12 11 11 final motion for new trial city of reno v coughlin rmc 11 cr 22176 (12 11 11 final motion...
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Zach Coughlin
817 N. Virginia St. #2Reno, NV 89501
Tele: 775229!7"7
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Notice o) ''eal, >otion to Vacate an* or Set otion )or
Reconotion )or Recuotion or &u?lication ) TranNT -(>NTS(a) Grounds. ne= trial @aA ?e grante* to all or anA o) the 'artie< an* on all or 'art o) the i
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R !0. R/ R> -(>NT R R(R(a) C"erica" Mista$es.Clerical @i
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(e) Sta! in avor of t/e State or Agenc! T/ereof.hen an a''eal i< taEen ?A the State or ?A anA countA, citA or to=n
=ithin the State, or an o))icer or agencA thereo) an* the o'eration or en)orce@ent o) the Du*g@ent i<
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Reno CitA ttorneA =a< gi6en one ?A @A C caC )eeling @A ?eing e6iction on or aroun* No6e@?er 1"th, then =rong)ullA
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&R SRV/C
/, Zach Coughlin, *eclare:
n (ece@?er 12, 2011, /, >r. Zach Coughlin otion to Vacate an* or Set otion )or Reconotion )or
Recuotion to Vacate an* or Set otion )or
Reconotion )or Recu
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/N(B T B3//TS:
1. B3//T 1.
7 Notice o) ''eal, >otion to Vacate an* or Set otion )or
Reconotion )or Recu
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B3//T 1: CCT/N &RT/NNT &&RS /N CT N( S&&RT T3 V >T/NS N( &(/NS
8 Notice o) ''eal, >otion to Vacate an* or Set otion )or
Reconotion )or Recu
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RE: your failure to propound discovery
From: Zach Coughlin([email protected])
Sent: Thu 12/08/11 5:14 PM
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12/12/2011
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Zach Coughlin, Esq.817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Thu, 8 Dec 2011 16:05:11 -0800
From: [email protected]
Subject: RE: your failure to propound discovery
Mr. Coughlin. I have never spoken to you and have never denied discovery to a defendant in any matter. Again
you seek to engage me in a convesation about the pending trespassing. I cannot speak with you. You are
represented by counsel.
Thank you,
Chris
Christopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226
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ATTORNEY-CLIENT PRIVILEGED
This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are
confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not the
intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that
any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or
attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in error,
please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and
then delete the message and its attachments.
-----Original Message-----
From: Zach Coughlin
To: ,
Date: Thu, 8 Dec 2011 15:44:36 -0800
Subject: RE: your failure to propound discovery
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12/12/2011
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Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat any disclosure, copying,
d is t r ibu t ion or any ac t ion taken or omi t t ed to be taken in re l iance on the contents of t h is informat ion is
prohibi t ed and may be unlawful . I f you receive this message in error , or ar e not t he named recipient (s) , please
not i fy t he sender, delet e this e-mai l f rom your comput er, and dest roy any copies in any for m immediately .
Receipt by anyone other t han the named recipient (s) is not a wai ver of any at t orney-c l ient , wor k product , or
other appl icab le pr iv i l ege.
Date: Wed, 7 Dec 2011 07:34:25 -0800
From: [email protected]
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded
with you, and your statement that you spoke with me is false. I have never spoken with you. You may have
your attorney, Roberto Puentes, contact me with any discovery issues or issues regarding the City's Motion to
Continue. Please do not correspond with me regarding this case in the future. As an attorney, you are fully
aware that I cannot communicate with a you as a represented party. Do not contact me without your
counsel.
Thank you,
ChrisChristopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226
ATTORNEY-CLIENT PRIVILEGED
This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are
confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not
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12/12/2011
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the intended recipient or a person responsible for delivering it to the intended recipient you are hereby
notified that any review, disclosure, copying, dissemination, distribution or use of any of the information
contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at
(775) 334-2050 and then delete the message and its attachments.
-----Original Message-----
From: Zach Coughlin
To:
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for
which Lew Taitel was apparently my court appointed attorney, but whom no longer is.
Further, I wish to be copied on everything past and present in any way related to this
matter until and after I procure another attorney. I did not agree to the continuance you
sought, nor was I informed you were seeking it. I find it particularly troubling that a
continuance was granted in the trespass case to the same man who is applying an
unlawful rent distraint on both my client files, personal property, AND THE
EXCLUPATING EVIDENCE I NEED TO DEFEND MYSELF IN THE PETIT
LARCENY CASE FOR WHICH I DETAIL THE COMPLAINTS I HAVE AGAINST
YOU AND YOUR OFFICE'S HANDLING BELOW. NO CONTINUANCE WAS
GRANTED OR AGREED TO AT TRIAL BY THE RMC OR MS. ROBERTS,
PERHAPS SHE WAS TOO BUSY ALLEGEDLY SUBORNING THE PERJURY OF
RSIC OFFICER KAMERON CRAWFORD.
In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted
against me there is a fax from the RSIC to you that has a fax heading for what appears to
be "page 1" followed by pages without that heading...then a heading with "page 4" etc...
I want the entire contents of anything provided by the RSIC and Walmart to you or
anyone connected with the Reno City Attorney or the Reno Municipal Court. Further, I
want all media provided by Walmart, and I question why you needed 45 minutes with
the three witness who testified at the November 30th, 2011 trial, from 1pm to 1:45pm.
Additionally, you are hereby served a NRCP 11 motion requiring you to correct the
perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.
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Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011
arrest in this matter demanding a copy of all documentation or discovery that I had any
right to. I was told I would not have any opportunity to review such materials prior to
the arraignment, which was not set for a full 30 days out from the arrest. Do I not have
a right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of
the arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written
demands and requests for such discovery and documentation were met with refusals to
provide such materials, and, in some case, claims that your office did not even have such
materials and would not get them until after the arraignment. Further, I spoke with and
provided written requests to RSIC Sargent Avansino within 2 days after the arrest and he
refused to provide the materials, as did the Reno Municipal Court. Please alert the court
to any wrongdoing on your's or the Reno City Attorney or the RSIC part in this regard in
prejudicing my ability to defend my case by delaying the production of essential
discovery, then refusing to agree to a continuance at trial, after earlier providing a
written agreement to such a continuance.
Sincerely,
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act,
18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you
are not the intended recipient or an ag ent responsible for delivering it to the intended recipient, y ou are hereby notified
that you have received this document in error and that any review, dissemination, copying, or the taking of any action
based on the contents of this information is strictly prohibited. This message is conf i dent ia l , i ntended only f or t he
named recip ient (s) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f rom
disclosure under appl i cable law. I f you are not t he intended recipient (s), you are not i f i ed that any disclosure,
copy ing, d ist r ibu t ion or any ac t ion taken or omi t ted t o be taken in re l iance on the contents of t h is informat ion
is prohibi t ed and may be unlawful . I f you receive this message in error , or a re not t he named recipient (s) ,
please not i fy t he sender, delet e this e-mai l f rom your computer, and destr oy any copies in any f orm
immediat ely. Receipt b y anyone other t han the named recipi ent (s) is not a waiver of any at t orney-c l ient , wor k
product , or ot her appl icab le pr iv i lege.
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Nevada Court Services475 So. Arlington Suite 1A
Reno, Nevada 89501(775) 348-7560
(Toll Free) 800-570-5583Fax: (775) 348-7977
Email: [email protected]
The following Attorney is associated with and highly recommended by Nevada Court Services
"Serving the People of Nevada"
Lewis S. Taitel
At torney at Law475 S. Arlington Suite 1A
Reno, Nevada 89501
(775) 322-2272Fax: (775) 348-7977
Nevada State Bar No. 4397Disclaimer: "The State Bar of Nevada does not certify any lawyer as a specialist or expert.."
Criminal Law - DUI Defense - Personal InjuryProperty Law - Collections - Divorce - Civil Law
Adoption - Family Law
Nevada Attorney Directory
Page 1 of 2Nevada Court Services - Attorney
12/12/2011http://www.nevcs.com/attorney.html
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Copyright 1997-2011 - Nevada Court Services - All Rights Reserved
Page 2 of 2Nevada Court Services - Attorney
12/12/2011http://www.nevcs.com/attorney.html
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motion for continuance
From: Zach Coughlin([email protected])
Sent: Fri 11/11/11 1:40 AM
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
ows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cp
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RE: motion for continuance
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Wed 11/16/11 3:35 PMTo: [email protected]
Thank You,
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Date: Mon, 14 Nov 2011 10:36:45 -0800
From: [email protected]
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court'sdecision to grant your motion to continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.
I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.
-----Original Message-----From: Zach Coughlin
To:
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
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RE: motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified thatyou have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat any disclosure, copying,
d is t r ibu t ion or any ac t ion taken or omi t t ed to be taken in re l iance on the contents of t h is informat ion is
prohibi t ed and may be unlawful . I f you receive this message in error , or ar e not t he named recipient (s) , please
not i fy t he sender, delet e this e-mai l f rom your comput er, and dest roy any copies in any for m immediately .
Receipt by anyone other t han the named recipient (s) is not a wai ver of any at t orney-c l ient , wor k product , or
other appl icab le pr iv i l ege.
From: Zach Coughlin([email protected])
Sent: Wed 11/16/11 5:30 PM
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Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Wed, 16 Nov 2011 17:12:21 -0800
From: [email protected]
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling any
additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send you
an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
-----Original Message-----
From: Zach Coughlin
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To:
Date: Wed, 16 Nov 2011 15:35:48 -0800
Subject: RE: motion for continuance
Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: [email protected]
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon at
1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we
are unable to resolve the case, you can ask the Court again for a continuance and I won't object. However, itis the Court's decision to grant your motion to continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.
I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.
ows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cp
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-----Original Message-----
From: Zach Coughlin
To:
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act,
18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you
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RE: motion for continuance
RE: motion for continuance
that you have received this document in error and that any review, dissemination, copying, or the taking of any action
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product , or ot her appl icab le pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Thu 11/17/11 3:37 PM
Dear Ms. Roberts,
I do not mean to suggest you do not know what your duty it. Believe me, I am well aware that you could mop
up the court room with a neophyte attorney such as myself. I was merely hoping to get some direction from you
regarding trial practice approaches in general.
Sincerely,
Zach
From: Zach Coughlin([email protected])
Sent: Mon 11/21/11 1:05 PM
Sincerely,
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Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Thu, 17 Nov 2011 07:40:44 -0800
From: [email protected]
Subject: RE: motion for continuance
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer. Penie
Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty is and I
will not debate it via email. Pam Roberts, Deputy City Attorney.
-----Original Message-----
From: Zach Coughlin
To: Date: Wed, 16 Nov 2011 17:30:36 -0800
Subject: RE: motion for continuance
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Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat any disclosure, copying,
d is t r ibu t ion or any ac t ion taken or omi t t ed to be taken in re l iance on the contents of t h is informat ion is
prohibi t ed and may be unlawful . I f you receive this message in error , or ar e not t he named recipient (s) , please
not i fy t he sender, delet e this e-mai l f rom your comput er, and dest roy any copies in any for m immediately .
Receipt by anyone other t han the named recipient (s) is not a wai ver of any at t orney-c l ient , wor k product , or
other appl icab le pr iv i l ege.
Date: Wed, 16 Nov 2011 17:12:21 -0800
From: [email protected]
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling
any additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send
you an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
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-----Original Message-----
From: Zach Coughlin
To:
Date: Wed, 16 Nov 2011 15:35:48 -0800
Subject: RE: motion for continuance
Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: [email protected]
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon
at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and
if we are unable to resolve the case, you can ask the Court again for a continuance and I won't object.
However, it is the Court's decision to grant your motion to continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.
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I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.
-----Original Message-----
From: Zach Coughlin
To:
Date: Fri, 11 Nov 2011 01:40:53 -0800Subject: motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
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temporary address change and instruction to pursue a continuance
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18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby
notified that you have received this document in error and that any review, dissemination, copying, or the taking of
any action based on the contents of this information is strictly prohibited. This message is conf i dent ia l , int ended
only for the named rec ip ient (s ) and may conta i n in format ion that is pr iv i leged, at tor ney wor k product or
exempt f rom disclosure under appl i cable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat
any disclosure, copying, dist r i but i on or any act ion ta ken or omit t ed to be taken in rel iance on t he contents
of t his infor mat i on is prohibi t ed and may be unlawf ul . I f you receive this message in error , or ar e not t he
named recipi ent (s) , please not i fy t he sender, delet e this e-mai l f rom your computer, and destr oy any copies
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at t orney-c l ient , work pr oduc t , or other appl icab le pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Mon 11/21/11 4:06 PM
To: [email protected]; [email protected]
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RE: motion for continuance
Zach Coughlin
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Mon 11/21/11 7:18 PM
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Ms. Roberts, the opposing attorney's unlawful rent distraint is preventing me from providing all the discovery I
would like to provide you with or ascertain the need to do, and further is preventing me from having access to
the materials and information I need to litigate this case.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: [email protected]
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
decision to grant your motion to continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.
I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.
-----Original Message-----
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From: Zach Coughlin
To:
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review, dissemination, copying, or the taking of any action based
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verint user agreement
on the contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat any disclosure, copying,
d is t r ibu t ion or any ac t ion taken or omi t t ed to be taken in re l iance on the contents of t h is informat ion is
prohibi t ed and may be unlawful . I f you receive this message in error , or ar e not t he named recipient (s) , please
not i fy t he sender, delet e this e-mai l f rom your comput er, and dest roy any copies in any for m immediately .
Receipt by anyone other t han the named recipient (s) is not a wai ver of any at t orney-c l ient , wor k product , or
other appl icab le pr iv i l ege.
From: Zach Coughlin([email protected])
Sent: Mon 11/21/11 8:40 PM
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
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Re: temporary address change and instruction to pursue a continuance
dis t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: Ken Howard([email protected])
Sent: Tue 11/22/11 7:01 AM
To: Zach Coughlin ([email protected]); [email protected]
Mr. Zach Coughlin
There is an appropriate manner in which to tender "motions" to the court. They are to be properly
prepared and filed. Do not use this e-mail address to communicate directly with the judge.
Ken Howard
Reno Municipal Court Judge
Department 4
(775) 326-6673
-----Original Message-----
From: Zach Coughlin
To: ,
Date: Mon, 21 Nov 2011 16:06:32 -0800
Subject: temporary address change and instruction to pursue a continuance
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Zach Coughlin
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U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
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you have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s)
and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are
not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the
named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately.
Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
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RE: motion for continuance
From: Zach Coughlin([email protected])
Sent: Tue 11/29/11 1:33 PMTo: [email protected]
Dear Ms. Roberts,
The opposing attorney in the Summary Eviction Proceeding against me in my home law office/business is
asserting a lien against my office, law practice files, and materials necessary to discovery production and
defending the case that you are the prosecutor on. I believe a continuance is absolutely necessary in the
interests of justice. Additionaly, you have been informed that Walmart previous to the arrest in this matter
became upset at the accused and made threats of malicious prosecution and abuse of process incident to the
accused questioning various Wal-mart personnel and managers about Wal-Marts curious practice of remixing
and forgetting the Return Policy stated in writing at Walmart.com (and expressly made applicable to purchases
made in Wal-Mart stores). A manager named "Ellis", though who may have identified himself as "John" and a
Loss prevention associate at the West 7th Street Wal-Mart in Reno allegedly told the accused that they would
have him banned from all Wal-Marts in retaliation for the accused seeking to do something to which he was
legally entitled to do, return and item at a Wal-Mart stores in accordance with Wal-Mart's stated and written
Return Policy. There are other retaliatory aspects to the conducts and statements made by both Wal-Mart and
RSIC personnel in this case.
Additionally, the video "evidence" that you provided is shameful. It consists of two short clips in some Wal-Mart
back room where 5-6 people, including 2 RSIC officers acting under color of state law on land their employer
owns and leases to Wal-Mart attempt to coerce not only a confession, but a consent to search. There is no audio
of the video, at least not the video you provided, that is. Where is the video of the alleged acts? How you can
maintain a case such as this stemming from the accused acts in a store like Wal-Mart, that has hundreds of
cameras and only provide video from some backroom that proves nothing and, in the words of "Jeannie" the
contact person at your office "doesn't show anything", I am not sure, and whether that is violative of your duties
as a prosecutor, Nifong, NRCP 11 (see Schumacher's application of that civil rule to the DA) is not clear. You
have been informed that the RSIC officer committed police misconduct and yet you brazenly announce in writing
that you do not intend to follow up on that, nor do you feel compelled to.
Zach Coughlin, Esq.
817 N. Virginia St. #2Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
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have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Tue, 22 Nov 2011 07:59:37 -0800
From: [email protected]
Subject: RE: motion for continuance
Dear Mr. Coughlin, you will need to file a motion to continue in compliance with Reno Municipal Court
procedures. As I have stated in a previous email, I do not object to your motion to continue, however, it is up
to the Judge whether or not he will grant your motion. Regarding the video which I obtained at your previous
court date, I have told you that you can come to our office and view the video. If you still want a copy, I
believe our staff will be able to make one for you. NRS 174.235 does not require me to do more than what I
have already done. We have provided you with the reports we have, listed the witnesses we will call and made
the video available to you. Pam Roberts, Deputy City Attorney.
-----Original Message-----
From: Zach Coughlin
To:
Date: Mon, 21 Nov 2011 13:05:28 -0800
Subject: RE: motion for continuance
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
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U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are
not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review, dissemination, copying, or the taking of any action based
on the contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied t hat any disclosure, copying,
d is t r ibu t ion or any ac t ion taken or omi t t ed to be taken in re l iance on the contents of t h is informat ion is
prohibi t ed and may be unlawful . I f you receive this message in error , or ar e not t he named recipient (s) , please
not i fy t he sender, delet e this e-mai l f rom your comput er, and dest roy any copies in any for m immediately .
Receipt by anyone other t han the named recipient (s) is not a wai ver of any at t orney-c l ient , wor k product , or
other appl icab le pr iv i l ege.
Date: Thu, 17 Nov 2011 07:40:44 -0800
From: [email protected]
To: [email protected]: [email protected]
Subject: RE: motion for continuance
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer.
Penie Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty
is and I will not debate it via email. Pam Roberts, Deputy City Attorney.
-----Original Message-----
From: Zach Coughlin
To:
Date: Wed, 16 Nov 2011 17:30:36 -0800
Subject: RE: motion for continuance
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Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act,
18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you
are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified
that you have received this document in error and that any review, dissemination, copying, or the taking of any action
based on the contents of this information is strictly prohibited. This message is conf i dent ia l , i ntended only f or t he
named recip ient (s) and may conta in in for mat ion t hat i s pr iv i leged, at torney work product or exempt f rom
disclosure under appl i cable law. I f you are not t he intended recipient (s), you are not i f i ed that any disclosure,
copy ing, d ist r ibu t ion or any ac t ion taken or omi t ted t o be taken in re l iance on the contents of t h is informat ion
is prohibi t ed and may be unlawful . I f you receive this message in error , or a re not t he named recipient (s) ,
please not i fy t he sender, delet e this e-mai l f rom your computer, and destr oy any copies in any f orm
immediat ely. Receipt b y anyone other t han the named recipi ent (s) is not a waiver of any at t orney-c l ient , wor k
product , or ot her appl icab le pr iv i lege.
Date: Wed, 16 Nov 2011 17:12:21 -0800
From: [email protected]
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request
for reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled
to copies of all the reports and witness statements and video we may have on this case. Since I am not
calling any additional witnesses that are not already mentioned in the reports/statements, I am not
obligated to send you an additional list of witnesses. I am also not obligated to do any further investigation
or interviews. Pam Roberts.
-----Original Message-----
From: Zach Coughlin
To:
Date: Wed, 16 Nov 2011 15:35:48 -0800
Subject: RE: motion for continuance
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Thank You,
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: [email protected]: [email protected]
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received
confirmation from the Court that your trial date has been continued, you will need to appear this
afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at
that time and if we are unable to resolve the case, you can ask the Court again for a continuance and I
won't object. However, it is the Court's decision to grant your motion to continue.
It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time,
so the Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in
a misdemeanor case.
I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.
-----Original Message-----
From: Zach Coughlin
To:
Date: Fri, 11 Nov 2011 01:40:53 -0800
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Subject: motion for continuance
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s)
only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are
hereby notified that you have received this document in error and that any review, dissemination, copying, or the
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FW: temporary address change and instruction to pursue a continuance
taking of any action based on the contents of this information is strictly prohibited. Thi s message is confi dent ial ,
in tended only for the named rec ip ient (s) and may conta in i n format ion t hat i s pr iv i leged, at t orney work
product or exempt f r om disclosure under appl icable law. I f you are not t he intended recipi ent (s) , you are
not i f i ed that any disclosure, copying, dist r ibut ion or any act ion taken or omit t ed to be t aken in rel iance on
t he contents of t his informat ion is prohibi t ed and may be unlawf ul . I f you receive this message in err or , or
are not t he named recipient (s) , please not i f y t he sender, delet e this e-mai l f rom your computer, a nd
destr oy any copies in any for m immediat ely. Receipt by anyone other t han the named recipi ent (s) is not a
waiver of any at t orney-c l ient , work product , or other appl icab le pr iv i l ege.
From: Zach Coughlin([email protected])
Sent: Tue 11/29/11 3:14 PM
To: [email protected]; [email protected]
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may
be punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights undercolor of state law and all those other things your office and Hartshorn, et all have been sued for over the years.
Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
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your cop lying, see your video drivers license produce ap overview at
6:49 mark
dis t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: [email protected]
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
Zach Coughlin,
From: Zach Coughlin([email protected])Sent: Sun 12/04/11 3:37 AM
To: [email protected]; [email protected]; [email protected]
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Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
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FW: your cop lying, see your video drivers license produce ap overview at
6:49 mark
From: Zach Coughlin([email protected])
Sent: Sun 12/04/11 3:45 AM
To: [email protected]; [email protected]; [email protected]
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Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: [email protected]
To: [email protected]; [email protected]; [email protected]
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
Date: Sun, 4 Dec 2011 03:37:24 -0800
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your cop lying, see your video drivers license produce ap overview at
6:49 mark
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
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From: Zach Coughlin([email protected])
Sent: Sun 12/04/11 4:05 AM
To: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
[email protected], [email protected]; [email protected]; [email protected]; [email protected]
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS AFAR MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT
THAT WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS
"PARTICIPATION", AND ITS ALL ON TAPE.
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Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
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discovery request;
dis t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Wed 12/07/11 1:16 AM
To: [email protected]; [email protected]
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RE: your failure to propound discovery
Zach Coughlin, Esq.817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
From: Zach Coughlin([email protected])
Sent: Thu 12/08/11 3:44 PM
To: [email protected]; [email protected]
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Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice**This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is conf ident ial , int ended only f or t he named
ows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cp
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rec ip ient (s ) and may conta in in format ion t hat i s pr iv i leged, at tor ney w ork pr oduc t or exempt f r om disc losure
under appl icable law. I f you are not t he intended recipi ent (s), you are not i f ied that any disclosure, copying,
d is t r ibu t i on or any ac t ion t aken or omi t t ed to be t aken in re l iance on the contents of t h is in format ion is proh ib i ted
and may be unlawf ul . I f you receive this message in err or , or a re not t he named recipient (s) , please not i f y t he
sender, delet e this e-mai l f rom your computer, and dest roy any copies in any form immediat ely. Receipt by anyone
other t han the named recip ient (s) is not a waiver of any at tor ney-cl ien t , work pr oduc t , or other appl icab le
pr iv i lege.
Date: Wed, 7 Dec 2011 07:34:25 -0800
From: [email protected]
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded
with you, and your statement that you spoke with me is false. I have never spoken with you. You may have
your attorney, Roberto Puentes, contact me with any discovery issues or issues regarding the City's Motion to
Continue. Please do not correspond with me regarding this case in the future. As an attorney, you are fully
aware that I cannot communicate with a you as a represented party. Do not contact me without your counsel.
Thank you,
Chris
Christopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226
ATTORNEY-CLIENT PRIVILEGED
This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are
confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not the
intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that
any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or
attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in error,
please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and
then delete the message and its attachments.
-----Original Message-----
From: Zach Coughlin
To:
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery
Dear Mr. Hazlett-Stevens,
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I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for which
Lew Taitel was apparently my court appointed attorney, but whom no longer is. Further, I
wish to be copied on everything past and present in any way related to this matter until
and after I procure another attorney. I did not agree to the continuance you sought, nor
was I informed you were seeking it. I find it particularly troubling that a continuance was
granted in the trespass case to the same man who is applying an unlawful rent distraint on
both my client files, personal property, AND THE EXCLUPATING EVIDENCE I NEED
TO DEFEND MYSELF IN THE PETIT LARCENY CASE FOR WHICH I DETAIL THE
COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S HANDLING
BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL BY
THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY
SUBORNING THE PERJURY OF RSIC OFFICER KAMERON CRAWFORD.
In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted
against me there is a fax from the RSIC to you that has a fax heading for what appears to
be "page 1" followed by pages without that heading...then a heading with "page 4" etc... I
want the entire contents of anything provided by the RSIC and Walmart to you or anyone
connected with the Reno City Attorney or the Reno Municipal Court. Further, I want all
media provided by Walmart, and I question why you needed 45 minutes with the three
witness who testified at the November 30th, 2011 trial, from 1pm to 1:45pm.
Additionally, you are hereby served a NRCP 11 motion requiring you to correct the
perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.
Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest
in this matter demanding a copy of all documentation or discovery that I had any right to.
I was told I would not have any opportunity to review such materials prior to the
arraignment, which was not set for a full 30 days out from the arrest. Do I not have a
right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of the
arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written demands
and requests for such discovery and documentation were met with refusals to provide such
materials, and, in some case, claims that your office did not even have such materials and
would not get them until