6 26 13 0204 3913 3914 opposition to motion in limine 488 pages stamped.pdf

7/27/2019 6 26 13 0204 3913 3914 Opposition to Motion in Limine 488 pages stamped.pdf

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, IFILEO I"[HO ~ l U N P A L COcI1'

, 1013 JUN26 PM 3: 19~ CLERK OF TH COURJN ~ I d I fbr No. 'Hll (tempcnrilpuSI'cnkd .sof6n1n Ordtt- ' 6OIl18Y' 1I H l E . ~ S I 0 purrReoo.NV89512Tcle InCI Fax : 9 - 0 6 71402pro """ indiFnl _ , : ; ~ ~ COUll owoint to-JUnS(1 onlr. 'f lOl pmnilt


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/he /;$ $rder prohiAited the Defendant or an agent of the Defendant from contacting(versus prohiAiting Coughlin from harassing' the *tate Bar of Nevadas Northern $ffice only(going so far as to prevent Coughlin from even mailing in the US mail harassing materials to theSBN, and, perhaps, any materials), reading:

/ * 0+/8+ $+D+D that you, the


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Coughlins N+* ")#3% otion to Disualify the +C as not responded to Ay the +Cithin . Eudicial days, Ay affidavit, as reuired Ay the procedures set forth therein) +ather thanproceed to filing a ;etition for ?rit of andamus, Certiorari, or ;rohiAition, it ould ma5e the mostsense to dismiss Aoth of these matters immediately, as the interests of Eudicial economy and Eusticeoverall calls for doing so) $n that note, the "!"!"3


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providing a copy of the cover page, Aut in this one instance ith respect to the .!"3!"3 filing in one orAoth of these matters, Coughlin is unaAle to find a complete copy of that appro1imately "3 pagefiling, hether in hard copy or digital format, and reuest the +C provide him ith one (hichCoughlin ould thereafter immediately provide a copy of to Chief Deputy ?ong')


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technically served' discovery to Coughlin, herein the "#!#!"# ;roof of *ervice Ay the +Cs Bailiff


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harassing content of any 5ind or hether they are merely filings in the N@"# matter in the *tate Barof Nevadas Cler5 of Courts records that Coughlin ould necessarily need to file to say, move for ane trial or otherise challenged the "#!"4!"# 0$0C$6 (via, say, a N+C; .#, .9, or % otion,hich, incidentally, the former to ould Ae reuired to Ae filed ithin ten Eudicial days from theentering of the "#!"4!"# 0$0C$6 )))meaning the due date for such post20$0C$6 motions ould Ae

the very day Coughlin is alleged to have delivered to the *BNs Cler5 of Court and the *BN motionsof Eust that very sort')

Defendant has filed herein various otions to Juash!Dismiss!Bifurcate, etc) these toprosecutions, to hich the +C< has failed to oppose, and accordingly, under DC+ "3(3' and ;ol5 v)*tate, such failure to oppose should result in a dismissal of these to prosecutions) n such filingsherein Coughlin has alleged issues and errors, including Aut not limited to, those regarding the *tateBar of Nevadas /emporary!1tended $rder for ;rotection


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manner of service)) /he courthouse sanctuary rule and the rule providing litigants!defendants andtheir attorneys immunity from service of process in the courthouse spea5s to the reuirements ofN+C; 4(g' (none of that information is contained in Bailiff nglishs ;roof of *ervie, ie, here hepurported to so service Coughlin (in the +eno ustice Court', hat time, in hat manner, etc)')Coughlin has at all times herein any +C Bailiff has attempted to or purported to service him

process or any other legal document hile Coughlin as in the +eno ustice Court and hileCoughlin as in the ?ashoe County ail, has asserted and therefore never aived, his rights toimmunity from not only service of process, Aut also from arrest) 0urther, the +C!+C< itself hasviolated the courthouse sanctuary!immunity rule in these to prosecutions, as defendant in a criminalcase ill not lose immunity from service of civil process Ay pleading to the indictment and Aeingreuired to give Aail) Coughlin as never served the summons in 39"3 or 39"4, and Coughlinsshoing up to the 4!"7!"3 arraignement in those matters and prior thereto further preserving hisrights in his filing of that date ith a time stamp prior to the start time of the arraignment furtherpreserved Coughlins rights in that respect) /he +C has failed to provide Coughlin any return ofservice in response to Coughlins various reuests for such as to the *ummons and Complaint in Aoth39"3 and 39"4 and Coughlin reiterates his reuests for such again here no) Greiger v) Greiger, 7

isc) #d .9., 7" N)>)*)#d 44& (*up "947', order affd, #7# )*)#d 4%3 ("st Dept"947'):)


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*chmitt, #&. )*) ###, .# *) Ct) 3"7, 7 6) d) 7#% ("93#'= ;age Co) v) acDonald, #" )*) 44,43 *) Ct) 4", 7 6) d) 737 ("9#3'= *teart v) +amsay, #4# )*) "#&, 37 *) Ct) 44, " 6) d) "9#("9"'=


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the courts of a state to attend the trial of litigation commenced Ay them against citiIens of that stateare not e1empt from service of a summons in an action Ay defendants for relief connected ith thesuAEect of the litigation commenced Ay them, here a full and complete adEustment of the rights ofthe parties cannot Ae had in the first action, and here full relief ould Ae denied the citiIens of thatstate in courts of the state of the plaintiffs residence)L0N4M L0N"M *teart v) +amsay, #4# )*) "#&,

37 *) Ct) 44, " 6) d) "9# ("9"'= arloe v) Baird, 3%" 0)#d "9 (th Cir) "9#'= 6yf2


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attorney is not suspended in any manner hatsoever)


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in all its unattriAuted hearsay and vagueness, see5 protection for (NNDB ;anel Chair cheverriasstaff, non2sensically, seems to Ae the party for hom the *BN is see5ing protection, for hich,clearly, its lac5s standing to apply for one on Aehalf of cheverria, his staff, or anyone ith theNNDB', Aeyond that the *BNs /;$ application fails to comply ith the statutory reuirement that itspecifically name hich employees it see5s to protect and hy, or provide an factual specifics as to

hy such an application is Eustified') 0urther, the *BNs /;$


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*ee N+* 33)#7%(9' (pon # days notice to an employer ho oAtained a temporary order forprotection against harassment in the or5place ithout notice or on such shorter notice to theemployer as the court may prescriAe) the person ho allegedly committed the harassment may appearand move the dissolution or modification of the temporary order for protection against harassment inthe or5place)' 8oever, rememAer, the /;$ in uestion purported to prohiAit Coughlin from

contacting the *BN Ay any means hatsoever, including Ay simply mailingsomething to the SBN)-oid for vagueness and unconsituttionalyy void regardless, the +C


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preclusion did not violate appellants due process rights #ecause a statute ao!ed appeant todirecty chaenge the order'=

*tate v) *mall, ".% N)8) 4.7, &43


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not served in accordance ith those rules and ho did not aive service of citation or appearvoluntar2ily)L0N4M /he Eudgment is void Aecause the trial court is ithout Eurisdiction and is suAEectto direct or collateral attac5)L0N.M 0or e1ample, in Eurisdictions hich prohiAit an interested personfrom ma5ing personal service on a party, personal service Ay a party renders any Eudgment or orderarising from the proceeding void, despite the defendants actual notice)L0NM 8oever, a claim of

insufficiency of process, unsupported Ay facts and documentation, is not enough to upset a Eudgment)L0N7M < suAstantial defect in notice renders an original notice fatally defective, and any EudgmentAased on it is void)L0N&M $n the other hand, a mere irregularity has no such effect on the originalnotice, and a Eudgment Aased on it is not void Aut may Ae voidaAle)L0N9M /he fact that a court acts inviolation of a statute does not mean that the resulting Eudgment is void)L0N"%M ?here a statuteauthoriIes a court to do a particular thing, and the poer of the court to act is suAEect to certainlimitations named, then a Eudgment of the court rendered contrary to the limitations named is not voidfor ant of Eurisdiction or suAEect to collateral attac5 Aut is voidaAle only)L0N""M 8oever, hereEurisdiction is statutory and the legislature reuires the court to e1ercise its Eurisdiction in a certainmanner, an act of the court Aeyond these limits is in e1cess of its Eurisdiction, and here the courtacts in e1cess of its authority, its Eudgment is void and may Ae attac5ed henever and herever it is

asserted)L0N"#M C6


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K #") ffect of status of record ?ests Gey NumAer Digest ?ests Gey NumAer Digest,udgment 5#4 n determining the validity of a Eudgment, resort may Ae had to the entire record,L0N"Mincluding the pleadings filed in the action)L0N#M < decision is facially void if an inspection of itsrecord proper shos that one or more of the reuisite Eurisdictional elementsL0N3M appears to haveAeen aAsent)L0N4M 8oever, an invalid Eudgment is not void in a legal sense unless its invalidity

appears on the face of the record)L0N.M f evidence aliunde is reuired for impeachment, theEudgment is not void Aut voidaAle)L0NM $n the other hand, the general principle is that here a courthas Eurisdiction over the person and the suAEect matter and the Eudgment rendered is not in e1cess ofthe Eurisdiction or poer of the court, no error or irregularity can ma5e the Eudgment void= it prevailseven if there is a fundamental error of la appearing upon the face of the record)L0N7M L0N"Mueller v) Ban5s, 33# *)?)#d 7&3 (/e1) Civ)


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the Eudgment is alloed to Aecome final, unless the lac5 of Eurisdiction is so gross that the Eudgmentis deemed void)L0N.M < reaffirmation agreement unaccompanied Ay a court order is not a finalEudgment on the merits and cannot Ae given preclusive effect)L0NM L0N"M n re /aylor, &&4 0)#d 47&(9th Cir) "9&9'= acoAs v) DuEmovic, 7.# 0) *upp) "." (D) Colo) "99%', Eudgment affd, 94% 0)#d"39# ("%th Cir) "99"') L0N#M ensen v) *chartI, 9% N)?)#d 7" (N)D) "9.&') L0N3M @eorgia v)

*outh Carolina, 497 )*) 37, ""% *) Ct) #9%3, """ 6) d) #d 3%9, .& )*)6)?) 494, 7% )*)6)?)3%39, "99% ?6 &4%# ("99%') L0N4M K ."3) L0N.M Disher v) nformation +esources, nc), &73 0)#d"3 (7th Cir) "9&9') L0NM +ein v) ;rovidian 0inancial Corp), #7% 0)3d &9. (9th Cir) #%%"')


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the court lac5ed Eurisdiction or if the courts action amounted to a plain usurpation of poerconstituting a violation of due process) 8oult v) 8oult, .7 0)3d ", 4" 0ed) +) vid) *erv) 7&3, 3# 0ed)+) *erv) 3d #&" ("st Cir) "99.') L0N.M ones v) @iles, 74" 0)#d #4. (9th Cir) "9&4'= Boie v)


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@N+


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0reedom 0orge Corp) v) ersey 0orging ?or5s, nc), .49 0) *upp) 99 ()D) ;a) "9'= n re arriageof NosAisch, . Cal)


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over the suAEect matter of the proceeding, and here the court has Eurisdiction over the class of caseinvolved, the Eudgment is not void on the ground that the right involved in the suit did not emAracethe relief granted) atter of state of c6aughlin, 7.4 ;)#d 79 (tah Ct)


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;)3d .%# (#%%3' (applying California la'= *eitI v) *eitI, "%7 *)?)3d 47& (o) Ct)


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application for that purpose, as a general rule it is not suAEect to collateral impeachment as long as itstands unreversed and in force)L0N9M ?hen revieing a collateral attac5 on a Eudgment, the courtpresumes the validity of the Eudgment under attac5)L0N"%M L0N"M Chicot County Drainage Dist) v)Ba1ter *tate Ban5, 3%& )*) 37", % *) Ct) 3"7, &4 6) d) 3#9 ("94%'= *onya C) By and /hrough$livas v)


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U) +60 0+$ D@N/* C) Collateral


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the voidaAle sentence) *tate v) *imp5ins, ""7 $hio *t) 3d 4#%, #%%&2$hio2""97, &&4 N))#d .&(#%%&', cert) denied, #%%& ?6 3&&94&% ()*) #%%&') < Eudgment is void only hen it is apparent thatthe court rendering Eudgment had no Eurisdiction of the parties or property, no Eurisdiction of thesuAEect matter, no Eurisdiction to enter the particular Eudgment, or no capacity to act) Broning v);rosto5, ". *)?)3d 33 (/e1) #%%.') $nly a void Eudgment may Ae collaterally attac5ed) Broning

v) ;rosto5, ". *)?)3d 33 (/e1) #%%.') 0or a Eudgment to Ae suAEect to collateral attac5, it must Aevoid) n re $cegueda, 3%4 *)?)3d .7 (/e1)


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arrant a collateral attac5 Aased on fraud)L0N&M ) #%"%')


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nc), 433 *o) #d "34. (0la) Dist) Ct)


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()D) o) "9'= @ail v) ?estern Convenience *tores, 434 N)?)#d (oa "9&9'= *tate e1 rel)+itthaler v) Gno1, #"7 NeA) 7, 3." N)?)#d 77, "& d) 6a +ep) 434 ("9&4'= Daniels v)ontgomery ut) ns) Co), 3#% N)C) 9, 3% *))#d 77# ("9&7') L0N4M selin v) 6a Coste, "47 0)#d79" (C)C)


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49., 49 /he general rule is that the aAsence of Eurisdiction of a court to render a particular Eudgmentconstitutes sufficient cause for a collateral attac5 upon the Eudgment)L0N"M /he collateral attac5 mayAe made Ay a party hose rights or interests are adversely affected Ay the EudgmentL0N#M henever itis sought to Ae enforced)L0N3M ?hile in most Eurisdictions a collateral attac5 may Ae availaAlehether the alleged lac5 of Eurisdiction is in regard to the suAEect mat2terL0N4M or over the parties,

L0N.M in some instances a Eudgment may not Ae attac5ed, in a collateral proceeding, for a lac5 ofsuAEect2matter Eurisdiction,L0NM and in particular, a party that has had an opportunity to litigate theuestion of suAEect2matter Eurisdiction may Ae Aarred from reopening that uestion in a collateralattac5 upon an adverse Eudgment)L0N7M 8oever, general presumptions in favor of the Eurisdiction ofa court to render a particular Eudgment, and of the presence of Eurisdictional facts, are applicaAle inattempts to impeach a Eudgment collaterally)L0N&M /hus, hen the Eurisdiction of a court is called intouestion in a collateral proceeding, the Eurisdiction presumptively, and in the aAsence of fraud orcollusion, is conclusively estaAlished Ay an allegation of the Eurisdictional facts contained in averified pleading)L0N9M ) City Civ) Ct) "979'= oore v) Connecticut @eneral6ife ns) Co), 7" *)D) ."#, # N)?)#d 9" ("947')


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39


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K 7%) ffect of status of record as to Eurisdiction ?ests Gey NumAer Digest ?ests GeyNumAer Digest, udgment 5497("' to 497(3' n general, a Eudgment is suAEect to collateral attac5 forlac5 of Eurisdiction if the Eurisdictional defect is apparent on the face of the record)L0N"M f theEurisdictional defect does not appear on the face of the Eudgment roll or record, the Eudgment isconsidered valid and therefore immune from collateral attac5)L0N#M nder this rule, the validity of a

Eudgment hen collaterally attac5ed must Ae tried Ay an inspection of the record alone,L0N3M and noother or further evidence on the suAEect is admissiAle,L0N4M even though such evidence might Aesufficient to impeach the Eudgment in a direct proceeding against it)L0N.M ?here the record is silent,it ill Ae presumed that Eurisdictional facts ere duly proved)L0NM < collateral attac5 upon aEudgment on the ground of the aAsence of Eurisdiction is precluded Ay statements in the record inregard to Eurisdiction or in regard to the presence of particular Eurisdictional facts)L0N7M /herecitations of the Eudgment control the rest of the record, and e1trinsic evidence cannot Ae used toestaAlish a lac5 of Eurisdiction)L0N&M /hus, a recital in the record as to the presence of Eurisdictionalfacts may not Ae impeached or contradicted in a collateral proceeding Ay evidence outside the record)L0N9M n determining hether a lac5 of Eurisdiction is apparent from the record, so as to arrantcollateral attac5 on the Eudgment, the court loo5s to the hole record, hich includes the pleadings,

the return on the process, the verdict of the Eury, and the Eudgment or decree of the court)L0N"%M ngeneral, a recital in a Eudgment of the presence of a Eurisdictional fact may Ae impeached in acollateral proceeding Ay a positive contrary shoing of the remainder of the record upon hich theEudgment is Aased)L0N""M /his is particularly true here the recital in the Eudgment e1pressly refersto the record evidence upon hich it is Aased)L0N"#M /he recital is regarded, in collateralproceedings, as conclusive, hoever, unless the contradiction Ay other parts of the record is direct,e1plicit, and irreconcilaAle)L0N"3M C6


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/eynor v) 8eiAle, 74 ?ash) ###, "33 ;) " ("9"3') L0N"3M /on of ;oint ;leasant v) @reenlee 8arden, 3 ?) -a) #%7, % *)) %" ("9%7')

K 7") ffect of status of record as to notice or process ?ests Gey NumAer Digest ?estsGey NumAer Digest, udgment 549.(#', 497(#', 497(3' ?hile a Eurisdictional challenge in acollateral proceeding may Ae Aased on inadeuate service,L0N"M the failure of the record of a court of

general Eurisdiction to recite a service of summons alone does not suAEect the Eudgment to collateralattac5)L0N#M ?here the record of a Eudgment is silent ith respect to the shoing of service or noticeon the parties, it may not Ae collaterally attac5ed Ay evidence outside the Eudgment record)L0N3M8oever, the rule that a Eudgment may Ae suAEect to collateral attac5 Aecause of its rendition againstone ho as never legally served ith process of the court may Ae applied here the aAsence, ordefect, of notice or of service of process appears upon the record)L0N4M /he recital of due service ofprocess, in the Eudgment, may Ae impeached in a collateral proceeding Ay a positive contrary shoingof the remainder of the record upon hich the Eudgment is Aased)L0N.M ?here the remainder of therecord positively shos a void service of process, the recital in the Eudgment does not give rise in acollateral proceeding to a presumption of another service)L0NM 8oever, there is authority for thevie that upon collateral attac5 a recital in a Eudgment of due service of process upon a defendant

imports aAsolute verity and may not Ae contradicted Ay other portions of the record shoing a failureto comply ith the reuirements of la as to service of process)L0N7M < recital in a Eudgment of dueprocess ordinarily may Ae impeached or contradicted upon collateral attac5 Ay an officers returnappearing in the record, particularly here the recital in the Eudgment refers to and identifies theprocess or the return upon hich the recital is Aased)L0N&M L0N"M Nore1 ;etroleum 6td) v)


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n re $verstreet, &." *)?)#d 4.& (Gy) "993') L0N4M -oigt v) *avell, 7% 0)3d "..# (9th Cir) "99.')L0N.M 6eis v) *tate e1 rel) vans, 3&7 *o) #d 79. ()*)#d 4"(3d Dept #%%&' (censure') L0N4M KK .& to %) L0N.M 8arms v) Bierman, 3" ll)


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L0N"M *tate e1 rel) DeAlasio v) ac5son, ##7 ?) -a) #%, 7%7 *))#d 33 (#%""') L0N#M$Connor v) 0irst Court of


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*))#d "&3 ("9&4' (falsifying puAlic records as violation of oath of puAlic officer'= Bron v) *tate,&4 N))#d .#9 (nd) Ct)


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*)?)#d "%.4 ("943'= n re @uardianship of adisia5, 4 $hio *t) 3d "7, .93 N))#d "379 ("99#')


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Corporation, "%4 0)#d "%7, "##


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that had no Eurisdiction over the matter that had Aeen presented to Eudge through an unusual ande1traordinary procedure, and hen e12husAands counsel ould not Ae Aullied into going along ithEudges attempts to circumvent procedures and the la, Eudge e1cluded counsel and dealt directly ithe12husAand, threatening him ith the loss of custody of his other child unless he accepted Eudgesagreed order) )*)C)) #%%') udge does not lose Eudicial immunity Aecause anaction is erroneous, malicious, in e1cess of authority, or disregardful of elementary principles ofprocedural due process, as long as the Eudge had Eurisdiction over the suAEect matter Aefore him= aEudge ill loose the cloa5 of immunity only hen he conducts proceedings over hich he lac5s anysemAlance of suAEect matter Eurisdiction) *tiggle v) /amAurini, 47 0) *upp) #d "&3 (D)+)) #%%')

ore and more there is a uestion as to hether the +Cs "#!#%!"#


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-) 6iaAilities


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ohn v) Barron, &97 0)#d "3&7, " 0ed) +) *erv) 3d "3. (7th Cir) "99%'= Ne


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disualification of Eudges are meant to Ae self enforcing)L0N3M ;ractice @uide: Ne statutorydisualification provisions ill not Ae applied retroactively)L0N4M /he purpose of a Eudicial recusalstatute reuiring a Eudge to disualify himself or herself hen the Eudges impartiality mightreasonaAly Ae uestioned is to promote puAlic confidence in the integrity of the Eudicial process)L0N.M 8oever, a disualification statute is not intended as an instrument to secure delays or

postponement of trialL0NM and should not Ae employed to produce inconvenience and aAsurdity)L0N7M L0N"M ndustrial ndemnity Co) v) *uperior Court, #"4 Cal)


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Gaye, 9. N)>)#d .., 7#" N)>)*)#d .&&, 744 N))#d "#3 (#%%%'= n re Disualification of Corts, 47$hio *t) 3d %", .4 N))#d 9#& ("9&&') L0NM atter of +onin, "39


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action and might Ae compelled to testify aAout it at a later proceeding)L0N3M n other cases, the Eudgehas Aeen held not to Ae disualified here the material evidence ithin the Eudges 5noledge couldAe oAtained from other itnessesL 0N4M or from the record of a prior related proceeding over hichthe Eudge presided)L0N.M L0N"M +ush v) ?allace, #3


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representative capacity, or relationship of Eudge to one ho is a party in an official or representativecapacity, as disualification, "%


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court to estaAlish an appearance of impropriety that reuires disualification= an oAEectivelyreasonaAle Aelief that the proceedings ere unfair is sufficient) DeNi5e v) Cupo, "9 N)) .%#, 9.&


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disualification in a proceeding here the Eudges impartiality might reasonaAly Ae uestioned and toavoid even the appearance of impropriety) Const) ;t) ",


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affd, ..7 *o) #d "3"" (


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preEudice)L 0N"M


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renders the Eudge disualified, despite the fact that the Eudge as not at all involved in the actualprosecution)L0N"M 8oever, other courts have reached the conclusion that a Eudge is not disualifiedif he or she did not appear personally or participate in the action,L0N#M freuently reasoning thatdisualification on such grounds ould hamper the smooth operation of Eudicial administration Aycausing too many disualifications on technical grounds)L0N3M < Eudge ho as a former prosecutor

is not disualified from hearing a criminal case if the crime occurredL0N4M or the information asfiledL0N.M after the Eudge as appointed) $ne ho has personally prosecuted or Aeen activelyengaged in any ay in the prosecution and conviction of one accused of a crime is disualified fromsitting as Eudge in a matter 4


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prosecuted the defendant in the prior felony cases,L0N4M though there is authority that Eudges aredisualified from sitting or acting in criminal cases on the ground that they previously prosecuted thedefendants in unrelated criminal proceedings that are Aeing adduced to prove the defendants status ashaAitual criminals or to enhance sentencing)L0N.M L0N"M )*) v) Bauer, "9 0)3d 4%9 (&th Cir) "994'=rAy v) *tate, 4#9 *o) #d ""79 (


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herself only from consideration of a particular issue in a case and may consider other issues severaAlefrom that reuiring recusal)L 0N""M *ua sponte recusal is unnecessary if the parties consent to theEudge hearing the case)L0N"#M t is as much the duty of a trial Eudge not to self recuse hen there areinsufficient grounds to do so as it is to self recuse hen there are grounds to do so)L0N"3MC6


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8urther, -9C *aiiff Engish's purported :P-OO8 O8 SE-;ICE +PON (uirements in that it fais to that that Engish is :o)er /?

years of age= and fais to indicate that he is a 'non%paty= @homsoe)er may thin" that #e an

utra technica approach might re)ie! 9udge Eiott's and (dam's !or" in disposing of CoughA

in's a!suits against @ashoe Lega Ser)ices in C;//%4/?1B, and against @ashoe Lega SerA

)ices, C((@, and T@S in C;//%4/177, referencing .arin's citation to :actua ser)ice does notecuse the faiure to technicay compy !ith ser)ice rues= approach (t east Coughin !as

not ha)ing court staff, Marshas, and *aiiff's 6a##ing there forearms into @LS's Ecano's a#A

domen and thrusting this or that document attempted ser)ed into his face, inside the courtA

house, !hie he !as at the courthouse to attend court, in a matter su#stantiay connected to the

su#6ect matter from !hich the document purported to #e then ser)ed stemmed

/he ;$ in %7 is void for Ging and the *BNs failure to meet a variety of Eurisdictional preXreuisites, including the failure to file an ;$


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DN/C


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")Issuance of su#poenasAy hearing panels and Aar counsel)Bar counsel and a memAer of ahearing panel ho is also a state Aar memAer, in matters under investigation Ay either, may adminisXter oaths and affirmations and issue and compel Ay suApoena the attendance of itnesses and the proXduction of pertinent Aoo5s, papers, and documents) The attorney may aso compe #y su#poena theattendance of !itnesses and the production of pertinent #oo"s, papers, and other documents

#efore a hearing pane) Subpoena and witness fees and mileage shall be the same as in a districtcourt)

#)Confidentiality stated on suApoena)*uAEect to the provisions of +ule "#", suApoenXas shall clearly indicate on their face that they are issued in connection ith a confidential inXvestigation under these rules and that it is regarded as contempt of the supreme court orgrounds for discipline under these rules for a person suApoenaed to in any ay Areach theconfidentiality of the investigation) t shall not Ae regarded as a Areach of confidentiality for a

person suApoenaed to consult ith counsel or to anser uestions as5ed Ay Aar counsel or theattorney to determine the facts "no!n #y the !itness )

3)(ttachment of person for faiure to o#ey su#poena or produce documents )?henever

any person suApoenaed to appear and give testimony or to produce Aoo5s, papers, or other documentsas reuired Ay suApoena, or reuested to provide documents pursuant to +ule 7&).("'(A',refuses toappear or testify #efore a hearing pane, or to ans!er any pertinent or proper >uestions, or to

pro)ide the re>uested documents, that person sha #e deemed in contempt of the discipinary

#oard, and thechairof the disciplinary #oardshallreport the fact to a district 6udge of thecou n ty in !hich the hearing is #eing hed or the in)estigation conducted) /he district court shalpromptly issue an attachment in the form usual in the court, directed to the sheriff of the county,commanding the sheriff to attach such person and #ring such person forth!ith #efore the

court) $n the return of the attachment, and the production of the person attached, the district courtshall have jurisdiction of the matter= and the person charged may purge himsef or hersef of thecontemptin the same ay, and the same proceedings shall Ae had, and the same penalties may be

imposed, and the same punishment inflictedas in the case of a itness suApoenaed to appear andgive evidence on the trial of a civil cause Aefore a district court of the *tate of Nevada)

4)Contest of subpoena)< contest of a suApoena sha #e heard and determined #y thechairof the appropriate discipinary board)

.)+estriction on discovery)Discovery Ay the attorney, other than under +ule "%.(#'(c', is not permitted prior to hearing, ecept #y the order of the chair for good cause upon moAtion under -ue /40$7& or -ue /40$B&

)rehearing conference)


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that the various poers accorded to such Qdisciplinary Aoard chairY ithin *C+ ""% (and, also,under , is not permitted prior to hearing, e1cept Ay the order of the chair for good cause upon motionunder +ule "%3(.' or +ule "%3('' to so entrust ith such authority) ?hile NNDB Chair *usichs7!#7!"# riting to Coughlin directs Coughlin to coordinate and inuire as to certain matters ith the*BNs $BC and *BN Cler5 of Court 6aura ;eters, it in no ay, authoriIes or identifies the *BN,

$BC, or *BN Cler5 of Court as a *C+ ""%(' QdesigneeY) 0urther, the use of the term QconferenceYin *C+ ""%(' necessarily reuires Coughlins participation, or, at least, an opportunity to participatein such a conference Ae given to Coughlin, and notice thereof) nstead, the NNDB, ;anel, and $BCcontinually treated Coughlin li5e theElephant Man) Coughlin is not an animal) 8e is a human AeXing)

0urther, Ging li5ely violated +;C 3)", 3)#, 3)3, 3)4, 3)., 3)&, &)", &)#, and &)4 here he admitXted to Coughlin, on "%!".!"# that he fully intended to have such a conference in Coughlins aAsence(and apparently did so' an an effort to achieve his stated goal of s5irting the e1press dictates in thisCourts !7!"# $rder in %&3& and *C+ """(&' and thereAy QconsolidateY the reuirement stemmingfrom this Courts $rder (hich e1pressly incorporates the dictate found ithin *C+ """(&'' thatQrefer(red' the matter to the appropriate disciplinary Aoard for the institution of a forma hearingAe

fore a hearing panel in !hich the soe issue to #e determined sha #e the etent of the discipineto #e imposedY' into

Q*C+ +ule"%4)*tate Aar counsel) ")*tate Aar counsel shall: ))) QA'*uAEect to +ule"%.("', dispose of all matters involving allegedmisconduct Ay dismissal of the allegation(s' or #ythefiling of a written complaint)Y ronically, it is the $BCs Gings Aeloved *C+ """(.' that nosturns on him here) Q*C+ """(.')Certified document concusi)e)< certified copy of proof of aconviction is concusi)e e)idence of the commission of the crime stated in it in any discipinaryproceedinginstituted against an attorney Aased on the conviction)Y


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(*C+ "%.(#': QCommencement of forma proceedings)0ormal disciplinaryproceedings are comXmenced Ay Aar counsel fiing a !ritten compaint in the name of the state #ar ))Y', Note, *C+"%.(#' decidedly!O"# $OT say that Qformal disciplinary proceedings are commenced Ay AarcounselY doing that hich *C+ "%4(d' calls for (*C+ "%4("'(d' reads:Q("' *tate Aar counsel shall:)))(d' 8ie with the supreme courtpetitionsith certified copies of proof of conviction demonstrating

that attorneys have Aeen convicted of serious crimes, as defined in +ule """)Y ?here *C+ "%.(#'provides that as to the: QCommencement of forma proceedings)0ormal disciplinarypr o ceedingsare commenced Ay Aar counsel fiing a !ritten compaint in the name of the state #ar ))Y and suchComplaints are alays filed Aefore the appropriate Disciplinary Board in the *tate Bar of Nevada(that is to say that the name of the court listed aAove the caption of such Complaints alays indicates:

Q*/uaifier :forma=& found in SC- /47$3&& 0urther, the approach ta5en Ay the *BNs $BC

- 56-


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here, here the Complaint contains three grievance case numAers, none of hich represents an idenXtifier or case numAer (hy no appearance of the *C+ """ ;etitions numAer, %&3&F') /he $BCoffered nothing in its filings to marry any of the three grievance numAers to this Courts !7!"# manXdate in %&3& or that reuired under *C+ """(&')

and *C+ "%4("'(d' reads:Q("' *tate Aar counsel shall:)))(d' 8ie with the supreme courtpet iAtionsith certified copies of proof of conviction demonstrating that attorneys have Aeen convicted ofserious crimes, as defined in +ule """)Y ?here *C+ "%.(#' provides that as to the: QCommencementof forma proceedings)0ormal disciplinaryproceedings are commenced Ay Aar counsel fiing a!ritten compaint in the name of the state #ar ))Y and the Complaint here Aares three Qcase numXAersY (N@"#2%#%4, N@"#2%434, N@"#2%43.', hile, noticeaAly, the *C+ "%.(3'(a' Qrevie Ay suXpreme courtY and *C+ "%.(3'(a' QappealY is accorded a different case number(here, #337'

*C+ """(&': Q+eferral to disciplinary Aoard)pon receipt of a petition filed under suAXsection 4 of this rule, demonstrating that an attorney has Aeen con)ictedof a serious crime, thesupreme court shall, in addition to suspending the attorney in accordance ith the provisions of suAXsection 7 of this rule, refer the matter to the appropriate disciplinary Aoard for the institution of a

forma hearingAefore a hearing panein hich the sole issue to Ae determined shall Ae the e1tentof the discipline to Ae imposed) /he panel may, for good cause, postpone the proceeding until all apXpeals from the conviction have Aeen concluded)Y

Notice *C+ """(&' DOES NOT -E(< Qfor the institution of formal disciplinary procee d Aingsafter Bar Counsel follos th Qprocedure on receipt of complaintY set out in *C+ +ule "%.("'(a'and a Qinvestigations shall Ae initiated and conducted Ay Aar counsel or Aar counselRs staff or other inXvestigative personnel at #ar counseFs directionpriororpursuantto the opening of agrievancefile)))Y hereupon at Qthe conclusion of an investigation of a grievance file, Aar counselY Ging ma5esthe decision to Qrecommend in ritingY the fiing of a !ritten complaint= here such QrecommendXation shall Ae promptly revieed Ay a screeningpanel)))Y N$/C /8


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+) *erv) 3d ""39 (3d Cir) #%%9' < nonmonetary sanction may also include reuiring participation inseminars or other educational programsL0N"%M or referring the matter to disciplinary authorities)L0N""M L0N""M


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(' Coughlin as afforded ample opportunity to prepare a verified anser or response to the allegXations of the Complaint and failed to timely do so) *ee 0indings of 0act 34, 3. and 3)


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C8+*/N+CG*$N?


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2Cause ) /ermination' and Notice of *ummary e)iction 2 N+* 4%)#.4 to: Zachary Coughlin "#"+iver +oc5 *treet +eno, Nevada &9.%3 B> !s! Casey D) Ba5er, s)Y)

Ba5er and erliss failed to comply ith the reuirements of N+* 4%)#&% (specifically as to aitness and more' for the alleged service of a . day D Notice on 9!#7!"")

0$+]9 Q


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8ill ant Aig Aoy attorneys fees, they should Ae reuired to get those sorts of things right to Eustifysuch e1orAinant fees, or even Aegin to', the Eustice court or the district court shall hold a hearing,after service of notice of the hearing upon the parties, to determine the truthfulness and sufficiencyof any affidavit or notice (Ba5er continually maintained that it as only Coughlins uires that such an an Order #e ser)ed under N-CP B$e& !here

persona ser)ice is not accorded, thus re>uiring 0 days for maiing 8urther, N-(P ? and some

7 day stay suggested in (n)ui, is argua#y appica#e There is itte indication in Ch 54 or

eseh!here to pro)ide some epanation of 6ust ho! and in !hat manner such a :summary orA

der= !oud #e carried out and !hether it !oud ao! for the approach ta"en #y the @CSO in

such situations @hie N-S 54370$0&$#&$3& does contain the term :summary order=, the apApearance therein of the :!ithin 35 hours= anguage, com#ined !ith the non%appearance of such

:!ithin 35 hours anguage= in N-S 54370$B&, under traditiona principes of statutory conA

struction, actuay augers for an interpretation of su#section B that !oud re>uire moretime for

a tenant than is pro)ided for under N-S 54370$0&$#&$3&DJ=That if the court determines that the

tenant is guity of an una!fu detainer, the court may issue a summary order for remo)a of

the tenant or an order pro)iding for the nonadmittance of the tenant, directing the sheriff or

consta#e of the county to remove the tenant ithin #4 hours after receipt of the order=

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It seems rather impausi#e to suggest that the :!ithin 35 hours= anguage is some dicA

tate to the Sheriff or consta#e re>uiring such oc"outs #e effectuated in some narro! !indo!

of time -ather, particuary gi)en the primacy to indi)idua's and #usinesses inherent to their

uses as residences of paces of #usiness $or, in /4?, as #oth& it !oud seem entirey more i"ey,

and reasona#e, to concude that the egisature intended for the :!ithin 35 hours= anguage to

afford tenant's :at east= 35 hours from the posting $if not the constructi)e receipt in the maiunder N-CP B$e& if no persona ser)ice !as to #e had& of such a oc"%out Order to remo)e

those items they find a#soutey essentia $see Coughin's difficuties in /45? !here depri)ed of

his medications, eyegasses, contacts, some important ega fies, etc, not to mention the -PC

07( )ioation attendant to the defaut on 272/3, especiay !here the -9C and NCS's ChandA

er "ne! Coughin !as in 6ai incident to a 202/3 arrest stemming from North!ind's handyA

man re#'s faacious accusation of Coughin :distur#ing the peace=

the court may issue a summary order for remo)a of the tenant

(so, the -9C may need to epain !hy it faied to fie in fa fiings #y Coughin

!here it either did fie in some #y i and *a"er in /4? $or consider any faiure to fie any/42/02// (ffida)it of +na!fu


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The S*N is i"ey resting upon some theory that the TPO and EPO granted it #y -9C 9udge Pearson, !hich inA

dicates that Coughin may 8irst, the /2 //52/0 EPO granted the S*N indicates that Patric"

O!en ing, Es>, appeared at the Etension earing to represent the S*N (s such, ing,

"no!ing he !as etremey i"ey to #e a !itness in such an action, had a duty to !ithdra!

from representation, and therefore himsef )ioated a -PC //B re>uir he so !ithdra! !here

his #eing a !itness !as a )irtua certainty 8urther, ing's TPO appication rests amost enAtirey on uns!orn hearsay, for !hich ing ma"es no indication !ith regard to from !hom or

ho! he #ecame a!are of such hearsay detaiing such purported :facts= 8or instance, the maA

gic of hearsay may ao! a comment i"e :its not fair that *ar Counse ing gets a this e

parte face time !ith Pane Chair Eche)erria= that may ha)e #een said to


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+estitution of ;ossession as reuested, particularly here the 6oc5out $rXder fails to conform to the folloing statute:

QN-SJ545348orm of rit of restitution eecution

0urther, ern faied to fie in a Landord's (ffida)it prior to the 02/72/3 summary e)iction pr o A

ceeding, !hich !as noticed for ?D04 am, Aut to hich the Goc5out $rder had a fa1 header indicatedthe $rder as fa1ed to the ?C*$ Civil Division at &:#4 am)


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/he +C impermissiAly held the 3!".!"# summary e)iction proceeding in 37. before Gernfiled a 6anlords


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C$@86N*N$/C6$/$N*DND) / * 0+/8+ $+D+D /8


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0$+


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Coughlin suAseuently filed a grievance against Dogan hich


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CO+.LIN*ELIE;ESE@(SONTIME8O-TE?D04 (ME(-IN.ON02/72/3, TO+.TE9(;S (+


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Chief Civil Cler5 Garen *tancil and Cler5 Bonnie Cooper' that, hen an attorney is representing thelandlord, the attorneys ill typically prepare their on $rders, and that the attorneys ill then arXrange for such $rders to Ae delivered or transmitted to the ?C*$ Civil Division) /hat assertionruns counter to the sorn testimony Ay 8ills associate Casey D) Ba5er, s), at the criminal trespassprosecution trial of Couglhin on !"&!"# in +C #4%., here Ba5er sears:

+@


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+C udge Nash 8olmes, and +C udge *chroeder had e1tra2Eudicial discussions related to CoughXlin (perhaps that is here udge 8olmes as Aeteen ":3% pm and 3:%%pm hen her udicial


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++6-


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CN/+= D


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ary procedure is reuired) +egardless, a proper Eury trial demand is hereAy made) /here is perhaps anXother person against hom this action should Ae Arought, namely rin


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+egardless, the *BN as provided the #!#3!"# filing Ay Coughlin in ##"7 (it as inXcluded in the ""!&!"# 3,#%% page document production to Coughlin Ay the *BN', hich contained arXgument critical of the handling of the prosecution of Coughlin incident to the ""!3%!"" /rial, and imXmediate, stay denied, 3 day summary contempt incarceration of Couglin Ay +C udge 8oard,hom had denied Coughlin Aoth court appointed Counsel (despite failing to specifically rule that Eail

time as not a possiAility and the mandatory authority found in the #%%& Nevada Courts of 6imitedurisdiction Bench Boo5 Q5non to all EudgesY in Nevada Ay the


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preted to Ae a threat of any sort sufficient to meet the reuirement for a ?or5plance ;rotection $rdermuch less an QnstitutionalY ?or5place ;rotection $rder) Both .99 and %7 are egregious aAuses oprocess and the pointing of gun at Coughlins head from 4 feet aay Ay +;D $fficer ?addle, inCouglins Aac5 yard, upon ?addle Eumping out from Aehind a Aac5yard shed at Couglin, ithout somuch as a single instance of the +;D announcing themselves as la enforcement or otherise issuX

ing sort of order or reuest to Couglin of any type, and thereupon arresting Couglin and charging himith Aoth a felony and a gross misdemeanor(in an oAvious attempt Ay the *BN, ?C;D, +C, and?CD


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the start time for the /rial in %.3% on "#!""!"# to ":3% pm from a 9 am start time (hich ouldma5e sense considering the /rial /om -iloria, s), respresented a defendant in that morning asCouglin itnessed, upon Coughlin calling the +C to inuire aAout something and Aeing told that the/rial in %.3% as, in fact, starting at 9 am that morning, at hich point Coughlin hurriedly traXversed to the +C, arriving Ay "% am) Despite +oAAin Ba5er, curiously Aeing aAsent from or5 that

day, udge Clifton sua sponte indicated that Coughlin as QrongY ith regard to his contention thatBa5er had informed him of the start time for the "#!""!"# /rial Aeing moved to ":3% pm) Coughlinas prevented from suApoening or calling Ba5er at the #!".!"# Contempt *ho Cause 8earing in%.3% to reAut udge Cliftons contention that Coughlin had Aeen QarnedY against Aeing lateQagainY) $N #!".!"3 udge Clifton summarily sentenced Couglhin to . days incarceration to Aeginimmediately here he also denied Coughlins otion for even a Arief *tay (folloing his settingCoughlins Aail at a ridiculous H"%,%%% on #!"4!"3, some might say' ith no possiAility of paying afine in lieu of serving said . days) udge Clifton someho managed to find Couglhins sleepingthrough to alarm cloc5s upon attempting to ta5e a 3% minute nap at .:3% am on #!"4!"3 after Aeingforced to cram for the continuation of trial in %.3% due to the to rongful arrests of Coughlin (on#!"!"3 and #!&!"3' as QvolitionalY) Coughlins suddenly court appointed defender, Bruce 6indsay

s) (ho is it Couglin gets court appointed counsel for a civil contempt hearing on #!"4!"3 in%.3% here he as denied such at the 3!#3!"# *ho Cause 8earing in %3#& and on ""!3%!"# in##"7 upon udge 8oard announcing he may find Couglin in Contempt, then finding Coughlin inContempt, Aut insisting Coughlin continue on in self representing himself through the remainder ofthat criminal prosecution here the possiAility months Eail time e1isted and Coughlin as deniedcourt appointed counsel Ay +C udge 8oardF') +C Chief Bailiff *e1ton indicated to Couglin, ina holding cell that Couglin had Qfive different violations of udge *ferraIIas


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entire


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tion that


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P-OO8 O8 SE-;ICE

;ursuant to N+C; .(A', certify that served a copy of the foregoing document upon the folXloing party Ay fa1ing, emailing, dropping if at their office, and placing a true and correct copy ofthe foregoing document in the us mail addressed to:

Chief Daniel ?ong, s)Brian *ooudi s)$ne ast 0irst *treet, 3rd 0loor0a1 numAer: 77.233424##dong`reno)gov, Asooudi`reno)gov+eno City


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8inding of Pro#a#e Cause, Notice of Interocutory (ppea as to 8inding of Pro#a#e Cause

Motion to ;acate Notice Setting earing, Motion for Continuance Shoud Tria date of 72302/0

Not #e ;acated, Notice of Non%Ser)ice of Notice Setting earing Motion to Proceed In 8orma

Pauperis and


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A) LK#%)4#M Duration of nEunctionc) LK#%)43M odification or /ermination of nEunctiond) LK#%)44M +eneal of nEunctione) LK#%)4.M ;ersons Covered7) LK#%)4M /ransmission of $rder to 6a nforcement


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plaintiff) Code of Civil ;roc) K.#7)(A') /his reuirement is demanding) t is not enough todemonstrate mere discomfort or annoyance) +ather the plaintiff must prove that the emotional impactof the course of conduct as such that no reasonaAle person could Ae e1pected to endure it) *child,#3# Cal)


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email directly to Ging, on the very same day that 8ill oAtained in a scant 4% minutes a /;$ againstCoughlin hile Coughlin as simultaneously Aeing suAEect to a custodial arrest for Eayal5ing(though the +;D ould not indicate hy Coughlin as Aeing arrested for hours' incident to 8illcalling 9"" and lying to $fficer 8ollingsorth, (as capture in the videos Coughlin too5 at the timeand transcriAed and provided to the *BNs Ging, hom, amaIingly, someho still managed to

include in his &!#3!"# Complaint, essentially, verAatim, the lies 8ill as alleging to the +;D that daythat purportedly resulted in his arrest) /he ;anel refused to even consider, much less admit suchvideos) Gings &!#3!"# Complaint, hoever, in an effort to distance itself from the tadry, tac5yveneer applied here NNDB 8ills name ould Ae attached, in one ay or another, to each and everyallegation in the Complaint, fails to include any specifics here it apparently is referencing the eventsof "!"#!"#, as such Complaint does not include the case numAer for the eviction (Coughlin asevicted Ay the +C a record "# times Aeteen ""!"!"" and "%!#!"#, to go along ith the ". custodialarrests he has Aeen suAEect to since &!#"!"")))though Coughlin hasnt filed a single lasuit against the+;D, the ?C*$, +*C, +C, +C, etc), etc)')

nterstingly, +C udge Clifton refused to allo Coughlin, an attorney, QauthoriIed topracticeY in the +C here representing himself (as he as forced to due to the malevolence and

incompetence of Biray Dogan and im 6eslie' in +C+"#2%.3%, to issue his on suApoenas, Aut ontop of that, sua sponte, entered an illegal order reuiring Coughlin to oAtain udge Cliftonspermission for any suApoenas he ished to utiliIe)


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payphone outside of ;arr ail upon Couglin posting Aail for the custodial Eayal5ing arrest chargepremised upon 8ills lies to the +;D that very day)))immediately after Aeing released at around "%:3%pm on "!"#!"# (here the temperature, even ithout indchill Aeing accounted for, and its ase1ceedingly indy' as #% degrees, and the last Aus for the night had left, and Couglin residence as4 miles aay')

n the magnificent faAric of connections eaved throughout this ordeal, it as that veryprosecution in %.3%, that spaned Coughlins #!#"!"# filed QNotice of


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N-SJ/?0??Presence of defendant3)n prosecutions for offenses punishaAle Ay fine or Ayimprisonment for not more than " year, or Aoth, the court, ith the ritten consent of the defendant,may permit arraignment, pea, tria and imposition of sentence in the defendantJs absence, if thecourt determines that the defendant as fully aare of the applicaAle constitutional rights hen thedefendant gave consent)

oung as orderedto leverage the placement of N+* "99)#&% ithin the Q


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did)))')


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Cathcart $/11& 7 C(5th ?47, ?41, B C-3d 01?.eydon v Ale;ander, supra, 3/3 C(0d at 7 see

aso#mith v #ilvey $/1?0& /51 C(0d 544, 54B, /1 C- /7 $respondent coud not #e en6oined

from initiating compaints a#out petitioner !ith pu#ic agencies& The course of conduct must

#y its nature cause a reasona#e person to suffer su#stantia emotiona distress, and must

actuay cause su#stantia emotiona distress to the petitioner CCP 73B$#&$0&'rekke v 4ills,

supra, /37 C(5th at /5/5Q/5/7)0or e1ample, the court may not grant a /+$ and preliminary inEunction under CC; K.#7),enEoining a nuisance such as the noise from the use of a Aas5etAall court, ithout proof that the noisecaused suAstantial emotional distress to the petitioner) *ee Schild v #ubin ("99"' #3# C


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(7' in K#%).) f the conduct aAout hich the petitioner is complaining does not meet this statutorydefinition, the court may not provide relief, temporary or otherise)(4' ssue a /+$ if the petitioner has made the reuired shoings) Courts must use the udicialCouncil form ?-2""%, /emporary +estraining $rder) f the petitioner shos good cause, the courthas the discretion to issue a /+$ that includes other named family or household memAers) CC;

K.#7)&(d')(.' *et hearing on the petition for an inEunction) *et the matter for hearing ithin #" days or, if goodcause appears, #. days, from the date that the petition for the /+$ is granted or denied) CC;K.#7)&(h') f no reuest for temporary orders is made, the court must set the hearing ithin #" daysor, if good cause appears, #. days, from the date that the petition is filed) CC; K.#7)&(h') Courts mustuse the udicial Council form ?-2"%9, Notice of Court 8earing)K#%). California udges Benchguide #%P) LK#%).M Chec5list: Conducting 8earing on and ssuing nEunction("' Before the hearing on the petitionerRs petition for an inEunction, determine that the respondent asproperly served ith a copy of the petition, the /+$, and notice of hearing on the petition) ;ersonalservice is reuired in the manner provided for service of summons, at least five days Aefore the

hearing, unless the court has shortened the time for service for good cause) CC; K.#7)&(m') *eeK#%)3) /he proof of service should Ae made on udicial Council form ?-2#%%)(#' Before the hearing, determine that the petitioner as properly served ith the respondentRsresponse to the petition) /he response may Ae ritten or oral, or Aoth) *ee Cal +ules of Ct 3)"".#(d')f a ritten response is served on the petitioner or the petitionerRs attorney at least to days Aeforethe hearing, the petitioner may not reuest a continuance on an account of the response) *ee Cal+ules of Ct 3)"".#(d'= K#%)37) /he proof of service should Ae made on udicial Council form ?-2#.%)(3' +evie the response to the petition filed Ay the respondent) f the response is ritten, therespondent must use udicial Council form ?-2"#%) /he respondent may file a response thate1plains, e1cuses, Eustifies, or denies the alleged unlaful violence or crediAle threats of violence)CC; K.#7)&(i') *ee K#%)37)(4'


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reneal of the inEunction Ay filing a ne petition at any time ithin three months Aefore theinEunction e1pires) *ee KK#%)4#, #%)44)(&'


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could ta5e against her parents for their restrictions on her, and he taunted mother on telephone')Constitutionally protected activity is not included ithin the term Kcourse of conduct)b CC;K.#7)(A'("') 0or e1ample, filing a legal action does not constitute harassment Aecause an individualhas a constitutional right to petition for redress of grievances) *ee Byers v Cathcart ("997' .7 C


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pro per) CC; K.#7)(5') n addition to, or in lieu of a ritten response, the petitioner can challengethe issuance of a permanent order through oral testimony at the hearing) Cal +ules of Ct 3)"".#(d')d) LK#%)".M Continuance< respondent may reuest a continuance of the hearing on a shoing of good cause) Cal +ules of Ct3)"".#(e') f the court in its discretion grants the continuance, any temporary restraining order that

has Aeen granted remains in effect until the end of the continued hearing unless otherise ordered Aythe court) Cal +ules of Ct 3)"".#(e')


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f there are allegations of unlaful violence or crediAle threats of violence, a support person mayaccompany the petitioner in court) CC; K.#7)(l') f the petitioner is appearing in pro per, the supportperson may sit ith the petitioner at the counsel taAle) CC; K.#7)(l') /he support person may notprovide legal advice, Aut is alloed to Ae present to provide moral and emotional support to thepetitioner) CC; K.#7)(l') /he court has the discretion to remove the support person from the

courtroom if the court Aelieves that the support person is prompting, saying, or influencing thepetitioner) CC; K.#7)(l').) ssuance of nEunctiona) LK#%)"9M 0indingsf the court finds Ay clear and convincing evidence that unlaful harassment e1ists, it must issue aninEunction prohiAiting the harassment) CC; K.#7)(i'= see udicial Council form C82"3%) /hepetitioner must also estaAlish that great or irreparaAle harm ould result to the petitioner if aninEunction is not issued Aecause of the reasonaAle proAaAility that unlaful violence ill occur in thefuture) +ussell v Douvan (#%%3' ""# C


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f an action is filed for the purpose of terminating or modifying a protective order Aefore thee1piration date specified in the order Ay a party other than the protected party, the party ho isprotected Ay the order must Ae given notice of the hearing for modification or termination Ay personaservice (see CC; K"%%.(A'' or, under specified circumstances, Ay service on the *ecretary of *tate)CC; K.#7)(E'(3') f the party ho is protected Ay the order cannot Ae notified prior to the e1piration

date, the court must deny the motion to modify or terminate the order ithout preEudice or continuethe hearing until the party ho is protected can Ae properly noticed and may, on a shoing of goodcause, specify another method for service of process that is reasonaAly designed to afford actualnotice to the protected party) CC; K.#7)(E'(3') /he protected party may aive his or her right tonotice if he or she is physically present in court and does not challenge the sufficiency of the notice)CC; K.#7)(E'(3')e) LK#%)#3M +eneal of nEunction


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K.#7), or a reissuance, e1tension, modification, or termination of the order, and any suAseuentproof of service) CC; K.#7)('(3')nformation on any /+$ or inEunction relating to civil harassment issued Ay a court under CC;K.#7) must Ae transmitted to the#%-#" Civil 8arassment and ?or5place!;ostsecondary *chool -iolence K#%)#9

Department of ustice in accordance ith CC; K.#7)('(#' or (3') CC; K.#7)('("')7) LK#%)#7M *uAseuent


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") LK#%)3"M ?ho ay *ee5 +elief


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and that serves no legitimate purpose) CC; K.#7)&(A'(#') /he intent reuirement for a true threat isthat the respondent intentionally or 5noingly communicates the threat= it is not necessary that therespondent intends to, or is aAle to carry out the threat) 8untingdon 6ife *ciences, nc) v *top8untingdon


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either directly or indirectly, Ay mail or otherise, or coming ithin a specified distance of, ordisturAing the peace of the employee)


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the petitioner is not entitled to a continuance on account of the response) Cal +ules of Ct 3)"".#(d')/he respondent may appear in the proceeding Ay counsel or in pro per) CC; K.#7)&(l') n addition to,or in lieu of, a ritten response, the petitioner can challenge the issuance of a permanent orderthrough oral testimony at the hearing) Cal +ules of Ct 3)"".#(d')d) LK#%)3&M Continuance

< respondent may reuest a continuance of the hearing on a shoing of good cause) Cal +ules of Ct3)"".#(e') f the court in its discretion grants the continuance, any temporary restraining order thathas Aeen granted remains in effect until the end of the continued hearing unless#%-#7 Civil 8arassment and ?or5place!;ostsecondary *chool -iolence K#%)4"otherise ordered Ay the court) Cal +ules of Ct 3)"".#(e')


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inEunction) 7# C


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/he court must order the petitioner or the petitioners attorney to deliver a copy of an order issuedunder CC; K.#7)&, or reissuance, e1tension, modification, or termination of the order, and anysuAseuent proof of service, Ay the close of the Ausiness day on hich the order, reissuance,e1tension, modification, or termination as made, to each la enforcement agency havingEurisdiction over the residence of the petitioner and to any additional la enforcement agencies

ithin the courts discretion as are reuested Ay the petitioner) CC; K.#7)&('(#')


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defined aAove) /he event(s' occurred as follos: N$/: B*;C0C


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unchec5ed' mployee(s' also or5 at the additional specific locations that need to Ae enumerated inthe $rder: *treet es No (neither Ao1 is chec5edAy Ging'f yes, please Ariefly e1plain: [[[)7- *ave there been any other &ourt actions or any other relationships between the employer

and the dverse "arty8 %es-

5f yes, please describe9 Discipline 8earing held ""!"4!#%"#)-ELIE8 -EH+ESTEuirements of N-S 00374$3&$c&, !hich re>uires thatsuch :)erified appication must incuded, !ithout imitationD :$c&J( detailed description of theeventsthat allegedly constituted harassment in the worplaceand the dates on which these eventsoccurred)Y

< fe glaring proAlems ith Gings application appear here he fails to list any other locationfor the *BN Aeyond its +eno office)


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3JJIf, for any reason, #ar counse is dis>uaified or has a confict of interest, the #oard ofgo)ernors sha appoint an attorney, ad hoc, to act in the pace of #ar counse

0urther, Ging clearly needs to Ae removed from #337 and %7 in light of not only *C+ +ule"#%, Aut also in light of the dictates of +;C 3)7:Q +ule3)7)6ayer as ?itness) (a'< layer shall not act as advocate at a trial in hich the layer is li5ely to Ae a necessaryitness unless: ("'/he testimony relates to an uncontested issue=)))Y

Gings QtestimonyY aAsolutely does relate to a contested issue, many of them, as furtherdetailed herein, including, Aut not limited to, the insufficiency of postage the *BN affi1ed to the"%!9!"# Notice of ntent to /a5e Default in the *C+ "%. disciplinary matter herein the *BN andNNDB so egregiously overstepped to Eurisdiction accorded it Ay *C+ """(&' and the Courts !7!"#$rder in %&3&)

/hereafter, as is Gings consistent practice, he fails to attach an nde1 to 1hiAits or any coverpages to his various Qe1hiAitsY) 0urther, hile the first page folloing the last page of the Q0rom B23Y "#!#%!"# /;$


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/here has Aeen aAsolutely no assertion Ay anyone that Coughlin actually committed any act hichcause any Aodily inEury to anyone or damage to anyones property) $nly to most attenuatedhypchondriac, histrionic fit throer ould assert Coughlin committed any act sufficient to havealready caused QsuAstantial harm to the physical or mental health or safety of a personY)

*o, one must assume that the courts Eustification for issuing Aoth the /;$ and ;$ as Aased

upon a finding that Couglin threatened to cause: QAodily inEury to the person or another person, or,damage to the property of another person= or, suAstantial harm to the physical or mental health orsafety of a person

Neither /;$s nor ;$s may Ae granted on a default Aasis) ven if an adverse party fails tooppose any such application or attend any such hearing, the court is still reuired to evaluate hetherthe reuirements of N+* 33)#4%, 33)#.%, and 33)#7% are met)

*o, Eust hat, if anything in Gings /;$ application may suffice to meet those standardsF


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has received numerous e2mails detailing hat r) Coughlin perceives to Ae amiscarriage of Eustice in his discipline matter and has indicated that he ill e;posehim as a liar and a fraud )

n a etter dated No)em#er , 34/3, prior to the discipine hearing, theOffice of *ar Counse sent Mr Coughin a etter as"ing that he refrain from

coming to the #tate 'ar offices without calling beforehand) $n No)em#er /,34/3, after the discipine hearing, the anel Chairissued an Order instructingMr Coughin to refrain from contacting any mem#er of the Pane, the Court

-eporter $whom -r( Coughlin had contacted by phone at her residence&, any of

the Pane Chair's office staff, or either office of the State *ar of Ne)ada)$n oneoccasion, an e%mai !as sent to se)era recipients, incuding four

$5& empoyees of the State *ar, !hich incuded a in" to a )ioent scene from the

mo)ie Cape 8ear) (he#tate 'ar feels that this is a direct suggestive threat tooffice staff and'ar personnel) /herefore, the State Bar re;ueststhat a ;rotective$rder Ae and that r) Coughlin Ae prohiAited from contactingthe Bars +eno andKor.as 0egas Office Ay telephone, by eMmail or by fa;) Because he is currently

temporarily suspended from the practice of la and his disciplinary hearing hasconcluded -r( Coughlin has no business on #tate 'ar property (94. DouAle +Blvd or %% ) Charleston Blvd), 6as -egas, N-') /he recordof his disciplinarymatter!i soon #e su#mitted to the Ne)ada Supreme Court for a de novo review

at !hich time he will receive a complete set of all of the pleadings, both filed and

unfiled, in this matter)t shoud #e noted that the State *ar and its -eno staff find it very

difficult to work under these conditions Mr Coughin continues to monopoliEe our

time and resources and is causing an unnecessary amount of stress)

(N$/: the aAove Q*ummaryY fails to indicate Coughlin is causing QfearY of that

reuired Ay N+* 33)#4%, Aut rather that Qthe *tate Bar and its renot staf find it verydifficult to or5 under these conditionsY (such as Coughlin reuesting copies ofdocuments, see5ing the copy of the record!transcript of the ""!"4!"# proceeding thathe is entitled to under *C+ ""9, hich reuires that he QcontactY Bar Counsel tooAtain such, hich Coughlin attempted to do on numerous occasions immediatelyafter the ""!"4!"# disciplinary hearing Aoth Ay telephone and in riting, hich theBar and Ging failed to respond to until "#!"9!"#, ith Chair cheverrias ""!"7!"#$rder seemingly void in that it, depending on ones interpretation of QcontactY orQcontactingY ould have precluded Coughlin from so see5ing a copy of the transcriptpursuant to *C+ ""9 here such ""!"7!"# $rder readsY) 0urther, it appears that6aura ;eters herself from the Q*ummaryY hich ould not only vitiate any Qfirst

handY 5noledge reuirement Aeing met even assuming the illogical leap toincorporate Ay reference that contained in 1hiAit " is made, despite the failure ofGings Declaration on page & of his /;$


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such QContinuation ;ageY into the esterday you arrived at the *tate Bar office after.:%% p)m) to file several documents) ?hen you discovered that the front door asloc5ed, and although there is a mail slot in the door, you elected to al5 around theoutside of the Auilding until you found someone inside) >ou stood outside anemployees indo, got her attention and as5ed to he let in) /his employee unloc5edthe door and too5 receipt of your documents after hich you continued to as5 furtherassistance)

>our Aehavior is Aecoming increasingly disturAing and harassing)/herefore, e1cept for your formal hearing, hich ill ta5e place on NovemAer "4,#%"#, Aeginning at &:4. a)m), you are not to arrive at the +eno $ffice of the *tate Barunannounced) f you have papers or pleadings to present tor filing, you are hereAyinstructed to either mail them or to call the office (3#924"%%' prior to your arrival);lease Ae advised that if you appear at the *tate Bar in the future, e1cept for theNovemAer "4, #%"#, hearing or in the case of your need to lie a document (f$fhich you must call ahead', the police ilt Ae summoned immediately) *incerely, !s!;atric5 $) Ging, s)


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to his "#!#%!"# /;$


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Q*uAEect: 0?: /he /hree s=cpd failure to provide essential 9" call cd discovery of &!"3!and &!"7, #%"# to Coguhlin in rcr#%"#2%.3%

/his attorney feels that his la firm staff as threatened Ay Zach Coughlin) amconcerned for our staff) ;lease advise) ;atric5 GingY

/hereafter, Gings email forards or contains hat purports to Ae an email to Ging fromCoughlins then ?C;D im 6eslie, of "#!"#!"#, addressed only to Ging, hich reads:

Qr) Ging: /he Aelo email from r) Cogulhin contains a reference at the end of the first paragraphto a eAsite containing a video clip from the movie Cape 0ear) ;lease advise hether any action isreuired of our office or yours regarding this possiAle veiled or indirect threat of violence againstattorneys in this office Ay r) Coughlin)

/han5 >ou, ames B) 6eslie, s), Chief Deputy ;uAlic Defender, ?ashoe County ;uAlicDefenders $fficeY

/he /rial yesterday in +C+#%"#2%.3% featured e1tended discussions regarding the failure of the

?C;D, Dogan, and 6eslie, to turn over discovery propounded Ay DD< >oung in the form of cdsfeaturing 9"" calls DD< >oung provided to the ?C;D on &!"3!"# and &!"7!"#))) oung)))etc)

f *vengali!Diann +oss Diva im 6eslie is going to micromanage Dogan and @oodnights cases, andgag order them, he Aetter Ae sure not to scre up the cases reuiring a mistrial Ay failing to providethe client the cds of 9"" calls DD< >oung gave the cpd on &!"3 and &!"7!"# in rEc rev#%""2%.3%,and clearly, any pac5et from 7!#7!"# ouldnt have them (not to even get into the flip floppingcontradictory accounts Ay 6eslie and Dogan as to ho gave Coughlin the pac5et, or ho didnt orAlah Alah Alah')))and certainly 6eslie email Aelo only contained a .7 page pdf)))ay to close to the"#!""!"# trial date, and containing materials Coughlin had never Aeen given Aefore))))so much easier,

- 113-


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immy *leaIy to email the client a digital transmittal proving hat you gave and hen))))Aut, no,that ould ma5e it so hard to fudge the accounts of hat as contained therein, or ho handed hatto hom, or ho failed to pic5 up this or that, or Dogans slippery nonsense:

0rom: leslie`ashoecounty)us/o: Iachcoughlin`hotmail)com

CC: BDogan`ashoecounty)us

*uAEect: 9"" Case

Date: 0ri, 7 Dec #%"# "7:%9:%& %%%%

r) Coughlin:


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*o, hile Dogan states on 7!#7!"# in .3% >our 8onor, have never even spo5en ith udgeDorothy Nash 8olmes)))he coyly fails to indicate hether he spo5e ith anyone ith the +C,

arilyn /ognoni, included, or hy his #!#&!"# fa1 to Coughlin as so insistent that it as 6a5esCrossings Bill Davis, ;h)D) ho must conduct the Competency valuation, or ho it as udgeCliftons #!#7!"# $rder for Competency valuation could have possiAly 5non and included udgelliott as the randomly assigned Eudge to that Competency Case in C+"#2%37 (udge lliott onCommittee to


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in N+* 4% and ""&


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8olmes, so, sorry ;atty ce, nice try, no *C+ """(.' an $rder or conviction is conclusive proof ofguilt and dont recogniIe ClaiAorne as Ainding authority Aecause it ma5es my EoA harder))))))))

/han5 >ou im for continuing to prevaricate in riting, your recent email comAined ith some, uh,

other materials that have Aeen culled, ill surely Ae helpful in e1posing you for the fraud that youare) oung in coercing from me my 0ifth


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assuming e in on the pat don, ma5e sure to oppose the notation that there as sufficientproAaAle cause for an arrest and search incident thereto)))), not to mention that it as Coughlin(hose filings im managed to cheerfully announce /he ;uAlic Defenders $ffice is not Eoining inon those fugitive documents))), despite the #!#"!"# 0ilings Ay @oodnight that do Eust that))))' thatpointed out the hole N+* "7")3% Aasis for throing out the search (hich im managed to not cite

to or uote from in his closing argument as the *uppression 8earing)))here im did manage to as5Cory @oAle uestions on cross that ere designed to do nothing more than estaAlish a citiIens arrestsufficient to reAut the N+* "7")3% Aasis for throing out the arrest and fruits culled therefrom)))')

$h, then there is your office Alac5ing out the numAers of the callers on the dispatch logs and refusingto turn over even a redacted version of the alleged victims call records for the time in uestion,thereAy completely oAstructing the defendants aAility to impeach the various lies testified to Ay allthe itnesses) oung can tell you all aAout his 4% minutes coaching sessionsvisiAle through the ple1iglass in the ustice Court loAAy ith Zarate, @oAle, 6ichty, and /empleton,and their constant parroting (along ith +;D Duralde' of prosecutor AuIIords (illfullyithheld, report from dispatch of a possiAle fight, my training and e1perience, detained, dont rememAer ho made the call, cant rememAer hich one of my friends it as ho as ithme, etc), etc)'


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made the trespass arrest no detailed in N) *) Ct) case "9%"', on Aehalf of Deputy achen, in theconference room ithin the Courtroom B of the +C, despite Coughlin, an efiler, having alreadyAeen served it') 8oever, the only filing Ay Coughlin that could Ae said to uote roc5 lyrics is the#!#"!"# filing in Dogans case %.3% (the one here Dogan had appeared as attorney of record thenfailed to sho up for a hearing on #!"3!"#, then retaliated against Coughlin for Coughlins #!#"!"#

filing in %.3% Ay moving for a Competency valuation and Aasically doing aAsolutely nothing onthe case for the ne1t 9 months Aesides raping from Coughlin his medical privacy rights along ithudge *teven lliot and DD< Zach >oung at the 4!"9!"# hearing in C+"#2%37 (one of 3 criminalappeals udge lliot as randomly assigned in hich Coughlin is a party)))to go along ith therongful termination suit Ay Coughlin that udge lliot presided over in C-""2%"9.. hereinCoughlin sued C


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


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N+* "7&)3&& provides that the defendant must Ae present at arraignment, trial, and sentencing andprovides that the defendant may aive his appearance hen certain conditions are met)

ts 5ind of odd ho udge Clifton (hose attached Aio indicates he has deep and longstanding ties tothe domestic violence industry infrastructure' 5ne instantaneous to signing the $rder forCompetency valuation of #!#7!"# at ":3" pm that the matter ould Ae randomly assigned to DistrictCourt udge *teven lliot (also a lifelong prosecutor ith deep and longstanding ties to the domesticviolence industrial comple1, and a memAer of the Committee to


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*o, hile Coughlin is reportedly not even alloed to email DD< >oung aAout cases not even Aeforeudge Clifton, or something li5e that)))DD< >oung is aAle to get an unnoticed, e1 parte, emergencyotion to ;rho

*incerely,

Zach Coughlin

"47" ) 9th *t)

+eno, N- &9."#

/el and 0a1: 949 7 74%#ZachCoughlin`hotmail)com

0rom: leslie`ashoecounty)us

/o: Iachcoughlin`hotmail)com

CC: BDogan`ashoecounty)us

*uAEect: 9"" Case

Date: 0ri, 7 Dec #%"# "7:%9:%& %%%%

r) Coughlin:


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*ince e have Aeen removed from the 9"" case, e are closing our file) /he attached materials eresitting at our front des5) *ince you failed to retrieve them, e provide the attached courtesy copyAefore final closure of our file)

No response to this transmittal is reuired from you)

ames B) 6eslie, s)Chief Deputy ;uAlic DefenderY

(N$/: that concludes the 39 page 1hiAit " to Gings "#!#%!"# /;$


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pon Coughlin Aeing assigned an alternate defender (aside from the also conflicted out


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reuired of our office or yours regarding this possible veiled or indirectthreat of violence against attorneys in this office by -r( Coughlin)

*ent: ?ednesday, DecemAer "#, #%"# #:.9 ; /o: Gandaras, ary*uAEect: 0?: /he /hree s= cpd failure to provide essential 9"" call cddiscovery of &!"3 and &!"7, #%"# to Coughlin in rcr#%"#2%.3%

ary:

Pease re)ie! my transmitta to Patric" ing at the #ar,Aelo, andlet me 5no if should do anything else from a civil perspective)

/han5s,

ames B) 6eslie, s)

Chief Deputy ;uAlic Defender

22222$riginal essage22220rom: 6eslie, im *ent: ?ednesday, DecemAer"#, #%"# #:49 ; /o: patric55`nvAar)org *uAEect: 0?: /he /hree s=

cpd failure to provide essential 9"" call cd discovery of &!"3 and &!"7,#%"# to Coughlin in rcr#%"# 2%.3%

r) Ging:

/he Aelo email from r) Coughlin contains a reference at the end ofthe first paragraph to a eAsite containing a video clip from the movieCape 0ear) ;lease advise hether any action is reuired of our office oryours regarding this possiAle veiled or indirect threat of violence againstattorneys in this office Ay r) Coughlin)

/han5 you,

ames B) 6eslie, s) Chief Deputy ;uAlic Defender ?ashoe County;uAlic Defenders $ffice

22222$riginal essage22220rom:

Zach Coughlin Lmailto:Iachcoughlin`hotmail)comM *ent: ?ednesday,DecemAer "#, #%"# #:3. ; /o: 6eslie, im= Bosler, eremy= Dogan,Biray= @oodnight, oseph ?= 0ortier, Chris= /uttle, *teve= Gandaras,ary= >oung, Zach= s5auc`reno)gov= ongd reno)gov=5adlicE`reno)gov= complaints`nvAar)org= cvellisÀhfs)com=Eeèloreno)com= patric55`nvAar)org= davidc`nvAar)org=rosec`nvAar)org= laurap`nvAar)org= s5ent`s5entla)com=mi5e tahoelayer)com= eifert)ntaàtt)net= nevtelassn`sAcgloAal)net=

fflaherty`dlpfd)com= fflaherty`dyerlarence)com*uAEect: /he /hree s= cpd failure to provide essential 9"" call cddiscovery of &!"3 and &!"7, #%"# to Coughlin in

rcr#%"# 2%.3%

/he /rial yesterday in +C+#%"#2%.3% featured e1tended discussionsregarding the failure of the ?C;D, Dogan, and 6eslie, to turn overdiscovery propounded Ay DD< >oung in the form of cds featuring 9""

- 125-


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calls DD< >oung provided to the ?C;D on &!"3!"# and &!"7!"# ))) oung ))) etc))))Y

/he lin5 that 6eslie refers to as containing a Qvideo clip from the movie Cape 0earY actuallycontains only an audioclip of a short uote from Cape 0ear (the "99" *corsese version')

t as arguaAly an aAuse of process Ay Bar Counsel ;atric5 Ging) 8oever, Coughlinsrecollection of the NovemAer th, #%"# (the night of the ;residential lection)))Coughlin as5edNevada 6ayer employee ;aula CampAell if she 5ne ho as inning in the polls)))etc),' Ariefencounter Aeteen she and Coughlin as of one of an entirely cordial, professional nature)


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there, so Coughlin has to, Aasically , Araid the ires together every time he drives at night and inturning the lights uon and off (hat a pain'))

))

1hiAit " to r) Gings /emporary ;rotection $rder


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Coughlin from utiliIing a messenger service to deliver a filing to the *BNs Cler5 of Courts $ffice

for the securing of a file stamp to Aeat a deadline, such as the "!3!"3, or "!4!"3 (depending upon

hether holidays are included in the 3 days for mailing calculus under N+C; (e' and the DeAoer

decision', for Coughlin to file a N+C; .# or .9 otion as to the "#!"4!"# NNDB ;anel 0indings of

0act, Conclusions of 6a, hich recommends that Coughlin Ae irrevocaAly disAarred (disAarments

Aecame irrevocaAle in #%%&') /o curtail the time Coughlin had to prepare such a motion, hich as

scant to Aegin ith, Ay applying an onerous ;$ application, or the threat of arrest for anything

arguaAly violative of it, ould or5 and inEustice, and has here, as Coughlin as arrested and

charged ith a felony ;$ violation for some alleged violation in connection ith his see5ing fromthe *BN a stipulation to an e1tension of time to file his appeal Arief in #337 on or around the

deadlien to do so of "!#3!"3) /he *BN has failed to respond to Coughlins reasonaAle inuiries in

that regard, as has the ?C

6 26 13 0204 3913 3914 opposition to motion in limine 488 pages stamped.pdf

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