8 14 13 0204 3913 3914 62337 CR13-1332 Petition for Writ Against RMC Judges, Marshals, And Clerks 74 Pages

7/27/2019 8 14 13 0204 3913 3914 62337 CR13-1332 Petition for Writ Against RMC Judges, Marshals, And Clerks 74 Pages

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Clar5 -) -ellis, s ), and ichael E) ohnson, s )) /he *tate Bar of Nevada (the *tate Bar 'appeared and as represented Ay Deputy Bar Counsel, ;atric5 $) Eing, s )) /he +espondent,Zachary Bar5er Coughlin, Nevada *tate Bar No) 9473 (the +espondent or Coughlin ' appeared in

propria persona)FINDINGS OF FACT

Based upon the pleadings filed, the documentary evidence admitted as 8earing 1hiAits "through " , and the testimonial evidence of the 8onoraAle udge Bruce Beesley, +ichard 8ill, s ),;aul cano, s ), the 8onoraAle udge Dorothy Nash 8olmes, Zachary B) Coughlin, s ) and aryBar5er presented at the hearing of these proceedings, the ;anel ma5es findings of facts asfollo s:

") Coughlin is an attorney licensed to practice la in the *tate of Nevada) At allrelevant times prior to and at the time of the filing of the Complaint in this matter, the

Respondent's principle office , as file !i"# "#e S"a"e Ba$ %f Ne&a a i' a((%$ a'(e !i"# "#e R)le%f P$%fessi%'al (%' )(" *+RPC+ - */ *a , !as P%s" Offi(e B%0 1 2/, Re'%, N3 4 565 ) *ee8earing 1hiAit " at %%%", lines 72"% (*tate Bar of Nevada vs) Zachary B) Coughlin, s ), Case No:

N@"#2%#%4, N@"#2%43., N@"#2%434,Complaint at P1 (filed


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*ee 8earing 1hiAit "" $+D + 0$+ *


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rancorous interactions ith arshal enGel at the "%!"%!"" arraignment (the hold of hichviolated N+* "7&)4%. in light of the then pending 9!7!"" $rder for Competency evaluation of

hich the + C as made a are, in riting in', similar interactions ith + C filing officecounter cler5s and supervisors incident to their refusal to allo Coughlin to access even thealmart s 0rontino and $fficer Eameron Cra ford', and a to per seindigent under #%%& ndigent Defense $rder, aAuse of (%'"e87" po er, violation of ;engilly

and cCormac5, failure to grant a continuance here e1cuplatory evidence as Aeingrongfully ithheld Ay and opposing counsel hom had AurglariGed Coughlin s former homela office ith Aoth the >C*$ and +;D (+ussell v) Ealian, N+* 4%)#.3(.', ayes v) - ',and denial of a continuance to Coughlin (despite one Aeing agreed to in riting Ay +CCD< let drag on for nearly a yearin a transparent attempt to leverage such ( hich they al ays intended to dismiss given the enormityof the proAlems associated ith the !"4!"# . Day Notice allegedly posted (Aut not mailed, much less

ith a *;* Certificate of ailing' listing, pursuant to N+* 4%)#.3(3'(A'(3' L*par5s ustice CourtHas the court hich Coughlin must file his /enant s


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and the + C s general email address))) hich is odd considering, clearly, such email as, at one point, part of such file, on the left hand side thereof, under the doc5et)

0or instance, ith @essin, for hom Coughlin filed an $pposition to otion for *ummaryudgment on 3!"9!"# (Kust 4 days after Aeing AurglariGed Ay the >C*$ and @ayle Eern, s ), on

3!".!"# incident to the too early summary loc5out' there is no a decision detailing such time periodfrom the nited *tates Ban5ruptcy


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file certified copies of the state court Kudgment and record and too5 the matter under suAmission) $nune &, #%"#, the Aan5ruptcy court entered an order granting /aitanoPs * on the grounds that the

state court arAitratorPs a ard estaAlished every element under .#3(a'(#' and thus the doctrine ofissue preclusion prevented deAtor from relitigating those elements in the Aan5ruptcy court) DeAtortimely appealed)))) ) ** >hether the Aan5ruptcy court erred in deciding that the state court

Kudgment as nondischargeaAle under .#3(a'(#' Aased on the doctrine of issue preclusion)H

9) udge Nash 8olmes oA se$&e that the pleading filed Ay Coughlin failed to addressmost of the topics listed in the caption) +ather, she oA se$&e , the document contained ramAlingreferences to Coughlin s personal life, his father s footAall career in college? doGens of pages of stringcitations ta5en from the internet and other unrelated references) udge Nash 8olmes found the

pleading to Ae disKointed and incoherent and a pathetic demonstration of hat might once have Aeenlegal and academic pro ess that appears to no Ae greatly damaged) *ee 8earing 1hiAit .,$+D +, ;#, lines 92".? ;#, lines " 2#%)

"%) udge Nash 8olmes also found that Coughlin, after Aeing released from custody

follo ing the 0eAruary #7, #%"# (%'"e87" of Court incarceration, filed other nonsensical pleadingsincluding a #"& page document:

)))purported to Ae yet another motion in this case entitled otion to +eturn Cell;hones? otion to *et


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evidence, Aased on her e1perience and Aac5ground as an attorney, prosecutor and Kudge that Coughlinhad violated numerous provisions of the Nevada +ules of ;rofessional (%' )(" ) *ee/ranscript of ;roceedings of >ednesday, NovemAer "4, #%"#, ; "37, 6 ## 2; "3&, 6 9)

" ) )*) Ban5ruptcy udge Bruce Beesley as called to testify at the hearing of thismatter) During the time frame #%"" to #%"#, Coughlin appeared Aefore udge Beesley t o or three

times as an attorney representing clients in a Aan5ruptcy matter) $n one occasion Coughlin appearedearing a /2shirt and a tie and no Kac5et) *ee /ranscript of ;roceedings of >ednesday, NovemAer"4, #%"#, ; "%, 6 "%2" ) Coughlin had filed a pleading in the Aan5ruptcy matter, on Aehalf of hisclient) udge Beesley testified that the pleading as lengthy, didn t ma5e any sense, and Kust sort oframAled through a great deal of irrelevant stuff) *ee /ranscript of ;roceedings of >ednesday,

NovemAer "4, #%"#, ; "%, 6 #4 2; "", 6 ") $n other occasions, although Coughlin appeared politeand intelligent, his pleadings and arguments didn t ma5e any sense) *ee /ranscript of ;roceedings of>ednesday, NovemAer "4,#%"#, ; "", 6#27

"7) udge Beesley Aecame concerned, rote a letter to the *tate Bar e1plaining hise1perience ith Coughlin and indicated that he did not Aelieve Coughlin, in his current state, asaAle to ade uately represent his clients) *ee /ranscript of 8earing >ednesday, NovemAer "4, #%"#,;

"3, 6 #4 2; "4, 6 7)"&) n udge Beesley s opinion, Coughlin is not competent to practice la ) *ee /ranscriptof ;roceedings of >ednesday, NovemAer "4,#%"#,; *, 6 "" 2".)

"9) *tate Bar Counsel called attorney +ichard 8ill to testify at the hearing of this matter:r) 8ill has Aeen a memAer in good standing ith the *tate Bar of Nevada for 33 years) *ee

/ranscript of ;roceedings of >ednesday, NovemAer "4, #%"#, ; 3 , 6 ## ; 37 6 4) r) 8ill asretained Ay Dr) erliss to assist Dr) erliss in a landlord tenant dispute ith his tenant Coughlin) *ee/ranscript of ;roceedings of >ednesday, NovemAer "4, #%"#, ; 37, 6"4 2#%) r) 8ill representedDr) erliss in +eno ustice Court and >ashoe County District Court and t o appeals to the Nevada*upreme Court in the matters involving Dr) erliss and Coughlin) *ee /ranscript of 8earing>ednesday, NovemAer "4, #%"#, ; 39, 6 "3 2#4) r) 8ill has also revie ed filings in of a case in

hich Coughlin is involved ith >ashoe 6egal *ervices) *ee /ranscript of ;roceedings >ednesday, NovemAer "4, #%"#, ; 39, 6 #. ; 4%, 6 3)

#%) n thee&i("i%' proceeding Aet een Dr) erliss and Coughlin, r) 8ill s firm oAtainedan e&i("i%' order allo ing Coughlin one ee5 to vacate the premises) ltimately, Coughlin failed tocomply ith the e&i("i%' order and as convicted of criminal "$es7ass ) *ee /ranscript of 8earing>ednesday, NovemAer "4, #%"#, ; 4", 6 "& 2; 44, 6 "#)

(LHEARING 3%l. I, *Pa9es / /- "% / ' B= +) E N@: F Did you end upgetting an eviction order removing r) Coughlin from Dr) erliss s homeM < (+ichard @)8ill, s )' >e did) F *uAse uent to the eviction order, as r) Coughlin removed fromthe homeM < m sorry) /here as an %$ e$issued in court "#a" 9a&e M$. C%)9#li' a"ee$ to vacate ) Aelieve it as NovemAer " that my ife, my associate 22 and myassociate, "ent to the home "ith the sheriff and conducted a loc$out ) /he front doorloc5s ere changed) /he Aac5 door loc5s ere changed) +) C$ @86 N: $AKection)

+) C8 - ++


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everything, ma5e sure the place is secure, videotaped it) ashoe District Court udge ;atric5 0lanagan entered the order on une #., #%"#)(N$/ : this use of the term LsanctionH is noticeaAly aAsent from this LfindingH and the follo inge1cerpt from the transcript cited to, further, despite such e1cerpt Aeing only t o lines long, it doesmanage to reveal that udge 0lanagan s $rder granted L erliss s motion for attorney s feesH))) hich,

hen one considers that erliss s 4!"9!"# filing as titled L' *ee /ranscript of ;roceedings of>ednesday, NovemAer "4, #%"#, ; 47, 6 327)

(8


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associate, Casey D) Ba5er, s ), cited to as providing a Aasis for such a fee a ard(never mind that N+* 4%)4%% ma5es N+


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QiRt is hard to imagine a more appropriate case than this in hich to a ard the ma1imumamount Kustified Ay the suAstantial evidence Aefore the court) ( ot) at p) )' erliss goeseven further and states:


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ith >ashoe 6egal *ervices, r) 8ill is of the opinion that Coughlin is not competent to practicela ) *ee /ranscript of 8earing >ednesday, NovemAer "4, #%"#, ; 39, 6 " 2"#)

#3) Based on r) 8ill s e1perience in litigating ith Coughlin, Coughlin as not truthfulith either counsel or the court) *ee /ranscript of 8earing >ednesday, NovemAer "4, #%"#, ; .3, 6 2" ) r) 8ill felt that Coughlin s filings ere aAusive, at one point calling r) 8ill s associate a

lichen) Coughlin has accused r) 8ill of AriAing the +eno ;olice Department to have Coughlinarrested) r) 8ill s staff is terroriGed Ay Coughlin) *ee >ednesday, NovemAer "4, #%"#, ; .4, 6 42".)

#4) *tate Bar Counsel called attorney ;aul lcano to testify at the hearing of this matter)r) lcano is the e1ecutive director of >ashoe 6egal *ervices that provides legal services to

indigents) *ee /ranscript of 8earing >ednesday, NovemAer "4, #%"#, ; &&, 6 #. 2; &9, 6 "4)Coughlin as employed Ay >ashoe 6egal *ervices from ednesday, NovemAer "4, #%"#, ; 93, 6 "7 2#%) r) cano Aecame a are ofan order entered Ay udge @ardner on )@ardner for giving such to udge Nash 8olmes, though, clearly, udge >) @ardner e1pressed surpriseto hear that such 08 3 that he received from his sister and passed around to his fello + C udgeshad Aeen provided to the *BN Ay udge Nash 8olmes (echoing the lac5 of permission to spea5 on his

Aehalf that + C udge Dil orth e1pressed disatisfaction ith respect to during the trial incident tothe rongful +;D arrest of 7!3!"# in + C "# C+ "#4#%') >hether udge >) @ardner as negligentin providing such inoperative 08 3 to udge Nash 8olmes is a matter for r) *arno s5i, and

perhaps the courts, given Kudicial immunity is not uite such an impenetraAle defense hen it comesto courts of limited Kurisdiction)))*ee, @laGier)

- 15 MOTION TO DISQUALIFY RMC AND HON. JUDG DIL!ORTH


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# DC udge 6) @ardner s #!#.!%9 $rder reads: $+D + + ;+ /+


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appealaAility of the $rder ithregard to appeal of the issues pertaining to the oshi marriage!divorce, the Court finds the$rder 6* in only serving certain selected filings or orders in D-%&2%"" & onCoughlin upon his Aeing terminated Ay >6*)

*pringgate s letter to Coughlin supports the Consent Decree argument, to hatevere1tent any fees ere even still part of any operative $rder or Decree given *pringgate s;roposed Decree of .!#"!%9 contained a section e1pressly providing for such fees, here the

0inal Decree # DC udge 6) @ardner entered on !"9!%9 ( hich noAody served on Coughlin,conveniently' contained all of *pringgate s ;roposed Decree save the paragraph therein providing for an a ard of attorney s fees) 0urther, udge 6) @ardner s $rder of 7!".!%9further supports the position that there as no longer any attorney fees a ard, as a sanction orother ise (li5ely due to a recognition of the legitimacy of Coughlin s argument ith respectto *pringgate having failed to comply ith N+C; "" s #" day safe harAor provision(incorporated into N+* 7)%&. Ay the e1press language of such statute' in addition to the factthat the 4!"3!%9 $rder 6* and *pringgate arguaAly entered into a Consent Decree even further vitiating anyfinding that attorney s fees ere a arded) *pringgate s letter to Coguhlin of "#!&!%9 reads:

LDecemAer &, #%%9 - < < 6 Zachary Coughlin, s ) 73" 0oreset *treet +eno, N=&9.%9 Dear Zach: have received the *upreme Court s $rder Denying ;etition for >rit of

andamus)


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the help and ould Ae happy to put this case Aehind me) ;lease advise as to your intentions)-ery truly yours, $8N ;) *;+ N@@ednesday, NovemAer "4, #%"#, ; "74, 6 "3 2; "&%, 6 4) *ee 8earing 1hiAit &) (N$/ : "#e$e is '%"#i'9 i'"#e $e(%$ "% s)77%$" "#e fi' i'9 "#a" C%)9#li' $e(ei&e s)(# le""e$ from Ba$ C%)'sel , in fact,Coughlin testified to Bar Counsel s chicanery in that regard, and certainly Eing should not Aeallo ed to LtestifyH to sending Coughlin some letter that Eing refused to even see5 have admitted

into evidence, especially here Eing successfully moved, on an e1 parte Aasis, to uash Coughlin ssuApoenas on Eing and *BN Cler5 of Court ;eters, not to mention +;C 3)7, etc))0 )$"#e$, "#e$e is '%"#i'9 i' "#e $e(%$ "% i' i(a"e "hen Coughlin first sa" such 3!"4!"#

grievance letter that + C udge Nash 8olmes sent to the *BN, not Coughlin (Eing s constanttrumpeting of the LAates stampsH that he had affi1ed to the Ao1 of 3,#%% pages delivered to Coughlinfour Kudicial days Aefore the hearing (in flagrant violation of all of *C+ "%.(#'(c' references the Aatesstamps found on the 8earing 1hiAit &)))and here Eing admits such letter did not have any such

Aates stamping on it to Aegin ith, its inappropriate for Eing to have successfully had admitted such



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version ith Eing s ""!7!"# production of 3,#%% pages orth of Aates stamped *C+ "%.(#'(c'materials (none of hich include any Canon #, +ule #)". letters from the udges hose orders Eingoffered as evidence of Coughlin s professional mis (%' )(" , such as 8earing 1hiAit # s udge0lanagan $rder of !#.!"# in the appeal of the summary e&i("i%' from Coughlin s former home laoffice that +ichard @) 8ill, s ), AurglariGed hile managing to get Coughlin rongfully convicted

of criminal "$es7ass (see "9%"' Ay 8ill s lying to, and ith, the +eno ;olice Department') *omeLclear and convincingH evidence of *hen Coughlin received or vie ed such letter ould Ae prettyimportant to support the ;anel s LfindingH that Coughlin Lfailed to directly respond "% >)es"i%'i'9$e9a$ i'9 !#e"#e$ %$ '%" #e #a s)


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allegations to Bar counsel, the allegations made in the letter Ay udge 8olmes, and theaccompanying documents? did you respond to that investigationM <


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that Aelieve is relevant to the determination of the degree of punishment, if any, thatshould flo to you as a result of your (%' )(" ) *o, r) Eing, move on, please) +)E N@: /han5 you) /8 > /N **: =our 8onor, can Kust uic5ly attempt to morethoroughly address that issueM +) C8 - ++ e have multipleaddresses for r) Coughlin and can t seem to locate him Aet een cases veryeasily) >e are setting that case for trial and attempting to serve him at the mostrecent address e have ("4## ) 9th *t) U# +eno N- &9."#', al"#%)9# I #ea$"% a: he may be living in his vehicle some"here ) >e do have an address forhis mother, ho ever, as she recently posted part of a fine for him)

udge Een 8o ard, Department 4, had a case on r) Coughlin late last yearthat is no on appeal to the *econd udicial District Court) udge Bill @ardner,Department #, also has a matter currently pending in his court ith r)Coughlin as the defendant) have enclosed some copies of documents fromthose matters, in chronological order , simply Aecause they appear todemonstrate that he is #uic$ly decompensating in his mental status ) $ur staff

also made you some audio tapes of Coughlin in the matters in Departments #and 4 so you can hear for yourself ho this attorney acts in court) =ou can seehis Aehavior in my traffic citation case does not appear to Ae an isolatedincident)

t is my understanding that +eno ustice Court also has a matter pending on thisattorney) M: J) i(ial Assis"a'" !as (%'"a("e


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hich certainly is not supported Ay the Certificate of ailing on such #!#&!"#$rder at +$< ""7#, hich indicates such $rder as mailed to Coughlin at thevery L"#" +iver +oc5 *t)H address from hich udge Nash 8olmes and several Departments of the + C 5ne Coughlin had Aeen evicted from Ay the very+ichard @) 8ill, s ), referenced at +$< ""7% lines #42#& (L L' here suchCertificate of *ervice fails to include a chec5 ne1t to L>ashoe County ailH andinstead seems to indicate only that such $rder as fa1ed to some unspecifiedfa1 numAer, though, Coughlin can attest, he certainly as not fa1ed any such$rder (the + C has steadfastly refused to e1tend any such courtesies toCoughlin from the very Aeginning, despite there Aeing a multitude of instances

here Certificates of *ervice Aet een the + C and the +C< and the + C scourt appointed defender allo for service Aet een each other Ay email or fa1,even here Coughlin pleaded ith the + C to at least copy him on such $rdersdue to the domestic violence Aased interference ith his mails he as facingduring the times in uestion at "4## ) 9 th *t) U# (not to mention the misconduct

of the *;* @olden -alley *tation s Buc5 8yde, and /erri ;assot, and @ayleEern, s ), and her LassociateH *usan Eing of >estern Nevada anagement(property manager') nterestingly, the Certificate of *ervice for a 3!&!"# $rder

Ay udge 8olmes denying Coughlin s other s re uest for a return of the I"%%she paid to have Coughlin released from the summary . day incarceration oneday early (doing Lthe old s itcherooH the + C too5 Coughlin s mother smoney, then concocted a ridiculous scheme here a Kail deputy removedCoughlin from his cell and al5ed him do n, in chain the entire time, to the

Aoo5ing des5, and announced he as having an Lad Aoo5H done, thenimmediately returned Coughlin to his cell) (insert complete te1t of ridiculous

3!&!"# $rder in # &%%, here Coughlin s mother, ell over one year after such$rder as entered, mysteriously and uitely as mailed such I"%% Ay the + C,hich also appears to have mailed Coughlin the I"#%)%% Aail he as forced to

post hen he could ill afford to, on "!"#!"# incident to +ichard @)8ill, s ),getting Coughlin arrested for Kay al5ing hile 8ill oAtained he on command/;$ from + C udge *chroeder in less than forty minutes time in +C;#%"#2%%%%"&, sufficient to oAstruct Coughlin s aAility to film any more the fact that8ill s contractor, NB s ;hil *te art, had via 8ill s filings, suAmitted Ailsl tocourts see5ing to charge Coughlin I",%%% to Aoard up Coughlin s former homela office ith Coughlin s o n ply ood, and other misconduct Ay 8ill)


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the storage area in the attic' then 8ill s associate Ba5er lied in his "!3!"#$ppsoition to Coughlin N+* 4%)3&. otion to *tay of "#!3%!"" in alleging heand 8ill and entered some agreement ith Coughlin to allo Coughlin moreaccess to remove his Aelongings in e1hange for a aiver of the securitydeposit!cleaning fee of I7%% that remains unreturned despite their failure to

provide a ritten account ithin 3% days and especially here collateralestoppel ought prevent any assertion of rent Aeing o ed incident to theaAandonment of the non2payment summary initial of t o cases Arought in+ev#%""2%%"49#)


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page . of such $rder at +$< "7#7, the Aates stamping Eing had applied to all pages of the 3,#%% page production to Coughlin on ""!7!"# (pages " through 4of such LversionH of the $rder Eing included in the Lpac5etH in 08 " purportedto Ae an accurate copy of the version of such 3!"#!"# $rder attached as 1hiAit 3to Eing s Complaint, hen, in fact, Eing and *usich used the same Alurry,illegiAle copy of such $rder in Aoth Eing s Complaint and the version attachedas an 1hiAit in %97. that Coughlin as5s this Court ta5e Kudicial notice of no(ie, a legiAle copy ithout the ""!7!"# Aates stamping')


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form the + C hold out for such purposes, directed to ards oAtaining the audiotranscript of all hearings in that matter, including that of #!#7!"#, hich the+ C refused to respond to))) hich is hy Coughlin had to stealthily have hismomma go oAtain to the audio transcript from the + C, in addition to theLversionsH hich Eing and the *BN finally provided Coughlin in late une#%"#, hich Eing, curiously, alleges to Ae Lnot certifiedH and apparently lac5ingin foundation and proAaAly not all that truthful, apparently ( if "#a";s s%, "#e'!#: is';" s%8e%'e i'&es"i9a"i'9 "#e RMC f%$ 7$%&i i'9 altered a) i%"$a's($i7"s "% "#e SBN M')

3") $n arch , !1 Coughlin caused to Ae filed an


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LL 0;! 0 N


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Cler5 of Court ;eters) here *uch Did Not ven @o $ut /he Ne1tDay "%!#.!"", But >as $nly ;ic5ed p By /he sps $n "%!# !"#, ;reKudicingCoughlin s here ;anel Chair

cheverria, Curiously (even /hough /he ;anel 8ad $nly Been Designated /he;revious Date, "%!3%!"# By NndA Chair *usich' ntered


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is not all that surprising considering Eing s o n signature on that $ppositionindicates such as +espectfully suAmitted on this #. day of $ctoAer, #%"# */


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similar (such as a Demurrer, a otion to Dismiss, a otion for ore Definite*tatement, etc', not $ppositions, so cheverria s suAse uent Lconclusion of la H thatthe allegation in Eing s Complaint L could be ta$e as admitted as a matter ofdefault H in vie of his LfindingH that Coughlin failed to file a L responsive pleading His seriously undone': /herefore, / * 8 + B= $+D + D:)) ") otion to Dismiss

7$e7a$e *eptemAer " , #%"#, and filed $ctoAer " , #%"#, is D N D) #) M%"i%'f%$ O$ e$ "% S#%! Ca)se +egarding mproper


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reason, are those part of the record that go up on appealM n civil litigation, ithhich m only familiar, that does Aecome part of the record if so designated) +)

E N@: f the orders go up, pleadings that are not admitted do not go up) +)C$ @86 N: =our 8onor, if can Kust interKect 22 +) E N@: n other ords,everything r) Coughlin sent, oftentimes ith these multiple captions here he s

sending them to many people, he might caption as a pleading, it doesn t ma5e it a pleading) t has to Ae something that as sent to us, filed in, and that ould Ae a pleading)


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#%"2#%4 Notice of Non2*ervice of ntent to /a5e Default of hopper Choc5ed "%!9!"# itnesses and



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*ummary of vidence prepared Ay Aar counsel pursuant to *upreme Court +ule)(o the e tent that Coughlin "ants to revie" the disciplinary files pertaining tohis case, .ar Counsel has no objection ) Coughlin sM%"i%'s "% Bif)$(a"e a'"% Dis8iss must Ae denied as totally lac5ing in merit) Consistent ith other

pleading filed Ay Coughlin, the instant motion is t enty2seven (#7' pages longincluding over one hundred ("%%' pages of attached documents) /ogether themotions lac5s merit and must Ae denied) /he Complaint in this matter issufficiently clear and specific as "% inform C%)9#li' of the charges againsthim a' the underlying conduct supporting the charges )/he Complaint includes t"o criminal convictions (N$/ : s)(# s%$" %f)' e$8i'es "#e NNDB Pa'el;s fi' i'9s a' (%'(l)si%' 7$e8ise )7%' "#e&ie! "#a" C%)9#li' s)s"ai'e "!% ($i8i'al (%'"e87" (%'&i("i%'s, noM' anda Court $rder finding that by clear and convincing evidence Coughlin violatednumerous rules of professional conduct ) *ee *C+ "%.(#') (N$/ : funny, nomention of 08 #, udge 0lanagan s attorney s fee LsanctionH ( ell,

+presumably , rightM No mention of # DC udge 6) @ardner s stale, lachesridden $rder Aeing asserted as a Aasis for charging Coughlin ith violations ofLnumerous rules of professional conductH'Coughlin had t enty (#%' days to file a verified ans"er to the Complaint)nstead, Coughlin attempted to avoid service and no argues that the Complaint

Ae Aifurcated and or dismissed) Coughlin has Aeen temporarily suspended Ay the Nevada *upreme Court as a result of a *C+ """ petition filed after appeal of amisdemeanor conviction) /he Court referred the matter to a disciplinary panelof the Northern Nevada Disciplinary Board) /he pending formal Complaintfiled Ay the *tate Bar of Nevada "as not based e clusively on the %CR 111

petition , Aut primarily from grievances filed "ith the $ffice of Bar Counsel)Coughlin is misapplying the Court *rder resulting from a %CR 111 petition )/he *upreme Court said, regarding the criminal conviction, that the only thingto Ae decided is the discipline or penalty that should Ae imposed) /he Court s

position on this is consistent ith the fact that Coughlin as found guilty Aeyond a reasonaAle douAt and therefore the *tate Bar need not prove thatCoughlin committed the crimes) Coughlin ould li5e that interpretation to meanthat that *tate Bar may not bring multiple disciplinary charges againstCoughlin in the Complaint ) Clearly, Coughlin s interpretation is rong)/he *upreme Court in the same $rder found that Coughlin is suspended

pending a disciplinary hearing ) (N$/ : the phrase Lformal disciplinaryhearingH as found in *C+ "%., is aAsent Eing s restatement of the !&!"# $rderin %&3&') Coughlin s otion to Dismiss, "hile largely unintelligible , is Aasedon Coughlin s assertions that Bar Counsel failed to conduct an ade uateinvestigation) *ee otion page " ll "%2 "# here Coughlin argues as follo s:L*o Coughlin has Aeen and continued to tell Eing aAout the ridiculousness ofthe conviction and dismissal of the appeal in the criminal trespass matter , andEing gets all spoo5ed aAout his utter failure to investigate , and tries to Kam



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through an *C+ """ filing hile on the phone ith Coughlin)H otion page "ll "%2"#)(his matter #as


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Coughlin s LallegationsH (N+C; "" Ay ay of N+* 7)%&. involves LallegationsH, right,>illiam 6) /erry, s ), not the LargumentsH addressed in +;C 3)3 s Lmeritorious claimsHrule' ere not LAased in fact or la H here, ultimately, as admitted to in her !"9!%9 0inalDecree of Divorce, # DC udge 6) @ardner (only after her $rder gave >6* s lcano a

prete1t to fire Coughlin' had to admit that some alimony, in fact, as appropriate (ie, hard toargue Coughlin Lve1atiously e1tended a proceedingH Ay failing to Auy *pringgate and udge6) @ardner s hard sell of *rpinggate s Lsettlement proposalH herein Coughlin s client as to

aive any claim for alimony in e1change for some illusory agreement that *pringgate s clientould Ae reponsiAle for the inflated medical deAt, and third party unsecured credit card deAt

for hich *pringgate s client as the sole signatory (Coughlin provided the *BN all hisfilings in .3&33 and .4&44, hich ell detail the hole Ldomestic duty has priority over third

party deAtH Aasis in Lfact and la H that should have prevented the ridiculous LsanctionH Ay# DC udge @ardner (especially here Coughlin referenced his 6* (*ternlicht can Aehave in as outrageously offensive andcaustic manner as she please)))Coughlin needs to follo a dress code, hip up a ;etition tochallenge the Board of ualiGation s ruling that non2profit >6* must pay its for profitlandlord s property ta1es in the days preceding the very trial from hich # DC udge 6)@ardner s 08 3 $rder stems, etc), and the minute Coughlin voices any annoyance ith not

Aeing given the raise promised upon his Aeing employed at >6* for one years time ( hereCoughlin had Aeen employed "& months Ay that point', >6*, rather than address the reasons

Aehind >6* ;resident Eathleen Brec5enridge ordering and oAtaining a copy of the 0-%92%%&& /;$ hearing herein Coughlin, representing a, gasp, male victim of domestic violence(see %3%#, %3"7 for details on *ternlicht declaring to an assemAly of dv victims (that

included t o men' at a clinic that Lmen cannot Ae victims of domestic violenceH for an ideaof hy >6* ould prefere to Kump on the prete1tual L udge 6) @ardner s 4!"3!%9 $rder6* Brec5enridge s oAtaining acopy of the recording (as noted in the doc5et in such case' of the 3!"#!%9 /;$ hearing priorto the entry of such 08 3 $rder Ay # DC udge @ardner (the doc5et notates thatBrec5enridge, apparently in response to Complaints Ay the same C


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during the second day of the divorce trial in D-%&2%"" &, hich occurred on3!"7!%9, (ie, t o Kudicial days apart ere the t o trial dates in that divorcecase, contrary to >6* lcano s orn testimony and his Lnot in the heat of

AattleH commentary in his termination letter to Coughlin of .!7!%9 (8


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39) During the course of the hearing of this matter Coughlin continued to demonstrate a pattern of (%' )(" similar to, if not identical to, (%' )(" in other forums for hich he had repeatedly Aeen sanctioned) *ee /ranscript of 8earing >ednesday, NovemAer "4,#%"#) ;leadings in this matterfiled Ay Coughlin ere e1ceedingly lengthy, demonstrated a lac5 of focus and understanding of theissues involved, ere ramAling and incoherent and contained discussion of irrelevant issues) *ee, e)g

8earing 1hiAits "4, "., " ) !ee also, ;leadings Doc5et otion for $rder to *ho Cause ))) dated$ctoAer #,#%"#? otion to +evie and nspect Bar +ecords ))) 0iled $ctoAer " , #%"#? ;leadingentitled >ell >ould =ou 6oo5 at /hat ))) dated NovemAer 7,#%"#? mergency 1 ;arte otion/o Dismiss or Fuash ))) 0iled NovemAer "3,#%"#)

4%) Coughlin s(%' )(" at the hearing included (%' )(" not reflected in the transcript ofthe proceedings Ay ay of facial gestures, Aody language, voice intonation and volume) *ee/ranscript of 8earing >ednesday, NovemAer "4, #%"#, ; "&", 6 "92; ", 6 ")

CONCLUSIONS OF LAWBased on the foregoing 0indings of 0act, the ;anel hereAy issues the follo ing Conclusionsof 6a :(


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DecemAer , attorney had four ee5s to oAtain ne counsel and to prepare for the continuedhearing) n re Discipline of *chaefer, #%%", #. ;)3d "9", ""7 Nev) 49 , modified on denial ofrehearing 3" ;)3d 3 ., certiorari denied "## *)Ct) "%7#, .34 )*) ""3", "." 6) d)#d 974)

/he facts of this case oAviously re uired a continuance, hich Coughlin sought on numerousoccasions, Aut hich as denied, as as the case ith Coughlin s filings see5ing to Ae granted

additional time to file a Lverified ans er or responseH should the ;anel determine that Coughlin hadyet to do so ( here Coughlin maintians that he had filed, more than once, Kust such a Lverified ans eror responseH or the functional e uivalent thereof: *ee +$< at:#%"2#%4 Notice of Non2*ervice of ntent to /a5e Default of hopper Choc5ed "%!9!"#


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personal, suAKect matter, and authorityH ' 22 +) C8 - ++


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;age "73 of the #!"3!"3 +$< is enormously proAlematic considering there is no indication such as attachedto the "%!9!"# Notice of ntent to /a5e Default, and it is e1tremely preKudicial to allo for the inclusion of (not to mentionthe presentation of it to the ;anel' of such a fugitive document, is not an affidavit, its not even signed, and its not s orn,and it goes to one of the very Aiggest issue of the case, one that affects the legitimacy of the entire case, the "#!"4!"#0$0C$6, and the holding of a formal disciplinary hearing on ""!"4!"#, ie, hether the Complaint as ever properlyserved')

$f course, Coughlin s otion for $rder to *ho Cause ( hich the *BN had to include in the +$< Aecausecheverria as "%!3"!"# $rder referred to it and denied it (other ise, such ould not have even Aeen included in the +$


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party that is serving me) i'9 No, the Court cler5 is serving you) =our at the *tate Baroffice Aeing served ith a Complaint Coughlin: ve got cases this the you can serve acriminal defendant hen they sho up to a civil proceeding i'9 /his is *tate Bar)Coughlin: $h, get it) >e re playin prison rules, huhM 6i5e in that movie /he CaAle @uy

hen im Carrey is playing pic5up Aall and says $h, e re playing prison rules,huhM /o

the guys ho Kust fouled him so hardM guess, e are playin prison rules do n here atthe *tate Bar, huhM here Aelieveevery other document s Aeen sent, if you loo5 at the certificates of mailing attached at theend of the documents has Aeen sent in t o 22 Ay t o methods, first class mail and certifiedmail) *o it s a little strange that notice of intent to ta5e default 22 mayAe this is some 5ind ofold school Bar counsel tric5) don t 5no ) But it as only sent Ay one method, certifiedmail) *o go to pic5 it up once, the guy doesn t find it) go the ne1t ee5, and this is theguy /im 22 +) C8 - ++


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i'"e'" "% "a e efa)l" ) +) C8 - ++ hat sthatM +) C8 - ++


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(&' >hether Coughlin violated +;C 4)" (/ruthfulness in *tatements to $thers'(9' >hether Coughlin violated +;C 4)4 (+espect for the +ights of /hird;ersons'("%' >hether Coughlin violated +;C &)" (Disciplinary atters'(""' >hether Coughlin violated +;C &)# ( udicial and 6egal $fficials'

("#' >hether Coughlin violated +;C &)4 ( is (%' )(" '("3' /he e1tent of the discipline to Ae imposed pursuant to *C+ """ as a resultof Coughlin s conviction of the serious crime of ;etit 6arceny)

(@' /he *tate Bar must prove Ay clear and convincing evidence that Coughlin violated +;C")",")#,3)", 3)3, 3)4,3).,4)",4)4, .< (sic',&)",&)#,and &)4) *ee Nev *up) Ct) +) "%.(#'(e'? n re *tuhff, "%&

Nev) at 332 34, &37 ;)#d at &. ? @entile v *tate Bar, "% Nev) %, #, 7&7 ;)#d 3& ,3&7 ("99%')C%87e"e'(e(8' +;C ")" states < la yer shall provide competent representation to a client) Competent

representation re uires the legal 5no ledge, s5ill, thoroughness and preparation reasonaAly necessary

for the representation)( ' /he record clearly and convincingly estaAlishes that Coughlin lac5s the (%87e"e'(: torepresent clients, including himself)

( ' 0irst, the record demonstrates severe criticism Ay the trial court in the handling of the oshimatter, including Coughlin s lac5 of understanding of a Aalance sheet, his failureT to (%' )(" discovery, his lac5 of 5no ledge of the rules of evidence and trial procedure) *upra #.

(E' *econd, udge Beesley testified that the pleadings filed Ay Coughlin on Aehalf of hisclient in a Aan5ruptcy case ere lengthy, didn t ma5e any sense, and Kust sort of ramAled through agreat deal of irrelevant stuff) udge Beesley also testified that Coughlin s pleadings and argumentson Aehalf of his client didn t ma5e any sense) *upra " udge Beesley Aecame concerned enoughaAout Coughlin s competency as a la yer that he contacted the *tate Bar) *upra "7

(6' /hird, udge Nash 8olmes uestioned Coughlin s competency as a la yer and in her$rder finding Coughlin in (%'"e87" of Court noted that Coughlin disregarded the rules of evidence,continually imposed improper uestions, failed to properly e1amine itnesses, repeatedly as5ed the

uestion, misstated ans ers, inKected irrelevant material, argued ith itnesses and mischaracteriGedtestimony) *upra 7 (N$/ : >here the punishment for contempt is limited to a fine or imprisonment,an attorney may not Ae disAarred as a punishment for contempt of court) 1 parte +oAinson, & )*)."3)'

( ' 0ourth, udge Nash 8olmes found that Coughlin s pleadings failed to address topics listedin the caption, contained ramAling references to Coughlin s personal life and other irrelevant

material, ere overly lengthy, disKointed and incoherent) *upra 9 S "%(N' 0ifth, the *tate Bar called t o Kudges and t o practicing attorneys ( lcano is not listed as

an active attorney at )nvAar)org, nor has he Aeen for over . years', each ith significante1perience ith Coughlin and each of hom rendered an e1pert opinion regarding Coughlin scompetency as a la yer) udge Beesley testified that in his opinion, Coughlin as not competent to

practice la ) *upra J"&) udge Nash 8olmes testified that in her opinion, Coughlin violatednumerous +ules of ;rofessional (%' )(" including his lac5 of competency to practice la ) *upraJ".)


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($' *i1th, the record estaAlishes that Coughlin %ffe$e '% e07e$" %7i'i%' %$ e&i e'(e as "% #is (%87e"e'(: )Dili9e'(e

(;' +;C ")# states < la yer shall act ith $eas%'a' udge Nash 8olmes found, for e1ample, that Coughlin repeatedly inKected allegations of AriAery, perKuryand police retaliation in a simple traffic case involving the failure to stop at a stop sign) *upra JT7 *he also found tha tCoughlin repeatedly inKected attorney +ichard 8ill into uestions and statements hen r) 8ill asin no ay involved in the traffic citation trial) *upra J 7 *he also found that pleadings filedsuAse uent to Coughlin s incarceration ere lengthy (more than #%% pages' contained scant discussion of, or relevanceto, the matter and contained irrelevant discussion of facts unrelated to the proceedings at hand) *upraJ) "%

( ' /he record estaAlishes that in the erliss e&i("i%' action, Coughlin s (%' )(" as so ve1atious andfrivolous as to result in suAstantial sanction of attorney s fees) *upra J #" *ee 8earing 1hiAit #, ; #, 6 & 2"3? ;3, 6 42"")

(=' /he ;leading Doc5et in this matter estaAlishes also that Coughlin s filings, even in hiso n defense of the disciplinary matter, inKect lengthy, irrelevant facts and legal issues into this

proceeding)Ca' %$ "% "#e T$iednesday, NovemAer "4, #%"#, ; "39, 6(BB'


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continuing pattern of 5no ingly ignoring and disoAeying instructions from the Court)(00' n his $rder of (%'"e87" , udge 8o ard found that Coughlin refused to oAey directives

of the udge and continued lines of uestioning after Aeing instructed to refrain from doing so) *upra4

(@@' udge Nash 8olmes, in her $rder of (%'"e87" , found that Coughlin incessantly argued

ith the Court, interrupted the Court, repeatedly restated matters after having Aeen admonished torefrain from doing so, disregarded directives to as5 properly phrased uestions and disoAeyedn nerous admonitions Ay the court to stop repeating uestions, misstating ans ers, inKectingirrelevant material, arguing ith the itness and mischaracteriGing testimony) *upra J 7 triAunal)repeatedly (%' )(" s himself in a manner that is is$)7" ive of the triAunal hile in the courtroom)

(88' /he transcript of the hearing in this matter clearly demonstrates that Coughlinrepeatedly and incessantly interrupts itnesses, counsel, ;anel memAers and ;anel Chairman andrefuses to heed admonitions to refrain from doing so) *ee generally of >ednesday, NovemAer "4,#%"#)

I87a$"iali": a' De(%$)8 %f "#e T$i$> in response to courtrulings? laughing during testimony and further uestioning the court and its authority)

*ee 8earing 1hiAit "" $+D + 0$+ *


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8o ard))non e of hich have a Certificate of *ervice (notice no harping on ho the appeal turnedout Ay the ;anel Chair for either of the Lcriminal convictionH for contempt)))indeed, here +Colff, ""#

Nev) "3.., 9#9 ;)#d "9 , and *hydler v) *hydler, "94 Nev) "9#, "9 , 9.4 ;)#d 37, 39("9&&')))) / * *$ $+D + D)

/he only other difference Aet een *pringgate s ;roposed Decree and the final Decreeof Divorce udge 6) @ardner entered is found in paragraph .: L.) *;$ * years and s) 8oshi has al"ays beenemployed during that time , inclusive of the fact that she oAtained a college degree prior tomarriage , Aoth parties Aeing healthy and aAle to or5, "#e C%)$" does not


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>itness the alterations to *pringgate s ;roposed Decree aAove in the final Decree ofDivorce udge 6) @ardner ultimately entered: L.) S7%)sal S)77%$" : /he Court has found that

r) oshi is ." and s) oshi is 4 ? the parties earn roughly e uivalent amounts? "#e 7a$"ies#a&e olff v) >olff, ""# Nev) "3..,9#9 ;)#d "9 , and *hydler v) *hydler, "94 Nev) "9#,"9 ,9.4 ;)#d 37, 39 ("9&&'H

8o ever, J) 9e L. Ga$ 'e$;s fi'al De($ee %f Di&%$(e !%)l )7 #i9#li9#"i'9 "#efa(" "#a" C%)9#li' i , i' fa(", 7)" %' e&i e'(e s)77%$"i&e %f a' ali8%': (lai8 , the factthat the parties had Aeen married #" years, ( here, at least under the L/onopah formulaH isover t ice the ten years rule of thumA so commonly predictive in family court of hetherthere ill Ae an a ard of at least some, or rehaAilitative alimony, especially here there arechildren of the marriage) udge 6) @ardner s final Decree of Divorce altered the language in

*pringgate s ;roposed Decree in a manner hich accentuates such fact ( hich Coughlinargument during trial and direct e1amination of his client, s) oshi, estaAlished, inCoughlin s ma5ing argument for an a ard of alimony that as, in fact, Aased in fact and la(in addition to Coughlin s insightful invocation of an 6* and lcano completely oAstructed Coughlin s aAility todisprove such, including refusing to allo Coughlin to access his forme rcoughlinGV ashoelegalservices)org email account or * $utloo5 files' especially here Coughlin isnot in privity ith s) oshi' here *pringgate s retort to Coughlin s in uiring as to Kust hatdiscovery *pringgate himself conducted as met ith the specious response that L + did mydiscovery in the 1F)1 H (see *pringgate email to Coughlin to support the Alan5et assertion thatsuch L 8) Ieneral Credit Card Debt H ( hich J) 9e L. Ga$ 'e$ s"%7s s#%$" %f fi' i'9 "%


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a((%)'"s f%$ !#i(# #e$ #)s6* on 4!#%!%9(the day after his ritten complaint to lcano of a hostile or5 environment and other issues'incident to udge 6) @ardners or5 in 08 3, particularly ith respect to the final Decree ofDivorce and the impact thereof as to the $rder DC+ 9 ;roposed 0inal Decree, + : discovery re uestsM 0rom:

Zach Coughlin (GachcoughlinVhotmail)com' *ent: *un .!#4!%9 7:"9 ; /o:springgatela VsAcgloAal)net 8i on, 8ave you suAmitted a 0inal Decree or 0indings

of 0act yetM >ill you Ae providing me a copy) DC+ 9M



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f am, have . days to oAKect to it, etc))) + $no" "e previously discussed language forban$ruptcy concerns in our settlement discussion, but + feel it is important for the finalorder to specify "hat is for "hat so that any G 3&a&1G or G 3&a&G issues do not become

problematic ? granted she is >6* s client))) 7o"ever, to the e tent that the 2inal Decreespells out the sanctions, + believe + am entitled to G days to revie" any proposed 2inal

Decree prior to your submitting it ) )))Can you respond to my earlier uestion, see Aelo ,regarding "hether you ever sent any discovery re#uests to s) 8oshi M *incerely, ZachCoughlin)))) LH

L+ : >DC+ 9 ;roposed 0inal Decree, + : discovery re uestsM 0rom: arc


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Ms. J%s#i i' "#e e&e'" M$. J%s#i file f%$ 6* did not see fit to include Coughlin on

numerous Certificates of *ervice (or, indeed serve him such documents, never mind >6*utterly failing to defend Coughlin, support him in having the 4!"3!%9 $rder 6* employeeshom Coughlin ould need oAtain chec5s from to send out discovery, etc), or those that prove Coughlin did in fact e1tensively research the issues involved in that case prior to ta5ingthe positions he too5 at trial', and the # DC removed Coughlin from the list of individualsaAle to access such case on e0le1, unless Coughlin paid an I&& real party in interest firstappearance fee ( hich >6* refused to pay on Coughlin s Aehalf', and Coughlin as notallo ed to LappealH the $rder


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and >6* to let Coughlin continue to litigate an appeal and then a ;etition for >rit all thehile Aeing una are that # DC udge @ardner had entered an $rder on !"9!%9 hich

vitiated completely the 4!"3!%9 attorney fee sanction)t is entirely clear hy udge 6) @ardner, *pringgate, and >6* did not ant Coughlin

to Ae a are of the !"9!%9 Decree, specifically to the e1tent that the changes from the $rder6* s rationale proffered for firingCoughlin, hich rested entirely, (Lsole reasonH according to lcano' upon udge 6) @ardner ssince 4!"3!%9 $rder 6* (see %3%#, %3"7' madethe decision to terminate Coughlin employment, announcing such to Coughlin on .!7!%9,ma5ing the !"9!%9 date of entry of the final Decree of Divorce incrediAly convenient for allinvolved e1cept Coughlin)))Kust so long as Coughlin does not Aecome a are of the entry ofsuch final Decree on !"9!%9, and so long as he is not a are of the e1tent to hich thechanges Aet een the t o completely vacate the sanctions, and, in doing so, eviscerate >6* srationale for terminating Coughlin)

L0rom: GachcoughlinVhotmail)com /o: springgatela VsAcgloAal)net *uAKect:

discovery re#uests Date: on, "& ay #%%9 %9:43:"7 2%7%% 8i ohn, Do you have anyrecord of sending any discovery re uests to Bharti oshiM f so, could you indicate hat they

ere and hen and provide a copyM *incerely, Zach Coughlin, s )H+e: >DC+ 9 ;roposed 0inal Decree, + : discovery re uests 0rom: ohn *pringgate

(springgatela VsAcgloAal)net' ) *ent: /ue .!# !%9 .:"4 ; /o: GachcoughlinVhotmail)com" attachment #%%9%.# "7"".&7.&)pdf (34.)% EB' ") /he proposed order as filed ay #") have attached a copy via pdf) 5ept it very sparse on the sanctions) #) /he Aan5ruptcyconcerns are not your issue, she is not your client) 3) did my discovery in the " )")H

Coughlin s conduct therein, is made all the more understandaAle given the complaintsto lcano Ay then named L/ahoe >omen s *ervicesH upon Coughlin failing to satisfy

LadvocateH Cecilia @onGaleG s standard as to Kust ho much he should have e1orted his thenclient ;aula 8auAl to proceed at the e1tension hearing for the order of protection she oAtainedagainst her husAand, here rs) 8auAl as e1tremely conflicted in that regard, and here8auAl actually spo5e ith and rote to lcano praising Coughlin s representation of herincident to lcano conducting an investigation in response to />* s ritten complaintagainst Coughlin, hich lcano refused to provide to Coughlin')

*uch Arings to mind the uestion, then ho as *pringgate s use of discovery, presentation of various forms of LevidenceH (testimonial, documentary, or other ise'sufficient to avoid a sanction, not to mention his L5no ledge of procedural rules and rules ofevidenceH here *pringgate, not Coughlin violated udge 6) @ardner s ;re2/rial orderrespecting the re uirement to provide Coughlin a copy of the Lmore than ten e1hiAitsH that*pringgate offered, Lprior to trialH in a form that is LAound, taAAed, and inde1edH (ironically,*pringgate s violation of such procedural order ( udge @ardner s 08 3 ta5es Coughlin to tas5

here he oAKected to such Lthen failed to cite to a specific ruleH, despite there Aeing nospecific rule, Aut rather, such Aeing la of the case incident to the ;re2/rial $rder thatCoughlin, not *pringgate, complied ith')

ndeed, udge 6) @ardner s $rder of 7!".!%9 further e1plained: L I's%fa$ as ... "#ea!a$ %f a""%$'e:;s fees,... the Court did not intend the a"ard of attorney's fees to be



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included in the Decree of Divorce ))))$n ay "3, #%%9, a otion to *tri5e as filed Ay ohn;) *pringgate, s ), alleging ))) there "as no final judgment entered in this matter yet as the*rder After (rial had not been memoriali:ed into a 2indings of 2act, Conclusions of /a",

8udgment and Decree of Divorce H)H @iven that, the stipulation to an Amended $ecree bet*een !pringgate and 9:! on

;6 3&3&4&7 (Nev) #%"%') n light of our decision to reversein part the district court s grant of summary Kudgment in favor of respondents, e concludethat any a ard of attorney fees and costs under N+C "&)%"%(#'(A' is premature, and thus, the

a ard must Ae reversed) Eahn, "#" Nev) at 4792&%, ""7 ;)3d at #3& (reversing an entire feea ard made under N+* "&) %"%(#'(A' hen a summary Kudgment as reversed in part andaffirmed in part on appeal') Nev),#%"%) d ards v) National Credit ednesday, NovemAer "4, #%"#) (N$/ :no, not good enough cheverria to go *ee generally , see, getting specific) 0urther, the 08 #$rder a arding attorney s fees failed to specify such as Aeing against Coughlin in his role as his o nattorney, versus against Coughlin as the litigant incident to 0lanagan s void application of a



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prevailing party attorney fees statute that only applies to plenary Kudgments any ays (N+*9)%.%')

Rela"i%'s !i"# O77%si'9 C%)'sel (NN' +;C 3).< states >hen a la yer 5no s or reasonaAly should 5no the identity of a la yerrepresenting an opposing party, #e %$ s#e s#%)l '%" "a e a &a'"a9e %f "#e la!:e$


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(**' /he record estaAlishes clearly and convincingly that in the erliss e&i("i%' action,Coughlin (%' )(" ed himself in a manner that as abusive, ve atious and for purposes of delay ) /hematter as a simple eviction action (apparently all evictions are LsimpleH in Nevada, huhM' thatapparently lasted through several proceedings at the unicipal Court level, an appeal to the DistrictCourt and t o appeals to the Nevada *upreme Court and hich also resulted in Coughlin s

conviction for criminal "$es7ass ) *upra "9 and #%

Coughlin s (%' )(" in the proceedings as so egregious that udge 0lanagan orderedCoughlin to pay (N$/ : notice such is not referred to as a LsanctionH and does not specify hetherCoughlin the litigant or Coughlin acting as his o n attorney as the capacity in hich such LorderH

as issued)))Aut regardless)))such is irrelevant Aeyond estaAlishing the defensive collateral estoppel Aar to all the various +;C s the *BN and ;anel 5eep trotting out ith such LorderH in an attempt tos5ip straight past even estaAlishing any such violation Ay ay of meeting a Aurden of proof via theintroduction of actual evidence (rather than hearsay via an interested party dressed up as Le1perttestimonyH' (8ill, udge Nash 8olmes, lcano'' Dr) erliss I4#,% .).%, an amount that is stillunpaid) *upra #"

(//' /he record also estaAlishes that Coughlin #ahose competency is Aeing uestioned, againMDis(i7li'a$: Ma""e$s( ' +;C &)"(A' provides, in pertinent part, ))) a la yer ))) in connection ith a disciplinary

shall not: (A' ))) '%!i'9l: fail "% $es7%' "% a la!f)l e8a' f%$ i'f%$8a"i%' f$%8 a'a 8issi%'s %$ is(i7li'a$: a)"#%$i": )))H

(--' /he record clearly and convincingly establishes that Coughlin $no"ingly failed torespond to the %tate .ar's re#uest for information in the disciplinary proceeding and f aile "%"i8el: file a $e>)i$e &e$ifie $es7%'si&e a's!e$ %$ 7lea i'9 "% "#e C%87lai'" )

(>>' Fi$s", C%)9#li' as e f%$ a' e0"e'si%' %f "i8e "% $es7%' "% "#e le""e$ %f Fe)es"i%'s i'>)i$i'9 if C%)9#li' e&e$ s))e'"l: $es7%' e "% Ba$ C%)'sel;sle""e$ %f Feednesday, NovemAer "4, #%"#, ; " 9, 6 "3 2; "7#, 6 " )H

8


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don t 5no hat it is) /N **: No, that asn t the uestion) 8e said did you receive this

letter) )es"i%' is Di :%) se' as))e'" le""e$ %$ e07la'a"i%' "% "#e S"a"e Ba$ M n other ords, you re as5ing for

additional time) Did you ever send 22 < >hat you do is evil, ;at) +) C8 - ++ /N **: >hat you do is evil) +) C8 - ++


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this point) *o right hen got that letter 22 and thin5 if had Aeen '%"i(e d on this, ouldhave given you the envelope that sho s that there as some 22 li5e the post office ouldn tlet me 22 forget e1actly hat happened) But thin5 gave ;at this stuff 22 +) i'9 >ith the chair s permission, ll move on) /8 > /N **: 22 legitimate reasons hy didn t get this that evince a lac5 of culpaAility on my part) But that s consistent ith hat

;at does) 8e puts on stuff he 5no s is Aaseless) +) C8 - ++ hen did you first respond suAstantively to r) 8ill s complaintsM have not heard anans er) /he response 22 /8 > /N **: =eah) +) C8 - ++


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(d' ngage in (%' )(" that is preKudicial to the administration of Kustice)( ' /he ;leadings, 8earing 1hiAits and /ranscript of these proceedings over helmingly, clearly and

convincingly estaAlish a repeated, unrelenting and oAstinate pattern %f 8is(%' )("


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Disciplinary .oard for further disciplinary proceedings , i' a((%$ a'(e !i"# SCR ///*-a' *4 ) H

8 ell, it could consider thetrespass thing certain, rightM B)" Ba$ (%)'sel file a' SCR ///. 7e"i"i%' $e(e'"l:. W#a"

%es "#a" 8ea' I" 8ea's Ba$ (%)'sel "#e8sel&es a 8i" "#a" "#a" !as '%" a se$i%)s($i8e, a se$i%)s %ffe'se as el)(i a"e )' e$ SCR ///.2 H


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the same effect as though the defects or mista5es had never e1isted)Q#R 8o ever, it usually does notma5e a ne Kudgment or confer any ne or additional rights,Q3R although any suAstantivemodification of a Kudgment constitutes an opening of the Kudgment,Q4R and a change materiallyaffecting a Kudgment and the rights of the parties against hom it is rendered and involving thee1ercise of Kudicial discretion does amount to a ne Kudgment)Q.R @enerally, an amendment leaves

the original Kudgment effective and unimpaired)Q R >here the court stri5es part of a Kudgment, theremaining portion stands, so that the court need not enter a ne Kudgment ith the stric5en partomitted)Q7R


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Nash 8olmes, udge >) @ardner, etc), etc) /he + C and # DC decided not to Koin the party Eingthre , and for good reason) /he + C either as not smart enough to do that, or had to deal ith therash, imprudent, acts of Kudicial conduct that it had already committed to record ( %&3& (aAuse of thecontempt po er, misconduct in illfully violating Canon " +ule ")" in failing to aAide Ay the

ndigent Defense $rder', "9%" (failure to recuse here either per se re uired, or over helmingly

indicated, violations of N+* "7&)4%., ridiculously Aiased approach throughout the case (not right toconfront the arresting officer even', the + C s 6isa @ardner trashing the timely notice of appealCoughlin filed on !#&!"#, and, li5e in the case resulting in %&3&, the + C illingly and5no ningly countenance a multitude of instances of misconduct Ay City of +eno prosecutors and thecontract Aased court appointed defense counsel the + C or City of +eno employs', and udge Nash8olmes hysterical offensive, etc)

8


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C8 - ++ hich e1hiAit, sirM +) C$ @86 N: 1hiAit 4, your 8onor) B= +)C$ @86 N: F =ou rote, defendant lying to the court in response to direct uestions posed Ay thecourt) >hat ere the lies in your vague order that lac5s any specificity to support a summarycontempt finding, hat ere those lies that you failed to elucidate in your orderM +)

C8 - ++ hat ere you referring to hen you rote,Defendant lying to the court in response to direct uestions M < >ell, it ould Ae e1plained in theorder there) don t rememAer everything at this time Aecause don t have it in front of me) But do

Aelieve that you lied aAout or misrepresented that you ere not recording, Aecause Aelieve you proAaAly ere) don t 5no ) Aelieve you proAaAly ere)


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property (the smart phone and micro sd card of a practicing attorney, and his cell phone' released tothem ( hich Aoth the + C and >C*$ have since lied aAout in attempting to cover such up, Aut,darn it, Deputy 8odge told the truth to Coughlin on 3!"9!"#, and people are Kust going to have to deal

ith that, and someone needs to e1plain the erasing of all the data on those items prior to their Aeingreturned to Coughlin (causing massive damages to Coughlin s life and practice', and the e1tent to

hich such Aeing done has preKudiced Coughlin s aAility to defend himself (can t e1actly offer intoevidence the micro sd card or smart phone to prove that Coughlin did not, in any ay, lie to udge Nash 8olmes in response to her enormously inappropriate sua sponte interrogation of himimmediately after the one restroom Area5 on that trial date, and, contrary to cheverria s fraudulentattempts to find that Coughlin failed to deny such accusations, Coughlin most certainly did, in fact,he has denied each and every accusation made in Eing s piffle ridden Complaint)

/he fact that cheverria and the *BN have clumsily sought to ma5e disappear the filingsCoughlin suAmitted on "%!3"!"#, ""!9!"#', "!3!"3, "!"7!"3, and others only further underscores thee1tent to hich all involved, e1cept for Coughlin, in this disciplinary matter are enormously immoral,corrupt, and, in many ays, rather inept) 6aughaAle is easel Clar5 -ellis tal5ing himself out of hisguity conscience stemming from Aeing such a illing participant in the gang Aang Eing and

cheverria put on on ""!"4!"#, here he oAviously relies on some attenuated and vague conceptionthat a Ausy Nevada *upreme Court ill catch anything important that he might have missed in thefilings included in that hich ould Ae transmitted ith the +$< ( here Eent missed such Aecausehe admitted not to loo5ing at things, and not caring to, then he and Eing got caught lying aAout

hether the *BN had provided copies to each ;anel memAer of the discs Coughlin attached ase1hiAits to his various filings, and -ellis, laughaAly, s allo s do n Eing s nonsensical e1planationof Kust hat ill Ae included in the +$


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""%(4' issues here NNDB *usich refuses to communicate ith Coughlin in any manner, as as alsothe case ith cheverria, on top of the *BN providing all the misdirection and lies it could muster)

0urther, Ay L5itchen sin5H2ing it, here, the ;anel fails to do that hich the Court ordered it todo, here it does not specify the Lnature and e1tentH of the punishment for the conviction in %&3&,

Aut rather lumps everything together in a ridiculously over rought, and, fran5ly, enormously

fraudulent LrecommendationH')DECISION AND RECOMMENDATIONn assessing the fonn of discipline to recommend, the ;anel has accounted for a numAer of

aggravating and mitigating factors that must Ae considered) /he ;anel finds that the *tate Bar hassho n Ay clear and convincing evidence the presence of at least eight of the eleven aggravatingcircumstances to Ae considered in accordance ith the provisions of *C+ "%#).("')

0irst, hile there have Aeen no fonnal prior disciplinary proceedings Ay the *tate Bar, therecord estaAlishes that Coughlin has Aeen disciplined Ay ay of sanctions on at least four prioroccasions)

*econd, the record reflects, at least ith respect to the erliss matter and the t o criminaltrials, that the pattern of (%' )(" as for selfish reasons: to preserve an unla ful tenancy and to

delay and prolong criminal convictions)/hird, the record clearly and convincingly estaAlishes that the pattern of misconduct isconsistent *NOTE too Aad Eing failed to '%"i(e plead pattern on continuing mis (%' )(" in hisComplaint' and includes, ithout limitation: the is$)7" ion of the proceedings? the refusal to heedthe directions and admonitions of the court? the inKection of irrelevant material and matters? the filingof lengthy, irrelevant and nonsensical pleadings? the illingness to lie to court and counsel and theinaAility to understand and follo the rules of evidence and procedure)

0ourth, the record clearly and convincingly estaAlishes that Coughlin has committed multipleviolations of the +ules of ;rofessional (%' )(" , as more fully discussed aAove)

0ifth, the record clearly and convincingly estaAlishes that Coughlin engaged in a Aad faithoAstruction of the disciplinary process Ay failing to file the pleading re uired Ay *C+ "%.(#' andinstead filing several lengthy, irrelevant and nonsensical pleadings, mostly pleadings filed in othermatters, and refiled in the disciplinary action under a similar Aut different caption) n some instances ,Coughlin simply crossed out the case name and hand rote the names of the parties in the disciplinary proceeding)

*i1th, the record clearly and convincingly estaAlishes that Coughlin has refused toac5no ledge the rongful nature of his (%' )(" despite having Aeen sanctioned on at least four prioroccasions)

*eventh, the record clearly and convincingly estaAlishes that Coughlin has sho n a completeindifference to ma5ing restitution and has so far ignored orders to do so)

ighth, the record clearly and convincingly estaAlishes that some of Coughlin s mis (%' )(" involvesillegal (%' )(" that evinces fraud and dishonesty) 0or e1ample, he as convicted of one instance of

petit larceny and is a aiting trial on a second)/he ;anel finds fe potentially mitigating factors to Ae present) >hile the ;anel finds that

there is a lac5 of prior puAlic discipline Ay the *tate Bar, the ;anel notes that Coughlin has Aeen puAlicly criticiGed in the oshi matter, has Aeen heavily sanctioned ith an adverse a ard ofsuAstantial attorney s fees in the erliss matter, and has Aeen incarcerated at least t ice for criminal(%'"e87" of court)


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cause of the mis (%' )(" , no evidence of recovery Ay rehaAilitation and no evidence that a recoveryhas arrested the mis (%' )(" and that a recurrence is unli5ely to occur)

/hese potentially mitigating factors are ea5 at Aest and do not e1cuse the ell estaAlishednumerous and repeated violations of the +ules of ;rofessional (%' )(" and do not out eigh theaggravating circumstances estaAlished over helmingly Ay the *tate Bar)

RECOMMENDATIONS/he ;anel recommends that the +espondent Ae ordered:("' rrevocaAly disAarred Ay the *upreme Court) >hile irrevocaAle disAarment is clearly the

harshest form of discipline, the unusual circumstances here, compounded Ay the repetitive nature ofthe mis (%' )(" prior ) to and even during the disciplinary process and hearing, clearly arrant the

level of punishment recommended)(#' /hat his temporary suspension Ae continued pending final resolution of this matter)(3' >ithin three (3' days of the effective date of disAarment, to demonstrate to Bar that he has placed all his

Nevada clients ith other counsel, other ise concluded the representation, or ith the assistance of Bar Counselthereafter attempted to e1peditiously aid anyremaining client in finding ne counsel)

(4' /o pay the costs associated ith these proceedings pursuant to *C+ "#%)

INDE OF HEARING E HIBITS *SBN ;S / TO /1 C%)9#i';s / /5 C#ai$;s /2

" 2I' e0 %f D%()8e'"s Sele("e f%$ Hea$i'9 Pa( e" Ay *BN s ;at Eing in attempt to s5irt hislie that he lac5ed a certified copy of every $rder attached to filings contained therein andcontaining numerous fraudulent ;roofs of *ervice Ay the *BN 7a9e 111

7. 112 . pages of hat Eing purports +;C e1cerpts (")#, 3)", 3)3, 3)4, 3)., 3).


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4@ 1@/ SBN 3. . COUGHLIN SCR /65 COMPLAINT, NG/ 6 6 , 6 1 , 6 15

;6


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Aasement) /he +eno ;olice tried to coa1 hoever as in the Aasement to open the door) Dr) erlissas forced to 5ic5 open the door here the +eno ;olice found +espondent) +espondent had Aro5en

into the home and living in the Aasement) +espondent as arrested for criminal "$es7ass and assuAse uently convicted of that charge)

"#) +espondent, representing himself as co2counsel, filed a 3 2page motion to dismiss on

arch ., #%"#) /he motion as denied Ay udge >illiam @ardner and as determined to Ae ithoutmerit) /he motion, on its face, demonstrates that +espondent lac5s competence to practice la )"3) $nce +espondent as evicted, an order as oAtained to remove his Aelongings from the

home) +espondent interfered ith the contractor ho as hired to remove +espondent s personal Aelongings) /he police ere called and after tal5ing ith +espondent they recommended that he findsomething else to do) +espondent refused to their advice and as suAse uently arrested Ay the +eno

police)"4) n the case of City of +eno vs) Zachary Bar5er Coughlin, Case No) "" /+ # &%% #", a

trial as held on a traffic citation issued to +espondent) /he matter as called at appro1imately 3:%% p)m) and concluded ithout a verdict at aAout 4:3% p)m) after the court held +espondent in criminal(%'"e87" of court for his Aehavior and activities committed in the direct presence of the court during

trial) ".) n a arch "#, #%"# $rder, unicipal Court udge Dorothy Nash 8omes found Ay clearand convincing evidence that r) Coughlin committed numerous acts of attorney mis (%' )(" ) *ee

1hiAit 3) udge 8olmes e1plained in her $rder that after +espondent se$&e his five2day (%'"e87" of court sanction imposed Ay the court on 0eAruary #7, #%"#, +espondent fa12filed to the court a ##42

page document) udge 8olmes found that the document contained ramAling references to his personallife and as incoherent)

" ) n her $rder, udge 8omes found Ay clear and convincing evidence that +espondentviolated +ule of ;rofessional (%' )(" ( +;C ' ")" (Competence', +;C ")3 (Diligence', +;C 3)"( eritorious Claims and Contentions', +;C 3)# ( 1pediting 6itigation', +;C 3)3(a' (Candor to ardthe /riAunal', +;C 3


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#7) n light of the forgoing +espondent violated +;C ")" (Competence'? +;C ")# (Diligence'?+;C 3) " ( eritorious Claims and Contentions': +;C 3)3 (Candor to the /riAunal': +;C 3)4(0airness to $pposing ;arty and Counsel'? +;C 3)* ( mpartiality and Decorum of the /riAunal'? +;C4) " (/ruthfulness in *tatements to $thers': +;C 4)4 (+espect for the +ights of /hird ;ers

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8 14 13 0204 3913 3914 62337 CR13-1332 Petition for Writ Against RMC Judges, Marshals, And Clerks 74 Pages