> di&&icult => the client@ and this rule is su=Cect to a good &aith
requirement. .hat is, la?>ers canAt invoBe it to get out o& di&&icult or com<le' cases or to insure
the> onl> receive eas> cases. Can some=od> e'<lain to me ?h> DicB /ill going on vacation is a
su&&icient Custi&ication &or continuing a criminal trial, =ut m> =eing evicted and ?rong&ull> arrested
Ddue to DicB /illAs alleged =ri=er> o& the )5D and the )5DAs ?rong&ull arrest o& me, etc., and DicB
/illAs a<<l>ing a ?rong&ul and outla?ed rent distraint u<on =oth m> clientAs &iles and e'cul<ator>
evidence in C) !!7%; does not <resent a valid =asis &or a continuanceG 6nd - told .aitle -
?anted an o<<osition &iled to the motion &or continuance, >et it ?as not. "ee attached E'hi=it &or
su<<ort &or the contention that 5uentes ?ithdra? here is ina<<ro<riate as has =een most o& his
actions in this matter.
52-N." 6ND 61./2)-.-E"
6N6:7"-"
-NC2)52)6.E B7 )E3E)ENCE 6:: :64 6ND 6""E).-2N" -N 6..6C/ED
565E)" 6ND 5:E6D-N9" 6ND 4)-.-N9" -N EH/-B-. :
)econsideration 4DC) !D9;, DC) 3...
)1:E $9. NE4 .)-6:"8 6EENDEEN. 23 01D9EEN."
'a( )rounds* 6 ne? trial ma> =e granted to all or an> o& the <arties and on all or <art o& the issues &or an> o& the
&ollo?ing causes or grounds materiall> a&&ecting the su=stantial rights o& an aggrieved <art>: D; -rregularit> in the
<roceedings o& the court, Cur>, master, or adverse <art>, or an> order o& the court, or master, or a=use o& discretion =>
?hich either <art> ?as <revented &rom having a &air trial8 D!; Eisconduct o& the Cur> or <revailing <art>8 D3; 6ccident or
sur<rise ?hich ordinar> <rudence could not have guarded against8 D4; Ne?l> discovered evidence material &or the <art>
maBing the motion ?hich the <art> could not, ?ith reasona=le diligence, have discovered and <roduced at the trial8 D$;
Eani&est disregard => the Cur> o& the instructions o& the court8 D%; E'cessive damages a<<earing to have =een given under
the in&luence o& <assion or <reCudice8 or, D7; Error in la? occurring at the trial and o=Cected to => the <art> maBing the
motion. 2n a motion &or a ne? trial in an action tried ?ithout a Cur>, the court ma> o<en the Cudgment i& one has =een
entered, taBe additional testimon>, amend &indings o& &act and conclusions o& la? or maBe ne? &indings and conclusions,
and direct the entr> o& a ne? Cudgment.
'( "i&e for Motion* 6 motion &or a ne? trial shall =e &iled no later than ( da>s a&ter service o& ?ritten notice o& the
entr> o& the Cudgment.
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'c( "i&e for Ser+in, Affida+its* 4hen a motion &or ne? trial is =ased u<on a&&idavits the> shall =e &iled ?ith the motion.
.he o<<osing <art> has ( da>s a&ter service ?ithin ?hich to &ile o<<osing a&&idavits, ?hich <eriod ma> =e e'tended &or
an additional <eriod not e'ceeding !( da>s either => the court &or good cause sho?n or => the <arties => ?ritten
sti<ulation. .he court ma> <ermit re<l> a&&idavits.
'd( !n Court-s %nitiati+e; Notice; Specif.in, )rounds* No later than ( da>s a&ter entr> o& Cudgment the court, on its
o?n, ma> order a ne? trial &or an> reason that ?ould Custi&> granting one on a <art>Is motion. 6&ter giving the <arties
notice and an o<<ortunit> to =e heard, the court ma> grant a timel> motion &or a ne? trial &or a reason not stated in the
motion. 4hen granting a ne? trial on its o?n initiative or &or a reason not stated in a motion, the court shall s<eci&> the
grounds in its order.
'e( Motion to Alter or A&end a Jud,&ent* 6 motion to alter or amend the Cudgment shall =e &iled no later than ( da>s
a&ter service o& ?ritten notice o& entr> o& the Cudgment.
.he 2rder allo?ing 5uentes ?ithdr?as &its under @ -rregularit> in the <roceedings o& the court, Cur>, master, or
adverse <art>, or an> order o& the court, or master, or a=use o& discretion => ?hich either <art> ?as <revented &rom having
a &air trial@ as 5uentes ?as at least ommitting Be> in&ormation to the court, i& not misleading it as to his rationale &or
?ithdra?ing. 5lus 0udge 9ardnerAs 2rder, res<ect&ull> contains @Error in la? occurring at the trial and o=Cected to => the
<art> maBing the motion. 2n a motion &or a ne? trial in an action tried ?ithout a Cur>, the court ma> o<en the Cudgment i&
one has =een entered, taBe additional testimon>, amend &indings o& &act and conclusions o& la? or maBe ne? &indings and
conclusions, and direct the entr> o& a ne? Cudgment.@ .he la? sim<l> does not allo? &or such an unsu<<orted => &acts or
s<eci&ics Eotion to 4ithdra? to =e granted.
)1:E %(. )E:-E3 3)2E 01D9EEN. 2) 2)DE)
'a( Clerical Mista/es* Clerical mistaBes in Cudgments, orders or other <arts o& the record and errors therein arising &rom
oversight or omission ma> =e corrected => the court at an> time o& its o?n initiative or on the motion o& an> <art> and
a&ter such notice, i& an>, as the court orders. During the <endenc> o& an a<<eal, such mistaBes ma> =e so corrected =e&ore
the a<<eal is docBeted in the a<<ellate court, and therea&ter ?hile the a<<eal is <ending ma> =e so corrected ?ith leave o&
the a<<ellate court.
'( Mista/es; %nad+ertence; #$cusale Ne,lect; Ne0l. 1isco+ered #+idence; Fraud, #tc* 2n motion and u<on such
terms as are Cust, the court ma> relieve a <art> or <art>Is legal re<resentative &rom a &inal Cudgment, order, or <roceeding
&or the &ollo?ing reasons: D; mistaBe, inadvertence, sur<rise, or e'cusa=le neglect8 D!; ne?l> discovered evidence ?hich
=> due diligence could not have =een discovered in time to move &or a ne? trial under )ule $9D=;8 D3; &raud D?hether
hereto&ore denominated intrinsic or e'trinsic;, misre<resentation or other misconduct o& an adverse <art>8 D4; the
Cudgment is void8 or, D$; the Cudgment has =een satis&ied, released, or discharged, or a <rior Cudgment u<on ?hich it is
=ased has =een reversed or other?ise vacated, or it is no longer equita=le that an inCunction should have <ros<ective
a<<lication. .he motion shall =e made ?ithin a reasona=le time, and &or reasons D;, D!;, and D3; not more than % months
a&ter the <roceeding ?as taBen or the date that ?ritten notice o& entr> o& the Cudgment or order ?as served. 6 motion
under this su=division D=; does not a&&ect the &inalit> o& a Cudgment or sus<end its o<eration. .his rule does not limit the
<o?er o& a court to entertain an inde<endent action to relieve a <art> &rom a Cudgment, order, or <roceeding, or to set
aside a Cudgment &or &raud u<on the court. 4rits o& coram no=is, coram vo=is, audita querela, and =ills o& revie? and =ills
in the nature o& a =ill o& revie?, are a=olished, and the <rocedure &or o=taining an> relie& &rom a Cudgment shall =e =>
motion as <rescri=ed in these rules or => an inde<endent action.
.he 2rder or 0udgment is void as it e'tends to matters &or ?hich the Court cannot rule, ie, an 2rder allo?ing
?ithdra? ?here not good &aith =asis &or requesting a ?ithdra?al e'ists.
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<rosecutorial misconduct Dsuch as the D.6. ?ithholding @e'cul<ator>@ evidence that couldIve hel<ed >our de&ense;
Cudicial errors Dsuch as the Cudge <ermitting evidence that shouldIve =een e'cluded or vice versa;
erroneous a<<lication o& a la? or regulation im<ro<er Cur> instructions
ine&&ective assistance o& counsel or other mal<ractice the evidence did not <rove >our guilt =e>ond a reasona=le dou=t
36-:1)E .2 6332)D "-H./ 6EENDEEN. )-9/. .2 C21N"E: 2) 9)6N. DEE6ND 32) 01)7 .)-6:8
another DEE6ND 32) 01)7 .)-6: /E)EB7 E6DE -N E*EN. 23 NE4 .)-6:, "-E-:6):7 )EJ1E". 32)
-N 32)E6 5615E)-" ".6.1" /E)EB7 E6DE 6ND "1552).ED B7 6..6C/ED -35 5E.-.-2N
C2NC:1"-2N
De&endantF6<<elant Coughlin here=> res<ect&ull> requests all 2rders, Convictions,
0udgments, Contem<t 3indings, ?hatever, stemming &rom 3e=ruar> !nd ,!(! /earing on 5uentes
Eotion to 4ithdra? =e *acated or "et 6side or )econsidered and are here=> a<<eal ?ith an -35
request to ?aive the &iling &ee &or the notice o& a<<eal or allo? a relation =acB &or the &iling date u<on
an> denial o& the &ee ?aiver. 3urther, a co<> o& the audio o& the !F!F! /earing is here=> requested..
633-)E6.-2N 5ursuant to N)" !39B.(3(
.he undersigned does here=> a&&irm that the <receding document does not contain
the social securit> num=er o& an> <erson.
D6.ED this 3th Da> o& 3e=ruar>, !(
KFsF Zach Coughlin
Zach Coughlin
De&endant
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DEC:6)6.-2N 23 Z6C/ C219:-N -N "1552). 23 ./E 32)E92-N9 D2C1EEN.
. .his Declaration is made <ursuant to the <rovisions o& N)" $3.(4$, - am <resentl> in the "tate o&
Nevada and - declare under <enalt> o& <erCur> that the &oregoing is true and correct.
!. Declarant is the 5lainti&& in the a=ove title action.
3. Declarant avers that the &actual statements set &or a=ove in the &oregoing document are, to the
=est o& his Bno?ledge and understanding, accurate.
4. -, Zach Coughlin, am availa=le to testi&>, i& necessar>, as to these matters. - declare under <enalt>
o& <erCur> that the &oregoing is true and correct.
E'ecuted on 3e=ruar> 3th, !(!
FsF Zach Coughlin
Zach Coughlin
5:6-N.-33
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5)223 23 "E)*-CE
-, Zach Coughlin, declare:
2n 3e=ruar> 3th, !(!, -, Er. Zach Coughlin served the &oregoing Notice o& 6<<eal,
Eotion to *acate and or "et 6side, 0C)C5 $9, 0C)C5 %(, Eotion &or )econsideration8 Eotion &or
)ecusal => emailing and &a'ing and or <lacing in the mail a true co<> thereo& to:
0ill DraBe
Com<an>: )eno Cit> 6ttorne>As 2&&ice , Criminal Divison 6ddress: 5.2. Bo' 9(( )eno , N*
+9$($ 5hone Num=er: 77$,334,!($( 3a' num=er: 77$,334,!4!(
DraBe0Lreno.gov
D6.ED ./-" 3th da> o& 3e=ruar>
B7:
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Zach Coughlin
De&endant
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-nde' to E'hi=its
. E'hi=it : .?ent>,si' D!%; <age collection o& attorne> client corres<ondence =et?een Coughlin
and 5uentes in su<<ort o& the undersigned contnetions herein.
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EH/-B-.
EH/-B-.
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continuance and my files

continuance and my files
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 12/09/11 1:11 AM
To: puenteslaw@aol.com

Dear Mr. Puentes,

I would like for you to subpoena both Officers present at the arrest of November 13, 2011 to testify at the trial. I would like for you to subpoena (by
subpoena duces tecum, I suppose) all recordings, dispatch reports, written documentation, reports in any way connected to, or other materials, whether
admissible or not, in any way connected to the arrest of November 13, 2011 or the charges against which I am defending in conjunction with your
representation. I wish for you to email me these materials to the extent possible, and where that is not possible, please mail them to me at my address
of record at www.nvbar.org, and found below at the end of this letter. Email is better for me than fax, as it is free whereas I have to pay for faxes by the
page, whether local or not. I prefer email too over having to take time out of what is an extremely busy and trying schedule of mine currently.

RPD Officer Carter made a statement at the scene of the arrest that Mr. Richard Hill paid him a lot of money and therefore he does what Mr. Hill says to
do and arrest who Mr. Hill says to arrest. This has been reported to several RPD Officers, including Sargent Tarter, who responded by retaliating against
me with several traffic citations and made incorrect assertions about whether one would be turning into oncoming one way traffic to get to Mr. Hills
652 Forest St. address from the intersection of Forest and St. Laurence in justifying his retalitatory citation (for which he apparently called in another
officer to write out, curiously). I DO NOT WANT YOU TO DISCUSS MY CASE WITH ANYONE OUTSIDE OF MY PRESENCE, INCLUDING VERBAL
AND OR WRITTEN COMMUNICATIONS. THIS INCLUDES ANY COMMUNICATIONS, VERBAL OR WRITTEN WITH THE RENO MUNICIPAL
COURT AND ANYONE IN ANY WAY CONNECTED WITH THE RENO POLICE DEPARTMENT OR RENO CITY ATTORNEY'S OFFICE, AS WELL AS
LEW TAITEL.

Please email or fax meacompletecopy of my file, including all pleadings, correspondences, and any other documentation or mediaat all connected with my case.
Please further discloseany conflicts of interest you might havein representing me. I did not agreeto acontinuance, and I believeit is my right as aclient to control
themeans and objectives of thelitigation and or defense, and that, to me, does not includewaiving my right to contest any motion for acontinuanceor making things
nice and easy for Richard G. Hill, Esq. Further, I would liketo know who agreed to thecontinuanceand why it is Mr. Taitel is no longer attorney of record (nothing
against you, pleasebelievethat).

Further, if Mr. Taitel is no longer attorney of record in this matter, pleaseexplain why, in detail, in writing. If he has withdrawn, and if you did so based on some
conflict of interest, how is it that that conflict of interest did not precludehim fromapparently agreeing to acontinuanceor failing to filean opposition or alerting me
to the situation at all? Pleasenotemy new address and contact information below. Additionally, pleaseindicate, in writing, theextent to which you havean
established procedureto check for conflicts prior to taking on cases and prior to obtaining confidential client files and information. Pleaseindicatein writing any
deviation fromsuch aprocedureor failing of your office's practices to prevent such prejudiceto my casein your taking on my representation. Pleasecopy meon any
and all correspondences and or documentation or discovery in any way related to this matter.

Sincerely,
/S/ ZACH COUGHLIN, SIGNED ELECTRONICALLY

Zach Coughlin
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

Sent: Fri 12/09/11 3:53 AM
1 attachment
12 8 11 fax to Puentes.pdf (63.6 KB)
Mr. Puentes, please find attached my signed written request for you to file certain motions. I want to
review the final drafts prior to your filing them and have tried hard to do most of the work for you.
Further, you might find the following documentary that someone posted on youtube.com helpful in
understanding this case:
http://www.youtube.com/user/25teddyjames?feature=watch

Zach Coughlin, Esq.
Reno, NV 89501
Tel: please only communicate in writing
Page 1of 26 Hotmail Print Message
2/2/2012 http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=cc595d46-b764-4d56-...
Fax: 949 667 7402

Dear Mr. Puentes,

I would also like for you to subpoena Dr. Matt Merliss, the owner of the property who was present at the scene of arrest. Further, I would like for you to
depose both RPD Officers (Carter and the female Officer). I would like a copy of the probable cause sheet and all witness statements and Officer's
Supplemental Declarations as soon as possible, please, in addition to all the other materials I set forth in my previous written correspondence to you.

I would like a Motion in Limine to be filed to exclude anything discovered upon the RPD illegal search of the property, including any videos by Richard
Hill or anyone else that the Reno City Attorney seeks to have admitted. I want a Motion to Dismiss filed seeking to dismiss this case based upon a
number of arguments, including the fact that any underlying Summary Eviction Order was void for lack of jurisdiction (please see my recent filing,
attached, in Reno Justice Court case rev2011-001708, in that this was noticed as a No Cause Eviction against a commercial lessee. As such, any
Summary Eviction Order is void for lack of jurisdiction given the express prohibition in both NRS 40.253 and the Nevada Supreme Court's explanation in
the Landlord Tenant Handbook found on the Supreme Court's website and elsewhere where it is made explicitly clear that landlord's may not use
Summary Eviction Proceedings to evict commercial lessees or tenants where non payment of rent is not alleged or where the Notice of Eviction or
Unlawful detainer is a No Cause notice, as was the case in Rev2011-001708. As such, no trespassing could have occurred.
Beyond that, I am requesting you file a Motion to Dismiss based upon the fact that any lockout occurring on November 1, 2011 necessarily occurred
too early and prior to any lawful notice or service of any Summary Eviction Order only signed on October 27
th
, 2011, especially where no personal
service of such an ordered was alleged or shown. I detailed this in the email pasted below.
Further, a Motion to Dismiss I request you file due to Casey Baker's November 11, 2011 letter to me wherein he sends me a bill for the full rental value
of the property where the commercial lease was located for the entire month of November 2011, a period after the alleged illegal lockout. As such, no
trespass could have occurred because such a bill for rent is tantamount to rescinding any void eviction order or otherwise indicative of an invitation,
entrapment, or assent to the addressee of such a letter or bill being able to go onto the property, allegedly. In his letter mailed to Coughlin of
November 10, 2011, Casey Baker, Esq wrote In addition to the sums identified by Dr. Merliss in his affidavit, your debt now also includes fees for
storage of your personal possessions left at the property, which accrue daily at the fair rental value of the property. Your debt further includes actual
costs for inventorying and moving your possessions from the property. See NRS 118A.460. Those sums will be provided to you once they have been
fixed. Enclosed you will also find a notice of entry of the court's order awarding costs and attorney's fees against you. The court's award of cost in the
amount of $421.75, and attorney's fees in the amount of $1,500.00, has now been reduced to judgment. You are responsible for those sums. Further, as
you know, in his Memorandum of Costs and Disbursements filed on October 27,2011, Dr. Merliss actually sought $607.24 in costs and $17,938.75 in
attorney's fees against you. We believe you are responsible for those amounts, plus any and all fees and costs that have accrued, and continue to
accrue, since Letter to Zachary Coughlin Re: Verification of Debt November 10, 2011 Page 20f2 that date, in the matters currently pending before the
courts as an item of damages. Dr. Merliss win seek recovery of those sums, and an future fees and costs incurred, through the appropriate channels...

As such, Baker and Hill sent Coughlin a bill for the full rent of the property. $900 a month was the rent for the property under the commercial lease.
Baker and Hill wrote telling Coughlin they were continuing to charge him that even after the alleged illegal lockout of November 1, 2011. Further, Baker
and Hill flagrantly wrote to Coughlin in the same letter that the impermissible $1,500 in attorney's fees ordered by Judge Sferrazza was not enough for
them, and that they fully intended to continue to pursue recovery of the nearly $20,000 in attorney's fees they sought in their Memorandum of Fees and
Costs of October 27
th
, 2011, despite the res judicata effect of Judge Sferrazza's November 9, 2011 Order granting them $1,500 in attorney's fees, and
despite the fact that NRS 69.030 only allows for prevailing party attorney's fees in civil actions, while JCRCP 3 specifically provides that there are three
types of matters in Nevada's Justice Court, and expressly separates landlord tenant matters from civil actions, and, as such, the prevailing party
attorney's provisions of NRS 69.030 do not apply and there exists no other basis for an attorney's fees award under any of the arguments Baker or Hill
put forth. There conduct is tantamount to extortion while leveraging their law licenses and degrees.

Further, I would like for you to seek a continuance of the trial in this matter as this case is going to require extensive discovery, settlement negotiations,
and other complex legal work and there is not enough time for that as the schedule is currently set. I am attaching a collection of written materials the
landlord/property owner at 121 River Rock St 89501 (where the trespass arrest occurred sent me), including some letters that inform me they were
charging me the full rent of the property for the entire month of November 2011 (the illegal lockout allegedly occurred on November 1, 2011, though
there has been no proof of service or "receipt" pursuant to NRS 40, and given that the lockout was apparently signed by Judge Sferrazza on October
27th, 2011, that day does not count for service of the Order, the Reno Justice Court is closed on Fridays, non judicial weekend days don't count for the 3
days for service under NRCP 4-6, etc. As such, the earliest service by mail could have been affected for the Order for Summary Eviction would have been
November 2, 2011. It is alleged the lockout occurred prior to that time, and further, no emails were received from Richard Hill's email address,
rhill@richardhillaw.com at any point between August 17th, 2011 and November 18th, 2011, period. Whether any emails from Hills
rhill@richardhillaw.com address were "bounced back" to him or whether that address was added to my "blocked sender" list is a matter for Mr. Hill to
sludge his way through, but I can attest under penalty of perjury that I did not receive any emails from that rhill@richardhillaw.com email address
between that time period. I can further attest that I made calls and written correspondences to both Hill's rhill@richardhillaw.com email and his
associate Casey Baker, Esq.'s email, electroencephalographic addresses that went unresponded to with regard to my numerous requests to be allowed
access to remove my property commercial and otherwise

These included, but were not limited to, the following:

From: zachcoughlin@hotmail.com

Sent: Wed 11/09/11 12:43 PM

To: Casey Baker (cdbaker@richardhillaw.com)

Don't ignore my calls about my possessions. You potentially conducted an illegal lockout of a law office an inspection outside my presence. The lease
requires my presence. It also makes your guy responsible for the electric bill, read it carefully. Show your proof of any "receipt" of any lockout order 24
hours prior to your actions. My possessions better be safe and afforded all legal protections and I want updates one whatf is being done with them and
an opportunity to clean or otherwise put the premises in the condition I intended to leave it in prior to the illegal lockout. I want my possessions that
are in the house and all privacy rights respected. There is a motion for stay in district court right now.

Re: Verification of Your Debt? 11/10/11
To Casey Baker
(Sent: Thu 11/10/11 12:24 PM
To: Casey Baker (cdbaker@richardhillaw.com)
You guys are way over the days for providing verification under the FDCPA. Can you say treble damages? I habe not received a single email such as
those you refer to from richard hill. I dont consent to service of anything via email from your shop. I know you want everything to be at warp speed, but
you have to serve me through the mail or some non electronic means. Make sure rich isnt getting "unnsuccessful email transmission" messages....i can
certainly prove i have not received any such emails from Dick. I want my stuff its important client materials etc. You guys have not returned my
messages about that, its wrong to try to charge me rent when you are ducking me.

From: zachcoughlin@hotmail.com Sent: Fri 11/11/11 12:49 AM To: Casey Baker (cdbaker@richardhillaw.com); rhill@richardhillaw.com
(rhill@richardhillaw.com) Hi Guys, I have been having some technical difficulties, some emails appear blank or black, kind of like your client described in
response to some of my emails. Hey, ever heard of a litigation hold notice? That is what this is ,please retain and failure messages you recieve in your
own email which might prove that an email you sent me just didn't quite make it. You know just producing a copy of some email you sent me (even
though i have repeatedly told you i dont consent to service electronically in any form and am not a registered efiler like you two legal eagles) is not
going to be good enough when i break out the old litigation hold notice and anything elese that might tend to show any emails you sent could not
have made it to me....why such a rush, Boys? You are doing your patented and typical bang up milking job on thos headstrong rich client of yours...smell
the flowers a little. For instance, you don't want to do an illegal lockout and illegal inspection, particularly where the lease calls for my presence at any
inspection and then if you did not make sure the "receipt" requirement was met for any lockout order then went ahead and violated someone's
constitutional rights to boot. Plus you are way late on the FDCPA stuff, and the prevailing party atty fee statute is for cicil actons, which jcrcp 3 separates
justice court matters into 3 types, and the civil actions mentioned in seller's prevailing party fee statute is mentioned as different from landord tenant
cases and small claims cases..So where is your good faith basis for moving for atty fees, much less for $20k worth of them. Why did you cite the
controlled substances manufacture statute to support your atty fee motion? I pulled every eviction y'all ever done... RJC has been like swinging the bat
in the on deck circle with 5 donuts on the bat for me, gentlemen. For you, its been the polar opposite. But we gettin' called up to the show! You never
know when you are on tape or film guys. And my bat speed is lookin' tremendous. I have tried again and again to get some response from you guys
about accesing my important files and keeping my very valuable possesions safe but have yet to here back feom you, in the event you have done a
lockout. Mr. Baker said he did some filmmaking or something when he broke in to any attorneys office, it was hard to hear through all the cooing.
Anyways, I aren't that smart, but dontcha have to like store my possessions after movin' them somewhere safe, the make a reasonably diligent attempt
to rent the place out to mitigate and damages or lost rent, plus provide me my deposit within like 10 days or something? I know mighty Casey likes to
give me lil research projects, but I am busy fleshing out some motion work right now, so maybe you get on that and let me know when and where I can
get my things and valuable client files, hopefully you two points of light haven't done nuthhin' to 'em. Now, I dont want to come between you and
Casey...I know he is probably getting a little tired of you keeping most of the profit while he gets dirty doing the gutters, but you guys have a nice lil
batman robin thing going and it would be a shame to see it end, so let's just try and make this work."

From the alleged date of the illegal lockout of November 1, 2011 until Casey Baker's November 10, 2011 written bill to me for full rent for the month of
November 2011 (ie, after the alleged illegal lockout and therefore extinguishing the eviction and creating a new lease or rescinding the eviction order
and, perhaps making extortionate threats to apply an unlawful rent distraint in contravention of NRS 40.460, and NRS 40. 520, etc.) I received two
written correspondences of any sort from anyone connected with the landlord Matt Merliss (a neurosurgeon graduate of Beverly Hills HS) and the law
office of Richard G. Hill, Esq. (including Hill and Baker, etc.). These two written correspondences from Casey Baker are attached and pasted below:

subject: Verification of Your Debt
11/10/11
Casey Baker
To zachcoughlin@hotmail.com
From: Casey Baker (cdbaker@richardhillaw.com)
Sent: Thu 11/10/11 11:13 AM
To: zachcoughlin@hotmail.com
1 attachment
LT Coughlin (verif of debt)(11-10-11).pdf (146.0 KB)
Mr. Coughlin:
Attached please find my letter to you dated November 10, 2011.
Sincerely,
Casey D. Baker, Esq.
Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858

Email: cdbaker@richardhillaw.com
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RE: request for 30 days additional to stay in possession disability

11/04/11
Casey Baker
To zachcoughlin@hotmail.com
From: Casey Baker (cdbaker@richardhillaw.com)
Sent: Fri 11/04/11 12:36 PM


Mr. Coughlin:

We have never been served with any paper entitled Motion to Continue in Possession. If you have proof to the contrary, please provide it.
With respect to your request for another 30 days, please identify the legal and factual basis for your request, including any specific statute you are
purporting to invoke.
Casey Baker

Below for your convenience is a copy of the email I recently sent you as my, Zach Coughlin's, counsel of record, Mr. Puentes:

Zach Coughlin, Esq.
Subject: continuance and my files
Date: Fri, 9 Dec 2011 01:11:35 -0800

Dear Mr. Puentes,

I would like for you to subpoena both Officers present at the arrest of November 13, 2011 to testify at the trial. I would like for you to subpoena (by
subpoena duces tecum, I suppose) all recordings, dispatch reports, written documentation, reports in any way connected to, or other materials, whether
admissible or not, in any way connected to the arrest of November 13, 2011 or the charges against which I am defending in conjunction with your
representation. I wish for you to email me these materials to the extent possible, and where that is not possible, please mail them to me at my address
of record at www.nvbar.org, and found below at the end of this letter. Email is better for me than fax, as it is free whereas I have to pay for faxes by the
page, whether local or not. I prefer email too over having to take time out of what is an extremely busy and trying schedule of mine currently.

RPD Officer Carter made a statement at the scene of the arrest that Mr. Richard Hill paid him a lot of money and therefore he does what Mr. Hill says to
do and arrest who Mr. Hill says to arrest. This has been reported to several RPD Officers, including Sargent Tarter, who responded by retaliating against
me with several traffic citations and made incorrect assertions about whether one would be turning into oncoming one way traffic to get to Mr. Hills
652 Forest St. address from the intersection of Forest and St. Laurence in justifying his retalitatory citation (for which he apparently called in another
officer to write out, curiously). I DO NOT WANT YOU TO DISCUSS MY CASE WITH ANYONE OUTSIDE OF MY PRESENCE, INCLUDING VERBAL AND OR
WRITTEN COMMUNICATIONS. THIS INCLUDES ANY COMMUNICATIONS, VERBAL OR WRITTEN WITH THE RENO MUNICIPAL COURT AND ANYONE IN
ANY WAY CONNECTED WITH THE RENO POLICE DEPARTMENT OR RENO CITY ATTORNEY'S OFFICE, AS WELL AS LEW TAITEL.

Please email or fax me a complete copy of my file, including all pleadings, correspondences, and any other documentation or media at all connected
with my case. Please further disclose any conflicts of interest you might have in representing me. I did not agree to a continuance, and I believe it is my
right as a client to control the means and objectives of the litigation and or defense, and that, to me, does not include waiving my right to contest any
motion for a continuance or making things nice and easy for Richard G. Hill, Esq. Further, I would like to know who agreed to the continuance and why
it is Mr. Taitel is no longer attorney of record (nothing against you, please believe that).

Further, if Mr. Taitel is no longer attorney of record in this matter, please explain why, in detail, in writing. If he has withdrawn, and if you did so based
on some conflict of interest, how is it that that conflict of interest did not preclude him from apparently agreeing to a continuance or failing to file an
opposition or alerting me to the situation at all? Please note my new address and contact information below. Additionally, please indicate, in writing,
the extent to which you have an established procedure to check for conflicts prior to taking on cases and prior to obtaining confidential client files and
information. Please indicate in writing any deviation from such a procedure or failing of your office's practices to prevent such prejudice to my case in
your taking on my representation. Please copy me on any and all correspondences and or documentation or discovery in any way related to this matter.

Sincerely,
/S/ ZACH COUGHLIN, SIGNED ELECTRONICALLY
Zach Coughlin
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402


faxed signed letter attached
Sincerely,

Zach Coughlin, Esq.
Sent: Wed 12/14/11 12:35 AM
2 attachments
12 14 11 faxed letter to Puentes 11 CR 26405 2I.pdf (55.0 KB) , Coughlin IFP and Financial Inquiry Application RMC 11222011 11 CR 26405
2I.pdf (381.9 KB)
Mr. Puentes,
Please find my faxed signed letter attached. Also, if I am supposed to file an updated Financial Status
Application, please find that attached.

December 13th, 2011
Dear Mr. Puentes,
Hello, I received a package from you in the mail today. It did not contain a letter from you or any
indication of whether you will subpoena Dr. Merliss to attend the January Trial date, which is fast
approaching, whether you will depose him or Richard Hill, etc. Please respond in writing regard the
various written requests and questions I posed to you in my recent written correspondences, including,
but not limited to, whether you will comply with my requests to file a Motion in Limine, Motion to
Dismiss, Depose Dr. Merliss and Richard Hill, file a Motion to Set Aside the Continuance, for which I
was never appropriately provided a chance to contest, or served the Original Motion for Continuance.
I want to be copied, in writing, on every single thing related in any way to this case. RMC Rules
require the attorney, such as you and Lew Taitel to file a Notice of Appearance and to file a Motion to
Withdraw. Please provide a copy of the docket in this case. I do not see where Mr. Taitel ever filed a
Motion to Withdraw or where an Order Granting such a withdrawal was granted. It is my
understanding, though, that an Order Granting a Motion to Dismiss was likely entered. I want for you
to file a Motion To Set Aside that Order if it was based on Richard Hill citing some lame reason, like he
was going to be Porsche shopping in Florida or otherwise on vacation for some extended stretch or that
Richard Hill was the only person able to testify about whatever it is Richard Hill may want to testify
about. Dr. Merliss can take time out of raking in millions of dollars being a Beverly Hills HS graduate
neurosurgeon. I want him subpoenaed and deposed for the upcoming trial. I want a subpoena duces
tecum served on Richard Hill for any evidence related to this case, including any videos. Further, I
want you to make an inquiry and take appropriate action to discern whether I was appropriately served
any Notice Setting Hearing documents in this case, ascertaining exactly who (including which Marshal)
may have served me anything, the manner and place in which is was served, whose signature is there,
etc., whether the signature bears a date that is PRIOR in time to the Print Date on the Notice Setting
Hearing, etc.
Further, I want you to subpoena or obtain a copy of (and provide one to me) of the video of the
November 14th, 2011 arraignment, the entire video, start to finish (not just my appearance), I will pay
any charge if I have to, but I believe an IFP was granted that would cover such a charge in this matter.
I do not believe it would be accurate for the Reno Municipal Court to state or write, with respect to my
and the November 14, 2011 arraignment, that DEFENDANT APPEARED, WAS EXPLAINED
HIS/HER RIGHTS BY THE JUDGE AND INDICATED THAT HE/SHE UNDERSTOOD THEM
COMPLETELY... If the RMC has made that assertion in writing I want you to file something in
writing contesting that assertion. I do not believe I have been told that there is any possibility that I will
be required to pay you or the RMC any fees in connection with your representation. If that is not the
case, please explain in writing.
Sincerely,
Zach Coughlin, Esq

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
ZachCoughlin@hotmail.com

client controls means and objectives of litigation under Rules of Professional
Conduct
Nevada Bar No: 9473

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Sent: Wed 12/14/11 12:52 AM
Dear Mr. Puentes,

Please let me know when we can discuss my case, the trial is very soon. I received a mailing from you, but it did not have a signed letter
from you stating what was in the package. Please email me or fax me any document production in the future and redact my personally
identifiable information from all documentions coming in or out of your office.
In the mailing I received from you was:
1. WCSO Mugshot Profile booking no: 1119876, one page
2. Criminal Complaint 11-22185, one page, signed by Richard Hill, not filestamped
3. ARrest Report and Declaration of Probable Cause rpd 1101921 C r650225 , Declarant RPD Officer Carter, no Magistrate signature
(please find out why), one page
4. RPD, 3 pages 11-22185 Adminstrative Information, etc. (please subpoena and depose both RPD Officer's Lopez and Carter, asking them
whether they verbally identified themselves prior to, according to Hill, kicking the door down, and further questions them concerning the
accuracy of Hill's written statement and whether Officer Carter said to the accused that Richard Hill pays him, Officer Carter, a lot of
money and therefore Carter arrests who Hills says to arrest and does what Hill says to do. Further, please depose both officers, asking
whether the accused requested they take any action or ask Hill any questions and whether the Officers did so. Please subpoena the RPD for
any recordings, calls, documentation relating to this matter, or RPD Sargent Tarter's alleged retaliation against me and the traffic citations
he called in another RPD officer to write against me on or around November 15th, 2011. Please file a counterclaimalleged 42 USC 1983
violations againt the City of Reno and the RPD, in addition to other appropriate counterclaims. Please depose Hill to verify his written
account that he actually walked into the Basement, that Merliss himself kicked the door down, whether the RPD Officers verbally
identified themselves prior to the door being kicked down, whether the accused hesitated at all upon the RPD identifying themselves, etc....

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473


CORRECTION FW: client controls means and objectives of litigation under Rules
of Professional Conduct
confidential information intended for thespecified individual (s) only. If you arenot theintended recipient or anagent responsiblefor delivering it to theintended

Sent: Wed 12/14/11 1:19 AM
Dear Mr. Puentes,

Please amend the list below to include the following:
5. RPD Statement by Richard Hill 11-22185

Further, please note I mistakenly noted in paragraph 4 below, that Hill was attributed as making a
written stament about entering the basement. Please, instead, ask the same questions of Officer Carter,
as to whether he "entered the doorway of the basement and found..." and what exactly he means by "He
was hesitant to come out and eventually did so". IE, what exactly does "eventually" mean? Like, one
second, ten minutes? What? Whether Officer Carter ever actually stepped foot in the basement, or
whether by writing that he "entered the doorway" Officer Carter is actually stating that he peeked his
head in or otherwise peered in. Please inquire as to whether the RPD refused to kick the door down or
whether someone else did, etc. PLEASE ASK OFFICER CARTER WHETHER HIS WRITTEN
STATMENT IS ENTIRELY ACCURATE WHERE IT ATTRIBUTES A QUOTE TO THE
ACCUSED THAT CARTER IS OR WAS "ON RICHARD HILL'S PAYROLL..." and further what
exactly was allegedly said about "working a deal". Please ask Carter and Lopez whether the accused
asked why they didn't just issue a citation and whether one would be arrested for getting their mail after
an eviction and why exactly an incarceration was necessary compared to a citation. Please further
inquire as to whether these Officers refused to make any arrests or investigation requested by the
accused and whether Carter indicated that he would never arrest anyone based on anything said by the
person he is arresting at the time such accusations, or counter accusations, are made. Please further
send Merliss and Hill subpoena duces tecum/interrogatories/request for production/ and request for
admission seeking specific, written indication and evidence supporting all contentions in any of the
materials upon which this arrest or this case is based, including, but not limited to Hill's written
statement that "We have observed evidence that he was coming and going."

Sincerely,

Zach Coughlin

Subject: client controls means and objectives of litigation under Rules of Professional Conduct
Date: Wed, 14 Dec 2011 00:52:25 -0800

Dear Mr. Puentes,

Please let me know when we can discuss my case, the trial is very soon. I received a mailing from you, but it did not have a signed letter
from you stating what was in the package. Please email me or fax me any document production in the future and redact my personally
identifiable information from all documentions coming in or out of your office.
In the mailing I received from you was:

THIS COULD WIN THE CASE IN 11 CR 26405 2I
1. WCSO Mugshot Profile booking no: 1119876, one page
2. Criminal Complaint 11-22185, one page, signed by Richard Hill, not filestamped
3. ARrest Report and Declaration of Probable Cause rpd 1101921 C r650225 , Declarant RPD Officer Carter, no Magistrate signature
(please find out why), one page
4. RPD, 3 pages 11-22185 Adminstrative Information, etc. (please subpoena and depose both RPD Officer's Lopez and Carter, asking them
whether they verbally identified themselves prior to, according to Hill, kicking the door down, and further questions them concerning the
accuracy of Hill's written statement and whether Officer Carter said to the accused that Richard Hill pays him, Officer Carter, a lot of
money and therefore Carter arrests who Hills says to arrest and does what Hill says to do. Further, please depose both officers, asking
whether the accused requested they take any action or ask Hill any questions and whether the Officers did so. Please subpoena the RPD for
any recordings, calls, documentation relating to this matter, or RPD Sargent Tarter's alleged retaliation against me and the traffic citations
he called in another RPD officer to write against me on or around November 15th, 2011. Please file a counterclaimalleged 42 USC 1983
violations againt the City of Reno and the RPD, in addition to other appropriate counterclaims. Please depose Hill to verify his written
account that he actually walked into the Basement, that Merliss himself kicked the door down, whether the RPD Officers verbally
identified themselves prior to the door being kicked down, whether the accused hesitated at all upon the RPD identifying themselves, etc....

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473


Sent: Wed 12/14/11 5:02 AM
5 attachments
11 1 2011 Affidavit of Service, Notice of Entry of Order, and Order for Summary Eviction Rev2011-001708.pdf (7.8 MB) , Affidavit of Service
Sheriff's Machen 4 30 pm 11 1 2011.pdf (555.1 KB) , 12 14 11 fax to Puentes ISSUES THAT CAN WIN THE CASE.pdf (144.2 KB) , 11 21 11
Declaration of Richard Hill attach to his M for OSC (11-21-11) Compare to Police Reports and deposition of RPD's Carter and Lopez and
Merliss.pdf (791.4 KB) , 11 21 2011 REV2011-00178 RICHARD HILL'S M for OSC (11-21-11).pdf (711.7 KB)
ZachCoughlin, Esq.
817N. VirginiaSt. #2
Reno, NV89501
Tel: pleaseonlycommunicateinwriting
Fax: 9496677402
LicensedinNevada, NV Bar No: 9473

December 14
th
, 2011

Dear Mr. Puentes,

Mr. Puentes,

Please find attached the Affidavit of Service, filed November 7th, 2011 in the eviction case in RJ C (REV2011-0017808) from which the
trespass case you are Attorney of Record for (RMC 11 CR 26405 2I) stems. TURNS OUT, THE AFFIDAVIT OF SERVICE FILED BY
THE WASHOE COUNTY SHERIFF'S AUTHORIZED AGENT, J OHN MACHEN ADMITS, IN WRITING, THAT THE EVICTION
ORDER AND LOCKOUT WERE SERVED AND CONDUCTED PRIOR TO THE TIME AND DATE CALLED FOR BY THE
EVICTION ORDER (WHICH WAS NOT EVEN PUT INTO THE MAIL WITH A PROOF OF SERVICE UNTIL NOVEMBER 1,
2011...AND NRCP 4-6 APPLY TO STATUTORY UNLAWFUL DETAINER ACTIONS, THEREFORE, THE RJ C IS CLOSED
FRIDAYS AND OTHER NON JUDICIAL DAYS DO NOT COUNT, NOR DOES THE DAY THE ORDER IS SIGNED COUNT).
PLEASE ALSO FIND ATTACHED RICHARD HILL, ESQ'S DECLARATION ATTACHED TO A MOTION TO SHOW CAUSE HE
FILED IN REV2011-001708, WHICH I BELIEVE MAY PROVIDE FERTILE GROUND FOR IMPEACHING THE WRITTEN
STATEMENTS AND FUTURE TESTIMONY OF RPD OFFICER'S CARTER, LOPEZ, LANDLORD MERLISS, HILL HIMSELF,
ETC. PLEASE DO NOT DISCUSS THIS VERBALLY OR IN WRITING WITH ANYONE OTHER THAN MYSELF ABSENT MY
EXPRESS WRITTEN CONSENT PRIOR TO DOING SO.

I prefer to discuss this with you prior to your taking any action in relation to this illegal lockout or insufficient service of process or early
lockout or however it is described. The Sheriff's server, Machen, might try to argue that he served the Eviction Order at 4:30 pm, then
waited around until after 5 pm (as required by the Eviction Order) to perform the actual lockout. I think it would be best to get Machen
admitting, by tricking him into admitting, if necessary, that he performed the lockout within minutes of serving the Eviction Order.
Further, the law in our State does not seemexceptionally clear with regard to the service and process requirements and timelines, and
manner of calculating time with respect to the "receipt" of Lockout Orders. The Affidavit of Service by Machen states that he "personally
served the described documents upon" my, Zach Coughlin...However, I can attest by Affidavit that I was not "personally served" to the
extent that "personally served" means or implies that I was there, that Machen saw me or identified me, or any of the other indicators of
something, such as a Complaint, being "personally served" such as I understand the phrase to me. NRCP 5(b)(2)(A)(i-iii). Further, as
Baker and Hill have so often pointed out, I cannot, according to them, receive any attorney's fee award for appearing as pro se attorney, as
such, NRCP 5(b)(2)(A)(i-iii), should apply to me only as a party, and not as a party's attorney, and, therefore, according to NRCP 5,
Service: "(2) Service under this rule is made by: (A) Delivering a copy to the attorney or the party by: (i) handing it to the attorney or to the
party; (ii) leaving it at the attorneys or partys office with a clerk or other person in charge, or if there is no one in charge, leaving it in a
conspicuous place in the office; or (iii) if the office is closed or the person to be served has no office, leaving it at the persons dwelling
house or usual place of abode with some person of suitable age and discretion residing there..." So, either it was my office, in which
case a No Cause Eviction Notice makes impermissible a Summary Eviction Proceeding under NRS 40.253, and therefore, the Order of
Summary Eviction is void for lack of jurisdiction, or, the Affidavit of Service was on my home, and was not "handed" to me, or
"personally served" (despite the Affidavit attesting to having "personally served" me), nor was the Order of Summary Eviction served in
accordance with NRCP 5(b)(2)(A)(iii), which requires: "if the office is closed or the person to be served has no office, leaving it at the
persons dwelling house or usual place of abode with some person of suitable age and discretion residing there.."

Further, I believe posting an Order on one's residence door, particularly in the context of serving a No Cause Notice of Eviction or
Unlawful Detainer, is only valid if the document being served is also placed in the mail and 3 non judicial days are accorded for service to
be complete. See NRCP 6(e). I do not believe they can prove that at all, not even close. NRCP applies to Summary Eviction Actions,
according to the following:
"NRS 40.380 Provisions governing appeals. Either party may, within 10 days, appeal from the judgment rendered. But an appeal by the
defendant shall not stay the execution of the judgment, unless, within the 10 days, the defendant shall execute and file with the court or
justice the defendants undertaking to the plaintiff, with two or more sureties, in an amount to be fixed by the court or justice, but which
shall not be less than twice the amount of the judgment and costs, to the effect that, if the judgment appealed frombe affirmed or the
appeal be dismissed, the appellant will pay the judgment and the cost of appeal, the value of the use and occupation of the property, and
damages justly accruing to the plaintiff during the pendency of the appeal. Upon taking the appeal and filing the undertaking, all further
proceedings in the case shall be stayed.
Actually, a lot of people seemed confused regarding the 24 hours lockout thing. The only appearance in either NRS 118A or NRS 40, in the provisions
applicable to Summary Eviction Proceedings of anything related to 24 hours is in NRS 40.253(5), which only speaks to a situation where the Tenant
does not file a Tenant's Answer or Tenant's Affidavit, which is clearly inapplicable here, as the Tenant did file such a Opposition to the No Cause Eviction
Notice: 5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
apartment, mobile home or commercial premises are located or to the district court of the county in which the dwelling, apartment, mobile home or
commercial premises are located, whichever has jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order. The affidavit must state or contain...
So, absent some statutory provision allowing the Order of Summary Eviction to result in a lockout by the Washoe County Sheriff's Office prior to the 3
days for mailing where personal service of the Order of Summary Eviction was not effectuated, despite what WCSO employee may have incorrectly (or
falsely) asserted in the WCSO's John Machem's Affidavit of Service from, file stamped November 7, 2011 (especially where it is timestamped 4:30 pm,
November 1, 2011, especially where the Order of Summary Eviction explicitly reads that no such lockout shall occur prior to 5:00 pm on November 1,
2011). See, NRCP 5(b)(2)(A)(i-iii), NRCP 6(e).
Interestingly, Richard Hill knows his case is toast under NRCP 5(b)(2)(A)(i-iii), NRCP 6(e), in addition to NRCP 11. That is why in
Richard Hill's November 21, 2011 Motion for Order To Show Cause, on page 2, Hills resorts to literally grasping at straws, imagining that
what the Washoe County Sheriff's Office customarily does is somehow automatically codified into mandatory precedent black letter law.
To wit, Richard Hill wrote in his Motion For Order To Show Cause that: FACTS SHOWING CONTEMPT OF COURT 6. EXHIBIT
1 was served on Coughlin on November " 2011 by the Washoe County Sheriffs Department, by posting same on the front door of the
property in the manner customary for evictions in Washoe County. The locks to the premises were changed at that time, thereby ejecting
and dispossessing Coughlin of possession of the Property. Further, therein Richard Hill admits that the lockout occurred at 4:30 pm, as
indicated in writing in the WCSO's Machem's Affidavit of Service, contra to the mandate of J udge Sferrazza's Order of Summary Eviction
requiring any lockout to occur after 5:00 pm, November 1, 2011.
NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of premises to pay rent during stay. Upon an
appeal from an order entered pursuant to NRS 40.253:
1. Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with the trial court a bond in
the amount of $250 to cover the expected costs on appeal. In an action concerning a lease of commercial property or any other
property for which the monthly rent exceeds $1,000, the court may, upon its own motion or that of a party, and upon a showing of
good cause, order an additional bond to be posted to cover the expected costs on appeal. A surety upon the bond submits to the
jurisdiction of the appellate court and irrevocably appoints the clerk of that court as the suretys agent upon whom papers
affecting the suretys liability upon the bond may be served. Liability of a surety may be enforced, or the bond may be released, on
motion in the appellate court without independent action.
2. A tenant who retains possession of the premises that are the subject of the appeal during the pendency of the appeal shall pay to the
landlord rent in the amount provided in the underlying contract between the tenant and the landlord as it becomes due. If the tenant fails to
pay such rent, the landlord may initiate new proceedings for a summary eviction by serving the tenant with a new notice pursuant to NRS
40.253.
NRS 40.390 Appellate court not to dismiss or quash proceedings for want of form. In all cases of appeal under NRS 40.220 to 40.420,
inclusive, the appellate court shall not dismiss or quash the proceedings for want of form, provided the proceedings have been conducted
substantially according to the provisions of NRS 40.220 to 40.420, inclusive; and amendments to the complaint, answer or summons, in
matters of form only, may be allowed by the court at any time before final judgment upon such terms as may be just; and all matters of
excuse, justification or avoidance of the allegations in the complaint may be given in evidence under the answer.
NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate
Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with the provisions of NRS 40.220 to
40.420, inclusive, apply to the proceedings mentioned in those sections.
So, considering that NRS 40.400 requires that NRCP apply to Summary Eviction Proceedings under NRS 40.253, then service, process,
and time calculations of such must comport with the dictates of NRCP 5-6: " RULE 5. SERVICE AND FILING OF PLEADINGS AND
OTHER PAPERS
(a) Service: When Required. Except as otherwise provided in these rules, every order required by its terms to be served, every
pleading subsequent to the original complaint unless the court otherwise orders because of numerous defendants, every paper relating to
discovery required to be served upon a party unless the court otherwiseorders, every written motion other than one which may be heard ex
parte, and every written notice, appearance, demand, offer of judgment, designation of record on appeal, and similar paper shall be served
upon each of the parties. No service need be made on parties in default for failure to appear except that pleadings asserting new or
additional claims for relief against them shall be served upon themin the manner provided for service of summons in Rule 4.
(b) Same: How Made.
(1) Whenever under these rules service is required or permitted to be made upon a party represented by an attorney, the service
shall be made upon the attorney unless the court orders that service be made upon the party.
(2) Service under this rule is made by:
(A) Delivering a copy to the attorney or the party by:
(i) handing it to the attorney or to the party;
(ii) leaving it at the attorneys or partys office with a clerk or other person in charge, or if there is no one in charge,
leaving it in a conspicuous place in the office; or
(iii) if the office is closed or the person to be served has no office, leaving it at the persons dwelling house or usual place
of abode with some person of suitable age and discretion residing there.
(B) Mailing a copy to the attorney or the party at his or her last known address. Service by mail is complete on mailing;
provided, however, a motion, answer or other document constituting the initial appearance of a party must also, if served by mail,
be filed within the time allowed for service; and provided further, that after such initial appearance, service by mail be made only
by mailing from a point within the State of Nevada.
(C) If the attorney or the party has no known address, leaving a copy with the clerk of the court.
(D) Delivering a copy by electronic means if the attorney or the party served has consented to service by electronic
means. Service by electronic means is complete on transmission provided, however, a motion, answer or other document
constituting the initial appearance of a party must also, if served by electronic means, be filed within the time allowed for service.
The served attorneys or partys consent to service by electronic means shall be expressly stated and filed in writing with the clerk
of the court and served on the other parties to the action. The written consent shall identify:
(i) the persons upon whom service must be made;
(ii) the appropriate address or location for such service, such as the electronic-mail address or facsimile number;
(iii) the format to be used for attachments; and
(iv) any other limits on the scope or duration of the consent.
An attorneys or partys consent shall remain effective until expressly revoked or until the representation of a party changes
through entry, withdrawal, or substitution of counsel. An attorney or party who has consented to service by electronic means shall,
within 10 days after any change of electronic-mail address or facsimile number, serve and file notice of the new electronic-mail address or
facsimile number.
(3) Service by electronic means under Rule 5(b)(2)(D) is not effective if the party making service learns that the attempted
service did not reach the person to be served.
(4) Proof of service may be made by certificate of an attorney or of the attorneys employee, or by written admission, or by
affidavit, or other proof satisfactory to the court. Failure to make proof of service shall not affect the validity of service...
RULE 6. TIME
(a) Computation. In computing any period of time prescribed or allowed by these rules, by the local rules of any district court, by
order of court, or by any applicable statute, the day of the act, event, or default from which the designated period of time begins to run
shall not be included. The last day of the period so computed shall be included, unless it is a Saturday, a Sunday, or a nonjudicial day, in
which event the period runs until the end of the next day which is not a Saturday, a Sunday, or a nonjudicial day, or, when the act to be
done is the filing of a paper in court, a day on which weather or other conditions have made the office of the clerk of the district court
inaccessible, in which event the period runs until the end of the next day which is not one of the aforementioned days. When the period of
time prescribed or allowed is less than 11 days, intermediate Saturdays, Sundays, and nonjudicial days shall be excluded in the
computation except for those proceedings filed under Titles 12 or 13 of the Nevada Revised Statutes...
(e) Additional Time After Service by Mail or Electronic Means. Whenever a party has the right or is required to do some act
or take some proceedings within a prescribed period after the service of a notice or other paper, other than process, upon the party
and the notice or paper is served upon the party by mail or by electronic means, 3 days shall be added to the prescribed period.
Subdivision (a) is revised to extend the exclusion of intermediate Saturdays, Sundays, and nonjudicial days to the computation of time
periods less than 11 days consistent with the 1985 amendments to the federal rule. Additionally, the inaccessibility of the court
provision found in subdivision (a) of the federal rule is added to Rule 6(a). Subdivision (a) is further amended, by adding language
referring to proceedings filed under Titles 12 or 13 of the Nevada Revised Statutes, to avoid any changes to current procedures in
probate, guardianship and trust proceedings....
Subdivision (e) is amended to provide an additional 3 days to act in response to a paper that is served by electronic means under
new paragraph (2)(D) added to Rule 5(b)."
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant for default in payment of rent.
1. Except as otherwise provided in subsection 10, in addition to the remedy provided in NRS 40.2512 and 40.290 to 40.420, inclusive,
when the tenant of any dwelling, apartment, mobile home, recreational vehicle or commercial premises with periodic rent reserved
by the month or any shorter period is in default in payment of the rent, the landlord or the landlordsagent, unless otherwise agreed in
writing, may serve or have served a notice in writing, requiring in the alternative the payment of the rent or the surrender of the premises...
4. If the tenant files such an affidavit at or before the time stated in the notice, the landlord or the landlords agent, after receipt of a
file-stamped copy of the affidavit which was filed, shall not provide for the nonadmittance of the tenant to the premises by locking or
otherwise.
5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the justice court of the township in which
the dwelling, apartment, mobile home or commercial premises are located or to the district court of the county in which the dwelling,
apartment, mobile home or commercial premises are located, whichever has jurisdiction over the matter. The court may thereupon issue an
order directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order..
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the information contained in the affidavit, and
the filing by the landlord of the affidavit permitted by subsection 5, the justice court or the district court shall hold a hearing, after service
of notice of the hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice provided for in this section.
If the court determines that there is no legal defense as to the alleged unlawful detainer and the tenant is guilty of an unlawful
detainer, the court may issue a summary order for removal of the tenant or an order providing for the nonadmittance of the
tenant. If the court determines that there is a legal defense as to the alleged unlawful detainer, the court shall refuse to grant either
party any relief, and, except as otherwise provided in this subsection, shall require that any further proceedings be conducted
pursuant to NRS 40.290 to 40.420, inclusive. The issuance of a summary order for removal of the tenant does not preclude an action
by the tenant for any damages or other relief to which the tenant may be entitled....
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a motion, file a motion with the court, on a
form provided by the clerk of the court, to dispute the amount of the costs, if any, claimed by the landlord pursuant to NRS 118.207 or
118A.460 for the inventory, moving and storage of personal property left on the premises. The motion must be filed within 20 days after the
summary order for removal of the tenant or the abandonment of the premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed fromthe premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the motion. The hearing must be
held within 10 days after the filing of the motion. The court shall affix the date of the hearing to the motion and order a copy
served upon the landlord by the sheriff, constable or other process server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118.207 or 118A.460 and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges determined to be due or if no charges are determined to
be due.
Landlord Merliss filed only a No Cause Notice of Eviction in REV2011-001708 on Commercial Tenant Zach Coughlin, Esq.'s law office.
As such, a Summary Eviction Proceeding is impermissible given the requirement of NRS 40.253 that the Notice alleged non-payment of
rent to allow the landlord to proceed under the Summary Eviction Proceeding section, NRS 40.253. Further, Judge Sferrazza was
precluded from ruling on anything other than possession of the premises pursuant to NRS 40.253(6), Anvui, and Glazier. Further, the
tenancy did not terminate under the Lease Agreement, it ws renewed.
NRS 40.254 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant from certain types of property.
Except as otherwise provided by specific statute, in addition to the remedy provided in NRS 40.251 and in NRS 40.290 to 40.420, inclusive,
when the tenant of a dwelling unit which is subject to the provisions of chapter 118A of NRS, part of a low-rent housing program operated
by a public housing authority, a mobile home or a recreational vehicle is guilty of an unlawful detainer, the landlord is entitled to the
summary procedures provided in NRS 40.253 except that:
1. Written notice to surrender the premises must:...(e) A statement that the claim for relief was authorized by law.
As such, the too early lockout brings into play the following:
NRS 118A.390 Unlawful removal or exclusion of tenant or willful interruption of essential services; procedure for expedited relief.
1. If the landlord unlawfully removes the tenant from the premises or excludes the tenant by blocking or attempting to block the
tenants entry upon the premises or willfully interrupts or causes or permits the interruption of any essential service required by
the rental agreement or this chapter, the tenant may recover immediate possession pursuant to subsection 4, proceed under NRS
118A.380 or terminate the rental agreement and, in addition to any other remedy, recover the tenants actual damages, receive an
amount not greater than $1,000 to be fixed by the court, or both.
2. In determining the amount, if any, to be awarded under subsection 1, the court shall consider:
(a) Whether the landlord acted in good faith;
(b) The course of conduct between the landlord and the tenant; and
(c) The degree of harmto the tenant caused by the landlords conduct.
3. If the rental agreement is terminated pursuant to subsection 1, the landlord shall return all prepaid rent and security recoverable under
this chapter.
4. Except as otherwise provided in subsection 5, the tenant may recover immediatepossession of the premises from the landlord by filing a
verified complaint for expedited relief for the unlawful removal or exclusion of the tenant fromthe premises or the willful interruption of
essential services.
5. A verified complaint for expedited relief:
(a) Must be filed with the court within 5 judicial days after the date of the unlawful act by the landlord, and the verified complaint must be
dismissed if it is not timely filed. If the verified complaint for expedited relief is dismissed pursuant to this paragraph, the tenant retains the
right to pursue all other available remedies against the landlord.
(b) May not be filed with the court if an action for summary eviction or unlawful detainer is already pending between the landlord and
tenant, but the tenant may seek similar relief before the judge presiding over the pending action.
6. The court shall conduct a hearing on the verified complaint for expedited relief within 3 judicial days after the filing of the verified
complaint for expedited relief. Before or at the scheduled hearing, the tenant must provide proof that the landlord has been properly served
with a copy of the verified complaint for expedited relief. Upon the hearing, if it is determined that the landlord has violated any of the
provisions of subsection 1, the court may:
(a) Order the landlord to restore to the tenant the premises or essential services, or both;
(b) Award damages pursuant to subsection 1; and
(c) Enjoin the landlord fromviolating the provisions of subsection 1 and, if the circumstances so warrant, hold the landlord in contempt of
court.
7. The payment of all costs and official fees must be deferred for any tenant who files a verified complaint for expedited relief. After any
hearing and not later than final disposition of the filing or order, the court shall assess the costs and fees against the party that does not
prevail, except that the court may reduce themor waive them, as justice may require.

NRS 118A.090 Exclude defined. Exclude means to evict or to prohibit entry by locking doors or by otherwise blocking or attempting to block entry,
or to make a dwelling unit uninhabitable by interrupting or causing the interruption of electric, gas, water or other essential services.
ALL PAPERS AND PLEADINGS AND CORRESPONDENCS PREVIOUSLY SUBMITTED TO THE RENO JUSTICE COURT AND OR ITS EMPLOYEES IS HEREBY
INCORPORATED BY REFERENCE INTO THIS FILING.
NRS 118A.190: Notice: Definition; service.
1. A person has notice of a fact if:
(a) The person has actual knowledge of it;
(b) The person has received a notice or notification of it; or
(c) From all the facts and circumstances the person reasonably should know that it exists.
2. Written notices to the tenant prescribed by this chapter shall be served in the manner provided by NRS 40.280.
3. Written notices to the landlord prescribed by this chapter may be delivered or mailed to the place of business of the landlord designated in the rental
agreement or to any place held out by the landlord as the place for the receipt of rental payments from the tenant and are effective from the date of
delivery or mailing.
NRS 40.280 Service of notices to quit; proof required before issuance of order to remove.
1. Except as otherwise provided in NRS 40.253, the notices required by NRS 40.251 to 40.260, inclusive, may be served:
(a) By delivering a copy to the tenant personally, in the presence of a witness;
(b) If the tenant is absent from the tenants place of residence or from the tenants usual place of business, by leaving a copy with a person of suitable
age and discretion at either place and mailing a copy to the tenant at the tenants place of residence or place of business; or
(c) If the place of residence or business cannot be ascertained, or a person of suitable age or discretion cannot be found there, by posting a copy in a
conspicuous place on the leased property, delivering a copy to a person there residing, if the person can be found, and mailing a copy to the tenant at
the place where the leased property is situated.
I did not receive any of the emails allegedly sent to my from Richard Hill's email address, rhill@richardhillaw.com between August 18
th
, 2011 to
November 17
th
, 2011, and certainly none from rhill@richardhillaw.com during the period between the illegal lockout at 4:30 pm November 1, 2011 and
the trespass arrest of November 13
th
, 2011 which allegedly spoke to my being provided access to the property for the purpose of my removing my
belongings, despite my numerous calls and written requests, which outlined the exigencies inherent to my being precluded access to my client files
incident to an unlawful and improperly notice and too early occurring lockout by the WCSO. I and my business have been damaged greatly by these
acts. Further, I had repeatedly sent both Baker and Hill notice, in writing, that I did not consent to service or notice of anything via electronic means.
Further NRS 118A.190 does not speak to notice of a legal finding, but rather to notice of a fact. As such, I was not appropriately served notice of the
Order of Summary Eviction, and an illegal lockout occurred, as such no criminal trespass charge can stand.
NRS 118A.260 Disclosure of names and addresses of managers and owners; emergency telephone number; service of process.
1. The landlord, or any person authorized to enter into a rental agreement on his or her behalf, shall disclose to the tenant in writing at or before the
commencement of the tenancy:
(a) The name and address of:
(1) The persons authorized to manage the premises;
(2) A person within this State authorized to act for and on behalf of the landlord for the purpose of service of process and receiving notices and
demands; and
(3) The principal or corporate owner.
(b) A telephone number at which a responsible person who resides in the county or within 60 miles of where the premises are located may be called in
case of emergency.
2 The information required to be furnished by this section must be kept current and this section is enforceable against any successor landlord or

FW: THIS COULD WIN THE CASE IN 11 CR 26405 2I
manager of the premises.
3. A party who enters into a rental agreement on behalf of the landlord and fails to comply with this section is an agent of the landlord for purposes of:
(a) Service of process and receiving notices and demands; and
(b) Performing the obligations of the landlord under law and under the rental agreement.
4. In any action against a landlord which involves his or her rental property, service of process upon the manager of the property or a person described
in paragraph (a) of subsection 1 shall be deemed to be service upon the landlord. The obligations of the landlord devolve upon the persons authorized
to enter into a rental agreement on his or her behalf.
5. This section does not limit or remove the liability of an undisclosed landlord.
NRS 40.310 Issue of fact to be tried by jury if proper demand made. Whenever an issue of fact is presented by the pleadings, it shall be tried by a jury, if
proper demand is made pursuant to the Nevada Rules of Civil Procedure or the Justice Court Rules of Civil Procedure

Actually, a lot of people seemed confused regarding the 24 hours lockout thing. The only appearance in either NRS 118A or NRS 40, in the provisions
applicable to Summary Eviction Proceedings of anything related to 24 hours is in NRS 40.253(5), which only speaks to a situation where the Tenant
does not file a Tenant's Answer or Tenant's Affidavit, which is clearly inapplicable here, as the Tenant did file such a Opposition to the No Cause Eviction
Notice: 5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
apartment, mobile home or commercial premises are located or to the district court of the county in which the dwelling, apartment, mobile home or
commercial premises are located, whichever has jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
constable of the county to remove the tenant within 24 hours after receipt of the order. The affidavit must state or contain...
So, absent some statutory provision allowing the Order of Summary Eviction to result in a lockout by the Washoe County Sheriff's Office prior to the 3
days for mailing where personal service of the Order of Summary Eviction was not effectuated, despite what WCSO employee may have incorrectly (or
falsely) asserted in the WCSO's John Machem's Affidavit of Service from, file stamped November 7, 2011 (especially where it is timestamped 4:30 pm,
November 1, 2011, especially where the Order of Summary Eviction explicitly reads that no such lockout shall occur prior to 5:00 pm on November 1,
2011). See, NRCP 5(b)(2)(A)(i-iii), NRCP 6(e).
Interestingly, Richard Hill knows his case is toast under NRCP 5(b)(2)(A)(i-iii), NRCP 6(e), in addition to NRCP 11. That is why in
Richard Hill's November 21, 2011 Motion for Order To Show Cause, on page 2, Hills resorts to literally grasping at straws, imagining that
what the Washoe County Sheriff's Office customarily does is somehow automatically codified into mandatory precedent black letter law.
To wit, Richard Hill wrote in his Motion For Order To Show Cause that: FACTS SHOWING CONTEMPT OF COURT 6. EXHIBIT
1 was served on Coughlin on November " 2011 by the Washoe County Sheriffs Department, by posting same on the front door of the
property in the manner customary for evictions in Washoe County. The locks to the premises were changed at that time, thereby ejecting
and dispossessing Coughlin of possession of the Property. Further, therein Richard Hill admits that the lockout occurred at 4:30 pm, as
indicated in writing in the WCSO's Machem's Affidavit of Service, contra to the mandate of J udge Sferrazza's Order of Summary Eviction
requiring any lockout to occur after 5:00 pm, November 1, 2011.
Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

Sincerely,

Zach Coughlin, Esq.


Sent: Wed 12/14/11 5:39 AM
5 attachments
11 1 2011 Affidavit of Service, Notice of Entry of Order, and Order for Summary Eviction Rev2011-001708.pdf (7.8 MB) , Affidavit of Service
Sheriff's Machen 4 30 pm 11 1 2011.pdf (555.1 KB) , 12 14 11 fax to Puentes ISSUES THAT CAN WIN THE CASE.pdf (144.2 KB) , 11 21 11
Declaration of Richard Hill attach to his M for OSC (11-21-11) Compare to Police Reports and deposition of RPD's Carter and Lopez and
Merliss.pdf (791.4 KB) , 11 21 2011 REV2011-00178 RICHARD HILL'S M for OSC (11-21-11).pdf (711.7 KB)
Hi Mr. Puentes,

What is inconsistent in the discovery you provided me and Hill's Motion to Show Cause? I am
interested to see what you come up with and who you would want to ask what questions. I went to the
University of Washington too, for awhile at least, year round from 9/95 to 12/96.

Hill's Declaration in his 11 21, 2011 Motion to Show Cause indicates that:
"DECLARATION OF RICHARD G. HILL, ESQ.
RICHARD G. HILL, ESQ., being first duly sworn, deposes and under penalty
of perjury avers:
1. I am a resident of the City of Reno, County of Washoe, State of Nevada,
and over 18 years of age. This declaration is based on my personal knowledge, exceptthose
matters stated on information and belief, and as to those items I believe them to be true.
This declaration is made in support of plaintiffs Motion for Contempt Citation, and
represents my testimony if called on to present same in court.
2. I am an attorney duly licensed as such by the State of Nevada to practice
before all courts of this State and maintain my office at 652 Forest Street, Reno, Nevada.
I am also licensed to practice before the United States District Court for the District of
Nevada, the Ninth Circuit Court of Appeals and the United States Supreme Court.
III
3. My office represents the plaintiff, Dr. Matthew Merliss, in this matter.
4. On October 27, 2011, this court signed a summary eviction order, and on
November 1, 2011, the Washoe County Sheriff's Department served that order. The notice
was posted on the door of the home by the Washoe County Sheriff's Department in the
manner customary in Washoe County for evictions. The locks on the front door and back
door were changed, and we retained all keys to the home.
5. After that date, I began to notice that it looked like somebody had been
getting into the home. On approximately November 4, 2011, I became concerned about the
home and its contents. I entered it and was able to confirm that "somebody" had been
getting in. I thought I had secured the means of entry being used by whoever it was that
was getting in. However, on later visits to the home, it was clear that the home was still
being surreptitiously accessed.
6. On November 13, 2011, Dr. Merliss came to Reno because he wanted to
inspect the home. Upon entry, it was clear that somebody had again accessed the home.
7. We tried to enter the basement and found the door was barricaded, not
locked, from the inside. We were concerned that whoever had been accessing the home was
inside, so we called the police.
8. When the police arrived, they agreed with us that it was very likely that
somebody was barricaded in the basement. The police tried to coax the personto come out,
but without success.
9. When the police declined to break down the door, Dr. Merliss did so. The
police looked inside and discovered the defendant, Zachary Coughlin, and his dog.
10. Coughlin came out peacefully, went upstairs and was placed under arrest
by the police for trespassing.
11. After Coughlin was taken to jail, Dr. Merliss and I tried to videotape the
contents ofthe basement where Coughlin had been hiding. It was too dark to effectively
videotape, but we were able to ascertain that Coughlin and his dog have been living. in the
III
basement of the home for quite some time, likely even before the lockout. Iobserved that
Coughlin had a bed set up. He had several computer monitors. He had a store of both food
and water. He had electric space heaters.
12. Since the eviction order was served, my associate, Mr. Baker, and I had
sent numerous emails to Coughlin, in which we both repeatedly made it clear to him that
he was not to be at the home without our prior permission. No such permission was given.
Mr. Coughlin had no reason to possibly think he was permitted on the property. We had
tried to coax him to cooperate on getting his possessions out, without success, or even a
response.
13. As a result of Mr. Coughlin's break-ins, Dr. Merliss has incurred a bill of
$1,060 with a licensed contractor to secure the premises. That does not include the cost of
the door that was broken in order to get Coughlin out. That does not include the numerous
hours of me and my staff to deal with Mr. Coughlin's repeated break-ins at the home.
14. I am no expert, but I believe Mr. Coughlin is what is called a "hoarder."
He has many car seats throughout the house. He has many dead televisions. He has a box
of car window servo motors. The attic, which can only be accessed through a very narrow
opening, is full of items, including dead electronic devices.
15. We have found drugs at the home. We found a bag of what looks like
marijuana on the kitchen counter. I found a crack pipe. The contractor found what he said
was a large quantity of pills.
16. Mr. Coughlin has been harassing and stalking me, and possibly, my staff.
On November 15, 2011, he burst intomy office and created a scene. Then, he was parading
up and down the sidewalk across the street with a video camera screaming obscenities at
me and my staff.
III
II I
III
17. I declare under penalty of perjury that the foregoing is true and correct..."
But RPD Officer Carter wrote in his Supplemental Declaration: "On November 13, 2011 at
approximately 1200 hours I responded to 121 River Rock St, Reno, on a report of an
unwanted subject in the home. I arrived on scene with Sgt Lopez and we met with the RIP. Richard Hill,
who told
us the following:Richard is a local attorney who is representing the home owner, Matthew Merliss.
Matthew filed eviction papers on
his tenant, Zachary Coughlin, at 121 River Rock St last month and they were served at the home by
leaving them
on the door. The eviction papers stated that Zachary was to vacate the property on November 1, 2011 .
Matthew has been to the house several times over the past week and has observed evidence of someone
coming
and going. Today he was at the house and found the basement door to be locked from inside.
Matthew contacted Richard who responded and called the police.
Sgt Lopez and I knocked on the basement door and announced loudly "Reno Police" and called out for
Zachary to
open the door. We were met with no response. Matthew decided he would kick the door open, and did
so.
I entered the doorway of the basement and found Zachary standing at the rear of the room holding a
small dog.
He was hesitant to come out and eventually did so.
Zachary came upstairs and instantly started arguing his legal standing in the house, asking me
"hypothetically
speaking" type questions. He then told me I was making a false arrest due to the fact that I am on
Richard Hill's
payroll and he was going to sue me.
I tried to explain to Zachary that he was seNed eviction papers and he asked me what I could do about it
if he
hypothetically didn't get them . He then told me that he had worked a deal with Matthew to continue
paying rent
and that the legal eviction was no longer val id.
I again tried to explain to Zachary that a judge had signed anorder forcing him to leave the property and
all he did
was cite civil case law to me (l'm unsure if any of the cases he was rambling on about even exist) and
tell me that
I was making a bad arrest.
Due to Zachary not believing he has done anything wrong that the fact he believes he still has standing
there is
reasonable grounds to believe Zachary will return to the house. Therefore he did not qualify for a
misdemeanor
citation.
Richard completed a statement on Matthews' behalf and signed a criminal complaint.
Zachary was transported and booked into the Washoe County Jail without incident for
Trespassing...."Further, Richard Hill's own Written Statment of 11 13, 2011, provided to the RPD writes
that "We evicted Coughlin. The papers were posted by WCSO on 11/1/11 We have observed evidence
that he was coming and going...."

Why didn't Merliss make a Written Statement. Was Merliss really in Reno during the time frame to
observe what Hill asserts Merliss observed in Hill's Declaration of 11 21, 2011? What other holes do
you see?

Hills 11 21, 2011 Declaration states that: "6. OnNovember 13, 2011, Dr. Merliss came to Reno because
he wanted to
inspect the home. Upon entry, it was clear that somebody had again accessed the home.
7. We tried to enter the basement and found the door was barricaded, not
locked, from the inside. We were concerned that whoever had been accessing the home was
inside, so we called the police.
8. When the police arrived, they agreed with us that it was very likely that
somebody was barricaded in the basement. The police tried to coax the person to come out,
but without success.
9. When the police declined to break down the door, Dr. Merliss did so. The
police looked inside and discovered the defendant, Zachary Coughlin, and his dog.
10. Coughlin came out peacefully, went upstairs and was placed under arrest
by the police for trespassing."

However, RPD Officer Carter's Narrative, on page 3 of 3 from his November 14th, 2011 Report
writes that: "Matthew has been to the house several times over the past week and has
observed evidence of someone coming and going. Today he was at the house and found the
basement door to be locked from inside.
Matthew contacted Richard who responded and called the police.
Sgt Lopez and I knocked on the basement door and announced loudly "Reno Police" and
called out for Zachary to open the door. We were met with no response. Matthew decided he
would kick the door open, and did so.
I entered the doorway of the basement and found Zachary standing at the rear of the room
holding a small dog.
He was hesitant to come out and eventually did so."

Hill's Declaration contains nothing about this "reluctance" RPD Officer Carter mentions

FW: 121 River Rock
Further, Hill's Declaration makes no mention of Merliss's noticing anything at the property or
any trips by Merliss to the property, in marked contrast to RPD Officer's Carter writing that
"Matthew has been to the house several times over the past week and has observed evidence
of someone coming and going." Additionally, Merliss picked up my dog and held it in his
hands close to his body and demanded that I let him have it, and the RPD Officers did nothing
about it, further, Merliss was taunting me during the arrest demanding I give him "some more
eye contact", accusing me of costing him $20,000 for the informed consent wrong site legal
surgery that was Hill's billing of $20K in a Summary Eviction Proceeding where JCRCP 3 and
NRS 69.030 preclude an award of fees, etc. Notice Hill's Declaration only writes that "the police
tried to coax the person out" but clearly does not corroborate RPD's Carter's assertion that the
RPD announced itself as police prior to the door being kicked down. Hills Written Statement
that the eviction papers were "served" by the WCSO "leaving them on the door" is a violation
of NRCP 11 and leaves him and his client liable for the wrongful arrest and defamation that
occurred incident to RPD's actions.

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473


Sent: Sat 12/17/11 12:15 AM
To: ballardd@reno.gov; howardk@reno.gov; robertsp@reno.gov; renomunirecords@reno.gov; hazlett-stevensc@reno.gov; puenteslaw@aol.com

Unbelievable. The idea that exculpating evidence is being withheld under some "lien" is transmitted into the universe, next thing I know, my law office
is broken in to and the Richard B. Hill gang is stil asserting a lien on property that was stolen, in my opinion,as a result of their own negligence, leaving
a window air conditioner unit in a window, without even putting a window jam between the top of the sill and lower pain, facing a sidewalk a block
from the Lakemill Lodge and across from City Center Apartments, great. Great. And I still have not been faxed or appropriately served the Order and
Contempt OrderI was told would be faxed to me.

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473


To: cdbaker@richardhillaw.com; knielsen@richardhillaw.com; sgallagher@richardhillaw.com
Subject: RE: 121 River Rock
Date: Wed, 14 Dec 2011 15:43:38 -0800

Dear Mr. Baker,

I drove by the property recently and saw you had added boarding up the front door on very, very recently. Unfortunately, your client and your firm,
despite billing up some $1,060 for "securing" the property on top of charging $900 for storage for what could fit inside a 10x20 foot storage shed,
never once providing an inventory, and contributing to a wrongful arrest and defamation causing me and my clients great damage, failed to take even
basic steps to secure the property, despite my making numerous written requests that you do so, including, but not limited to, taking the damn window
unit air conditioner out of the window facing the sidewalk on the side of the house very close to the damn Lakemill Lodge, or even putting a strong
stick in between the bottom sliding window pain and the top of the sill to prevent someone from simply pushing in the window unit air conditioner and
pushing the window up to gain access. Further, a blanket that was on the orange circular couch is clearly in the flower bed in front of the house.
Additionally, there are reports that someone with your office gave someone a mattress from the inventory of Coughlin Memory Foam (a Nevada
licensed business located at the property) and an expensive mattress platform has clearly been damaged and placed in the flower bed as well, in
addition to one of the wooden porch shades being removed from the front porch. You and your client are, of course, liable for all of this.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
Nevada Bar No: 9473

** Notice** This messageand accompanying documents arecovered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
recipient, you arehereby notified that you have received this document in error and that any review, dissemination, copying, or thetaking of any action based on the

From: cdbaker@richardhillaw.com
CC: rhill@richardhillaw.com
Subject: 121 River Rock
Date: Wed, 14 Dec 2011 13:50:02 -0800


need to communicate with you regarding my requests
Mr. Coughlin:

The River Rock property has been broken into. We believe the break-in occurred sometime on Monday, December 12, 2011. There appear to be items
missing, including the TV in the living room, perhaps a computer monitor, and perhaps some stereo equipment. I cant tell what else. The contents of
the residence appear to have been rifled through.

I am providing you with this information as a courtesy. This email does NOT constitute permission for you to go to the River Rock property.

Casey D. Baker, Esq.
Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: cdbaker@richardhillaw.com

CONFIDENTIAL: ATTORNEY WORK PRODUCT; ATTORNEY-CLIENT PRIVILEGE
This e-mail may contain legally privileged or confidential information. If you are not the intended recipient, please do not read, copy, use, or disclose this communication to anyone other than the
intended recipient. If you have received this message in error, please notify the sender and delete the email message from your system. Thank you.
Circular 230 Notice.
To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be
used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed
herein.

Sent: Mon 12/26/11 3:52 PM

Dear Mr. Puentes,
I called you just now and left a message. I have received nothing from you in regard to my written requests for action on your part and for information
in connection with the matter for which you are attorney of record RMC 11 CR 22185 2I.

Please respond in writing.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473


scope of representation

new address for me

Sent: Fri 12/30/11 10:36 PM
Dear Mr. Puentes,
Please move for a continuance immediately in this matter, set for trial on J anuary 10th, 2011. You
assured me in person at our meeting at your office that you would be able to get one, and I definitely
want and need one, and RMCR indicates there are certain deadlines for moving for one, which I have
already asked you to do in writing.

I am upset that you slammed down the telephone ended our telephone conversation abruptly when we
spoke yesterday, immediately after I asked you to provide something in writing outlining the scope of
your representation of me. I wish for you to prepare and file (after receiving express prior written
authorization from me upon review of your drafts) the Motion to Supress and Motions in Limine I
previously request that you file, in addition to subpoening Dr. Merliss, Richard Hill, both RPD Officers
at the scene of the trespassing arrest, and a subpoena duces tecume to the Law Office of Richard Hill,
the RPD, and Dr. Merliss demanding any and all documentation and or media at all connected with this
matter in any way. Further you indicated that you had not even attempted to view the discovery
produced by the Reno City Attorney, nor did you have any interest in seeing anything I might have to
show you. That was enormously upsetting to me, as any sentient human being might reasonably be
expected to anticipate. Please note my new address. Please file a conflict motion seeking to make the
Reno City Atty recuse itself in light of the conflicts of interest incident to the various arrests and torts
against me committed by the RPD and Reno City Attorney.

Sincerely,

Zach Coughlin, Esq.
1422 E. 9th St.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473



Pendency of Criminal Prosecution as Ground for Continuance or Postponement
of Civil Action Involving Facts or Transactions upon which Prosecution Is
PredicatedState CasesPendency of Criminal Prosecution as Ground for
Continuance or Postponement of Civil
Sent: Sat 12/31/11 1:32 AM

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

** Notice** This messageand accompanying documentsarecovered by theelectronic CommunicationsPrivacy Act, 18 U.S.C. 2510-2521, andmay contain confidential information intended for the
specifiedindividual (s) only. If you arenot theintendedrecipient or an agent responsiblefor delivering it to theintended recipient, you areherebynotifiedthat you havereceived thisdocument in error andthat
any review, dissemination, copying, or thetaking of any action based on thecontentsof thisinformation isstrictly prohibited. This message is confidential, intended only for the named recipient
(s) and may contain information that is privileged, attorney work product or exempt fromdisclosure under applicable law. If you are not the intended recipient(s), you are
notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be
unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in
any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.

Sent: Sat 12/31/11 8:14 PM
2 attachments
jail time counsel sixth amendment possibility misdemeanor.pdf (3.1 MB) , fifth amendment right civil proceeding parallel.pdf (2.6 MB)
Pendency of Criminal Prosecution as Ground for Continuance or Postponement of Civil
Action Involving Facts or Transactions upon which Prosecution Is PredicatedState
Cases...37 A.L.R.6th 511 (Originally published in 2008)
;please find that ALR attached, perhaps it speaks to the res gestae and or stay during the pendency of the
civil appeal we discussed vis a vis the criminal trespass charge

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


Is Roberto Puentes on Youtube.com? also more motivation for you in this case

Zach Coughlin has shared a folder with you.

Sent: Sat 12/31/11 9:19 PM
10 attachments
Legal malpractice in defense of criminal prosecution.pdf (6.7 MB) , Public Defender's Immunity from Liability for Malpractice.pdf (4.0 MB) ,
process server fraud harass trespass.pdf (3.1 MB) , f_Circumstances giving rise to prejudicial conflict of interests between criminal defendant.pdf
(2.7 MB) , public defender liability.pdf (2.2 MB) , conflicts with PUBLIC DEFENDER EMPLOYEES.pdf (2.0 MB) , Civil liability of attorney for abuse
of process process server trespass fraud.pdf (1925.1 KB) , process server abuse harass trespass.pdf (1816.6 KB) , Trespass state prosecution for
unauthorized entry or occupation, for public demonstration purposes, of business, industrial, or utility premises.pdf (339.6 KB) , SUBPOENA TO
TESTIFY AT A HEARING OR TRIAL IN A CRIMINAL CASE.pdf (281.9 KB)
Hi Mr. Puentes,
I know you have repeatedly told me you could care less to watch any youtube.com videos, regardless of
whether they prove my innocence or whatever, however, I think you might need to watch some of these:
http://www.youtube.com/results?
search_query=nevada+court+services&oq=nevada+court+services&aq=f&aqi=&aql=&gs_sm=e&gs_upl=18l3308l0l3556l19l15l0l9l0l1l311l1375l0.1.4.1l6l0

It seems Nevada Court Services, which shares an office and a receptionist with the former appointed public defender for this case representing me, Lew
Taitel, Esq, who departed from RMC Rules by failing to file a Motion to Withdraw when he sought to and failed to disclose the conflict of interest that
he failed to prevent his taking on my case and reviewing ultra personal information, that is directly connected to the subject matter of the litigation
from which the conflict arises as well as the defense of the suit you and he have both appeared as attorney of record in, this trespass case. I don't think
you are on any of the videos, but there are so many ultra zealous documentary filmmakers these days that I cannot be sure.

Anyways, Lew Taitel, as I have indicated to you in writing, is listed as "associated with" Nevada Court Services, on their website, with his picture. They
share and office and a receptionist, and perhaps others staff, in the office across from the former Chocolate Bar. PERHAPS MOST IMPORTANTLY OF
ALL, AND SOMETHING I WANT YOU TO LITIGATE AGGREsSIVELY (CLIENT CONTROLS MEANS AND OBJECTIVES OF A LITIGATION, WHETHER
APPOINTED ATTORNEY LIKES IT OR NOT) IS THAT NEVADA COURT SERVICES, INCLUDE ITS PROCESS SERVER JOEL DURDEN, CAN BE SEEN
TRESPASSING ONTO MY PROPERTY AND OTHERWISE ASSAULTING, HARASSING, AND VEXING ME, BEHIND MY BACK GATE, NO LESS IN THE VIDEOS
FOUND AT THE LINK ABOVE.

PLEASE DISCLOSE ANY CONFLICTS OR PREVIOUS WORKING RELATIONSHIPS YOU HAVE WITH ANY OF THE RENO CITY ATTORNEY, RPD, RENO
MUNICIPAL COURT STAFF, RICHARD HILL, OR ANY OTHER INDIVIDUALS WITH WHOM YOU HAVE HAD PRIOR DEALINGS AND THEREFOR MAY
PRESENT A SITUATION WHERE A CONFLICT OF INTEREST ARISES.

Sincerely,

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

specifiedindividual (s) only. If you arenot theintendedrecipient or an agent responsiblefor delivering it to theintended recipient, you arehereby notifiedthat you havereceived thisdocument in error andthat

Sent: Thu 1/05/12 8:22 AM

video of trespass arrest
Dear Mr. Puentes, Please let me know, in writing, the status of the Motion For Continuance you indicated you would both file and which you felt sure
would be obtained, either through written stipulation with opposing counsel of by Order of the RMC
Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
zach's arrest 001.avi
Download all
Share your files with
Sent: Thu 1/05/12 8:43 AM
1 attachment
zach's arrest 009.flv (10.4 MB)
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1050&parid=43084638F32F5F28!117&authkey=!ACPUJSqi94trtcY

Dear Mr. Puentes,

Please provide an indication, in writing, as to the status of the continuance of the upcoming trespass trial, which you indicated would be obtained.

Sincerely,

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


another video of the arrest which lacks anyone telling Coughlin to leave or
seeking to issue a citation in lieu of custodial arrest

ARRESTED FOR JAYWALKING BY RENO PD

Sent: Thu 1/05/12 3:26 PM
1 attachment
zach's arrest 011.flv (16.2 MB)

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


Sent: Fri 1/13/12 7:49 AM
To: peteeastman@gmail.com; tcoughlinmd@hotmail.com; marybarkbark@yahoo.com; carcoughster@gmail.com; melissa.l.ulloa@gmail.com;
tjhlaw@eschelon.com; geofgiles@hotmail.com; teddyjames25@gmail.com; jgoodnight@washoecounty.us; puenteslaw@aol.com
1 attachment
SUPPLEMENTAL REPLY TO OPPOSITION CV08-01709 1 13 12.pdf (162.9 KB)
Nevada Courts Services CEO Jeff Chandler drove by the scene while I was in the patrol car. I am suing
Nevada Court Services incident to their trespassing into my backyard and banging on windows and
ringing doorbells in teams for 40 minutes at a clip three times a day on Richard HIlls behalf. Mr.
Puentes, as my court appointed defender in the trespass action against me (arrested at Richard Hill's
behest by an RPD Officer would said Hill pays him money) you recently informed me you have ties to
Nevada Court Services and Lew Taitel, the court appointed defender whom mysteriously was able to
withdraw from my representation prior to your involvement despite not filing a motion in compliance
with Reno Municipal Court Rules, nor any Order granting such a withdrawal being filed. Can you
clarify your, in your words "extremely close relationship with Lew Taitel" and your "business
relationship" with Nevada Court Services?

Sincerely


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



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