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(No Subject)

From: Zach Coughlin (zachcoughlin@hotmail.com)

Sent: Tue 11/06/12 7:44 PM

To: laurap@nvbar.org (laurap@nvbar.org); patrickk@nvbar.org

(patrickk@nvbar.org)

Dear Bar Counsel King and Clerk of Court/Investigator Peters and ChairmanEcheverria,

There is a big problem with respect to when the State Bar of Nevada actuallysent the Respondent, Coughlin the Designation of Witnesses and Summary of 

Evidence (DoWSoE) (and Coughlin has yet to received a file stamped versionof that DowSoE. Further, Coughlin has never received any Notice of Intentto Take Default (NoITD) from the SBN. As such, the notice and other 

 procedural safeguards attendant to the Hearing set for 11/14/12 are severely

deficient. This is just the 13th chime of the clock, and I have had as many "getright with Jesus" (or any other number of nondenominational Saviors) talks

with Bar Counsel King and Clerk Peters as anyone deserves. Add to that thisnew thing where first Bar Counsel says, as required by SCR 105(2)(c)'s:

 "The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the

names of the witnesses bar counsel intends to call for other than impeachment, together with a brief statement of the

facts to which each will testify, all of which may be inspected up to 3 days prior to the hearing. "

See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out

from under Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to allow inspection

of others (even where the SCR 105 Complaint specifically invokes s uch non copied materials), and then cut short the time

up to which Respondnet may inspect. Let's say Bar Counsel did copy and provide thos e materials on October 31st, 2012.

 Okay, well SCR 105 allows Coughlin to go to the SBN and inspect "up to 3 days prior"...so Coughlin may go to the SBNtomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is a violation of SCR 105, right? Please advise

in writing.

Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel

and the Panel's failure to follow these rules "may result in contempt of the appropriate

disciplinary board or hearing panel having jurisdiction..." Please note there has already been a

Motion for Order to Show Cause filed against Bar Counsel and or the Board or Panel in 60838 and

61426. Additionally, please be aware that SCR 119(3) holds: 3. Other rules of 

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procedure. Except as otherwise provided in these rules, the Nevada Rules of Civil Procedure

and the Nevada Rules of Appellate Procedure apply in disciplinary cases.

In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for

procedural safeguards in that it was issued prior to the expiration of five judicials days from the

constructive service upon Coughlin, under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged

mailing. The term "alleged" is used do to a recent visit to the SBN on October 31st, 2012 at around

4:45 pm when I saw in the SBN outgoing mail box two certified letter to myself that Clerk of Court

Peters admitted would not be picked up that day by the regular postal carrier to the SBN, despite

what they certificates of mailing therein might state. It is particularly troubling to me that the

Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence included

with it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it

from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up

with less than the required notice (and jam the Panel up to for the matter, though there has been

little indication so far that the Panel cares or has much an intent to do anything more than let Bar

Counsel King lead them down the same primrose path that Clerk Peters can tell you about...). It is

a path that Richard G. Hill, Esq. often takes people down too...

I would be very interest to know who was on the screening Panel...which Bar Counsel King

promised to tell me, though, like most all of Pat's promises, he has broken...could it have been

David Hamilton, Esq.? Richard G. Hill's best friend, David Hamilton? Was it WCDA Mary

Kandaras? The one included in the correspondences about my smartphone and micro sd data card

being searched and or seized illegally and or outside any lawful search incident to arrest given the

hand of an booking it into Coughlin's property on 2/27/12, only for the RMC Marshals to return on

2/28/12 (at the soonest) to take it back to Judge Nash Holmes? What's next, Judges showing up

in our bedrooms reading our diaries out of the blue?

It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas

and granted me indigent status as to witness fees...if this is not within the power of Bar Counsel or

is otherwise against the Orders of the Panel or Board, please let me know very soon. Please See

SCR 110 and in that regard, I am requesting a prehearing conference for the purpose of gathering

admissions from Bar Counsel and narrowing the issues, and in that regard, I recently sent Bar

Counsel and at least Panel Chair Echeverria materials related to what I see as a frivilous issue, the

ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John Gessin.

 

Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have

voiced to President of the State Bar of Nevada Flaherty, in that light:

Rule 120.  Costs; bar counsel conflict or disqualification

2. If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of 

governors shall appoint an attorney, ad hoc, to act in the place of bar counsel.

Zach Coughlin

1471 E. 9th St.

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Reno, NV 89512

Tel and Fax: 949 667 7402

ZachCoughlin@hotmail.com

Zach has 5 files to share with you on SkyDrive. To view them, click the links below.

11 6 12 0202 Objection and Notice.pdf 

supplemental to Coughlin's designation fo witnesses and summary and production of evidence and

notice of objection 0204 CORRECTED CAPTION.pdf 

0204 notice of non service of purported notice of intent to take default.pdf 

0204 SUBPOENA WITH DISCLAIMER.pdf 

0204 subpoena all.pdf 

Download all