12 13 12 0204 607 599 email to wcda leslie, panel, bar and others bw

7/28/2019 12 13 12 0204 607 599 Email to WCDA Leslie, Panel, Bar and Others Bw

1/16

3/4/13 Outlook Print Message

The Three E's; wcpd failure to provide essential 911 call cd discovery of

8/13 and 8/17, 2012 to Coughlin in rcr2012-065630

From: Zach Coughlin ([email protected])

Sent: Thu 12/13/12 9:34 AM

To: [email protected](j [email protected]);jb [email protected](jb [email protected])[email protected](b [email protected]);j [email protected]([email protected]); [email protected]( [email protected]);[email protected]( [email protected]);mk [email protected]([email protected]);z [email protected](z [email protected]);[email protected]( [email protected]); [email protected]( [email protected]);k [email protected]([email protected]); [email protected]( [email protected]); [email protected] ([email protected]);[email protected] ([email protected]); [email protected]( [email protected]); [email protected]([email protected]); [email protected]( [email protected]); [email protected]( [email protected]);[email protected] ([email protected]);m [email protected] ([email protected]);[email protected]( [email protected]); nevtelassn@sbcglo bal.net( nevtelassn@s bcglo bal.net);[email protected] ([email protected]); [email protected] ([email protected])

28 attachments12 7 12 declaration ofz ach coughlin 0204.pdf( 81.2 KB) , 2 6 12 email from Fortier regardingD ogan065630.pdf( 30.3KB) , 10 11 12 email fwm isue of 911 case 065630 fortier et al.htm (347.1KB) ,transparent nevada V eronicaL opez Marcia L opez 26405 22176 00696 065630 0204.pdf( 104.2 KB) , 1 1212 rpd police report 12 cr 00696 sifre leedy look nash youngk andarasb radshaw 0204 065630 redactedocrd.pdf( 3.2 MB) ,B eckett_RI20110404 0204 065630.pdf( 117.7 KB) ,B eckett and Tanner examplesspecial treatement for prosecutor and tannerpetty theft involve s16K 0204Bar_Counsel _Report__June_2011.pdf( 284.4 KB) , 11 22 12 26405M otion for Continuanceb ecauseH illon vacationH azlettD eclaration 0204 065630.pdf(4 07.6 KB) , 12 6 12 not authorized b y Clifton CustodianofR ecords W CPD 065630.pdf( 1791.3KB) , coughlin nsct docket search as of 12 7 12 0204 065630.pdf(48.6KB) , 8 20 11 unredacted dispatch logs 063341b ack from tiff.jpg.pdf( 229.0KB) , 9 7 12 063341OrderF or Competency Evaluation 0204 065630 12420.pdf( 1573.5KB) , 12 19 11 063341

GOODNIGHT'S REQUESTFOR DIS COVERY 0204 065630.pdf( 2.4 MB) , nsct docket 54844 coughlin vdist ctj oshi 01168 0204 26405 61901.pdf( 33.5 KB) , 11 27 12 065630 fax cover page post it clifton 11 2812 don't file this in stays w case file however 1 of 69 pages.pdf( 265.7 KB) , 12 6 12 26405N otice ofDeficiency ofR ecord onAppeal andF iling ofJ udicial D iscipline Commission Complaint 0204 - Copy.pdf(777.9 KB) , 12 6 12 stamped 065630 emergencyM otion forM istrial and ContinuanceG iven state's failuretimely provide discovery exculpatory - Copy.pdf( 765.2 KB) , 124 12 A ffidavit ofS erviceRJ CB ailiffJohnR eyes lacks a lack number, lacks a notary 065630 063341 067980 has noO rder attached to it orincorporatedb y reference.pdf(4 92.2KB) , paes 1 to 17 from first fax judicial discipline commissioncomplaints 0204 gardner elliot howard nash holmes sferrazza clifton final-2-2.pdf( 596.6 KB) ,P aul-D-Elcano-Jr--1070555-a stanford 0204 elliot echeverria.pdf( 67.3KB) , 01955 docket coughlin elliot gardnerelcano.pdf( 152.4 KB) , cr12-0376 coughlinj udge steven elliot 0204 docket ccwashoe.pdf( 23.9 KB) ,cr11-2064 docket coughlin v city of reno j udge elliot city attorney ro berts 0204.pdf(4 2.7KB) , paul elcanosuing rutherform chiropractice and dr ross and nichols 0204 60317.pdf( 18.7KB) , 2 3 12 22176 608380204 robertsGm ail - courtesy copy of audio of trail exhibit 1 toS upplement toOpposition toM otion toDismiss.pdf( 16.8 KB) , 11 10 12 063341 nrs 174.345 sbupoena onD uraldeR osa A laksa and others rrrcertified 1045 skau 0204.pdf( 10.5 KB) , 11 26 12 5b ig recent emails 60302 60317G arinWLS G ardner0204 60331 61383 063341 etc.pdf( 645.8KB) , 54844 COUGHLIN VS. DIST. CT. andL indaG ardner0204 0435 26405.pdf( 5.1 MB)

The Trial yesterday inR CR2012-065630 featured extended discussions regarding the failure of theW CPD,Dogan, andL eslie, to turn over discoverypropoundedb yDDA Y oung in the form of cd's featuring 911 callsDDA Youngprovided to theW CPD on 8/13/12 and 8/17/12... And the heavy hitters were there, too ( Elliot


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Sattler).....despite numerous written requests from Coughlin that theW CPD do so, andm ultiple trips to theWCPDpersonallyb y Coughlin to pick suchm aterials up, and despitem ore flip flopping on their storyb yL eslieandD ogan regarding whether they ever gave Coughlin somepackage ofm aterials responsive to Coughlin'srequest for his" file"...But, J im Leslie is stuck with the 7/27/12 date hem entions in his email, then he is stuckwith what his recent email wherein hepurports to have therein digitally transmitted Coughlin his" file", whicho bviously does not include the cd's of 911 calls( the one'sDDA Y oung took up an enormous amount of courttimeplaying, over and over( well,Y oung onlyplayed over and over theparticular calls he felt were strongest fohis case andm ost prejudicial, claiming some" cutting room floorm ishap" for the reoccurrence of certain calls,arguing that such a" happy accident" justifiedplaying them again and again, at ever increasing volumes, etc., etcApparently,I am here to subsidizeY oung'sb abym aking,j ust likeI was withM s. Gorman, as a continuance ofprejudicial length of afforded to theS tate where none was forthcoming to Coughlin, despiteL eslie andD ogan'so bstructionist tantrums, ones of aq uality that would. I remember whenm y life featured happym oments like thbirth of twins...but that wasb efore your leviathan legal system wrecked shop onm y existence. What,sir,shallmy compensation? Do you mind ifIput my arm around....http://tinyurl.com/bgmlfdr

This is a formal grievance against Dogan, Leslie, Bosler, Young...etc.

If Svengali/Diann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order them, he

better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of 911 calls DDA Youn

gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-065630, and clearly, any packet from 7/27/12 wouldn't have them (not

to even get into the flip flopping contradictory accounts by Leslie and Dogan as to who gave Coughlin the packet, or whodidn't or blah blah blah)...and certainly Leslie email below only contained a 57 page pdf...way to close to the 12/11/12 tria

date, and containing materials Coughlin had never been given before....so much easier, Jimmy Sleazy to email the client

"digital transmittal" proving what you gave and when"....but, no, that would make it so hard to fudge the accounts of wh

was contained therein, or who handed what to whom, or who failed to pick up this or that, or Dogan's slippery nonsense

"From: [email protected]

To: [email protected]

CC: [email protected]

Subject: 911 Case

Date: Fri, 7 Dec 2012 17:09:08 +0000

Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response

your request. Please note that the July 27, 2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packet

encloses a copy of the April 17, 2012, hand delivery transmittal of the very same documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to

retrieve them, we provide the attached courtesy copy before final closure of our file.

No response to this transmittal is required from you.

James B. Leslie, Esq."

So, whileD ogan states on 7/27/12 in 65630 "Y ourH onor,I have never even spoken withJ udgeD orothyN ashHolmes"...he coyly fails to indicate whether he spoke with anyone with theRM C,M arilyn Tognoni, included, owhy his 2/28/12 fax to Coughlin was so insistent that it was"L ake's Crossing'sB ill D avis,P h.D." whom ustconduct the" Competency Evaluation", or how it wasJ udge Clifton's 2/27/12O rder for Competency Evaluatiocould havepossiblyk nown and includedJ udge Elliott as the" randomly assignedj udge" to that Competency Ca


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4/16


5/16


6/16


that J udge Elliot presided over in CV11-01955 wherein Coughlin sued CAAW andWLS , despiteJ udge Elliotsitting on CAAW'sB oard, and whereJ udge Elliot, theP anel Chair at Coughlin's formal disciplinary hearing of11/14/12, andW ashoeL egalS ervice'sP aul Elcano all went to S tanford together, and whereJ udge Elliot workeforP anel ChairJ ohn Echeverria's father's law firm, Echeverria andO sborne). Then there isL indaG ardnerb einJudgeB reen's law clerk, andJ udgeB reen removing Coughlin from Mental H ealth Court inMH 12-0032, wheretheMH C'sR eneB iondo andS haronD ollarhide lied about whatm edications were listed as accepted or not in thmaterialsprovidedb yG oodnight and or theMH C along with the contract entered into with Coughlin, whom waccepted into theMH C. Then there isW CPD JoeG oodnight andJ enniferR ains refusal to file anything directedtowards enforcing theMH C's contract with Coughlin, wherein theyb oth demonstrated theyk now what side the

bread isb uttered on and indicated" therej ust isn't ab asis for seeking reconsideration ofJ udgeB reen'sO rder".JudgeP eterB reen,MD.

Funny how Dogan did not state to Judge Clifton that he never spoke with anyone else at the Reno

Municipal Court about Coughlin.... including Marilyn Tognoni...but, rather Dogan just indicated he

never spoke with Judge Nash Holmes, in his best innocent little boy voice that he cops when he isn

busy tittering away with Jim Leslie in the spectator area during the 11/19 and 11/20 Trial in 063341

(where he failed to apprise Judge Sferrazza of the fraud attendant to his earlier attestations regardi

proof of service (by fax no less) of his 11/7/12 Motion to Quash Coughlin's Subpoena....

Also, its a bit strange how Dogan and the WCPD redact or black out the names of the RPD Officers

and Dispatch Operators beginning on page 16 of the 56 page file Jim Leslie finally emailed me toda

titled "Coughlin Discovery 911 Case", which, as is their wont, he and Dogan have continued to

change their stories about whether they had or had not provided to me already until the last possib

minute before trial, whereupon, with a Trial date of December 11th, 2012 in rcr2012-065630, Jim

Leslie finally emails me a 56 page pdf purporting it to be my "file". One wonders where any audio

recordings, dispatch recordings, 911 call recordings or other media are any why Leslie and Dogan d

not provide them. Coughlin appeared at the WCPD's Office today and asked for the hard copy of h

file, yet was told by front desk receptionist "Paula" (of course, no last name provided) that she "spo

with an associate" and they told her that Jim Leslie had already provided Coughlin his file and that

he, therefore, would not be given the hard copy. "Paula" eventually seemed to have to admit that

the misleading use of the term "associate" actually did not connote her having spoken with an

attorney about the matter...but rather Linda Gray, whom has been curiously silent as to the apparen

misconduct attendant to her admitting that she did not mail out any written notice to Coughlin of

the August 6th, 2012 "combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over tha

fact by sending Coughlin a note about how he "saved the day" with his "advocacy"...skipping past t

part about how the client, Coughlin, was not noticed on the hearing in any matter, much less in

writing....Leslie later refused to indicate with any specificity whatsoever how he "knew" Coughlin had

been noticed on the 8/6/12 hearing in writing...and RJC Judges are only too willing to "believe" Jim

Leslie, Esq. when he explains away vaguely such things...

Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have continued in your way

(similar to how you approached the rcr2011-063341 case where Joe Goodnight, Esq. was counsel of

record until you had him removed on 7/16/12, the morning of Trial...after Mr. Goodnight and I have

completed a video conference final trial preparation at 4:30 pm on Friday, July 13th, 2012 while I wa

in custody (pursuant to an arrest on July 3rd, 2012, ordered by RPD Sargent Kim Bradshaw, she of t


7/16


8/16


Elcano went to Stanford with Judge Elliot and the Panel Chair of Coughlin's 11/14/12 Formal

Disciplinary Hearing before the State Bar of Nevada, John Echeverria in the late 1960s...and Judge

Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne Board of Directors, in

addition to being a former ass

In CV11-01955, Coughlin sued his former employer Washoe Legal Services, whose Executive Directo

Paul Elcano went to Stanford in the late 1960s with Judge Steven Elliot and John Echeverria, the

Panel Chair of Coughlin's 11/14/12 Formal Disciplinary Hearing before the State Bar of Nevada..and

Judge Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne, and Judge Elliot

served on the Board for CAAW, and was a prosecutor as the Sparks City Attorney.

Also, Mr. Leslie, while the 56 page pdf you finally sent me (gosh, was it that hard to click "attach",

load a 2 mb pdf file and hit "send" on an email to me? No debatin', no arguing about whether Lesl

and Dogan left the package at the desk, whether Dogan already gave it to Coughlin, or whether

Dogan then changed his story and said Leslie gave it to Coughlin, whether Coughlin already picked

up, no claims by Jessica the Receptionist of anyone kickin' furniture...nothing like that, just a digital

verifiable means of ascertaining what you transmitted and when...was that so hard? Heck, Jim, youcould probably just email those ECOMM recordings too...and if attachment size is an issue, sign up

for a www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive

functionality, and up to 100 mb attachments via plan email, and over 25 free gb of storage on the

Skydrive, etc., etc...). But its Leslie finally sent the 56 page "client's file" on or about 12/7/12, yet he

failed to include the insipid Motion of 11/26/12 by DDA Young (wherein, just after Judge Clifton

finishes telling Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even think about t

other two RJC shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just not

relevant to this proceeding"...and anytime Coughlin would point out specific basis for undertaking a

recusal or conflict analysis vis a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or theWCDA, Judge Clifton would say "your're losing me...your're losing me..." as if Coughlin was speakin

in tongues all the sudden...

So, while Coughlin is reportedly not even allowed to email DDA Young about cases not even before

Judge Clifton, or something like that...DDA Young is able to get an unnoticed, ex parte, emergency

Motion to Prho

Sincerely,

Zach Coughlin

1471 E. 9th St.

Reno, NV 89512

Tel and Fax: 949 667 7402

[email protected]

From: [email protected]


9/16


To: [email protected]

CC: [email protected]

Subject: 911 Case

Date: Fri, 7 Dec 2012 17:09:08 +0000

Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response

your request. Please note that the July 27, 2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packetencloses a copy of the April 17, 2012, hand delivery transmittal of the very same documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to

retrieve them, we provide the attached courtesy copy before final closure of our file.

No response to this transmittal is required from you.

James B. Leslie, Esq.

Chief Deputy Public Defender

Was hoe County Public Defenders O ffice

350 South Center Street

Fifth Floor

Reno, NV 89509

1-800-762-8031

Direct Dial: 775-337-4828

Fax: 775-337-4856

Email : jlesl [email protected]

The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL INFORMATION, are legal ly privileged, and are in tended for use and review only by the party sending sa

and the intended recipient. If you are not the in tended recipient, you are h ereby notified that any disclosure, copying, distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly

prohibited. If you received this communication in error, please immediately notify us at 775 -337-48 00 to arrange return of the original transmittal. Thank you.

--Forwarded Message Attachment--

Close Print

FW: misue of 911 case

From:Zach Coughlin ([email protected])

Sent: Thu 10/11/12 2:34 PM


10/16


To: [email protected]; [email protected]; [email protected]; [email protected];

[email protected]

5 attachments

011412 RJC RCR2012-065630 RCR2011-063341 RCR2012-067980 Reno Police Department Sargent Paul Sifre

arrests Reno Attorney for misuse of 911 second arrest in 2 days by Sifre of Attorney.3gp (11.8 MB) , Mental

Health Court mh-0032 contract coughlin rcr2012-065630 rcr2011-065630 5 5 2012.pdf (596.5 KB) , email to

[email protected] 4 11 2012 had the Sifre arrest video.htm (262.5 KB) , PAUL SIFRE

TransparentNevada 185k per year.htm (3.3 KB) , rcr2012-065630 4 19 12 letter from dogan with Complaint and

discovery attached and Order for Competency evaluation from 2 27 12 sifre schaur pthoa misue 911.pdf (3.6

MB)

Zach Coughlin

PO BOX 3961

Reno, NV 89505

Tel 775 338 8118

Fax 949 667 7402

[email protected]

From: [email protected]

To: [email protected]; [email protected]; [email protected]

Subject: misue of 911 case

Date: Thu, 20 Sep 2012 02:20:22 -0700

Mr. Dogan,

Oh, look at that, there is the MH C contract with Coughlin that fails to exclude the m edicationCoughlin was taking and which the MH C andB iondo cited as their rationale for expellingCoughlin, libelling him, in fact. Not that oldJ enniferR ains was going to advocate anythinga bout that? I have no idea what the purpose of even having an attorney there is? A ndJ udgeElliot was really thrown for a loop whenB iraym entioned a " social worker" on staff at theWCPD, in that transcript of the April 27th, 2011H earing that I finally gotsm y hands on.

I am curious to hear yoru theory of the case ( whether the charge b e resisting or obstructingarrest or whatever it wasY oung sought to amend the Complaint to ( somethingm ore in linewith a '"erious crime" vis a vis a S CR 111(6) analysis, or if the charge remaisnm isue ofemergency services. Please provide m e with any novel legal research you culled for this case.Additionally, yoru were already provided these videos,b ut here they are again, videos ofb otharrestsm ade or orderedb yS argent S ifre ( who gets $ 185K a year and a bout our age,B iray)within a 36 hour period of each other, with an intervening pulloverb yO fficerD uralde and 5otherRPD personnel late at night after Coughlinb onded out on the custodial arrest forjaywalking onJ anuary 12th, 2012.


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Biray, some peoplem ight say that DDA Y oung has used you, the W CDA Office has used you,the RM C andJ udge N ashH olmes have used you, andperhpas even that M r. Bosler andM r.Leslie are using you. Maybe you like it. Maybe you like b eing used. Maybe you like b eingpushed around. Maybe you love it. Maybe that is what you are good at.

Biray, please tellm e how true any of the following strikes you asb eing:

SCR 111(6): "Definition of serious crime. The term serious

crime means (1) a felony and (2) any crime less than a felony a

necessary element of which is, as determined by the statutory or

common-law definition of the crime, improper conduct as an

attorney, interference with the administration of justice, false

swearing, misrepresentation, fraud, willful failure to file an

income tax return, deceit, bribery, extortion, misappropriation,

theft, or an attempt or a conspiracy or solicitation of another

to commit a serious crime.

Coughlin's WCPD, Biray Dogan, Esq. and DDA Young, in the RJC

prosecution for "misuse of emergency services" (911 calls), whenconsidering their lack of candor to the tribunal, fairness to

opposing counsel (given Coughlin filed a Notice of Appearance and

has the right to represent himself, and is an attorney),

DDAYoung's repeated instances of violating NRS with respect to

all matters being stayed upon an Order for Competency Evaluation

being entered against a party, such a Coughlin, and the failure

of Dogan to alert Coughlin to, or provide any copy of (depsite

Coughlin's repeated written demands) the July 31st, 2012 Motionto Amend Complaint (that, upon Judge Sferrazza querrying DDA

Young as to whether the DA even needed seek an Order allowing it

to so amend such a Complaint, responded that the DA did not, but

that he was just seeking one "for purposes of keeping the record

'clean'", whatever in the world that means. When viewed with

Dogan, Young and Leslie's attempts to shuffle Coughlin on through

the MSC process (DDA Young indicated, to Judge Sferrazza, on the


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record, while attempting to check of the MSC box minutes before

the Start of the August 29th, 2012 iPhone petty larceny Trial,

that he anticipated the MSC "only taking a couple minutes, at

most" and felt it was Coughlin's "obstructionist" and "difficult"

attitude of "non-compliance" that was preventing him from

effecting his stated goal. DDA Young clearly subscribes to the

RPD Ron Rosa/Nick Duralde school of "How's that runnin' for ya"style retaliation, intimidation, and misconduct.

Most troubling about Dogan and DDA Young's apparent conspiracy to

get an Order for Competency Evaluation against Coughlin during

their clandestine MSC of 2/27/12 (which, again, Coughlin was

noticed, in writing, had been continued out to March 29th, 2012),

including impermissible communications to the RMC and Judge NashHolmes (who arguably violated NRS by continuing on with the

traffic Trial just minutes after being made aware of the 2/27/12

Order for Competency Evaluation in the RJC by Dogan and, perhaps,

by DDA Young as well, is Dogan's failure to inform Coughlin of

DDA Young's RPC 3.8 violating Motion to Amend Criminal Complaint,

wherein DDA Young seeks to alter the charge to one that would

invoke a mandatory SCR 111 Petition in light of SCR 111(6)'s

definition of a "serious crime" and the "statutory or common law

definition" of the crime for which DDA Young, though lacking

"probable cause" sufficient to satisfy his RPC 3.8 duty, sought

to have so amended to an "obstructing or resisting a public

officer" charge, which of course fits squarely in the "serious

crime" definition set forth in SCR 111(6). So, no, Judge

Sferrazza, Coughlin was not "over-lawyering it" on August 29th,

2012 during the "only take a minute at most" MSC Dogan and DDA

Young (and Leslie) sought to slip past Judge Sferrazza right


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[email protected]; [email protected]

Hotmail Active ViewVideo from YouTube

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Dear Mr. Bosler,

Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tack

commentary on my suit and tie ("so, are you workin' construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts a

humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after admittedly muzzling Joe Goodnight, who I respected

at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open

Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary

regarding Ms. Halstead was especially troubling. I am formally forbidding anyone with the WCPD from speaking with anyone with the Reno Municipal Cou

or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open court under a search incident to arrest

following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent

attempt to protect Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions ofbribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a pathetic criminal trespass arrest in the context of a civil eviction

proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was

attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of

NRS 118A.460.

RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and

utter lack of documentation in these files setting forth any reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to

filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever conducted. Further, Mr. Goodnight, the file i

he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date

vacated, and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnight

constantly quote me the "basis in fact and law" language in NRCP Rule 11 when explaining their complete failure and refusal to do anything I ask be done in

my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is inapplicable in a crimin

setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for

continuing to prosecute this pathetic gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in

FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the arresting RPD Sargent Sifre admitting he was engaging


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in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations

where they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively

rebuked such involvement by Sargent Thew. About six weeks later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre

had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation by someone other than Coughlin

who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.

The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a

retaliatory competency evaluation after Coughlin reported and criticized Dogan's failure to appear for a court date:

http://www.youtu be.com/watch?v=oU3t _kRR0RA

The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:

http://www.youtu be.com/watch?v=gBu9zflGALE

Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses.

Amazingly, you have disclosed a "Colton Templeton" while refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the

unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer Kevorkian" approach needs to cease,

Mr. Goodnight.

The Arrest:

http://www.youtu be.com/watch?v=5PR7q4OI5 b0Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:

http://www.youtu be.com/watch?v=to _UOFIccLw

Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.

Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was

sought, after a "hearing" for BOTH of the competency evaluations I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held,however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an Order for Competency

Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's

Crossing and the WCPD, and an illegal tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible

searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note attempting to describe my first trip down to Lake's Crossing. I

wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much you

office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so,

given how weak Goodnight and Hylin's rationale was for seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate

request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed out to Goodnight how very

intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, the

to divulge client confidences in open court over the remonstrances of the client.

Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's

Cross ing evaluator if I have a "private attorney". Further, she indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator

I utilize the services of the WCPD.

Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications inviolation of the duty of confidentiality attendant to the attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practic

of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based upon "hunches" and the DPD's "duty to the

court" is rather suspect.

Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff

Reyes was attempting to prevent Coughlin from standing near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender

Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions himself all over the RMC And RJC

Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he

alternates with a shingle eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal

filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G. Hill, Esq. was extremely successful in getting a protection order from

Judge Schroeder of the RJC, in a scant 40 minutes from the time he filed it no less (and that application contained perjury by Hill that was subsequently

unveiled at the hearing on Hill's Motion for Order to Show Cause before Judge Flanagan on 3/23/12), Coughlin was not so successful in getting a Protection

Order against Bailiff Reyes. While Hill's protection order application contained only unsupported hearsay, and some nonsense about climbing on a truck

(which was thoroughly discredited at the 3/23/12 Hearing in D7), Coughlin's TPO application against Bailiff Reyes actually set forth a threat of sexual assault,

yet Coughlin did not even get a hearing on the matter and now Bailiff Reyes has amped up his misbehavior. This, in combination with RJC civil office counte

clerk Christine Erickson brazen refusal to file various exigent Motion's and Notices of Appeal and other landlord tenant based filings submitted by Coughlin,despite Coughlin providing the RJC with support for his contention that such refusals are clearly in violation of established Nevada law and contribute to

substantial losses to Coughlin personally and professionaly. Most ironic of all, Bailiff Reyes, recently, explained to RJC Court Administrator Tuttle in

Coughlin's presence at the RJC civil division filing office that Reyes "does not think it is appropriate" for Coughlin to have any communications with RJC civil

division filing office staff of anything other than the most brief and sterile nature. Apparently Bailiff Reyes finds telling Coughlin, under color of law, and for

no legitimate reason, that he will "put my foot up your ass", while, curiously Bailiff Reyes somehow finds Coughlin's sayign "hello" and "how was your

weekend" to filing office staff to be "inappropriate".

Further, Richard G. HIll, Esq. threatened Coughlin at the 12/20/11 Hearing on Coughlin's Motion to Release Personal Property (where Coughlin as charged

the outrageous sum of $30 per day "storage" and forced to pay a lien for the contents of his former law office after Richard G. Hill, Esq.'s negligence cause

it to be burglarized on December 12, 2011, something for which Hill now seeks to have Coughlin pay for in his ridiculous Memorandum of Costs on appeal

in D7 in CV11-03628) when Hill exclaimed to Coughlin, in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also made threatening commentary to

Coughlin on multiple occasions seeking to prevent Coughlin from filing documents with the RJC incident to exigent eviction matters) that Hill, too, "would lik

to stick something up Coughlin's ass". Hill said this in a loud voice approximately 20 feet from Coughlin, with Bailiff Reyes and Chief Bailiff Sexton standing

near Hill, all three gentlemen sharing a good laugh, during a recess , but while in the courtroom, in RJC Rev201-001708's 12/20/11 Hearing. Judge Sferrazza

was informed of this on the record. Please place a copy of this formal complaint in both Deputy Reyes and Chief Deputy Sexton's employment and


15/16


Biray Dogan's Malpractice

From:Zach Coughlin ([email protected])Sent: Wed 4/11/12 9:51 AM

To:[email protected]; [email protected]; [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected];[email protected]; [email protected]

Hotmail Active ViewVideo from YouTube

Play video00:03:55Added on 3/19/12290 views


There was a problem connecting to YouTube. This video may not exist or it may only play on YouTube. T ry going to their website: http://www.youtube.com/watch?v=gBu9zflGALE


There was a problem connecting to YouTube. This video may not exist or it may only play on YouTube. T ry going to their website: http://www.youtube.com/watch?v=5PR7q4OI5b0


There was a problem connecting to YouTube. This video may not exist or it may only play on YouTube. T ry going to their website: http://www.youtube.com/watch?v=to_UOFIccLw

Dear Mr. Bosler,

Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tack

commentary on my suit and tie ("so, are you workin' construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts a

humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after admittedly muzzling Joe Goodnight, who I respected

at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open

Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary

re ardin Ms. Halstead was es eciall troublin . I am formall forbiddin an one with the WCPD from s eakin with an one with the Reno Munici al Cou


16/16


or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open court under a search incident to arrest

following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent

attempt to protect Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions of

bribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a pathetic criminal trespass arrest in the context of a civil eviction

proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was

attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of

NRS 118A.460.

RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and

utter lack of documentation in these files setting forth any reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to

filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever conducted. Further, Mr. Goodnight, the file i

he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date

vacated, and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnightconstantly quote me the "basis in fact and law" language in NRCP Rule 11 when explaining their complete failure and refusal to do anything I ask be done in

my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is inapplicable in a crimin

setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for

continuing to prosecute this pathetic gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in

FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the arresting RPD Sargent Sifre admitting he was engaging

in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations

where they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively

rebuked such involvement by Sargent Thew. About six weeks later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre

had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation by someone other than Coughlin

who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.

The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a

retaliatory competency evaluation after Coughlin reported and criticized Dogan's failure to appear for a court date:

http://www.youtu be.com/watch?v=oU3t _kRR0RA

The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:

http://www.youtu be.com/watch?v=gBu9zflGALE

Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses.

Amazingly, you have disclosed a "Colton Templeton" while refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the

unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer Kevorkian" approach needs to cease,

Mr. Goodnight.

The Arrest:

http://www.youtu be.com/watch?v=5PR7q4OI5 b0Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:

http://www.youtu be.com/watch?v=to _UOFIccLw

Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.

Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was

sought, after a "hearing" for BOTH of the competency evaluations I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held,

however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an Order for Competency

Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's

Crossing and the WCPD, and an illegal tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible

searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note attempting to describe my first trip down to Lake's Crossing. I

wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much you

office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so,

given how weak Goodnight and Hylin's rationale was for seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate

request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed out to Goodnight how very

intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, the

to divulge client confidences in open court over the remonstrances of the client.

Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's

Cross ing evaluator if I have a "private attorney". Further, she indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator

I utilize the services of the WCPD.

Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications in

violation of the duty of confidentiality attendant to the attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practic

of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based upon "hunches" and the DPD's "duty to the

court" is rather suspect.

Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff

Reyes was attempting to prevent Coughlin from standing near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender

Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions himself all over the RMC And RJC

Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he

alternates with a shingle eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal

filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G. Hill, Esq. was extremely successful in getting a protection order from

12 13 12 0204 607 599 email to wcda leslie, panel, bar and others bw

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