10 31 12 0204 pre hearing motion to dismiss and for summary judgement and memorandum of law...

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http://www.scribd.com/doc/169475335/6-13-13-0204-61383-Declaration-of-Coughlin-Concernign-Trespass-Conviction-and-Hill-s-Sworn-Testimony-13-17328

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    prove strict compliance with all requirements for summary proceeding; as omission of required act of

    service is fatal to plenary.

    FACTS

    1. Earlier today, on October 28th, 2012 Coughlin submitted for filing, essentially, a duplicate of this

    filing which, unfortunately, upon further review, contained a signature that was not close enough to the

    signature line, arguably, to be effective. Therefore, a correction has been made in that regard, placing the

    signatures in a more appropriate setting in relation to the signature line. The only other change involves the

    following paragraph, with the additional materila in bold:

    On February 27th, 2012, while awaiting trial before Judge Nash Holmes in 11 TR

    26800, and in a private meeting with Reno City Attorney Allison Ormaas in one of the private

    conference/meeting rooms outside the interior doors to the court room, RMC Marshal Harley

    entered the room and purported to personally serve Coughlin a document in the appeal of the

    eviction from Coughlin's former home law office, in CV11-03628, apparently at the direction of

    Richard G. Hill, Esq., on behalf of his client Merliss (the landlord, whom all three of the appointed

    defenders provided by the RMC to Coughlin refused to subpoena, apparently because it would cut

    into their $7K fee from the RMC and because of an apparent desire to torpedo Coughlin's defense,

    despite Merliss being a material witness. Further, it is believed OFficer Carter and Sargent Lopez

    were subpoened by the City, and perhaps by Coughlin, though a continuance was denied upon their

    faling to appear). Washoe County Sheriff's Deputy John Machen filed a false Affidavit of Service on

    November 7th, 2011, in RJC Rev2011-001708 alleging to have "personally served" Coughlin at the

    time the WCSO's Deputy Machen effectuated the lockout on November 1st, 2011 at 4:30 pm (by

    which time the ORders of October 25th and October 27th, 2011 made exhibits in this Trial by the

    City had become stale, invalid, perhaps void, etc. given, as admitted to, apparently, by both the

    - 2/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    RJC's Chief Civil Clerk/Supervisor Karen Stancil (to be clear, I mean this only to the extent that Ms.

    Stancil has represented to the undersigned the "usual custom and practice" of the RJC is to fax over

    Orders such as those mentioned above to the WCSO the day they are file stamped, or at the latest by

    the next day...plus Baker testified, apprently to receipt of the ORder by the WCSO on October 28th,

    2011...all making the WCSO's "receipt" of the Orders outside the statutorily dictate that the lockout

    occur "within 24 hours" thereof under NRS 40.253. Regardless, back to RMC Marshal Harley

    (whom RMC Judge Nash Holmes, in her March 12, 2012 rendition of some Order finding Coughlin

    guilty of every RPD in the book, incident to a traffic citation matter tha Judge Nash Holmes had

    transmogrified into a hearing before the NNDB, apparently (see In Re Kunstler), Judge Nash Holmes

    alleged that Marshal Harley, apparently, followed Coughlin into the bathroom during the restroom

    break just prior to Judge Nash Holmes incarcerating Coughlin, whereup Harley apparently played

    peeping tom on Coughlin the bathroom stall and averred to Judge Nash Homes that Coughlin

    "dissassembled his smart phone" (Martin Crowley is laughing somewhere)...the thing is, "summary

    contempt" (even "misdemeanor summary criminal contempt", ie, some law Judge Nash Holmes

    appears to have legislated on the spot, and which does not require her to comply with the dictates of

    NRS 189.010-060, as she refuses to transmit the record and order the production o the transcript

    (and its illegal for the RMC to force criminal indigents to pay Pam Longoni, and only Pam Longoni,

    ANYTHING, up front, in some application of a civil statute related thereto. Regardless, Judge Nash

    Holmes "summary criminal contempt" Orders relies upon allegations of conduct allegedly

    committed OUTSIDE the presence of the Court, so whichever Marshal went playing peepin' Tom on

    Coughlin in a restroom stall needs to sign their name on an Affidavit and stand behind it like a

    grown up rather than right some insipid letter to the State Bar of Nevada criticizing Coughlin's

    fashion sense, then proceeding to lie and lie and lie about Coughlin whilst also demonstrating a

    - 3/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    distrubing extent to which the City of Reno Marshals behave as a coordinated crew of intimidators

    and coerces towards the citizens of Reno attempting to access justice, and to which these Marshals

    themselves obstruct justice on a regular basis. Right in line with that behavior was that

    demonstrated by RMC Marshal Harley in barging into a plea bargaining session between City

    Attorney Ormaas and Coughlin and undertaking the legally questionable task (but certainly an

    intimidating, coercive, and inappropriate action by Harley) of "personally serving" Coughlin and

    ORder to Show Cause in CV11-03628 (despite Coughlin already having been served it via his

    electronic filer status, something Richard HIll and Casey Baker, ESq. knew full well) . Harley

    personally served Coughlin some document, then WCSO Machen filed an Affidavit of Service on 3 8

    12 saying he himself personally served Coughlin. The RMC puts peopel in jail for less than that

    every single day. Then Harley got real uncomfortable with Coughlin asking him questions related to

    the propriety of what Harley just did. Then Harley starts whispering in City Attorne Ormaas's ear

    during the trial in 11 TR 26800, held after that on the same day, despite the RMC, apparently, in

    light of Judge Nash Holmes March 14, 2012 letter/grievance against Coughlin to the SBN indications

    therein, being aware that an Order For Competency Evaluation of Coughlin was entered at 1:31pm

    on 2/27/12 in RCR2012-065630, as Judge Nash Holmes admits to communications with the WCPD

    regarding Coughlin. The RMC Marshals, especially Marshal Menzel like to bark menacingly at

    defendnats that they have to sign some acceptance of service or waiver of service of various

    documents in some apparent effort to cost cut postage expenses of the RMC in affording others due

    process. But worse than that is Marshal Harley taking it upon himself to personally serve Coughlin

    documents on behalf of Richard G. HIll, Esq. especially where RPD Sargent Tarter came to testify

    that day about the 3 traffic citations he issued for Hill against Coughlin, and Tarter put his feet up on

    Judge Nash Holmes bench (ie, where the Judge might set her gavel) while the RMC staff served

    - 4/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Sargent Tarter bottled water. Avoding an appearance of impartiality or impropriety is a cannon or

    something, some might say. This is true especially incident to a trial appearance related to 3

    retaliatory traffic citations issued by the RPD after they told Coughlin to leave the sidewalk near

    Hill's law Office, and where Judge Nash Holmes told Coughlin she would "put you in jail if you say

    Richard HIll's name one more time"... See some of the materials in Exhibit 1 that show Also,

    there may be some clerk failure or misconduct where Michelle Purdy and or Lori Matheus appear to

    have refused a filign by Coughlin on October 19th, 2011 which arguably could have functioned as a

    Motion for STay in CV11-03051 - ZACH COUGHLIN VS. MATT MERLISS ET AL (D1) Filing

    Date: Wednesday, October 19th, 2011 . And City Attorney allison Ormaas and Dan Wong both

    told Coughlin the were not going to investigate, follow up on, notate, or in any way document the fact

    that Coughlin repeated to them the exact words that RPD Officer Chris Carter said to Coughlin on

    November 13th, 2011 when the following exchange occurred between Coughlin and RPD Officer

    Carter after Carter subjected Coughlin to a custodial criminal trespass arrest where Hill and

    Sargent Lopez both admit that nobody issued Coughlin a warning to leave the premises that day and

    that the RPD did not identifiy themselves as law enforcement or issue a lawful order to leave to

    Coughlin prior to landlord Merliss kicking in a "basement" door:

    Coughlin: (speaking to RPD Officer Carter) Are you on Richard G. Hill's payroll, too?RPD Officer Chris Carter, Jr: "Yes, I am. Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do".

    Officer Carter said it. I reported it. Period. Now the SBN's Patrick King has failed to subpoena

    Marshal Harley or City Attorney Ormaas (maybe he is afraid they will start whispering in each

    other's ears again during some hearing the SBN wants to violate Coughlin's due process rights in

    holding on November 14th, 2012), and instead Pat King has listed his old friend and coworker from

    the Attorney Generals Office to come testify at the hearing and also listed Marshal Coppa (instead of

    - 5/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Harley?) to testify as the hearing? Hhmmmmmn......Its just wrong for a smirking and chortling

    RMC Marshal Harley to be perpetuating the fraud of WCSO Machen and the Rambo charlatan

    litigation tactics, attempts at intimidation, and creation of the appearance of impropriety that

    Richard HIll and Casey Baker cultivate so well in everything they do. Besides, why does Hill need

    to have the wCSO and RMC serving Coughlin notices of Orders to Show cause when the following is

    documented: 02-08-2012 Court Proof of Electronic Service Filed by or in behalf of: Court Proof

    of Electronic Service 02-08-2012 Court Ord to Show Cause Filed by or in behalf of: Court Ord to

    Show Cause...02-10-2012 Court Proof of Electronic Service Filed by or in behalf of: Court Proof

    of Electronic Service 02-10-2012 Defendant Notice of Entry of Ord Filed by or in behalf of:

    RICHARD HILL, ESQ. Notice of Entry of Ord - Continuation (if not for some impermissible

    purpose?).

    All of the allegations herein also relate to "irregularities" in the proceedings and prosecutorial

    misconduct" justfying the relief requested herein. Coughlin's ability to get this exculpatory video wherein

    Sargent Lopez admits RPD Officer Carter and Richard Hill, Esq. and Casey Baker, Esq. lied, under oath (in

    Hill's case) at the June 18th, 2012 Trial and in violation of NRCP Rule 11 (in Baker's case in his November

    21st, 2011 Opposition to Coughlin's Motion to Contest Personal Property Lien) was severaly comprimised,

    to an excusable neglect extent, and to a good cause standard, by the various fraudulent, retaliatory arrests

    and incarcerations (which have seen attendant deprivations of Coughlin's medication or medications, some

    of which are considered "pyschotropic" by the WCDC), and the fraudulent attempts by RPD Officer

    Warren and others to alienate Coughlin from his family and any other type of a support system, all in the

    name of covering up wrongful arrests by the WCPD, and or WCSO and or wrongful "summary contempt"

    findings, including those in 11 TR 26800, RCR 2012-065630 ( ARgent Sifre's order to arrest Couglin on

    January 14th, 2012 for "misue of emergency communciations", in addition to WCSO Deputy Machen's

    - 6/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    fraudulent arrest of Coughlin on June 28th, 2012, including the fraudulent "Sixth Amendment

    representation by WCPD Jim Leslie and Biray Dogan (in RCR 2012-065630 and RCR2012-067980) in

    those matters)) (if Marshal Harley is going to follow Coughlin into the restroom, then peer through a

    restroom stall and, as alleged by Judge Nash Holmes in her 3/12/12 Order following a hearing that

    Coughlin was not appropriately noticed on by the RMC, despite it being aware of Coughlin's then current

    address at the time it mailed a 2/28/12 Order in 11 TR 26800 to Coughlin...and Judge Nash Holmes is

    going to enter and Order finding Coughlin to be guilty of "summary criminal contempt" (which isn't even

    an actual charge under NRS), then Marshal Harley and or Judge Nash Holmes need to sign affidavits to the

    extent those Ordes explicitly reference alleged conduct in a bathroom stall, ie, not, allegedly "committed in

    the court's presence" under any section of NRS 22)), then Marshal Harley needs to sign an affidavit, which

    he has not done. And RMC Marshal Coppa should perhaps focus less on critiquing Coughlin's alleged

    wearing of "pajama bottoms" to the RMC filing office coutner while checking a traffic citation, and more

    on whether he violated the Fourth Amendment and other laws incident to his conduct on February 27th,

    2012 in pulling into a back room in the sally bay at the WCDC WCSP Deputy Cheung and seeking to, upon

    information and belief, commit some misconduct (and the RMC Marshals coming back to the WCDC on

    June 28th, 2012 and retrieving Coughlin's smart phone, phone, and micro sd card is not a "search incident

    to arrest", and a warrant needs to be produced to show how the RMC and or the Marshal did not violate the

    Fourth Amendment. Further, the RMC needs to answer for why it has flouted Nevada law in failing to

    transmit the appropriate materials in response to Coughlin's filing, on March 7th, 2012, of a NOtice of

    Appeal (see NRS 189.010-.050) in 11 TR 26800). Further, if any "recording device" was "dissassembled"

    during a bathroom break, then how could Coughlin's answers to Judge Nash Holmes sua sponte

    interrogation, incident to improper suggestions made to her by the Reno Marshals and or City Attorney

    Allison Ormass, possibly be appropriate? Further, in CR12-0376 Coughlin's rights were raped by the court

    - 7/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    system, and WCPD Biray Dogan and Jeremy Bosler, and Judge Elliot's incarcerating Coughlin on April

    19th, 2012 until April 26th, 2012 (incident to a fraudulent filed letter by Lake's Crossing of April 18t, 2012,

    signed by Dr. Bill Davis, and Dr.Farmer, though Davis disclaims and connection to that letter, amazingly)

    provides a further excusable neglect basis, as does the fraudulent conduct of the RJC and or the WCSO

    (including Deputy Machen) of June 28th, 2012 in the custodial arrest (with impermissible denial of a phone

    call, for now reason at all, thanks to the misconduct of Deputy Van der Wall and "Nurse Katherine", and

    Deputy Beatson, in denying Coughlin a phoen call for 20 hours, for no reason whatsoever (despite WCDC

    policy and or the law requiring one within 3 hours), in addition to the fraud of Nevada Court Services

    (partners with RMC court appointed defender Lew Taitel, whom represented Couglin in this very matter,

    11 CR 26405, despite an obvious conflict). Also, the fraud by Ltn. Kevin Brown, Sargent Oliver Miller,

    Officer Alan Weaver, and Sargent Dye of the RPD in connection with the incarceration of Coughlin from

    July 3rd, 2012 to July 21st, 2012 contributed to preventing Coughlin from (as did the fraud by the WCDC

    in refusing to timely file Coughlin's court filings so submitted, including one's in this case and in the sister

    case appeal in cv11-03628 wherein during his incarceration Coughlin was prevented from opposing or

    otherwise addressing an outrageous $40,050 attorney's fees award to Richard G. Hill, Esq. incident to the

    appeal of the wrongful summary eviction in RJC Rev2011-001708 by Richard. G. HIll, ESq., and further

    curious is RMC Judge Gardner's 11/30/11 transferring of the ridiculous wrongful arrest for "jaywalking" of

    Coughlin on January 12th, 2012 incident to Coguhlin's peacefully filming Hill's crew loading up personalty

    from Coughlin's former home law office to take to the town dump, wherein HIll lied to RPD Officer Alan

    Hollingsworth, i na criminal violation by Hill, eventually leading to a wrongful custodial arrest of Coughlin

    for jaywalking in RMC 12 CR 00696 (the case "Administrative Judge" William Gardner of the RMC just

    so happened to transfer to Judge Nash Holmes (to go along with all the work she was puttin' in for thr RMC

    on 11 TR 26800, the triple traffic citation incdient to Coughlin seeking the return of his client's files and

    - 8/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    state issued indentification from Richard G. Hill, ESq. on NOvember 125th, 2011, following Coughlin's

    relesae from 3 days incarceration incident to the fraudulent and wrongful custodial arrest of Coughlin on

    NOvember 13th, 2011 in 11 CR 26405 by RPD Officer Carter and Sargent Lopez.. Everytime, Coughlin

    has been wrongfully arrested (which is everytime Coughlin has been arrested) the WCDC has

    impermissibly withheld Coughlin's medications from him while the WCDA's Office and REno City

    attorney and or the RMC and RJC have sought to violate NRS 178.405 and NRS 5.010 in plowing ahead

    with Trials and settings during the pendency of an Order for Competency Evaluation (including the one's

    detailed in Coughlin's previous filing in this regard). Add to that the fraud of Northwinds in RJC reve2012-

    001048, the fraud of GAyle Kern and WNM's Sue King in the Coughlin v. Park Terrace Town Homes

    HOA in the RJC and that of Jeff Nichols in Couglhin v NIchols (another landlrod tenant matter in the RJC)

    and its excusable neglect any extent to which Coughlin did not previously produce this excuplatory video,

    particularly where it was wrongfully withheld from his under an unlawful rent distraint or other

    impermissilbe action by a landlord, and how that is excusable neglect is obvious, no matter what RMC

    Judge Howard's lack of appreciation of what being a tenant subjected to fraud by a landlord may have

    revealed in 11 CR 22176 or the misconduct of Pam Roberts, Esq., City attorney in that matter (and all the

    fallout of the decisions and action by those two therein).

    1.1 January 13th, 2012 RPD Sargent Marcia Lopez and Officer Travis Warren and Officer Avila

    respond to a call for help regarding a domestic disturbance from Zach Coughlin relating to the attacks by

    his housemates, Christopher "Erin" Allaback and Laura Foreshee for which Coughlin ultimately received

    two Orders of Protection in FV12-00187 and FV12-00188. Sargent Lopez subjected Coughlin to a

    custodial arrest for criminal trespass in Reno Municipal Court case 11 CR 26405, on November 13th, 2011

    (which resulted in Coughlin being convicted for criminal trespass following the June 18th, 2012 Trial

    wherein Richard Hill testified as follows:

    - 9/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    The admission by Sargent Lopez was captured on a high 8mm video camera that Coughlin bought

    from a thrift store for five dollars after his then housemate ruined his digital smart phone video recorder by

    throwing hot coffee on it an Coughlin. Coughlin then transferred the tape from that high 8mm to a digital

    version by filming a television with a digital video camera later obtained, while it was playing that high

    8mm tape. The file was name "0201 cropped Carter Lopez 26405.wmv, and the following represents and

    accurate transcription thereof, in relevant part:

    Coughlin: Sargent Lopez are you going to arrest Nevada court services for trespass?Lopez: I'm not going to arrest them for trespass.Coughlin: but you arrested me for trespass.Lopez: because you were squatting in the property.Coughlin: why do you say that you have any evidence of that? (5 seconds of silence is Sargent Lopez's response) did you announce that you were Reno PD prior to kicking the door in?Lopez: I didn't kick the door in.Coughlin: did you announce that you are Reno PD prior to anybody kicking the door in?Lopez: I didn't have to,Coughlin: so nobody announced that they were Reno PD?Lopez: because the guy who kicked it in had to kick in his own door because you were squatting in his place.Coughlin: so you are admitting that you guys didn't announce that you were Reno PD.Lopez: you are wearing my patience thin, Sir, okay. I am trying to come here to help you, and I bring a specialized officer (motioning to RPD Officer Travis Warren, whom has been described as some sort of RPD Officer with some specialty in "mental health" related areas).Coughlin: that's interesting, you admit that you and Officer Carter never announced that you are Reno PD, and that you never asked me to leave, did you, prior to the door being kicked in?Officer Travis Warren: She didn't have to do anything like that.Coughlin: you didn't have to! That's great, but that means you didn't either.Warren: hold on Zach. You asked us to come here because you needed help now you are being confrontational.Coughlin: no I'm not, no not. Anybody who asked you a question is confrontational, I guess, huh?Warren: Zach, let's try to stay on topic.Coughlin: On topic? I'm not on the topic you want me to be on.Warren: Zach the topic that I'm interested in...

    - 10/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: Is the one that covers your ass!Warren: No, it's not.Coughlin: Yes, it is."...Coughlin: So, Sargent Lopez you have admitted that you did not ask me to leave and you did not announce that you are Reno PD either you or your partner either of those things when you arrested me for trespass. Are you been arrest Nevada Court Services for the trespass that there is video evidence of on YouTube right now? Are you can a do that, Sargent? Sargent, are you?Warren: Zach, that's not the topic were on.Coughlin: Are you going to do that, Sargent? Sargent, are you?Lopez: are you going to fill out your statement?Coughlin: sure. Are you going to do that?Lopez: I am not going to arrest Nevada Court Services.Coughlin: Why, are they your buddies?Lopez: because they did their job.Coughlin: wait a did their job by going behind my back fence and banging on my windows for 45 minutes three times a time a day? Interesting...Lopez: Zach, we need you to fill out the paper.Coughlin: Interesting how it works down there at the Reno PD. You know, there is a lots of documentary filmmakers out there these days, Sargent Lopez? Do you have anything you would like to say?Lopez: Zach, you need to finish your statement.Warren: Zach, you call us here to help you, and now your are...Coughlin: well apparently not because you arrest me for trespass when you either didn't tell me to leave for announced that you were the PD (police Department) and then you have video evidence of Nevada Court Services doing trespassing harassing banging on windows for 40 min. at a clip three times a day, behind a back gate is obviously trespassing, and you are seeing you are not going to do anything...Lopez: have you had your day in court on that yet?Coughlin:That is coming up....Warren: Zach, we really need to stay on topic, okay?Coughlin: What is the topic? Nevada Court Services? The buddies of Sargent Lopez?Warren: No......Coughlin: are you guys going to do anything on this call because the last time you didn't run anybody's priors and if you had it would have been interesting what you would have found, what did you say? Is that proper procedure children somebody's priors?Lopez: The priors for who?

    - 11/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: because you guys didn't do that... Well who would I be talking about?Lopez:(smirking) Yourself, maybe? The priors for yourself?Coughlin: Oh, is that a...do you think you are funny?Lopez: I think it is funny, yeah. I think everything is funny, actually. I am amused by a lot of stuff.Coughlin: Really? Do you think it's funny when your partner says that Richard Hill pays him a lot of money to arrest whom he says to?Lopez: I am pretty sure he didn't..Coughlin: and you were there? And you didn't follow up with the questions of whether Richard Hill had given me a bill for rent that month and yet you still arrested me for trespass?Lopez: 5 min. Zach.Coughlin: I think that's funny, that you think it's funny.Lopez: 4 min. Zach...Lopez:, did the management give you an eviction notice?Coughlin: what are you getting involved in civil matters now? You are going above and beyond, Sargent Lopez, getting involved in civil matters...Lopez: Zach did they give you an eviction notice or not?Coughlin: wow you are working of the storm over there aren't youLopez: Yes or no:Warren: you could say no comment, Zach.Coughlin: thank you, counselor. I appreciate your advice. Now, what criminal matter were you investigating here?Lopez: I am asking you a question.Coughlin: About a what? A civil matter?Lopez: Zach, did you get an eviction notice from these guys (Sargent Lopez is referring to Western Nevada Management posting a John Doe 30 day eviction notice, allegedly, on the door of the 1422 E. 9th St. #2 town home that WNM (which, like NCS, commits the unauthorized practice of landlord tenant law) had agreed to some deal with Coughlin's housemates (or maybe they were his sublessors? Coughlin rented a room from them off of Craigslist, but to some extent they were held out to be employees or partners of WNM, and WNM did testify at a February 23rd, 2012 hearing after Coughlin filed an interruption of essential services complaint against WNM, Gayle Kern, Esq., LTD, and Park Terrace Townhomes that former WNM manager, Robyn Batalado received approval from the Park Terrace Town Homes Homeowners Associattion to allow Coughlin's sublessors to live their in exchange for some handyman work (and perhaps in light of the lessened insurance costs associated with not having the unit vacant incident to some scenario where the PTTHOA bought the unit at a foreclosure sale).

    - 12/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Warren: We will take that as a yes or no, or a maybe, who knows? All right, Zach? You are not going to be able to bait us into saying things?Coughlin: Well, I've been listening to you here whether you've been baited or not, you have said a whole lot today. ...

    Coughlin:... What if Richard Hill sent me a Bill for rent for the month of November, should you follow phone that before you make it trespass arrest? And what did you say to that? You say no we are not going to that Richard Hill pays us a lot of money, and we are going to arrest whom he says to arrest, did you hear that Sargent Lopez?

    Warren: Zach, let's stay on topic.Coughlin: this could be your star turn... This could be your star turn.Lopez: you need some help, brother.Coughlin: really?Lopez: Yeah, you do....(Sargent Lopez and Officers Warren and Avila then leave shortly thereafter, and Coughlin has the following exchange with his housemate's/abusers teenage daughter):Coughlin: look someday, you are trying to support yourself and someone steals your license plate, and slashes your tires, and locks you out after you have given them the last money you had...Teenage Girl's Friend: well, someday we won't be an assh*le like youCoughlin:What is an "assh*le" about that?Teenage Girl: you are f*cking r*tarded, you are being r*tarded, you're making my dad not like you, you steal his knives. His steak knives, like seriously?Coughlin: You mean the one of he held while chasing me up the stairs with saying he was gonna kill me?Teenage Girl: He didn't f*ckin' chase you up the stairs and tell you he was gonna kill you. Why would he say that, he's not like that. And if he say's it, it doesn't mean he means it. You make him say that, you f*ckin' pr*ck."

    January 12th, 2012 custodial arrest for "pedestrian failing to use sidewalk where available" (aka, jaywalking) in front of Coughlin's former home law office at 121 River Rock St., Reno, NV 89501.

    (in the video Coughlin begins filiming from the parking lot in fron of his former home law office and walks towards the property, where Hill's contractor Phil Stewart is already there (for some reason Hill kept making a deal about how Coughlin was "already at the property" when Stewart returned their from the transfer center, but that is not true, Coughlin actually took almost 30 minutes to get to the River Rock Property after the talks at the transfer center, as Coughlin had to go retrieve his hi 8mm video camera from his E. 9th St. address on that date.

    - 13/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: What would the contractor's board say about you submitting fraudulent bills? (said to Hill's contractor, Phil Stewart, owner and operator of Nevada Building Industries (NBI), whose bill for $1,060 for "securing" the property was submitted as an attachment in Hill's Memorandum of Costs and in Hill's Opposition to Coughlin's Motion to Contest Personal Property Lien under a personalty lien theory citing to NRS 118A.460, which allows for reasonable costs for "moving, storage, and inventorying" a tenant's personal property). Would they be okay with that? Neck carpet right there that's Dr. Merliss's property if you throw it away, you are throwing away the carpet, so you are on notice and you should tell Richard Hill, if he tries to sue me for the carpet, and you throw it away, I will sue you for fraud....(Coughlin is seen in the video walking a few feet off the sidewalk in light of the fact that Hill's contractor's crew have taken up the whole of the sidewalk (Stewart's white dumptruck is parked so as to extend from the drive way out onto the street so as to completely block the sidewalk, and beyond that, the sidewalk is dotted with various items Stewart's crew is in the process of moving from the former home law office) on the southern facing side of the property in furtherance of their efforts to load up the rest of Coughlin's personalty and take it to the dump (as there was apparently an incredibly urgent need to do something with the property, despite the fact that, to this day, over one year later, it still remains un-rented).

    Coughlin: gentlemen, you are under notice this is my property and I want it. I believe I might have some legal recourse against you for destroying my property. I could be wrong. You are certainly welcome to listen to your boss. You know what is interesting is that I have proof right here that you used my own plywood to board up the property and then you try to charge a thousand dollars for it and for fixing a leak that's my plywood Phil or whatever your name is, guy with a contractor's license. (Coughlin is saying this while in the parking lot of the studio apartments that abuts the backyard fence to his former home law office (ie, not on the sidewalk even. One of Stewart's laborers walk up to Coughlin within about 8 feet of him and snaps a flash photo):

    John Doe: What's up?. (snaps another photo of Coughlin in the parking lots of the Mill Place studio apartments)Coughlin: Hi, how are you doing? What's your name?John Doe: John Doe.Coughlin: John Doe, really?Doe: Don't get mouthy, buddy.

    - 14/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: What's that?Doe: I said don't get crowley, buddy.Coughlin: What's "crowley"?Doe: "Crowley" means like "Crowley Lake".Coughlin: I don't know what you mean. Anyways Phil what do you have to say about the fact that you fraudulently submitted a Bill for thousand dollars for boarding up the property to fix a leak yet you used my plywood to do it, Phil?John Doe: Hey, can you stay away from him (motioning to Phil Stewart)?Coughlin: I am on a public spot right here (actually, Coughlin is still standing in the Mill Place studio apartment's parking lot at this time). I am not bothering him you guys just expect people to watch you use their own property to board up a place?Phil Stewart: do you have a receipt for that?Coughlin: yeah I do. It was submitted into evidence guy. You guys submitted it into evidence as a bill. (Coughlin then walks out of the Mill Place parking lot and around Stewart's white dump truck (which was completely blocking the sidewalk) and out a few feet into the road on Court St west of River Rock, where the camera's view reveals Stewart's crew has set a couch and some other personalty on the sidewalk, where Stewart and John Dow walk onto towards the front of the property on River Rock St. to talk with Richard G. Hill, Esq.) are you going to ask Richard about that? I even ask Richard about the fact they used my own property to board up the property and charged with thousand dollars for it this gotta be an easier way to make money was and ain't that easy to be an attorney as you can see, Phil.Stewart: you obviously need to start taking your medication.Coughlin:(Coughlin has retreated back to the Mill Place parking lot at this point) what did you say? Are you making some sort of accusation or insult about taking medication? Is that what you are doing? You know it is funny because a lot of this property could've been used to feed families in need. Phil are you going to throw away the carpet and then try to bill before it is that what you are going to do some pretty sure that that would be fraud Phil. Sir, I am putting you on notice that carpet belongs to Dr. Merliss (a couple members of Stewart's crew are now seen picking up the rolled up bundles of carpet that Coughlin, whom has now walked around to the front of the property to River Rock St. walking just off the sidewalk (though a large tan/brown Silverado style pickup truck parked on the North Side of Court Street, that Coughlin recalls seeing a large manilla folder in with the notation, in hand writing, "Sargent Bradshaw" is an obstacle Coughlin must walk around, especially where Stewart himself is utilizing the sidewalk, and given John Doe's very recent request that Coughlin "stay away" from Stewart, it would seem cautious of Coughlin not to attempt to walk on the same small patch of sidewalk off Court Street as Stewart and his

    - 15/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    laborers.) Hey, Phil? Phil? The carpet, there was also some more of it right around there... Hopefully you haven't thrown it away already... Hopefully, you do not try to bill me for it Phil....(Coughlin is now standing on the sidewalk on the western side of River Rock, parallel with the northern boundardy line of the property, when John Doe appears from around the corner off of Court Street and snaps another flash bulb photograph at Coughlin).Coughlin: Sir, this is a public street. This is a public street you do not on the sidewalks are have you ever heard of a documentary? You know there's a lot of guys making documentaries these days about the bad things people do.(up rolls RPD Officer Hollingsworth on his motorcycle, and RPD dispatch chatter can be heard describing a "suspect in a larceny". Officer Hollingsworth has been called to the scene by Richard G. Hill, Esq. and Phil Stewart. Hill shows up seconds after Hollingsworth. Now, neither Hill nor Stewart were charged with "misuse of emergency services like Coughlin was in RCR2012-065630. So in this video Stewart talks with officer Hollingsworth for a few moments until Richard Hill arrives...)

    Coughlin: hey Rich how are you doing?Hill: Great, Zach, thank you buddy.Coughlin: would you prefer of psychology Mr. Hill?Hill: I would, Zach.Coughlin: Mr. Hill, how are you doing? Hey that is a cool "skulls" shirt, Mr. Hill (Hill is wearing a black Ed Hardy style bowling shirt with flaming red skulls on it.. Hill begins doing his Reno PD thing with Officer Hollingsworth, Coughlin stands back about 12 feet from their communique).

    Hill: (to Officer Hollingsworth) can we get him out of here? (and therein, besides calling 911/RPD dispatch in the first place where no legitimate reason existed to, Hill proceeds to leverage law enforcement acting with color of law to prevent opposing counsel from collectin evidence for a wrongful eviction damages analysis).Hollingsworth: first of all of gotta figure out if I have legal authority to do so.Hill: Re: court order evicting him from the property, subsequently we had him arrested for trespass is lost his appeal (which was totally not true when Hill made that false statement to a police officer seeking to have Coughlin arrested, on January 12th, 2012, given that the appeal would not be decided for months), he's lost.... Now we have been talking to our workersHollingsworth: Have you tried to get a protection order?Hill: no but we do have an order from the court disposition of the premises (unintelligible...)

    - 16/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: what about the sidewalk bridge you on the sidewalk?Hill: is been over to the transfer station Sargent Bradshaw I just left from there is Sargent Bradshaw who is been on (unintelligible)... These over here just generally being a pain in the assCoughlin: freedom of the press, Rich. (Hill starts making some big gesticulating motions to Officer Hollingsworth like a child whom is not being given the toy he wanted for Christmas or Veruca Salt throwing a fit in Charley's Chocolate Factory). They have important things to do rich they are busy. (Helen Stewart continued talking the Hollingsworth by this time Officer Del Vecchio is showed up, it looks like Officer McQuattie is there (actually, that might be then trainee Officer Leedy, Officer Look is there now too)Officer Look: hey how are you doingCoughlin: Hi, Sir, good to see you again. I didn't catch your name last time I recognize you from the the day..Look: with officer lookCoughlin nice to see you again I think I saw you the other day when came out on a call with Officer Gannon, for a domestic disturbance a run East-Sagelook: I honestly don't rememberCoughlin: Yeah, I think you guys are up in my bedroom...

    Look: Right on ScottsdaleCoughlin: Satan E. 9th St., Park Terrace Town homes... Freedom of the press, Rich.Look what you guys have going on today?Hill: contempt of court Mr. Coughlin!Coughlin: well, that carpet belongs to your client, Mr. Hill if you try to throw it away and then build me for itHollingsworth: (comes over to talk to Coughlin) can you turn that off, Sir, for a second stuff over here on over on the sidewalk (Coughlin was already on the sidewalk, but Hollingworth leads them further North along the River Rock side walk's western side). Okay so what's the deal today why are we here?Coughlin: I don't know, sir.Hollingsworth did used to live here?Coughlin: I prefer to just keep my privacy as a private citizen. But I mean you no disrespect Sir.Hollingsworth no problem, I can respect that here's the deal you understand here in the sidewalk no problem you on it student run tape no problem but you can't interfere with them doing their job and they're probably enough apply for temporary station order against you in which he/she can be within 100 yards of there or them. (Hill gets into his $100,000 Porsche Carrera where he goes off the Reno Justice Court and gets a TPO signed by Judge Schroeder within 40 minutes of the application being stamped in. Behind Hill's Porsche is Officer Look's

    - 17/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    patrol car and the patrol car being utilized by Officer Leedy and his training, tenured Officer, Officer Del Vecchio. These vehicles are in addition to the motorcycle ridden by Officer Hollingsworth. Richard Hill's wife/legal assistant Sheri Hill is parked in the lot on the east side of River Rock in her maroon Lexus SUV. Contractor Stewart is seen jaywalking across River Rock to the lot where Sheri Hill is parked, but he is not arrested.). All they are trying to do is get their business or taking care ofCoughlin: I'm trying to take care of my business, too.Hollingsworth: okay is there something we can help you with?Coughlin: I don't believe so, sir. I called the police recently I told them somebody threatened my life the the day that in six see fit to arrest anybody so apparently Richard Hill is a national treasure.Hollingsworth: Okay, well, I don't know who that is, all I know is I'm here today and you are here with the camera and you're not breaking any laws that I can see but they're gonna try to get it to where you are violating a temporary protection orderCoughlin I understand it threatening abuse of process and malicious prosecutionHollingsworth: so it would be helpful if maybe you could find something else to do this afternoon because I have been listening on the radio and we've had two or three calls for service for you already today and would like to be evidence of do some other work today, no one I meanCoughlin okay well I hear what you're sayingHollingsworth is basically a second help you withCoughlin: if you wouldn't mind telling me your last nameHollingsworth: HollingsworthCoughlin thank you, Sir, Goodbye Officer Look, good to see you again, Sir.(Coughlin then proceeds to walk back towards the mill place parking lot Western Lane along court street he does not walk in the street but rather uses the sidewalk which is now cleared of Stewart's laborers and any of the personalty they are seeking to take to the dump however the white dump truck belong to Stewart is still blocking the sidewalk. Coughlin Fox all the way back to the area in the Mill's Place parking lot immediately to the west of the fenced, gated backyard to his former home law office, and can view Officer Hollingsworth pull away on his motorcycle heading north on River Rock. Footage of contractor Stewart's white dump truck reveals how extremely implausible Stewart sworn testimony was at the February 23, 2012 Order to Show Cause hearing (which Hill had Coughlin personally served Notice of by WCSO Deputy Machen (by way of RMC Marshal Harley) incident to Coughlin arriving and waiting at the RMC for the traffic citation Trial in 11 TR 26800 stemming from the three traffic citations RPD Sargent John Tarter had issued to Coughlin incident to the November 15 incident at Hill's law office where Coughlin ventured upon being

    - 18/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    released from three days incarceration following the November 13, 2011 criminal trespass rests at Coughlin's former law office Coughlin went to Hill's office to retrieve his keys state issued drivers license and or identification his wallet and his client's files, which Hill refused to release. It took until November 22nd, 2011 before Hill turned over Coughlin's wallet and driver's license to Coughlin. It took until December 22nd, 2011 before Hill turned over Coughlin's client's files, causing Coughlin to incur great expense in arranging for alternatives. Coughlin starts to make his way back towards the front of the property and decides to walk along the edge of the parked Tan Brown pickup truck instead of venture near it be laborers working for Stewart who are now utilizing the sidewalk on the north side of court street once again. Coughlin notices the large manila envelope and the dashboard of the track with a large. Written note indicating Sargent Bradshaw on the outside of of the folder. Coughlin then crosses the street in a straight continuation from the northern sidewalk on Court St. to the parking lot on the east side of River Rock, just as any pedestrian would (except Contractor Stewart actually just walked out in the middle of the road when he crossed River Rock earlier, rather than in a straight continuation of the sidewalks. Coughlin notices Contractor Stewart milling about on the west sidewalk of River Rock just north of his former law office. This group includes Stewart, Del Vecchio, Leedy, and Look, whom are now joined by Sargent Sifre. Officer Hollingsworth has left to do some real police work by this time. Sheri Hill is still watching on from her maroon Lexus SUV in the parking lot).

    Coughlin: (talking vaguely in the direction of Contractor Stewart who is approximately 30 feet away) you might when I try to make sure you don't throw away that carpet over there because I will dispute it if you guys try to bill me for it. (Coughlin then positions himself to get a shot of the interior of the former home law office where a he sees a very sentimental item to him that he forgot to grab at the last second during the mad rush to move his property out to whatever extent possible by the 5 PM deadline December 23 this item is a 5" x 16" caricature of his former domestic partner of the preceding four and a half years from a relationship that ended in late May 2011 and himself done during the early stages of their relationship. This was amongst Coughlin's most treasured possessions and was only left atop a crown molding during the move with the idea that it would be the last thing Coughlin would grab, and therefore he would be able to place it in a safe place on his U-Hauls dash board or somewhere else where it would be safe. However, the chaos incident to Richard Hill's showing up in demanding everyone be off the property by exactly 5 PM under the threat of arrest caused Coughlin to overlooked grabbing this treasured sentimental item. This caricature is visible in the video)

    - 19/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: that is that sentimental picture that I told them about of Melissa and I. the caricature... And I believe the dolphin windchime mobile, one of the last things my grandmother gave me before she died is in there...oh, and look at that there is $150 appliance. (to Contractor Stewart). Sir I season sentimental heirloom keepsakes in their that I guess you are just going to throw it away you don't care, the last thing my grandmother gave me before she died very sentimental thing (at this point Contractor Stewart turns to the camera an makes a revolting gesture). Sir when you put a padlock on the back fence? (Hill's placing a padlock on the back fence only just about the time that it was Coughlin's right to remove his property resulted in Coughlin's progress in moving all his personalty being severely impeded.)....(At this point in the video Coughlin returns to the parking lot of Mill's Place, private property, behind the fenced back yard of his former home law office. Like a couple of goons approaching, Officer's Leedy and Officer Look venture into that private property, the Mill's Place parking lot:Officer Leedy: Mr. Coughlin could talk to for second?Coughlin: I mean neither confirming that that's my name, Sir, but you are the law under asking to speak to somebody so.(at this point Officer Look approaches Coughlin very rapidly and immediately grabs Coughlin's wrist, Couglin holding his video camera, which is, obviously, still filming, as Officer Leedy and Officer Look immediately jump straight to applying excessive force to Coughlin's wrists. Officer Look jumps at Coughlin from Coughlin's left side and Officer Leedy sneeks around behind Coughlin and grabs Coughlin's camera out of his right hand and turns it off)Officer Look: video camera down, put your camera down.Coughlin:Whoa! Whoa! Why are you touching me! (Officer Look is captured on video breaking back Coughlin's left wrist and wrenching Coughlin's left arm behind his back, prior to any sort of attempt to peaceably approach Coughlin, a license attorney, whatsoever, but then accidentally turns it back on a second later, a fact to which he is unaware. Officer Leedy places both of his hands on Coughlin's right side and right arm and wrist in a display of excessive use of force.)Officer Leedy: We don't want your camera....Coughlin why are you touching me this is not their properties, Sir? (the camera goes black for a moment)Coughlin: Owww!. You are breaking my wrist!! Oww! Owww!! Help!!! Help!!! My wrist hurts, somebody call 911. Owww!! Owww!!! Somebody help!!! Somebody help!!! Sir, there is no need to break my wrist like that, Sir. Oww!!!. Oww!!!Why are you handcuffing me, Sir?Officer Leedy: You are being placed under arrest.

    - 20/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: For what? For what?Sargent Paul Sifre: They'll explain everything to you in a little bit (but, actually, Coughlin would not be told what he was charged with for over an hour and a half, and in the intervening period while he was handcuffed and placed in the Officer Leedy's patrol car, with tenured training Officer Del Vecchio (whom had handcuffed Coughlin, and placed him in the back of his patrol car on night in July 2011 incident to Del Vecchio drawing his weapon, or appearing to, on both Coughlin (whom was walking his bike at the time) and another bicyclist in front of Coughlin's former home law office at approximately 10 pm at night, all because Officer Del Vecchio felt the light on Coughlin's bike was "not up to code").Sargent Sifre: I am going to shut your camera off so the battery will not run down.(Officer Del Vecchio can be seen in the video at this point walking around in his acid wash jeans).Coughlin: I don't wan't it shut off, Sir. You are obstructing justice if you shut it off! (Sargent Paul Sifre then shuts off the video camera whereupon Officer's Look and trainee Officer Leedy continuing applying the wrongful use of excessive force to Coughlin's arms and wrists as they pin him face down to the concrete with a smug, nauseating Californian transplant name Sargent Paul Sifre (whom incident to another wrongful detention of Coughlin on March 29th, 2012 told Coughlin he doesn't like Nevada or Reno, but the job he has pays him so much, and he has so little chance of finding such an arrangement in any local more to his liking, that he essentially has a pair of "golden handcuffs" tying him to Northern Nevada, which he detests, before going on to tell Coughlin about how he lead his little league team in both home runs and strike outs, then proceeding to ramble on unconvincingly about how he was "trying to get you the help you need", in a tone that was more suggestive of a veiled threat to Coughlin, the import of which was clear, ie, that Coughlin better not complain anymore about the RPD's police misconduct, such as Coughlin did in his written complaints to the RPD on September 7th, 2011 and January 8th, 2012 wherein Coughlin complained of the police misconduct by RPD Officers Nick Duralde and Ron Rosa during the wrongful arrest of Coughlin on August 20th, 2011in RCR2011-063341 (written complaint submitted to the RPD on September 7th, 2011 and supplemental on January 8th, 2012, at which time a written complaint against Nevada Court Services, RPD Officer Chris Carter, Jr., and Sargent Marcia Lopez incident to their police misconduct during the November 13th, 2011 wrongful arrest of Coughlin in RMC 11 CR 26405. Sargent Sifre would again order Coughlin arrested less than 48 hours later in RCR2012-065630 for "misue of emergency communications services". In between these two arrests RPD Officer Duralde would get a chance to retaliate against Coughlin incident to pulling Coughlin over in his car in the early morning hours of January

    - 21/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    13th, 2012, after Coughlin bailed himself out of jail and use a combination of a cab ride and walking to get to his car in 20 degree whether on a very windy night. Coughlin instantly recognized Sifreon January 14th, 2012 from seeing him on January 12th, 2012 as on both days fact that Sifre was wearing a short sleeves uniform shirt emphasizing his tribal armband tatoos, and body builder biceps.

    ...See attached in Exhibit 1 the videos from all of these varius wrongful arrests by local law enforcemtn of Coughlin

    While it may be expendient for some in local law enforcement to discredit Coughlin or have him "committed", it does not make it legal, and it does not vitiate the import of law enforcement misconduct in all of the wrongful arrests of Coughlin since August 19th, 2011.

    Coughlin was just informed by his mother that this same Officer Travis Warren, along with another

    RPD Officer and "two social worker types" met with Coughlin's mother, Very Special Arts of Nevada

    (VSAN) Program Director Mary Barker, and Coughlin's father, Dr. Timothy D. Coughlin, MD, of Reno

    Family Physicians at Dr. Coughlin's medical office in an purported attempt to have Coughlin "committed"

    sometime in approximately February 2012. Such a meeting is conveniently and suspiciously close in time

    to the video transcribed above wherein Sargent Lopez essentially admits that she and Officer Carter lacked

    probable cause for a criminal trespass arrest of Coughlin (and, upon information and belief, the RPD was

    served a subpoena by Coughlin requiring Carter and Lopez's presence at Trial, though neither managed to

    show up, despite the City Attorney's having previously subpoenaed at least one of them for that purpose as

    well...It seems to City Attorney's Office got wind of how terribly fraudulent Officer Carter's probable cause

    sheet was (and Carter did tell Coughlin, in the "Zach's arrest 010.mp4" video that Carter would put his

    name on the "arrest sheet if you have any problem with that" in response to Coughlin mentioning to Officer

    Carter that the police did need to have probable cause to make such an arrest. Further troubling is the fact

    that RPD Sargent Sifre had Coughlin arrested just over 24 hours after Sargent Lopez put her foot in her

    mouth her, bringing 5 other RPD Officers with him on January 14h, 2012 to respond to a 911 call by

    - 22/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin reporting the disappearance of his Pekingese dog, Jackson Pawluck, and the menacing statements

    connected thereto by the house mates against whom Coughlin would eventually be awarded two different

    TPO's.

    Just about 12 hours prior to Sargent Lopez and Officer Warren and Officer Avila arriving at

    Coughlin's E. 9th St. rental in response to a call by Coughlin reporting a domestic dispute (two of

    Coughlin's tires had been slashed and his license plate had turned up missing), just after Coughlin spent his

    last $160 bailing himself out of jail incident to the January 12th, 2012 "jaywalking" arrest ordered by RPD

    Sargent Paul Sifre, Coughlin was pulled over while driving home his vehicle after making his way to it

    from the Washoe County Detention Center (which had seen fit to release Coughlin exactly a couple

    minutes after the last RTC bus had left for the night (on a night where the temperature was a balmy 25

    degrees, with a considerable wind chill on top of that) by the same RPD Officer Nick Duralde (whose wife

    is an emergency communications dispatcher, Jessica Duralde, which complicates matters considering that

    the petty larceny of an iPhone case, RCR2011-063341 stemming from Duralde's wrongful August 20th,

    2011 arrest of Coughlin has involved an inquiry wherein Duralde's basis for alleging he was justified in

    conducting a Terry Stop "weapons check pat down" and or a search incident to arrest was largely premised

    upon some purported "information he received from dispatch" of a "disturbance or possible fight", despite

    the fact that none of the discovery, 911 logs, dispatch reports, etc. propounded to Coughlin mention a

    "possible fight", but they do mention a "disturbance" and "possible larceny of a cell phone" and the "RP

    (reporting party) screaming at the accused". DDA Young may need to answer for just where this whole

    notion of Duralde being dispatched mention of a "possible fight" comes from exactly, other than the

    prosecutors wish list of things he wishes there was documentation of to support his hopes of proving

    Coughlin's Fourth Amendment rights were not violated by an Officer eager to show up the lawyer in front

    of some teen-agers and early twenty-somethings. To be fair, those youths did a fair amount of lying that

    - 23/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    night in their fraudulent attempts to cover up the conduct of Cory Goble, which may be tantamount to

    having abandoned (and if Goble did not abandon it, then anyone whom claimed it in response to the "man

    holding a six-pack" offering it up and threatening to "throw it in the river if someone doesn't claim it right

    away", arguably "saved" the iPhone from being destroyed in connection with Goble's alleged negligence or

    abandonment of it, and thereby, the iPhone was no longer Goble's, if it was, indeed, his to begin with

    (which is unclear given Goble's contradictory statements in that regard where he alleges that he himself

    bought it three years previously, according to Duralde in his Supplemental Declaration incident to his arrest

    report, in comparison to Goble's testimony on the August 29th, 2012 Trial date in RCR2011-063341,

    wherein Goble alleges his brother bought it for him three years previously, not that WCPD Jim Leslie

    would undertake any investigation or issue a subpoena to clarify such a thing, mind you) his three year old

    iPhone 3G (Goble's friend testified that Goble set it down on the concrete ground at around 11:00 pm or so

    on a Saturday evening in the downtown Reno skate plaza in front of City Hall (and Goble's statements in

    his Witness Statement, that he was "skateboarding 15 feet away from the phone" conflicting sharply with

    both Goble's statements on the audio tape of his 911 calls (wherein he admits to having been at his Jeep at

    the relevant time, which was, apparently, according to Goble's friend Nathaniel Zarate's testimony, parked

    on the west side of the skate plaza, on Virginia Street, whereas some still unidentified "man holding a six-

    pack" whom Zarate alleges picked up the phone off the ground and held it aloft (and Zarate's friend Nicole

    Watson admitted on a video filmed by Coughlin upon his being released from 7 days in WCDC, where this

    lifelong resident of Reno, an attorney, whose entire immediate family lives here, who had no criminal

    record previous convictions aside from a January 2003 "dry" reckless driving conviction, was denied an OR

    release by a retaliatory WCDC staff for 7 days, and where Coughlin's bail was impermissibly inflated by

    Duralde's fraudulent overcharging as felony grand larceny for the purported theft of an item that was three

    years old and on worth "between $250 and $300" when it was bought new three years previously. The

    - 24/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    RMC impermissibly violated NRS 5.011 when Judge Gardner held Coughlin's arraignment in 11 CR 22716

    on October 10th, 2012 during the pendency of the Order for Competency Evaluation of Coughlin in

    RCR2011-063341. So, Officer Duralde and five other RPD Officers just happened to be hanging around

    Coughlin's car when he finally made his way to it upon his release from jail in the early morning hours of

    January 13th, 2012. Coughlin had previously filed a written complaint against RPD Officer Duralde and

    Officer Ron Rosa on September 7th, 2011 and January 8th, 2012, making such a large show of force

    incident to that pull over (for a license plate that just so happened to all the sudden turn up missing", and

    the main suspects would be the RPD, or Coughlin's then house mates, or, finally, some stranger). A video

    of the wrongful arrest was taken by Coughlin, and here is the transcript (of the video Coughlin took of the

    August 20th, 2011 petty larceny arrest in RCR2011-063341):

    RETALIATORY ARREST: "Let him do his job or we will call the Nevada Bar and tell them how you cooperated with our investigation. How's that runnin' for ya?" and "Now, your're under arrest ofr larceny. Now we can search you incident to arrest. How's that?"

    On the video/audio recording of the arrest ( VID_20110820_232801) the file name of which represent an accurate time stamping of the time at which the video file began recording on 8/20/11 at 11:28:01 pm incident to the petty larceny charge Coughlin is currently facing in RCR2011-063341)

    (3 second mark)Coughlin: I am scared of you young kids...you have nothing to lose, of course I'm scared of you...please don't hurt me...you have clearly scared me"

    (at approximately the 22 second mark RPD Officer Duralde arrives on the scene)

    Austin Lichty: We saw it light up in his pocket. He won't give it back.Robert Dawson: He won't give us the phone he stole.

    (27 second mark)Zarate: I saw the whole thing.(28 second mark)Duralde: Do you have the phone?...Is it in your pocket?" Coughlin: What?Colton Templeton: The iPhone!Lichty: Don't play dumb, just give it to us!Duralde: The iPhone.(41 second)Coughlin: Don't I have a right not to answer an Officer when he inquires as to what is in my pockets? Unless this is a Terry Stop, but I don't think this is a reasonable cause to do a pat down...Duralde: It is a reasonable cause to do one.Coughlin: Perhaps, you might be right.

    (54 second mark)

    - 25/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Templeton: And if he calls it and it lights up in his pocket, will that prove it?Duralde: Set your bike down on the ground, and move over there for a pat down.

    (1:00 minute mark)Coughlin: This dog likes to run away, Officer, can I tie it to something? Duralde: Tie it to your bike.Coughlin: Okay.

    Austin Lichty: Corey, We can call it. Let's call it.

    (1:02 mark).Duralde: Dude, I am going to be real with you right now, the kid will probably be fine if you give him the phone back, if not, we are going to get it out of your pocket and you are going to go to jail .

    (From the 1:08 mark to the 1:28 mark Coughlin ties his dog to his bike and moves several feet south towards the Siena in response to D's direction.)Templeton: You want to go to jail over a iPhone that's not yours?Lichty: You have a touch screen phoneGoble: Seriously, I don't get it, you just said iPhones are played out...

    (1:28 mark)Duralde: Face that way, other hand on the back of your head...this hand on the back of your head, there you go...(1:32 mark)Coughlin: Can, I say one thing Officer? I'm a lawyer.(1:36 mark)Duralde (startled): Okay! (strange slipping/click sound emitted on video of arrest at this point)Coughlin: You just touched my junk! Officer, I don't appreciate you touching my penis. I am a lawyer, and you haven't even asked me a question yet and you are handcuffing me. I don't see how this is a Terry Stop. I wish you would tell me why you are proceeding like this.(2:00 minute mark)Alaksa: You are a suspect in a larceny of a phone. You have been identified by a victim as a suspect in a larceny of a phone. We are conducting an investigational stop. We checked you for weapons to make sure that you do not have any weapons,.Zach: Those young men assaulted me, I do not see them being handcuffed.(2:35 mark)Duralde: Dude, you are the one who is accused of the frickin' crime.Coughlin: I am accusing them of assaulting me.Duralde: Okay, and I am saying that is unfounded how are you injured.Coughlin: Uh, assault isn't injury, its apprehension of imminent bodily harm.Duralde: Okay, so what did they do?Coughlin: They grabbed me, they pushed me, they reached into my pocket, and they pulled my dog from me, Duralde: If they touched you its not assault. Coughlin: ...As a gang of skaters, twenty of them backed me up into oncoming traffic.(3:05 mark)Duralde: Citizen's arrest. They wouldn't have been coming after you if you hadn't stolen the kids phone.Coughlin: Officer, let me tone this down a little bit, okay. I have respect for you.Duralde: What is your name?Coughlin: Zachary Coughlin, Nevada Bar number 9473.Duralde: I don't care what your bar number is, what is that? How does that bare on this?Coughlin: Well, maybe it bares towards...okay, you seem to not respect or be willing to hear anything an attorney says, yet a group of skaters you believe wholeheartedly.Duralde: Do you have the phone?Coughlin: I'm not an...well, let me think about that....Do I have the phone? Do I have a right not to answer your question?

    - 26/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    (3:41 mark)Duralde: Just don't talk anymore.Coughlin: Okay. (3:45)Coughlin: Do you have a right to search my pockets right now?

    Duralde: What is your last name, how do you spell it?(3:55 mark)Coughlin: Am I under arrest?Duralde: Dude, you are detained for a crime we have every right to identify you.Coughlin: So, I think its under the Hiibel case where the guy refused to give the police officer his name?Rosa: Its called 171.123, Terry Stop. You can provide your name or be arrested for obstruction.Coughlin: You know what I'm talking about.RPD Officer Rosa: Yeah, I know what your are talking about.Coughlin: Search incident to arrest.RPD Officer Rosa: That's not what your being...you are being detained, dude.Duralde: You are not under arrest.Coughlin: Okay.(4:15 mark)RPD Officer Rosa: Provide your name or go to jail for obstruction, and we will call the Nevada Bar and let them know how you cooperated with our investigation, how is that runnin' for ya? We are tired, and we are busy tonight, we have got better things to do tonight than be out here and debate the law with you. Give the man your name and let him do his job. Is there anything wrong with that?Coughlin: Well, can I ask you a question?RPD Officer Rosa: No! You can't, just provide your name and information or go to jail. Those are your options, we are done discussing the law.(4:40 mark)Coughlin: Am I under arrest?RPD Officer Rosa: How many times do I have to tell you, your are being detained.(4:42 mark, dispatch radio traffic can be heard in the background from the Officer's radio saying "3994", the State failed to produce any dispatch recordings despite being served with a subpoena and despite the fact that such radio traffic is recorded under RPD policies).RPD Officer Alaksa: A decision has not been made(4:46 mark, off in the distance)Skater voice, likely Templeton's: It will either light up or vibrate.

    Coughlin: Okay, Can I just ask a question? RPD Officer Rosa: What is your question.Coughlin: I have total respect for you, believe me, I do.

    (4:51 mark off in distance)Goble: He might have switched it over and or flipped it over.

    (4:52 mark)RPD Officer Rosa: Well then give the man your name, show him a little respect.

    (4:54 mark)Goble: He might have flipped it over to the right if it isn't in there then.Licthy: Yeah, that is what he did.

    (4:58 mark)Coughlin: Can you ask these kids to back off so we can tone down this situation..RPD Officer Alaksa: You guys can you leave us along! Back off! I said I would help you out. Okay, allow me to do my job, okay?

    - 27/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    (5:02 mark, radio dispatch traffic remains audible)

    (5:07 mark)Duralde: Now, you are under arrest for larceny. Now, we can search you incident to arrest. How's that?Coughlin: Well, I mean, I wish you had asked me some questions prior to arresting me, I mean, it might look better for you.Duralde: Stand up!(5:39 mark)RPD Officer Alaksa: Who do you live with, Sir.Coughlin: At this point Officer, though I respect you, if you guys want to play so hardcore with me, you know...RPD Officer Alaksa: I want to try to help you with your dog and your bike, who can take care of your dog?Coughlin: I live alone.(5:52 mark, RPD Officer Duralde removes Coughlin's HTC G2 smartphone from Coughlin's right side short's pocket, looks at the screen light up after touching it, and presses the red recording button to stop the video recording).

    The RPD and or Reno City Attorney's Office misconduct justifies a tolling of any deadline to file a

    Motion for New Trial, or Arrest Judgment, or any other deadline given the many instances of such

    wrongful conduct, including the following January 14th, 2012 arrest of Coughlin in RJC RCR2012-065630

    for "misuse of emergency services" (and add to that the repeated fraud by the pre-trial services staff at the

    WCDC in lying and comitteing misconduct incident to their retaliatory dealings with Coughlin). Here is a

    transcript, in relevant part, of at least some of the video and or audio recordings of the momenets prior to

    the arrest in RCR2012-065630 (and ECOMM and DDA Young and the RPD/State's misconduct in refusing

    to turn over excuplatory recordings and materials in that matter further provides a good cause, tolling,

    excusable neglect basis for granting the relief requested herein).

    TRANSCRIPT OF RECORDING OF RPD INTERACTIONS, IN PART, OF COUGHLIN INCIDENT TO CUSTODIAL ARREST FOR MISUSE OF EMERGENCY SERVICES INCIDETN TO CUSTODIAL ARREST OF COUGHLIN ON JANUARY 14TH, 2012 IN RCR2012-065630:

    RPD OFFICER SCHAUR: how are you doing over here?Coughlin: not so good.Schaur: What's wrong.Coughlin: My dog is gone.Schaur: What kind of dog do you have?Coughlin: Pekingese.Schaur: Peningese? I didn't see a Pekingese when we were comin' in here...do you have a tracker on it or somethin' on it, one of those little scanners?

    - 28/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin: Like a microchip? You have six cops here? Why? I recognize this guy over here (refercing RPD Sargent Paul Sifre, whom admits to having ordered Coughlin be subjected to a custodial arrest for "jaywalkign" which obstructed justice incident to Coughlin collecting evidence for a wrongful eviction lawsuit stemming from RJC Rev2011-001708.) You arrested me for jaywalking the other day.RPD Sargent Paul Sifre: No, I didn't arrest you for jaywalking but I was on the scene.Coughlin: what was your name?Sargent Sifre: Here's the deal...what do you need today?Coughlin: My dog is gone, threatening statements and smirks were made by the two women or girls in here and the man......Sifre: You are not injured or anything?Coughlin: No, sir.Sifre: are these your roomates?Coughlin: she wasn't she moved in afterwards, it's my understanding she is supposed to be living with her mother. Can I go in there an here what they are saying (motioning to the RPD interviewing Laura Foreshee and Stephanie Allaback).Sifre: No, you have to stay here, we have to figure out if you even have a domestic relationship.Coughlin: So, you didn't arrest me the other day?Sifre: No, I was on the scene, though.Coughlin: So, who did arrest me?Sifre: its on the paperwork.Coughlin: Who did arrest me? Officer Leedy, the trainee, or Officer Del Vecchio, the observer?Sifre: Officer Leedy, the trainee,.Coughlin: So Leedy was the trainee but he was making the arrest?Sifre, Yeah, but he was still sworn personnel. How long have you been livin' here, man?Coughlin: why wouldnt' you tell me what the arrest was for?Sifre: Yeah, they told you.Coughlin: What was it?Sifre: Pedestrian in a roadway.Coughlin: is that normally necessitate a custodial arrest?Sifre: It can be.Coughlin: Why did it need to be a custodial arrest, Sir?Sifre: That one, because I said it was?Coughlin: Why did you make that choice?Sifre: Because we had several incidents involving you yesterday, or, uh, Thursday.Coughlin: And just because they involved me, it necessitated a custodial arrest?Sifre: Yeah, you didn't qualify for a citation?Coughlin: Why was that?Sargent Sifre: I just told you, we had several incidents involving you...Coughlin: But, what if I was the victim in each incident?RPD Sargent Sifre: then you shouldn't keep putting yourself in that situation.Coughlin: Oh, okay. (Coughlin previously worked as a domestic violence attorney/advocate at Washoe Legal Services and is well familar with the "blaming the victim" methodology employed here by RPD Sargent Sifre)/Sargent Sifre: That is why you got served with the TPO (temporary protection Order filed by Richard G. HIll, Esq., incident to his abuse of process and successful attempts to obstruct justice in

    - 29/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    The cases wherein Coughlin was a victim of opposing party and or law enforcement misconduct justifying the relief sought herein, include, but are not limited toREV 2012-001082 Northwind Apts. Vs Zach CoughlinREV 2012-001083 Northwind Apts. Vs Zach CoughlinREV 2012-075658 Zach Coughlin vs Jeff NicholsRJC 2012-076746 Zach Coughlin vs Northwind Apts.REV 2012-00374 Park Terrace Townhomes vs Zach CoughlinREV 2012-074408 Zach Coughlin vs Park Terrace TownhomesREV 2012-001048 Northwind Apts vs Zach CoughlinREV 2012-001167 Northwind Apts vs Zach CoughlinRJC RCP2012-000287 Milan Krebs (Northwinds maintenance man) v. Zach Coughlin (another TPO the RPD fraudulently induced a landlord to procure against Coughlin, thanks to RPD Officer Alan Weaver, Sargent Oliver Miller, and Ltn. Kevin Brown).REV 2012-001168 Northwind Apts vs Zach CoughlinREV 2011-001492 Matt Merliss vs Zach CoughlinREV 2011-001708 Matthew Merliss vs Zachary CoughlinRJC 2012-078432 Zachary Barker Coughlin vs Superior Mini (in this matter, on approximately September 22nd, 2012, besides RPD Officer Weaver calling up Coughlin's mother an attempt to coerce her into assisting him and the RPD In violating Soldal v. Cook County, the RPD and Officer Weaver and Sargent Oliver Miller also attempted to induce Superior's Matt Grant to file another fraudulent "distrubing the peace" charge against Coughlin shortly after Weaver swaggeringly, and in a smug manner, threatened to fraudulently arrest Coughlin again for another "failure to secure a load" citation and conduct another impermissible "search incident to arrest" or "inventorying" of Coughlin's vehicle. RPD Sargent Dye and Officer Weaver had also violated criminal laws in attempting to dissuade Couglin from testifying at to their misconduct in RMC 12 CR 12420 on September 5th, 2012 (SArgent Dye tracked Coughlin down while he was deliverying materials incident to his part time job, shortly after midnight on September 5th, 2012 to attempt to intimidate Coughlin in a Scolari's desolate parking lot, and Officer Weaver made menacing gesticulations to Coughlin in court while they waited for the 12 CR 12420 case to be called, wherein Reno City Attorney committed professional misconduct in violating RPC 3.8 in amending the criminal complaint in that matter to charge Coughlin with trespassing, and RMC "defenders" Keith Loomis, Esq. and Henry Sotelo both violated NRS 178.405 and NRS 5.010 at various times by failing to abide by the stay required therein and in obtaining orders allowing their withdrawal (of course, the kept their monthly, princely $7K "side gig" payment from the RMC, which for all purposes seems to be made in exchange for their selling their criminal indigent client's down the river and or subjecting them to impromptu cross examination demanding answers to which they are not entitled, especially in Loomis's case, and otherwise withholding from criminal indigent defendant's the few inviolable rights they have, including, the right to counsel under the Sixth Amendment, the right to subpoena or call witnesses, and the decision on whether or not to testify.Storage. Loomis also committed fraud in assisting in having Coughlin incarcerated wrongfully for nearly 20 days in July 2012, including his failure to forward to the RMC the proof of insurance Coughlin provided Loomis (which had already been provided to charlatan police officer's Weaver and Dye anyways), and in coercing wrongfully from Coughlin some purported consent to view Coughlin's HIPAA protected medical records (something WCDC social worker Jan Guidetti also sought to do on behalf of RMC Judge Nash Holmes)

    - 30/42 - NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL

    MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT

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    Coughlin also took a video of the January 12th, 2012 "jaywalking" arrest in RMC 12 CR 00696,

    and Coughlin also took a video of at least part of the January 14th, 2012 arrest for "misuse of emergency

    services" (a gross misdemeanor) in RCR2012-065630. Both arrests were ordered by Sargent Sifre, as

    admitted by Sifre himself in the video Coughlin took of at least part of the January 14t, 2012 arrest. And,

    curiously, the RPD, ECOMM, and DDA YOung, despite having been loaded up with visible cameras and

    audio recorders (amongst the various 6 officers dispatched in response to Coughlin's 911 call of that night)

    have so far failed to propound (despite WCPD Dogan purporting to have made such requests and or served

    the appropriate subpoenas...though everything with Dogan has been rather "murky", with his supervisor

    Jim Leslie hovering around the case exacting a similar toll upon Coughlin's defense as that Leslie has done

    to two other cases wherein he purports to be "defending" Coughlin (in RCR2011-063341, the iPhone petty

    larceny case, which Coughlin finally managed to get Leslie booted from on October 22nd, 2012, leaving

    Coughlin little time to prepare for the November 19