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. &RPSDQ\ EcheverrIu uw OIIIce $GGUHVV qqz DoubIeR BIvd. - Reno , NV8qz1 3KRQH 1XPEHU ;;-;86-q8oo )D[ QXPEHU ;;-;86-q8o8 (PDLO :HEVLWH $GPLW 'DWH oqJzJ;z /DZ 6FKRRO HusLIngs 6SHFLDOL]DWLRQ None 3URIHVVLRQDO /LDELOLW\ ,QVXUDQFH Yes -2+1 3(7(5 (&+(9(55,$ &XUUHQW 0HPEHU 6WDWXV $WWRUQH\ $FWLYH %$5 180%(5 zoo Disciplincr Actions: Disciplincr ccses cre ctcilcble jrom1cnucr :, zooto the present. This dctcbcse includes public discipline onl cnd does not include pendin discipline ccses. The dctcbcse is jrequentlupdcted but mc not be current ct the time oj our secrch. Ior the most current injormction recrdin cn cttorne's disciplincr histor, contcct the Djjice oj cr Counsel. Clicl here jor the discipline le. The Djjice oj cr Counsel strites to ensure the disseminction oj timel, cccurcte public injormction concernin cttorne discipline. The injormction contcined in this site is belieted to be correct, houeter, its cccurcc ccnnot be ucrcnteed. Iurther, the Djjice oj cr Counsel is not responsible jor cn errors or omissions cnd cssumes no licbilit jor its use, ctcilcbilit or compctibilit uith uebsite user's sojtucre or computer. In cddition, some bcr members shcre the scme ncme. Plecse terij thct ou hcte selected the correct lcuer. The Djjice oj cr 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. Note: An cttorne hcs the dutto mcintcin c Lcuer's iorcphiccl Dctc Iorm uhich detcils their cddress, licensin injormction, crecs oj speciclizction, bcclround, trcinin cnd lecl experience. You mc request this jorm directl jrom our cttorne. ),1' $ /$:<(5 { Buck Lo Seurch ResuILs ] 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 Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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... 2 of 17 3/29/2012 2:18 PM 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 Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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. Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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. Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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. Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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, Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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? Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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 Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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, Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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 Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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 Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 16 of 17 3/29/2012 2:18 PM Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3... 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 Submit a review Peer Rating 5.0 / 5.0 Phone number not available Website not available Paul D. Elcano, Jr. Paul D. Elcano, J r. is a Lawyer in Reno, Nevada Is This You? Update Your Profile Areas of Law Personal Injury Law Labor Law Medical Malpractice Law Peer Rating Meets very high criteria of general ethical standards Overall Peer Rating 5.0 out of 5.0 No feedback is available. The individuals that have reviewedthis lawyer have not provided any additional feedback. Experience & Credentials Admission Details Admitted in 1978, Nevada (inactive) Law School Attended McGeorge School of Law J .D. University Attended Stanford University B.A. Lawyers.com>Find a Lawyer >Paul-D-Elcano-J r- Search Lawyers.com Search Connect with Us Find a Lawyer Understand Your Legal Issue Discuss Your Legal Issue Legal News & Blogs Legal Forms Page 1 of 2 Paul D. Elcano, Jr. - Lawyer in Reno, Nevada (NV) - Lawyers.com http://www.lawyers.com/Nevada/Reno/Paul-D-Elcano-Jr--1070555-a.html http://www.lawyers.com/...
10 31 13 72675 65630 63341 71437 607 599 Filing and Voxox Fax Proof With 4 4 13 Fax Header's Motion To Strike Remand and Sentencing Memor and Extension of Time Sought Appt of Counsel Etc. Vacate Epo
10 24 13 72675 Printed Notice of WCDA's Attempt To Remand Coughlin and Revoke Two Probations and Addendum To Post-Trial Motions Stamped With Ex 1 Opt A9 Printed
UPDATE With Voluntary Withdrawal of Complaint by Keenan in Re CES NOM To Intervene With Exhibits and MOL USDC SDNY 11-Cv-8500 - and - Proposed - Supplement With May 30 2012 Hearing Transcript
Metrolina Family Practice Group, P.A., the Durwood Medical Clinic, Incorporated, North Mecklenburg Family Practice Group, P.A., Thomas Dunlin, M.D., Charlotte Medical Clinic, P.A., Ralph v. Kidd, M.D., Mecklenburg Medical Group, P.A., Travis Medical Clinic, P.A., Kouri Medical Clinic, P.A., Charlotte Internal Medicine Associates v. Louis W. Sullivan, Secretary of Health and Human Services, U.S. Department of Health & Human Services, 929 F.2d 693, 4th Cir. (1991)