1

2
3
4

In Re Matter of

Zachary B. Coughlin

8
9
10
11

12
13

14

15

ST&TE BAR HEARING

16
17

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

At

18

June

21,

2002

9:11 o 'clock a.m.

At 600 East Charleston Boulevard

19

Las Vegas, Nevada

20
21

22
23
24

25

Reported by:

Linda Horton Sprague.

C.C.R.

No.

466

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

....... ,,"

w<=>c::t

Sahara Avenu e ,

Suite

770,

Las

Vegas,

Nevada

a910;?

APPEARANCES:

Panel Members :

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

4
5

For Zachary 8.

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

By:

9
10

Also Present:
11

Patrice Eichman. Esq.

Director of Admissions
State Bar of Nevada

12

13
14
15

16
17
18

19
20
21
22

23
24
25

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

2300 West

Sahara Avenue,

Suite

770,

Las Vegas,

Nevada

89102

Thereupon-MR. CHAIRMAN,

The record should reflect

that this is the continued hearing before the State

Bar of Nevada, Moral and Fitness Committee.

We had previously met with the applicant on

2002.

And at my re quest,

as a reflection

March 1st,

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

postponed -- or continued.

The applicant is present .

I would remind y ou , Mr. Coughlin,

you've

10

previously been sworn,

and we wi ll not readminister

11

the oath,

12

say today will be pursuant to the earlier oath you

13

took .

but we wi ll anticipate that everything you

14

Do you recall taking the oath?

15

THE WIT NESS:

16

MR. CHAIRMAN;

Yes.
We'r e pl eased to say that

17

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

18

I'll introduce the com mi ttee .

I'll start on my far

19

right with Dr. Gregory Brown.

Ms.

20

my immediate right.

21

And I'm Mi chael Rowe.

To my left,

Lori Story

is Mr.

23

of.

24

n o tice of the formal hearing for today .

25

on

Kevin Kelly.

I'm chairman of the committee.

A fe w other procedural thi ng s

22

1S

And

to take care

The committee will have marked as Exhibit 4 the

You've attached that to your brief as

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

2300 Wes t Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

Exhibit A.

2
3

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

and why you are prese nt today?

MR. CHRISTI ANSEN,

MR.

CH AIRMAN:

That ' s correct.

Exhibit Number 5 is the

notice of the State Bar Witne sses.

notices are dated May 30th,

8
9

Both of those

2002.

The record should r eflect that I have

consulted with members of the committee and with the

10

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

11

Dean Morgan toda y.

12

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

13

his busy schedule .

"4

It's our belief that our concerns

Co unsel has indicated to me prior to the

15

hearing that he did not request that the Dean be

16

present for toda y's hearing.

17

Is that correct?

18

MR. CHRISTI AN SE N:

19

MR.

CHAIRMAN :

That's accurate again.

The next exhibit in order,

20

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

21

starting up today from the e xh ibit numbers that we

22

left off of from Marc h 1st.

23

Ex h ibit Number 6 , Counsel,

will be your

24

brief with your exhibits attached to it .

2~

received a copy of the prchearing brief with

We have all

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

2300

West

Sahara Avenue,

Suite

770.

La s

Vegas,

Nevada

89102

And I ' m quite certain that all the ot her

exhibits.

members have revie wed it.

well.

I have revie wed it as

So we are familiar with that.

The burden still is upon --

MR.

Would you like to have the

KELLY :

transcript as part of the record?

The question be ing clearly

>JR. CHAIRMAN ,

7
8

whether we were going to mark the transcript from the

earlier proceedings as an exhibit to this procedure.

10

But at least my reco l lection of what the Supreme

11

Court said to us in April,

12

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

13

happy to do it if you wish.

MR . KELLY:

o.

But I'm

I'm just making sure.

I had mentioned t o

MR. CHA IRM AN:

15

the transcript is the

16

Mr. Christiansen bef o re the hearing started after the

17

hearing of March 1st, we had requested that

18

Mr. Coughlin produce

19

about what documents he should produce, one of which

20

was the affidavit attached to the brief.

21

we made some suggestions

But there were t wo documents that we asked

22

for .

23

Admissions -- I'm s o rry.

24

25

And I am advised by the Director of

Ms. Reporter,
honorable pLesence

or

would you please reflect the

Ms. Patri ce Eichman,

wh o is

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

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

My apologies,

with us today as well .

We had asked Mr.

Pat.

Coughli n to produce for us

the police report,

that I will brand the movie

theater i ncident, and also his transcript from Boyd

School of Law.

received neith er of those documents.

And I'm advised this morning that we

Is that correct

MS.

MR. CH AIRMAN:

10

EICHMAN,

That ' s correc t.

Would you like to address

t hat ?
MR. CHRISTIA NSE N:

11

Sure .

I will take

I took it upon myself to be

12

responsibility.

13

responsible for producing those documents.

In an effort -- I did notice,

when I did

15

reviewed the transcri pt that Ms.

Eichman wa s kind

16

enough to provide me with, a question was asked about

17

the police reports.

18

In an effort to obtain chose ,

19

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

20

Mr. Coughlin dealt with -- and attempted,

21

staff,

22

staff that because the documents re sulted -- or the

23

charges resulted in an ultimate dismissal that the

24

underlying reports are not kept for an e x tended

2S

period of time and they could not be located.

to secure those documents.

I contacted

through his

I wa s told by

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

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

7
I can tell you f r om my practice that o n ce a

1
2

misdemeanor conviction is dismissed -- and this

obviously was a dismissal -- once i t has been

dismissed,

keep onl y the police reports leading to that

in vestigation for a period of 12 months,

they're destr oyed.

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

and

hen

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

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

10

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

11

the police reports to see ho w the resolution was for

12

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

13

of cours e and not to hide a nything.

14

The minutes have n lready been produced

15

sho wing the dismissal,

16

anything .

17

couldn't get them,

18

and I was unable to obtain

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

I guess,

is the short story.

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

19

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

20

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

21

that I had to attach my transc r ipt,

22

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

23

applicatio n.

2~

25

and I assumed

Zack has a copy of his Boyd t ranscrip ts at

his house.

It won't be an officia l.

raised seal.

ASSOCIATED REPORTERS OF NEVADA - 702/382 -8778

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

stamped copy, but I can have that delivered today to

the commit tee.

my fault,

And I apologize again.

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

That would be

For the purposes of today's

I believe that we did want to revie w that,

hearing,

as we al ways do with each applicant.

A n o n -certified

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

8

but I

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

a certified cop y of the transcript from the law

10

school .
So if yo u will represe n t

11
12

get that here as soon as possible,

13

appreciate it.

, 4
15

MR. CHRISTIANSEN:

to us that you will

we would

I ' ll send Mr. Coughlin

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

MR.

16

CHAIRMAN:

Your brief ackno wledges the

17

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

18

We have seen, as I indicated.

19

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

20

prove that the applicant possesses the moral fitness

21

to become a member of the State Bar of Nevada.

your brief,

but I would

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

22

23

possess the character and fitness required t o

24

practice .

25

LULn Lhis over to counsel for presentati on

And since the burden is upon you,

I will

unlps~

the

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

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

com mittee members have any questions of co unsel at

this poi nt.

As I referenced in my

MR. CHRISTIANSEN:

One is Dr.

have a couple witn esses .

Hunter,

brief,

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

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

And maybe I can pag e him.

gi v e me the number to page him.

I'm sure Ms. Eichman ca n

If I do that first,

then I can call his

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

10

father .

11

Maybe there will be a call back from Dr.

12

his page.
( Wh ereupon ,

13

Hunter from

Dr. Hunter wa s paged,)

MR. CHRI STIANSEN:

Dr . Hunter ?

Yes.

15

THE WITNESS:

16

MR. CHRIS TIANSEN,

Dr.

Hunter,

I 'm present

17

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

18

Ms . St o ry,

19

me as well .

20

taking time to come and testify telephonically.

21

But rather than asking you a ser ies of

Mr.

Rowe,

and Kevin Kelly.

J kn o w y ou have patients,

Brown,

Zack is with
and so you're

22

questions,

23

your involvement with Zack and your opinion ab out

24

Zack.

2,

why don't you tell the committee members

THE WITNE SS:

First: off,

appr eciate your

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

Suite 770, Las Vegas, Nev ada 89102

2300 West Sahara Av enue,

10
1

letting me check in telephonically.

in such company .

MR.

THE WITNESS,

I'm honored to

CH AIRr..,AN:

You flatt.er us,

Doct.or.

Do you guys have the letter in

front of you that I wrote on 5-21?

MR.

CHRISTIANSEN,

THE WITNESS,

They do,

Doctor.

That pretty much summarizes my

Zack has been coming in to see me since

findings .

early April.

He and I have spent enough time

10

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

11

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

12

kid shouldn't be practicing law.

MR.

13

CHRISTIANSEN:

Doctor. you refer to

14

Axis I and Axis II diagnostic tests.

15

what t. hey are .

16

them and what the results we re.

But ma y be you can clarify why you did

T HE h'ITNESS :

17

I ha ve an idea

It's a diagnosis on five

18

levels.

The y call them Axi s 1.

II,

19

For the purposes of this hearing,

20

don't belong here.

III,

II.

IV and V.

III,

IV,

and V

The big one is Axis I.

Axis I is what you think of when you thi nk

21
22

of a psychological diagnosis.

Axis I answers the

23

question :

What's going on here?

What's wrong here?

Axis II is less commonly discussed, but

25

equally important criteria for a personaliLy

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

11

This individual's pers o nality has been

diagnosis.

structured in such way tha t

chronic problems .

This is an antisocial person or

Zack has no Ax is II diagnosis.

wh atever.
5

they ' re going t o h ave

There is

nothing pathological about his personality structure .

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

Wh en you have a -- a norma l

adjustment reaction.

person under

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

10

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

Axis II.

CHRISTIAN SEN:

Dr.

Hunt er , how many

sessions have you had with Zack?

THE WITNESS:

15
16

And that'S significant.

MR.

13

14

stressful circumstances that

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

11

12

temporar~ly

d o n't kn o w.

More t han si x,

but l ess than ten.

MR. CHRISTIANSEN,

And in those sessions,

18

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

19

develop any type of mechanism for dealing with

20

stress?

21

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

22

about the m.

23

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

THE WITNESS:

That's been a large thrust of

21

what we have talked about.

And,

yes,

I think h e ' s

25

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

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

12

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

MR. CHRISTIANSEN,

you

seen him develop the mechanism to deal wi th

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

he ha s dealt with it in the past?

THE WIT NESS:

Yes,

He clearly

ver y mu c h so .

has taken more significantly hi s ge n eral a wareness

level of i nsight.

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

Mo st people who wi n d up with

the y ' re n o t

11

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

12

fl y on auto pilot,

13

situations.

14

paying r eal good atte n t i on .

So stuff

10

jus t

kind of reacting to

Zack and I talked ab out a tremendous amount

15

about his cognitive structure,

16

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

17

sig hted by stuff .

18

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

19

st r ess le v els are significantly better than they

20

were .

21

MR.

his abilit y t o

His general a wareness level is

CHRISTIANSEN :

Do y o u have a

22

recommendation f o r Zack o ngoing?

23

to th erapy regul arl y ?

24

THE WITNE SS :

25

Does he ne ed t o go

He and I believe -- Za c k --

yuu Cdn quesLi o n him mor e

- - but I

think we

h~vc

ASSOCI ATED REPORTERS OF NEVAD A - 702/382-8778

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

13

affected a relationship at a level where he will call

me as he needs me .

more.

I'm going to see him a little bit

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

regularly scheduled therapy.

I do think it ' s g oo d

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

but I think that we have affected that.

MR . CHRISTIANSEN,

7
8

seen him ,

marked improvemen t

10

Over the time that you'v e

the numb er of months ,

ha v e

y ou

seen a

in his ability to deal with these

things?

Absolutely .

11

THE WITNESS:

12

MR . CHRISTIA NSE N :

Dr.

Hunter,

I ' ve

talked

13

to you at length about this outside of this hearing.

14

But can y o u sort of impress,

15

committee,

16

your opinion on Zack.

17

your letter implie s it,

18

them.

19

I guess,

THE

if you can, upon t he

the strength of your feelings or

WITNESS:

I kno w what it is.

think

but I ' d like y ou to just tell

I feel real strongly -- and

20

so me of this is because of my historical relati onship

21

with the Bar .

22

with attor n eys in Las Vegas .

23

Bar's agent on some psychological consults.

24
25

I ' ve done a tremendous amount of wor k

I ' ve served as the

I don't know the current panel,

exception of Mr.

Kelly,

who

with the

I'm familiar wi t h .

But

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

Suite 770, Las Vegas, Nevada 89102

2300 West Sahara Avenue,

my reputation is that I'm a fairly conservative guy

on this stuff.

is no reason that this guy should not be pra cticing

la w.

MR.

And I

feel v ery strongl y tha t

CHRISTIAN SE N,

Dr.

Okay.

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

committee may have qu es ions,

MR. BRO WN:

just wanted to ask

10

standardized

11

that nature?

12

THE

13

Hi,

Dr.

there

Hunter,

The Bar

though.
Hunter.

Dr. Greg Brown.

if y ou perf orme d any kind of

esting,

l i ke an MMPI o r something of

No , Doctor,

\<1 ITNESS:

I did noc.

I did

not feel the n eed to do that.

14

MR. BRO WN:

Okay.

15

MS . S TOR Y,

Yo u say you think Zack needs - -

That's a ll .

16

or will have a cou pl e more regular sessions before

17

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

18
19

20

21
22
23

24
25

THE WITNESS:
expectation .

Yes,

MS. STORY,

Yes .

Tha t

was our

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

kno w for sure.

MR. CHAIRHAN:

Dr.

Hunter.

this is

Mik e Rowe.
Did Zack explain to y o u in any detail the
previous hearing that we conducted with h im on
ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778
2300 vl est Sahara Av e nue, Suite 770, Las Vegas . Ne va da 89102

15

Mar ch 1st?

That was part of our

THE WITNE SS ,

discussion, yes .
Wha t did he describe for you

MR . CHAIRMAN:

as his co nduct.

right term .

if you wi ll.

I'm n ot sure I could quote it

THE WITNESS,

I ' m not sure that's the

directly,

But the language wa s either , verbatim or pretty close

10

to ,

11

do wn.

"I

12

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

Oh, my God.

melted down.

It wa s

I really melted

horrible.~

MR . CHAIRMAN:

I think that ' s probably a

13

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

14

rate .

15

Doctor,

the concern that I as one member

16

have is stress exists,

17

occur to all of us all the time,

18

our professio n.

19

last hearing to the point where we stopped the

20

proceedings based o n Mr.

21

like the last hearing,

and

sometimes hourly in

And we were greatly concerned at the

THE WITNESS,

Coughlin's being upset.

Right.

I understand that.

22

And I am actually,

in general , appreciative of the

23

sensitivit y of the Bar .

24

this than the medical board.

25

a little more sophisticated , a litLle loore open of

You guys do a better job on

In general,

the Bar is

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778

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

16

emotional issu es o f i ts pra c titioners.

It r e mains my professional op in ion that it

was an isolated incident that was the end of a long

cumulative peri o d.

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

Aga i n,

It was a very atypical situation

i f I felt definitely -- Kevin,

felt differently,

guys not to let him pra c tice .

10

f'>1R.

Doctor .

I wou ld have no problem tell i ng you

CHAI RMAN:

THE ,II TNESS ,

12

MR. CHAIRMAN:

MR.

Kevin, do you have any

KELLY:

think y ou ans wer ed it whe n y ou

id entified it being an isolated in c ident.

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

16

17

Okay .

questions?

14

15

I appre ciate your candor,

Thank y ou very mu ch .

11

13

adjustment rea ct ion period last?

THE WITNES S ,

18

Anywhere, Kev i n,

19

months,

20

But I think he wa s clearl y,

21

of it.

22

if I

fr om days to

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

MR.

KELLY :

c l earl y t hr o ugh the worst

I mean , his physical

23

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

24

like o n March 1st.

2~

thousand percent better.

And j ust,

physi c ally,

he looks a

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

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

17

THE WITNESS;

Yeah .

I really do think you

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

It was at the end of what was the most stressful

period of what,

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

the president of the club and so on .

to being in an underdog's position, and,

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

frankly,

He wasn't used
frankly,

10

part of Zack's stress arises from self-imposed

11

standards t hat aren't realistic?

THE WITNESS;

12

he

Do you think it's possible that

r<1s . STORY ;

had been an untroubled life .

I think that's absolute ly

That's absolutely what has been addressed in

13

true .

14

therapy.

15

of doctors .

16

is the criteria he sets for himself.

This is true of a lot of lawyers and a lot

The most demanding criteria in his life

17

But I think we've talked through that, and

18

he has more realistic expectations of what he ought

19

to be doing .

20

MR. CHR ISTIANSEN;

21

Pete Christiansen.

22

questions .

23

y our patients.

24

25

Dr . Hunter,

this is

I guess e v erybody is done asking

I appreciate you taking time a way from

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

THE t'l ITNESS;

Okay .

I appreciate it.

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

ASSOCIATED REPORTERS OF NEVADA -

702/382-8778

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

18
1

record about ho w I feel.

me the chance to do so .

MR.

THE WITNESS,

So I appreciate your giving

CHRISTIANSEN:

Thank you,

Doctor.

Call me lat er and let me know

ho w it went.
MR. CHRIST IANSEN,

Okay .

if I could call Tim Coughli n,

out in t he lobby.

think maybe next

Zack's father.

He's

10

Thereupon ,

11

TI MOTHY D. COUGHLIN

12

was calle

as a witness and,

13

s worn , testi fi ed as follo ws:

having been first duly

14

MR. CHRIS TIANSEN:

15

Dr. Coughlin,

this isn't

16

quite like the questi oning that would be in court,

17

but you are under o ath today.

18

committee that is going to make a recommendation in

19

Supreme Court on the admission or non-admission of

20

your son.

21

22
23

Tell the Bar,

This is the Bar

the committee members, wh at

y ou do for a living .
THE WITNESS:

I ' m a family practitioner in

24

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

25

Family Physicians .

And I'm an associate professor at

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

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

19

Family Practice at the medical school.

MR.

You 're also the father of

CHRISTIANSEN,

the applicant?
Yes.

THE vII TNESS:

MR. CHRISTIA NSEN:

As you know,

the area --

you and I

with is the moral character of Zack.

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

-- that the Bar has expressed concern

In general,

10

have

Tha t's correct.

of.

And you ' ve had

how was Zack prior to this.

sort

last eight months of his life?

THE WITNESS:

11

12

of character .

13

to me.

Well,

this is completely out

This is -- you know,

it's mystifying

And it just simply isn't Zack.

I remember when Zack graduated from high

15

school,

16

published poet and professor of English at Reno High

J.

and,

Tom Mishare

(phonetic),

who is,

you know, a long-term MBA player,

y ou kn o w,

wr ote him the

18

most glo wing letter that I've ever read.

19

better than anything I ' ve ever had.

20

Zack that I

21

It wa s much

And that's the

remember.

Zack was a, you know,

National Merit

22

Finalist.

23

most valuable player in the Morman Triple A and a

24

com plete straight arro w .

25

anything out of line.

He was All-State in basketball.

He wa s

I mean, he didn ' t do

And his mother and J

would

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

2300 West Sahara Avenu e, Suite 770, Las Vegas, Nevada 89102

20

say,

you kno ....'.

gOing to have

other.

ever y once in a while,

0 act out a

You know,

sometime he's

little bit,

one way or the

You

the e-mails wer e appalling.

know,

I read one where he was complaining about a

professor wh o was apparently stalking some female law

students and had given Zack, y ou know,

in the class,

involved wi th the best grades in the class.

while he gave the t wo girls that he wa s

The letter wa s

10

just ridiculous.

It was beyond belief.

11

immature.

12

is going on here?

13

character. "

. 4

a poor grade

And I

It

said.

was so
"What

This is just completely out of

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

And I think we 'v e

15

concerns about that sort of stuff .

16

come through that .

17

diagnosis of an adjustment reaction is accurate.

18

think he wh o learns must suffer.

19

has learned a great from this,

20

has.

21

he has.

I think there is -- I think the

And I

think Zack

at least I hope he

And after talking with him repeatedly,

22

I'm sure

And we are very much a ware of how

23

inappropriate this stuff was.

24

And I read the brief that he wrote there.

2S

thoughL,

you kno w,

Some of it's arrogant.

And I

what are you using for judgment

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2300 l1 est Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

21

here?

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

that is flippant and immature .

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

But I can tell you,

regard .

typical of Zack.

this is not

Can you tell us -- or I

MR . CHRISTIA NSEN ,

absolutely,

Can you tell the committee members

already know.

what stress you kno w of that Zack was undergoing

during this sort of window in his life where these

10

inappropriate things were happening?

I kn o w that Zack is o ne of the

11

THE WITNESS:

12

hardest workers I ' ve ever met.

13

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

When he gets focused

He taught himself to play the pian o whil e he

14

After he gave up sports,

15

wa s in college .

16

music very intently.

And I know that

17

~n

he took up

his freshman year in law

18

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

19

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

20

And,

apparently,

And he told me that

that was one of the impetus

21

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

22

that he had worked incredibly hard and that some,

23

know,

24

wa s the only B he got that year .

25

you

behavior on the part of a professor was -- it

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

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778
2300 West Sahara Avenue, Suite 770, Las Vega s , Nevada 89102

22

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

wanted .

But the way you said i t ,

it's just nutty.

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

is ridiculous.

In t h e last t wo years,

You

know,

I've gone through a

We've now reconciled.

But I

think that

separation.

wa s a major stress o n Zack.

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

thought that financially he wa s a burden.

And,

10

in fact,

You kno w, we had three

I have spent over a

hundred

11

thousand dollars in the last three years on education

12

alone for,

13

have.

14

would we not have supported him.

15

But,

you kno w, a number of the children we

you kn o w,

he misread that.

At no time

You know, my parents took out loans until

16

they were blue in the face.

17

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

18

all four kids through graduate school.

19

occurred to me to pay a tuition.

20

ridiculous I was at that point.

21

They didn't take

It never even

That's how

And looking back on this.

y ou know.

there

22

were some periods in my life where my judgment early

23

on rivaled Zack here at this point.

24

tell you some hair-curling stories of just atrocious

25

judgment and borderline criminal behavior.

I mean,

could

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

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

23

stories.

ca n you tell us -All right.

THE WITNESS:

Rather than tell us your

MR. CHRISTIANSE N,

I'm not going to

do that.

Can you tell the

MR. CHRISTIANSEN,

committee members what improvement,

seen in your son since

do wn day Mar ch 1st,

California Bar,

if a ny, you've

well, we'll call the melt

2002.

The day after he takes the

and his car breaks down,

and he comes

10

back to Vegas and appears before these four people by

11

himself.

THE WITNESS:

12

13

of,

I think,

1;

he had w ith a girl,

the first real meaningful relationship

too.

MR. CHRISTIANSE N,

15

16

Plus there was the break up

Dr. Hunter,

have you seen a marked difference at all.

17

THE WITNESS:

18

MR. CHRISTIA NSE N:

19

Yes.
Wh at difference have you

seen?
THE WITNE SS:

20

It's more like the old Zack,

21

you know,

that I remember.

22

you know,

has some judgment .

23

immature.
change.

25

Since he's been seeing

You know,

He's solid.

He's stable,

Isn't flippant and

it's nice to have him back for a

I think we'v e gone through a very rough

pel.-iod.

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2100 West Sahara Avenue, Suite 770, Las Vegas. Nevada 89102

24

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

Yeah.

THE WITNESS:

MR. CHRISTIANSEN:

school and wor king; right?

Took the bar wh ile in-law

Right.

THE WITNESS,

MR. CHRISTIANSEN,

No w , he finished la w

MR. CHRISTIANSEN,

Passed the Nevada Bar

before he even graduated from la w school?

THE WITNESS:

That's correct.

That,

also,

10

was the difficulty of having turned in the paper was

11

sort of symptomatic of the whole thing .

12

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

13

graduate from law school,

l~

revie w,

15

You're obviously doing your work .

16

think if

if you've made the la w

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

But you put yourself in a terrible position

17

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

18

then developing all kinds of rights and privileges

19

and stuff.

20

silly .

21

way s about it .

22

you kno w, along that line that wa s

I mean,

it was j ust stupid.

just

There 's no two

But I think when you look at the overall

23

thing,

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

24

mean,

25

there without having done the work .

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

ASSOCIATED REPORTERS OF NEVAD A - 702/382-8778

2300 \'l est Sahara Avenue, Suite 770, Las Vegas, Nevada 89102

25
An d

then to wards the end of

the draft,

you kno w,

he

I'm sure he

juSt drifts off i n to being

thought he was being cute.

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

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

HR. CHRISTIANSE N:

To me,

i t ' s insulting

in lig ht

Do you have

of

you

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

10

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

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

standards he n eeds to?

THE

11

~'lI

No .

TNESS :

I kno w to an absolute

12

ce rtainty that Zack kno ws rig h t

13

very seriously_

14

thing_

15

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

from wrong.

takes it

He kno ws when he's doing the wr ong

And he has a g oo d heart.

You kno w , he's

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

16

little kid .

18

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

19

it ' s unfortunate h e picked la w schoo l

20

it b eca use he h adn't

21

him in high school and co l lege,

22

this is the most soli d,

23

ever met.

24

So this is -- I

guess this is some sort

17

25

do

And I

think

to go through

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

you would have said

stable person, you k no w,

I' v e

And then suddenly we drift off into this

thing.

But , you k no w,

I 'v e had periods like that.

ASSOC I ATED REPORTERS OF NEVADA - 702/382 -8778

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

26

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

like that .

through it without any major ,

happening here.

A lot of this is self-inflicted

damage.

it simply didn't need to happen .

But,

I mean,

fortunately ,

additional questi o n s

committee members do.

for Dr.

MR. CH AI RMAN:

thi n k we've gotten

terrible things

I d o n't think I have

MR. CHRISTI ANSE N:

Coughlin.

I'm sure the

Starting again Dr.

Bro wn?

I d o n't think so.

10

MR.

BROWN:

11

HR . CH AIRMAN,

12

MS.

13

THE WI TNESS:

14

MS . STORY:

15

THE WITNE SS ,

STORY :

Ms. Story?

Ho w many c h ildre n do you have?

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

His has

16

t wo

17

psychology fr o m Portland .

18

sister who's teaching special ed in the middle school

19

in Ren o .

20

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

21

junior year , and t wo sisters at home.

22

23

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

He ha s another older

He h as a younger brother here in Vegas

MS . STORY ,

I believe,

his

How o ft e n did y ou talk to Zack

while he wa s in la w school?

24

THE WITNESS:

25

MS STORY :

Once a week,

at least.

Did he ever express Lo you oc did

ASSOCIATED REPORTERS OF NEV ADA - 702/382-8778

2300 West Sahara Av enue , Suite 770 , Las Vegas, Nevada 89102

27
1

you ever pick up from him the stress and the

financial problems he was having?

THE WITNESS:

Yeah.

first year when he was,

And I

-- especially

the,

with the professor who has subsequently. apparently.

left the law school and did -- I mean,

kind o f unusual

it was a very

I kno w from running a large group

you kno w, when you accuse somebody of

10

sexual harassment,

11

charge .

that ' s a very, very serious

And I said to Zack,

12

in conflict

very scary sort of thing.

I mean,
practice that.

apparently,

I don't know what you're

There's only two things that ca n

13

thi nking about.

14

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

15

dealing with somebody who is probably very sick and

16

very bright,

17

of trouble .

And y o u're

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

But this being the re al world , a third thing

18

19

happened -- nothing.

20

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

21

he would have been fired immediat el y.

MS. STORY,

22
23

So did Zack pay for his o wn la w

school education?
THE vIITNESS,

24
25

So -- which astounded me

kind

of

st uff.

With a lot of loans and that

But we provided,

you know,

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

Suite 770, Las Vegas , Nevada 89102

2300 West Sa hara Avenue,

28
1

significant financial support too.

of

law school wit h a fair amount of debt.

MS.

THE WITNESS ;

MS.

But he's come out

STOR Y,

STORY ,

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

questions.

MR . CHAI RMAN:

MR.

KELLY,

MR.

CHAIR MAN:

10

THE WITNESS :

11

MR.

KELLY,

Mr.

Kell y?

No questions .

Thanks for taking your time.

You're welcome.

Thanks for reading this stuff .

12

A lot of guys come in and they give character

13

references for their kids or a good friend,

14

haven't read a damn thing.

15

it.

THE WIT NE SS:

17

MR.

21

KELLY,

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

well.

THE WITNESS:

19
20

of

Enough to get himself in a lot

t.rouble.

MR.

CH AIRMAN,

Doctor,

22

co ndu cted the first hearing,

23

become very emotional.

24

the hearing.

25

clearly, you 've read

and we appreciate the time --

16

18

And,

and they

on March 1st when we

we noticed that Zack had

And as a result, we stopped

Has Lhere ever been a similar kind o[

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

2300 Nest Sahara Avenue, Suite 770, Las Vega s , Nevada 89102

29

incident?

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

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

observed .

knowledge?

Has this occurred in the past,

THE HITNE SS :

No.

to your

That wa s very, very

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

you know,

do wn and cry in a meeting,

upset.

Zack is a pretty tough kid .

Now,

10

And to break

he had to be very,

very

depression does run in the family.

An d

And,

11

so I assume that he was stressed and depressed.

12

apparently,

13

his own and was terrified that every time he turned

14

around he was going to be incurring another legal

15

bill .

16

to do that on his o wn,

17

And,

he was trying to handle this hearing on

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

and he just wa sn ' t up to it.

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

18

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

19

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

20

admit that they were wrong.

And,

21

fortunately,

admit it.

I think he sent enough

22

letters of apology and realizes that he was just

23

flat,

24

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

25

him to have .

dead wrong.

And, you know,

it was -- you kno w,

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

Suite 770, Las Vegas , Nevada 89102

2300 \<Iest Sahara Avenue,

30

And I thi nk he had driven o v er to

his car blew up on the way over

California ,

taken

there --

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

took the Cali f ornia Bar,

You kno w,

it sou n ds like

- - well,

there,

was a three - hour hearing at that poin t.

something along that li ne .

MR. CHAI RMAN,

Well,

Is that

--

I think the last time

But we ha d taken

10

was about that lo ng,

11

several breaks to all o w Zack an opportunity to try

12

and collect himself.

13

adjourned,

14

that and allo w him t ime to collect himself.

15

Doctor.

I wasn't

And 1 guess that

but it sou nd s pretty bad.

came back f or this,

And the third o ne.

it was obvious to us that we

wh en we

needed to do

and I ' m not saying it for

T hi s committee

16

any reason other t han advising you,

17

formal title is Mo ra l Character and Fitn ess .

18
19
20

And,

Doctor , our

fran k l y, my concerns are more the

nature of the fitness , based on what I observed .

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

21

charged were doing, wh at are your feelings ab out

22

continued cou n seling or therapy wi th Dr.

23

you think that ' s advisable?

24

THE WITNESS:

25

MR.

CHAIR MAN:

Hunt er?

Do

dad,

--

Yes.
Based on being

how

ASS OCI ATED REPORTERS OF NEV ADA - 702/382-8778

2300 \'l est Saha ra Av enue, Suite 770, Las Vegas, Nevada 89102

31

THE WITNESS,

I think that's a good idea,

It ' s just -- anybody would benefit from

you know.

counseling.

You k no w, a good counselor is worth

their weight

~n

every o nce in a while.

is not worth living, and yet we careen through our

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

what ' s happeni ng to us .

wouldn't benefit from that .

gold.

And we all ought to do that

They say the unexamined life

So t h ere isn't anybody that

And I've been to counseling.

10

You know,

11

we're in marriage counseling at this point, and

12

that's been very helpful too.

13

what soever with that.

14

you

15

year is atypical.

know,

16

So I have no quarrel

But I also want to reiterate,

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

And I feel real strongly we're not dea ling

17

with any kind of underlying major psychopatholog y .

18

we ' re not dealing with somebody that's schizophrenic

19

or somethi ng like that.

20

We're dealing with somebody that has -- you

21

know,

I think the adjustment reaction idea is

22

accu r ate .

23

immaturity.

24

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

25

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

And r think there's a certai n amount of

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

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2300 West Sah ara Avenue, Suite 770, Las Vegas, Nevada 89102

32

misplaced it where he put it.

But when he wa s in high school,

the Yale

basketball coac h came do wn and intervie wed him.

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

telling him Zack was very funny.

And

And Zack sho wed up and sho wed him catatonia,

one word ans we rs,

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

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

10

a whip,

stuff like that.

And I said,

" What
And

but they're still just 17 .

11

And when somebody comes down and

12

intimidates -- you know,

13

I said,

14

going on here?"

is sort of intimidating, and

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

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

15
16

that has to do with this,

17

that sometimes,

18

wh o are still young.

19

make steel .

20

really.

What's

know what

But it reminds me

you know, you're dealing wi th people

You know, and it takes fire to

And you have to go through a whole lot of,

21

you know,

22

out on the other side with some judgment and some

23

humility.

24

here .

25

bad things every once in a whil e to come

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

MR. C}I AIR MAN :

Any further questions?

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

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

Nevada 89102

33
1

MR. CHRI STI ANSE N,

You k no w ,

and I

Thanks,

I ' ve done these a

number of times

now,

hearing me blo w a bunch of smoke,

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

respond to some qu est i o n s

think the be st appr o a c h,

Dr . Coughlin .

rath er than

is to let Zack talk

from y ou .

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

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

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

10

Mar c h the 1st.

I ' ve had Zack in my office .

11

You kn o w,

12

somebody on t he committee recommended he come see me

13

early on .

14

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

15

my office ,

16

do wn in tears t o t o day.

17

h ou r s yesterday ,

18

able to handle it.

19

And I can te ll y ou ,

where,

it ' s like loo k ing at

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

wh e re,

berated him,

you kn o w --

for t wo

and h e ' s pr etty much

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

20

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

21

just poi n t

22

the one yo u sa w the n.

23

So ,

And I

o ut that that ' s a different emotion than

Za c k,

why don ' t

y ou tell ,

in your o wn

24

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

25

in --

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

-- it's ab out three

ASSOCI ATED REP OR TERS OF NEVA DA - 702 /3 82-8778

2300 Hest Saha ra Av e nue. Sui t e 77 0 , Las Vega s , Ne v ada 89102

34

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

What have you learned

THE WITNESS ,

break for a second.

MR.

(Recess from 9:55 a.m.

MR.

CHRISTI AN SE N,

CHRISTI AN SEN :

THE WITNESS ;

MR.

12

THE WITNESS :

13

this point.

14

stuff.

15

MR.

16

hearing,

17

haven't I?

to 10 : 0 4 a.m.)

Zack ,

tell

the Bar the

I'm working at Perry and

CHR I ST IANSEN,

I ' m doing researc h and writ ing some

CHRISTIANSEN:

No w,

since this March

I've had occasion to see you in court,

THE WITNESS :

19

MR . CHRISTIA NSE N:
the re ?

Wh at are you doing there?

I suppose I'm a la w clerk at

18

21

That's fine .

Spann.

11

20

Sure.

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

9
10

the best question?

May be I could take a rest room

15

You were n' t

That ' s correct.

What were you doing over

practi ci ng.

THE WITNESS:

I was n't practicing.

wa s

22

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

23

Judge Parraguirre for some attorneys from Oklahoma

24

who were practicing with Early and Savage on a

25

medical malpractice defense .

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778

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

35

MR.

CHRISTIANSEN,

through an actual jur y trial?

THE IH TNESS,

MR. CHRISTI ANSE N:

So did you get to sit

Pretty much, yeah.

Did you do some of the

pretrial motion work?

Some of the v erdict packet.

THE WITNES S,
7

help out a lot on some of the research issues,

of that sort .

MR.

CHRISTIANSEN:
h~d

things

I wa s not here for the

10

last meeti ng you

11

transcript sho ws that you told the Bar committee that

12

you

13

stressful time in your life.

with the Bar, but your

thought taking the Bar was going to be the most

Have

y ~~

may e change d thal o pin io n?

THE WITNESS,

Sure.

I mean,

never really

16

intended to sa y that.

17

be more stressfu l than what an attorney does,

18

certainly .

19

You kno w,

I thought taking the Bar would

--

MR. CHRIST IANSEN:

You have some real life

20

experience of the stress that goes along with

2]

practicing?

22

THE WITNESS :

23

MR.

24

THE WITNESS,

25

Sure.

CHRISTIANSEN:

Absolutely .
Is it stressful?

Certai nly,

it's stressful.

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

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

2300 West Sahara Av enue , Suite 770, Las Vegas, Nevada 89102

36

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

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

stressful

developed the coping mechanisms for stress that most

attorneys have de v eloped because they have to.

at that p oint in time,

And so in that regard,

I hadn't

it was more stressful

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

practicing.
MR . CHRISTIA NSEN :

10

school in three full y ears?

11

THE vHTNES S :

12

MR.

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

and a half year s?

Two and a half years.

CHRISTIANSEN:

Too k the Bar after your

13

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

.:. 4

school;

right?

15

THE \>lITNESS:

16

MR.

Yes .

CHRISTIANSEN :

You heard about e-mails

17

and briefs and the movie incident,

18

called it , and do you have any different perspective

19

on those now after dealing with Dr . Hunter than you

20

did,

21

with Dr . Hun ter and me,

22

maybe,

as Mr . Ro we has

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

THE WITNESS,

to be honest?
Certai nly .

You k no w,
you kno w ,

the

23

further I get away from all this ,

the more

24

and more I have to cringe at reading some of the

25

e-mails and things of that sort .

Not so much in the

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

2300 i'/est Sahara Avenu e , Suite 770, Las Vegas , Nevada 89102

37

underlying actions that caused the e-mails because I

d o still su bmit that I

certainly t he way I handled it wa s completely

inappro priat e .

turned in the p a per,

And , u
yo kn o w ,

but

the furth er and further I get

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

hard to loo k at that st uff.

10

it's

Has Dr . Hun ter helped you

MR . CHRISTIAN SE N,
i n any regard?

THE WITNESS:

Ce rtainly.

I've developed

11

some coping mechanisms for stress .

12

mentioned,

13

is essential to avoiding some of the situatio n s

14

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

15
16

17
18
19

And as you

some of the self-monitoring behavior that

MR.

KELLY:

Zack ,

can you

I've

just tell me what

some of those co pin g sk ills are?

THE WITNESS ,

Well,

to try to do too mu ch .
MR.

KELLY;

I think foremost is not

You kn o w,

a good example

Do you reall y believe that have

20

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

21

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

22

accept that?

23

THE WI TNESS:

24

Unfortunately ,

25

I first met you guys.

No.

I t hink I have.

I had already -- I was n' t

able to when

I had just taken the

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2300 West Sahara Av enue, Suite 770, Las Ve gas , Nevada 89102

38
1

California Bar .
MR.

today.

KELLY,

We rememb er .

I'm o nly talking

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

I ' m tr y ing to relate to that .

THE iH TNESS:

That was probably taking on more than I should have,

trying to take that Bar.

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

that I can ' t

you know,

And if I was doing that

because I know

j ust keep pushing things until I have,

n o real energy left in my life to make the

10

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

11

wh ere I'm facing too much stress .

12

accepted that.

13

MR. CHRISTIANSE N:

14

me when you

15

Bars you wanted to take.

16

Califo rnia Bar ;

Tell them what you told

first canle and told me about how many

You wanted to take the

right?

17

THE WITNESS,

18

MR.

19

And I think I have

Yeah.

CHRISTIA NSE N;

was such a thing ,

And I didn't kno w there

but the Patent Bar?

20

THE WITNESS:

21

MR . CHRISTIANSEN :

Y eah .

An d some other Bar.

22

mean,

23

take every Bar under the sun,

24

that

you had these ideas that you were going to go

it seemed to me.

Isn't

right?

25

THE WIT NESS :

That's right .

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2300 \ol es t

Sahara Av e nue,

Suite

770,

Las

V egas ,

N evada

89102

39

MR.

CHRISTIANSEN:

Is that still the way you

see yourself -- needing to do that?

THE WITNESS,

much I can and still,

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

you kno w ,

accepting that I set some unrealistic goals for

myself.

No.

I just want to take on as

you know,

implement the coping

about -- not trying to do so much,

and things of that sort .

And sometimes when those goals aren't met,

10

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

11

critical of myself.
MR.

12

KELLY:

13

morning.

14

the wh ole day _

15
16
17

Tell me a typical day_

Tell me what time you got up.

THE WITNESS:

Oh,

Go through

got up probably about 7:00

And --

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

MR.

KELLY:

This

Do you read the paper?

18

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

19

eat breakfast?

20

to hear what y ou do.

21

22

Just give me a typical day .

THE WITNESS,

Yeah.

I get up.

I,

Do you
Do you
I want

maybe,

listen to a morning sho w or something .

23

MR.

KELLY,

24

THE wITNESS ,

25

of that sort -- or some music .

What channel?
Channel 3.

NBC or something

ASSOCIATED REPORTERS OF NEVA DA - 7 02/382-8778

2300 \1es t Sa hara Av e nue, Suite 770, Las Vegas, Nevada 89102

40
1

MR.

KELLY,

THE WITNE SS,

Yo u know,

fort.unat.ely,

come home often for lunch.

there's -- y o u know,

a re kind of calming influences.

--

And that's ni ce.

And

Those

They must be better than my

wa s going to say, mine

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

MR.

12

THE WI TNESS:

13

MR. KELLY:

KELLY,

What time do y ou leave work?

About 5:15.

Wh at do y ou do wh en y ou get

home?

THE WI TNESS,

15

I usually just relax for a

16

while.

17

actually have a fairly bad back problem,

18

tub help s with that.

19

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

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

20

MR.

21

THE WITNESS,

22

MR.

23

so I

I have a couple d o gs no w.

MR. CHRISTI ANS EN:

11

14

come

d ogs .

10

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

MS. STORY,

Okay.

KELLY,

KELLY.

and the hot

An d I wat ch some TV or , maybe,

Do yo u have roommates?
I

have o ne roommate.

Okay .

What time do you go to

bed?

24

THE vllTNESS:

2S

MR.

KELLY:

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

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

5:30,

AS SOCI ATE D REP ORTERS OF NEVADA - 702/382-8778

2300 West Sahara Avenue, Suite 770, Las Vegas , Neva da 89102

41

you hit

the hot tub .

Do y ou have dinner?

THE WIT NESS :

MR . KELLY :

THE WITNESS :

MR .

Do y ou k no w ho w to cook?

KELL Y,

What happens bet ween 7 : 00 and

THE WITNESS ,

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

something of that sort .

MR .

KELLY :

Are y ou reading a book n o w?

10

THE WI TN ESS :

11

MR.

12

THE WITNESS ,

13

I coo k right no w.

10 : 00 before y ou reti r e?

Sure .

Yea h .

What are y ou reading?

KELL Y:

Right n o w ,

just started a

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

14

MR.

KELLY,

15

THE WIT NESS :

What is the plot?

Oh ,

it.

co n ti n uation on his

"Angela's Ashes."

And

16

earlier book t hat he wrote

17

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

18

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

19

his young life .

Do y ou go to mo v ies?

20

MR .

21

THE WITN ESS :

22

MR . KELL Y,

23

THE WIT NESS :

K ELLY:

24

about a mo n th ago.

25

had a

But 1

Well , sometimes .
What ' s

the last mo v ie you sa w?

I kn o w I sa w a movie probably

When I was looking for jobs,

loL of free time on my hands .

was going to

ASSOCI ATED REPO RTERS OF NEVADA - 702/382-8778

2300 West Sahara Avenue , Suite 770 , Las v egas , Nevada 89102

42
1

movies .

MR. CHRIS TIANS EN,

THE WITNESS;

MS . STOR Y :

THE WITNE SS,

MR. CHRIST IANSE N,

Paying f o r movies.

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

members about yo ur back.

my brief .

Paying f or mo vies?

THE WI TNESS,

Tell the committee

I neglected to do that in

Well , I have a r eal k ind of

10

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

11

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

12

describe it as c hronic pain.

13

of money recently o n MRI s

l4

Beca u se I don ' t

-- it

And we 'v e spent a lot

and things of this sort .

hav e any health ins ura n ce

15

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

16

through schoo l more quickly because the student

17

healt h insura n ce

18

MRI,

19

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

20

th at just wasn' t

23

if you want to get an

they ' ll pay for about $ 200 ,

and th en y ou h a v e

to

And

t oo r e alistic then.

MR. CHR ISTIAN SE N:

21

22

you kn o w,

So was t ha t an added

stress?
THE WIT NE SS ,

Yeah.
it 's

I mean,

anybody wh o h as

I t hink everybody

24

lived with chronic pain,

25

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

And,

you

ASSOCI ATED REP ORT ERS OF NEV ADA - 702/382-8778

2300 West Saha r a Avenue, Suite 770, Las Vegas, Nevada 89102

43

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

kno w,

a good percent of y our allotted stress,

takes up

y ou kn o w.

And we 'v e r eally tried to address the

3
4

problem .

insurance.

But ,

y ou kn o w ,

it is difficul t

with out

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

shortly my insura nce will be started,

that will help.

stress.

MR.

10

11

i t

Ce rtainly,

BROWN:

and some of

it wi l l a v oid some o f

th e

Ha ve you talked to Dr. Hun ter

about the c hr o nic pain?

12

THE WI TNESS :

Ye ah,

I did.

And he

13

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

14

And I ' d like to go to h im .

15

little out of my ball park right n o w.

16

talk to him about dealing with the pa in .

17

kn o w,

Unfortunatel y,

it ' s a

But.

you know,

A nd ,

y ou

it's a mystifyi ng thing to me.

And he tried to giv e

18

to be honest,

he

19

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

20

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

21

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

22

people tel l

23

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

24
25

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

but

you kn o w

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

iL , and I

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

ASSOCI ATE D REP ORTERS OF NEVA DA - 702/382-8778

2300 West S ahara Av e nu e , Suite 77 0 , Las Vegas , Nevada 89102

44
1

MR. BROWN;

Is it allover in your back?

THE WITNESS:

mid-thoracic problem .

of neck pain.

be a pain from a neck problem

showed something like three bulging discs in my neck

and then a bulgi ng disc in my back.

think structurall y that ma ndated a surgical

intervention .

It's pretty much a

Bu t

I also have a fair amount

And some of the doctors think it might

And some of the MRIs

And they didn't

10

But we have a s p orts a lternative way of

11

addressing the problem, such as therapy and some

12

alternative treatme n ts in additio n to the physical

13

measures of , you kno w, ice and massage and

14

chiropractic.
MR . BROWN:

15

THE WIT NESS:

17

What helps the most?

Exercise helps.

Not sitting

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

MR.

18

BROWN:

What were some of those - -

19

Dr. Hunter and you both mentioned that you were

20

beginning to do self-regulation or to do

21

self-monitoring of your behavior of your feelings.

22

Can you tell me what t hat means.

23

THE WITNESS ,

Well , I think,

to a certain

24

extent,

self-monitoring starts with having the time

2S

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

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

45

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

really too close t o things to see what they really

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

accomplish less,

realistic goals and thus enable me t o,

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

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

morning and read that again.

10

trying to do less, set more

y ou kn o w,

You kno w ,

kind

things of

that sort.

MR.

11

CHRISTIANSEN:

The e-mails,

in

12

hindsight, do you have any doubt that they were

13

inappropriate?
THE

~olI:'NE SS;

15

16

inappropriate.

say.

cringe when I

MR.

17

18

fiasco?

19

right?

No,

n ot at all.

r ead them.

CHRISTIANSE N :

:;: mean,

like

So I know they are

Ho w about the movie

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

20

THE WITNESS:

21

MR.

22

THE WIT NESS ,

23

MR.

24

ultimately dismissed?

25

THE WITNESS :

Abs olutely .

CHRISTIANSEN:

And not run from people?

Yeah.

CHRISTIANSEN:

And that case was

That's right.

ASS OCI ATED REPORTERS OF NEVADA - 702/382-8778

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

46

MR. CHRISTI ANSE N,

No charges?

No

convict.io ns?
That's correct.

THE WI TNESS:

MR. CHRI STI AN SE N,

The Stratos paper -- you

read the brief that I submitte d,

Amy Jones?

and -- is it

Yes .

THE WITNE SS ,

MR. CHRISTI AN SE N,

And Amy Jones signed an

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

10

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

11

Bar committee,

12

correct?

and y o u've turned in the paper;

13

THE WI TNESS ,

14

MR. CHRISTI AN SEN :

Yes .

An d t h ere was an

15

investigation into Professor Stratos giving you a

16

grade suffici ent to gra dua te?

17

THE WITNESS:

18

MR . CHRISTIANSE N :

That ' s correct.

Similarly , any of the

19

investigations or incide n ts at the la w school.

20

of

21

dishonesty or dishonesty of any sort;

22

correct?

them resulted in a ny finding of academic

23

THE WI TNESS ,

24

MR . CHRISTIANSEN :

25

none

is that

That ' s correct.

You were asse ssed one

time a hundred dollars for moving a computer you

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778

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

47
1

used,

and that hundred dollars was the money that the

staff

incurred in putting it back; right?

That ' S correct.

THE WITNESS,

MR. CHRIST IANSE N:

And part of what I

submitted is stuff that the school -- the Boyd School

of

apology letters you wr ote to the of fen ded parties

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

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

THE WIT NESS:

T h at ' s co rr ect.

MR. CHRISTI AN SE N ,

10

Di d y o u wr i te the

11

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

12

Mr.

13

e xtend ed vacation.

Stratos to be h ere.

14

He ' s i n Euro p e on an

Did you write the letter before you got the

l~

passing grade or after to say thank you for giving me

16

the pasSlng grade?

THE WIT NESS :

17

18

before I got the grade i n the class .

MR. CHRISTI ANSEN,

19

20

I wrote it se v eral months

So you had at least some

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

21

THE WIT NESS :

22

MR. CHRISTI AN SE N:

Sure .
And all of t h is stuff,

23

Zack,

:4

Ms. Eichman and sending her e-mails?

2S

that happened , were you timely rep orti ng it to

THE WITNESS ;

Yes .

I think I wac.

ASSOC IATED REPORTERS OF NEVA DA - 702/382-8778

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

48

MR. CHR I STIANSE N,

hide the misdemeanor charge?

THE WIT NESS,

MR. CHRISTI AN SE N,

Did y ou make an effort to

No,

not at all.

And they were ultimately

dismissed?

THE WITNESS:

Within a wee k of the charge .

academic investigation being conducted on me.

the incidents at the la w schoo l,

10

notified Ms . Eichman of that as well as having an

Any of

I notified the Bar

of.

MR. CHRISTI AN SE N,

11

An d those are -- I've

12

attached eight or nine exhibits to this brief.

13

those part of these exhibits?

'.

THE WITNESS:

That's correct.

Were

And in

1~

addition,

16

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

17

so mething wr ong, and I don ' t

18

movie theater people were entirely sure what I had

19

done wr o ng.

20

r had snuck into the movie theater.

21

Bar that,

22

I was pretty forthright with t h is arrest.

think the police or the

And I was fo rthri g h t

a nd told them that

And I told the

too.

MR. CHRISTIANSEN:

I read in y our

23

trans cri pt

24

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

25

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

and I know that I think it raised a

"a case of

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778

2300 West Sahara Av enue , Suite 770 , Las Vegas, Nevada 89102

49

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

You're not sa y ing

Yo u sneak into the movie .

that .

that was a mistake?

THE WITNESS,

No .

Th a t's correct.

into the movie.

step o ut side and talk to them .

choice and ran ou t of the the ater.

think it was mistaken identit y is they c hased after

me for half a mile,

10

to snea king

y o u kn o w,

to

And I made a poor

and that didn' t

Th e reason I

seem commensurate

into a theater .

And,

11

and then they asked me,

I snuck

subsequently,

learned that they

12

thought I was somebody who had apparently committed

13

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

MR . CHRISTIANSEN,
THE WITNESS;

15

Previ ously?

Previ o usly.

I ' m no t

Within the

16

procee ding months.

sure what the i nfr action

17

was.

18

candy or so mething or maybe something more serious,

19

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

20

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

21

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

22

wasn ' t me.

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

23

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

"4

proceed further with any investigation.

2S

regard,

So in that

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

ASSOCI ATED REPORTERS OF NEVADA - 7 02/382-8778

2300 West Sahara Av e nue, Su ite 770, Las Vega s , Nevad a 89102

50

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

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

theater.

MR. CHRISTIA NSEN,

o kay ?

THE WI TNESS,

MR. CHRISTIANSEN,

Nor running?

THE WITNESS:

That's absolutely a poor

11

MR. KELLY:

No.

Wh at kind of la w does this firm

practice?
THE WITNES S:

12

13

Not at all.

judgme nt o n my part.

10

.;.

Your sneaking In is not

Insurance defense litigation,

primarily.

.,

MR.

KELLY:

THE WITNESS:

15

16

and Chuck Spann.

17

Las Vegas .

Tel! me the name again.

Perry and Spann.

Victor Perry

There's an office in Reno and

18

MR. KELLY :

19

THE WIT NE SS:

How big is t h e firm here?

There ' s about five attorneys

20

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

21

Reno.

22

23

MR. KELLY,

What is the prospect for full

employment should you pass the Bar?

Has that bee n

discussed?
25

THE WITNES S :

well.

1 've told the

firm of my

ASSOCIATED REPORTERS OF NEV ADA - 702/382-8778

2300 West Sahara Av enue, Suite 770, Las Ve gas , Nevada 89102

51
1

situation with the Bar.

employed right no w.

An d I think I ' m fully

MR.

CHRISTIANSEN,

MR.

KELLY:

TheY've called me .

I was thinking y ou hadn't taken

the Bar. but he's already passed.

THE WI TNESS,

I'm fairly certain

hope I

get admitted so they can utilize my skills as an

attorney.
MR.

10

KELLY:

What kind of salary are you

making now?

THE WITNESS:

11

You kn o w,

l2

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

13

first pay day.

MR.

14

15

to night?

and today is the

How about going to a movie

Min o rity Re por t?

THE WITNES S :

16
17

KELLY,

I'm not really sure.

Yeah.

That looks like a good

movie.

18

MR.

KELLY:

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

19

read this last time

20

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

21

was certainly bu sting your chops pretty heavy, a nd

22

t hat wasn't my intenti o n.

23

I read the transcript.

and I

because I

But there was a question that I asked at the

24

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

25

suggest?

Wh at ' s going o n?

ASSOCI ATED REPORTERS OF NEVADA - 702/382-8778

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

52

Now,

Rob Hunter may have ans we r ed it --

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

3
4

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

Dr . Hunter will be used and not just some smoke

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

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

7
8

whatever it ta ke s .

record,

10
11

today .

Yo ur hi s t o ry, your academic

your a c hievements,

you've excelled at

everything you've done.

But every single one o f us reach es a point

12

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

13

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

14

can d o that.

15

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

16

mean,

You

there 's no quest ion in my mind.

jus t want to be sure.

just want yo u to

17

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

18

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

19

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

20

do in t h e past?

21

for help."

22

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

THE WITNESS:

23

wou ld ask for help .

24

through this again.

25

MR.

What ar e you

KELLY:

Sure.

Yes .

Certainly .

"Ask

I ce rtainly d o n ' t want to go

You ' re not afraid to -- you

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

Las Vegas , Ne v a da 89102

2300 West Sahara Av enue , Suite 770,

53

wouldn't be afraid to pick up the phone?

help.

MR. CHRISTIANSEN,

Have you

How about me?

called me?
THE WITNESS,

And I have asked for

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

No.

THE HITNESS:

you

I' v e certainly called

Yes .

asked for yo ur cou nse l.

MR . CHRISTIANSEN,

Dr . Hunter ?

THE WITNESS:

Yes,

have.

And I've really

10

utilized wh at we talk about in our meetings .

11

been a very good i n fluence.

MR . KELLY,

12

Do you have -- who is your best

13

friend in the practice of la w?

14

may not yet.

THE WITNESS:

15

He ' s

Do you have one?

You kno w,

unfortunately ,

You

the

16

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

17

work at a firm to develop some contacts,

18

have been beneficial.

So I certainly like and respect the peo ple

19

20

in my firm that I work with.

21

a ware of my situation.

22

keeping an eye me,

23
24
25

which wo uld

You kno w,

they're fully

So I think they ' re probably

y ou kno w .

MR. CHAIR MAN,

Who is the supervising

attorney?
THE WIT NESS ;

gues~

it would be

ASSOCIATED REPORTERS OF NEVADA - 702/382 - 8778

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

54

Alan Westbrook.
MR.

THE WITNESS,

He called me.

CHRISTIANSE N:

An d I think Vic Perry is

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

there .

And I've developed contacts

of keeping an e y e on me .

Some attorne y s that -- Carl LeBare

in Reno n o w.
7

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

kno w,

up in Reno .

whose counsel I can request.

10

MR. CHAIRMAN:

11

THE

12

MR . CHAIRMAN:

WIT NESS :

He's an attorney

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

13

member s of the firm are knowledgeable of your current

14

status with the committee and with the Bar?

16

Yes.

THE WITNESS:

15

That's right.

That's

correct.
MR. CHRISTI AN SE N:

17

ca n tell the committee

18

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

19

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

20

investigation .

21

him wa s e xactly wha t

22

hasn't bee n sugarcoating anything for him.

He told me what information

Zac k had told him.

23

MR. CH AIRMAN ,

24

MR.

25

BROWN:

gave

So Zack

Do you hav e any questions?

I already asked what I was going

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

2300 West Sahara Avenue,

ss
MR.

CH AIRMAN,

and I

Zack,

counsel,

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

<1

woun .

apologize ,

1'm interrupting

but I want to ask you to

Dr. Hunter told us that you described your

~ontact

I woul d use that term myse l f.

as I

concern for us without regard to wh ether you were

10

on March 1st as appalling.

said then,

I d on 't kno w that

I would certainly say,

that this caused a great deal of

applying for the Bar or not.

11

We , as I mentioned to your dad,

are charged

12

not onl y with the obligation to advise and recommend

13

to the Supreme Cou rt

14

such as the movie th eate r

's

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

on moral characteristic issues,

incident or library

whether the person is fit to practice law .

17

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

18

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

19

melt do wn,

20

Ho w do you perceive t hat?

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

THE WITNESS:

21

Well,

I just see it as

22

something that doesn't necessarily reflect my ability

23

to represent clients.

"4

to represent myself in front of this committee.

25

you know,

I think it reflects my ability

But,

there ' s a longstanding saying that the

ASSOC IATED REPORTERS OF NEVADA - 702 /382-8778

2300 West Sahara Avenue, Suite 77 0 , Las vegas, Nevada 89102

56

la wyer who represents h imself is a fool or something

of that regard.

MR . CHA IRMAN:

an idiot for a la wyer.

THE WI T NESS;

You kno w,

Something like that.

Yeah.

I mea n - -

MR . CHAIRMAN:

T HE WI TNESS,

Has a fool f or a client and

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

I went down there , y ou kno w,

10

there,

11

of

12

in flea-bag mote l

13

California Bar,

14

year -- i t was a really brutal test

15

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

16

17

it died,

I drove my ca r down

I had to get it towed in the middle

the night and rent a car and then stay,

MR.

you

know,

for three days and take the

wh ich had a 33 percent pa ss rate that

and then drive

Did you come back

CHRISTIA NSEN:

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

18

THE WIT NE SS :

19

MR . KELLY:

Yeah.
Was it the night before?

20

thought you drove up that day.

21

THE WITNESS:

No.

I drove ba ck that night

22

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

23

So I know it looks li k e --

24

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

25

able to represent clients e ff ectively .

I kno w my reaction in that

I would be

And I don'c

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

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

57

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

MS.

STOR Y:

THE WITNESS ,

MS . STORY,

THE WITNESS ,

Did it cause y ou concern,

Certainly.

Cer tainly.

Zack?
it did.

Wou ld you d o it differently?

Yes , I

wou ld.

wasn't

chinking really c learly.

I was very he sitant -- I

didn't have any money,

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

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

10

of the hearing or del ay it until sometime after che

11

California Bar until

12

something of that sor t.

for one thing .

I didn't even
I

was able to get an att or ney or

13

So.

14

differently.

15

lot easier by getting you a prehearing brief wi th all

16

t he apologies and th ings o f that sort.

17

yeah.

18

certainly,
I

mean,

MR . CHAIRMAN '

I would have done it

I co uld hav e made your job a

And.

so,

My a s s es sme nt of y ou on

19

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

20

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

21
22
23

THE WITNESS:

Zack.

The apologies hadn ' t occurred

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

For wha tever reason .

And you

24

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

25

cou ns el has described it and everybody has said you

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

58

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

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

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

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

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

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

y ou to continue with the counseling and receive the

help that you've obviousl y already gotten to impress

10

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

11

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

12

sure th at instead of a broken do wn car,

13

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

14

in a shortened time ; and instead of the Californi a

15

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

16

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

17

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

18

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

19

trial.

to be

y ou got a

20

21

one of us .

22

you practice law .

23

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

24

my life and said ,

25

mea n,

And

this stuff happens t o each and e v ery

This happens every day of every week that

An d I guarantee you , there are

"Man, that was an easy tim e . "

want

you

to understand ,

we

hdvt:

ASSOCIATED REPORTERS OF NEVA DA - 702/382-8778

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

59

concern about that. we are required to investigate

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

Accordingly,

I'd like your reaction t o us

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

if the res t o f

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

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

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

q~alified

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

to provide the counseling to ensure that

10

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

11

What's your reaction to that?

12

THE WITNESS:

13
4

I'd say , y o u know,

Well,

I'm amenab le t o that.

I think that ' s fine.

any problem with that.

I don't hav e

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

I think so me of my

J5

prac tice law as I am right no w .

16

emotional reaction today has more to do with,

17

kn o w,

18

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

19

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

yo u

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

20

And I think an un co nditi onal admittan c e

21

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

22

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

23

com ply.

~4

able to afford Dr. Hunter.

25

Certainl y,

I ' ve enjoyed Dr . Hun ter .

MR. CH AIRMAN:

I'll be

Let me assure y ou something.

ASSO CIATED REPORTERS OF NEVADA - 702/382-8778

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

60

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

bet ween us and the committee .

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

your license,

any such agreeme nt if one is reached.

There is no red

and no one is certa inly made a war e of

Your license. assuming they print it the

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

as mine.

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

This wo uld be a confide ntial thing.

MR.

10

Let me just add somet hing.

KELLY,

- - particularly.

11

feel as if,

when a

since I practice

12

i n Vegas --

that somehow after a hearing like this.

13

when an appl icant sees me,

]4

can assure you tha

]5

in this room,

16

outside this room and say something to you about

17

these hearings.

they run away fr om me.

what happens in this r o om stays

that I would never ever meet you

That ' s never going to happen.

So what the c hair is saying,

18

I echo it

19

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

20

fear not.

21
22
23
24
25

THE WITNE SS :
would happen at all,
MR.

So

I really didn't think that

you kno w .

CHAIRMAN:

interrupted y ou .

I'm

sorry, Cou n sel.

MR.

CHRISTIANSEN,

That's all right.

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

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

61

I probably distracted you

MR. CHAIRMAN:

from where you we re going.

anything further.
MR.

long .

back.

KELLY,

But you're wel come to ask

He can ' t hold a thought very

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

MR.

CHRISTIANSEN,

This is all true.

have

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

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

10

interest to let yo u folks ask the questions.

When I read the transc ript,

11

12

Kevin did

13

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

14

lawyer so he just beat you up until it happened.

15

I commend him for d oing that.

~t

on purpose.

I told Za ck that

Kevin was just mean to y ou

And

And I think you had a young man before you

16

17

that was emotional ly distraught.

18

as tight as a drum.

19

he's made mar k ed improvement since then.

20

He was just wound

And I think he's made

I know

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

21

on a pro bono basis.

22

because somebod y on this committee thought I could

23

help him.

24

initial point,

2S

to me and more from talking to Dr . Hunter.

I was just going to do it

And however crazy that thought is on its

I think he has benefited from talking

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

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

62

He is somebody that on day one I could make

cry with a sente nce.

And I prepped h im for this

thing yesterday, and he ' S a different kid,

man, different lawyer.

I think -- not that wha t

different

I think carries

he will , if ordered to continue o n

much weight -- bu t

with Dr. Hunter, do that.

here,

uncond it ional admission to practice la w .

I have cited t he la w

~n

and legally I believe he's entitled to an

He's not

10

going to fight a conditional admission.

11

candidly,

12

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

13

say don't do

14

MR.

KELLY:

15

MR.

CHRISTIAN SE N:

if y ou tell him

Hunter,

don't

it.

I told you he wo uld

16

more of your time either.

17

wind ed.

18

agreement pending the end

ake the

I ' m not going to take any

I ' ll try not to be long

If that is something that is a tentative

MR. CHAIR MAN:

19

to see Dr.

And .

I need to clarify mys elf ,

20

Counsel.

21

have no t discussed with my fellow members at all

22

about the disp osit ion of this matter.

23

Those are my thoughts o n the matter.

I think we all agree as to wh at happened on

24

March 1, but we need to deliberate a little bit

25

further about this .

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

63

MR.

CHRISTI ANSEN,

I'm happy to -- if any

member of this committee ha s areas o f concern that

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

practice law,

able to address them.

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

A co nditi o n al admission,

he 11 live with and

I

But if so meb ody

pro bably, can didly,

sitting is h e re v oting thumbs do wn.

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

10

benefit from.

I'd like t o hear

like to address it.

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

11

12

the transc ript

13

tried to address them with the witness here tod ay.

MR.

14

in my brief.

KELLY,

and 1,

you

kno w ,

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

15

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

]6

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

f'.m. CHA I RMAN :

17

18

Apr11,

Remember ,

MR.

KELLY;

20

MR.

CHRISTIANSE N;

21

MR.

CHAIRMAN,

anybody

I tri ed that in

I thi nk y ou ' re covered.

Thank y o u.

Do you have any o ther

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

23

MS . STORY ,

24

MR.

25

Can you

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

19

22

have

We need the tra nscr i pt.

CHRIST IANSEN,

I promise.

He ' s g o ing to

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

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

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

64

it around.

MR. KELLY:

Let him get his paycheck.

MS.

Yeah.

MR. CHRISTIANSEN:

I think he' s

go~ng

on

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

MR. CHAIRMAN,

I think they charge for

that.

STORY,

it a we ek

from today.
MR. CHRISTIANSEN:

At this point,

MR. CHAIRMAN:

10

Yes.

11

will be close d,

12

in wr iting pretty quickly.

the record

and my recommendations will come out

13
14

( Exhibits 4 ,

5.

and 6 were marked for

15

identification and are at tached hereto.)

16

17

(The State Bar Hear ing concluded at

18

10:43 a .m. l

19

---000---

20

21
22
23

24
25

ASSOCIATED REPORTERS OF NEVADA - 702/382-8778

2300 West

Sah ara Avenu e ,

Suite

770,

Las Vegas.

Nevada

89102

65

1
2

REPORTHR ' S CERTIFICATE

STATE OF NEVADA
55 .

COU NTY OF CL ARK

I , Linda Horto n Sprague,

a du l y

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

Nevada ,

do hereby ce rtify:

That I re p orted the State Bar Hea ring

commenci ng on F riday, June 21,

2002 , at 9 :11 a .m.;

That I t hereafte r transcribed my said

10

shortha nd n ot es into typewriting,

11

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

12

complete,

13

shorthand n ote s.

14

true,

and that t he

a nd accurate transcripti o n of said

1 further ce rtify that

am not a

15

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

16

of th e parties,

17

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

18

person fi nan ci ally interested in the action.

19

no r a relative or employee of a ny

I N WITNESS WHEREOF,

I hav e hereunto set

20

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

21

Nevada,

t hi s 16th day of Jul y,

nor a

State of

2002.

22
23
24

'-f \

'""

\,

,
~ ,;.-

, ..

.'

..,

,.1'
-, .

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

/' I

4 66

. 0

25

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

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

......lbon of State Bar Hearing

Re: Zachary B_ Coughlin

WORDINDE)t

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

600 1:19

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

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

<8>
8 39:16 42:19

:12,13 21:4 35:2245

8:17

:20 50:8

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

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

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

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

academic 46:20 48:8

52:8

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

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

30th 4.7
33 56:13

accepting 39: 7 43:2

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

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

anybody 26: 1 31 :2,8

42:2363:15

absolute 25:11
Absolutely 13: 11 17

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

:1 16:24 23:8 28:21

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

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

answered 16:14 52:1

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

apologies 6: 1 57: 16,

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

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

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

addition 7:1644:12

48:15

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

22:2 31 :22 65:12

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

appreciate 8: 13 9:25

16:9 17:22,24 18:1 2

8:15

appreciative 15:22
ago 41:24 42:11 54:1 approach 33:3
April 5:11 10:9 63:1
8 60:7
agree 62:23
8
area 19:5
agreed 9:6
agreement 60:5 62:1 areas 4: 12 63:2,11
arises 17: 10
8
arrest 48: 15
Alan 54: 1
arrives 41:18
alliance 13:5
arrogant 20:23
allotted 43:2
arrow 19:24
allow 29:230:11,14
Ashes 41:16
alternative 44: 10, 12
asked 5:21 6:2,16 4
amazing 28:4
9:5 51 :23 53:2,7 54:
amenable 59: 12

8,24
amount 12:14 13:21

asking 9:21 17:21 5

28:2 31 :22 44:3

Amy 46:6,8
Angela's 41:16

8:13
assessed 46:24
assessment 57: 18
associate 18:25
Page I

~-u.o-

,,,cd ReporterS of Nevada

Depoeltion of Stale Bar H

"""".

29:11
aSSumed 7: 19,21

60:14
~~:i~~~:~~:59:2560:6,9
27:19
40:10
atrocious 22:24

attach 5:12 7:21

attached 3:25 4:24
5:2048:1264:15
attempted
6'2047'1
1
..

Re: Zachary B Caughlin

1 48:9,21 50:23 51. ,

54:14 55:10 56:13 5
7:11 58:15 64:17 65:
1
Bars 38:15
Bar's 13:23
based 15:20 30:19,2
5
basis 61:21

basketball 19:22
59:18
attention 12:10
beat 61:14
lIal~orney 35:1751:8
bed 40:23
53:24
57: 11 65: 1 beginning 44:20
5,17
behavior 21 :23 22:2
13:22 34:2 537:1239:544:21
36:5 50:19 54:6
belief 4: 11 20: 11
16:4 29:24
believe 8:5,8 12:24
31:
26:20 37:19 59:14 6
auto 12:12
2:8
avoid 43:8
belong 10:20
avoiding 37: 13
beneficial 53: 18
20:22 53:21 6 benefit 31:2,9 63:7
benefited 61 :24
12:7,17,1 berated 33: 17

Axis 10:14,14,18,20,2
1,22,2411:4,11,12
<B>

Ilb"ck 9:11 22:21 23:1

0.23 25:7 30:3 40:17
42:7,1044:1,7 45:7
56:15,16,17,21
""O:,,'J 61:6
30:6 32:21 40:1
7
bag 56:12
ball 43: 15

best 20:9 33:3 34:2

53:12 61:9
better 11:25 12:19 1
5:23 16:25 19:19
beyond 20:11
bi9 10:20 32:9 50:1

Bill 6:1929:1542:1
9
bit 13:2 20:2 48:24
59: 19 62:24
blew 30:2
blind 12:16
blow 33:4
blue 22: 16
board 15:24
BAR 1:163:4 4:6 7:2 bono 61 :21
book 41:9,13,16
8:21 9:17 13:21 1
borderline
22:25
15:23,24 18:17,2
Boulevard
1:19
19:6 23:9 24:4,7,1
Boyd
6:4
7:24
47:5
30:3 34:7 35:10,11,
162536:1238:1,6,1 brand 6:3
6:19:21,2346:11 47:1 brat 22:1

break 23:12 29:7 34

:4
1breakfast 39:19
breaks 23:9 3D: 11
brief 3:25 4:24,25
08:16,189:4 20:24
42:846:548:1257:1
5 63:12
briefs 36:17
bright 27:16
broken 58: 12
brother 26: 19

:24 49:25 58: 18

cases 7:9,9
catatonia 32:6
caught 17:2 44:25
cause 57:2
caused 37: 1 55:8 5
6:24
CCR 65:24
certain 5:1 31:2244
:23 51:6 52:3
certainly 35: 18,24 3
6:22 37:3,10 43:8 51
:21 52:22,23 53:6,19
55:7 57:3,3,13 59:23

Brown 3:19 9:17 14:1~1l)0:4

4 26:9,10 43:10 44:1, certainty 25:12
5,18 54:24
CERTIFICATE 65: 1
brutal 56:14
certified 8:6,9 63:25
bulging 44 :6,7

certify 65:6,14

bunch 33:4

chair 60:18

burden 5:48:17,19,2

4 22:9

Chairman 2:3 3:2,

14:5,195:7,156:9
busy 4:13 9:5 17:23 8:4,16 10:3 14:22 15
:4,12 16:9,12 26:9,11
<C>
28:7,9,21 30:9,25
C.C.R 1:25
553:2354:10,12,23
55:1 56:3.7 57:18,23
California 23:930:2, 59:2560:2361:1 62:
38:1,1656:1357:11
963:17,2164:7,10
58:14
chance 18:2 19:8
call 4:10 9:6,9,11 10 change 23:24
:18 13:1,5 14:17 1
rctlan!ged 35:14
23:7 54:7
channel 39:23,24
called 18:12 34:22 3
6:1841:13 51:3 oo:o,~ character 8:23 19:7,
54:2,18
220:1328:1230:17
calming 40:6
characteristic 55: 13
candidly 62: 11 63: 7
candor 16:9
characterization 15:
candy 49:18
3
captain 17:5
car 23:9 30:2 56:9,1 charge 27: 11 48:2,6
1 58: 12
64:3
care 3:22
charged 30:21 55: 11
careen 31:6
charges 6:23 46: 1
Carl 54:6,10
Charleston 1: 19
carries 62:5
chart 15:8
case 34:22 45:23 48 chase 50:1
busting 51 :21

Page 2

ASStKlatcd Rcponcrs of Nevada

.u

"

Rc: Znchary 8. Coughlin

49:8
10:1
6:19
22:12 26:12
44:14
49:7
59:7
51 :21
2:7 3:1
74:4,18 5:166:11 8
:14.179:3,14,1610:6,
3 11:13,17 12:2,21 1
3: 7.12 14:5 17:20,21
18:3.6,15 19:2,5 21:6
23:1,5,15,1824:1,4,7
25:6 26:6 33:1 34:5,7,
1.15,1935:1,4,9,19,2
3 36:9,12,16 37:8 38
13,18,21 39:1 40:9
:2,6,21 45:11,17,21,
3 46:1,4,8,14,18,24 4
,10,19,22 48:1,4,1
1,22 49:14 50:4,7 51
:3 53:4,8 54:2,17 56:1
660:2561:762:15
1,20,24 64:5,9
chronic 11:342:12,2

443:1,11
Chuck 50: 16
circumstances 11:8
cited 62:7
clarify 10: 15 62:19
CLARK 65:3,5,20
class 20:8,9 47:18
clean 11:11
clearly 5:7 8:22 12:6
16:20.20 28:14 29:24

49:21 57:6
clerk 34:12
client 56:3
clients 55:23 56:25
client's 61: 9

close 15:9 45:2

closed 64: 11

17:6
32:3
12:1 5
30:12,14

college 21:15 22:8

25:21

conducted 14:25

come 7:8 9:20 20: 1

2 48:8

628:1,1232:21 33:1

confident 10:10
confidential 60:8
conflict 27:4
confusing 48:16
conservative 14:1
consulted 4:9
consults 13:23
contact 55:6
contacted 6: 18
contacts 53:1754:5
context 12:18
continuance 57:9
continuation 41: 15

240:2,442:1956:15,

6 64: 11
comes 11:11 23:9 3

2:11
coming 10:8
commencing 65:8
commend 61:15
commensurate 49:9
comment 55: 15
commissioned 65:5
committed 49: 12,20

company 10:2
complaining 20:5
complete 19:24 65: 1

2
completed 58: 17
completely 19: 11 20

:12 37:3

:1940:5
course 7:13
Court 5:11 18:16,19

34:16 55:13 58:15 6

3:15
covered 63:19
crazy 56:8 61 :23
crime 49:20
criminal 7:9 22:25
cringe 36:24 45:15
criteria 10:25 17:15,

Committee 3:4,18,21

34:98:29:1,17,22
13:15 14:7 18:18,21
21:723:6 26:8 30:15
33:12,24 34:8 35:11
42:646:11 54:14,17
55:24 59:5 60:2 61:
2 63:2
committee's 3: 7
commonly 10:24

counselor 31:3
COUNTY 65:3,5,20
couple 9:4 14: 16 16

cont inue 58:8 59:6,9

62:6
continued 3:3,8 30:2

2
conviction 7:2
convictions 46:2
convinced 8: 22
cook 41 :3,4
cooperating 7:9
coping 36:4 37:11 ,1

6 38:3 39:4 52 :4

critical 39: 11
cry 29:8 62:2
cumulative 16:4
curling 22:24
current 13:24 54:13
cute 25:3,5

< 0>
D.A.'s 7:4,12
dad 30:25 33:8,19 5

5: 11 57:24
damage 26:5

copy 4:25 7:24 8:1,7, damn 28:14

dated 4:7
24: 17 46 :10 63:25
corner 40: 10 60:3
day 23:8,8 39:12,14,
correct 4:4,17 6:7,8
19:4 24:9 34:18 46:3, 9 51:13 56:20,22 58:

complicated 42:10
comply 59:23
computer 46:25
concern 15:15 19:6

2,17,22,23 47:3,8,9 4
8:14 49:4 54:16

48:24 51:18 52:3

56:24 57:2 59:1 63:2

Coughlin 1:6 2:6 3:9

5:18 6:2,20 8:14 9:1

8,21 62:1 65:21

days 16:18 17:2 56:

o 18:7,11,15

2 58:23
dead 29:23

26:7 33

:1

deal 12:3 13:9 27:16

Coughlin's 8:3 15:2

33:9 43:19 55:8 59:4

concerns 4: 11 20: 15

25:8 30:18

counsel 3: 17 4: 10, 1

dealing 11 :1927:15
31:16,18,2032:1736
:19,2043:16
dealt 6:20 12:5 33:1

concerned 15: 18

concluded 64:17
conditional 59:22 62
:10 63:6
conduct 15:5

4,23 8:25 9: 1 53:7 5

4 :8 55:2 57 :25 60:24
62:20 65:15,17
counseling 30:22 31
:3,10,11 58:8 59:6,8

4
Dean 4:11,15 21:21

Page 3

..

\I

Stale Bar Hearing

Rc: Zachary B. Coughlin

28:2
lldeclde 58: 7

dismissal 6:23 7:3,1

~~~~~en~21:3
38:10
34:25

kh

16:6
0
62:24
8: 1

II~::~:~::~~.1

17:15
II1I~::;r~~~=~~g 29:11
depression 29:10
deputy 6:19

describe 15:4 29:1,2

42:12
described 55:5 57:2

4.24,25
desk 44:17
destroyed 7: 7, 12
detail 14:24
develop 11:18,1912

:3 53:17
developed 36:4,5 37
10 54:5
lie,'elop,ng 24:18
diagnosis 10: 17,22

11'1,4,6,920:17
diagnostic 10: 14
died 56:10
difference 23:16,18

12:1633:8,1
4,21 36:18 62:3,3,4
16:7 52:1
9 57:4,14

II":::~~::~43:4
24:10
dinner
:1
directly 15:8
Director 2: 11 5:22 8

:8
disc 44:7

44 :6
10:24.
"
15:3
.. : : : : : 46:21,21

excelled 52:9
early 10:9 22:22 24:2 exception 13:25
33:13 34:24
exceptionally 28:17
dismissed 7:2,4 45:2 easier 57:15
exercise 42:4 44:16
4 48:5 49:23
East 1:19
disposition 62:22
easy 58:24
Exhibit 3:23 4:1,5, ,
distracted 61: 1
eat 39:19
1,23 5:9
distraught 61: 17
echo 60:18
exhibits 4:24 5:1 48
ed 26:18
:12,1364:14
Doctor 10:3,6,13 14:1
exists 15: 16
2 15:15 16:10 18:3
education 22: 11 27:2 expectation 14:19
28:21 30:10,16
3
expectations 17: 18
doctors 17:1544:4
effect 49: 17
experience 11 : 10 35
documents 5:19,21
effectively 56:25
:20
6:6,13,21,22 63:22
effort 6:14,18 7:164 explain 14:24 49: 1
dogs 40:5,8
8:1
explained 48:25
dOing 17:19 24:15 2
express 26:25
5:13 27:20 30:21
1Eichman 5:25 6:8,15 expressed 19:6
1,13,19 38:6 45: 1 61 7:22 9: 7 47:24 48:7
extended 6:24 47:13
:8,15
eight 19:10 22:17 4
extent 44:24
dollars 22:11 46:25
8:12
eye 53:22 54:5
47:1
either 15:9 62:16
doubt 45: 12 52:7 57 emotion 33:21
<F>
:1
emotional 16:1 28:2
face 22:16
downside 62: 12
3 33:8,9 59:16
facing 38: 11
emotionally 61: 17
fact 22:10
Dr 3:19 9:4,10,11,13,
factors 58: 1
4,16,17 11 :1313:12
employed 36:1351:2 fair 28:2 44:3
14:5,8,8,22 17:20 1
employee 65: 15, 16
5 23:16 26:7,9 30:22 employment 50:23
fairly 14:1 40:17 51
33:1 36:19,21 37:8 3 enable 45:6 53:16
familiar 5:3 13:25
9:5 43: 10 44: 19 52:5 energy 38:9
53:8 55:5,19 58:10 5 English 19:16
family 18:23,25 19:1
9:7,23,24 61:25 62:7, enjoyed 59: 23
29:10 40:19
ensure 59:8
1
far 3:1841:17
entire 3:7
draft 24:24 25: 1 46: 1 entirely 48:18
father 9:10 18:7 1
entitled 62:8
33:20
equally 10:25
drift 25:24
fault 8:3
especially 27:3
drifts 25:2
favorable 7: 10
Esq 2:4
drive 56: 14
fear 60:20
essential 37: 13
driven 30: 1
federal 58: 13
ethical 25:9
drove 56:9,20,21
fee 57:8
Europe 47:12
feel 13:19 14:2,13 1
drum 61:18
7:25 18:1 31:16 58:7
due 58:16
everybody 17:21 33: 60:11
duly 18:12 65:4
feeling 31:7
42:24 43:21 57:25
exactly 54: 19,21
<E>
feelings 13:1530:21
earlier 3:12 5:941:1 example 37:18

6
Pagc4

of Nevada

..

1III,.fS.... Bar Heuing

62:12
Ifalk)W 62:21
16:6,7 21 :21

::~:~ 45:18
20:6
58:18

llfinh. 62:10

58:13,17
filling 51 :20
Finalist 19:22

Rc: Zachary B. Coughlin

1 40:3
found 61:8
founding 18:24
four 22:8,18 23: 10
Fourth 2:8 58:18
Frank 41:13
frankly 17:4,7 30:18
free 41 :25
freshman 21: 17
Friday 1: 17 65:8
friend 28:13 53:13
friends 40:19
front 10:5 15:8 34:2

29:14 32:14 35:12 3

6: 13 38:22 40:9 41:2
551:14,2552:12,13,1
5,19,20 54:19,24 59:1
760:9,1761:2,21 62
:10,12,1563:3,24
gold 31:4

3:18
handled 37:3
hands 41:25
Hane 6:19
happen 26:5 27:14

60:1,17,22
happened 27:19

""K"

3 47:23 61 :14 62:23

good 12:10 13:4
325:1428:1331:1,3,
happening 21: 10
5 37:18 43:2 51:16
31 :8
53:11 63:14
II~'~:~:~::' 27:2 28:1
II
Iy 22:9 65: 1
gotten 26:2 37:14 5
8
2 55:24
happens 41:5 58:
8:9
finding 46:20
full 36:10 50:22
160:1,14
findings 10:8,10
fully 51: 1 53:20
grade 20:7 22: 1 46: 1
34:5 59: 13
functioning 11:9
happy 5: 13 29: 1 63:
647:15,16,18
lfinish"d 24: 1
harassment 27:10
funny 31:24 32:5
grades 20:9
fire 32: 18
hard 21:22 24:12 29
further 28:5 29: 1 32 graduate 22:18 24:1
fired 27:21
:25 36:23 37:5,5 49:2 3 46:16
:19 37:7
hardest 21:12,19
461:362:2565:14
graduated 19:14 24:8 health 42: 14, 17
firm 50:10,18,25 53:1 future 38:3 52:19
great 20:19 27:16 3
hear 39:20 63:4,8
7,20 54:12,13
heard 29:6 36:16 49
<G>
1:24 55:8
firmly 59: 14
:17
greatest 52: 17
9:9,25 18:12 23 Gee 32:13
HEARING 1:16 3:3,2
13 27:4 28:22 37:25 general 12:7,17,181 greatly 15: 18
4 4:15,16 5:16,17 :
Greg 14:8
5:22,24 19:9
38:14 51:13
10:19 13:13 14:25 1
Gregory 3: 19
getting 24:17 57:15
fit 55:16 59: 14
group 27:8
5:16,19 28:22,24 29:1
58:13
Fitness 3:4 8:20,23
growing
25:
18
2 30:7 33:4 34:16 3
girl
23:14
30:17,19
guarantee
58:22
6:20
51 :24 52:6 57:8,
girls 20:8
guess 7:17 13:15 1
059:1760:1264:17
10:1742:11 50:1
65:7,11
give 9:8 28:12 39:19 4:20 17:21 25:17
hearings 60:17
42 :11 53:25
43:18,19
29:23
gun 21:1
heart 25:14 33:20
given 20:7
::~e~56:12
10:3
heavy 51 :21
giving 18: 1 46: 15 4
guy
14:1,3
24:14,23
heck 52:12
7: 15
IIflippant 21:2 23:22
hell 32:8
32:4,1358:10
glowing 19:18
12:12
he'll 63:6
focused 21: 12
go 8:15 12: 22 25:18, guys 10:4 15:23 16:8 help 35: 7 43:8 52:2
folks 61:10
1,23 53:3 58:9 61 :23
17:2 28: 12 37:25
9 32:20 38:22 39:13
18:1341'18
helped
37:8 53:3
40:16,2241:2043:14
56:1,3
helpful 31: 12
<H>
52:23 59:5
37:17
helps 40:18 44:15,1
hair
22:24
goals 39: 7,9 45:6
32:9
6,17
God 15:10
3:24 30'17
hereto
64: 15
half 24:2 34: 1 36: 10,
goes 35:20
52:4
hereunto 65:19
1 49:9 50: 1 59: 10
48:15,19
hesitant 57:6
hand
60:3
65:20
going 5:8 10:23 11:2
Hi
14:8
handle
17:8
29:
12
3
16:5 18:1820:2,
.....11 26:2 29:2 13:2
hide
7: 13 48:2
2 23:3 26:20 27:16

1I

Page 5

Bar Hearing

19:14,16 25:21
:23 32:2 59: 18
36:1
hindsight 45: 12
historical 13:20
history 52:8
hit 41:1
hold 61:4
holds 33:19
home 26:21 40:4,

5
honest 36:21 43:18
honorable 5:25
honored 10: 1
hope 20: 19 51:6

horrible 15: 11
Horton 1 :25 65:4,24

40:16,1741:1
hour 30:7
hourly 15: 17

33:17
'Ollse 7:25 32:9
humility 32:23
humor 31 :25
hundred 22: 10 46:2

Rc: Zal;hary B. Coughlin

11 10:14,18,19,24 11:

2
111 10:18,19
immature 20: 11 21:2

23:23
immaturity 31 :23
immediate 3:20
immediately 27:21
impetus 21 :20
implement 39:4
implies 13: 17
important 10:25
imposed 17:10
impossible 55: 18
Impress 13:14 58:9
improvement 13:9 2

3:6 25:761:19
inability 25:8
inappropriate 20:23
21:1037:4 45:13,16
incident 6:4 16:3,15

29:1 36:1748:16
9 55:14,15
incidents 46:19 48:9

inclined 63:9
incredibly 21 :22
incurred 47:2
47.1
incurring 29: 14
'41113141
indicated 4:14 8:18
H un t er 9 ., , , ,
6 11:13 13:12 IQ:;J,O'1 individual's 11:1
2 17:20 23:16 30:22
inflicted 26:4
36:19,21 37:8 39:54 influence 53:11
3:1044:19 52:1 ,5 53 influences 40:6
:8 55:5,19 58: 10 59:7, information 54:20
3,2461:2562:7,11
infraction 49:13,16
Hunter's 52:18
initial 61:24
insight 12:8
insulting 25:3
<I>
insurance 42: 14, 17
ice 44:13

10:14 31:1,21
38:22
64:15
16:15
48:25 49:8,2
,.' ""~

56:4

43:5,750:12

intend 4: 10
intended 35: 16 36: 7
intention 51 :22
intently 21 : 16
interest 61: 10
interested 65:18

interrupt 4:12
interrupted 60:23
interrupting 55: 1
intervention 44:9
interviewed 32:3
intimidates 32:12
intimidating 32: 12
introduce 3: 18
investigate 59: 1
investigation 7:6 46:
5 48:8 49:24 54:20

58:16
investigations 46:19
involved 20:9 65:17
invo lvement 9:23
isolated 16:3,15

Kevin 2:4 3:20 9:18

16:6,12,1861:12,12
kid 10:12 17:5 25:17
29:7 62:3
kids 22:8,18 28:13
kind 6:15 12:11,12
14 :9 27:7,25 28:25 2
9:24 31:1740:6 41:1
8 42:9,10 45:6 50: 10
51:9 54:4 59:4
kinds 24:18
know 9:19 11:15 13:

6,24 14:21 17:8,23 1

8:419:5,12,15,17,21
20:1,4,5,7,1 4,2521:3,

issues 16:1 35:7

3 63:4
its 16:1 61:23
IV 10:18,19
<J>
job 15:23 57:14
jobs 41 :24
Jones 46:6,8
Judge 34:23 58:13
judgment 20:25 22:2

2,25 23:22 32:22 50:

July 65:21
June 1:1765:8
junior 26:21
jury 35:2
<K>
keep 7:5 38:8 52:13
keeping 53:22 54:5
Kelly 2:4 3:20 5:5,1

4 9:18 13:25 16:14,2

228:7,8,11,1737:15,
9 38:2 39:12,17,23 4
0:1,11,13,20,22,2541
:3,5,9,11,14,20,2250:

1,13,17,23,25 22:2,3,
2,13,15,21 23:21,22,2
3 24:19 25:2,9,11,
0,22,25 26: 1 27:8,9,1
2,2529:7,17,18,
330:531:2,3,10,14,2
132:8,12,15,15,17,
1 33:2,11,16,19,253
5:1836:22,23 37:5,6,
8 38:7,7,9,10,18 39:4,
40:2,5 41:3,18,23
7 43: 1,2,4, 15, 17,22,2
3 44:13 45:6,9,15,18
48:23 49:5 51:11,18
52:6,7 53:3,15,20,22
54:8,10 55:6,17,25 5
6:6,9,11,23,23 58:2 5
9:13,17,18,22 60:22
61:18 63:12,15,18
knowing 30:20
knowledge 29:4
knowledgeable 54:1
3
known 25:20
knows 25:12,1347:1
1

0,14,18,2251:4,9,14,1

8 52:25 53:12 56:19

60:10 61:4 62:14 63:
4,19 64:2
kept 6:24

<L>
lane 59: 19
language 15:9
large 11 :23 27:8
Page 6

-'-CiMHt R.eponcu of Nevada

"

of Stale Bar Hearing

Rc: ZaCh'H)' B. Coughlin

1 :20 13:22 50:2,

2:7 6:5 8:9 10:1

2 14:420:621:17,18
1,4,8,13,1325:19
26:23 27:6,22 28:2 3
4:12 36:9 46:19 47:6
48:9 50:10 53:13,16
55:16 58:22 59:15 6
,9 63:4
lawyer 56:1,4 61:14
62:4
lawyers 17:14
leading 7:5
learn 52:13

line 19:25 24: 19 30:8

listen 33:7 39:22
listening 43:21
litigation 50: 12
little 13:2 15:25,25
20:222:1 25:1743:1
5 48:24 62:24
live 40:3 63:6
lived 42:24
lives 31:7 37:21
living 18:22 31:6 43
:1
loans 22:15 27:24
lobby 18:8
located 6:25
long 16:3, 16 19:17
30:10 43:20 44: 17 6
0:7 61:5 62 :16
longer 58: 11
longstanding 55:25

59:4
malpractice 34:25
Man 58:24 61: 16 62:
63:3
mandated 44:8
manner 7:10

Members 2:2 4:9

9:1,17,22 18:21,24 2
1: 7 23:6 26:8 29:2 3
3:24 42 :7 54:13 62:2

1
memory 16:23 59:19
mention 4:20

March 3:64:22 5:17 mentioned 5:15 37:1

15:1 16:24 23:8 28:2 2 44:19 55:11
1 33:10,25 34:15 55:6 1Merit 19:21
9 57:19,20 58:4 62:2
4
met 3:5 21:12 25:23
mark 5:8
37:25 39:9
Michael 2:3 3:21
marked 3:23 13:9 2
3:1661:1964:14
mid 44:3
marriage 31 : 11
middle 26: 18 56: 10
massage 43:22 44: 1 midnight 56: 22
learned 20:19 33:24
3
Mike 14:23
34:2 49:11 52:17
master's 26: 16
mile 49:9 50:2
learns 20: 18
matter 3:7 7:12 62:2 mimic 31:24
leave 27:14 40:11
look 24:22 31 :7 37:6, 0,22
mind 30:20 52:14
45:3 52: 12
leaves 27:14
MBA 19:17
mine 40:9 60:8
looked 16:23 49:21
McCourt 41 :13
LeBare 54:6
Minority 51:15
58:23
McKenna 43:13
left 3:20 4:22 27:6
minutes 7:14
mean 11 :20 16:22 1 misdemeanor 7:2 4
9:24 22:23 24 :20, 24
looking 22:21 33:13
8:2
legal 29:14
41:24
26:5 27:6,8 35:15 38 Mishare 19: 15
legally 62:8
looks 16:24 51:16 5 :22 42:23 45: 14 49: 1 misplaced 32: 1
length 13:13
52:14 56:6 57:14 58:2 misread 22: 13
6:23
52:17
061:12
missed 7:19
Lori 3:19
meaningful
23:13
lot
17:
14,
14
26:4
27
mistake 49:3
letter 10:4 13:17 19:1
means
44:22
:2428:12,1932:203
820:1021:2147:11,1
5:7,2536:1 41:25 42 meant 36:2
mistaken 48:25 4":",~
4
measures 44: 13
:12 53:3 57:15 58:1
5
letters 29:22 47:7
mechanism
11:
19
1
MMPI
14:10
59:17,18
letting 10: 1
2:3
Monday
64:6
lower
60:3
level 12:8,17 13:1
mechanisms
36:4
3
money
42:13
47:1 5
lunch
40:4
levels 10:18 12:19
7:7
7:11 39:5
IIII ~;:;:;'~ 34:22
medical 15:24 19: 1
monitor 12:16 44:25
<M>
55:14
34:25
monitOring 37:1244
ma'am
14:19
license 60:4,6
meet
60:15
:21.24
mail
24:1745:8
life 11 ' 1017:2,4,15
mails 19:8 20:4 36:1 meeting 29:8 32:4 3 month 41:24
19:1021:9,1922:22
6,25 37:1,14 45:11 4 5:10 56:24
29:19 31:5 35:13,19
months 7:6 13:8 16:
meetings 53:10
7:24
41 : 19 58:24
9 19:10 31 :14 34:1
melt 23:7 55:19
25:6 41:7
47:1749:1659:10
melted
15:10,10
major
22:7
26:3
31:1
37:21
member 8:21 15:15
7
1:25 65:4.24
Moral 3:4 8:20 19:7
63:2
making 5:14 51:10
Pnge 7

of Nc:vada

tl

j"Ofs.... Elu Hearing

7 55:13

Re: Zachary B. Coughlin

_~an 4:11
nisht 56:11,15,17,19,2
19:23
1
6:5 17:23
nine 48: 12
3S:13,18,22 45:9 56:1 non 8:6 18:19
normal 11:7
motel 56:12
Notary 65:5
mother 19:25
notes 65: 10, 13
motion 35:5 58:13
notice 3:244:2,66:1
movie 6:3 36:17 41
4
2,23 45: 17 48: 18,20
noticed 28:22
49:2,550:251:14,17
notices 4:7
55:14
notified 48:7,9

Okay 14:5,14 16:11

17:24 18:6 40:1,22 5

0:554:11
Oklahoma 34:23
old 23:20 25:7 55:3
older 26:16,17
oldest 26: 15
once 7:1,3 20:1 26:2

431:532:21 45:7
ongoing 12:22 13:3
open 15:25
operate 25:9
opinion 9:23 13:16

16:2 35:14
movies 41:2042:1,

18

mystifying 19:1243:1
7

N>
name 43:13 50:14
National 19:21
nature 14:11 30:19
NBC 39:24
necessarily 55:22

II n,eck 44:4,5,6
need 5: 12 8:22 12:2

2 13:3 14:13 26:5 6

2:19,24 63:23
30:1361:13
needing 39:2
needs 13:2 14:15 2
5:10

6:642:7
\2~~:~~e~
\ 1:20 3:4 8:2

1 18:24 24:7 65:2,6,2

1
1I..."",r 22: 18 31: 7 35
60:15,17
41:18
39:18
23:2340:4
ofNe:vada

Number 4:5,20,23 9:6 Bopportunity 30: 11

13:822:1233:247:6 order 4:19
numbers 4:21
ordered 62:6
numerous 7:8
originally 61 :20
nutty 22:4
ought 17:18 31:4
outside 13: 13 49:6
60:16
<0>
overall 24:22
000 64:19
oath 3:11,12,14 18: 1 overload 30:4
7
<P>
obligation 55: 12
packet 35:6
observed 15:13 29:3 page 9:7,8,12
paged 9:13
30:19
pain 42: 12,24 43:1,1
obtain 6:18 7:10,15
1,13,16,19,20,23 44:4.5
obvious 30: 13
pains 25:18
Panel 2:2 13:24
obviously 7:3 24:15
paper 24:10 25:4 37
58:9
:239:1746:4,9,10,11
occasion 34: 16
papers 37:6
occupied 58: 1
parents 22:15 53:3
occur 15:17
park 43:15
Parraguirre
34:23
occurred 22:19 29:3
part 5:6 15:2 17 :10
57:19,21 58:3
21:2347:4
48:13
o'clock 1:18
particularly
60: 11
offended 47:7
parties 47:7 65:16
Office 7:4,12 27:20
33:11,1550:1665:20 pass 24:12 50:23 56
:13
Offices 2:7
Passed
24:7 51:5
official 7:25
Oh 15:10 39:15 41:1 passing 47:15,16
Pat 6:1
5
Patent 38:19

pathological 11:5
patients 9:19 17:23
Patrice 5:25
pay 22:19 27:22 42:

8 45:18 51:13 57:8

paycheck 64:2
paying 12:1042:2,3
pending 62: 18
people 12:8 23:10 2

5:18 29:19 32:17 33:

4 43:22 45:21 48:18
53:19
perceive 55: 18,20
percent 16:25 43:2
56:13
performed 14:9
period 6:25 7:6 1

7 17:4 23:25
periods 22:22 25:25
Perry 34:9 43:6 50:1
5,15 54:3
person 11 :3,8 25:22

55:1665:18
personality 10:25 11

:1,5
perspective 33:5

8
persuade 63:16
Pete 17:21
Pete's 52:18
phone 40:19 53:1
phonetic 19:15 54:7
photo 49:19
physical 16:2244:1
2
phYSically 9:6 16:24

56:17
Physicians 18:25
piano 21: 14

pick 27:1 53:1

picked 25:19
pilot 12:12
pissy 22: 1
pitch 63:14

Page 8

Re: Zachary B. CoughJin

11:25 26:14
21:14
19:17.23
;llease 5:24
pleased 3:16
plot 41:14
Plus 23:12
poet 19: 16
point 9:2 15:19 22:2
0.23 30:7 31:11 33:2
1 34 13 36:3 41'17
1612464:7,10

".r

police 6:3,17 7:5,11

48:17
policy 7:4
poor 20: 7 49:6 50:8
Portland 26: 17
position 17:724:16
possess 8: 23
possesses 8:20
possible 8:12 17:9
postponed 3:8
practice 7:1 8:24 16

previously 3:5.10 12
:149:14.15
primarily 50: 13
print 60:6

purpose 61: 12
purposes 8:4 10:19
pursuant 3: 12
pushing 38:8

prior 4:14 11:21 19:9 put 22:17 24:16 32:1

privileges 24:18
60:3
pro 61 :21
putting 47:2
probably 15:12 27:1

5 38:5,7 39:15 41:23

53:21 61:1 63:7
problem 16:7 40: 17
42:1043:4 44:3,5,11
59:14.21
problems 11:3 12:9
27:2
procedural 3:22
procedure 5:9
proceed 49:24
proceeding 49: 16

<Q>
qualified 59:8
quarrel 31: 12
question 5:7 6:16 1

0:23 12:25 16:16 33:

534:251:2352:14
questioning 18: 16
questions 9:1.22 14:

14:25

:17
Public 65:5
published 19:16

:20 45:6
realize 57:9
realizes 29:22
really 15:10 17:1 31

:7 32:16 35:15 37:19

41:1743:345:2,251
:11 53:956:14 57:6
60:21
reason 10:11 14:3 3
0:1649:7 57:23
reasons 29:15 42:15
recall 3:14
receive 58:8
received 4:25 6:6
Recess 34:6
recollection 5: 10
Itecommend 55:12 5

16:13 17:22 26:7 28:15jtIJ:2

32:25 33:6 54:23 61.

proceedings 5:9 15:2 quick 63: 25

o
quickly 42 :16 64 :12
produce 5:18,19 6:2
qu ite 5: 1 18:16
19:1 27:950:11 5 produced 7:14
quote 15:7
55:16 58:22
producing 6:13
5 60: 11 62:9 63:4
profession 15: 18
<R>
professional 12:4 1
raised 7:25 48:23
practicing 10:12 14:3 6:2 25:9
ran 49:7
34:20.21.24 35:21 36
rate 15:14 56:13
professor 18:25 19:1 reached 60:5
:8
6 20:6 21 :23 25:4 2
reaches 52: 11
practitioner 18:23
7:5 46:15 47:8
reacting 12: 12
practitioners 16: 1
progress 59:9
reaction 11: 7 16: 17
preferred 59:21
promise 63:24
20:1729:24 31:21 5
2:2 56:23 58:6 59:3,1
IID.rah,earina 4:25 57:1 proposition 37:20
prosecutor
51
:20
1,16
5
prospect
50:22
reactions
11 :20 12:9
IIpnepp<.d 62:2
read 19:18 20:5,24
pnesence 5:25 50:20 prove 8:20
provide
6:
16
59:6,8
39:1745:9,1
28:14.14
pnesent 3:8 4:3.16 9
provided 27:25
5 46:5 48:22 51: 19, 1
:5.16
961:11
preMntation 8: 25
psychological
10:22
17:6
reading 28: 11 36:24
13:23
35:5
psychology
26:
17
41:7,9.11
10:7,10 15:9
33:17 35:3 psychopathology 31 readminister 3: 10

48:15 51:21 58:

realistic 17:11 ,18 42

recommendation

2 18: 18
recommendations 6
4: 11
recommended 33: 12

43:13
recommending 55: 1

5
reconciled 22:6
record 3:2 4:8 5:6,1

2 8:19 18:1 52:9 64:

red 60:2
refer 10:13
referenced 9:3
references 28: 13
reflect 3:2 4:8 5:24

55:22
reflection 3:6
reflects 55:23
regard 21:4 36:6 37'
45:4 49:25 55:9 56:2
regular 14:16
regularly 12:23 13:4

regulation 44 :20
real 12:10 13:19 23:1 reiterate 31: 13
327:18 31:16 35:19 relate 38:4
38:9 42:9
related 12:9,9
Page 9

..........~.Jt~....., ...r~.JI

Bar Hearing

Reo Zachary B. C'oughlil

o
13:1,20

14'17 23: 13
relative 65:15,16
relax 40:15
14: 17
remaining 42:19
remains 16:2
remedy 43: 21

results 10: 16
retire 41:6
review 8:5,7 19:8 21

School 6:58:10 19:1

shorthand 65: 10,13

shortly 43:7
show 39:22

:18 24:14

5 21:18 22:18 24:5,8,

3 25:19,21 26:18,23
27:6,23 28:2 31 :23 3

showed 32:6,6 44:6

reviewed 5:2,2 6: 15

2:236:10,1442:164

49:19

6:19 47:5,5 48:9 53:1 showing 7:15

59:18 63:25
shows 35:11
o
scratch 55:3
sick 27:15
remember 7:20 19: 1
screen 52:6
side 32:22
.20 23:21 31 :23 38:
right 3: 19,20 156,21 seal 7:25
sighted 12:17
63:17
23:3 24:2,5,6 2512,1 second 34:4 36: 13
signed 46:8
remind 3:9
536:1438:10,16,24,2 secure 6:21
reminds 32'16
540:341:4,1243:15
significant 11: 12 28:
45: 19,25 47:2 51:2 5 see 5:12 7:11,18
significantly 12: 7, 19
Reno 18.24,24 19:16 4:15 59:15 60:3,25
13:231:2533:1234: silly 24:20
26:19 50:16,21 54:6,9 rights 24: 18
6 39:2 45:2 47:20 5
similar 28:25
rent 56: 11
rivaled 22:23
5:2162:11 , 12
Similarly 46:18
repeated 16:5
Rob 52:1,18
seeing 23: 15
simply 19:13 26:5
repeatedly 20:20
seen 8:18 11:18,20
single 52: 11
report 6:3 51: 15
room 34:3 60: 14, 15, 1 12:3 13:8,8 23:7, 16,1 sister 26: 18
Reported 1 :25 65:7
6
931:1461:20
sisters 26:16,21
Reporter 5:24
roommate 40:21
sees 60:13
sit 35: 1
REPORTER'S 65:1
roommates 40:20
sitting 44:16 63:8
reporting 47:23
rough 23:24
self 12:16 17:1026:4
row 22:17
37: 12 44:20,21 ,24,25
situation 16:4 38:10
reports 6: 17,24 7:5,1
send 8:14 21:1 45:8 39:10 51:1 53:21
Rowe 2:3 3:21 9:18
sending 21 :21 47:24
1 59:7
14:23 36:17
sense 31 :25 57:22
represent 8: 11 55: 2
situations 11:2112:1
rules
8:8
sensitivity
15:23
3 37:13
3.24 56:25
sent 29:21
six 11:15 16:19 26:1
represents 56: 1
run 29:10 45:21 60:1 sentence 62:2
331:14
reputation 14:1
separation 22:6
3:64:157:1 3,19
running
27:8
30:4
5
series
9:21
skills 37:16 51:7
54:8
0:7
smart 32:9
requested 5: 17
serious
27:1049:13,
smoke 33:4 52:5
require 8:8
8
<S>
sneak 49:2
required 8:23 59:1,2
seriously 25: 13
salary 51:9
served 13:22
Savage 34:24
sneaking 49:10 50:
34: 13 35:7
sessions
11:
14,17
1
saw
33:9,2241:22,2
sneaks
12:11
7:11
4:16
346:961:1363:11
snuck
48:20
49:4
resolved 7: 10
set
39:7
45:5
65:
19
saying 22:2 30:154
soft 33: 19,20
53:19
setbacks
58:23
solid
23:21 25:22
6:9
49:2
55:25
58:5
4:2 33:6
sets
17:16
somebody
13:525:1
60:18
6:12
seven
22:17
527:9,15,2031:18,2
scab 55:3
6:13
o 32:11 33:12 4Q'1?>I
sexual 27: 10
scary
27:7
34:3 59:4
shelf 40:10
1 50:1 61:2262:16
schedule 4: 13 9:5
7:22 28:23
3:7
short 7:17 10:11
scheduled 13:4
somewhat 48:16
....... 6:22,23 46:2 schizophrenic 31:18 shortened 58:14
ridiculous 20:10 22:

11~~~~~~8:8

_lit

Psg. 10

Rc: Zachary B.

18.20 23:7
8:12,15
15:25

tophomore 26:20
5:23 60:24
13:14 19:9 20:1
521:9 24:11 25:17
27:7 32:12,23 35:8 3
1.25 39:8,25 41:8
:13 45:10 46:21 4
9:13 54:7 57:12,16
sounds 30:5,6
South 2:8
34: 10 43:6 5
15.16
special 26: 18
specialist 43: 13
spent 10:9 22:10 42
:12
sports 21:1544:10
spot 33: 19.20
Sprague 1 :25 65:4.2
4
stable 23:21 25:22
6:21.22 47:2
;takes 36:1
stalking 20:6
stamped 8:1
stand 25:15
14:10

1I

stop 43:21 61:13

stopped 15:19 28:23
stories 22:24 23:2
Story 3:19 7:17 9:18
14:15.201 7 :926:11,1

suggestions 5: 18
summarizes 10: 7
sun 38:23
Sunrise 34:22
supervising 53:23
support 28: 1

tell 7:1 9:22 13:17 1

8:21 21 :4,6,7 22:24
23:1,2.5 33:7.13,23 3
4:737:1538:1339:1
2.13 42:6 43:22 44:2
2 50:14 52:17 54:17
62: 11
telling 16:7 32 :5
temporarily 11:8
ten 11:1625:5
tentative 62 : 17

2,14,22,25 27:22
22:14
40:7 42:4 57:2,4 63:2 suppose 34:12
3 64:3
supposed 45: 18
straight 19:24
strategies 11 :25
Supreme 5:10 18:19
55:13 58:15 63:15
Stratos 46:4,15 47:8,
term 15:6 19:17
2
sure 5:14 6:11 7:19
terms 56:24
Street 2:8
9:7 14:21 15:5,7 20:2 terrible 24:16 26:3
strength 13:15
o 25:2 26:7 34:5 35: terrified 29:13
5.2241:247:21 48:1 test 56: 14
stress 11 :20 12:4,9,
849:1651:11 52:1
testified 18: 13
9 15:16 17:1021:8
2 58: 12
testify 9:10.20
22:7 27:1 35:20 36:4 surgical 44:8
testing 14 :10
37: 11 38: 11 42:22.25 sworn 3:10 18:13
tests 10:14
43:2,9 58:1
symptomatic 24: 11
Thank 16:10 18:3 4
stressed 29: 11
7:15 63:20
<T>
Thanks 28:9,11 33:1
stressful 11 :8,21 17:
35: 13, 17,23,24,25
aake 3:22 6:11 22:16 theater 6:4 48:18,20
Strip 50:2
34:3 37:6 38:6,15, . 49:7.10.1350:355:1
strongly 13:19 14:2
339:3 56:1261:56
4
17:2531:16
2:14.15
therapy 12:23 13:4
structurally 44:8
17:14 30:22 44:11
structure 11 :5 12:15 Taken 1:17 12:7 30:?ll lhir,n 21: 1 24:11,23
standards 17: 11 25: 1 structured 11:2
037:2551:4
25:14,2527:7.1828:1
student
42:16
4 33:9 38:19 43:17
o
students 20: 7
takes 23:8 25:12
57:7 60:8 62:3
::::~e~3: 18
8 43:1 52:8
5:1641:124 stuff 12:10,17 14:2
things 3:22 13:10 2
20:15,23 24:19 27:25 talk 19:8 26:22 32:1
1:10 26:3 27:13 32:2
11 43:7 59:9,10
28:11
32:7
33:14
40:19
43:16
3
33:4.8
1 34:1 35:7 36:1.25
4:21 26:9
4 37:7 47:5,22 58:20 49:6 53:10
38:8 39:8,18 42:13 4
stupid 24:20
talked 11 :21.24 12:1
3:19,23 45:2,9 57:16
4
13:12
17:17
39:5
submit
37:2
47:6
59:18
1:16 3:3 4:6
submitted 46:5.10 4 43:10
think 6:19 10:21 ,21
19:22 64: 17
talking 20:20 38:2 6 11 :24 12:25 13:3,4.6,
7:5
65::/,5,1,11.20
1:24,25
subsequently
27:5
4
54:14
6 14:15 15:12 16:14.
taught
21:
14
9:11
017:1,9.12.1718:6
56:11
teaching 26: 18
suddenly 25:24
20:15.16.16,18.1822:tlla
60:14
team
17:5
23:13.24
24:11.22 25
suffer 20: 18
32:19
tears 33: 16
:1826:2.6.10 28:17
sufficient 46:16
45:7 49:6
telephonically
9:20
29:21
30:1.4.9,23 31:
sugarcoating
54:22
80:3
10:1
1.22
32:23
33:3 35:2
suggest
51
:25
82:12
536:237:17.2338:1

_IS

l'llfllbot. t!or Hearing

Re: Zachary B.

42:24 44:4,8,23 47
48:17,23 49:8,25
1,20 51:1 53:21 5
55:23 57:20 59
:13,15,2060:21 61:1
6,18,24 62:5,5,23 63:
9 64:3,5
thinking 27: 13 51:4

52:3,6 55:19 59:166

3:13 64:8
today's 4: 16 8:4
told 6:21 21:18 35:1
138:13,1443:2348:1
9,20 50:25 54:20,21
55:5 61:11 62:1463:1
8
tolerate 42: 25
26:15 27:18 30 Tom 19:15
:12
tonight 51: 15
44:3
tough 29: 7
thought 20:25 22:9
towed 56:10
25:3 29:6 35:12,16 4 town 43:13
9: 12 56:20 61:;'f,,:),L,<,LI transcribed 65:9
3
transcript 5:6,8,11 6
IItt,oulants 62:20
:4,15 7:18,21 8:9 35:
thousand 16:25 22:1 1 48:2351:1961:11
1
63: 12,23 65: 11
three 22:7,11 30:7 3 transcription 65: 12
3:2536:1044:656:1 transcripts 7:24
2 59:10
treatments 44:12
thrust 11:23
tremendous 12:14 1
thumbs 63:8
3:21
61:18
trial 35:258:19
9:10 18:7
tried 7:10 11:18 29:1
7 43:3,18,19,24,25 6
6:25 9:20 10:9
11:10 13:7 15:17 17: 3:11,13,17
2 22:8,13 28:9,15 29 trip 59: 19
:1330:9,14 35:13 36 Triple 19:23
:3 39:1340:11,2241 trouble 27:17 28:20
:25 44:24 46:25 51:1 true 17:13,14 61:7 6
9 58:14,24 60:7 62:1 5: 12
6
try 30:11 37:1842:5
47:23
62:16
7:8 25:5 33:2
trying 25:5 29:12,15
37:21 38:4,6 39:6 45
18: 11
:1,4,5 55:3
tub 40:16,1841:1
tuition 22:19
turn 8:25 25:4 46:9
63:25
turned 24:10 29:13

3:12,244:3,11
8:1,7,15 18:17
38:3,3,7 51:12

37:2 46:11
turning 24:17
TV 40:18

two 5:21 20:8 22:5

24:2,20 26:16,21 27:1
3 33:14,16 36:10,11

Vegas 1:20 13:22 2

3:1026:1950:2,176

0:12,19

51:12 54:18

verbatim 15:9
verdict 35:6
type 11 :1933:858:1 version 10: 11
versus 12:4
6
Vic 54:3
typewriting 65:10
victims
49: 20
typewritten 65: 11
Victor 50: 15
typical 21:5 39: 12, 1
view 3:7
9
vision 52: 18
vivid 16:23
<U>
vote
63:3
ultimate 6:23
voting 63:8,9
ultimately 45:24 48:4
<W>
unable 7:15
wait 45:8
want 8:5 12:11 31:1
unconditional 59:20

3 39:3,19 42:17 52:1

6,16,2355:258:11,2
5

62:9
underdog's 17:7
undergoing 21:8

wanted 14:9,20 17:2

underlying 6:24 31:1

7 37:1
understand 15:21 5

8:25
unexamined 31:5
unfortunate 25: 19

5 22:2 38:15,15 42:1

5 58:7
watch 39:1840:18
way 11:212:4,1620
:2 22:3 25:16 30:2 3
7:339:1 44:10 53:16

60:7
Unfortunately 37:24

ways 12:4 24:21

43:14 53:15
unofficially 54:4
unprofessional 47:2

unrealistic 39:7
unrealistically 39: 1
untroubled 17:4
unusual 27:7
upset 15:20 29:9

upsetting 29:6
use 55:7
usually 16: 19 40: 15
utilize 51:7
utilized 53: 10

week 26:24 48:6 56:

58:21 64:8
weeks 16:1951:12
54:18
weight 3 1:4 62:6
welcome 28:10 61:2
well 5:36:1 9:19 19

:11 23:7 28:16,18 30

:5,9 31:25 37:17 41
1 42:9 44:23 48: 7 5
0:25 54: 10 55:21 59:
2
went 18:5 36:9 39:1
6 53:16 56:9

<V>
vacation 47:13
vacations 22: 17

We're 3: 16 4:20
031:7,11,16.18,205

valuable 19:23
Page 12

of Nevada

Bar Hearing

Re: Zachary B. Coughlin

~~~...~~,~

working 24:5,12 34:

243:6
world 27:18
worst 16:20 17:2
worth 31:3,6
wound 55:461:17
32:10
write 24:24 47: 10,14
wind 12:8
writes 28: 16,17
winded 62: 17
writing 34:13 64:12
21 :9
wrong 10:23 25:12,1
wish 5: 13 63:22
3 29:18,20,2348:17,1
WITNESS 3: 15 7:9
9
9:15,2510:4.7,1711: wrote 10:5 19:1720
5,23 12:6,24 13:11,1
:24 24:24 41:16 47:7,
9 14:12,18 15:2.7,21
7
16:11,1817:1,12,24
18:4,12,2319:4,112
<Y>
1:11 23:3,12,17,202
Yale 32:2
:3,6,9 25:11 26:13,1
5,24 27:3,24 28:4,10, Yeah 17: 1 24:3 27:3
6,19 29:5 30:24 31:1 35:3 38:17,20 39:21
, , 41:1042:2343:124
. 3,9,12,18,21
5:2251:1656:5,185
5,22,24 36: 11,15,22
37: 10,17,23 38:4,17,2 7:17 64:3
39:3,15,21,24 4
12,15,21,2441:
17",0" 21:17,24 26:21
0,12,15,21,23 42:3,59'.tI;'7" 31:1536:1356:
343:1244:2,16,234 4

54:1,18
17:17 20:14,1
22:6 23:24 26:2 4
243:3
whatsoever 31: 13
65:19

'"

5:14,20,22,25 46:3,7,1

3,17,23 47:3,9,17,21,2
548:3,6,1449:4,15
50:6.8,12,15,19,25 51
:6,11,1652:2253:
II.'/~ 54:3,11,15 55:2
1 56:5,8,18,21 57:
1 59:12 60:21 63:13
65:19
4:69:4
32:7
33:24

33:4,11,23 34:7 37:1

,2 47:23 54:21,21 55:
57:2,1961:11
Zack's 17:10 18:72
6:14

years 22:5,11,1724:2
36:10,10,11 42:11
yesterday 33:17 62:3
York 41:18
young 32:1841:19

61 :16 63:3
younger 26: 19

<Z>
Zachary 1:6 2:6

13:21 24:14, , Zack 7:24 9:18,23,24

10:811:4,14,1812:1
II"'''~ 35:5 39:16 40:3, 4,22,24 13:16 14:15,2
1 53:17,20

!~rked 21: 19,22

21:12

4 19:7,9,13,14,20,21

20:7,1821:5,8,1122:
323:2025:7,1226:1

5,22 27: 12,22 28' 22

29:7 30:11 31:23
Page 13

........fNevada