12 11 11 Final Motion for New Trial City of Reno v Coughlin RMC 11 CR 22176 (12 11 11 Final Motion...

7/28/2019 12 11 11 Final Motion for New Trial City of Reno v Coughlin RMC 11 CR 22176 (12 11 11 Final Motion for New Tri

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Zach Coughlin

817 N. Virginia St. #2Reno, NV 89501

Tele: 775229!7"7

a$: 9%9!!77%02&ro 'er (e)en*ant+''ellant

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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


9/107

RE: your failure to propound discovery

From: Zach Coughlin([email protected])

Sent: Thu 12/08/11 5:14 PM

To: [email protected]

ows Live Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cp

12/12/2011


10/107

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


12/12/2011


11/107

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


12/12/2011


12/107

Zach Coughlin, Esq.

817 N. Virginia St. #2

Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402



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



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


City of Reno

Tel: 326-6628

Fax: 334-4226



confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not


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.


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.


12/12/2011


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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.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402


** 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.


12/12/2011


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12/12/2011


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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


17/107

Copyright 1997-2011 - Nevada Court Services - All Rights Reserved

Page 2 of 2Nevada Court Services - Attorney

12/12/2011http://www.nevcs.com/attorney.html


18/107

motion for continuance


Sent: Fri 11/11/11 1:40 AM


Zach Coughlin

121 River Rock St.

Reno, NV 89501

775 338 8118





19/107

RE: motion for continuance










pr iv i lege.


Sent: Wed 11/16/11 3:35 PMTo: [email protected]

Thank You,



20/107

Date: Mon, 14 Nov 2011 10:36:45 -0800



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



21/107


Zach Coughlin

121 River Rock St.

Reno, NV 89501

775 338 8118



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










Sent: Wed 11/16/11 5:30 PM




22/107

Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118

Licensed in Nevada












pr iv i lege.

Date: Wed, 16 Nov 2011 17:12:21 -0800



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.


From: Zach Coughlin



23/107

To:

Date: Wed, 16 Nov 2011 15:35:48 -0800


Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800




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.




24/107


From: Zach Coughlin

To:

Date: Fri, 11 Nov 2011 01:40:53 -0800


Zach Coughlin

121 River Rock St.

Reno, NV 89501

775 338 8118



are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified



25/107













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


Sent: Mon 11/21/11 1:05 PM


Sincerely,



26/107

Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118

Licensed in Nevada












pr iv i lege.

Date: Thu, 17 Nov 2011 07:40:44 -0800



CC: [email protected]


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.


From: Zach Coughlin

To: Date: Wed, 16 Nov 2011 17:30:36 -0800




27/107

Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118Licensed in Nevada













Date: Wed, 16 Nov 2011 17:12:21 -0800




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.



28/107


From: Zach Coughlin

To:

Date: Wed, 16 Nov 2011 15:35:48 -0800


Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800





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.



29/107



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



30/107

temporary address change and instruction to pursue a continuance


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

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 , work pr oduc t , or other appl icab le pr iv i lege.


Sent: Mon 11/21/11 4:06 PM

To: [email protected]; [email protected]



31/107



32/107


Zach Coughlin












pr iv i lege.


Sent: Mon 11/21/11 7:18 PM




33/107

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












pr iv i lege.

Date: Mon, 14 Nov 2011 10:36:45 -0800




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.





34/107

From: Zach Coughlin

To:

Date: Fri, 11 Nov 2011 01:40:53 -0800


Zach Coughlin

121 River Rock St.

Reno, NV 89501

775 338 8118







35/107

verint user agreement










Sent: Mon 11/21/11 8:40 PM


Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118

Licensed in Nevada










36/107

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




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


From: Zach Coughlin

To: ,

Date: Mon, 21 Nov 2011 16:06:32 -0800

Subject: temporary address change and instruction to pursue a continuance



37/107



38/107

Zach Coughlin





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.



39/107



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







40/107









pr iv i lege.

Date: Tue, 22 Nov 2011 07:59:37 -0800




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.


From: Zach Coughlin

To:

Date: Mon, 21 Nov 2011 13:05:28 -0800


Sincerely,

Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118

Licensed in Nevada




41/107












Date: Thu, 17 Nov 2011 07:40:44 -0800


To: [email protected]: [email protected]


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.


From: Zach Coughlin

To:

Date: Wed, 16 Nov 2011 17:30:36 -0800




42/107

Zach Coughlin, Esq.

121 River Rock St.

Reno, NV 89501

775 338 8118

Licensed in Nevada



are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified










Date: Wed, 16 Nov 2011 17:12:21 -0800




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.


From: Zach Coughlin

To:

Date: Wed, 16 Nov 2011 15:35:48 -0800




43/107

Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800

From: [email protected]: [email protected]



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.



From: Zach Coughlin

To:

Date: Fri, 11 Nov 2011 01:40:53 -0800



44/107


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



45/107

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.


Sent: Tue 11/29/11 3:14 PM


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.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402











46/107

your cop lying, see your video drivers license produce ap overview at

6:49 mark





pr iv i lege.



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]



47/107

Zach Coughlin, Esq.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402













pr iv i lege.



48/107

FW: your cop lying, see your video drivers license produce ap overview at

6:49 mark


Sent: Sun 12/04/11 3:45 AM




49/107

Zach Coughlin, Esq.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402













pr iv i lege.



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



50/107

your cop lying, see your video drivers license produce ap overview at

6:49 mark

Zach Coughlin, Esq.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402


** 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










pr iv i lege.



51/107


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.



52/107

Zach Coughlin, Esq.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402











53/107

discovery request;





pr iv i lege.


Sent: Wed 12/07/11 1:16 AM




54/107

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













pr iv i lege.


Sent: Thu 12/08/11 3:44 PM




55/107

Zach Coughlin, Esq.


Reno, NV 89501

tel: 775 338 8118

fax: 949 667 7402









56/107







pr iv i lege.

Date: Wed, 7 Dec 2011 07:34:25 -0800



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


City of Reno

Tel: 326-6628

Fax: 334-4226



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.


From: Zach Coughlin

To:

Date: Wed, 7 Dec 2011 01:48:03 -0800

Subject: your failure to propound discovery

Dear Mr. Hazlett-Stevens,



57/107

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

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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Transcript of 12 11 11 Final Motion for New Trial City of Reno v Coughlin RMC 11 CR 22176 (12 11 11 Final Motion...