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In Re Matter of

Zachary B. Coughlin

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ST&TE BAR HEARING

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Tar.:en u: , Frirl. ;t y ,

At

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June

21,

2002

9:11 o 'clock a.m.

At 600 East Charleston Boulevard

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Las Vegas, Nevada

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Reported by:

Linda Horton Sprague.

C.C.R.

No.

466

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


....... ,,"

w<=>c::t

Sahara Avenu e ,

Suite

770,

Las

Vegas,

Nevada

a910;?

APPEARANCES:

Panel Members :

Mi chael Ro we , Chairman
Dr. Gregory Bro wn
Kevin Kelly, Esq
Lori Story, Esq.

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For Zachary 8.

Coughlin:
Christianse n La w Of fices
Peter Christiansen, Esq.
520 Sout h Fou rth Street
Las Veg as, Nevada 89101

By:

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Also Present:
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Patrice Eichman. Esq.


Director of Admissions
State Bar of Nevada

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ASSOCI ATED REPORTERS OF NEVA DA - 702/382-8778


2300 West

Sahara Avenue,

Suite

770,

Las Vegas,

Nevada

89102

Thereupon-MR. CHAIRMAN,

The record should reflect

that this is the continued hearing before the State

Bar of Nevada, Moral and Fitness Committee.

We had previously met with the applicant on


2002.

And at my re quest,

as a reflection

March 1st,

of the entire committee' s vie w, the matter wa s

postponed -- or continued.

The applicant is present .

I would remind y ou , Mr. Coughlin,

you've

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previously been sworn,

and we wi ll not readminister

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the oath,

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say today will be pursuant to the earlier oath you

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took .

but we wi ll anticipate that everything you

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Do you recall taking the oath?

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THE WIT NESS:

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MR. CHAIRMAN;

Yes.
We'r e pl eased to say that

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Mr. Christiansen is here as applica nt's counsel.

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I'll introduce the com mi ttee .

I'll start on my far

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right with Dr. Gregory Brown.

Ms.

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my immediate right.

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And I'm Mi chael Rowe.

To my left,

Lori Story

is Mr.

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of.

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n o tice of the formal hearing for today .

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on

Kevin Kelly.

I'm chairman of the committee.

A fe w other procedural thi ng s

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1S

And

to take care

The committee will have marked as Exhibit 4 the

You've attached that to your brief as

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Exhibit A.

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Is that the n otice to whi ch y ou 've resp o nd


and why you are prese nt today?

MR. CHRISTI ANSEN,

MR.

CH AIRMAN:

That ' s correct.

Exhibit Number 5 is the

notice of the State Bar Witne sses.

notices are dated May 30th,

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Both of those

2002.

The record should r eflect that I have


consulted with members of the committee and with the

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applicant's counsel , and we do n ot intend to call

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Dean Morgan toda y.

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are in other areas, and we wo uld rather not interrupt

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his busy schedule .

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It's our belief that our concerns

Co unsel has indicated to me prior to the

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hearing that he did not request that the Dean be

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present for toda y's hearing.

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Is that correct?

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MR. CHRISTI AN SE N:

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MR.

CHAIRMAN :

That's accurate again.

The next exhibit in order,

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wh ich wi ll be Numb er 6 -- I should menti on we're

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starting up today from the e xh ibit numbers that we

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left off of from Marc h 1st.

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Ex h ibit Number 6 , Counsel,

will be your

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brief with your exhibits attached to it .

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received a copy of the prchearing brief with

We have all

ASS OCI ATE D REPORTERS OF NEVA DA - 702/382-8778


2300

West

Sahara Avenue,

Suite

770.

La s

Vegas,

Nevada

89102

And I ' m quite certain that all the ot her

exhibits.

members have revie wed it.

well.

I have revie wed it as

So we are familiar with that.

The burden still is upon --

MR.

Would you like to have the

KELLY :

transcript as part of the record?


The question be ing clearly

>JR. CHAIRMAN ,

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whether we were going to mark the transcript from the

earlier proceedings as an exhibit to this procedure.

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But at least my reco l lection of what the Supreme

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Court said to us in April,

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re cord, and I don ' t see a need t o attach it.

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happy to do it if you wish.


MR . KELLY:

o.

But I'm

I'm just making sure.


I had mentioned t o

MR. CHA IRM AN:

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the transcript is the

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Mr. Christiansen bef o re the hearing started after the

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hearing of March 1st, we had requested that

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Mr. Coughlin produce

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about what documents he should produce, one of which

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was the affidavit attached to the brief.

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we made some suggestions

But there were t wo documents that we asked

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for .

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Admissions -- I'm s o rry.

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And I am advised by the Director of

Ms. Reporter,
honorable pLesence

or

would you please reflect the


Ms. Patri ce Eichman,

wh o is

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


2300 West Sahara Avenue, Suite 770 , Las Vegas, Nevada 89102

My apologies,

with us today as well .

We had asked Mr.

Pat.

Coughli n to produce for us

the police report,

that I will brand the movie

theater i ncident, and also his transcript from Boyd

School of Law.

received neith er of those documents.

And I'm advised this morning that we

Is that correct

MS.

MR. CH AIRMAN:

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EICHMAN,

That ' s correc t.


Would you like to address

t hat ?
MR. CHRISTIA NSE N:

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Sure .

I will take

I took it upon myself to be

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responsibility.

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responsible for producing those documents.


In an effort -- I did notice,

when I did

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reviewed the transcri pt that Ms.

Eichman wa s kind

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enough to provide me with, a question was asked about

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the police reports.

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In an effort to obtain chose ,

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Bill Hane -- I think he's the chief deputy who

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Mr. Coughlin dealt with -- and attempted,

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staff,

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staff that because the documents re sulted -- or the

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charges resulted in an ultimate dismissal that the

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underlying reports are not kept for an e x tended

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period of time and they could not be located.

to secure those documents.

I contacted

through his

I wa s told by

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


2300 West Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

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I can tell you f r om my practice that o n ce a

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misdemeanor conviction is dismissed -- and this

obviously was a dismissal -- once i t has been

dismissed,

keep onl y the police reports leading to that

in vestigation for a period of 12 months,

they're destr oyed.

it is the policy of the D.A. 's Office to

and

hen

I have had it co me up numer o u s ti mes in

crimi n al cas es wher e a cooperating witness ha s cases

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resolved in a fa vora ble manner and I tried to obtain

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the police reports to see ho w the resolution was for

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him , and the D. A. ' s office destroyed them as a matter

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of cours e and not to hide a nything.

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The minutes have n lready been produced

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sho wing the dismissal,

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anything .

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couldn't get them,

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and I was unable to obtain

In add iti on -- so I made the effort, and I


I guess,

is the short story.

An d as to the t ran script , I didn ' t see the

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re qu est , and I'm sure I just missed it or assumed

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that , beca use when I applied with t h e Bar , I remember

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that I had to attach my transc r ipt,

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that Ms . Eichman had t hem a s a result of his

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applicatio n.

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and I assumed

Zack has a copy of his Boyd t ranscrip ts at


his house.

It won't be an officia l.

raised seal.

ASSOCIATED REPORTERS OF NEVADA - 702/382 -8778


2300 West Sa har a Av enue, Sui t e 770 , Las Vegas, Nevada 89102

stamped copy, but I can have that delivered today to

the commit tee.

my fault,

And I apologize again.

n ot Mr. Coughlin's .
MR. CHAIRMAN :

That would be

For the purposes of today's

I believe that we did want to revie w that,

hearing,

as we al ways do with each applicant.

A n o n -certified

copy woul d be acceptable for our re v ie w today,


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but I

believe t h e director requires , and our rules requir e,


a certified cop y of the transcript from the law

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school .
So if yo u will represe n t

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get that here as soon as possible,

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appreciate it.

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MR. CHRISTIANSEN:

to us that you will


we would

I ' ll send Mr. Coughlin

today as soon was we are done to go get it.


MR.

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CHAIRMAN:

Your brief ackno wledges the

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burden that ' s upon the applicant, Mr. Christiansen.

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We have seen, as I indicated.

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li ke to state for the record it is your burden to

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prove that the applicant possesses the moral fitness

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to become a member of the State Bar of Nevada.

your brief,

but I would

We need to be clearl y co n vinced that you do

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possess the character and fitness required t o

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practice .

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LULn Lhis over to counsel for presentati on

And since the burden is upon you,

I will

unlps~

the

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


2300 I,olest Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

com mittee members have any questions of co unsel at

this poi nt.


As I referenced in my

MR. CHRISTIANSEN:

One is Dr.

have a couple witn esses .

Hunter,

brief,

wh o, because of a busy schedule. couldn't be present

physically, but has agreed to call in at a number .

And maybe I can pag e him.

gi v e me the number to page him.

I'm sure Ms. Eichman ca n

If I do that first,

then I can call his

Dr. Tim Coughlin, who is her e to testify .

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father .

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Maybe there will be a call back from Dr.

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his page.
( Wh ereupon ,

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Hunter from

Dr. Hunter wa s paged,)

MR. CHRI STIANSEN:

Dr . Hunter ?

Yes.

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THE WITNESS:

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MR. CHRIS TIANSEN,

Dr.

Hunter,

I 'm present

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with the Bar co mmitt e e members -- Dr.

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Ms . St o ry,

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me as well .

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taking time to come and testify telephonically.

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But rather than asking you a ser ies of

Mr.

Rowe,

and Kevin Kelly.

J kn o w y ou have patients,

Brown,

Zack is with
and so you're

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questions,

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your involvement with Zack and your opinion ab out

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Zack.

2,

why don't you tell the committee members

THE WITNE SS:

First: off,

appr eciate your

ASS OC IATED REPORTERS OF NEVADA - 702/382 -8 778


Suite 770, Las Vegas, Nev ada 89102

2300 West Sahara Av enue,

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letting me check in telephonically.

in such company .

MR.

THE WITNESS,

I'm honored to

CH AIRr..,AN:

You flatt.er us,

Doct.or.

Do you guys have the letter in

front of you that I wrote on 5-21?

MR.

CHRISTIANSEN,

THE WITNESS,

They do,

Doctor.

That pretty much summarizes my

Zack has been coming in to see me since

findings .

early April.

He and I have spent enough time

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together that. I am pretty confide nt in my findings.

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And the very short version is there ' s no reason this

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kid shouldn't be practicing law.


MR.

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CHRISTIANSEN:

Doctor. you refer to

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Axis I and Axis II diagnostic tests.

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what t. hey are .

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them and what the results we re.

But ma y be you can clarify why you did

T HE h'ITNESS :

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I ha ve an idea

It's a diagnosis on five

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levels.

The y call them Axi s 1.

II,

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For the purposes of this hearing,

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don't belong here.

III,

II.

IV and V.

III,

IV,

and V

The big one is Axis I.

Axis I is what you think of when you thi nk

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of a psychological diagnosis.

Axis I answers the

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question :

What's going on here?

What's wrong here?

Axis II is less commonly discussed, but


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equally important criteria for a personaliLy


ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778
2300 West Sahara Avenue, Suite 77 0, Las Vegas, Nevada 89102

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This individual's pers o nality has been

diagnosis.

structured in such way tha t

chronic problems .

This is an antisocial person or

Zack has no Ax is II diagnosis.

wh atever.
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they ' re going t o h ave

There is

nothing pathological about his personality structure .


And he onl y has one diagnosis -- whi c h is

Wh en you have a -- a norma l

adjustment reaction.

person under

affect his functioning -- that'S a diagn osis that all

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But he comes up cle an o n b ot h on Axi s I and


Axis II.

CHRISTIAN SEN:

Dr.

Hunt er , how many

sessions have you had with Zack?


THE WITNESS:

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And that'S significant.


MR.

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stressful circumstances that

of us e xperience at some time in y o ur life.

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temporar~ly

d o n't kn o w.

More t han si x,

but l ess than ten.


MR. CHRISTIANSEN,

And in those sessions,

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have y o u tried to develop or hav e you seen Za c k

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develop any type of mechanism for dealing with

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stress?

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pri o r st res sf ul situations, and y ou and I talked

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about the m.

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I mean , you've seen s o me of his rea ctio ns to

THE WITNESS:

That's been a large thrust of

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what we have talked about.

And,

yes,

I think h e ' s

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got better s tr a tegies in place n o w than he has had


AS SOCI ATED REPORTERS OF NEVADA - 702/382-8778
2300 West Saha ra Avenue, Suite 77 0 , Las Vegas , Nevada 89102

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prev iousl y .
Does he hav e -- o r have

MR. CHRISTIANSEN,

you

seen him develop the mechanism to deal wi th

stress in a pro f essio nal way v e rsus some of the way s

he ha s dealt with it in the past?


THE WIT NESS:

Yes,

He clearly

ver y mu c h so .

has taken more significantly hi s ge n eral a wareness

level of i nsight.

stress -re lated problems o r stress - related reacti o ns.

Mo st people who wi n d up with

the y ' re n o t

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kind of snea ks up o n them because -- if you want t o

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fl y on auto pilot,

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situations.

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paying r eal good atte n t i on .

So stuff

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jus t

kind of reacting to

Zack and I talked ab out a tremendous amount

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about his cognitive structure,

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self-monitor in a different way a nd to n ot get blind

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sig hted by stuff .

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onl y in the context -- general a wareness of his o wn

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st r ess le v els are significantly better than they

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were .

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MR.

his abilit y t o

His general a wareness level is

CHRISTIANSEN :

Do y o u have a

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recommendation f o r Zack o ngoing?

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to th erapy regul arl y ?

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THE WITNE SS :

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Does he ne ed t o go

He and I believe -- Za c k --

yuu Cdn quesLi o n him mor e

- - but I

think we

h~vc

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2300 West Saha ra Avenue , Suite 770, Las Vegas, Neva da 89102

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affected a relationship at a level where he will call

me as he needs me .

more.

I'm going to see him a little bit

I don't chink there ' s a need for ongoing,

regularly scheduled therapy.

I do think it ' s g oo d

that he has alliance with somebody that h e can c all,

but I think that we have affected that.


MR . CHRISTIANSEN,

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seen him ,

marked improvemen t

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Over the time that you'v e

the numb er of months ,

ha v e

y ou

seen a

in his ability to deal with these

things?

Absolutely .

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THE WITNESS:

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MR . CHRISTIA NSE N :

Dr.

Hunter,

I ' ve

talked

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to you at length about this outside of this hearing.

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But can y o u sort of impress,

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committee,

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your opinion on Zack.

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your letter implie s it,

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them.

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I guess,

THE

if you can, upon t he

the strength of your feelings or

WITNESS:

I kno w what it is.

think

but I ' d like y ou to just tell

I feel real strongly -- and

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so me of this is because of my historical relati onship

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with the Bar .

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with attor n eys in Las Vegas .

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Bar's agent on some psychological consults.

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I ' ve done a tremendous amount of wor k


I ' ve served as the

I don't know the current panel,


exception of Mr.

Kelly,

who

with the

I'm familiar wi t h .

But

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


Suite 770, Las Vegas, Nevada 89102

2300 West Sahara Avenue,

my reputation is that I'm a fairly conservative guy

on this stuff.

is no reason that this guy should not be pra cticing

la w.

MR.

And I

feel v ery strongl y tha t

CHRISTIAN SE N,

Dr.

Okay.

d on 't have any more questions for y ou .

committee may have qu es ions,

MR. BRO WN:

just wanted to ask

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standardized

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that nature?

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THE

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Hi,

Dr.

there

Hunter,

The Bar

though.
Hunter.

Dr. Greg Brown.

if y ou perf orme d any kind of

esting,

l i ke an MMPI o r something of

No , Doctor,

\<1 ITNESS:

I did noc.

I did

not feel the n eed to do that.

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MR. BRO WN:

Okay.

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MS . S TOR Y,

Yo u say you think Zack needs - -

That's a ll .

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or will have a cou pl e more regular sessions before

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you rele as e him to this on-call r el ati o n s hip ?

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THE WITNESS:
expectation .

Yes,

MS. STORY,

Yes .

Tha t

was our

ma'am.
I guess that's all I wan ed to

kno w for sure.


MR. CHAIRHAN:

Dr.

Hunter.

this is

Mik e Rowe.
Did Zack explain to y o u in any detail the
previous hearing that we conducted with h im on
ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778
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Mar ch 1st?

That was part of our

THE WITNE SS ,

discussion, yes .
Wha t did he describe for you

MR . CHAIRMAN:

as his co nduct.

right term .

if you wi ll.

I'm n ot sure I could quote it

THE WITNESS,

I ' m not sure that's the

directly,

But the language wa s either , verbatim or pretty close

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to ,

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do wn.

"I

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and I don't h ave his chart in front of me .

Oh, my God.

melted down.

It wa s

I really melted

horrible.~

MR . CHAIRMAN:

I think that ' s probably a

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good characterization, of wh at I obser v ed at any

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rate .

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Doctor,

the concern that I as one member

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have is stress exists,

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occur to all of us all the time,

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our professio n.

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last hearing to the point where we stopped the

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proceedings based o n Mr.

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like the last hearing,

and

sometimes hourly in

And we were greatly concerned at the

THE WITNESS,

Coughlin's being upset.

Right.

I understand that.

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And I am actually,

in general , appreciative of the

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sensitivit y of the Bar .

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this than the medical board.

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a little more sophisticated , a litLle loore open of

You guys do a better job on


In general,

the Bar is

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778


2300 Nest Sa hara Avenue, Suite 77 0 , Las Vegas, Ne v ada 89102

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emotional issu es o f i ts pra c titioners.

It r e mains my professional op in ion that it

was an isolated incident that was the end of a long

cumulative peri o d.

that's not going to be r e p eated .


Aga i n,

It was a very atypical situation

i f I felt definitely -- Kevin,

felt differently,

guys not to let him pra c tice .

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f'>1R.

Doctor .

I wou ld have no problem tell i ng you

CHAI RMAN:

THE ,II TNESS ,

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MR. CHAIRMAN:

MR.

Kevin, do you have any

KELLY:

think y ou ans wer ed it whe n y ou

id entified it being an isolated in c ident.


T h e questio n 1 had was ho w long does an

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Okay .

questions?

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I appre ciate your candor,

Thank y ou very mu ch .

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adjustment rea ct ion period last?


THE WITNES S ,

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Anywhere, Kev i n,

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months,

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But I think he wa s clearl y,

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of it.

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if I

fr om days to

most usuall y a couple of si x we eks or so .

MR.

KELLY :

c l earl y t hr o ugh the worst

I mean , his physical

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appearance -- I have a vivid memo ry of wh at he looked

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like o n March 1st.

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thousand percent better.

And j ust,

physi c ally,

he looks a

ASSOCIATED REPORTERS O~ NE VADA - 702 /3 8 2-8778


2300 West Sahara Av e nu e , Suite 770, La s Vegas. Neva da 89102

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THE WITNESS;

Yeah .

I really do think you

guys caught him on one of the worst days of his life.

It was at the end of what was the most stressful

period of what,

This kid had always been t h e captain of the team and

the president of the club and so on .

to being in an underdog's position, and,

just didn't kn o w ho w to handle it .

frankly,

He wasn't used
frankly,

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part of Zack's stress arises from self-imposed

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standards t hat aren't realistic?


THE WITNESS;

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he

Do you think it's possible that

r<1s . STORY ;

had been an untroubled life .

I think that's absolute ly

That's absolutely what has been addressed in

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true .

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therapy.

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of doctors .

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is the criteria he sets for himself.

This is true of a lot of lawyers and a lot


The most demanding criteria in his life

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But I think we've talked through that, and

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he has more realistic expectations of what he ought

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to be doing .

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MR. CHR ISTIANSEN;

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Pete Christiansen.

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questions .

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y our patients.

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Dr . Hunter,

this is

I guess e v erybody is done asking

I appreciate you taking time a way from


I kn o w you're very busy this morning.

THE t'l ITNESS;

Okay .

I appreciate it.

[eel stro ngly about this, and I wan ted to be on the


ASSOCIATED REPORTERS OF NEVADA -

702/382-8778

2300 \oJ est Sahara Av e nue, Suite 770, Las Vega s , Nevada 89102

18
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record about ho w I feel.

me the chance to do so .

MR.

THE WITNESS,

So I appreciate your giving

CHRISTIANSEN:

Thank you,

Doctor.

Call me lat er and let me know

ho w it went.
MR. CHRIST IANSEN,

Okay .

if I could call Tim Coughli n,

out in t he lobby.

think maybe next

Zack's father.

He's

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Thereupon ,

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TI MOTHY D. COUGHLIN

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was calle

as a witness and,

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s worn , testi fi ed as follo ws:

having been first duly

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MR. CHRIS TIANSEN:

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Dr. Coughlin,

this isn't

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quite like the questi oning that would be in court,

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but you are under o ath today.

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committee that is going to make a recommendation in

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Supreme Court on the admission or non-admission of

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your son.

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Tell the Bar,

This is the Bar

the committee members, wh at

y ou do for a living .
THE WITNESS:

I ' m a family practitioner in

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Reno, Nevada, and one of the founding members of Reno

25

Family Physicians .

And I'm an associate professor at

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19

Family Practice at the medical school.


MR.

You 're also the father of

CHRISTIANSEN,

the applicant?
Yes.

THE vII TNESS:

MR. CHRISTIA NSEN:

As you know,

the area --

you and I

with is the moral character of Zack.

a chance to revie w e-mails and talk to me about him.

-- that the Bar has expressed concern

In general,

10

have

Tha t's correct.

of.

And you ' ve had

how was Zack prior to this.

sort

last eight months of his life?

THE WITNESS:

11

12

of character .

13

to me.

Well,

this is completely out

This is -- you know,

it's mystifying

And it just simply isn't Zack.


I remember when Zack graduated from high

15

school,

16

published poet and professor of English at Reno High

J.

and,

Tom Mishare

(phonetic),

who is,

you know, a long-term MBA player,

y ou kn o w,

wr ote him the

18

most glo wing letter that I've ever read.

19

better than anything I ' ve ever had.

20

Zack that I

21

It wa s much

And that's the

remember.

Zack was a, you know,

National Merit

22

Finalist.

23

most valuable player in the Morman Triple A and a

24

com plete straight arro w .

25

anything out of line.

He was All-State in basketball.

He wa s

I mean, he didn ' t do

And his mother and J

would

AS SOC IATED REPORTERS OF NEVADA - 702/382-8778


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say,

you kno ....'.

gOing to have

other.

ever y once in a while,


0 act out a

You know,

sometime he's

little bit,

one way or the

You

the e-mails wer e appalling.

know,

I read one where he was complaining about a

professor wh o was apparently stalking some female law

students and had given Zack, y ou know,

in the class,

involved wi th the best grades in the class.

while he gave the t wo girls that he wa s

The letter wa s

10

just ridiculous.

It was beyond belief.

11

immature.

12

is going on here?

13

character. "

. 4

a poor grade

And I

It

said.

was so
"What

This is just completely out of

So, you kno w, we've had -- I've had s o me


And I think we 'v e

15

concerns about that sort of stuff .

16

come through that .

17

diagnosis of an adjustment reaction is accurate.

18

think he wh o learns must suffer.

19

has learned a great from this,

20

has.

21

he has.

I think there is -- I think the

And I

think Zack

at least I hope he

And after talking with him repeatedly,

22

I'm sure

And we are very much a ware of how

23

inappropriate this stuff was.

24

And I read the brief that he wrote there.

2S

thoughL,

you kno w,

Some of it's arrogant.


And I

what are you using for judgment

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21

here?

You're under the gun and you send off a thing

that is flippant and immature .


You know, we don't have any defense in this

But I can tell you,

regard .

typical of Zack.

this is not

Can you tell us -- or I

MR . CHRISTIA NSEN ,

absolutely,

Can you tell the committee members

already know.

what stress you kno w of that Zack was undergoing

during this sort of window in his life where these

10

inappropriate things were happening?


I kn o w that Zack is o ne of the

11

THE WITNESS:

12

hardest workers I ' ve ever met.

13

o n something, you kno w, it gets done.

When he gets focused

He taught himself to play the pian o whil e he

14

After he gave up sports,

15

wa s in college .

16

music very intently.


And I know that

17

~n

he took up

his freshman year in law

18

school, he made the la w re v ie w.

19

this was the hardest he had ever wor ked in his life.

20

And,

apparently,

And he told me that

that was one of the impetus

21

for send ing this letter to the dean was that he felt

22

that he had worked incredibly hard and that some,

23

know,

24

wa s the only B he got that year .

25

you

behavior on the part of a professor was -- it

And I said, you know, y o u came across as


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22

just a pissy little brat wh o didn't get the grade he

wanted .

But the way you said i t ,

it's just nutty.

You kn o w, wh at you're saying is accurate.


is ridiculous.

In t h e last t wo years,

You

know,

I've gone through a

We've now reconciled.

But I

think that

separation.

wa s a major stress o n Zack.

or four kids in co ll ege at one time , so I think he

thought that financially he wa s a burden.


And,

10

in fact,

You kno w, we had three

I have spent over a

hundred

11

thousand dollars in the last three years on education

12

alone for,

13

have.

14

would we not have supported him.

15

But,

you kno w, a number of the children we


you kn o w,

he misread that.

At no time

You know, my parents took out loans until

16

they were blue in the face.

17

vacations f or se ven and eight years in a row and put

18

all four kids through graduate school.

19

occurred to me to pay a tuition.

20

ridiculous I was at that point.

21

They didn't take

It never even

That's how

And looking back on this.

y ou know.

there

22

were some periods in my life where my judgment early

23

on rivaled Zack here at this point.

24

tell you some hair-curling stories of just atrocious

25

judgment and borderline criminal behavior.

I mean,

could

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23

stories.

ca n you tell us -All right.

THE WITNESS:

Rather than tell us your

MR. CHRISTIANSE N,

I'm not going to

do that.

Can you tell the

MR. CHRISTIANSEN,

committee members what improvement,

seen in your son since

do wn day Mar ch 1st,

California Bar,

if a ny, you've

well, we'll call the melt

2002.

The day after he takes the

and his car breaks down,

and he comes

10

back to Vegas and appears before these four people by

11

himself.

THE WITNESS:

12

13

of,

I think,

1;

he had w ith a girl,

the first real meaningful relationship


too.

MR. CHRISTIANSE N,

15

16

Plus there was the break up

Dr. Hunter,

have you seen a marked difference at all.

17

THE WITNESS:

18

MR. CHRISTIA NSE N:

19

Yes.
Wh at difference have you

seen?
THE WITNE SS:

20

It's more like the old Zack,

21

you know,

that I remember.

22

you know,

has some judgment .

23

immature.
change.

25

Since he's been seeing

You know,

He's solid.

He's stable,

Isn't flippant and

it's nice to have him back for a

I think we'v e gone through a very rough

pel.-iod.

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earl y -- right? -- t wo and a half years?


Yeah.

THE WITNESS:

MR. CHRISTIANSEN:

school and wor king; right?

Took the bar wh ile in-law

Right.

THE WITNESS,

MR. CHRISTIANSEN,

No w , he finished la w

MR. CHRISTIANSEN,

Passed the Nevada Bar

before he even graduated from la w school?


THE WITNESS:

That's correct.

That,

also,

10

was the difficulty of having turned in the paper was

11

sort of symptomatic of the whole thing .

12

you're working hard enough to pass the Bar before you

13

graduate from law school,

l~

revie w,

15

You're obviously doing your work .

16

think if

if you've made the la w

you're not a guy who doesn ' t do his work.

But you put yourself in a terrible position

17

by not turning in the e - mail copy and then getting

18

then developing all kinds of rights and privileges

19

and stuff.

20

silly .

21

way s about it .

22

you kno w, along that line that wa s

I mean,

it was j ust stupid.

just

There 's no two

But I think when you look at the overall

23

thing,

this is not a guy who d oes n't do his wor k .

24

mean,

25

there without having done the work .

he couldn ' t write the draft that he wr ote in

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An d

then to wards the end of

the draft,

you kno w,

he

I'm sure he

juSt drifts off i n to being

thought he was being cute.

when you turn in a paper like that to a professor,

where you're try i ng to be c u te by ten times .


HR. CHRISTIANSE N:

To me,

i t ' s insulting

in lig ht

Do you have

of

you

kn o w , operate to t h e pro f essional and ethical

10

the im p rovement t h at - - the old Zack is back.

have a n y co n cer n s about his inability to , you

standards he n eeds to?


THE

11

~'lI

No .

TNESS :

I kno w to an absolute

12

ce rtainty that Zack kno ws rig h t

13

very seriously_

14

thing_

15

so mebody wh o will stand up for what ' s right.

from wrong.

takes it

He kno ws when he's doing the wr ong

And he has a g oo d heart.

You kno w , he's

And h e ' s been that way ever since he was a

16

little kid .

18

of growing p ains t h at p eo p le go through .

19

it ' s unfortunate h e picked la w schoo l

20

it b eca use he h adn't

21

him in high school and co l lege,

22

this is the most soli d,

23

ever met.

24

So this is -- I

guess this is some sort

17

25

do

And I

think

to go through

-- you kno w, if you had kn o wn


you would have said

stable person, you k no w,

I' v e

And then suddenly we drift off into this


thing.

But , you k no w,

I 'v e had periods like that.

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26

And I don't kno w if anybody here has had anything

like that .

through it without any major ,

happening here.

A lot of this is self-inflicted

damage.

it simply didn't need to happen .

But,

I mean,

fortunately ,

additional questi o n s

committee members do.

for Dr.

MR. CH AI RMAN:

thi n k we've gotten

terrible things

I d o n't think I have

MR. CHRISTI ANSE N:

Coughlin.

I'm sure the

Starting again Dr.

Bro wn?

I d o n't think so.

10

MR.

BROWN:

11

HR . CH AIRMAN,

12

MS.

13

THE WI TNESS:

14

MS . STORY:

15

THE WITNE SS ,

STORY :

Ms. Story?

Ho w many c h ildre n do you have?

Si x .
What 's Zac k' s plac e?
Zack is third oldest.

His has

16

t wo

17

psychology fr o m Portland .

18

sister who's teaching special ed in the middle school

19

in Ren o .

20

wh o 's a sophomo re who is going into ,

21

junior year , and t wo sisters at home.

22

23

older sisters , o n e of wh om just got a master's in

He ha s another older

He h as a younger brother here in Vegas

MS . STORY ,

I believe,

his

How o ft e n did y ou talk to Zack

while he wa s in la w school?

24

THE WITNESS:

25

MS STORY :

Once a week,

at least.

Did he ever express Lo you oc did

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1

you ever pick up from him the stress and the

financial problems he was having?

THE WITNESS:

Yeah.

first year when he was,

And I

-- especially

the,

with the professor who has subsequently. apparently.

left the law school and did -- I mean,

kind o f unusual

it was a very

I kno w from running a large group

you kno w, when you accuse somebody of

10

sexual harassment,

11

charge .

that ' s a very, very serious

And I said to Zack,

12

in conflict

very scary sort of thing.

I mean,
practice that.

apparently,

I don't know what you're

There's only two things that ca n

13

thi nking about.

14

happen here -- he leaves, o r you leave.

15

dealing with somebody who is probably very sick and

16

very bright,

17

of trouble .

And y o u're

and y o u're going to be in a great deal

But this being the re al world , a third thing

18

19

happened -- nothing.

20

because if somebody had been d oi ng that in my o ffic e ,

21

he would have been fired immediat el y.


MS. STORY,

22
23

So did Zack pay for his o wn la w

school education?
THE vIITNESS,

24
25

So -- which astounded me

kind

of

st uff.

With a lot of loans and that

But we provided,

you know,

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1

significant financial support too.

of

law school wit h a fair amount of debt.

MS.

THE WITNESS ;

MS.

But he's come out

STOR Y,

STORY ,

Most o f us do .
It ' s amazing.
I don't have an y further

questions.

MR . CHAI RMAN:

MR.

KELLY,

MR.

CHAIR MAN:

10

THE WITNESS :

11

MR.

KELLY,

Mr.

Kell y?

No questions .

Thanks for taking your time.


You're welcome.

Thanks for reading this stuff .

12

A lot of guys come in and they give character

13

references for their kids or a good friend,

14

haven't read a damn thing.

15

it.

THE WIT NE SS:

17

MR.

21

KELLY,

He writes well.
I think he writ es exception a lly

well.

THE WITNESS:

19
20

of

Enough to get himself in a lot

t.rouble.

MR.

CH AIRMAN,

Doctor,

22

co ndu cted the first hearing,

23

become very emotional.

24

the hearing.

25

clearly, you 've read

and we appreciate the time --

16

18

And,

and they

on March 1st when we

we noticed that Zack had

And as a result, we stopped

Has Lhere ever been a similar kind o[

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29

incident?

And I'd be happy to describ e it further or

allo w any of the other members to des c ribe wh at we

observed .

knowledge?

Has this occurred in the past,

THE HITNE SS :

No.

to your

That wa s very, very

upsetting to me wh en r heard that because I thought,

you know,

do wn and cry in a meeting,

upset.

Zack is a pretty tough kid .

Now,

10

And to break

he had to be very,

very

depression does run in the family.

An d

And,

11

so I assume that he was stressed and depressed.

12

apparently,

13

his own and was terrified that every time he turned

14

around he was going to be incurring another legal

15

bill .

16

to do that on his o wn,

17

And,

he was trying to handle this hearing on

That's one of the reasons that h e was trying


and he just wa sn ' t up to it.

you kno w, what I've tried to get across

18

to him is, you know, when you ' re wrong,

19

You kno w, life is very hard for people who can't

20

admit that they were wrong.


And,

21

fortunately,

admit it.

I think he sent enough

22

letters of apology and realizes that he was just

23

flat,

24

that is clearly a very atypical kind of reacti o n for

25

him to have .

dead wrong.

And, you know,

it was -- you kno w,

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And I thi nk he had driven o v er to

his car blew up on the way over

California ,

taken

there --

and I think he was just runn ing on o verl oa d.

took the Cali f ornia Bar,

You kno w,

it sou n ds like

- - well,

there,

was a three - hour hearing at that poin t.

something along that li ne .


MR. CHAI RMAN,

Well,

Is that

--

I think the last time

But we ha d taken

10

was about that lo ng,

11

several breaks to all o w Zack an opportunity to try

12

and collect himself.

13

adjourned,

14

that and allo w him t ime to collect himself.

15

Doctor.

I wasn't

And 1 guess that

but it sou nd s pretty bad.

came back f or this,

And the third o ne.

it was obvious to us that we

wh en we

needed to do

and I ' m not saying it for

T hi s committee

16

any reason other t han advising you,

17

formal title is Mo ra l Character and Fitn ess .

18
19
20

And,

Doctor , our

fran k l y, my concerns are more the

nature of the fitness , based on what I observed .


So with t hat in mind, kn o wi ng what we 'r e

21

charged were doing, wh at are your feelings ab out

22

continued cou n seling or therapy wi th Dr.

23

you think that ' s advisable?

24

THE WITNESS:

25

MR.

CHAIR MAN:

Hunt er?

Do

dad,

--

Yes.
Based on being

how

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THE WITNESS,

I think that's a good idea,

It ' s just -- anybody would benefit from

you know.

counseling.

You k no w, a good counselor is worth

their weight

~n

every o nce in a while.

is not worth living, and yet we careen through our

lives and never really look at how we're feeling and

what ' s happeni ng to us .

wouldn't benefit from that .

gold.

And we all ought to do that


They say the unexamined life

So t h ere isn't anybody that

And I've been to counseling.

10

You know,

11

we're in marriage counseling at this point, and

12

that's been very helpful too.

13

what soever with that.

14

you

15

year is atypical.

know,

16

So I have no quarrel

But I also want to reiterate,

what I've seen in the last six months or a

And I feel real strongly we're not dea ling

17

with any kind of underlying major psychopatholog y .

18

we ' re not dealing with somebody that's schizophrenic

19

or somethi ng like that.

20

We're dealing with somebody that has -- you

21

know,

I think the adjustment reaction idea is

22

accu r ate .

23

immaturity.

24

is v ery funny, and he's a great mimic.

25

see he ' S got -- well, a good sense of humor.

And r think there's a certai n amount of


I remember when in high school -- Zack
And you can
He

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32

misplaced it where he put it.


But when he wa s in high school,

the Yale

basketball coac h came do wn and intervie wed him.

I was meeting wi t h the guy beforehand , and I was

telling him Zack was very funny.

And

And Zack sho wed up and sho wed him catatonia,

one word ans we rs,

the hell -- you kno w, what happened in there? "

you forget the y ma y be as big as a house and smart as

10

a whip,

stuff like that.

And I said,

" What
And

but they're still just 17 .

11

And when somebody comes down and

12

intimidates -- you know,

13

I said,

14

going on here?"

is sort of intimidating, and

" Gee, you didn't talk to the guy.

So I don't kn o w if that -- I don ' t

15
16

that has to do with this,

17

that sometimes,

18

wh o are still young.

19

make steel .

20

really.

What's

know what

But it reminds me

you know, you're dealing wi th people


You know, and it takes fire to

And you have to go through a whole lot of,

21

you know,

22

out on the other side with some judgment and some

23

humility.

24

here .

25

bad things every once in a whil e to come

And I think that's sort of what's happened

MR. C}I AIR MAN :

Any further questions?

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33
1

MR. CHRI STI ANSE N,

You k no w ,

and I

Thanks,

I ' ve done these a

number of times

now,

hearing me blo w a bunch of smoke,

about some o f the perspective he's had and maybe

respond to some qu est i o n s

think the be st appr o a c h,

Dr . Coughlin .

rath er than

is to let Zack talk

from y ou .

I wo uld tell e v e rybod y that to listen to his

dad tal k ab ou t him is a different typ e of emotional

thi ng than an emotional deal where -- that you sa w

10

Mar c h the 1st.

I ' ve had Zack in my office .

11

You kn o w,

12

somebody on t he committee recommended he come see me

13

early on .

14

t wo different pe o p le from how he dea lt wit h stuff in

15

my office ,

16

do wn in tears t o t o day.

17

h ou r s yesterday ,

18

able to handle it.

19

And I can te ll y ou ,

where,

it ' s like loo k ing at

i n a q u estion , I could have had him

wh e re,

berated him,

you kn o w --

for t wo

and h e ' s pr etty much

Hi s dad h olds a s o ft spot -- y ou kn o w, he

20

has a soft spot in h is heart for his fat h er.

21

just poi n t

22

the one yo u sa w the n.

23

So ,

And I

o ut that that ' s a different emotion than

Za c k,

why don ' t

y ou tell ,

in your o wn

24

words , the committee members what y ou ' v e learned

25

in --

I don't know -- Mar c h 1s t

-- it's ab out three

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34

and a half months -- about things that you did.

What have you learned

THE WITNESS ,

break for a second.


MR.

(Recess from 9:55 a.m.

MR.

CHRISTI AN SE N,

CHRISTI AN SEN :

THE WITNESS ;

MR.

12

THE WITNESS :

13

this point.

14

stuff.

15

MR.

16

hearing,

17

haven't I?

to 10 : 0 4 a.m.)

Zack ,

tell

the Bar the

I'm working at Perry and

CHR I ST IANSEN,

I ' m doing researc h and writ ing some

CHRISTIANSEN:

No w,

since this March

I've had occasion to see you in court,

THE WITNESS :

19

MR . CHRISTIA NSE N:
the re ?

Wh at are you doing there?

I suppose I'm a la w clerk at

18

21

That's fine .

Spann.

11

20

Sure.

committee what y ou 're d oing no w where you're working .

9
10

the best question?

May be I could take a rest room

15

You were n' t

That ' s correct.


What were you doing over

practi ci ng.

THE WITNESS:

I was n't practicing.

wa s

22

wor king o n a case called Lewis v Sunrise in front of

23

Judge Parraguirre for some attorneys from Oklahoma

24

who were practicing with Early and Savage on a

25

medical malpractice defense .

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MR.

CHRISTIANSEN,

through an actual jur y trial?

THE IH TNESS,

MR. CHRISTI ANSE N:

So did you get to sit

Pretty much, yeah.


Did you do some of the

pretrial motion work?

Some of the v erdict packet.

THE WITNES S,
7

help out a lot on some of the research issues,

of that sort .

MR.

CHRISTIANSEN:
h~d

things

I wa s not here for the

10

last meeti ng you

11

transcript sho ws that you told the Bar committee that

12

you

13

stressful time in your life.

with the Bar, but your

thought taking the Bar was going to be the most

Have

y ~~

may e change d thal o pin io n?

THE WITNESS,

Sure.

I mean,

never really

16

intended to sa y that.

17

be more stressfu l than what an attorney does,

18

certainly .

19

You kno w,

I thought taking the Bar would

--

MR. CHRIST IANSEN:

You have some real life

20

experience of the stress that goes along with

2]

practicing?

22

THE WITNESS :

23

MR.

24

THE WITNESS,

25

Sure.

CHRISTIANSEN:

Absolutely .
Is it stressful?

Certai nly,

it's stressful.

think it ' s a lot more stressful than taking the Bar.

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778


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36

There ' s a lot higher stakes and things of that sort .

I think what I meant when I said it wa s more

stressful

developed the coping mechanisms for stress that most

attorneys have de v eloped because they have to.

at that p oint in time,

And so in that regard,

I hadn't

it was more stressful

than I inte nded for it to be when I'm a c tually

practicing.
MR . CHRISTIA NSEN :

10

school in three full y ears?

11

THE vHTNES S :

12

MR.

No w , y ou went through la w
T~ o

and a half year s?

Two and a half years.

CHRISTIANSEN:

Too k the Bar after your

13

second y ear while y o u were employed and going to

.:. 4

school;

right?

15

THE \>lITNESS:

16

MR.

Yes .

CHRISTIANSEN :

You heard about e-mails

17

and briefs and the movie incident,

18

called it , and do you have any different perspective

19

on those now after dealing with Dr . Hunter than you

20

did,

21

with Dr . Hun ter and me,

22

maybe,

as Mr . Ro we has

at your last h ea ri n g o r before dealing

THE WITNESS,

to be honest?
Certai nly .

You k no w,
you kno w ,

the

23

further I get away from all this ,

the more

24

and more I have to cringe at reading some of the

25

e-mails and things of that sort .

Not so much in the

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778


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37

underlying actions that caused the e-mails because I

d o still su bmit that I

certainly t he way I handled it wa s completely

inappro priat e .

turned in the p a per,

And , u
yo kn o w ,

but

the furth er and further I get

a way and take a l ook at the papers, you kn o w,

hard to loo k at that st uff.

10

it's

Has Dr . Hun ter helped you

MR . CHRISTIAN SE N,
i n any regard?

THE WITNESS:

Ce rtainly.

I've developed

11

some coping mechanisms for stress .

12

mentioned,

13

is essential to avoiding some of the situatio n s

14

gotten myself i nt o with some of these e-mails.

15
16

17
18
19

And as you

some of the self-monitoring behavior that

MR.

KELLY:

Zack ,

can you

I've

just tell me what

some of those co pin g sk ills are?

THE WITNESS ,

Well,

to try to do too mu ch .
MR.

KELLY;

I think foremost is not

You kn o w,

a good example

Do you reall y believe that have

20

you ' ve acce p t ed that propositio n -- that we all have

21

limitatio n s in ou r liv es , o r are you still trying to

22

accept that?

23

THE WI TNESS:

24

Unfortunately ,

25

I first met you guys.

No.

I t hink I have.

I had already -- I was n' t

able to when

I had just taken the

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38
1

California Bar .
MR.

today.

KELLY,

We rememb er .

I'm o nly talking

ho w y ou 're co ping today and in the future.


I ' m tr y ing to relate to that .

THE iH TNESS:

That was probably taking on more than I should have,

trying to take that Bar.

today , I probably wouldn 't , you kno w,

that I can ' t

you know,

And if I was doing that

because I know

j ust keep pushing things until I have,

n o real energy left in my life to make the

10

right decisions or , y ou kn o w, not get in a situation

11

wh ere I'm facing too much stress .

12

accepted that.

13

MR. CHRISTIANSE N:

14

me when you

15

Bars you wanted to take.

16

Califo rnia Bar ;

Tell them what you told

first canle and told me about how many


You wanted to take the

right?

17

THE WITNESS,

18

MR.

19

And I think I have

Yeah.

CHRISTIA NSE N;

was such a thing ,

And I didn't kno w there

but the Patent Bar?

20

THE WITNESS:

21

MR . CHRISTIANSEN :

Y eah .

An d some other Bar.

22

mean,

23

take every Bar under the sun,

24

that

you had these ideas that you were going to go


it seemed to me.

Isn't

right?

25

THE WIT NESS :

That's right .

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39

MR.

CHRISTIANSEN:

Is that still the way you

see yourself -- needing to do that?

THE WITNESS,

much I can and still,

mechanisms and behavi or that Dr. Hunter and I talked,

you kno w ,

accepting that I set some unrealistic goals for

myself.

No.

I just want to take on as

you know,

implement the coping

about -- not trying to do so much,

and things of that sort .

And sometimes when those goals aren't met,

10

it ca n be a situatio n wh ere I'm unrealistically

11

critical of myself.
MR.

12

KELLY:

13

morning.

14

the wh ole day _

15
16
17

Tell me a typical day_

Tell me what time you got up.

THE WITNESS:

Oh,

Go through

got up probably about 7:00

And --

and went into work at about 7:45 or 8:00.

MR.

KELLY:

This

Do you read the paper?

18

wat ch any of the ne ws things in t he morning?

19

eat breakfast?

20

to hear what y ou do.

21

22

Just give me a typical day .

THE WITNESS,

Yeah.

I get up.

I,

Do you
Do you
I want

maybe,

listen to a morning sho w or something .

23

MR.

KELLY,

24

THE wITNESS ,

25

of that sort -- or some music .

What channel?
Channel 3.

NBC or something

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1

MR.

KELLY,

THE WITNE SS,

Yo u know,

fort.unat.ely,

come home often for lunch.

there's -- y o u know,

a re kind of calming influences.

--

And that's ni ce.

And

Those

They must be better than my

wa s going to say, mine

just ate o f co rner o ff my s helf.


MR.

12

THE WI TNESS:

13

MR. KELLY:

KELLY,

What time do y ou leave work?


About 5:15.

Wh at do y ou do wh en y ou get

home?

THE WI TNESS,

15

I usually just relax for a

16

while.

17

actually have a fairly bad back problem,

18

tub help s with that.

19

talk to some friends or family o n the pho ne.

I g o in the hot tub for a whi le because I

20

MR.

21

THE WITNESS,

22

MR.

23

so I

I have a couple d o gs no w.

MR. CHRISTI ANS EN:

11

14

come

d ogs .

10

l ive right next to my wor k n o w ,

MS. STORY,

Okay.

KELLY,

KELLY.

and the hot

An d I wat ch some TV or , maybe,

Do yo u have roommates?
I

have o ne roommate.

Okay .

What time do you go to

bed?

24

THE vllTNESS:

2S

MR.

KELLY:

About 10:00, 10: 30 , 11:00.


So y o u're hom e at 5:00,

5:30,

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41

you hit

the hot tub .

Do y ou have dinner?

THE WIT NESS :

MR . KELLY :

THE WITNESS :

MR .

Do y ou k no w ho w to cook?

KELL Y,

What happens bet ween 7 : 00 and

THE WITNESS ,

Mayb e s ome lig ht r ea d i n g or

something of that sort .


MR .

KELLY :

Are y ou reading a book n o w?

10

THE WI TN ESS :

11

MR.

12

THE WITNESS ,

13

I coo k right no w.

10 : 00 before y ou reti r e?

Sure .

Yea h .

What are y ou reading?

KELL Y:

Right n o w ,

just started a

boo k called "'Ti s" by F rank McCourt .

14

MR.

KELLY,

15

THE WIT NESS :

What is the plot?


Oh ,

it.

co n ti n uation on his

"Angela's Ashes."

And

16

earlier book t hat he wrote

17

I ' m not really that far into it at t his point.

18

kno w he arrives in Ne w York and it kind of follo ws

19

his young life .


Do y ou go to mo v ies?

20

MR .

21

THE WITN ESS :

22

MR . KELL Y,

23

THE WIT NESS :

K ELLY:

24

about a mo n th ago.

25

had a

But 1

Well , sometimes .
What ' s

the last mo v ie you sa w?

I kn o w I sa w a movie probably

When I was looking for jobs,

loL of free time on my hands .

was going to

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42
1

movies .

MR. CHRIS TIANS EN,

THE WITNESS;

MS . STOR Y :

THE WITNE SS,

MR. CHRIST IANSE N,

Paying f o r movies.

Do y ou e x ercise?
I try to, y o u kn o w .

members about yo ur back.

my brief .

Paying f or mo vies?

THE WI TNESS,

Tell the committee


I neglected to do that in

Well , I have a r eal k ind of

10

complicated back pro blem that ' s bee n kind o f

11

started about five years ago , and I gu ess y ou could

12

describe it as c hronic pain.

13

of money recently o n MRI s

l4

Beca u se I don ' t

-- it

And we 'v e spent a lot

and things of this sort .

hav e any health ins ura n ce

15

and that was one of the reasons t hat I wan ted to get

16

through schoo l more quickly because the student

17

healt h insura n ce

18

MRI,

19

co me up with 8 to $1,200 r emai n ing o n the bill .

20

th at just wasn' t

23

if you want to get an

they ' ll pay for about $ 200 ,

and th en y ou h a v e

to

And

t oo r e alistic then.

MR. CHR ISTIAN SE N:

21

22

you kn o w,

So was t ha t an added

stress?
THE WIT NE SS ,

Yeah.
it 's

I mean,

anybody wh o h as

I t hink everybody

24

lived with chronic pain,

25

only has so much st r e ss they can tol@rate.

And,

you

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43

if you're living with c hr on i c pain.

kno w,

a good percent of y our allotted stress,

takes up

y ou kn o w.

And we 'v e r eally tried to address the

3
4

problem .

insurance.

But ,

y ou kn o w ,

it is difficul t

with out

No w I ' m working at Perry and Sp ann, an d

shortly my insura nce will be started,

that will help.

stress.

MR.

10

11

i t

Ce rtainly,

BROWN:

and some of

it wi l l a v oid some o f

th e

Ha ve you talked to Dr. Hun ter

about the c hr o nic pain?

12

THE WI TNESS :

Ye ah,

I did.

And he

13

recommended a pain spec ia list in to wn nam e Mc Kenna .

14

And I ' d like to go to h im .

15

little out of my ball park right n o w.

16

talk to him about dealing with the pa in .

17

kn o w,

Unfortunatel y,

it ' s a

But.

you know,

A nd ,

y ou

it's a mystifyi ng thing to me.


And he tried to giv e

18

to be honest,

he

19

tried to give me some thi n gs to deal with pain,

20

sometimes wh e n y ou 've been in pain for so long

21

ever yb od y has a remedy , and y ou stop liste n ing to

22

people tel l

23

so I kno w h e told me some things about pain.

24
25

y o u h o w to get a massage o r,

but

you kn o w

And I tried t o -- something about a cce pti ng


iL , and I

trie d to get as much out of it as I could .

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1

MR. BROWN;

Is it allover in your back?

THE WITNESS:

mid-thoracic problem .

of neck pain.

be a pain from a neck problem

showed something like three bulging discs in my neck

and then a bulgi ng disc in my back.

think structurall y that ma ndated a surgical

intervention .

It's pretty much a


Bu t

I also have a fair amount

And some of the doctors think it might


And some of the MRIs

And they didn't

10

But we have a s p orts a lternative way of

11

addressing the problem, such as therapy and some

12

alternative treatme n ts in additio n to the physical

13

measures of , you kno w, ice and massage and

14

chiropractic.
MR . BROWN:

15

THE WIT NESS:


17

What helps the most?


Exercise helps.

Not sitting

do wn at a desk for too lo n g helps.


MR.

18

BROWN:

What were some of those - -

19

Dr. Hunter and you both mentioned that you were

20

beginning to do self-regulation or to do

21

self-monitoring of your behavior of your feelings.

22

Can you tell me what t hat means.

23

THE WITNESS ,

Well , I think,

to a certain

24

extent,

self-monitoring starts with having the time

2S

to self-monitor and not be so caught u p in what


ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778
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45

you're dOing. what you're trying to accomplish.

really too close t o things to see what they really

look like.
So in that regard, we worked on trying to

accomplish less,

realistic goals and thus enable me t o,

of be able to step back once in a while and say maybe

I won't send that e-mail , maybe I'll wait until

morning and read that again.

10

trying to do less, set more


y ou kn o w,

You kno w ,

kind

things of

that sort.

MR.

11

CHRISTIANSEN:

The e-mails,

in

12

hindsight, do you have any doubt that they were

13

inappropriate?
THE

~olI:'NE SS;

15

16

inappropriate.

say.

cringe when I

MR.

17

18

fiasco?

19

right?

No,

n ot at all.

r ead them.

CHRISTIANSE N :

:;: mean,

like

So I know they are

Ho w about the movie

You kno w you ' re supposed to pay for movies ;

20

THE WITNESS:

21

MR.

22

THE WIT NESS ,

23

MR.

24

ultimately dismissed?

25

THE WITNESS :

Abs olutely .

CHRISTIANSEN:

And not run from people?

Yeah.

CHRISTIANSEN:

And that case was

That's right.

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46

MR. CHRISTI ANSE N,

No charges?

No

convict.io ns?
That's correct.

THE WI TNESS:

MR. CHRI STI AN SE N,

The Stratos paper -- you

read the brief that I submitte d,

Amy Jones?

and -- is it

Yes .

THE WITNE SS ,

MR. CHRISTI AN SE N,

And Amy Jones signed an

affidavit saying that she saw y ou turn the paper in.

10

I ' ve submitted a co py of a draft of the paper to the

11

Bar committee,

12

correct?

and y o u've turned in the paper;

13

THE WI TNESS ,

14

MR. CHRISTI AN SEN :

Yes .

An d t h ere was an

15

investigation into Professor Stratos giving you a

16

grade suffici ent to gra dua te?

17

THE WITNESS:

18

MR . CHRISTIANSE N :

That ' s correct.


Similarly , any of the

19

investigations or incide n ts at the la w school.

20

of

21

dishonesty or dishonesty of any sort;

22

correct?

them resulted in a ny finding of academic

23

THE WI TNESS ,

24

MR . CHRISTIANSEN :

25

none

is that

That ' s correct.

You were asse ssed one

time a hundred dollars for moving a computer you

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47
1

used,

and that hundred dollars was the money that the

staff

incurred in putting it back; right?


That ' S correct.

THE WITNESS,

MR. CHRIST IANSE N:

And part of what I

submitted is stuff that the school -- the Boyd School

of

apology letters you wr ote to the of fen ded parties

Professor Stratos bei ng o ne of t hem ; correct?

Law didn't submit, which was one of a number o f

THE WIT NESS:

T h at ' s co rr ect.

MR. CHRISTI AN SE N ,

10

Di d y o u wr i te the

11

letter -- so the Bar knows I attemp t e d to get

12

Mr.

13

e xtend ed vacation.

Stratos to be h ere.

14

He ' s i n Euro p e on an

Did you write the letter before you got the

l~

passing grade or after to say thank you for giving me

16

the pasSlng grade?

THE WIT NESS :

17

18

before I got the grade i n the class .

MR. CHRISTI ANSEN,

19

20

I wrote it se v eral months

So you had at least some

ability to see what you had done was u n professional?

21

THE WIT NESS :

22

MR. CHRISTI AN SE N:

Sure .
And all of t h is stuff,

23

Zack,

:4

Ms. Eichman and sending her e-mails?

2S

that happened , were you timely rep orti ng it to

THE WITNESS ;

Yes .

I think I wac.

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48

MR. CHR I STIANSE N,

hide the misdemeanor charge?

THE WIT NESS,

MR. CHRISTI AN SE N,

Did y ou make an effort to

No,

not at all.

And they were ultimately

dismissed?

THE WITNESS:

Within a wee k of the charge .

academic investigation being conducted on me.

the incidents at the la w schoo l,

10

notified Ms . Eichman of that as well as having an


Any of

I notified the Bar

of.

MR. CHRISTI AN SE N,

11

An d those are -- I've

12

attached eight or nine exhibits to this brief.

13

those part of these exhibits?

'.

THE WITNESS:

That's correct.

Were

And in

1~

addition,

16

It ' s some what of a confusing incident. and I had done

17

so mething wr ong, and I don ' t

18

movie theater people were entirely sure what I had

19

done wr o ng.

20

r had snuck into the movie theater.

21

Bar that,

22

I was pretty forthright with t h is arrest.

think the police or the

And I was fo rthri g h t

a nd told them that


And I told the

too.

MR. CHRISTIANSEN:

I read in y our

23

trans cri pt

24

little bit of concern -- y ou said in here,

25

mistake n identity ," and y o u ' ve e xpla ined that to me.

and I know that I think it raised a


"a case of

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49

wo uld y ou e xplain to them what you mean by

You're not sa y ing

Yo u sneak into the movie .

that .

that was a mistake?


THE WITNESS,

No .

Th a t's correct.

into the movie.

step o ut side and talk to them .

choice and ran ou t of the the ater.

think it was mistaken identit y is they c hased after

me for half a mile,

10

to snea king

y o u kn o w,

to

And I made a poor

and that didn' t

Th e reason I

seem commensurate

into a theater .

And,

11

and then they asked me,

I snuck

subsequently,

learned that they

12

thought I was somebody who had apparently committed

13

some sort of serio us infra c ti o n at the theater.


MR . CHRISTIANSEN,
THE WITNESS;

15

Previ ously?

Previ o usly.

I ' m no t

Within the

16

procee ding months.

sure what the i nfr action

17

was.

18

candy or so mething or maybe something more serious,

19

and they took my ph oto at the incident and sho wed it

20

to the v ictims o f what e ver cr im e had been committed

21

by s o mebod y wh o looked l i ke me , and , c l earl y , it

22

wasn ' t me.

I've heard s o met hing to the effect of tak ing

23

They dismiss e d me bec aus e they didn't

"4

proceed further with any investigation.

2S

regard,

So in that

I think it was a case of mista k e n identity.

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I don't think they would chase somebody o ver half a

mile o n the Las Vegas S tri p for sneaking into a movie

theater.

MR. CHRISTIA NSEN,

o kay ?

THE WI TNESS,

MR. CHRISTIANSEN,

Nor running?

THE WITNESS:

That's absolutely a poor

11

MR. KELLY:

No.

Wh at kind of la w does this firm

practice?
THE WITNES S:

12

13

Not at all.

judgme nt o n my part.

10

.;.

Your sneaking In is not

Insurance defense litigation,

primarily.

.,

MR.

KELLY:

THE WITNESS:

15

16

and Chuck Spann.

17

Las Vegas .

Tel! me the name again.


Perry and Spann.

Victor Perry

There's an office in Reno and

18

MR. KELLY :

19

THE WIT NE SS:

How big is t h e firm here?


There ' s about five attorneys

20

here, and I think they have more of a presence in

21

Reno.

22

23

MR. KELLY,

What is the prospect for full

employment should you pass the Bar?

Has that bee n

discussed?
25

THE WITNES S :

well.

1 've told the

firm of my

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1

situation with the Bar.

employed right no w.

An d I think I ' m fully

MR.

CHRISTIANSEN,

MR.

KELLY:

TheY've called me .

I was thinking y ou hadn't taken

the Bar. but he's already passed.


THE WI TNESS,

I'm fairly certain

hope I

get admitted so they can utilize my skills as an

attorney.
MR.

10

KELLY:

What kind of salary are you

making now?

THE WITNESS:

11

You kn o w,

l2

I've only wor ked th ere t wo we eks,

13

first pay day.

MR.

14

15

to night?

and today is the

How about going to a movie

Min o rity Re por t?


THE WITNES S :

16
17

KELLY,

I'm not really sure.

Yeah.

That looks like a good

movie.

18

MR.

KELLY:

Yo u kn o w, my concern is wh en I

19

read this last time

20

must have be e n filling in as the prose cuto r

21

was certainly bu sting your chops pretty heavy, a nd

22

t hat wasn't my intenti o n.

23

I read the transcript.

and I

because I

But there was a question that I asked at the

24

last h ear ing - - something about wh at does this

25

suggest?

Wh at ' s going o n?

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778


2300 West Sa hara Av enue, Suite 77 0 , Las Vegas, Nevada 89102

52

Now,

Rob Hunter may have ans we r ed it --

adjustment reaction .
My conce rn then and my c ertain today is t h at

3
4

the co p ing skills that you may have f o rmu l at ed with

Dr . Hunter will be used and not just some smoke

screen f or this hearing, y ou kn o w,

Yo u kn ow, ther e 's n o d ou bt that y o u can d o

7
8

whatever it ta ke s .

record,

10
11

today .

Yo ur hi s t o ry, your academic

your a c hievements,

you've excelled at

everything you've done.


But every single one o f us reach es a point

12

wher e we have to look and say, what the heck is going

13

o n a n d t hen t o lea rn from that and ke ep going .

14

can d o that.

15

It seems like you h a v e e veryth in g going.

16

mean,

You

there 's no quest ion in my mind.

jus t want to be sure.

just want yo u to

17

tell me what's the greatest lessen y ou 'v e learned

18

from Rob Hun ter ' s visi on -- and Pete's.

19

going to do differently in the future that y ou didn't

20

do in t h e past?

21

for help."

22

And I h o pe you' re g oi ng to say,

THE WITNESS:

23

wou ld ask for help .

24

through this again.

25

MR.

What ar e you

KELLY:

Sure.

Yes .

Certainly .

"Ask

I ce rtainly d o n ' t want to go

You ' re not afraid to -- you

ASSOCI ATED REPORTERS OF NEVA DA - 702/382 -8778


Las Vegas , Ne v a da 89102

2300 West Sahara Av enue , Suite 770,

53

wouldn't be afraid to pick up the phone?

help.

MR. CHRISTIANSEN,

Have you

How about me?

called me?
THE WITNESS,

And I have asked for

You k no w, my parents have helped me a lot.

No.

THE HITNESS:

you

I' v e certainly called

Yes .

asked for yo ur cou nse l.

MR . CHRISTIANSEN,

Dr . Hunter ?

THE WITNESS:

Yes,

have.

And I've really

10

utilized wh at we talk about in our meetings .

11

been a very good i n fluence.


MR . KELLY,

12

Do you have -- who is your best

13

friend in the practice of la w?

14

may not yet.


THE WITNESS:

15

He ' s

Do you have one?

You kno w,

unfortunately ,

You

the

16

way I went through la w school didn't enable me to

17

work at a firm to develop some contacts,

18

have been beneficial.

So I certainly like and respect the peo ple

19

20

in my firm that I work with.

21

a ware of my situation.

22

keeping an eye me,

23
24
25

which wo uld

You kno w,

they're fully

So I think they ' re probably

y ou kno w .

MR. CHAIR MAN,

Who is the supervising

attorney?
THE WIT NESS ;

gues~

it would be

ASSOCIATED REPORTERS OF NEVADA - 702/382 - 8778


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54

Alan Westbrook.
MR.

THE WITNESS,

He called me.

CHRISTIANSE N:

An d I think Vic Perry is

So I thin k , unofficially , they ' re both kind

there .

And I've developed contacts

of keeping an e y e on me .

Some attorne y s that -- Carl LeBare

in Reno n o w.
7

(pho neti c) is someone sort of wh o I can call, you

kno w,

up in Reno .

whose counsel I can request.

10

MR. CHAIRMAN:

11

THE

12

MR . CHAIRMAN:

WIT NESS :

He's an attorney

I kn o w Carl well .
Okay.
You said t h at the firm -- o r

13

member s of the firm are knowledgeable of your current

14

status with the committee and with the Bar?

16

Yes.

THE WITNESS:

15

That's right.

That's

correct.
MR. CHRISTI AN SE N:

17

ca n tell the committee

18

that Mr . Westbroo k called me two weeks ago and asked

19

me what e x actly wha t was going on i n the

20

investigation .

21

him wa s e xactly wha t

22

hasn't bee n sugarcoating anything for him.

He told me what information


Zac k had told him.

23

MR. CH AIRMAN ,

24

MR.

25

BROWN:

gave

So Zack

Do you hav e any questions?

I already asked what I was going

to ask.
AS SOCI ATED REPORTERS OF NEVA DA - 702/382-8778
Suite 770, Las Vega s , Nevada 89102

2300 West Sahara Avenue,

ss
MR.

CH AIRMAN,

and I

Zack,

counsel,

and I'm n ot trying to scratch the scab off an old

<1

woun .

apologize ,

1'm interrupting

but I want to ask you to

Dr. Hunter told us that you described your

~ontact

I woul d use that term myse l f.

as I

concern for us without regard to wh ether you were

10

on March 1st as appalling.

said then,

I d on 't kno w that

I would certainly say,

that this caused a great deal of

applying for the Bar or not.

11

We , as I mentioned to your dad,

are charged

12

not onl y with the obligation to advise and recommend

13

to the Supreme Cou rt

14

such as the movie th eate r

's

incide nt, but we also hav e to comment on recommending

on moral characteristic issues,


incident or library

whether the person is fit to practice law .


17

If y o u can -- and I kn o w this may be

18

impossible for you to do -- how do you perceive your

19

melt do wn,

20

Ho w do you perceive t hat?

as Dr . Hunter said, on Ma rch 1st today?

THE WITNESS:

21

Well,

I just see it as

22

something that doesn't necessarily reflect my ability

23

to represent clients.

"4

to represent myself in front of this committee.

25

you know,

I think it reflects my ability


But,

there ' s a longstanding saying that the

ASSOC IATED REPORTERS OF NEVADA - 702 /382-8778


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56

la wyer who represents h imself is a fool or something

of that regard.

MR . CHA IRMAN:

an idiot for a la wyer.


THE WI T NESS;

You kno w,

Something like that.

Yeah.

I mea n - -

MR . CHAIRMAN:

T HE WI TNESS,

Has a fool f or a client and

Maybe.
-- that was just a cra z y week.

I went down there , y ou kno w,

10

there,

11

of

12

in flea-bag mote l

13

California Bar,

14

year -- i t was a really brutal test

15

back that night . and then come here in the morning .

16

17

it died,

I drove my ca r down

I had to get it towed in the middle

the night and rent a car and then stay,

MR.

you

know,

for three days and take the

wh ich had a 33 percent pa ss rate that


and then drive

Did you come back

CHRISTIA NSEN:

physically the night before you came ba c k her e?

18

THE WIT NE SS :

19

MR . KELLY:

Yeah.
Was it the night before?

20

thought you drove up that day.

21

THE WITNESS:

No.

I drove ba ck that night

22

and got in arou nd midnight and came in the next day.

23

So I know it looks li k e --

24

meeting cause d y ou co n cern in terms of if

25

able to represent clients e ff ectively .

I kno w my reaction in that


I would be

And I don'c

ASSOCI ATED REP OR TERS OF NEVADA - 702/382-8778


2300 West Sa hara Av enue, Suite 770, Las Vegas , Nevada 89102

57

have an y d o ubt that I will be able co.

MS.

STOR Y:

THE WITNESS ,

MS . STORY,

THE WITNESS ,

Did it cause y ou concern,


Certainly.

Cer tainly.

Zack?
it did.

Wou ld you d o it differently?


Yes , I

wou ld.

wasn't

chinking really c learly.

I was very he sitant -- I

didn't have any money,

have enough to pay the 5500 fe e for the hearing.

didn't realize I might be able to get a continuance

10

of the hearing or del ay it until sometime after che

11

California Bar until

12

something of that sor t.

for one thing .

I didn't even
I

was able to get an att or ney or

13

So.

14

differently.

15

lot easier by getting you a prehearing brief wi th all

16

t he apologies and th ings o f that sort.

17

yeah.

18

certainly,
I

mean,

MR . CHAIRMAN '

I would have done it

I co uld hav e made your job a

And.

so,

My a s s es sme nt of y ou on

19

March 1st -- the ap ologies hadn't occurred yet,

20

I d o n't think yo u would have d o n e that on Ma rch 1st.

21
22
23

THE WITNESS:

Zack.

The apologies hadn ' t occurred

to me in the sense that I -MR. CH AIR I1AN:

For wha tever reason .

And you

24

des cribe d it and y our dad has describ e d it and yo ur

25

cou ns el has described it and everybody has said you


ASSOC IATED REPORTERS OF NEVA DA - 702/382-8778
2300 West Sahara Av e nue. Suite 770, Las Vegas. Ne vada 89102

58

were pretty oc cupied with a l ot of stre ss factors,

and I don 't kno w that y o u would have been able to d o

that or that it wo uld have occurred to y ou to d o that

on March 1st.
As I said then and I ' m sa ying now, we are

co ncern e d with what woul d your reacti o n - - o r how

woul d you feel i f we were to d ecide that we wanted

y ou to continue with the counseling and receive the

help that you've obviousl y already gotten to impress

10

a guy li ke Dr . Hun ter and make that something that

11

we'd wan t you to do fo r a while longer jus t

12

sure th at instead of a broken do wn car,

13

federal judge asking y ou about g et ting a motion filed

14

in a shortened time ; and instead of the Californi a

15

Bar, y o u got the Supreme Cou rt; and instead of t he

16

$500 due, you got t o get some type of investiga tion

17

completed so that you ca n get a n affidavit filed in a

18

case where you ' re in the fourth or fifth day of

19

trial.

to be

y ou got a

20

21

one of us .

22

you practice law .

23

days when I 've l ooked back o n some of the setbacks in

24

my life and said ,

25

mea n,

And

this stuff happens t o each and e v ery

This happens every day of every week that

An d I guarantee you , there are

"Man, that was an easy tim e . "

want

you

to understand ,

we

hdvt:

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778


2300 I'Jest Sa hara Avenue , Suite 770 , La s Vegas, Neva da 89102

59

concern about that. we are required to investigate

that, and we're required to recommend ab out that.


Accordingly,

I'd like your reaction t o us

I'm kind o f making a deal, perhaps,

if the res t o f

the committee were to go along with this -- that y ou

would continue with this co un seling and pro vid e some

reports from Dr. Hunter or whomever you choose that's

q~alified

you continue with the progress that y ou 'v e started in

to provide the counseling to ensure that

10

the three and a half months that you've started.

11

What's your reaction to that?

12

THE WITNESS:

13
4

I'd say , y o u know,

Well,

I'm amenab le t o that.

I think that ' s fine.

any problem with that.

I don't hav e

I f ir mly believ e I'm fit t o


I think so me of my

J5

prac tice law as I am right no w .

16

emotional reaction today has more to do with,

17

kn o w,

18

lot of things about, you kno w, high school basketball

19

o r whatever is just a trip do wn memory lane a bit .

yo u

it ' s just going through a lot of -- hearing a

20

And I think an un co nditi onal admittan c e

21

would be preferred, but I don ' t have any problem with

22

the co nditi onal admittance because I kn o w I'll

23

com ply.

~4

able to afford Dr. Hunter.

25

Certainl y,

I ' ve enjoyed Dr . Hun ter .

MR. CH AIRMAN:

I'll be

Let me assure y ou something.

ASSO CIATED REPORTERS OF NEVADA - 702/382-8778


2300 West Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

60

Wh atever happens is somet h ing that wou ld happe n

bet ween us and the committee .

sticker that is put at the lower right-hand corner of

your license,

any such agreeme nt if one is reached.

There is no red

and no one is certa inly made a war e of

Your license. assuming they print it the

same way they did a long time ag o , would be the same

as mine.

assuming that that ' s where we ' re going with this.

This wo uld be a confide ntial thing.

MR.

10

Let me just add somet hing.

KELLY,

- - particularly.

11

feel as if,

when a

since I practice

12

i n Vegas --

that somehow after a hearing like this.

13

when an appl icant sees me,

]4

can assure you tha

]5

in this room,

16

outside this room and say something to you about

17

these hearings.

they run away fr om me.

what happens in this r o om stays

that I would never ever meet you

That ' s never going to happen.

So what the c hair is saying,

18

I echo it

19

because I might run into you do wn here in Vegas.

20

fear not.

21
22
23
24
25

THE WITNE SS :
would happen at all,
MR.

So

I really didn't think that


you kno w .

CHAIRMAN:

interrupted y ou .

I'm

sorry, Cou n sel.


MR.

CHRISTIANSEN,

That's all right.

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


2300 West Sa hara Avenu e, Suite 770, Las Vegas, Nevada 89102

61

I probably distracted you

MR. CHAIRMAN:

from where you we re going.

anything further.
MR.

long .

back.

KELLY,

But you're wel come to ask

He can ' t hold a thought very

So it may take him a wh ile to get his thought

MR.

CHRISTIANSEN,

This is all true.

have

found doing these at the times I ' ve been before the

committee is that it is best and in the client's

10

interest to let yo u folks ask the questions.


When I read the transc ript,

11

12

Kevin did

13

because he sa w that you needed to stop and get a

14

lawyer so he just beat you up until it happened.

15

I commend him for d oing that.

~t

on purpose.

I told Za ck that

Kevin was just mean to y ou

And

And I think you had a young man before you

16

17

that was emotional ly distraught.

18

as tight as a drum.

19

he's made mar k ed improvement since then.

20

He was just wound

And I think he's made

I know

I' v e seen him -- origi nal ly , he came to me

21

on a pro bono basis.

22

because somebod y on this committee thought I could

23

help him.

24

initial point,

2S

to me and more from talking to Dr . Hunter.

I was just going to do it

And however crazy that thought is on its


I think he has benefited from talking

ASSOCIATED REPOR TER S OF NEVADA - 702/382-8778


2300 West Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

62

He is somebody that on day one I could make

cry with a sente nce.

And I prepped h im for this

thing yesterday, and he ' S a different kid,

man, different lawyer.


I think -- not that wha t

different

I think carries

he will , if ordered to continue o n

much weight -- bu t

with Dr. Hunter, do that.

here,

uncond it ional admission to practice la w .

I have cited t he la w

~n

and legally I believe he's entitled to an


He's not

10

going to fight a conditional admission.

11

candidly,

12

see a do wnside, so I'm not going to stomp my feet and

13

say don't do

14

MR.

KELLY:

15

MR.

CHRISTIAN SE N:

if y ou tell him

Hunter,

don't

it.

I told you he wo uld

16

more of your time either.

17

wind ed.

18

agreement pending the end

ake the

I ' m not going to take any


I ' ll try not to be long

If that is something that is a tentative

MR. CHAIR MAN:

19

to see Dr.

And .

I need to clarify mys elf ,

20

Counsel.

21

have no t discussed with my fellow members at all

22

about the disp osit ion of this matter.

23

Those are my thoughts o n the matter.

I think we all agree as to wh at happened on

24

March 1, but we need to deliberate a little bit

25

further about this .


ASSOCIATED REPORTERS OF NEVADA - 702/382-8778
2300 West Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

63

MR.

CHRISTI ANSEN,

I'm happy to -- if any

member of this committee ha s areas o f concern that

your vote is g oi ng to b e t o not let the young man

practice law,

able to address them.

the n I ' d like to h e ar the issues and be

A co nditi o n al admission,

he 11 live with and


I

But if so meb ody

pro bably, can didly,

sitting is h e re v oting thumbs do wn.

why -- o r maybe n ot voting -- but inclined -- and I'd

10

benefit from.

I'd like t o hear

like to address it.


I tried to addres s the a re as that I saw i n

11

12

the transc ript

13

tried to address them with the witness here tod ay.

MR.

14

in my brief.

KELLY,

and 1,

you

kno w ,

That ' s a go o d p i t ch.

15

make that t o the Supreme Court -- y ou kn o w ,

]6

here I'd like t o be able to persuade y o u.

f'.m. CHA I RMAN :

17

18

Apr11,

Remember ,

MR.

KELLY;

20

MR.

CHRISTIANSE N;

21

MR.

CHAIRMAN,

anybody

I tri ed that in

I thi nk y ou ' re covered.


Thank y o u.

Do you have any o ther

d oc umen ts that y ou wis h to have admitted?

23

MS . STORY ,

24

MR.

25

Can you

and y o u kno w wh at they told me .

19

22

have

We need the tra nscr i pt.

CHRIST IANSEN,

I promise.

He ' s g o ing to

get a ce rtified copy as qui c k as the s c h oo l c an turn

ASSOC IATED REPORTERS OF NEVA DA - 702 / 382-8 778


2300 West Sa hara Av e nue . Suite 770. Las Vegas. Nev ad a 89102

64

it around.

MR. KELLY:

Let him get his paycheck.

MS.

Yeah.

MR. CHRISTIANSEN:

I think he' s

go~ng

on

Monda y.
Let's make a p oi nt of having

MR. CHAIRMAN,

I think they charge for

that.

STORY,

it a we ek

from today.
MR. CHRISTIANSEN:

At this point,

MR. CHAIRMAN:

10

Yes.

11

will be close d,

12

in wr iting pretty quickly.

the record

and my recommendations will come out

13
14

( Exhibits 4 ,

5.

and 6 were marked for

15

identification and are at tached hereto.)

16

17

(The State Bar Hear ing concluded at

18

10:43 a .m. l

19

---000---

20

21
22
23

24
25

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778


2300 West

Sah ara Avenu e ,

Suite

770,

Las Vegas.

Nevada

89102

65

1
2

REPORTHR ' S CERTIFICATE


STATE OF NEVADA
55 .

COU NTY OF CL ARK


I , Linda Horto n Sprague,

a du l y

commissione d No tary Public, Cl ark County, State of

Nevada ,

do hereby ce rtify:

That I re p orted the State Bar Hea ring

commenci ng on F riday, June 21,

2002 , at 9 :11 a .m.;

That I t hereafte r transcribed my said

10

shortha nd n ot es into typewriting,

11

typewritten t ran scrip t of sa id State Bar Hearin g is a

12

complete,

13

shorthand n ote s.

14

true,

and that t he

a nd accurate transcripti o n of said

1 further ce rtify that

am not a

15

relative or employee of an atto rn ey or cou nsel of any

16

of th e parties,

17

attorne y or co unsel invo lved in said a ctio n,

18

person fi nan ci ally interested in the action.

19

no r a relative or employee of a ny

I N WITNESS WHEREOF,

I hav e hereunto set

20

my hand in my off i ce in the Cou nty or Clar k,

21

Nevada,

t hi s 16th day of Jul y,

nor a

State of

2002.

22
23
24

'-f \

'""

\,

,
~ ,;.-

, ..

.'

..,

,.1'
-, .

Linda Ho rt o n "Sprague, CC R No.

/' I

4 66

. 0

25

ASSOCI ATED REP ORTERS OF NEVADA - 702/382-8778


2300 West Sa hara Av e nue, Suite 770, Las Vegas, Nev ada 89102

......lbon of State Bar Hearing


Re: Zachary B_ Coughlin

WORDINDE)t

<6>
6 4:20,23 64:14

600 1:19

39:15,1640:2424
541:5,6
' ,
<7>
04 34:6
7 39:15,1641:5

<1>
1 62:24
10 34:6 40:24,24 41:6
64:18
11 1:1840:2465:8
12 7:6
1200 42:19
15 40:12
16th 65:21
17 32:10
1st 3:6 4:22 5:17 15

<8>
8 39:16 42:19

:12,13 21:4 35:2245

8:17

:20 50:8

afford 59:24
afraid 52:25 53: 1
agent 13:23

< A>
a.m 1:18 34:6,6 64:1

8 65:8
ability 12:15 13:9 4
7:20 55:22,23
able 33:1837:2445:

56:2557:1,9,11 58:2
59:24 63:5,16

academic 46:20 48:8

52:8

<3>
3 39:24
30 40:24,25

accept 37:22
acceptable 8: 7
accepted 37:20 38:1

30th 4.7
33 56:13

accepting 39: 7 43:2

4:5 10:5 40:12,25,2


5 64:14
57:8 58'16
2:8
34:6

anybody 26: 1 31 :2,8


42:2363:15

absolute 25:11
Absolutely 13: 11 17

<9>
9 1:1834:6 65:8

:1 16:24 23:8 28:21

<4>
3:23 64:14
64:18
39:16
1.25 65:24

additional 26: 7
address 6:9 43:3 63
:5,10,11,13
addressed 17:13
addressing 44:11
adjourned 30: 13

answered 16:14 52:1


answers 10:22 32: 7
anticipate 3: 11
antisocial 11 :3

apologies 6: 1 57: 16,


adjustment 11: 7 16: 1 9,21
720:1731:21 52:2
apologize 8:2 55:2
admission 18: 19, 19
apology 29:22 47:7
62:9,10 63:6
appalling 20:4 55:6
apparently 20:6 21:2
Admissions 2:11 5:2 027:4,5 29:1249:12
3
appearance 16:23
admit 29: 18,20
APPEARANCES 2: 1
admittance 59:20,22
appears 23:10
admitted 51:7 63:22
applicant 3:5.8 8:6,1
advisable 30:23
7,20 19:360:13
advise 55: 12
applicant's 3: 17 4: 1
advised 5:22 6:5
o
advising 30:16
application 7:23
affect 11:9
applied 7:20
affidavit 5:20 46:9 5 applying 55: 10

33:10,2555:6,1957:1
9,20 58:4

<2>
42:18
1:17 3:6 4:7 2
3:8 65:8,21
21 1:17 10:5 65:8

addition 7:1644:12

48:15

2
4
accomplish 45: 1,5
accurate 4:18 20:17

22:2 31 :22 65:12


accuse 27:9
achievements 52:9
acknowledges 8: 16
act 20:2
action 65:17,18
actions 37: 1
actual 35:2
add 60:10
added 42:21

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Page 2

ASStKlatcd Rcponcrs of Nevada

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Rc: Znchary 8. Coughlin

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Page 3

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Stale Bar Hearing


Rc: Zachary B. Coughlin

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Page 5

Bar Hearing

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