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I accept States offer to settle all three charges as
detailed by Goodnight
From: Zach Coughlin (
Sent: Wed 8/22/12 5:58 PM
Mr. Leslie and Mr. Dogan,

One, Jim, you again slammed down the phone in a fit during the telephone conversation you reference
below, after refusing to set a meeting time. One could hardly say it is reasonable for you to then expect
a defendant to wait by their email inbox round the clock hoping you would change your mind and set
some meeting date, and for you to determine any such time you specify in an email to be set in stone
and agreed to merely by your clicking send. Further, Dogan's suggestion that I missed a hearing date
yesterday is similar to your own with respect to your statements regarding the August 6th, 2012 "combo"
hearing that you alleged you attended (though you indicated Biray Dogan was not there on August 6th,
2012 at that hearing), wherein you purport that you saved me from a trip to jail in light of some alleged
failure to appear....However, subsequently you and your office had to admit that you had failed to
provide me any notice of such an August 6th, 2012 hearing, the details thereof having fallen through the
cracks incident to Bosler covering for the suddenly vanishing Joe Goodnight at the July 16th, 2012 Trial
date in RCR2012-063341.

Leslie wrote: "so I tried to keep the conversation focused and told you I was calling to set up an
appointment to meet to continue our process of preparing for the petit larceny trial. You became
argumentative and told me to set up whatever time I want and you would be
there. Therefore, as per your request, if you wish to meet to discuss the petit
larceny trial, please be at our offices wednesday 8/22/12 at 11 a.m. . "

Really, Jim, you only prove my point with the above statement. You admit to slamming the phone
down in response to my requests that you provide a meeting time mixed with inquiries directed
towards why you refuse to advocate zealously on my behalf or otherwise conform to the Rules of
Professional Conduct and your departures therefrom that I detailed in my letter to you of yesterday,
then you try to act as if your emailing later to suggest a time somehow vitiates your express refusal
on the phone to set a meeting time. Jim, any reasonable person would not view your tact in refusing
to set a meeting time by slamming down the phone to mean one should reasonably be expected to
know of, and attend, some later emailed request on your part for a meeting at some suggested
time. Really, you do such a good job of showing in explicit detail this entitle public defender
mindstate you are trapped in, where free market forces are somethign entirely foreign to you, but
rather, you are used to having clients who are forced to employ you, and whom you treat as though
that were the case.
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Then, Dogan writes yesterday trying to copy your attempts to massage your office's failure to notice me
on any hearing alleged to have occured on 8/21/12 in any matter wherein I am a named party. I demand
a copy of the audio cd from such hearing, and anticipating your office's refusal to so provide one, a
written explanation of why you are so refusing. I have no problem signing a sworn affidavit attesting that
I did not receive any sort of letter such as the one Dogan alleges was sent on August 7th, 2012 informing
me of an August 21st, 2012 hearing. Can you provide me an affidavit from someone in your office
attesting that they sent one. Please email and fax me that letter. Regardless, I have previously placed
your office on notice that I require emails and faxes of any such correspondences from your office.
Additionaly, I will let you wonder what your various staff members have communicated to me and when
they did so with respect to what address your office has and has had on file for me for any letters such as
the one Dogan claims was sent on August 7th, 2012, or what they Court's files show with respect to the
timing of any such scheduling.

This little cover for each other game that you public defenders like to pull is getting old, as is your
tendency to hang up in a fit of pique at reasonable requests by clients. Biray, I demand you move to
vacate any trial date you have set, particularly to the extent that you failed to notice me on these recent
hearings. I get it, you like having hearings without me there, it allows you to be much less accountable,
and to get "creative" like with what occured on February 27th, 2012 at 1:00pm when Dogan retaliated
against my previous filing wherein I criticized his failure to appear at a hearing on February 13th, 2012,
whereupon Dogan promptly moved to have a second competency evaluation take place, the confidential
results of which he then read into the public record in violation of HIPAA.

Why don't you stop trying to build a phony malpractice defense trail and actually do some lawyering?

Regardless, I will let you wonder what your staff has told me with respect to letters such as the one
Dogan alleges was sent on August 7th, 2012, especially in light of the "tear off date slips" your office

Leslie wrote: "
I believe I have made reasonable efforts to obtain your cooperation in preparation
of a defense. Please advise of your availability to meet in preparation for the
8/29/12 9 am RJC trial in the petit larceny case. Please try to provide several
dates and times and I will do what I can to pick one or more that work with my
calender. Please understand, as I have noted previously, that I have other cases
and court appearances as well as yours and need advance notice in order to
schedule meetings with you. At this point, there is not much time remaining until
trial, so I ask that you reply promptly to this email."

Okay, Jim, I am available to discuss the case with you anytime tomorrow
Wednesday August 23rd, between noon and 10 pm provided you send me an
email confirming such a time prior to noon, tomorrow August 23rd. Same goes for
anytime all day Thursday or Friday, August 24th and 25th. Still waiting to get any
kind of written response from Jim, Biray, or the WCPD regarding my various
inquiries and requests for information (includign that related to the February 27th,
2012 meeting with Judge Nash Holmes and information related to the vacated
hearing of that date that took place anyways in my abscence) and audio cd's of
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specific hearings

Leslie also wrote: "Regarding today's 11 am appointment, we did have it set, as
reflected in my emails. I note also that you responded from your address, which is the same address I noticed you for
the meeting, as per your request on the phone. Notwithstanding your failure to
appear, I will inquire, again, of my investigator to see about availability over the
next couple/few days. "

That is inaccurate Jim. I asked you for a meeting time on the phone. I didn't tell
you to slam down the phone after refusing to provide a possible meeting time
then to try to sneak some request for a meeting time into a later email, only to
attempt to characterize such a request as an agreed to meeting time....

Leslie further writes: "Regarding providing documentation to you, you have been
provided the materials and moreover, I recall you showing up at our offices in an
agitated emotional state demanding additional copies, which we took the time to
make for you, and you then left without taking them."

Well, please do provide some specifics as to when I was provided such
documentaiton, date, by whom, form (did you ever comply with my request to fax
or email such, because, you know, that is the sort of thing that is real easy to
prove whether you did or not...oh wait, that's right, you and Biray prefer the buddy
approach of being each other's "witness" to things rather than being bound by
electronic data proof of transmissions and statements, huh?)....So even if your
allegation of your making "additional copies" is true, then where are those copies,
even I truly failed to take them? And if I was so agitated over getting them, why
would I leave without them? Really, you just prove what I say about, that
you play hide the ball and fickle defender, whose duty to perform his job, in his
mind, comes and goes with his own feelings of approval as to how the defendant
is complying with Leslie's definition of how he must be "treated". And in Leslie's
mind, one is not "being cooperative" if they request any sort of information that
might tend to allow for some oversight as to the level of zealousness and
competence put forth by counsel. That, according to Leslie, is "being abusive".


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Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402

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