12 11 11 Final Motion For New Trial City of Reno V Coughlin RMC 11 CR 22176 (12 11 11 Final Motion For New Trial City of Reno V Coughlin RMC 11 CR 22176 PDF

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Zach Coughlin
817 N. Virginia St. #2
Reno, NV 89501
Tele: 775229!7"7
#a$: 9%9!!77%02
&ro 'er (e)en*ant+,''ellant
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Ca<e No:11 CR 2217! 2/
(e't No: -u*ge 3o=ar*
1 Notice o) ,''eal, >otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or
Recon<i*eration5 >otion )or Recu<al
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Notice o) ,''eal, >otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or
Recon<i*eration5 >otion )or Recu<al5 >otion #or &u?lication 1) Tran<cri't at &u?lic 0$'en<e,
&etition )or /n #or@a &au'eri< Statu<
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(e)en*ant+,''ellant, Zach Coughlin, here?A )ile< thi< Notice o) ,''eal, >otion to Vacate an*
or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or Recon<i*eration5 >otion )or Recu<al5 >otion #or
&u?lication 1) Tran<cri't at &u?lic 0$'en<e, &etition )or /n #or@a &au'eri< Statu<.
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(a) Grounds. , ne= trial @aA ?e grante* to all or anA o) the 'artie< an* on all or 'art o) the i<<ue< )or anA o) the
)ollo=ing cau<e< or groun*< @ateriallA a))ecting the <u?<tantial right< o) an aggrie6e* 'artA: C1; /rregularitA in the
'rocee*ing< o) the court, DurA, @a<ter, or a*6er<e 'artA, or anA or*er o) the court, or @a<ter, or a?u<e o) *i<cretion ?A
=hich either 'artA =a< 're6ente* )ro@ ha6ing a )air trial5 C2; >i<con*uct o) the DurA or 're6ailing 'artA5 C"; ,cci*ent or
<ur'ri<e =hich or*inarA 'ru*ence coul* not ha6e guar*e* again<t5 C%; Ne=lA *i<co6ere* e6i*ence @aterial )or the 'artA
@aEing the @otion =hich the 'artA coul* not, =ith rea<ona?le *iligence, ha6e *i<co6ere* an* 'ro*uce* at the trial5 C5;
>ani)e<t *i<regar* ?A the DurA o) the in<truction< o) the court5 C!; 0$ce<<i6e *a@age< a''earing to ha6e ?een gi6en un*er
the in)luence o) 'a<<ion or 'reDu*ice5 or, C7; 0rror in la= occurring at the trial an* o?Decte* to ?A the 'artA @aEing the
@otion. 1n a @otion )or a ne= trial in an action trie* =ithout a DurA, the court @aA o'en the Du*g@ent i) one ha< ?een
entere*, taEe a**itional te<ti@onA, a@en* )in*ing< o) )act an* conclu<ion< o) la= or @aEe ne= )in*ing< an* conclu<ion<,
an* *irect the entrA o) a ne= Du*g@ent.
(b) Time for Motion. , @otion )or a ne= trial <hall ?e )ile* no later than 10 *aA< a)ter <er6ice o) =ritten notice o) the
entrA o) the Du*g@ent.
(c) Time for Serving Affidavits. 2hen a @otion )or ne= trial i< ?a<e* u'on a))i*a6it< theA <hall ?e )ile* =ith the @otion.
The o''o<ing 'artA ha< 10 *aA< a)ter <er6ice =ithin =hich to )ile o''o<ing a))i*a6it<, =hich 'erio* @aA ?e e$ten*e* )or
an a**itional 'erio* not e$cee*ing 20 *aA< either ?A the court )or goo* cau<e <ho=n or ?A the 'artie< ?A =ritten
<ti'ulation. The court @aA 'er@it re'lA a))i*a6it<.
(d) On Courts Initiative; Notice; Secif!ing Grounds. No later than 10 *aA< a)ter entrA o) Du*g@ent the court, on it<
o=n, @aA or*er a ne= trial )or anA rea<on that =oul* Du<ti)A granting one on a 'artAF< @otion. ,)ter gi6ing the 'artie<
notice an* an o''ortunitA to ?e hear*, the court @aA grant a ti@elA @otion )or a ne= trial )or a rea<on not <tate* in the
@otion. 2hen granting a ne= trial on it< o=n initiati6e or )or a rea<on not <tate* in a @otion, the court <hall <'eci)A the
groun*< in it< or*er.
(e) Motion to A"ter or Amend a #udgment. , @otion to alter or a@en* the Du*g@ent <hall ?e )ile* no later than 10 *aA<
a)ter <er6ice o) =ritten notice o) entrA o) the Du*g@ent.
G,< a@en*e*5 e))ecti6e -ulA 1, 2005.H
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(a) C"erica" Mista$es. Clerical @i<taEe< in Du*g@ent<, or*er< or other 'art< o) the recor* an* error< therein ari<ing )ro@
o6er<ight or o@i<<ion @aA ?e correcte* ?A the court at anA ti@e o) it< o=n initiati6e or on the @otion o) anA 'artA an*
a)ter <uch notice, i) anA, a< the court or*er<. (uring the 'en*encA o) an a''eal, <uch @i<taEe< @aA ?e <o correcte* ?e)ore
the a''eal i< *ocEete* in the a''ellate court, an* therea)ter =hile the a''eal i< 'en*ing @aA ?e <o correcte* =ith lea6e o)
the a''ellate court.
(b) Mista$es; Inadvertence; %&cusab"e Neg"ect; Ne'"! (iscovered %vidence; )raud* %tc. 1n @otion an* u'on <uch
ter@< a< are Du<t, the court @aA relie6e a 'artA or 'artAF< legal re're<entati6e )ro@ a )inal Du*g@ent, or*er, or 'rocee*ing
)or the )ollo=ing rea<on<: C1; @i<taEe, ina*6ertence, <ur'ri<e, or e$cu<a?le neglect5 C2; ne=lA *i<co6ere* e6i*ence =hich
?A *ue *iligence coul* not ha6e ?een *i<co6ere* in ti@e to @o6e )or a ne= trial un*er Rule 59C?;5 C"; )rau* C=hether
hereto)ore *eno@inate* intrin<ic or e$trin<ic;, @i<re're<entation or other @i<con*uct o) an a*6er<e 'artA5 C%; the
Du*g@ent i< 6oi*5 or, C5; the Du*g@ent ha< ?een <ati<)ie*, relea<e*, or *i<charge*, or a 'rior Du*g@ent u'on =hich it i<
?a<e* ha< ?een re6er<e* or other=i<e 6acate*, or it i< no longer eIuita?le that an inDunction <houl* ha6e 'ro<'ecti6e
a''lication. The @otion <hall ?e @a*e =ithin a rea<ona?le ti@e, an* )or rea<on< C1;, C2;, an* C"; not @ore than ! @onth<
a)ter the 'rocee*ing =a< taEen or the *ate that =ritten notice o) entrA o) the Du*g@ent or or*er =a< <er6e*. , @otion
un*er thi< <u?*i6i<ion C?; *oe< not a))ect the )inalitA o) a Du*g@ent or <u<'en* it< o'eration. Thi< rule *oe< not li@it the
'o=er o) a court to entertain an in*e'en*ent action to relie6e a 'artA )ro@ a Du*g@ent, or*er, or 'rocee*ing, or to <et
a<i*e a Du*g@ent )or )rau* u'on the court. 2rit< o) cora@ no?i<, cora@ 6o?i<, au*ita Iuerela, an* ?ill< o) re6ie= an* ?ill<
in the nature o) a ?ill o) re6ie=, are a?oli<he*, an* the 'roce*ure )or o?taining anA relie) )ro@ a Du*g@ent <hall ?e ?A
@otion a< 're<cri?e* in the<e rule< or ?A an in*e'en*ent action.
(c) (efau"t #udgments+ (efendant Not ,ersona""! Served. 2hen a *e)ault Du*g@ent <hall ha6e ?een taEen again<t anA
'artA =ho =a< not 'er<onallA <er6e* =ith <u@@on< an* co@'laint, either in the State o) Ne6a*a or in anA other
Duri<*iction, an* =ho ha< not entere* a general a''earance in the action, the court, a)ter notice to the a*6er<e 'artA, u'on
@otion @a*e =ithin ! @onth< a)ter the *ate o) <er6ice o) =ritten notice o) entrA o) <uch Du*g@ent, @aA 6acate <uch
Du*g@ent an* allo= the 'artA or the 'artAF< legal re're<entati6e< to an<=er to the @erit< o) the original action. 2hen,
ho=e6er, a 'artA ha< ?een 'er<onallA <er6e* =ith <u@@on< an* co@'laint, either in the State o) Ne6a*a or in anA other
Duri<*iction, the 'artA @u<t @aEe a''lication to ?e relie6e* )ro@ a *e)ault, a Du*g@ent, an or*er, or other 'rocee*ing
taEen again<t the 'artA, or )or 'er@i<<ion to )ile an an<=er, in accor*ance =ith the 'ro6i<ion< o) <u?*i6i<ion C?; o) thi<
rule.
(d) (efau"t #udgments+ Modification Nunc ,ro Tunc. 2hene6er a *e)ault Du*g@ent or *ecree ha< ?een entere*, the
'artA or 'artie< in *e)ault therein @aA at anA ti@e therea)ter, u'on =ritten con<ent o) the 'artA or 'artie< in =ho<e )a6or
Du*g@ent or *ecree ha< ?een entere*, enter general a''earance in the action, an* the general a''earance <o entere* <hall
ha6e the <a@e )orce an* e))ect a< i) entere* at the 'ro'er ti@e 'rior to the ren*ition o) the Du*g@ent or *ecree. 1n <uch
a''earance ?eing entere* the court @aA @aEe an* enter a @o*i)ie* Du*g@ent or *ecree to the e$tent onlA o) <ho=ing <uch
general a''earance on the 'art o) the 'artA or 'artie< in *e)ault, an* it <hall ?e entere* nunc 'ro tunc a< o) the *ate o) the
original Du*g@ent or *ecree5 'ro6i*e*, ho=e6er, that nothing herein containe* <hall 're6ent the court )ro@ @o*i)Aing
<uch Du*g@ent or *ecree a< <ti'ulate* an* agree* in =riting ?A the 'artie< to <uch action, an* in accor*ance =ith the ter@<
o) <uch =ritten <ti'ulation an* agree@ent.
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(a) Automatic Sta!. 0$ce't a< <tate* herein, no e$ecution <hall i<<ue u'on a Du*g@ent nor <hall 'rocee*ing< ?e taEen )or
it< en)orce@ent until the e$'iration o) 10 *aA< a)ter <er6ice o) =ritten notice o) it< entrA.
(b) Sta! on Motion for Ne' Tria" or for #udgment. /n it< *i<cretion an* on <uch con*ition< )or the <ecuritA o) the
a*6er<e 'artA a< are 'ro'er, the court @aA <taA the e$ecution o) or anA 'rocee*ing< to en)orce a Du*g@ent 'en*ing the
*i<'o<ition o) a @otion )or a ne= trial or to alter or a@en* a Du*g@ent @a*e 'ur<uant to Rule 59, or o) a @otion )or relie)
)ro@ a Du*g@ent or or*er @a*e 'ur<uant to Rule !0, or o) a @otion )or Du*g@ent in accor*ance =ith a @otion )or a
Du*g@ent a< a @atter o) la= @a*e 'ur<uant to Rule 50, or o) a @otion )or a@en*@ent to the )in*ing< or )or a**itional
)in*ing< @a*e 'ur<uant to Rule 52C?;.
(c) -eserved.
(d) Sta! .on Aea". 2hen an a''eal i< taEen the a''ellant ?A gi6ing a <u'er<e*ea< ?on* @aA o?tain a <taA. The ?on*
@aA ?e gi6en at or a)ter the ti@e o) )iling the notice o) a''eal. The <taA i< e))ecti6e =hen the <u'er<e*ea< ?on* i< )ile*.
" Notice o) ,''eal, >otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or
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(e) Sta! in )avor of t/e State or Agenc! T/ereof. 2hen an a''eal i< taEen ?A the State or ?A anA countA, citA or to=n
=ithin the State, or an o))icer or agencA thereo) an* the o'eration or en)orce@ent o) the Du*g@ent i< <taAe*, no ?on*,
o?ligation, or other <ecuritA <hall ?e reIuire* )ro@ the a''ellant.
(f) -eserved.
(g) ,o'er of Ae""ate Court Not 0imited. The 'ro6i<ion< in thi< rule *o not li@it anA 'o=er o) an a''ellate court or o)
a Du*ge or Du<tice thereo) to <taA 'rocee*ing< *uring the 'en*encA o) an a''eal or to <u<'en*, @o*i)A, re<tore, or grant an
inDunction *uring the 'en*encA o) an a''eal or to @aEe anA or*er a''ro'riate to 're<er6e the <tatu< Iuo or the
e))ecti6ene<< o) the Du*g@ent <u?<eIuentlA to ?e entere*.
(/) Sta! of #udgment as to Mu"ti"e C"aims or Mu"ti"e ,arties. 2hen a court ha< or*ere* a )inal Du*g@ent un*er the
con*ition< <tate* in Rule 5%C?;, the court @aA <taA en)orce@ent o) that Du*g@ent until the entering o) a <u?<eIuent
Du*g@ent or Du*g@ent< an* @aA 're<cri?e <uch con*ition< a< are nece<<arA to <ecure the ?ene)it thereo) to the 'artA in
=ho<e )a6or the Du*g@ent i< entere*.
G,< a@en*e*5 e))ecti6e -ulA 1, 2005.H
'ro<ecutorial @i<con*uct C<uch a< the (.,. =ithhol*ing Je$cul'atorAJ e6i*ence that coul*F6e hel'e* Aour *e)en<e;
Du*icial error< C<uch a< the Du*ge 'er@itting e6i*ence that <houl*F6e ?een e$clu*e* or 6ice 6er<a;
erroneou< a''lication o) a la= or regulation i@'ro'er DurA in<truction<
ine))ecti6e a<<i<tance o) coun<el or other @al'ractice the e6i*ence *i* not 'ro6e Aour guilt ?eAon* a rea<ona?le *ou?t
/ =ent to the )iling o))ice at the R>C a cou'le ti@e< recentlA, inclu*ing to*aA, an* <ent in another =ritten reIue<t <eeEing
an au*io ta'e o) the Trial in R>C 11 CR 2217! /C 110!27 RS/C ?ut =a< tol* ?A a ClerE that / =oul* nee* to 'aA )or
the entire Trial to ?e tran<cri?e*, an* onlA then =oul* / ?e allo=e* to rea* it, an* that / =oul* not ?e allo=e* to acce<<
the au*io o) the hearingK /< thi< correctK / nee* to ha6e the au*io o) the Trial to )ini<h @A Rule 59, !0, an* >otion )or
Recon<i*eration >otion<..../ =ill 'aA )or the au*io. / ha6e recei6e* @anA au*io c*+*6*L< )ro@ ?oth Reno -u<tice Court
an* 2a<hoe (i<trict Court, an* it =a< announce* in court that the trial =a< ?eing au*io recor*e*, a< <uch, / ho'e Aou =ill
a))or* @e a co'A. To*aA, / calle* the R>C an* <'oEe =ith Veronica, =ho <oun*e* 6erA angrA =ith @e an* *i<@i<<i6e. /
=a< <u@@arilA <entence* to " *aA< in Dail at the en* o) the trial in thi< @atter, e6en =here / ha* ?een *enie* @A Si$th
,@en*@ent Right To Coun<el, a)ter a Conte@'t co@@itte* in the courtL< 're<ence )in*ing =a< announce*, in a**ition to
a guiltA 6er*ict in the un*erlAing action. Veronica in)or@e* @e that <he =a< at the trial an* that the R>C ha* )aile* to
@ail @e or other=i<e <er6e @e =ith a co'A o) the =ritten 1r*er, either )or the guiltA con6iction in the un*erlAing ca<e or
the conte@'t or*er. / =a< )orce* into han*cu))< <o IuicElA ater -u*ge 3o=ar* conclu*e* i<<uing hi< oral ruling that / =a<
not e6en a?le to <a6e @A note< on @A co@'uter, it =a< literallA a''arentlA that e$igent a <ituation to han*cu)) @e....Then
a )e= >ar<hall< 'lace <o@e 'iece< o) 'a'er in )ront o) @e an* *e@an*e* / <ign the@, an* ?eca@e angrA, liEe Veronica
an* liEe >ar<hall >onte, / ?elie6e, =a< at the arraing@ent, =hen / a<Ee* a <i@'le Iue<tion relate* to *ue 'roce<<,
<o@ething @anA at the R>C *o not <ee@ all that ena@ore* =ith. / a<Ee* i) / coul* e6en rea* the 'a'er< theA =ere
*e@an*ing / <ign right then an* there. The curtlA an* lou*lA <ai* no, then *ragge* @e a=aA ?e)ore / coul* rea* the
'a'er<, @uch le<< <ign the@. Veronica <narle* at @e that that =a< all the <er6ice o) the 1r*er o) Conte@'t an* 9uiltA
Ver*ict that / =oul* get, ?ut that <he @ight )a$ it to @e, ho=e6er, no )a$ ha< arri6e*, *e<'ite @A illu<trating the
e$igencie< o) recei6ing the 1r*er in 're'aring @A Relie) #ro@ -u*g@ent >otion<. Veronica continue to curtlA re)u<e to
'ro6i*e @e anA co'A o) anA o) the 're6iou<lA )ile* 1r*er< o) the Court unle<< / 'ai* )or the@, *e<'ite @A a''arentlA not
ha6ing ?een 'ro6i*e* a co'A o) <uch or*er< in the )ir<t 'lace. / ha6e no i*ea =hat tho<e 'a'er< =ere CtheA certainlA =ere
not in the 'ro'ertA gi6en to @e u'on @A relea<e )ro@ Dail; an* ha6e recei6e* nothing in the @ail, *e<'ite u'*ating the
R>C =ith @A ne= a**re<< o): 817 N. Virginia St. #2, Reno NV 89501 an* )iling an o))icial Change o) ,**re<< =ith the
.S&S <hortlA a)ter / =a< <u@@arilA e6icte* C*e<'ite there ?eing onlA a No Cau<e Su@@arA 06iction notice again<t @A
co@@ercial lea<e, <o@ething entirelA 'ro?i?ite* again<t un*er NRS %0.25". Not onlA =a< / *enie* @A Si$th ,@en*@ent
Right to Coun<el =here Dail ti@e =a< a 'o<<i?ilitA Can* =here, /, in )act =a< Daile*, i@@e*iatelA;. / =a< *enie* a
continuance in thi< @atter *e<'ite a =ritten a<<ent to one ?A Reno CitA ,ttorneA &a@ Ro?ert< an* *e<'ite the )act that the
% Notice o) ,''eal, >otion to Vacate an* or Set ,<i*e, -CRC& 59, -CRC& !0, >otion )or
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Reno CitA ,ttorneA =a< gi6en one ?A @A <u''o<e* a''ointe* coun<el :e= Taitel C=ho@ i< Ja<<ociate* =ithJ
C htt':++===.ne6c<.co@+attorneA.ht@l ; an entitA that / ha''en to ?e <uing Ne6a*a Court Ser6ice<, inci*ent to the <a@e
e6iction 'rocee*ing )or =hich >r. Taitel *i* grant, an* the R>C *i* grant, a continuance in the other R>C ca<e again<t
@e, the tre<'a<< action that =a< <et )or trial on (ece@?er 1"th, ?ecau<e Richar* 9. 3ill, =ho / a@ al<o <uing in
connection =ith the =rong)ul e6iction again<t, =a< going to ?e on 6acation an* the R>C a''arentlA )oun* that a goo*
rea<on )or a continuance, co@'are* to the R>C )eeling @A ?eing e6iction on or aroun* No6e@?er 1"th, then =rong)ullA
arre<te* in connection =ith the e6iction, un*er a tre<'a<< charge, an* incarcerate* )or a nu@?er o) *aA<, all =hile Richar*
3ill a''lie* an unla=)ul rent *i<traint u'on @anA e$cul'atorA @aterial< that =oul* <'eaE to a <tate* an* e$'re<<
retaliatorA @oti6e on the 'art o) 2al@art an* the RS/C, an* other e$cul'atorA @aterial< ?eing =rong)ullA =ithhel* un*er
an unla=)ul rent *i<traint ?A Richar* 9. 3ill, 0<I., the <a@e 'er<on >r. Taitel, the Reno CitA ,ttorneA, an* the R>C
*eci*e* *e<er6e* <uch <anctitA a''lie* to hi< @onthlong 6acation )ro@ ThanE<gi6ing to Ne= 4earL< to grant a
continuance, =ith no in'ut )ro@ @e.
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another (0>,N( #1R -.R4 TR/,: 30R074 >,(0 /N 0V0NT 1# N02 TR/,:, S/>/:,R:4 R0M.0ST #1R
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(e)en*ant+,''elant Coughlin here?A re<'ect)ullA reIue<t< all 1r*er<, Con6iction<,
-u*g@ent<, Conte@'t #in*ing<, =hate6er, <te@@ing )ro@ the No6e@?er "0
th
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RE: your failure to propound discovery
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 12/08/11 5:14 PM
To: hazlett-stevensc@reno.gov
Windows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=57...
1 of 7 12/12/2011 4:21 PM

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure
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.

Date: Thu, 8 Dec 2011 16:05:11 -0800
From: Hazlett-StevensC@reno.gov
To: zachcoughlin@hotmail.com
Subject: RE: your failure to propound discovery
Mr. Coughlin. I have never spoken to you and have never denied discovery to a defendant in any matter. Again
you seek to engage me in a convesation about the pending trespassing. I cannot speak with you. You are
represented by counsel.

Thank you,

Chris
Christopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226

2 of 7 12/12/2011 4:21 PM
ATTORNEY-CLIENT PRIVILEGED

This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are
confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not the
intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that
any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or
attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in error,
please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and
then delete the message and its attachments.
-----Original Message-----
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: <hazlett-stevensc@reno.gov>, <robertsp@reno.gov>
Date: Thu, 8 Dec 2011 15:44:36 -0800
Subject: RE: your failure to propound discovery

3 of 7 12/12/2011 4:21 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
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.

Date: Wed, 7 Dec 2011 07:34:25 -0800
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded
with you, and your statement that you spoke with me is false. I have never spoken with you. You may have
your attorney, Roberto Puentes, contact me with any discovery issues or issues regarding the City's Motion to
Continue. Please do not correspond with me regarding this case in the future. As an attorney, you are fully
aware that I cannot communicate with a you as a represented party. Do not contact me without your
counsel.

Thank you,

Chris
City of Reno
Tel: 326-6628
Fax: 334-4226


confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not
4 of 7 12/12/2011 4:21 PM
the intended recipient or a person responsible for delivering it to the intended recipient you are hereby
notified that any review, disclosure, copying, dissemination, distribution or use of any of the information
contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at
(775) 334-2050 and then delete the message and its attachments.
To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for
which Lew Taitel was apparently my court appointed attorney, but whom no longer is.
Further, I wish to be copied on everything past and present in any way related to this
matter until and after I procure another attorney. I did not agree to the continuance you
sought, nor was I informed you were seeking it. I find it particularly troubling that a
continuance was granted in the trespass case to the same man who is applying an
unlawful rent distraint on both my client files, personal property, AND THE
EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT
LARCENY CASE FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST
YOU AND YOUR OFFICE'S HANDLING BELOW. NO CONTINUANCE WAS
GRANTED OR AGREED TO AT TRIAL BY THE RMC OR MS. ROBERTS,
PERHAPS SHE WAS TOO BUSY ALLEGEDLY SUBORNING THE PERJ URY OF
RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted
against me there is a fax from the RSIC to you that has a fax heading for what appears to
be "page 1" followed by pages without that heading...then a heading with "page 4" etc...
I want the entire contents of anything provided by the RSIC and Walmart to you or
anyone connected with the Reno City Attorney or the Reno Municipal Court. Further, I
want all media provided by Walmart, and I question why you needed 45 minutes with
the three witness who testified at the November 30th, 2011 trial, from 1pm to 1:45pm.
Additionally, you are hereby served a NRCP 11 motion requiring you to correct the
perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.
5 of 7 12/12/2011 4:21 PM

Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011
arrest in this matter demanding a copy of all documentation or discovery that I had any
right to. I was told I would not have any opportunity to review such materials prior to
the arraignment, which was not set for a full 30 days out from the arrest. Do I not have
a right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of
the arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written
demands and requests for such discovery and documentation were met with refusals to
provide such materials, and, in some case, claims that your office did not even have such
materials and would not get them until after the arraignment. Further, I spoke with and
provided written requests to RSIC Sargent Avansino within 2 days after the arrest and he
refused to provide the materials, as did the Reno Municipal Court. Please alert the court
to any wrongdoing on your's or the Reno City Attorney or the RSIC part in this regard in
prejudicing my ability to defend my case by delaying the production of essential
discovery, then refusing to agree to a continuance at trial, after earlier providing a
written agreement to such a continuance.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act,
18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you
are not the intended recipient or an ag ent responsible for delivering it to the intended recipient, y ou are hereby notified
that you have received this document in error and that any review, dissemination, copying, or the taking of any action
based on the contents of this information is strictly prohibited. This message is confidential, intended only for the
named recipient(s) and may contain information that is privileged, attorney work product or exempt from
disclosure 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.

6 of 7 12/12/2011 4:21 PM
7 of 7 12/12/2011 4:21 PM

Nevada Court Services
475 So. Arlington Suite 1A
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
Email: nevcs@nevcs.com

The following Attorney is associated with and highly recommended by Nevada Court Services

" Serving the People of Nevada"
Lewis S. Taitel
Attorney at Law
475 S. Arlington Suite 1A
Reno, Nevada 89501
(775) 322-2272
Fax: (775) 348-7977

Nevada State Bar No. 4397
Disclaimer: " The State Bar of Nevada does not certify any lawyer as a specialist or expert.."
Criminal Law - DUI Defense - Personal Injury
Property Law - Collections - Divorce - Civil Law
Adoption - Family Law
Nevada Attorney Directory
Page 1of 2 Nevada Court Services - Attorney
12/12/2011 http://www.nevcs.com/attorney.html
Copyright 1997-2011 - Nevada Court Services - All Rights Reserved

Page 2of 2 Nevada Court Services - Attorney
12/12/2011 http://www.nevcs.com/attorney.html
motion for continuance
Sent: Fri 11/11/11 1:40 AM
To: robertsp@reno.gov
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
Windows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=dd...
1 of 41 12/12/2011 4:29 PM
RE: motion for continuance
privilege.
Sent: Wed 11/16/11 3:35 PM

Thank You,

2 of 41 12/12/2011 4:29 PM
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: robertsp@reno.gov
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.

I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.

To: <robertsp@reno.gov>
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
3 of 41 12/12/2011 4:29 PM
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118

Sent: Wed 11/16/11 5:30 PM
4 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Wed, 16 Nov 2011 17:12:21 -0800
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling any
additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send you
an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
5 of 41 12/12/2011 4:29 PM
Date: Wed, 16 Nov 2011 15:35:48 -0800

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon at
1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we
are unable to resolve the case, you can ask the Court again for a continuance and I won't object. However, it
is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.


6 of 41 12/12/2011 4:29 PM
Date: Fri, 11 Nov 2011 01:40:53 -0800
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified
7 of 41 12/12/2011 4:29 PM

Sent: Thu 11/17/11 3:37 PM
Dear Ms. Roberts,

I do not mean to suggest you do not know what your duty it. Believe me, I am well aware that you could mop
up the court room with a neophyte attorney such as myself. I was merely hoping to get some direction from you
regarding trial practice approaches in general.

Sincerely,

Zach
Sent: Mon 11/21/11 1:05 PM
Sincerely,
8 of 41 12/12/2011 4:29 PM
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer. Penie
Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty is and I
will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
9 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Wed, 16 Nov 2011 17:12:21 -0800
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling
any additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send
you an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
10 of 41 12/12/2011 4:29 PM
Date: Wed, 16 Nov 2011 15:35:48 -0800

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon
at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and
if we are unable to resolve the case, you can ask the Court again for a continuance and I won't object.
However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.

11 of 41 12/12/2011 4:29 PM

Date: Fri, 11 Nov 2011 01:40:53 -0800
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
12 of 41 12/12/2011 4:29 PM
temporary address change and instruction to pursue a continuance
18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby
notified that you have received this document in error and that any review, dissemination, copying, or the taking of
any action based on the contents of this information is strictly prohibited. This message is confidential, intended
only for the named recipient(s) and may contain information that is privileged, attorney work product or
exempt from disclosure 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: Mon 11/21/11 4:06 PM
To: howardk@reno.gov; robertsp@reno.gov

13 of 41 12/12/2011 4:29 PM
14 of 41 12/12/2011 4:29 PM
Zach Coughlin
privilege.
Sent: Mon 11/21/11 7:18 PM
15 of 41 12/12/2011 4:29 PM
Ms. Roberts, the opposing attorney's unlawful rent distraint is preventing me from providing all the discovery I
would like to provide you with or ascertain the need to do, and further is preventing me from having access to
the materials and information I need to litigate this case.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Mon, 14 Nov 2011 10:36:45 -0800
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.


16 of 41 12/12/2011 4:29 PM
Date: Fri, 11 Nov 2011 01:40:53 -0800
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
17 of 41 12/12/2011 4:29 PM
verint user agreement

Sent: Mon 11/21/11 8:40 PM
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
18 of 41 12/12/2011 4:29 PM
Re: temporary address change and instruction to pursue a continuance
privilege.
From: Ken Howard (HowardK@reno.gov)
Sent: Tue 11/22/11 7:01 AM
To: Zach Coughlin (zachcoughlin@hotmail.com); robertsp@reno.gov
Mr. Zach Coughlin

There is an appropriate manner in which to tender "motions" to the court. They are to be properly
prepared and filed. Do not use this e-mail address to communicate directly with the judge.

Ken Howard
Reno Municipal Court J udge
Department 4
(775) 326-6673

To: <howardk@reno.gov>, <robertsp@reno.gov>
Date: Mon, 21 Nov 2011 16:06:32 -0800
Subject: temporary address change and instruction to pursue a continuance

19 of 41 12/12/2011 4:29 PM
20 of 41 12/12/2011 4:29 PM
Zach Coughlin
on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s)
and may contain information that is privileged, attorney work product or exempt from disclosure 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.

21 of 41 12/12/2011 4:29 PM
Sent: Tue 11/29/11 1:33 PM
Dear Ms. Roberts,

The opposing attorney in the Summary Eviction Proceeding against me in my home law office/business is
asserting a lien against my office, law practice files, and materials necessary to discovery production and
defending the case that you are the prosecutor on. I believe a continuance is absolutely necessary in the
interests of justice. Additionaly, you have been informed that Walmart previous to the arrest in this matter
became upset at the accused and made threats of malicious prosecution and abuse of process incident to the
accused questioning various Wal-mart personnel and managers about Wal-Marts curious practice of remixing
and forgetting the Return Policy stated in writing at Walmart.com (and expressly made applicable to purchases
made in Wal-Mart stores). A manager named "Ellis", though who may have identified himself as "John" and a
Loss prevention associate at the West 7th Street Wal-Mart in Reno allegedly told the accused that they would
have him banned from all Wal-Marts in retaliation for the accused seeking to do something to which he was
legally entitled to do, return and item at a Wal-Mart stores in accordance with Wal-Mart's stated and written
Return Policy. There are other retaliatory aspects to the conducts and statements made by both Wal-Mart and
RSIC personnel in this case.

Additionally, the video "evidence" that you provided is shameful. It consists of two short clips in some Wal-Mart
back room where 5-6 people, including 2 RSIC officers acting under color of state law on land their employer
owns and leases to Wal-Mart attempt to coerce not only a confession, but a consent to search. There is no audio
of the video, at least not the video you provided, that is. Where is the video of the alleged acts? How you can
maintain a case such as this stemming from the accused acts in a store like Wal-Mart, that has hundreds of
cameras and only provide video from some backroom that proves nothing and, in the words of "Jeannie" the
contact person at your office "doesn't show anything", I am not sure, and whether that is violative of your duties
as a prosecutor, Nifong, NRCP 11 (see Schumacher's application of that civil rule to the DA) is not clear. You
have been informed that the RSIC officer committed police misconduct and yet you brazenly announce in writing
that you do not intend to follow up on that, nor do you feel compelled to.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
22 of 41 12/12/2011 4:29 PM
privilege.

Date: Tue, 22 Nov 2011 07:59:37 -0800
Dear Mr. Coughlin, you will need to file a motion to continue in compliance with Reno Municipal Court
procedures. As I have stated in a previous email, I do not object to your motion to continue, however, it is up
to the J udge whether or not he will grant your motion. Regarding the video which I obtained at your previous
court date, I have told you that you can come to our office and view the video. If you still want a copy, I
believe our staff will be able to make one for you. NRS 174.235 does not require me to do more than what I
have already done. We have provided you with the reports we have, listed the witnesses we will call and made
the video available to you. Pam Roberts, Deputy City Attorney.
Date: Mon, 21 Nov 2011 13:05:28 -0800
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
23 of 41 12/12/2011 4:29 PM

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer.
Penie Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty
is and I will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
24 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified

Date: Wed, 16 Nov 2011 17:12:21 -0800
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request
for reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled
to copies of all the reports and witness statements and video we may have on this case. Since I am not
calling any additional witnesses that are not already mentioned in the reports/statements, I am not
obligated to send you an additional list of witnesses. I am also not obligated to do any further investigation
or interviews. Pam Roberts.
Date: Wed, 16 Nov 2011 15:35:48 -0800
25 of 41 12/12/2011 4:29 PM

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
confirmation from the Court that your trial date has been continued, you will need to appear this
afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at
that time and if we are unable to resolve the case, you can ask the Court again for a continuance and I
won't object. However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time,
so the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.


Date: Fri, 11 Nov 2011 01:40:53 -0800
26 of 41 12/12/2011 4:29 PM
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s)
only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are
hereby notified that you have received this document in error and that any review, dissemination, copying, or the
27 of 41 12/12/2011 4:29 PM
FW: temporary address change and instruction to pursue a continuance
taking of any action based on the contents of this information is strictly prohibited. This message is confidential,
intended only for the named recipient(s) and may contain information that is privileged, attorney work
product or exempt from disclosure 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: Tue 11/29/11 3:14 PM
To: robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may
be punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights under
color of state law and all those other things your office and Hartshorn, et all have been sued for over the years.

Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
28 of 41 12/12/2011 4:29 PM
your cop lying, see your video drivers license produce ap overview at
6:49 mark
privilege.

From: zachcoughlin@hotmail.com
To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800

Zach Coughlin,
Sent: Sun 12/04/11 3:37 AM
To: robertsp@reno.gov; kadlicj@reno.gov; kadlicj@ci.reno.nv.us
29 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
30 of 41 12/12/2011 4:29 PM
FW: your cop lying, see your video drivers license produce ap overview at
6:49 mark
Sent: Sun 12/04/11 3:45 AM

31 of 41 12/12/2011 4:29 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

From: zachcoughlin@hotmail.com
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
Date: Sun, 4 Dec 2011 03:37:24 -0800
32 of 41 12/12/2011 4:29 PM
your cop lying, see your video drivers license produce ap overview at
6:49 mark

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
33 of 41 12/12/2011 4:29 PM
Sent: Sun 12/04/11 4:05 AM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org; robertsp@reno.gov
pgoins@rsic.org, lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark

THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS A
FAR MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT
THAT WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS
"PARTICIPATION", AND ITS ALL ON TAPE.
34 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
35 of 41 12/12/2011 4:29 PM
discovery request;
privilege.
Sent: Wed 12/07/11 1:16 AM
To: robertsp@reno.gov; kadlicj@reno.gov

36 of 41 12/12/2011 4:29 PM
RE: your failure to propound discovery

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
Sent: Thu 12/08/11 3:44 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov
37 of 41 12/12/2011 4:29 PM

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
38 of 41 12/12/2011 4:29 PM
privilege.

Date: Wed, 7 Dec 2011 07:34:25 -0800
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded
with you, and your statement that you spoke with me is false. I have never spoken with you. You may have
your attorney, Roberto Puentes, contact me with any discovery issues or issues regarding the City's Motion to
Continue. Please do not correspond with me regarding this case in the future. As an attorney, you are fully
aware that I cannot communicate with a you as a represented party. Do not contact me without your counsel.

Thank you,

Chris
City of Reno
Tel: 326-6628
Fax: 334-4226


confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not the
intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that
any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or
attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in error,
please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and
then delete the message and its attachments.
To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
39 of 41 12/12/2011 4:29 PM
I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for which
Lew Taitel was apparently my court appointed attorney, but whom no longer is. Further, I
wish to be copied on everything past and present in any way related to this matter until
and after I procure another attorney. I did not agree to the continuance you sought, nor
was I informed you were seeking it. I find it particularly troubling that a continuance was
granted in the trespass case to the same man who is applying an unlawful rent distraint on
both my client files, personal property, AND THE EXCLUPATING EVIDENCE I NEED
TO DEFEND MYSELF IN THE PETIT LARCENY CASE FOR WHICH I DETAIL THE
COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S HANDLING
BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL BY
THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY
SUBORNING THE PERJ URY OF RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted
against me there is a fax from the RSIC to you that has a fax heading for what appears to
be "page 1" followed by pages without that heading...then a heading with "page 4" etc... I
want the entire contents of anything provided by the RSIC and Walmart to you or anyone
connected with the Reno City Attorney or the Reno Municipal Court. Further, I want all
media provided by Walmart, and I question why you needed 45 minutes with the three
witness who testified at the November 30th, 2011 trial, from 1pm to 1:45pm.
Additionally, you are hereby served a NRCP 11 motion requiring you to correct the
perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.

Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest
in this matter demanding a copy of all documentation or discovery that I had any right to.
I was told I would not have any opportunity to review such materials prior to the
arraignment, which was not set for a full 30 days out from the arrest. Do I not have a
right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of the
arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written demands
and requests for such discovery and documentation were met with refusals to provide such
materials, and, in some case, claims that your office did not even have such materials and
would not get them until after the arraignment. Further, I spoke with and provided written
requests to RSIC Sargent Avansino within 2 days after the arrest and he refused to provide
the materials, as did the Reno Municipal Court. Please alert the court to any wrongdoing
on your's or the Reno City Attorney or the RSIC part in this regard in prejudicing my
40 of 41 12/12/2011 4:29 PM
ability to defend my case by delaying the production of essential discovery, then refusing
to agree to a continuance at trial, after earlier providing a written agreement to such a
continuance.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
not the intended recipient or an agent responsible for delivering it to the intended recipient, y ou are hereby notified that

41 of 41 12/12/2011 4:29 PM
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~
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~~ ~ ~~~~ ~ ~ ~~ ~~~~~~~ ~ ~ ~~~~~~~~ ~ ~ ~~~ ~ ~ ~~~ ~~~~~ ~ ~ ~ ~~~~~~~ ~ ~~ ~ ~ ~~~ ~~~ ~~~~ ~~~ ~ ~ ~
~~ ~ ~~ ~~~~~ ~~ ~~ ~~~~~~~ ~ ~~~~ ~ ~~ ~~ ~ ~ ~~~ ~~~~~ ~ ~~ ~ ~~ ~~~ ~~
~
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11 cr 22176 2I
x
Judge Howard
Zachary Barker Coughlin
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
"Ellis" or "John", Customer Service Manager or ASM W. 7th St. Walmart 89503
Loss prevention manager and
2:06-cv-10887-GCS-VMM Doc # 1 Filed 02/28/06 Pg 1 of 19 Pg ID 1
6 again, that is rmc 11 cr 22176

RENO MUNICIPAL COURT
P.O. Box 1900
Reno, NV 89501
(775) 334-2290
Fax (775) 334-3824
E-mail address: RenoMuniRecords@reno.gov
RECORD REQUEST

INSTRUCTIONS: Request Date: ______________
1. Print out this request form.
2. Fill the form out completely.
3. Mail, fax or email your request to the Court.
4. You will be notified when your records are ready for pick up.
Copies may take 3-4 weeks

File Information:

Defendants Name: ______________________________________ Date of Birth: _______________________

Reno Police Case/Citation Number: ____________________________________________________________
(If you do not have this number you can contact Reno Police Department at 775-334-2175)

Charge(s):_________________________________________________________________________________

Charge Date: ______________________________________________________________________________

Requestor:

Name: ____________________________________________________________________________________

Mailing Address: ___________________________________________________________________________

Phone Number: ___________________________ Fax Number: ____________________________________

E-mail address: _____________________________________________________________________________

CHECK ONE:

Computer printout: This includes case history and disposition. ($0.30 per page)

Certified computer printout: This includes case history and disposition, all copies certified. ($3.00 per page)

I.N.S. Certified copies: ($3.00 per page)

Other documents: (Please specify) __________________________________________________________

You will be notified by phone or e-mail of the cost and when to pick up your records
11 28 2011
Zach Coughlin
9/27/1976
trespass
November 13th, 2011
Zach Coughlin
817 N. Virginia St
775 338 8118
949 667 7402
zachcoughlin@hotmail.com
x
x
and and all documents, and audio/video materials
pc sheet, witness statements, related police reports
dispatch recordings, 911 calls or other phone calls
Reno Police #11-22185
Court Rules and Procedures
Rule 1: Applicability of Rules
A. These rules may be referred to as the Reno Municipal Court rules and
may be abbreviated as R.M.C.R. These rules are intended to supercede
the rules promulgated and made effective on January 1, 1980 by the
Reno Municipal Court.
B. Whenever it appears that a particular situation does not fall within the
purview of a rule, or that a literal application of a rule would cause a
hardship or injustice in a case, the court may make such order as the
interests of justice require.
Rule 2: Organization of the Court
A. The Municipal Court consists of a number of departments designated by
City Council resolution, each presided over by a judge duly elected or
appointed to that position. Judges pro tem may sit in each department
from time to time as authorized by law. A judge pro tem duly appointed
and authorized by the presiding judge of a particular department to sit in
that department shall have the same jurisdiction as the presiding judge,
except that the judge pro tem has jurisdiction only over matters to be
heard on his or her assigned docket. Judges pro tem are not permitted to
act on any motion filed in any case, except those requiring resolution
before a case can proceed on the docket to which the pro tem judge is
assigned.
B. All cases set for trial or other post-arraignment proceeding, except a
sentencing set by the arraigning judge, shall be randomly or sequentially
assigned to one of the departments. Insofar as is practical, all cases
pertaining to a defendant shall be assigned to the same judge. In the
event a judge must recuse himself or herself, the matter shall be sent to
the administrative judge for reassignment to another department.
C. The elected or appointed judges of each department may act for one
another by mutual agreement as circumstances dictate.
D. Each year, the elected or appointed judges shall select one of their
number to act as administrative judge for the upcoming fiscal year. The
administrative judge shall handle all court administrative matters and
shall be authorized to speak publicly for the court on matters of court
policy.
Page 1of 3 City of Reno : Court Rules and Procedures
11/29/2011 http://www.reno.gov/Index.aspx?page=211
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of
their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the
court and serve the City Attorney with the same. The court may rule on
the motion or set a hearing.
Rule 4: Motions
A. Except for good cause shown, all motions shall be accompanied by
affidavit, and, when appropriate, by points and authorities. All motions
must be served on the opposing party and must be file stamped along
with accompanying proof of service.
B. The opposing party may file and serve answering points and authorities
on the moving party within 10 days after service of a motion.
C. The moving party may file and serve reply points and authorities within 5
days thereafter.
D. Upon the expiration of any time period set for response by this rule,
either party may file and serve a written request for submittal of the
motion, or the court may consider the motion submitted.
E. An opposition to a motion must state the reason(s) for objection.
F. Motions shall be decided without oral argument unless oral argument is
ordered by the court.
Rule 5: Motions by Facsimile
A. All rules and procedures that apply to motions filed in person at the
court shall also apply to motions filed by facsimile, except as otherwise
specified in this rule.
B. All persons are eligible to use motion-by-facsimile procedures.
C. All motions filed by facsimile must be accompanied by a cover sheet
which must include the persons name, address, fax number and
telephone number.
D. All facsimile motions filed by an attorney must include the attorney's
name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
E. All motions filed by facsimile must be accompanied by proof of service.
Service may be accomplished by facsimile when the receiving party is a
governmental agency, an attorney, or with the consent of the receiving
party. If service of the motion is accomplished by facsimile the 3-day
allowance for mailing shall not be computed into the time for response.
F. A defense attorney filing a motion in the first instance must also file a
proper authorization to represent.
G. Any motion received by the court after 4:30 p.m. or on a non-court day
shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except
for good cause. A motion or stipulation for continuance must state the reason
therefore and whether or not any continuance has previously been sought or
granted.
Rule 7: Corporations
Except with the permission of the court, a corporation or other business entity
shall not appear in propria persona.
Rule 8: Courtroom Conduct and Attire
Proceedings in court should be conducted with dignity and decorum. All
persons appearing in the court must be appropriately attired. All attorneys
must wear appropriate business attire.
Rule 9: Appeals to District Court
Except as otherwise provided in NRS 177.015 a defendant in a criminal action
tried before a Municipal Court Judge may appeal from the final judgment
therein to the Second Judicial District Court, at any time within 10 days from
the date that judgment is rendered.
Effective January 1, 2000
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
Janice store clerk walmart arrest receipt cashier 2nd St. 89501 Walmart
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
Brian Bain 2nd st Walmart Reno and LP supervisor 2nd St. 89501 Walmart
11 cr 22176 2I
x
Judge Howard
November 30,
2011
1pm
Zach Coughlin
29th
November
2011
faxed to or
asdfsadf Declaration
29th
NOvember, 2011
29th
November 2011
/s/ zach coughlin, signed electroncially
29th
dsafsdfaasdffdasfsafds
df
under penalty of perjury NRS
Janice cashier
, Brian Bain Store Manager; LP manager, 2nd ST. Walmart
John Ellis and ASM "Connie" 7th St. Walmart
emailed
NOvember 2011 notary not required where
Declaration under penalty
of perjury made NRS
and subpoena duces tecum
please appear and further bring any evidence including media related to
retaliatory threats by walmart staff or lp personnel
1. Odor v. Wal-Mart Stores East, Ltd. Partnership,
Slip Copy, 2011 WL 3203760, E.D.Ky., July 07, 2011 (NO. CIV.A.
10-287-WOB)
...endangerment in the second degree is a Class A misdemeanor. FN4. KRS
446.070 provides: Penalty no bar to civil recovery: (1) A person injured by the
violation of any statute may recover from the offender such damages as he sus-
tained ...
...Defendant violated these statutes. In fact, the only facts asserted are that
Plaintiff was struck by an automobile while in Wal Mart's parking lot and that
Wal Mart failed to use appropriate and reasonable means to properly control,
operate and/or manage its premises. (R. 141, ...
2. White v. Wyeth,
227 W.Va. 131, 705 S.E.2d 828, 2010 WL 5140048, W.Va., December 17, 2010
(NO. 35296)
...applicable to a common-law fraud claim applied, the Supreme Court noted that
[r]eliance is not a general limitation on civil recovery in tort. Id. at 655, 128
S.Ct. 2131. The Court went on to say in Bridge that while it may ...
...must, if possible, be given to every section, clause, word or part of the statute.
Syl. Pt. 3, Meadows v. Wal Mart Stores, Inc., 207 W.Va. 203, 530 S.E.2d 676
(1999) We recognize that some states require reliance on the deceptive...
3. Crouch v. Johnson & Johnson Consumer Co., Inc.,
Slip Copy, 2010 WL 1530152, D.N.J., April 15, 2010 (NO.
CIVA09-CV-2905(DMC))
...construed to limit a person's right to seek punitive damages where appropriate.
FN4. K.R.S. 446.070 Penalty no bar to civil recovery. A person injured by the
violation of any statute may recover from the offender such damages as he sus-
tained by ...
...2006 to 2008 purchased Defendants' products. J & J is a New Jersey corpora-
tion engaged in business throughout the United States. Wal-Mart is an Arkansas
corporation engaged in business throughout the United States. Therefore, the
Kentucky State contacts in the instant matter...
4. Kelly v. Palmer, Reifler, & Associates, P.A.,
681 F.Supp.2d 1356, 2010 WL 111492, 22 Fla. L. Weekly Fed. D 599, S.D.Fla.,
QUERY - "CIVIL RECOVERY" W/255
WAL-MART
DATABASE(S) -
ALLCASES,ST-ANN-ALL,NV-RULES,NV-AD
C,ALR,AMJUR,LAWREV-PRO
2011 Thomson Reuters. No Claim to Orig. US Gov. Works.
January 11, 2010 (NO. 08-21843-CIV)
...with either of these claims sufficient to send them to the jury. 18 FN18.
Plaintiffs focus on the allegedly deceptive civil recovery practices employed by
the Palmer Law Firm but do not claim the amount of money Simon and Baum
paid was ...
...pursue civil theft claims against them. Notwithstanding Plaintiff Simon's testi-
mony that she did not believe her son stole anything from Wal-Mart and she
only paid because she wanted to avoid being sued and incur additional legal ex-
penses [D.E. 165-3 at ...
...of these Plaintiffs can legitimately claim that there was no possible basis for re-
covery under 772.11 , which contemplates civil recovery for attempted
shoplifting. See 772.11(1) Any person who proves by clear and convincing
evidence that he or...
5. Robinson v. Rooto Corp.,
617 F.Supp.2d 748, 2008 WL 1999325, W.D.Tenn., May 06, 2008 (NO. 07-2543)
...E.D.Pa.2007) I adopt the view of those courts that the FHSA has no private
right of action Gibson v. Wal Mart Stores, Inc., 189 F.Supp.2d 443, 449
(W.D.Va.2002) The FHSA provides for no private right of action State tort ...
...precedents outside the Third Circuit, I find that the FHSA does not contain a
private cause of action. Isgett v. Wal Mart Stores, Inc., 976 F.Supp. 422, 429
(S.D.Miss.1997) In sum, except for the first Cort inquiry, all of the other ...
...Cross v. Bd. of Supervisors, 326 F.Supp. 634 (N.D.Cal.1968) (holding, seven
years before the Supreme Court decided Cort, that [ c]ivil [ r]ecovery under the
FHSA may be applied under appropriate circumstances [2] A few courts have
also applied the reasoning of Riegel...
6. Stringer v. Wal-Mart Stores, Inc.,
151 S.W.3d 781, 2004 WL 2363767, 150 Lab.Cas. P 59,920, 21 IER Cases 1682,
Ky., October 21, 2004 (NO. 2001-SC-0262-DG)
...a claim for common law invasion of privacy, the trial court appears to have
treated Appellants' claim as one for civil recovery for a violation of a statute. Ac-
cordingly, we, like the Court of Appeals below, will evaluate the claim as Appel-
lants ...
...The Court of Appeals held that: (1) the trial court erred when it granted partial
summary judgment for Appellants because Wal Mart's conduct in recording
conversation in the claims area as a mere incident of their intent to video the area
WAL-MART
DATABASE(S) -
fall[s] short of intent [W]e are convinced that the acts of Wal Mart were not of-
fensive to the eavesdropping statute ; and (2) Appellees were entitled to a direc-
ted verdict at trial because Appellants ...
...suffered as a result of the recorded conversations, and we think it incumbent
upon appellees to demonstrate injury resulting from Wal Mart's audio surveil-
lance. Hence, we are of the opinion that appellees failed to prove damages flow-
ing from the illegally recorded conversations...
WAL-MART
DATABASE(S) -

12 11 11 Final Motion For New Trial City of Reno V Coughlin RMC 11 CR 22176 (12 11 11 Final Motion For New Trial City of Reno V Coughlin RMC 11 CR 22176 PDF

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