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12/3/2012

Zachary Barker Coughlin


1471 E. 9th St.
949
67 7402
6
949 667 7402 tel and fax is the same
rmc judge william gardner
Reno Municipal Court
11 CR 26405
x
I recently appealed the denial on 11/14/12 of a Motion for
For New Trial filed a
in late October 2012
will supplement later, but
and 7/5/12 bail hearing in
12 cr 12420 and transfer
in 12 cr 00696
ng12-0204, ng12-0435, ng12-0434 (SBN v. Coughlin 11/14/12 formal hearing)
arraignment in 11 cr 22176 10/10/11
12/4/12
please see attached materials
please see attached materials
incorporate by reference all of Zach Coughlin's documents and exhibits on file before the
nevada supreme court
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
http://sdrv.ms/TQrulW incorporate all materials found therein as well
http://sdrv.ms/TQrEd6
http://sdrv.ms/RyRc0M
http://www.youtube.com/user/NEVADARADICAL/videos?view=0
http://www.youtube.com/user/NevadaGadfly/videos?view=0
in all these links
x
and incorporate by reference all materials found at all links herein and
therein
failed to file in my 6/28/12 notice of appeal in 11 cr 26405...judge steven elliot
member of CAAW's board, went to Stanford with washoe legal services paul elcano, whom
i sued along with CAAW, Elcano and WLS in cv11-01955 no 60317 and associated ith 60301
and elliot presided over, did not disclose and was "randomly" assigned my cases in
d
cr11-2064 (resulted in suspension of my law license) cr12-1262 and cr12-0376 (8 days in jail and
medical records privacy rights raped, 40K attorney fee award against me in cv11-03628
richard g. hill, esq. interspersed throughout...
oh, and see n s ct case 54844 judge w. gardner's sister I sued Mandamus he passed her order
cited as sole cause for firing me by WLS to RMC Judge Nash Holmes...ghost grievance
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme) with
local judges lately, ask rjc sferrazza and clifton in rcr2011-063341 and rcr2012-065630
12/5/12
zach coughlin
1471 e. 9th st
949 667 7402
dorothy nash holmes and kenneth howard
rmc
reno muni court
11 tr 26800 and 11 cr 22176 and 11 cr 00696
i can't tell anymore
x
every last one of them
12/5/12
6/28/12 notice of appeal in 11 cr 26405...judge steven elliot
member of CAAW's board, went to Stanford with washoe legal services paul elcano, whom
i sued along with CAAW, Elcano and WLS in cv11-01955 no 60317 and associated ith 60301
and elliot presided over, did not disclose and was "randomly" assigned my cases in
d
cr11-2064 (resulted in suspension of my law license) cr12-1262 and cr12-0376 (8 days in jail and
medical records privacy rights raped, 40K attorney fee award against me in cv11-03628
richard g. hill, esq. interspersed throughout...
oh, and see n s ct case 54844 judge w. gardner's sister I sued Mandamus he passed her order
cited as sole cause for firing me by WLS to RMC Judge Nash Holmes...ghost grievance
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme)
with
local judges lately, ask rjc sferrazza and clifton in rcr2011
please see attached materials
please see attached materials
incorporate by reference all of Zach Coughlin's documents and exhibits on file before the
nevada supreme court
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
http://sdrv.ms/TQrulW incorporate all materials found therein as well
http://sdrv.ms/TQrEd6
http://sdrv.ms/RyRc0M
http://www.youtube.com/user/NEVADARADICAL/videos?view=0
http://www.youtube.com/user/NevadaGadfly/videos?view=0
in all these links
x
and incorporate by reference all materials found at all links herein and
therein
12/4/12
Zachary Barker Coughlin
1471 E. 9th St., Reno, NV 89512
my telephone and fax is 949 667 7402
STeven Elliot
Second Judicial District Court for Washoe County
cr12-0376, cr12-1262, cr11-2064
x
cr12-0376 resulted in unlawful 8 day incarceration and coercion of waiver of HIPAA rights
cr11-2064 and cr12-1262 were fraudulently
denied
x
most of them, I will supplement this later but he is or was on CAAW's Board while presiding over
cv11-01955, wherein I was suing CAAW, and he has "randomly" managed to sink his hooks into three
criminal matters involving me this year, wherein ordeal with
Chief Appeals Clerk Lori Matheus has been especially curious. appearance of impropriety
incarcerated me for lies by Lakes Crossing that
were not in an affidavit as required by NRS 22.030...DDA Young violated NRS 178.405 stay
12/4/12
see attached and I will supplement this soon
see attached and I will supplement this soon
xxx
xx
cv11-10955 was appealed in 60317...I tried appealing cr11-2064 but apparently that, like Hiibel
will require a Mandamus Petition. Now, my appeal of the denial of my motion for new trial
is being retained as an extension of my initial appeal of rmc 11 cr 26405, in cr12-1262, though I
do not feel Judge Elliot should ever touch another one of my case, ever.
12/5/12
zach coughlin
1471 e. 9th st
tel and fax 949 667 7402
judge peter j. sferrazza
reno justice court
rev2011-001708 and rcr2011-063341
not sure where either case is exactly
x
12/5/12
6/28/12 notice of appeal in 11 cr 26405...judge steven elliot
member of CAAW's board, went to Stanford with washoe legal services paul elcano, whom
i sued along with CAAW, Elcano and WLS in cv11-01955 no 60317 and associated ith 60301
and elliot presided over, did not disclose and was "randomly" assigned my cases in
d
cr11-2064 (resulted in suspension of my law license) cr12-1262 and cr12-0376 (8 days in jail and
medical records privacy rights raped, 40K attorney fee award against me in cv11-03628
richard g. hill, esq. interspersed throughout...
oh, and see n s ct case 54844 judge w. gardner's sister I sued Mandamus he passed her order
cited as sole cause for firing me by WLS to RMC Judge Nash Holmes...ghost grievance
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme)
with
local judges lately, ask rjc sferrazza and clifton in rcr2011
please see attached materials
please see attached materials
incorporate by reference all of Zach Coughlin's documents and exhibits on file before the
nevada supreme court
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
http://sdrv.ms/TQrulW incorporate all materials found therein as well
http://sdrv.ms/TQrEd6
http://sdrv.ms/RyRc0M
http://www.youtube.com/user/NEVADARADICAL/videos?view=0
http://www.youtube.com/user/NevadaGadfly/videos?view=0
in all these links
x
and incorporate by reference all materials found at all links herein and
therein
didn't file in notice of appeal submitted 12/26/12 as to ORder "Resolving" contest proprty lient
hearing on 12/20/12 (its fraudulent to say I "agreed" to the "orderd" plus didn't give me a hearing
for 6 weeks though NRS 40.253 calls for one within 10 day sof 11/17/12...called jonas and stancil
coerced me out of fifth amenments rights at trial in rcr2011-063341 and ltos else.
i am not sure
x
x
12/5/12
Zach Coughlin
1471 E. 9th St. Reno NV 89512
tel and fax is 949 667 7402
I prefer email to ZachCoughlin@hotmail.com
x
its not entirely clear to me
reno justice court
Judge David Clifton
rcr2012-065630
x
this is mostly done out of an abundance of caution because I sense Judge Clifton being taken over by
per pressure from his fellow Judges and we need good Judges like Judge Clifton and I think its not too
late for him to use his talents for helping the forces of good, and not
evil, but he may need to help in getting there. pat flanagan hit me we a $42K atty fee award in
cv11-03628 where I was a pro se tenant appealing a summary eviction...motion filed while judge elliot
had me
locked up and deprived of medications...then the order came down shortly after the rpd and
judge gardner had me locked up on a phony charge and he raised the bail 10 times high over
nuthin'
12/5/12
Judge Clifton was shaking with anger and venom when he forced me to admit I had filed grievances
against DDA Zach "Norman Nifong" Young, Esq. for his rampant prosecutorial misconduct, saying "well,
that say's a LOT about YOU as a person" and other disparaging and threatening remarks...1983 McGeorge
Gammick 1982 McGeorge, suspended from practice of law 4 hours after emailing Gammick only time ever
on June 6, 2012...regarding alleged victim battering me with a lit cigarette....McGeorge Mafia:

6/28/12 notice of appeal in 11 cr 26405...judge steven elliot
member of CAAW's board, went to Stanford with washoe legal services paul elcano, whom
i sued along with CAAW, Elcano and WLS in cv11-01955 no 60317 and associated ith 60301
and elliot presided over, did not disclose and was "randomly" assigned my cases in
d
cr11-2064 (resulted in suspension of my law license) cr12-1262 and cr12-0376 (8 days in jail and
medical records privacy rights raped, 40K attorney fee award against me in cv11-03628
richard g. hill, esq. interspersed throughout...
oh, and see n s ct case 54844 judge w. gardner's sister I sued Mandamus he passed her order
cited as sole cause for firing me by WLS to RMC Judge Nash Holmes...ghost grievance
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme)
with
local judges lately, ask rjc sferrazza and clifton in rcr2011
please see attached materials
please see attached materials
incorporate by reference all of Zach Coughlin's documents and exhibits on file before the
nevada supreme court
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
http://sdrv.ms/TQrulW incorporate all materials found therein as well
http://sdrv.ms/TQrEd6
http://sdrv.ms/RyRc0M
http://www.youtube.com/user/NEVADARADICAL/videos?view=0
http://www.youtube.com/user/NevadaGadfly/videos?view=0
in all these links
x
and incorporate by reference all materials found at all links herein and
therein
judge clifton summarily took away my fax filing rights poor little dda young couldn't take it
and I had barely even been inserted as counsel yet when he did that, plus he tried to depose wcpd
dogan to get some rhythmn on denying me a continuance.
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jor the discipline le.
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Counsel is not responsible jor cn coincidence in the ncmes oj disciplined cttornes cnd oj members in ood stcndin cs c result oj
inditiducls hctin identiccl ncmes.
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Member Login
Page 1 oI 2 State Bar OI Nevada
http://www.nvbar.org/lawyer-detail/127 http://www.nvbar.org/lawyer-detail/127
this guy went to Stanford around 1966 with Washoe Legal Services Paul Elcano, whom he
admits to being "boyhood chums" with (what about the wine business, guys?) and Judge
STeven Elliot, who has "randomly" been assigned three criminal appeals of Coughlin's
since Coughlin upset the brother and sister Judge tandem of Linda and William Garnder
by filing a Petition for Writ of Mandamus in 54844 after her sanctions against him
were cited by Elcano as the
sole reason he fired
Coughlin....then in CV11-01955 Coughlin sued WLS and CAAW and Judge Elliot did
disclose that he was on
CAAW's Board or that he
worked at Echeverria and
Osborne, and now Echeverria is the Panel Chair for Coughlin formal Discipline
hearing and Elcano is added as a witness just a couple days before the hearing along with
most of the other people who graduated from McGeorge School of law between 1977-1982
please add JOhn Echeverria is he is subject to Judicial Discipline
Commission Jurisdiction in his role as Panel Chair.
Tom Susich and Pat King really did a "shake and
bake" on the formal disciplinary hearing Panel
selection for the 11/14/12 hearing in sbn v
coughlin
RE: Missing property
From: Campbell, Debra (DCampbell@washoecounty.us)
Sent: Tue 3/13/12 10:49 AM
To: zachcoughlin@hotmail.com
No, a micro sd card is not listed on the evidence envelope.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 10:29 AM
To: Campbell, Debra
Subject: RE: Missing property
Did these items that were placed into evidence include a micro sd card?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
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1 of 17 3/29/2012 2:18 PM
Subject: Missing property
Date: Tue, 13 Mar 2012 10:14:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
Mr. Coughlin:
Your email regarding your missing secure property was forwarded to me for response. I apologize for the delay
in responding to you but it took me a little while to figure out the issue.
Your two cell phones and electric razor were put into evidence at the request of Judge Nash-Holmes on
February 28, 2012. In order for us to release them to you, we will need an order from Judge Nash-Holmes that
the evidence can be released to you.
To make this matter smoother for you all documentation should reflect Washoe County Sheriffs Office case
number 12-1805 and evidence number C-47591. The court case number corresponding to this issue is
11TR26800.
If you have any questions all of my contact information is listed below.
Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
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FW: missing property from my secured property
From: Cummings, Tami (TCummings@washoecounty.us)
Sent: Mon 3/05/12 8:43 AM
To: zachcoughlin@hotmail.com
Cc: Sheriff - Bkg_CC Supervisors (SO-BKG-CC-SUPV@washoecounty.us)
Dear Mr. Coughlin:

Thank you for your email. We are forwarding your email to our Detenon Booking Supervisors for their
review and response. Should you need to contact them by phone, you can call Detenon Administraon at
328-2971.

Regards,

Community Relations| Washoe County Sheriff's Office
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Friday, March 02, 2012 9:40 PM
To: SheriffWeb
Subject: missing property from my secured property
Dear Washoe County Sheriff's Office and Jail,
The secured property returned to me today did not include either of my cell
phones or the micro sd card that were listed on my check in sheet. My agent,
Peter Eastman, did come and retrieve my keys and wallet, etc. (to help make
sure my dog would not starve to death, and I am so thankful to you for letting
him do that as animal control would have likely cost much money and I already
had a $300 towing bill for my car upon being release from jail and I am
literally flat broke, and just had to pay my $450 per year bar dues and pay for
twelve credits of continuing legal education and my yearly CLE dues....so it
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3 of 17 3/29/2012 2:18 PM
RE: Missing property
really helped that the Sheriff's Office let Mr. Eastman get my keys to feed my
dog, thank you!).
However, Mr. Eastman indicates to me that he did not receive either cell phone
or the micro sd card upon picking up my secured property.
If possible please reply by fax or email as I, obviously, do not have my phones
and there is a problem right now with my usps mailbox.
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
From: Campbell, Debra (DCampbell@washoecounty.us)
Sent: Tue 3/13/12 1:57 PM
To: zachcoughlin@hotmail.com
Yes, a micro sd card was listed on the inventory at intake and was released with the rest of your property on
2-29-12 to Peter Eastman. I will scan and email you a copy of the intake property form and the release form
signed by Mr. Eastman.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
4 of 17 3/29/2012 2:18 PM
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 11:08 AM
To: Campbell, Debra
Subject: RE: Missing property
Is a micro sd card listed on the property sheet at intake?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: RE: Missing property
Date: Tue, 13 Mar 2012 10:48:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
No, a micro sd card is not listed on the evidence envelope.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
5 of 17 3/29/2012 2:18 PM

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 10:29 AM
To: Campbell, Debra
Subject: RE: Missing property
Did these items that were placed into evidence include a micro sd
card?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: Missing property
Date: Tue, 13 Mar 2012 10:14:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
Mr. Coughlin:
Your email regarding your missing secure property was forwarded to me for response. I apologize for the delay
in responding to you but it took me a little while to figure out the issue.
Your two cell phones and electric razor were put into evidence at the request of Judge Nash-Holmes on
February 28, 2012. In order for us to release them to you, we will need an order from Judge Nash-Holmes that
the evidence can be released to you.
To make this matter smoother for you all documentation should reflect Washoe County Sheriffs Office case
number 12-1805 and evidence number C-47591. The court case number corresponding to this issue is
11TR26800.
If you have any questions all of my contact information is listed below.
Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
6 of 17 3/29/2012 2:18 PM
RE: Missing property
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.
From: Campbell, Debra (DCampbell@washoecounty.us)
Sent: Tue 3/13/12 2:50 PM
To: zachcoughlin@hotmail.com
1 attachment
Coughlin Property Docs 0312.doc (2.6 MB)
The two documents I referred to in my last email are aached.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
7 of 17 3/29/2012 2:18 PM
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 11:08 AM
To: Campbell, Debra
Subject: RE: Missing property
Is a micro sd card listed on the property sheet at intake?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: RE: Missing property
Date: Tue, 13 Mar 2012 10:48:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
No, a micro sd card is not listed on the evidence envelope.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
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8 of 17 3/29/2012 2:18 PM
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 10:29 AM
To: Campbell, Debra
Subject: RE: Missing property
Did these items that were placed into evidence include a micro sd
card?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: Missing property
Date: Tue, 13 Mar 2012 10:14:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
Mr. Coughlin:
Your email regarding your missing secure property was forwarded to me for response. I apologize for the delay
in responding to you but it took me a little while to figure out the issue.
Your two cell phones and electric razor were put into evidence at the request of Judge Nash-Holmes on
February 28, 2012. In order for us to release them to you, we will need an order from Judge Nash-Holmes that
the evidence can be released to you.
To make this matter smoother for you all documentation should reflect Washoe County Sheriffs Office case
number 12-1805 and evidence number C-47591. The court case number corresponding to this issue is
11TR26800.
If you have any questions all of my contact information is listed below.
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9 of 17 3/29/2012 2:18 PM
RE: Missing property
Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.
From: Campbell, Debra (DCampbell@washoecounty.us)
Sent: Wed 3/14/12 6:52 AM
To: zachcoughlin@hotmail.com
I am saying that two cell phones and an electric razor were placed into evidence at the instrucon of Judge
Nash-Holmes and the evidence envelope states that is what is in the envelope. As I do not work in or have
access to the evidence unit, I am relaying what they told me when they checked the envelope.

In response to your prior email, the property record form stated that there was a micro sd card. The
Authorizaon for Release of Property/Money was dated 2-29-12 and signed by Mr. Eastman. The statement
he signed states that he acknowledged that he received the items listed on the property record form. I can
only assume that is the case as he signed the form and you authorized him to pick up the property.

Since I am not an aorney I will send your last two emails to the Assistant District Aorney assigned to the
Sheris Oce for response.
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10 of 17 3/29/2012 2:18 PM

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 9:23 PM
To: Campbell, Debra; Kandaras, Mary
Subject: RE: Missing property
So, are you saying you or your office currently have an "evidence envelope" that contains
these items placed into "evidence" . Do you whether that comprots with previous
assertions made by your office or agents, or, if, in fact, it contradicts representations as to
whom came and took what? If you still have any of this property in your possession,
please consider whether it is legal for you to allow the RMC or the Reno Marshal to come
check it out like a book from the library, or whether you have some liability if, oopsie,
something "disappears". Please ask Deputy Cheung about all of these circumstances
detailed in our correspondences and provide written documentation detailing his
responses. Further, please provide pictures of the evidence envelope and all the "evidence"
within such an envelope, including whether a micro sd card in within such materials or
whether such a card is somehow contained in one of the phones or otherwise instereted
into the same. Additionally, please indicate whether a phone battery or two is present.
Please ask yourself who is running what and whether that is appropriate.
Sincerely,
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11 of 17 3/29/2012 2:18 PM
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: RE: Missing property
Date: Tue, 13 Mar 2012 10:48:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
No, a micro sd card is not listed on the evidence envelope.

Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 13, 2012 10:29 AM
To: Campbell, Debra
Subject: RE: Missing property
Did these items that were placed into evidence include a micro sd
card?
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12 of 17 3/29/2012 2:18 PM
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: Missing property
Date: Tue, 13 Mar 2012 10:14:59 -0700
From: DCampbell@washoecounty.us
To: zachcoughlin@hotmail.com
Mr. Coughlin:
Your email regarding your missing secure property was forwarded to me for response. I apologize for the delay
in responding to you but it took me a little while to figure out the issue.
Your two cell phones and electric razor were put into evidence at the request of Judge Nash-Holmes on
February 28, 2012. In order for us to release them to you, we will need an order from Judge Nash-Holmes that
the evidence can be released to you.
To make this matter smoother for you all documentation should reflect Washoe County Sheriffs Office case
number 12-1805 and evidence number C-47591. The court case number corresponding to this issue is
11TR26800.
If you have any questions all of my contact information is listed below.
Debi Campbell, Detention Operations Manager
Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
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13 of 17 3/29/2012 2:18 PM
RE: request for written response regarding property being
held in evidence
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.
From: Beckman, Trish (TBeckman@washoecounty.us)
Sent: Tue 3/20/12 8:49 AM
To: zachcoughlin@hotmail.com
Mr. Coughlin, Aached is the wrien response to your email. Per our phone conversaon a copy of this
response has been sent to the fax number you gave me (949-667-7402).

Trish

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, March 19, 2012 4:58 PM
To: Beckman, Trish
Subject: request for written response regarding property being held in evidence
Dear Ms. Beckman,
A WCSO Deputy informed me that my property was being held in evidence, including a
flip phone style cell phone, and an HTC g2 smartphone in addition to a micro sd memory
card, and an electric shaved. He indicated the items were booked into evidence on
2/27/12, then taken by the City of Reno Marshal Division on 2/28/12. A WCSO Deputy
also indicated these items in evidence were release again to the City of Reno Marshal
Division on 3/14/12 because "its just easier to get it back to you that way"....However, now
it appears once again your office has the property.
I would like a written response detailing the chain of custody of all the property for all
times since the arrest, and itemized listing of the property, and an indication of when, if
ever, I will be informed of why it is being held and when, if ever, it will be returned to me,
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14 of 17 3/29/2012 2:18 PM
RE: request for written response regarding property being
held in evidence
and and indication of what exactly has been done with this property, including whether an
viewing or copying of the contents has been undertaken or will remain in anyone's
possession other than mine.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
From: Beckman, Trish (TBeckman@washoecounty.us)
Sent: Tue 3/20/12 11:12 AM
To: zachcoughlin@hotmail.com
1 attachment
COUGHLIN.docx (145.4 KB)


From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, March 20, 2012 11:11 AM
To: Beckman, Trish
Subject: RE: request for written response regarding property being held in evidence
Dear Ms. Beckman,
There was nothing attached to your email. Would you please resend and attach the file
you referenced below?
Thanks,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
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15 of 17 3/29/2012 2:18 PM
Subject: RE: request for written response regarding property being held in evidence
Date: Tue, 20 Mar 2012 08:49:52 -0700
From: TBeckman@washoecounty.us
To: zachcoughlin@hotmail.com
Mr. Coughlin, Aached is the wrien response to your email. Per our phone conversaon a copy of this
response has been sent to the fax number you gave me (949-667-7402).

Trish

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, March 19, 2012 4:58 PM
To: Beckman, Trish
Subject: request for written response regarding property being held in evidence
Dear Ms. Beckman,
A WCSO Deputy informed me that my property was being held in evidence,
including a flip phone style cell phone, and an HTC g2 smartphone in addition to a
micro sd memory card, and an electric shaved. He indicated the items were booked
into evidence on 2/27/12, then taken by the City of Reno Marshal Division on
2/28/12. A WCSO Deputy also indicated these items in evidence were release again
to the City of Reno Marshal Division on 3/14/12 because "its just easier to get it
back to you that way"....However, now it appears once again your office has the
property.
I would like a written response detailing the chain of custody of all the property for
all times since the arrest, and itemized listing of the property, and an indication of
when, if ever, I will be informed of why it is being held and when, if ever, it will be
returned to me, and and indication of what exactly has been done with this
property, including whether an viewing or copying of the contents has been
undertaken or will remain in anyone's possession other than mine.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
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16 of 17 3/29/2012 2:18 PM
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17 of 17 3/29/2012 2:18 PM
1
1 CODE: 4185
LORI URMSTON, CCR #51
2 Peggy Hoogs & Associates
435 Marsh Avenue
3 Reno, Nevada 89509
(775) 327-4460
4 Court Reporter
5
6 SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
7 IN AND FOR THE COUNTY OF WASHOE
8 HONORABLE STEVEN P. ELLIOTT, DISTRICT JUDGE
9
10 STATE OF NEVADA,

11 Plaintiff,
Case No. CR12-0376
12 vs.
Dept. No. 10
13 ZACHARY BARKER COUGHLIN,

14 Defendant.
_____________________________/
15

16 TRANSCRIPT OF PROCEEDINGS

17 REPORT - PSYCHIATRIC EVALUATION
18 APRIL 19, 2012; THURSDAY
19 RENO, NEVADA
20
21
22
23
24 Reported by: LORI URMSTON, CCR #51
F I L E D
Electronically
05-09-2012:09:42:24 AM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2941159
2
1 APPEARANCES:
2 For the Plaintiff: ZACH YOUNG
Deputy District Attorney
3 1 South Sierra Street
South Tower, 4th Floor
4 P.O. Box 30083
Reno, Nevada 89520
5

6 For the Defendant: BIRAY DOGAN
Deputy Public Defender
7 350 S. Center Street
P.O. Box 30083
8 Reno, Nevada 89520
9
10 For the Department of
Parole & Probation: GAIL FALCONER
11

12
13
14
15
16
17
18
19
20
21
22
23
24
3
1 RENO, NEVADA; THURSDAY, APRIL 19, 2012; 10:20 A.M.
2 --o0o--
3 THE COURT: And then the last thing we're going to
4 take before a recess will be the Zachary Coughlin.
5 MR. YOUNG: Good morning, Your Honor.
6 MR. DOGAN: Your Honor, Biray Dogan on behalf of
7 Mr. Coughlin who is present today and out of custody.
8 THE DEFENDANT: Good morning, Your Honor.
9 THE COURT: All right. Then this matter is here on
10 a report of psychiatric evaluation. There is a letter
11 here from Sally Farmer and Bill Davis. And have you
12 received this, Mr. Dogan?
13 MR. DOGAN: Your Honor, can I have the Court's
14 indulgence?
15 MR. YOUNG: Your Honor, can we approach?
16 THE COURT: Yes.
17 (A discussion was held off the record.)
18 THE COURT: Well, as a result of the hearing here
19 at the bench, the Coughlin matter will be continued to
20 the end of our docket so that we can take a recess now.
21 And the end of the docket means that it would be after
22 the 10 o'clock matter, because it's already 25 after
23 10:00 or so, and we need to get on with another matter
24 in that we have a lot of people here.
4
1 All right. So court will stand in recess.
2 (A recess was taken and the following
proceedings were had at 10:45 a.m.:)
3
4 THE COURT: As our next case then, we'll go back to
5 the 8:30 docket, and let's take Zachary Coughlin again.
6 Let's see if we can conclude that matter.
7 MR. YOUNG: Good morning, Your Honor.
8 THE DEFENDANT: Good morning, Your Honor.
9 THE COURT: And then we're here to discuss the
10 letter of April 17 that was sent out really to
11 Mr. Dogan with copies to me and Mr. Young from Sally
12 Farmer and Bill Davis who are psychologists at the
13 Lakes Crossing Center.
14 And, Mr. Dogan, do you want to explain this?
15 MR. DOGAN: Yes, Your Honor.
16 THE DEFENDANT: I'm sorry, Your Honor, if I can
17 interject quickly.
18 THE COURT: I'm asking Mr. Dogan to start.
19 THE DEFENDANT: Yes, Your Honor, but before he puts
20 anything on the record, I'm going to ask to have him
21 withdrawn or--
22 MR. DOGAN: That would be a separate matter.
23 THE COURT: I'll go with Mr. Dogan.
24 THE DEFENDANT: Thank you, Your Honor.
5
1 MR. DOGAN: Your Honor, if any issues are raised
2 regarding a motion to withdraw or anything dealing with
3 my representation of Mr. Coughlin, that would be a
4 separate hearing. That hearing will be under Young
5 versus State. Today we are here for one matter, and
6 that is the SB89 regarding my client's competency and
7 whether he's fit to proceed with adjudication.
8 Your Honor, I'm going to be requesting a short
9 two-week continuance in this case so that my client can
10 be evaluated by Lakes Crossing, by both Sally Farmer
11 and Dr. Davis.
12 My client has done all he can do to make his
13 scheduled appointments with both of the doctors in this
14 matter. And there have been some significant
15 difficulties with Mr. Coughlin being evaluated by both
16 of those doctors. However, I believe those
17 difficulties will be able to-- we'll iron them out and
18 we'll be able to get that competency evaluation for the
19 Court within two weeks.
20 THE COURT: So you're in essence telling me that
21 you believe at this point in time that your client is
22 willing to cooperate with an evaluator?
23 MR. DOGAN: I do, Your Honor. Your Honor, the
24 reason is because the Court has never-- we've never
6
1 appeared in court. And if Your Honor orders
2 Mr. Coughlin to cooperate and to obtain the
3 evaluations, by then we should be able to have those
4 evaluations for Court.
5 The one thing that I want to prevent in this case
6 is Mr. Coughlin being remanded into the custody of the
7 Washoe County Sheriff so that he can be evaluated while
8 he's at the Washoe County Jail. That's a huge concern
9 of mine. And I do not want Mr. Coughlin to be remanded
10 to the custody of the Sheriff.
11 Your Honor, the main reason is because Mr. Coughlin
12 is a licensed attorney. He does have clients and he's
13 representing those clients. If he is remanded into the
14 custody of the Sheriff, he will not be able to pursue
15 the litigation that he must while representing those
16 individuals, and his livelihood-- it will significantly
17 impact his livelihood. And, therefore, I'm going to
18 make that request, that this matter be continued
19 briefly for two weeks, Your Honor.
20 THE COURT: Well, clearly if he's not going to
21 cooperate out of custody, putting him into custody, you
22 know, and forcibly cooperating is the alternative, so
23 it has to be considered.
24 And, Mr. Young, what is the State's position?
7
1 MR. YOUNG: Your Honor, I think Mr. Dogan
2 accurately stated that essentially your two
3 alternatives at this point are just to continue the
4 matter out a few weeks to give Mr. Coughlin an
5 opportunity to be evaluated or alternatively remand him
6 into custody where, as you stated, it would more or
7 less seek to-- that the evaluations take place.
8 I'm going to respectfully ask that you follow the
9 latter of those two alternatives. And if I could take
10 a minute to explain why I'm making that recommendation.
11 He was released for this case on a 1,500-dollar
12 bond that he posted. And obviously, one of the
13 conditions of somebody being released, whether it's
14 bond, OR or otherwise, is conditioned upon that
15 individual's good behavior. And what we have here is
16 an individual who-- The competency evaluation was
17 filed in Justice Court February 27th. The matter was
18 set to my knowledge for April 3rd in front of Your
19 Honor for the evaluation.
20 There was the request, albeit done by e-mail by
21 Mr. Coughlin in his personal capacity, but after
22 speaking with the court staff and Mr. Dogan, I agreed
23 to continue that out to give Mr. Coughlin the
24 opportunity to get his evaluations done.
8
1 We then go forward to today. And Your Honor has
2 already referenced the letter which talks about
3 threatening legal action against one of the evaluators,
4 showing up late to the scheduled appointment, taking
5 additional time to--
6 THE DEFENDANT: Object, Your Honor; hearsay.
7 THE COURT: Overruled.
8 THE DEFENDANT: Move to strike.
9 THE COURT: You're not in a position to object to
10 anything.
11 THE DEFENDANT: I understand that, Your Honor.
12 Respectfully, I submit that rather than having
13 handcuffs on me, by having Mr. Dogan as my attorney, I
14 would ask that I be allowed to represent myself.
15 THE COURT: You're in a position where, you know,
16 if you interrupt and cause trouble, you're going to be
17 taken into custody and then forcibly, you know, given
18 these evaluations, so if I were you, I would simply
19 cooperate with us and don't cause a problem.
20 All right. Mr. Young, you may proceed.
21 MR. YOUNG: Your Honor, after showing up 20 minutes
22 late according to the letter, which is on file with the
23 court, he takes an additional ten minutes arguing with
24 security personnel and basically being completely
9
1 disruptive to the process.
2 The ironic thing about this is that this evaluation
3 is entirely for Mr. Coughlin's benefit. The threshold
4 question is: Is he competent to stand trial? But even
5 if he's-- if the evaluations come back that he is
6 competent, his attorney can use that to his benefit
7 with what's contained in the evaluations for any
8 potential negotiation purposes, sentencing, should we
9 get to that point, and the like.
10 And so through the actions of the defendant, not to
11 mention his previous statements that, one, he doesn't
12 even want to get evaluated for competency, and then
13 subsequent to that having a problem having Lakes
14 Crossing do that, at a minimum, his actions are not
15 evidencing good character as is required by his bail
16 being posted. At worst, it's completely
17 obstructionist.
18 And he is in the sole position to bring this entire
19 proceeding to a screeching halt if he continues this
20 behavior, showing up late, not cooperating with going
21 through evaluations which benefit him.
22 So based on that, Your Honor, what I would ask is
23 that you revoke the bond that was previously posted and
24 remand him into custody. We can set this for another
10
1 hearing consistent with the Court's calendar and the
2 evaluators at Lakes Crossing so that we can come back
3 to Your Honor and determine, which is the only
4 threshold question at this point, is he even competent
5 to go forward.
6 And, like I say, based on the actions in this case,
7 the correspondence sent to me, either cc'd or directly
8 from Mr. Coughlin, it's clear to the State that he's
9 just being an obstructionist through this entire
10 process, and so remand is appropriate to the State.
11 THE COURT: Well, Mr. Coughlin, we are at this
12 stage where you need to have this evaluation. And I
13 need to know, are you going to cooperate and go over to
14 Lakes Crossing and get the evaluation?
15 THE DEFENDANT: Your Honor, if I may address that
16 for a moment.
17 THE COURT: Please do.
18 THE DEFENDANT: Okay. Your Honor, there's been
19 some problems in terms of working with Mr. Dogan here.
20 I haven't been copied on filings to the Court. It's
21 always been my understanding, either by Mr. Dogan or by
22 the D.A., it's always been my understanding as an
23 attorney that that's just a matter of course, you copy
24 your clients on anything you file and anything you
11
1 receive.
2 Mr. Bosler, after I had complained of Mr. Dogan's
3 failure to so copy me in that regard, particularly with
4 respect to, say, this order for competency eval--
5 MR. DOGAN: For the record, that was provided to
6 Mr. Coughlin.
7 THE DEFENDANT: He might have e-mailed that to me,
8 but certainly documents such as the D.A.'s opposition
9 to my motion to appear as co-counsel and have
10 Mr. Dogan, I believe, withdraw as counsel, that was
11 never forwarded on to me despite my--
12 MR. DOGAN: For the record, that was also provided
13 to Mr. Coughlin.
14 THE DEFENDANT: Excuse me, sir. I would like to
15 have my opportunity now.
16 THE COURT: Go ahead.
17 THE DEFENDANT: I have provided Mr. Dogan express
18 written indication that I wish to be copied on every
19 single filing in this matter. In addition, matters
20 which perhaps are going to be subject to a work product
21 exception which the Public Defender would not have to
22 provide me, such as e-mails between Mr. Dogan and
23 Mr. Young, but I have expressly indicated in writing on
24 numerous times that I wished to be copied on that.
12
1 To get back-- I know this is getting somewhat far
2 afield, Your Honor, from what you prompted me to
3 address, but this competency evaluation, I would object
4 to this competency evaluation on a number of grounds.
5 One would be res judicata. There was already a
6 competency evaluation done. I passed with flying
7 colors.
8 Judge Sferrazza thought so much it that he
9 essentially folded it up into a paper airplane and went
10 like that (indicating) and sent it right back to
11 Mr. Goodnight, and the bill along with it. Whereupon
12 Mr. Goodnight promptly-- He's a Public Defender who
13 attended to the first competency evaluation.
14 Mr. Goodnight promptly asked to be allowed to withdraw.
15 And Judge Sferrazza sagely pointed out to
16 Mr. Goodnight the inequity and disingenuous of his so
17 standing behind a request for a competency evaluation
18 only to immediately thereafter seek to withdraw,
19 essentially saying: Which is it, Mr. Goodnight? Does
20 your client need a competency eval or is he so-- he
21 doesn't need you?
22 Your Honor, there's some legal points I would like
23 to put in the record here. NRS 178, I believe it's dot
24 455, but I could be wrong, but I did copy Mr. Dogan and
13
1 Mr. Young on this recently in writing, says that
2 motions have to be in writing. There was no written
3 motion in this regard. I've reviewed the file in the
4 Reno Justice Court. And this is the case with both of
5 the competency evaluations that have been ordered here.
6 And both of them, I believe, demonstrate a retaliatory
7 intent on the part of the Public Defender.
8 And Mr. Hunt who was testifying here earlier, well,
9 he went into matters to which I can't-- I can't say--
10 I know Mr. Dogan. We went to high school together.
11 We're both Reno High, I believe, class of '95-ish, from
12 Swope to Reno High. And I've never known him to be a
13 Jihadist or anything or that sort. You know--
14 MR. DOGAN: A Jihadist for the Public Defender,
15 though.
16 THE DEFENDANT: He's always been a bright guy with,
17 you know, a good sense of humor. So I can't concur
18 with Mr. Hunt's statements in that regard.
19 Now, respectfully, I can submit I've been shushed.
20 I've been told, you know, things similar to what was
21 being said.
22 I understand that the Public Defender is in a very
23 funny situation. It's a very-- It's got to be very
24 difficult. And I'll just say respectfully, Your Honor,
14
1 I was a domestic violence attorney for a legal aid
2 organization which I believe you're aware of attendant
3 to another case in your court, but I thought that stuff
4 was heavy to deal with on an emotional level. But
5 sitting here this morning, witnessing what the bench
6 and the Public Defender and the District Attorney have
7 to deal with, that they have to do in the course of
8 their business every day, it's-- I don't want to say
9 impressive, but it makes me have even more respect for
10 the court and the Public Defender and the District
11 Attorney, because these are heavy matters. These are
12 very human issues that you deal with here.
13 And I say that respectfully. Now I'm going to get
14 to what I wanted to say, which is somewhat critical.
15 And I just prefaced it with that respect, to point out
16 that I do even more so now comprehend the enormity of
17 the-- the heaviness and the emotional burden that you
18 and those at the bar here face every day.
19 But I have been shushed a lot. I've had Mr. Dogan
20 storm away from me. Granted, it's not easy to have an
21 attorney as a client.
22 THE COURT: Mr. Coughlin, you know, I have limited
23 time today to devote to this matter, and really what
24 you are facing is that I agree that you need this
15
1 evaluation, I want to see it, and either you agree that
2 you'll cooperate and go over to Lakes Crossing and get
3 the two evaluations or I will revoke your bail, put you
4 into custody and then as an in-custody you will be
5 evaluated.
6 THE DEFENDANT: Yes, Your Honor. And just quickly
7 for the record, I'll dispense with the frilly language
8 and extemporaneous, you know, speechmaking, but there
9 was no motion here made pursuant to 178, I believe dot
10 455. There needs to be in the records with the Justice
11 Court articulating an express basis for seeking this.
12 I believe there's a retaliatory basis.
13 Just days prior to this being made, and I believe
14 improper contact being made with the Municipal Court by
15 somebody with the Public Defender's, just days prior to
16 that, I filed a motion critical of Mr. Dogan missing a
17 hearing. In that regard, I believe there also needs to
18 be a hearing. There was no hearing in either of these
19 matters.
20 THE COURT: Mr. Coughlin, are you basically telling
21 me that you're not intending to get the evaluation,
22 that you're resisting--
23 THE DEFENDANT: No, sir, that's not what I'm
24 telling you. I'm saying--
16
1 THE COURT: Because if you're not going to do it on
2 your own, I'll put you in custody and we'll take care
3 of it that way.
4 THE DEFENDANT: I understand, Your Honor. And
5 that's not what I'm saying. What I'm saying is-- You
6 referenced this process. I believe if we're going to
7 call it a process, it needs to entail some process,
8 some due process hopefully.
9 And if I ask Mr. Dogan to conduct some Legal
10 research on-- which I have done, Your Honor, and I
11 would like to put forth some of these cases to you,
12 directed to the parameters of such competency
13 evaluation, directed to the privacy rights attendant to
14 one forced to undergo such an evaluation. I've simply
15 received no counsel or no advocacy in this regard from
16 the Public Defender. I've had meetings missed. I've
17 been told to shush. I've been told all sorts of things
18 that just frankly I'm taken aback by.
19 This evaluation, we have no idea of the scope of
20 this other than I'm given some indication by the
21 statute what it is directed to, my ability to
22 understand the proceedings, to assist Mr. Dogan in the
23 defense thereof. And there's one more element which
24 I'm blanking on right now, but it's substantially
17
1 similar to the first one.
2 It's not a-- it's not a blank check to
3 psychiatrists who have some sort of requirement
4 contract with the Public Defender, and I stated some--
5 or the court. I've stated some objections. I believe
6 I should be able to have a private psychologist
7 appropriately certified under NRS 178 to perform this.
8 I've been told no. I've been told I won't be
9 reimbursed in that regard.
10 But it's not a blank check, I don't believe, to
11 force me, someone who is seeking to take advantage of
12 my tax dollars at work by having my Sixth Amendment
13 right to counsel accorded to me. It's not a blank
14 check to Lakes Crossing to demand anything they want to
15 know about me, particularly when I'm involved in a
16 field where mendacious and scurrilous individuals such
17 as Richard G. Hill will co-op any sort of information
18 or innuendo--
19 MR. YOUNG: Your Honor, I'm going to object to this
20 as completely irrelevant.
21 THE DEFENDANT: --to further their ends.
22 THE COURT: I have to agree.
23 Mr. Coughlin, if you're telling me fundamentally
24 that you don't plan to cooperate, I'll revoke your bail
18
1 and put you into custody of the Washoe County Sheriff
2 and then they can get you, you know, the evaluations as
3 an in-custody person. That's what I would have to do.
4 You know, you are a very articulate man and, you
5 know, you're stating your positions on this, but your
6 positions are against what I want done.
7 THE DEFENDANT: I don't know what you want done,
8 Your Honor.
9 THE COURT: I just want you to get the two
10 evaluations at Lakes Crossing. They're the people that
11 normally do this for everybody, you know, and--
12 THE DEFENDANT: And I presented--
13 THE COURT: --that's the appropriate thing to have
14 done at this time.
15 THE DEFENDANT: And I presented twice in that
16 regard, Your Honor, and it's my understanding they just
17 flat out refuse to continue. In that regard, I believe
18 I should-- One, I dispute the accuracy of their letter
19 wholeheartedly. I find it inaccurate, I find it
20 retaliatory in tone. But I did present-- And there's
21 a case--
22 THE COURT: Well, I've never seen a letter like
23 this before. I mean, people just don't show up, that's
24 true, but once they show up, they generally, you know,
19
1 cooperate with the talking and taking whatever testing
2 needs to be done and get the evaluation. It's not a
3 very painful process.
4 THE DEFENDANT: And I was told-- Maybe not for
5 people who aren't very aware of constitutional rights.
6 But for someone who is burdened with the fact that they
7 went to law school, you know, it's difficult. And I
8 would submit that there's a number of cases in juris
9 prudence in this regard that speak to the extent--
10 THE COURT: Mr. Coughlin, since you're not going to
11 cooperate--
12 THE DEFENDANT: No, I will cooperate. I just need
13 to know, Your Honor--
14 THE COURT: But you're telling me you're not
15 cooperating.
16 THE DEFENDANT: No, I will. I'm telling you I
17 will. And I did, I showed up. They asked me a
18 question--
19 THE COURT: You have to show up and you have to
20 meet with the two psychiatrists or psychologists, I
21 guess, technically, whatever they are, and, you know,
22 talk to them, be responsive and get the appropriate
23 evaluation.
24 THE DEFENDANT: If they ask me to take off my
20
1 clothes and appear naked, do I need to do that?
2 THE COURT: I think it's unlikely that that's going
3 to happen to you. I'm not going to speculate as to,
4 you know, totally absurd, you know, things that could
5 happen during a psychological--
6 THE DEFENDANT: If they ask me if I've ever had any
7 mental health treatment, if they ask me to have a copy
8 of any of my medical records, if they ask me any sort
9 of personal information that would normally be
10 protected--
11 THE COURT: Then you're saying you won't cooperate?
12 THE DEFENDANT: No, I didn't say that, sir. And I
13 didn't say that to Lakes Crossing either. They stormed
14 off. I said, "I'll have to check my records, let me--"
15 something like, "Let me think about that."
16 And they stormed off in anger. They said, "We're
17 done and left."
18 And it was appalling. And then to send the letter
19 they sent you, Your Honor, is appalling. I didn't
20 stand there and say: I'm refusing to tell you
21 anything. I didn't do that. Dr. Davis appeared--
22 THE COURT: Look, Mr. Coughlin, I just need to
23 know, are you going to go there and cooperate and get
24 this psychological evaluation or not? I mean, are you
21
1 going to do it on your own out of custody?
2 THE DEFENDANT: Yes, Your Honor, I will, but--
3 THE COURT: Okay. Well, if you are going to do
4 that and you commit to this court basically under
5 penalty of being found in contempt for failing to do
6 it, you know, I'll leave you out of custody and you can
7 get this on your own. But if you're not going to go
8 there and cooperate, I'm forced to revoke your bail and
9 put you into custody and then as an in-custody prisoner
10 you can get some psychological counseling, and, you
11 know, evaluation.
12 THE DEFENDANT: Your Honor, I would just put forth,
13 I always intend to follow orders of the court. I would
14 like an opportunity to brief this and oppose the order
15 initially since I've been--
16 THE COURT: Well, that is denied. We're at the
17 point now where it's already determined that you're to
18 get this evaluation.
19 THE DEFENDANT: But I believe that an excusable
20 neglect analysis would auger towards allowing me to
21 replace Mr. Dogan based on his fraudulence basically or
22 his excusable neglect or something, but I have not been
23 accorded a due process right to oppose this evaluation.
24 I would like that.
22
1 Failing that, I would like an opportunity to brief
2 the extent to which this evaluation is a blank check to
3 Lakes Crossing. I would also like the opportunity to
4 brief the extent to which I must utilize Lakes Crossing
5 versus a private certified entity or a professional.
6 THE COURT: Well, Mr. Coughlin, after hearing you
7 argue and argue about this issue, I'm making the
8 determination that you're not going to cooperate with
9 this, and I am revoking your bail.
10 THE DEFENDANT: Sir, I will cooperate. If that's
11 what it comes down to, I--
12 THE COURT: You're going to be placed into custody
13 of the Washoe County Sheriff at this time. I revoke
14 your bail.
15 THE DEFENDANT: Your Honor, I just respectfully ask
16 that you reconsider, and I'll do whatever you say for
17 my--
18 THE COURT: We're done with this. I'm sorry that
19 you've forced me to take this action. I don't really
20 want to put you in custody, but it's clear that you're
21 really not going to cooperate. And you're raising
22 issues about issues that seem kind of preposterous but
23 that would give you some excuse not to cooperate. So
24 you'll have to get the examination as an in-custody
23
1 person.
2 MR. DOGAN: Your Honor, can I make one suggestion?
3 THE COURT: Yes.
4 MR. DOGAN: As soon as those competency evaluations
5 are completed, can we have Mr. Coughlin removed or no
6 longer in custody at the Washoe County Jail?
7 THE COURT: He's going to remain in custody until
8 he can be brought back here for the hearing on
9 competence.
10 THE DEFENDANT: Your Honor, if I may just make one
11 request. Given your ruling, Your Honor, I basically
12 will do what you say to do, particularly--
13 THE COURT: Well, I don't believe that you will.
14 After all this, we've spent a lot of time on it, I just
15 don't believe you anymore.
16 THE DEFENDANT: Well, Your Honor, if I may move to
17 stay based on the prejudice to my clients that--
18 THE COURT: Denied.
19 MR. YOUNG: Your Honor, do we want to set a new
20 date?
21 THE COURT: So let's set this out about in about a
22 month.
23 MR. DOGAN: Can we just--
24 THE COURT: And if it's done earlier, fine, but
24
1 let's track it for about a month is what it normally
2 takes.
3 MR. DOGAN: I understand, Your Honor. Can we just
4 have a status hearing just in case both of the
5 evaluations have been completed?
6 THE COURT: If it's done, you all can get together
7 and set it back on the calendar at that time.
8 THE CLERK: Your Honor, the first available date
9 would be May 24th at 8:30. Is that acceptable?
10 MR. YOUNG: May 24?
11 THE CLERK: Yes. Is that acceptable?
12 MR. DOGAN: It is. Thank you.
13 THE DEFENDANT: May I have those papers entered
14 into the record?
15 MR. YOUNG: Thanks, Your Honor.
16 THE DEFENDANT: That legal research on the table.
17 THE COURT: Denied.
18 (The proceedings were continued to
May 24, 2012 at 8:30 a.m.)
19
20 --o0o--
21
22
23
24
25
1 STATE OF NEVADA )
) ss.
2 COUNTY OF WASHOE )

3
4 I, LORI URMSTON, Certified Court Reporter, in and
5 for the State of Nevada, do hereby certify:
6 That the foregoing proceedings were taken by me
7 at the time and place therein set forth; that the
8 proceedings were recorded stenographically by me and
9 thereafter transcribed via computer under my
10 supervision; that the foregoing is a full, true and
11 correct transcription of the proceedings to the best
12 of my knowledge, skill and ability.
13 I further certify that I am not a relative nor an

14 employee of any attorney or any of the parties, nor am

15 I financially or otherwise interested in this action.

16 I declare under penalty of perjury under the laws
17 of the State of Nevada that the foregoing statements
18 are true and correct.
19 DATED: At Reno, Nevada, this 19th day of

20 May, 2012.

21

22 LORI URMSTON, CCR #51

23 ___________________________

24 LORI URMSTON, CCR #51
****** IMPORTANT NOTICE - READ THIS INFORMATION *****
PROOF OF SERVICE OF ELECTRONIC FILING
A filing has been submitted to the court RE: CR12-0376
Judge: STEVEN ELLIOTT
Official File Stamp: 05-09-2012:17:17:16
Clerk Accepted: 05-09-2012:17:18:18
Court: Second Judicial District Court - State of Nevada
Case Title:
STATE VS ZACHARY BARKER COUGHLIN
(D10)
Document(s) Submitted: Order of Competency/Return JC
Filed By: Heidi Howden
You may review this filing by clicking on the
following link to take you to your cases.
This notice was automatically generated by the courts auto-notification system.
If service is not required for this document (e.g., Minutes), please disregard the below language.
The following people were served electronically:
PATRICIA HALSTEAD, ESQ. for STATE OF
NEVADA
ROY STRALLA, ESQ. for STATE OF NEVADA
BIRAY DOGAN, ESQ. for ZACHARY COUGHLIN
CHRIS FORTIER, ESQ. for ZACHARY
COUGHLIN
DIV. OF PAROLE &PROBATION
ZACH YOUNG, ESQ. for STATE OF NEVADA
The following people have not been served electronically and must be served by traditional
means (see Nevada electronic filing rules):
F I L E D
Electronically
05-09-2012:05:17:16 PM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2943750
County Home => Reno Justice Court => Divisions => Justices of the Peace => Department 2
Department No. 2
Pete Sferrazza currently serves as a Judge in Reno Justice
Court having been elected in November of 2!. Prior to
becoming a "udge# Pete served as the elected Reno $ayor
from %&!% to %&&' serving an unprecedented %( years.
Pete has also served in the Peace Corps in )ahia# )razil
from %&*& to %&+%# as a $arathon County Supervisor and
,ausau# ,isconsin City Councilmen from %&+( to %&+*# as
Director of Nevada -ndian .egal Services from %&+* to
%&+!# Chairman# /ice0Chairman and ,ashoe County
Commissioner from %&&! to 2+# a Deputy 1ttorney for
-n"ured 2or3ers# and 2as in private practice.
-n addition Pete served as 4ribal Judge for the $oapa
Paiute# 5erington Paiute# 6ly Shoshone# -ntertribal Court of
1ppeals# 7allon Paiute0Shoshone# Pyramid .a3e Paiute#
,al3er River Paiute# and the ,ashoe 4ribe.
8e is a graduate of $ichigan State 9niversity 2here he
received a )achelor of 1rts Degree in Political Science# the
9niversity of ,isconsin .a2 School 2here he received his
J.D. Degree and the John 7. :ennedy School# at 8arvard
9niversity.
Pete currently serves on the 1merican Judges 1ssociation )oard of Directors and the
Nevada State07ederal Judicial Council. 7ormerly he served on the )oard of Directors of the
National 1ssociation of Counties currently# )oard of Directors Nevada 1ssociation of
Counties currently# /ice0Chairman Reno Spar3s Convention and /isitors 1uthority# 6;ecutive
)oard 9.S. Conference of $ayors# ,ashoe County )oard of 8ealth# )oard of Directors for the
Nevada .egal Services# )oard of 4rustees for the ,illiam 7. 8arrah 1utomobile $useum# City
:ids of Reno# $ayor<s 5outh 1dvisory )oard# and Chairman of the Regional =overning )oard.
Pete is admitted to the Supreme Court of the 9nited States of 1merica# Nevada Supreme
Court# ,isconsin Supreme Court# 9.S. Court of 1ppeals for the Ninth Circuit# 9nited States
Court of 1ppeals for the 7ederal Circuit# 9.S. Court of 1ppeals for the Seventh Circuit# 9.S.
District Court# District of Nevada# 9.S. District Court# ,estern District of ,isconsin# 9.S.
District Court# 6astern District of ,isconsin# all of the 4ribal Courts in the State of Nevada
and the 9.S. 4a; Court.
Page 1 of 1 Department 2
http://www.co.washoe.nv.us/rjc/justiceofthepeacedept2.htm
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Paul D. Elcano, Jr.
Paul D. Elcano, J r. is a Lawyer in Reno, Nevada
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Areas of Law
Personal Injury Law
Labor Law
Medical Malpractice Law
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Experience & Credentials
Admission Details Admitted in 1978, Nevada (inactive)
Law School Attended McGeorge School of Law
J .D.
University Attended Stanford University
B.A.
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