12 16 11 cv11-01955 supplement motion to set aside dismissal howard patrick jackson evidence

SUPPLEMENT TO MOTION FOR RECONSIDERATION AND MOTION TO SET ASIDE NRCP 59, 60 DISMISSAL AND

SUPPLEMENT TO OPPOSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS and all Defendant's Motions to Quash Service,

MOTION FOR EXTENSION OF TIME TO RESPOND/CONTINUANCE; OPPOSITION TO MOTION TO TAX

COSTS SIMLUTANEOUSLY SEEKING EXTENSIONS OF TIME OR CONTINUANCE TO RESPOND

The undersigned, while still desiring some sort of extension or continuance

SUPPLEMENT TO MOTION FOR RECONSIDERATION AND MOTION TO SET ASIDE NRCP 59, 60 DISMISSAL AND SUPPLEMENT TO OPPOSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS and all Defendant's Motions to Quash Service, MOTION FOR EXTENSION OF TIME TO RESPOND/CONTINUANCE;

OPPOSITION TO MOTION TO TAX COSTS SIMLUTANEOUSLY SEEKING EXTENSIONS OF TIME OR CONTINUANCE TO RESPOND

$2645Zach Coughlin, Esq. 817 N. Virginia St. #2Reno, NV 89501Tele: 775-338-8118Fax: [email protected] for Plaintiff Coughlin

ZACHARY BARKER COUGHLIN; Plaintiff.

v.

Washoe Legal Services, et al,Defendants.

Case No:CV11-01955Dept No: 10

SUPPLEMENT TO MOTION FOR RECONSIDERATION AND MOTION TO SET ASIDE NRCP 59, 60 DISMISSAL AND SUPPLEMENT TO OPPOSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS and all Defendant's Motions to Quash Service, MOTION FOR EXTENSION OF TIME TO RESPOND/CONTINUANCE; OPPOSITION TO MOTION TO TAX COSTS SIMLUTANEOUSLY SEEKING EXTENSIONS OF TIME OR CONTINUANCE TO RESPOND

IN THE SECOND JUDICIAL DISTRICT COURT OF THESTATE OF NEVADA IN AND FOR

THE COUNTY OF WASHOE

F I L E DElectronically

12-16-2011:05:04:15 PMCraig Franden

Clerk of the CourtTransaction # 2652308

allowing for time to file a more pronounced Opposition and to avoid the undue

burden brought about by the circumstances set forth in the undersigned December

14th, 2011 Motion, hereby supplements the previously submitted filings seeking relief

from the dismissal and opposing all of the Defendants various attempts to take a look

in the mirror, er, actually litigate this case on the merits.

Attached as Exhibit 1 is an application for a Nevada Driver's license that Howard

Patrick Jackson filled out and left at my law office, perhaps absent mindedly. It

contains his date of birth and his social security number and some other identifying

information. I have redacted all information that I believe to qualify as personally

identifiable information. Attached as Exhibit 2 is a video filmed by Mr. Jackson as

he was serving Washoe Legal Services' employee and domestic violence unit worker

(advocate?) Jessica Garzae and the longest tenured, I believe, employee and senior

paralegal at WLS, Berta Mann, with both a Summons and a copy of the Complaint.

Attached as Exhibit 3 is a copy of the Proof of Service signed by Howard Patrick

Jackson with subsequent typewritten interlineations made by the undersigned,

myself, indicating that the Summons for cv11-01955 (which indicates it was issued

prior to Mr. Jackson's service on August 29th, 2011...the Summons has an issued date

of August 3, 2011, despite the fact that www.ccwashoe.com's “courtconnect” docket

for cv11-01955 does not seem to have an entry for the an Summons being issued on

that or any other date-and, perhaps, it is not supposed to, I am not sure). As such, the

undersigned believes the bulk of this Court's analysis in its dismissal Order is

addressed and the undersigned asks this court to set aside the dismissal or reconsider

it and at least address the issue that the undersigned extensively brief 20 pages on, ie,



http://www.ccwashoe.com/

whether service on Garzae (whom was promoted to something so beyond a

receptionist even while I was still at WLS) and Mann (Elcano's Affidavit is silent as

to whether Berta Mann was authorized to accept service, I believe).

The undersigned feels it necessary to underscore to this honorable Court: please

do not assume that dismissing this case will not result in the end of my ability to

access justice in connection with the wrongful termination etc from WLS. The

associated case, cv11-01986 may well be dismissed as well, largely due to the

Washoe County Sheriff's Office failure to even attempt to serve the complaints

provided to it, even where some authority exists to support the notion that Plaintiff

went above and beyond by printing out copies of the complaints and summons (and

there were some copies of the Complaints in these matters that were one page per

page full reproductions, ie, not all of them are attackable under the various

defendants legibility arguments, for which no real citation to any useful authority has

been provided...Gonsalves cites WDCR for the 8.5 by 11 inch requirement for the

motions submitted to the WDC, but fails to bring to the court any authority as to what

an “original copy” is, etc., etc. Garin merely pasted the Black's Law Dictionary for

the word “copy”. I actually spent about 4 hours researching the issue and if given the

time could provide the court with some real insight into the issue. However, please

understand, this case CV11-01955 may be my last and only chance to litigate this

matter, and a review of the record will show that beyond securing an IFP in cv11-

10896 and providing lots of materials to the WCSO in plenty of time for them to be

served or corrected, the undersigned also arranged for three other instances where

private individuals, all over 18, non parties, and residents of Nevada served or



attempted to serve WLS and Elcano, and in some cases, Torvine. Beyond MR.

Jackson's Proof of Service, the docket will reveal two other gentleman served Elcano

and WLS, with Fitzhenry also serving Torvien. Merely dismissing without prejudice

may be quite prejudicial considering the 90 days to file from “receipt” of the EEOC's

Right to Sue Letter issue, particularly where refiling would result in a later filing date

being secured, outside of the 90 day limitations period.

One would think such august institutions entrusted with such prestigious work as

performing legal aid for the indigent would perhaps take a less corporate law firm

win at all costs approach to disposing of a matter that invokes an inquiry as to

whether these institutions commit acts so counter to their very reasons for existing,

ie, sanctioning discrimination, censuring free speech, “tent-folding” (to use a term

Elcano favors) in the face of political pressure (and there is much evidence to be

presented that a cabal of far left “women's rights organizations” (though whose

rights and interests these groups actually fight for is up for debate, as, in my

experience, the often pressure the very women they are ostensibly “helping” or into

doing things these women expressly do not want to do or feel is in their own best

interest to do-the client involved in the Tahoe Women's Services interference

indicated exactly that to me and told Elcano that she felt like the Tahoe Women's

Services “advocate” was pressuring her to do things she did not want to do)....rather

some individuals in these groups seek to force their own personal political bents and

ideologies upon these women) pressured Elcano into firing the Plaintiff, whether any

legitimate reason for doing so existed or not). Opposes Tahoe Women's Services

Motion to Dismiss and Motions to Quash Service as well as all of CAAW's, and



WLS Motions, as the arguments and circumstances are substantially similar in

opposing all of their various Motions. In addition, the undersigned asks the court to

consider the extent to which the Washoe County Sheriff's Office was required to

effectuate service in CV11-01896 (though a different matter than this case, to be

sure) in combination with the diligent efforts the undersigned too in seeking to get an

Order Consolidating these two substantially similar matters and setting forth the

circumstances that required these multiplicative filings.

Also, I am basically being something or othered in Reno Justice Court right now, really having a (redacted) run on me, and to me it really underscores the lack of tenant's rights resources in Washoe County. I personally was able to work at WLS for about 18 months or so and I heard a lot more “no” “can't” “won't” “your wrong” “sir, listen to me, you aren't” and all other types of dismissive commentary instead of aggressive tenant's rights advocacy. Reno is about to become Las Vegas in that regard (actually, it already is pretty much, or worse, because at least in Las Vegas they follow JCRCP RULE 83, and print/publish and get approved by the Nevada Supreme Court the “boot the tenant out as quickly and cheaply and with as litigation supply demand risk reward costs to the landlord as possible” rule that they want to use, like JCRLV 44, whereas in the RJC, just look at what happens in the 87 page Exhibit 1 attachment to my recent filing. I was evicted in RJC Rev2011-001708 from a commercial tenancy where a No Cause Eviction Notice was all that was served, which is prohibited by NRS 40.253, then, a “rent escrow” deposit of $2,275 was forced upon me, in violation of NRS 40.253(6), Anvui, and Glazier, then I was denied my statutory right to hearing within 10 days in response to my 11/16/11 Motion to Contest Personal Property lien. The RJC finally got a hearing set, for 12/20/11, exactly one day after Richard G. Hill, Esq and Casey Baker, Esq, informed me, in writing, that they and their Beverly Hills HS graduate California Neurosurgeon client would dispose of my property (which includes client files and pretty much everything I own in the world because the WCSO came and changed the locks prior to the time set for changing them in the 10/27/11 Summary Eviction Order, which was not personally served on me, despite what the WCSO Affidavit of Service says, and which, if signed on 10/27/11, and the RJC is not open on Friday's, under NRCP 6(e), could not have been served on me until after the time at which the lockout occurred, if the “3 days for mailing” language under NRCP 6(e) does not count non-judicial days.

“NJCRCP 83: RULES BY JUSTICE COURTS Each justice or justice court in a township with more than one justice, by action of a majority of the justices thereof, may from time to time make and



amend the rules governing its practice not inconsistent with these rules. Copies of rules and amendments so made by any justice court shall upon their promulgation be furnished to the Supreme Court, but shall not become effective until after approval by the Supreme Court and publication. In all cases not provided for by these rules the justice courts may regulate their practice in any manner not inconsistent with these rules.”

AFFIRMATION Pursuant to NRS 239B.030

The undersigned does hereby affirm that the preceding document

does not contain the social security number of any person.

DATE THIS: December 16, 2011,

Sincerely,

/s/ Zach Coughlin, signed electronically

Zach Coughlin, Esq.

Plaintiff



Proof of Service:

On December 16, 2011, I, Zach Coughlin deposited in the mail a true

and correct copy of the foregoing Opposition to:

Brian Gonsalves, EsqP.O. Box 907 Kings Beach, CA96143Attorney for Tahoe Women's Services

E-Filers were served electronically, including:

Committee to Aid Abused WomenGary Fuller, Esq. Attorney for Defendant CAAW

Washoe Legal ServicesJoe Garin, Esq. Attorney for Defendant WLS

DATE THIS: December 16, 2011,

_/s/ Zach Coughlin

Zach Coughlin Plaintiff



INDEX TO EXHIBITS

1. EXHIBIT 1: Howard Patrick Jackson DMV license application with redaction of personally identifiable information; One (1) page.

2. Exhibit 2: CD containing video clip filmed by Howard Patrick Jackson of his service upon Jessica Garzae and Berta Mann, showing Summons and Complaint being served upon them at WLS on August 29, 2011 (note: I received permission from the WDC's Lori Mathews to deliver a hard copy of this CD to the court by noon on Monday, December 19th, 2011).

3. Exhibit 3: Proof of Service by Howard Patrick Jackson with subsequent typewritten notes added by Zach Coughlin; Three (3) page.



12 16 11 cv11-01955 supplement motion to set aside dismissal howard patrick jackson evidence

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