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9 30 13 nvd 539 attachment motion for tro stamped 204 pages.pdf

9 30 13 nvd 539 attachment motion for tro stamped 204 pages.pdf

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Published by: NevadaGadfly on Nov 01, 2013
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05/16/2014

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 NOTICE IN THE UNITED STATES DISTRICT COURTDISTRICT OF NEVADAZACHARY BARKER COUGHLINPETITIONER CASE NOVS.RENO JUSTICE COURT(JUDGESDAVID CLIFTON, PETER SFERRAZZASCOTT PEARSON), RENO MUNICIPALCOURT(JUDGES WILLIAML. GARDNER, KENNETH RAY HOWARDDOROTHY NASH HOLMES, JAY DILWORTH;SECOND JUDICIALDISTRICT COURT; STATE BAR OF NEVADA; RENO CITYATTORNEY’S OFFICE; WASHOE COUNTYDISTRICT ATTORNEY’SOFFICE; NORTHERN NEVADA DISCIPLINARY BOARD ________________________________________/MOTION FOR TRO OR INJUNCTION WHERE YOUNG ABSTENTION UNCALLED FOR IN LIGHT OF ENORMITY OF CONFLICTS OF INTEREST, IMPROPRIETY, MISCONDUCT, AND CONSTITUTIONAL ISSUES INVOLVEDCoughlinapologizes for this not being in better form but he is overwhelmed, and seeks an op- portunityto amend this proposed filing and to obtain counsel, hopefully at public expense or some sort of assistance. The court also may not promulgate rules in order to diminish constitutional rights, defeatthe right of litigants to access to the court,Knox v. Eighth Judicial Dist Court of State, In and For County of Clark, 108 Nev. 354, 830 P.2d 1342 (1992). “http://www.leagle.com/decision/19922172830P2d1342_12164It is unimaginable for the district court to refuse to order released the sealed portions of Coughlin’s own criminal trials in rcr2011-
Case 3:13-cv-00446-RCJ-WGC Document 9-1 Filed 09/30/13 Page 1 of 204
Case 3:13-cv-00539 Document 1-1 Filed 09/30/13 Page 1 of 204
 
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 NOTICE 063341, rcr2012-065630, etc., etc., especially where such is absolutely relevant,material and necessary to his Marsden and Stankewitz claims, amongst other appealable issues. Additionally, the RJC needs to face the music and release the three different hearing portions of 2/5/13 that in 065630 and 063341 that it is steadfastly refusing to release, same with the 12/18/12 hearing in rcr2012-067980 involving wcpd jim leslie. Its not a brady analysis, its what occurred in open court. Sunshine. Transparency. Access.Couglin declares everything he asserts herein is true and correct made under penalty of perjury with the the caveat that some of the dollar figures and dates as to his finances during oct 2011 through april 2012 are from memory and likely not exact and that such assertions are based upon his own  personal knowledge except those matters stated upon information and belief and as to those matters Coughlin believes them to be true: This filing should also be consider a Petittion for Extraordinarywrit (such as Mandamus, Prohibition, Certiorari, etc., etc. or evne Habeas Corpus) or a supplement to those file previously in these case. Actually, the 3/26/12 Motion for New Trial, or, in the alterantive, Motion to Alter or Amend Judge Elliott’s 3/15/12 Order Affirming Ruling of the RMC has never been adjudicated by the 2JDC, as such, the entire appeal in 60630 was arguably premature, and any orders therefrom, necessarily, void (as to cr11-2064). Coughlin asks for appointment of counsel at public expense and the transcript of the 2/27/12 and 3/12/12 trial dates in 11 tr 26800 to be prepared at  public expense (much more important that the 2/12/12 and 2/13/12 dates ordered prepared in cr12-0376 (the SBN is attempting to disbar Coughlin largely based uponthe horrid jurisprudence dished out in 11 tr 26800…which Coughlin appealed, and which he had a right to appeal (at least in his status as a party, as pengilly seems to make clear an attorney must file a writ to challenge either contempt or sanctiosn orders…). Coughlin would also like the entire record (certified docket, etc)
Case 3:13-cv-00446-RCJ-WGC Document 9-1 Filed 09/30/13 Page 2 of 204
Case 3:13-cv-00539 Document 1-1 Filed 09/30/13 Page 2 of 204
 
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 NOTICE from 11 tr 26800 ordered transmitted to the 2JDC. That case has caused everybody else plenty of headaches and problems, and the RMC and Judge Nash Holmes ought be made share the burden…As to all the Administrative Orders and pre-trial orders that alter all the deadlines applicable to every other defendant (equal protection violation): Lower courts may also have rulemaking authority[FN5]
but may not encroach upon the authority granted to the state's highest court 
.[FN6] Thus, the state's highest court's exclusive constitutional authority to enact rules that govern  procedural matters in all state courts cannot be supplemented, annulled, or superseded by an inferior court. [FN5] In re Nuotila's Estate, 360 Mich. 256, 103 N.W.2D 638, 82 A.L.R.2D 923 (1960). [FN6] United Services Auto. Ass'n v. Goodman, 826 So. 2D 914 (Fla. 2002).Coughlin has a substantive right to defend himself against all these convenient 1983 collateral  bar desiringprosecutions. Its ridiculous to be attempting to characterize Coughlin as a “vexatious litigant”…vexatious litigants sue people for money (fine there is some habeas reform, etc., etc., but the Rule 2.15 letters to the SBN (Judge Nash Holmes) and her 3/12/12 Order purporting Coughlin to have violated RPC 3.1 “meritorious claims” for asserting basic witness bias arguments and or cross-examination (and the same question can be asked for many, many different purposes, so Coughlin repeating one, despite Howardand Nash’s views, does not mean he is disobeying their directives), not defend themselves against ridiculous prosecutions and brain dead arrests:The court also may not promulgate rules in order to diminish constitutional rights,[FN10] de-feat the right of litigants to access to the court,[FN11] or hinder parties from exercising their rights in court.[FN12]A trial court is without authority to adopt local rules or procedures that conflict with statutes or with rules of court adopted by the Judicial Council, or that are inconsistent with the Con-stitution or case law. Elkins v. Superior Court, 41 Cal. 4th 1337, 63 Cal. Rptr. 3d 483, 163.[FN9] Sackett v. Santilli, 146 Wash. 2D 498, 47 P.3D 948 (2002). [FN10] City of Auburn v. Brooke, 119 Wash. 2D 623, 836 P.2D 212 (1992). [FN11]
 Knox v. Eighth Judicial Dist Court of State, In and For County of Clark, 108 Nev. 354, 830 P.2D 1342 (1992).
[FN12] Hochberg v. Davis, 171 A.D.2D 192, 575 N.Y.S.2D 311 (1st Dep't 1991).http://www.leagle.com/decision/1992742119Wn2d623_1701http://www.leagle.com/decision/1991363171AD2d192_1326
Case 3:13-cv-00446-RCJ-WGC Document 9-1 Filed 09/30/13 Page 3 of 204
Case 3:13-cv-00539 Document 1-1 Filed 09/30/13 Page 3 of 204

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