12 14 12 0204 063341 2025 email to wcpd leslie, sbn president flaherty, jim leslie is a scrappy dude...

7/28/2019 12 14 12 0204 063341 2025 Email to WCPD Leslie, SBN President Flaherty, Jim Leslie is a Scrappy Dude NRS 171.

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Jim Leslie is a scrappy dude RE: Coughlin

From: Zach Coughlin([email protected])

Sent: Fri 12/14/12 1:24 AM

To: Leslie, Jim ([email protected]); [email protected]([email protected]); [email protected]([email protected]); [email protected]([email protected]); [email protected] ([email protected]);[email protected] ([email protected])

Dear Jim Leslie, Esq.,

Jim, I need to get my discovery for the resumption of the trial in rjc rcr2012-065630...Despite your cries of "wasting county assets" at 9:05am on11/20/12 when, in your standby counsel role, you attempted to assist DDAYoung and Judge Sferrazza in further coercing from me my Fifth Amendmentrights...you seem intent on wasting county assets, as your failure to turn overthe discovery (the cd recordings of 911 calls DDA Young alleges he producedto my WCPD on 8/13/12 and 8/17/12 has not materially prejudiced mydefense in rcr2012-065630, in much the same way your failure to timely

transmit my file in rcr2011-063341 did, including your failure to produce theresults and response and production in connection with the subpoena of10/3/12, and given you were note removed as counsel of record until at theearliest 10/22/12...Kelley Dodma, ECOMM, and you have some 'splainin' todo.

Now you allege that you filed a false police report. Jim, please keep a copy ofany communications you have made to the RPD, and of course the call you

reference will be subpoenaed, and if there exists any recordings (video/audio,whatever) of the "incidents" you describe (not sure dropping of a writtenrequest for one's file/discovery to your receptionist given the fact that time isof the essence here is "distrubing the peace", but, to each his one, Iguess...however, its curious you never seem to place any restrictions on yourcontinuing to cash your sweet paychecks week after week, Jim...now you seemto be seeking some sort of protection against being served written notices orhaving them delivered, or making my ability to do some contingent upon your


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scheduling a meeting (any such meeting would likely terminate after fiveminutes, as they have in the past, with you pulling your Diana Ross-divaact....DDA Young got a good knowing laugh out of that one on 12/11/12.....).Jim, please do me a favor and reply to this email, copying the SBN andPresident of the State Bar and describe just exactly what occurred during theserecent "past several occasions"...and put it in an affidavit...also, will you

finally put in an affidavit your contentions that you "know" your office sentme notice in writing of the 8/6/12 combo-hearing date in 065630 and 067980(please also put in writing your refusal to send out subpoenas (easy under nrs174.345) to ECOMM for any calls to 911 or dispatch related to me in anyway since 8/20/12) and any dispatch to law enforcements recordings, andrecordings made by law enforcement or submitted to law enforcement byprivate parties, since that date as well. Please further indicate in writing whyyou are refusing to send the WCSO a subpoena duces tecum for any materials

related to me in any way from their civil division (that served process of theitems detailed in the variosu affidavits of services by Machen et al that havebecome of issue in 11 tr 26800, 067980, etc., etc., subpoena Northwinds LouCadia and Duane Jakob...)....See, Jim, you are still getting paid, you need to dosome work here, guy...

So cute how Biray Dogan, in the 8/21/12 Hearing in 065630 mentioned howhe "left a voice mail" for Linda Gray, but just couldn't, gosh darn it, get an

answer from her about whether she did send out written notice of the 8/6/12combo hearing...(you know, the one you testified about during our closedMardsen-lite conflict hearing in 063341...where you alleged you "knew" forsure that notice was sent, but then refused to provide any specifics as to howyou 'knew" or what you did to make sure of that..." Gray admitted toCoughlin on the phone that she did not mail out any written notice of the8/6/12 hearing to Coughlin because your office had marked his "PO BOX3961" address as "no longer good" at that time (and the audio of the 7/16/12

aborted Trial date clearlye establishes Coughlin was not provided the 8/6/12date at that time, because the temporary replacement for the suddenlydisappeared WCPD Goodnight, and DDA Young were directed to meet in thehall/counter after the conclusion of the proceeding on 7/16/12 and pick a dateand time, by which time Coughlin was taken back into custody (where he wasserving 18 days in jail due to the fraudulent bail increase in rmc 12 cr1240(another bogus "disturbing the peace charge" by the RPD...that even the Cityof Reno prosecutors had to drop (and we all know how adverse they are to


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dropping any charges, ever). Jim, why don't you just go wash the RPD's carsor something if you want to suck up to them so bad?

Please then explain to those listed above why your cross examination of CoryGoble on 8/29/12 in 063341 seemed to consist solely of an attempt on yourpart to defeat the NRS 171.136 problem the State faced, including the

exclusionary rule application, where the testimony as to the value of the phoneby the "victim" Goble was "about $80" valuation...well under the $250 neededat the time to support a "oooh, thats a felony" grand larceny charge (to quoteOfficer Duralde), and therein vitiate the legitimacy of any such arrest or searchincident thereto (unless a citizen's arrest could be established....which is whatyou spent your entire cross of Goble trying to establish, for the State'sbenefit...because you are a sleazy, spiteful, lazy, mean spirited, petty, hatefulindividual whom the DA wants on the case anytime it really, really needs a

win. Just because you have ascended to Chief Deputy status doesn't meanyou are any good at what you do, Jim, nor does it, in my opinion, providesome sheen of integrity to your act).

NRS 171.136 When arrest may be made.

1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of dayor night.

2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except :

(a) Upon the direction of a magistrate, endorsed upon the warrant;

(b) When the offense is committed in the presence of the arresting officer;

(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:

(1) There is a warrant of arrest against the person; and

(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain orarrest the person for another alleged violation or offense;

(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately afterthe offense is committed;

(e) When the offense charged is battery that cons titutes domestic violence pursuant to NRS 33.018and the arrest ismade in the manner provided inNRS 171.137;

(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violenceissued pursuant toNRS 33.017to 33.100, inclusive;

(g) When the person is already in custody as a resu lt of another lawful arrest ; or

(h) When the person voluntarily surrenders himself or herself in respons e to an outstanding warrant of arrest.
http://www.leg.state.nv.us/NRS/NRS-033.html#NRS033Sec100http://www.leg.state.nv.us/NRS/NRS-033.html#NRS033Sec017http://www.leg.state.nv.us/NRS/NRS-171.html#NRS171Sec137http://www.leg.state.nv.us/NRS/NRS-033.html#NRS033Sec018


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Sincerely,

Zach Coughlin

1471 E. 9th St.

Reno, NV 89512

Tel and Fax: 949 667 7402

[email protected]

From: [email protected]

To: [email protected]

Subject: Coughlin

Date: Thu, 13 Dec 2012 00:22:01 +0000

Mr. Coughlin:

Based on your behavior at our offices on several past occasions, including today where we had to call the

police due to you engaging in behavior constituting disturbing the peace, you are hereby directed NOT to

come to our offices without first having confirmed in writing an appointment with your assigned

attorney.

If you violate this email notification, we will contact law enforcement.

James B. Leslie, Esq.

Chief Deputy Public Defender

Was hoe County Public Defenders Office

350 South Center Street

Fifth Floor

Reno, NV 89509

1-800-762-8031

Direct Dia l: 775-337-4828
mailto:[email protected]


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Fax: 775-337-4856

Email:jl esl [email protected]

The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL INFORMATION, are legally privileged ,

and are intended for use and review only by the party sending same and the intended recipient. If you are not the intended recipien t, you are hereby

notified that any d isclosure, copying, distribution, use or taking any action relian t on said contents are CONFIDENTIAL and strictly prohibited. If you

received this communication in error, please immediately notify us at 775-337 -4800 to arrange return of the original transmittal. Thank you.
mailto:[email protected]

12 14 12 0204 063341 2025 email to wcpd leslie, sbn president flaherty, jim leslie is a scrappy dude...

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