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Panel Chair John Echeverria, Esq.

's FINDINGS OF FACT AND CONCLUSIONS OF LAW of


12/14/12 in SBN v. Zachary Barker Coughlin, NG12-0204, NG12-0434, and NG12-0435 reads:
"THIS MATTER came before a designated Formal Hearing Panel of the Northern Nevada
Disciplinary Board (the "Panel") for hearing on Wednesday, November 14, 2012. The Panel consisted
of John P. Echeverria, Esq., Chairman; Lay-Member Karen Pearl, Stephen Kent, Esq., Clark V. Vellis,
Esq., and Michael K. Johnson, Esq .. The State Bar of Nevada (the "State Bar") appeared and was
represented by Deputy Bar Counsel, Patrick O. King, Esq.. The Respondent, Zachary Barker Coughlin,
Nevada State Bar No. 9473 (the "Respondent" or "Coughlin") appeared in propria persona.
FINDINGS OF FACT
Based upon the pleadings filed, the documentary evidence admitted as Hearing Exhibits 1
through 16, and the testimonial evidence of the Honorable Judge Bruce Beesley, Richard Hill, Esq.,
Paul EIcano, Esq., the Honorable Judge Dorothy Nash Holmes, Zachary B. Coughlin, Esq. and Mary
Barker presented at the hearing of these proceedings, the Panel makes findings of facts as
follows:
1. Coughlin is an attorney licensed to practice law in the State of Nevada. At all relevant
times prior to and at the time of the filing of the Complaint in this matter, the Respondent's principle
office, as filed with the State Bar of Nevada in accordance with the Rule of Professional Conduct
("RPC") 79(1)(a), was Post Office Box 3961, Reno, NV 89505. See Hearing Exhibit 1 at 0001, lines 7-
10 (State Bar of Nevada vs. Zachary B. Coughlin, Esq., Case No: NG12-0204, NG12-0435, NG12-
0434, Complaint at P1 (filed August 23, 2012
2. Coughlin was admitted as a member of the State Bar of Nevada on March 25, 2005. See
Hearing Exhibit 1 at 0001, lines 7-8 (State Bar of Nevada vs. Zachary B. Coughlin, Esq., Case No:
NG12-0204, NG12-0435, NG12-0434, Complaint at P1 (filed August 23, 2012).
3. On September 9, 2011, Coughlin shoplifted a candy bar and cough drops from a Wal-
Mart store with an approximate value of fourteen dollars ($14.00). On November 30, 2011, Municipal
Court Judge Kenneth R. Howard found Coughlin guilty of the offense of Petit Larceny, a violation of
RMC 8.10.040. Coughlin appealed the judgment of conviction. On March 15, 2012, the Honorable
District Court Judge Steven P. Elliot affirmed the judgment of conviction on appeal. See Hearing
Exhibit 1 at 0002, 5, lines 11-15; (State Bar of Nevada vs. Zachary B. Coughlin, Esq., Case No:
NG12-0204, NG12-0435, NG12-0434, Complaint at P2 (filed August 23, 2012).
4. Coughlin's conduct during the trial of the petit larceny case on November 30, 2011, in
which Coughlin appeared in propria persona, was so disruptive that Judge Howard found Coughlin in
direct contempt of court and sentenced him to jail that same day to be released on December 3, 2011 at
8:00 PM. Judge Howard specifically found Coughlin's conduct to be disorderly and was either
contemptuous or behavior insolent toward the judge in that Coughlin refused:
"... to obey directives of the Judge, continuing lines of inquiry after being advised by the
Court to refrain from doing so; demeaning the Court with statements such as "WOW" in
response to court rulings; laughing during testimony and further questioning the court
and its authority."
See Hearing Exhibit 11 ORDER FOR SUMMARY PUNISHMENT OF CONTEMPT COMMITTED
IN THE IMMEDIATE VIEW AND PRESENCE OF THE COURT, November 30, 2011.
5. On June 7, 2012 the Suprem Court of the State of Nevada upon petition of Bar Counse
pursuant to SCR 111, ordered Coughlin temporarily suspended from the practice of law in Nevada.
The Order futher directed that the matter be referrred to the Appropriate disciplinary board, as
mandated by SCR 111 (8), with directions for the board to institute a formal hearing "before a hearing
panel in which the sole issue to be determined shall be the extent of the discipline to be imposed." In
the Matter of Discipline of ZACHARY B. COUGHLIN, Esq., Bar No. 9473, No. 60838, June 7, 2012.






6. On November 15, 2011 Coughlin was arrested and charged with three violations of the
Reno Municipal Code. The charges of Failure to Provide Evidence of Security or Insurance (a violation
of RMC 6.06.555(a)) and Failure to Provide Vehicle Registration (a violation of RMC 6.06.560(a))
were dismissed at arraignment. On February 27, 2012 a trial was held in Reno Municipal Court before
the Honorable Judge Dorothy Nash Holmes on the remaining charge of a Right of Way Stop Sign
violation at an intersection (a violation of RMC 6.06.170(a)). Coughlin again appeared in propria
persona. The trial commenced at 3 p.m. and was concluded by the Court at 4:30 p.m., without a verdict,
after the court held Coughlin in criminal contempt of court for his behavior and activities committed
during the course of the trial and in the presence of the Court. See Hearing Exhibit 4. ORDER
FINDING THE DEFENDANT IN CONTEMPT OF COURT AND IMPOSING SANCTIONS.
7. Judge Nash Holmes ordered Coughlin into custody on February 27, 2012 and to be
incarcerated at the Washoe County Regional Detention Facility for the term of five (5) days.
Alternatively Coughlin could pay a fine of $500. The Court's sentence was based on its detailed
findings regarding Coughlin's conduct in his own defense.
"The court finds that defendant's contemptuous conduct consisted of his rude,
sarcastic, inappropriate, insubordinate, disrespectful, antagonistic, deceitful,
disruptive, argumentative and childish behavior during trial, all of which
appeared to be done to vex and annoy the court, the witness, and the opposing
party, and to disrupt the trial process. The court finds that the following
occurred, and constitute contempt: 1) defendant's mimelike, clownish antics of
making faces at the court; sagging down into his seat and hanging his head;
looking behind himself and inside his coat as if searching for a better way to
ask a question; rolling his eyes; and mimicking others words; 2) defendant's
incessant arguing with the court, talking over the court, and interrupting the
court; 3) defendant's repeatedly restating matters after being told by the court
to "move on" or "ask the next question;" 4) defendant's repeatedly injecting
allegations of bribery, perjury, and police retaliation into the matter after the
court instructed him not to, and directed him to limit himself to issues
pertaining to the facts of the "Boulevard Stop;" 5) defendant's repeatedly trying
to insert" Richard Hill" into his questions and statements when such person
was not relevant to the proceeding and the defendant had been ordered to stop
discussing that; 6) defendant's disregarding the rules of evidence and court
procedure by continually posing improper questions after being directed by the
court to properly phrase his questions 7) defendant's continually accusing the
court of denying him the right or ability to ask questions and telling the court to
"give me a list of questions you want me to ask;" 8) defendant's suggesting that
the court "tell me what would make you happy;" 9) defendant's lying to the
court in response to direct questions posed by the court with regard to his
recording the proceedings; and 10) defendant's failing and refusing to properly
examine the witness, despite numerous admonitions by the court to stop
repeating questions, misstating answers, injecting irrelevant material, arguing
with the witness and mischaracterizing the testimony."
See Hearing Exhibit ORDER FINDING THE DEFENDANT IN CONTEMPT OF COURT AND
IMPOSING SANCTIONS.
8. The trial of the matter was continued to March 12, 2012. Coughlin failed to appear and
failed to contact the court to explain or excuse his absence. However, after serving the five-day
Contempt of Court sanction and after being released from custody, Coughlin fax-filed a 224-page



document entitled "Notice of Appeal of Summary Contempt Order; Motion to Return Personal
Property Confiscated by Reno Municipal Courts and Its Marshalls; Motion for New Trial and to Alter
or Amend Summary Contempt Order." See Hearing Exhibit 5, ORDER, P 2, lines 1-6.
9. Judge Nash Holmes observed that the pleading filed by Coughlin failed to address most
of the topics listed in the caption. Rather, she observed, the document contained rambling references to
Coughlin's personal life, his father's football career in college; dozens of pages of string citations taken
from the internet and other unrelated references. Judge Nash Holmes found the pleading to be
disjointed and incoherent and a "pathetic demonstration of what might once have been legal and
academic prowess that appears to now be greatly damaged." See Hearing Exhibit 5, ORDER, P2, lines
9-15; P2, lines 16-20.
10. Judge Nash Holmes also found that Coughlin, after being released from custody
following the February 27, 2012 Contempt of Court incarceration, filed other nonsensical pleadings
including a 218 page document:
"...purported to be yet another motion in this case entitled "Motion to Return Cell
Phones; Motion to Set Aside Summary Contempt Order; and Notice of Appeal of
Summary Contempt Order." With scant discussion of, or relevance to, the above
captioned matter, said document mostly argues against Judge Howard in a
Department 4 case and again contains more than 200 pages of string legal citations;
lyrics to rocks (sic) songs; Mr. Coughlin's personal family history; discussion of an
eviction case and another contempt case; disjointed legal citations and other
nonsensical matters that have no apparent relevance to his traffic citation case.
11. After observing that Coughlin's conduct had been inappropriate, bizarre, dishonest, irrational
and disruptive, Judge Nash Holmes concluded, by clear and convincing evidence, that Coughlin had
committed numerous acts of attorney misconduct, including, but not limited to, violating Rules of
Professional Conduct 8.4(c), 8.4(d), 3.3(a), 3.1, 3.2, 3.4(c), 1.3 and 1.1. See Hearing Exhibit 5,
ORDER, P,3, lines 25-26; P4, lines 5-23.
12. Judge Nash Holmes also concluded that Coughlin violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011 by surreptitiously recording the traffic
court proceedings without advance permission and lying to the court when questioned regarding the
matter by denying that he had done so. See Hearing Exhibits, ORDER, P,4, lines 24-28.
13. Judge Nash Holmes ordered, among other orders, that the traffic court matter be continued
and all proceedings relating to the traffic court matter be tolled pending referral of the matter to the
State Bar of Nevada. See Hearing Exhibit 5, ORDER, P,4, lines 7- 18,
14. On March 14, 2012, Judge Nash Holmes referred the matter of Coughlin to State Bar
Counsel David Clark and suggested the matter had some urgency. See Hearing Exhibit 8, Letter dated
March 14, 2012 from Reno Municipal Court Judge Dorothy Nash Holmes to Office of State Bar
Counsel, Nevada State Bar.
15. Judge Holmes testified at the hearing of this disciplinary matter that one of the purposes of
her March 14, 2012 Order was to provide the panel to hear this matter with clear and convincing
evidence, based on her experience and background as an attorney, prosecutor and judge that Coughlin
had violated numerous provisions of the Nevada Rules of Professional Conduct. See
Transcript of Proceedings of Wednesday, November 14, 2012, P 137, L 22 -P 138, L 9.
16. U.S. Bankruptcy Judge Bruce Beesley was called to testify at the hearing of this matter.
During the time frame 2011 to 2012, Coughlin appeared before Judge Beesley two or three times as an
attorney representing clients in a bankruptcy matter. On one occasion Coughlin appeared wearing a T-
shirt and a tie and no jacket. See Transcript of Proceedings of Wednesday, November 14, 2012, P 10, L
10-16. Coughlin had filed a pleading in the bankruptcy matter, on behalf of his client. Judge Beesley







testified that the pleading was "lengthy, didn't make any sense, and just sort of rambled through a great
deal of irrelevant stuff." See Transcript of Proceedings of Wednesday, November 14, 2012, P 10, L 24 -
P 11, L 1. On other occasions, although Coughlin appeared polite and intelligent, his pleadings and
arguments didn't make any sense. See Transcript of Proceedings of Wednesday, November 14,2012, P
11, L2-7
17. Judge Beesley became concerned, wrote a letter to the State Bar explaining his
experience with Coughlin and indicated that he did not believe Coughlin, in his current state, was able
to adequately represent his clients. See Transcript of Hearing Wednesday, November 14, 2012,P 13, L
24 -P 14, L 7.
18. In Judge Beesley's opinion, Coughlin is not competent to practice law. See Transcript of
Proceedings of Wednesday, November 14,2012,PIS, L 11 -15.
19. State Bar Counsel called attorney Richard Hill to testify at the hearing of this matter:
Mr. Hill has been a member in good standing with the State Bar of Nevada for 33 years. See Transcript
of Proceedings of Wednesday, November 14, 2012, P 36, L 22 P 37 L 4. Mr. Hill was retained by Dr.
Merliss to assist Dr. Merliss in a landlord tenant dispute with his tenant Coughlin. See Transcript of
Proceedings of Wednesday, November 14, 2012, P 37, L14 -20. Mr. Hill represented Dr. Merliss in
Reno Justice Court and Washoe County District Court and two appeals to the Nevada Supreme Court in
the matters involving Dr. Merliss and Coughlin. See Transcript of Hearing Wednesday, November
14,2012,P 39, L 13 -24. Mr. Hill has also reviewed filings in of a case in which Coughlin is involved
with Washoe Legal Services. See Transcript of Proceedings Wednesday, November 14,2012, P 39, L 25
P 40, L 3.
20. In the eviction proceeding between Dr. Meriiss and Coughlin, Mr. Hill's firm obtained an
eviction order allowing Coughlin one week to vacate the premises. Ultimately, Coughlin failed to
comply with the eviction order and was convicted of criminal trespass. See Transcript of Hearing
Wednesday, November 14, 2012, P 41, L 18 -P 44, L 12.
21. On behalf of his client Dr. Merliss, Mr. Hill sought and obtained an order in favor of Dr.
Merliss and against Coughlin awarding Dr. Merliss attorney's fees in the amount of $42,065.50.
Washoe District Court Judge Patrick Flanagan entered the order on June 25, 2012. See Transcript of
Proceedings of Wednesday, November 14, 2012, P 47, L 3-7. -See Hearing Exhibit 2, P 3, L 10-11. The
motion seeking attorney's fees was based on Coughlin's conduct in the defense of the eviction matter,
which conduct was characterized as frivolous and vexatious and presumably so found by Judge
Flanagan. See Hearing Exhibit P 2, L 8-13; P 3, L 4-11.
22. Based on Mr. Hill's experience and background, his review of the pleadings in the
litigation between Dr. Merliss and Coughlin and his review of the pleadings in Coughlin's litigation
with Washoe Legal Services, Mr. Hill is of the opinion that Coughlin is not competent to practice law.
See Transcript of Hearing Wednesday, November 14, 2012, P 39, L 1 -12.
23. Based on Mr. Hill's experience in litigating with Coughlin, Coughlin was not truthful
with either counsel or the court. See Transcript of Hearing Wednesday, November 14, 2012,P 53, L 6
-16. Mr. Hill felt that Coughlin's filings were abusive, at one point calling Mr. Hill's associate a lichen.
Coughlin has accused Mr. Hill of bribing the Reno Police Department to have Coughlin arrested. Mr.
Hill's staff is terrorized by Coughlin. See Wednesday, November 14, 2012, P 54, L 4 -15.
24. State Bar Counsel called attorney Paul Elcano to testify at the hearing of this matter. Mr.
Elcano is the executive director of Washoe Legal Services that provides legal services to indigents. See
Transcript of Hearing Wednesday, November 14, 2012, P 88, L 25 -P 89, L 14. Coughlin was
employed by Washoe Legal Services from August 29, 2007 to May 11, 2009. See Transcript of Hearing
Wednesday, November 14, 2012, P 93, L 17 -20. Mr. EJcano became aware of an order entered by
Judge Gardner on April 10, 2009 in the matter of Joshi v Joshi and, as a result, reviewed the taped
transcript of the hearing. See Transcript of Hearing Wednesday, November 14,2012, P 94, L 22 -P 95, L
6.



25. Judge Gardner's order in the Joshi matter indicated that Coughlin had conducted no
discovery in the case and failed to present any documentary evidence at the trial of the matter on behalf
of his client Mrs. Joshi. See Hearing Exhibit P 12, L 4 -6. After commenting on various negative
aspects of Coughlin's representation of his client Mrs. Joshi, (See Hearing Exhibit P 12, L 9 -P 13, L
40) Judge Gardner specifically held:
"The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic and
disrespectful presentation at trial; Mr. Coughlin's inability to understand a balance
sheet; his failure to conduct discovery; and his lack of knowledge with regard to the
rules of evidence and trial procedure. All of this was compounded with a continuously
antagonistic presentation of the case that resulted in a shift from a fairly simple divorce
case to a contentious divorce trial lasting an excessive amount of time. "
See Hearing Exhibit P 13, L 5 -10
26. Judge Gardner sanctioned Coughlin personally and awarded attorney's fees to Mr. Joshi in
the amount of $934 to be paid personally by Coughlin within 30 days of the order. See Hearing Exhibit
P 13, L 14 -17
27. Based on the order and Coughlin's conduct in the Joshi matter, Coughlin was tenninated by
Washoe Legal Services. See Transcript of Hearing Wednesday, November 14, 2012, P 110, L7-8 28, In
Mr. Elcano's opinion, Coughlin is not competent to practice law. See Transcript of Hearing Wednesday,
November 14, 2012, P 94, L 3 -8.
29. State Bar Counsel called Coughlin to testify at the hearing of the matter. Coughlin was
questioned with regard to a letter dated February 14, 2012 from Assistant Bar Counsel King to
Coughlin in which Bar Counsel forwarded to Coughlin correspondence received from Richard G. Hill.
See Transcript of Hearing Wednesday, November 14, 2012, P 163, L 13 -P 164, L 23. See Hearing
Exhibit 6. Coughlin's response, dated March 9, 2012, asked for additional time in which to respond.
See Hearing Exhibit 7. No evidence was presented that Coughlin substantively responded to Bar
Counsel's letter of February 14, 2012 prior to the filing of the Complaint in this matter. Coughlin failed
to directly respond to Bar Counsel's questions inquiring if Coughlin ever subsequently responded to
Bar Counsel's letter of February 14, 2012. See Wednesday, November 14, 2012, P 169, L 13 -P 172, L
16.
30. Coughlin also failed to directly respond to questioning regarding whether or not he had
substantively responded, prior to the filing of the Complaint in this matter, to a letter forwarded to him
from Bar Counsel regarding the letter received by the Nevada State Bar from Judge Dorothy Nash
Holmes and dated March 14, 2012. See Transcript of Hearing Wednesday, November 14, 2012, P 174,
L 13 -P 180, L 4. See Hearing Exhibit 8.
31. On March 7,2012 Coughlin caused to be filed an "Affidavit of Poverty in Support of
Motion to Proceed Informa Pauperis." See Hearing Exhibit 9. In his Affidavit, Coughlin represented
that he was self-employed as a "Jack of all Trades." See Hearing Exhibit 9. The Affidavit does not
identify Mr. Coughlin as a lawyer or identity any income from the practice of law. See Hearing Exhibit
9.
32. The record also indicates that Coughlin had also filed a motion on November 14, 2011 to
proceed In Forma Pauperis in case number I1CR 22176 pending in the Reno Municipal Court before
Judge Kenneth R. Howard. See Hearing Exhibit 10. Judge Howard's Order denying Coughlin's motion
specifically noted that Coughlin's "affidavit of poverty" did not identify any income from the practice
of law yet Coughlin had implied to the court when sentenced to incarceration for contempt that his
incarceration would adversely affect his clients. See Hearing Exhibit 10, P 2, L 19 -23.
33. Although Coughlin claims to suffer the impairment of attention deficit disorder, for which
he is prescribed medication and which medication he took on the day of his hearing, he does not feel he






needs any additional help. See Transcript of Hearing Wednesday, November 14, 2012, P 199, L 13 -P
204, L 9.
34. On August 23, 2012, the State Bar of Nevada filed its Complaint in this matter and served it
upon Respondent Coughlin by Certified Mail to his address then registered with the State Bar of
Nevada. See Docket. Complaint.
35. Not having received a response to the Complaint, on October 9, 2012 the State Bar of
Nevada filed and served on Respondent Coughlin, by certified mail, a "Notice of Intent to Proceed on a
Default Basis." The Notice attached an additional copy of the Complaint and indicated that unless a
responsive pleading to the Complaint was received by the State Bar by October 24, 2012, the matter
would proceed on a default basis. See Docket, Notice of Intent to Proceed on a Default Basis.
36. On October 31, 2012 Panel Chair Echeverria issued the Panel's Order denying Coughlin's
"Motion to Dismiss" filed October 16, 2012; Denying Coughlin's "Motion for Order to Show Cause
Regarding Improper Attempt by Bar Counsel and, Possibly, NNDB to Delay and Obstruct Hearing
Required by Courts (sic) June 7, 2012 Order in Case No. 60838 and Coughlin's SCR 102(4)(d) Petition
in Case 61426 filed October 2, 2012; Granting Coughlin's Motion to Review and Inspect Bar Records
filed October 16, 2012 and Denying Coughlin's Motion to Bifurcate Hearing and Motion to Dismiss for
(sic) Complaint (sic) Failure to Sufficiently State the Charges with Specificity and Support and for
Utter Failure of Bar Counsel to Perform Reasonable Investigation." See Order Dated October 31, 2012.
In that Order, Chairman Echeverria further ordered that the Formal Hearing would proceed on a default
basis unless Coughlin filed a Verified Answer to the Complaint by November 9, 2012. See Order Dated
October 31, 2012, P 2, L 7-10.
37. Again on November 7, 20 12, Chairman Echeverria, in an Order Granting the State Bar's
Motion to Quash certain Subpoenas reminded Coughlin that unless a Verified Answer to the Complaint
was filed by 5:00 p.m. on November 9,20 12 the panel would proceed on a default basis. See Pleadings
Docket Order Dated November 7, 2012, P 2, L 8 -13.
38. Following a lengthy attempt to determine whether or not Coughlin believed he had
filed a timely verified answer or response to the State Bar's Complaint, Coughlin attempted, at the
hearing of the matter, to transform a pleading previously filed in the Reno Municipal Court into a "New
Verified Response (sic) Pre-Hearing Motion to Dismiss/Summary Judgment, Memorandum of Law
(See Hearing Exhibit 14) and to transform an "Emergency Ex Parte Motion to Dismiss ... " previously
dated November 12, 20 12 and altered at the hearing to reflect a date of November 14, 2012 into a
"Declaration and Verified Response." See Hearing Exhibits 15 and 16. See Transcript of Hearing
Wednesday, November 14,2012, P 244, L 16 -P 270, L II.
39. During the course of the hearing of this matter Coughlin continued to demonstrate a pattern
of conduct similar to, if not identical to, conduct in other forums for which he had repeatedly been
sanctioned. See Transcript of Hearing Wednesday, November 14,2012. Pleadings in this matter filed by
Coughlin were exceedingly lengthy, demonstrated a lack of focus and understanding of the issues
involved, were rambling and incoherent and contained discussion of irrelevant issues. See, e.g Hearing
Exhibits 14, 15, 16. See also, Pleadings Docket Motion for Order to Show Cause ... " dated October
2,2012; "Motion to Review and Inspect Bar Records ... " Filed October 16, 2012; Pleading entitled
"Well Would You Look at That ... " dated November 7,2012; "Emergency Ex Parte Motion To Dismiss
or Quash ... " Filed November 13,2012.
40. Coughlin's conduct at the hearing included conduct not reflected in the transcript of
the proceedings by way of facial gestures, body language, voice intonation and volume. See Transcript
of Hearing Wednesday, November 14, 2012, P 181, L 19-P 182, L 1.
CONCLUSIONS OF LAW
Based on the foregoing Findings of Fact,the Panel hereby issues the following Conclusions
of Law:



















(A) The Panel was designated by the northern Nevada Disciplinary Board Chair to
adjudicate
the Comp
laint filed by the State Bar of Nevada against Zachary B. Coughlin,Case Nos. NGI2-0204,
NG12-0435 and NG12-0434 and to determine the extent of the discipline to be imposed pursuant to the
Nevada Supreme Court Order of Temporary Suspension and Referral to Disciplinary Board entered in
Case No. 60838, In the Matter of Discipline of Zachary B. Coughlin, Esq., Bar No. 9473, entered June
7,2012.
(B) The Panel has jurisdiction over the Respondent and the subject matter of these
proceedings. See Nev. Sup. Ct. R. 99.
(C) Venue in this matter is properly with the Northern Nevada Disciplinary Board and
in
the County of Washoe, State ofNevada. Nev. Sup. Ct. R. 105.
(D) Coughlin received notice and a copy of the Complaint, notice of his right to respond, as
well as notice of the evidence and witnesses upon which the State Bar intended to rely at a formal
hearing. Notice of the formal hearing was served on Coughlin. Coughlin appeared in the matter, filed
numerous motions, appeared at the hearing of the matter, cross-examined witnesses and testified on
behalf of the State Bar and on his own behalf. Accordingly, the State Bar complied with the procedural
requirements of SCR 105.
(E) Coughlin was afforded ample opportunity to prepare a verified answer or response to the
allegations of the Complaint and failed to timely do so. See Findings of Fact 34, 35 and 36.
Accordingly, the matter could proceed on a default basis and the allegations of the Complaint deemed
admitted. SCR 105(2) Notwithstanding the fact that the matter could have been decided on a default
basis, the Panel permitted the State Bar and Coughlin to present evidence.
(F) Submitted to the panel for decision are the following issues:
(1) Whether Coughlin violated RPC 1.1 (Competence).
(2) Whether Coughlin violated RPC 1.2 (Diligence). (NOTE: actually, RPC 1.2
is Scope of Representation and Allocation of Authority Between Client and
Lawyer, and RPC 1.3 is Diligence.
(3) Whether Coughlin violated RPC 3.1 (Meritorious Claims and Contentions)
(4) Whether Coughlin violated RPC 3.3 (Candor to the Tribunal).
(5) Whether Coughlin violated RPC 3.4 (Fairness to Opposing Party and
Counsel)
(6) Whether Coughlin violated RPC 3.5 (Impartiality and Decorum of the
Tribunal)
(7) Whether Coughlin violated RPC 3.5A (Relations with Opposing Counsel)
(8) Whether Coughlin violated RPC 4.1 (Truthfulness in Statements to Others)
(9) Whether Coughlin violated RPC 4.4 (Respect for the Rights of Third
Persons)
(10) Whether Coughlin violated RPC 8.1 (Disciplinary Matters)
(11) Whether Coughlin violated RPC 8.2 (Judicial and Legal Officials)
(12) Whether Coughlin violated RPC 8.4 (Misconduct)
(13) The extent of the discipline to be imposed pursuant to SCR 111 as a result
of
Coughlin's conviction of the "serious" crime of Petit Larceny.
(G) The State Bar must prove by clear and convincing evidence that Coughlin violated RPC
1.1,'
1.2,3.1, 3.3, 3.4,3.5,4.1,4.4, 5A (sic),8.1,8.2,and 8.4. See Nev Sup. Ct. R. 105(2)(e); In re Stuhff, 108
Nev. at 633-634, 837 P.2d at 856; Gentile v State Bar, 106 Nev. 60, 62, 787 P.2d 386,387 (1990).
Competence
(H) RPC 1.1 states "A lawyer shall provide competent representation to a client. Competent





representation requires the legal knowledge, skill, thoroughness and preparation reasonably necessary
for the representation."
(I) The record clearly and convincingly establishes that Coughlin lacks the competency to
represent clients, including himself.
(J) First, the record demonstrates severe criticism by the trial court in the handling of the Joshi
matter, including Coughlin's lack of understanding of a balance sheet, his failure to conduct discovery,
his lack of knowledge of the rules of evidence and trial procedure. Supra' 25
(K) Second, Judge Beesley testified that the pleadings filed by Coughlin on behalf of his client
in a bankruptcy case were "lengthy, didn't make any sense, and just sort of rambled through a great deal
of irrelevant stuff." Judge Beesley also testified that Coughlin's pleadings and arguments on behalf of
his client "didn't make any sense." Supra ' 16 Judge Beesley became concerned enough about
Coughlin's competency as a lawyer that he contacted the State Bar. Supra' 17
(L) Third, Judge Nash Holmes questioned Coughlin's competency as a lawyer and in her Order
finding Coughlin in Contempt of Court noted that Coughlin disregarded the rules of evidence,
continually imposed improper questions, failed to properly examine witnesses, repeatedly asked the
question, misstated answers, injected irrelevant material, argued with witnesses and mischaracterized
testimony. Supra' 7
(M) Fourth, Judge Nash Holmes found that Coughlin's pleadings failed to address topics listed
'in the caption, contained rambling references to Coughlin's personal life and other irrelevant material,
were overly lengthy, disjointed and incoherent. Supra' 9 & 10
(N) Fifth, the State Bar called two judges and two practicing attorneys (Elcano is not listed as
an "active attorney" at www.nvbar.org, nor has he been for over 5 years), each with significant
experience with Coughlin and each of whom rendered an expert opinion regarding Coughlin's
competency as a lawyer. Judge Beesley testified that in his opinion, Coughlin was not competent to
practice law. Supra 18. Judge Nash Holmes testified that in her opinion, Coughlin violated numerous
Rules of Professional Conduct including his lack of competency to practice law. Supra 15. Attorney
Richard Hill also testified that in his opinion Coughlin is not competent to practice law. Supra 22
Attorney Paul Elcano, who once supervised Coughlin as a lawyer and ultimately terminated him from
Washoe Legal Services, also testified that, in his opinion, Coughlin is not competent to practice law.
Supra 28
(O) Sixth, the record establishes that Coughlin offered no expert opinion or evidence as to his
competency.
Diligence
(P) RPC 1.2 states "A lawyer shall act with reasonable diligence and promptness in
representing a client." The record is less clear as to whether or not Coughlin violated RPC 1.2 on more
than on occasion.
(R) Judge Howard, in the Joshi case, certainly found that Coughlin failed to conduct discovery
on behalf of his client in that matter. Supra 25
(S) The record and Pleading Docket in this case establish that Coughlin failed to provide a
verified responsive pleading even in the defense of his own disciplinary action. Supra 38
(T) The record and Pleading Docket in this case establish that Coughlin habitually files
numerous, untimely and repetitive motions.
Meritorious Claims and Contentions
(U) RPC 3.1 in pertinent part states "A lawyer shall not bring or defend a proceeding, or assert
or controvert an issue therein, unless there is a basis in .law and fact for doing so that is not frivolous,
which includes a good faith argument for an extension, modification or reversal of existing law."
(V) The record clearly and convincingly establishes that Coughlin continuously and repetitively
files irrelevant pleadings. pleadings unrelated to the issue at hand and continuously and repetitively
injects irrelevant matters into proceedings.










(W) Judge Nash Holmes found, for example, that Coughlin repeatedly injected allegations of
bribery, perjury and police retaliation in a simple traffic case involving the failure to stop at a stop sign.
Supra 7 She also found that Coughlin repeatedly injected attorney Richard Hill into questions and
statements when Mr. Hill was in no way involved in the traffic citation trial. Supra 7 She also found
that pleadings filed subsequent to Coughlin's incarceration were lengthy (more than 200 pages)
contained scant discussion of, or relevance to, the matter and contained irrelevant discussion of facts
unrelated to the proceedings at hand. Supra. 10
(X) The record establishes that in the Merliss eviction action, Coughlin's conduct was so
vexatious and frivolous as to result in substantial sanction of attorney's fees. Supra 21 See Hearing
Exhibit 2, P 2, L 8 -13; P3, L 4 -11.
(Y) The Pleading Docket in this matter establishes also that Coughlin's filings, even in his own
defense of the disciplinary matter, inject lengthy, irrelevant facts and legal issues into this proceeding.
Candor to the Tribunal
(Z) RPC 3.3(a)(1) states "A lawyer shall not knowingly: (m)ake a false statement of fact or law
to a tribunal or fail to correct a false statement .of material fact or law previously made to the tribunal
by the lawyer."
(AA) The record clearly and convincingly establishes that Coughlin violated RPC 3.3(a)(l)
when he lied to Judge Nash Holmes as to whether or not he was surreptitiously and without permission
to record the proceeding. Supra 7 Of note, Coughlin did not deny that he had lied to Judge Nash
Holmes. Instead, his cross examination of Judge Nash Holmes focused on how she had learned of the
true facts. See Transcript of Hearing Wednesday, November 14, 2012, P 139, L
(BB) Attorney Richard Hill testified that based on his experience in litigating with Coughlin,
Coughlin was not truthful with either counsel or the Court. Supra Paragraph 23.
(CC) The record also establishes that Coughlin was less than candid with the Court in two
separate applications to proceed in forma pauperis, when he failed to disclose his true occupation as an
attorney and instead indicated he was self-employed as a "Jack of all Trades" failed to identify any
income from the practice of law after having represented to the court that his incarceration would
adversely affect his clients. Supra 31 & 32
Fairness to Opposing Party and Counsel
(DD) RPC 3.4(c) states "A lawyer shall not: (k)nowingly disobey an obligation under the
rules of a tribunal except for an op en refusal based on an assertion that no valid obligation exists."
(EE) The record clearly and convincingly establishes that Coughlin has a clear and
continuing pattern of knowingly ignoring and disobeying instructions from the Court.
(FF) In his Order of Contempt, Judge Howard found that Coughlin refused to obey directives of
the Judge and continued lines of questioning after being instructed to refrain from doing
so. Supra 4
(GG) Judge Nash Holmes, in her Order of Contempt, found that Coughlin incessantly argued
with the Court, interrupted the Court, repeatedly restated matters after having been admonished to
refrain from doing so, disregarded directives to ask properly phrased questions and disobeyed
nwnerous admonitions by the court to stop repeating questions, misstating answers, injecting irrelevant
material, arguing with the witness and mischaracterizing testimony. Supra 7 tribunal."
repeatedly conducts himself in a manner that is disruptive of the tribunal while in the courtroom.
(HH) The transcript of the hearing in this matter clearly demonstrates that Coughlin repeatedly
and incessantly interrupts witnesses, counsel, Panel members and Panel Chairman and refuses to heed
admonitions to refrain from doing so. See generally of Wednesday, November 14, 2012.
Impartiality and Decorum of the Tribunal
(II) RPC 3.5(d) states "A lawyer shall not engage in conduct intended to disrupt a
(JJ) The disruption must have occurred in the courtroom. One cannot disrupt a tribunal with
conduct outside of the courtroom. In re Michael Stuhff, 108 Nev. 629, 837P.2d 853 (1992)












(KK) The record overwhelmingly, clearly and convincingly establishes that Coughlin repeatedly
conducts himself in a manner that is disruptive of the tribunal while in the courtroom.
(LL) The various orders of contempt or imposing sanctions issued by Judges Kenneth Gardner,
Linda Gardner, Dorothy Nash Holmes and Patrick Flanagan each describe a similar pattern of conduct
and behavior that is intentionally disruptive of the tribunal. Supra 4,7, 10, 21 and 25
(MM) The transcript of the proceedings in this matter reveal a continuation of a similar pattern of
conduct by Coughlin despite his having been sanctioned twice with an adverse award of attorney's fees
and twice by incarceration. See generally of Wednesday, November 14,2012.
Relations with Opposing Counsel
(NN) RPC 3.5A states "When a lawyer knows or reasonably should know the identity of a lawyer
representing an opposing party, he or she should not take advantage of the lawyer by causing any
default or dismissal to be entered without first inquiring about the opposing lawyer's intention to
proceed." (?Judge Linda Gardner's former employer Gayle Kern, Esq. in RJC Rev2012-000374,
perhaps? "It is absolutely fair, Your Honor..." to RJC Judge Jack Schroeder when he entered a default
summary eviction on 3/15/12 against Coughlin despite Coughlin having filed a Tenant's Answer of
substantial length and substance and Coughlin appearing, perhaps even on time, on 3/15/12 for the
Hearing (and an unlawful interruption of essential services hearing had already taken place against
Kern's client, though only the property manager showed up to play lawyer for PTTHHOA).
(OO) Although the State Bar pled a violation of RPC 3.5A in its Complaint, no evidence was presented
that Coughlin ever violated the rule. Accordingly, the Panel finds that the State Bar failed to meet its
burden of proof on this issue as an evidentiary matter but finds that as a matter of default the violation
may be deemed admitted.
Truthfulness in Statements to Others
(PP) RPC 4.1 (a) states "In the course of representing a client a lawyer shall not knowingly: (a) (m)ake
a false statement of material fact or law to a third person."
(QQ) Although the evidence established that Coughlin knowingly made false statements to Court and
Counsel (See (AA), (BB) and (CC no evidence was presented that Coughlin knowingly made
false statements of material fact or law to a third person. Accordingly, the Panel finds that the State Bar
failed to meet its burden of proof on this issue as an evidentiary matter but fmds that as a matter of
default the violation may be deemed admitted. (this is a nonsense argument, especially where the Panel
and SBN pat themselves on the back for, allegedly, providing sufficient due process to
Coughlin/fulfilling SCR 105...its one or the other...but the Panel doesn't get to purport that Coughlin
defaulte where it is also trumpeting the feats of due process it enabled....).
Respect for the Rights of Third Persons
(RR) RPC 4.4(a) states '"In representing a client, a lawyer shall not use means that have no
substantial purpose other than to embarrass, delay, or burden a third person... " (uh...like Hill's
allegations of finding a "crack pipe and a bag of weed" or a "vial of something" and "a large quantity of
pills"?).
(SS) The record establishes clearly and convincingly that in the Merliss eviction action,
Coughlin conducted himself in a manner that was abusive, vexatious and for purposes of delay. The
matter was a simple eviction action that apparently lasted through several proceedings at the Municipal
Court level, an appeal to the District Court and two appeals to the Nevada Supreme Court and which
also resulted in Coughlin's conviction for criminal trespass. Supra 19 and 20 Coughlin's conduct in
the proceedings was so egregious that Judge Flanagan ordered Coughlin to pay Dr. Merliss $42,065.50,
an amount that is still unpaid. Supra 21
(TT) The record also establishes that Coughlin habitually prolongs proceedings unnecessarily;
files lengthy, irrelevant, nonsensical pleadings requiring court, staff and counsel to spend unnecessary
effort in evaluating and/or responding to the pleadings. Supra 4, 7, 8, 9, 10, 11, 16, 21, 23, 25, 27,
39 and 40






Disciplinary Matters
(UU) RPC 8.1(b) provides, in pertinent part, " ... a lawyer ... in connection with a disciplinary
shall not: (b) ... knowingly fail to respond to a lawful demand for information from an
(VV) The record clearly and convincingly establishes that Coughlin knowingly failed to
respond to the State Bar's request for information in the disciplinary proceeding and failed to timely file
a required verified responsive answer or pleading to the Complaint.
(WW) First, Coughlin asked for an extension of time to respond to the letter of February 14,
(XX) Second, Coughlin failed to respond to a subsequent letter from the State Bar regarding the
Complaint filed with the Bar by Judge Nash Holmes. Supra 30
(YY) Third, Coughlin ignored SCR 105(2) when he failed to timely file a verified response or
answer to the Complaint, despite several warnings to do so. Supra 34, 35, 36, 37, 38 Coughlin
compounded this violation when he attempted, during the course of the hearing in this matter, to
transform a pleading previously filed in Reno Municipal Court into a "New Verified Response (sic)
Pre-Hearing Motion to Dismiss/Summary Judgment, Memorandum of Law by crossing out the original
caption and handwriting the "new" caption. Supra 38.
Coughlin also attempted, during the hearing, to transform a pleading he had filed the day before
the hearing entitled "Emergency Ex Parte Motion to Dismiss ... " by handwriting the words
"Declaration and Verified Response ... " onto the caption of the pleading. Supra 38
(ZZ) The conduct described herein not only demonstrates a lack of cooperation with the State
Bar, but a lack of competency as well.
Judicial and Legal Officials
(AAA) RPC 8.2(a) states "A lawyer shall not make a statement that the lawyer knows to be
false or with reckless disregard as to its truth or falsity concerning the qualifications or integrity of a
judge, adjudicatory officer or public legal officer. ..
(BBB) During the course of the hearing, Coughlin accused Judge Nash Holmes of lying during
her testimony. Coughlin has expressed similar views concerning Judge Nash Holmes in various
pleadings filed in this proceeding as well as others. Coughlin has also uttered other derogatory remarks
about various judges with whom he has interacted.
(CCC) The State Bar presented scant evidence on this issue and no evidence from which the
panel could conclude that the expressions were knowingly false as opposed to an expression of opinion.
While the conduct displayed is, in the view of the Panel reprehensible, the Panel concludes that the
State Bar failed to meet its burden of proof on the issue as an evidentiary matter but fmds that as a
matter of default the violation may be deemed admitted.
Misconduct
(DDD) RPC 8.4 provides (in pertinent parts):
It is professional misconduct for a lawyer to :
(a) Violate or attempt to violate the Rules of Professional Conduct...
(b) Commit a criminal act that reflects adversely on the lawyer's honesty, trustworthiness
or fitness as a lawyer in other respects;
(c) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation;
(d) Engage in conduct that is prejudicial to the administration of justice.
(EEE) The Pleadings, Hearing Exhibits and Transcript of these proceedings overwhelmingly,
clearly and convincingly establish a repeated, unrelenting and obstinate pattern of misconduct by
Respondent Coughlin evincing numerous and repeated violations of several provisions of RPC 8.4 in
violation of RPC 8.4(a). (So, would that not be something not noticed or plead in the Complaint, and
therefore, only appropriate in some future disciplinary hearing, if any? Otherwise, is that not
transmogrifying what is required to be a plenary hearing into one of a summary nature?).
(FFF) Coughlin was convicted of petit larceny on November 30, 201 1, a violation of RPC
8.4(b). Such violation is sufficient alone to trigger application of SCR 111 . The Nevada Supreme Court














referred the matter to the appropriate disciplinary panel for a determination of the extent of punishment
that should follow from the conviction. Supra para. 5
(GGG) The record also establishes that Coughlin was convicted of criminal trespass in the
prolonged eviction proceedings involving Dr. Merliss, a violation of RPC 8.4(b). Supra 20
(HHH) The Complaint in this matter alleges that Coughlin has been arrested and is awaiting
trial on . a larceny charge involving a cell phone and on a charge of abusing 91 1 emergency
procedures. However, no evidence was presented on these charges but as a matter of default the
allegations may be deemed admitted and would constitute additional violations of RPC 8.4(b).
(JJJ) The record, as described at length above, establishes several violations ofRPC 8.4(c).
See (AA), (BB), (CC), (AAA), (BBB) and (CCC).
(KKK) The entire record in this matter is replete with instances demonstrating that Coughlin's
conduct is prejudicial to the administration of justice. Coughlin has been repeatedly sanctioned
monetarily and by way of incarceration for his conduct, has repeatedly filed lengthy, irrelevant and
nonsensical pleadings requiring staffs, courts and counsel to expend needless and unnecessary time in
responding to such pleadings, has repeatedly disrupted proceedings and failed to follow instructions
and admonitions of the courts. The record establishes that the pattern of conduct continues despite the
severe sanctions administered and continues up to and during the disciplinary process and hearing of
this matter.
The Extent of the to be imposed pursuant to SCR 111 As a Result of Conviction of the
"Serious" Crime of Petit Larceny.
(LLL) The matter of the referral from the Supreme Court was considered in conjunction with
the allegations in the Complaint filed by the State Bar. While the conviction at issue in the Supreme
Court Order of June 7, 2012 may not alone warrant the discipline recommended in this Panel's
recommendations, taken as a whole and in conjunction with the numerous and repeated other violations
of the Rules of Professional Conduct, warrant, in this Panel's view, the discipline recommended herein.
DECISION AND RECOMMENDATION
In assessing the fonn of discipline to recommend, the Panel has accounted for a number of
aggravating and mitigating factors that must be considered. The Panel finds that the State Bar has
shown by clear and convincing evidence the presence of at least eight of the eleven aggravating
circumstances to be considered in accordance with the provisions of SCR 102.5(1).
First, while there have been no fonnal prior disciplinary proceedings by the State Bar, the
record establishes that Coughlin has been disciplined by way of sanctions on at least four prior
occasions.
Second, the record reflects, at least with respect to the Merliss matter and the two criminal
trials, that the pattern of conduct was for selfish reasons: to preserve an unlawful tenancy and to delay
and prolong criminal convictions.
Third, the record clearly and convincingly establishes that the pattern of misconduct is
consistent and includes, without limitation: the disruption of the proceedings; the refusal to heed the
directions and admonitions of the court; the injection of irrelevant material and matters; the filing of
lengthy, irrelevant and nonsensical pleadings; the willingness to lie to court and counsel and the
inability to understand and follow the rules of evidence and procedure.
Fourth, the record clearly and convincingly establishes that Coughlin has committed multiple
violations of the Rules of Professional conduct, as more fully discussed above.
Fifth, the record clearly and convincingly establishes that Coughlin engaged in a bad faith
obstruction of the disciplinary process by failing to file the pleading required by SCR 105(2) and
instead filing several lengthy, irrelevant and nonsensical pleadings, mostly pleadings filed in other
matters, and refiled in the disciplinary action under a similar but different caption. In some instances,
Coughlin simply crossed out the case name and hand wrote the names of the parties in the disciplinary
proceeding.












Sixth, the record clearly and convincingly establishes that Coughlin has refused to acknowledge
the wrongful nature of his conduct despite having been sanctioned on at least four prior occasions.
Seventh, the record clearly and convincingly establishes that Coughlin has shown a complete
indifference to making restitution and has so far ignored orders to do so.
Eighth, the record clearly and convincingly establishes that some of Coughlin's misconduct involves
illegal conduct that evinces fraud and dishonesty. For example, he was convicted of one instance of
petit larceny and is awaiting trial on a second.
The Panel finds few potentially mitigating factors to be present. While the Panel finds that there
is a lack of prior public discipline by the State Bar, the Panel notes that Coughlin has been publicly
criticized in the Joshi matter, has been heavily sanctioned with an adverse award of substantial
attorney's fees in the Merliss matter, and has been incarcerated at least twice for criminal contempt of
court. Although there has been an absence of prior public discipline by the State Bar, there have been
multiple instances of judicial censure and sanction.
Although Coughlin suggested at the hearing that he may have personal or emotional problems
or a mental disability, he denied that he needed further help. Furthermore, no medical evidence was
presented regarding the potential impact of a mental disability, no evidence that the disability was the
cause of the misconduct, no evidence of recovery by rehabilitation and no evidence that a recovery has
arrested the misconduct and that a recurrence is unlikely to occur.
These potentially mitigating factors are weak at best and do not excuse the well established
numerous and repeated violations of the Rules of Professional Conduct and do not outweigh the
aggravating circumstances established overwhelmingly by the State Bar.
RECOMMENDATIONS
The Panel recommends that the Respondent be ordered:
(1) Irrevocably disbarred by the Supreme Court. While irrevocable disbarment is clearly the
harshest form of discipline, the unusual circumstances here, compounded by the repetitive nature of the
misconduct prior . to and even during the disciplinary process and hearing, clearly warrant the level of
punishment recommended.
(2) That his temporary suspension be continued pending final resolution of this matter.
(3) Within three (3) days of the effective date of disbarment, to demonstrate to Bar that he has
placed all his Nevada clients with other counsel, otherwise concluded the representation, or with the
assistance of Bar Counsel thereafter attempted to expeditiously aid any
remaining client in finding new counsel.
(4) To pay the costs associated with these proceedings pursuant to SCR 120. "
INDEX OF HEARING EXHIBITS (SBN 'S 1 TO 13) Coughin's 14-15 Chair's 16
1 -Index of Documents Selected for Hearing Packet by SBN's Pat King in attempt to skirt his lie
that he lacked a certified copy of every Order attached to filings contained therein and containing
numerous fraudulent Proofs of Service by the SBN page 333
- p. 336 5 pages of what King purports RPC excerpts (1.2, 3.1, 3.3, 3.4, 3.5, 3.5A, 4.1, 4.4, 8.1, 8.2,
8.4)
- p. 341 8/23/12 Complaint SBN v. Coughlin:
-Exhibit 1: 11/30/11 RMC Judge Howard Judgment of Conviction and Court Order in 22176 candy bar
3/15/12 Judge Elliott Order Affirming Ruling of the RMC in appeal CR11-2064
-Exhibit 2: 11/30/11 RMC Judge Howard Order for Summary Punishment of Contempt Committed in
View and Presence of the Court in 11 CR 22176
-Exhibit 3: 3/12/12 RMC Judge Nash Holmes Order of 3/14/12 with "clear and convincing" language.
2 -Attorney Fees Order of $42,050 by Judge Flanagan in CV11-03628 6/28/12 pursuant to 4/19/12
Motion for Attorney's Fees by Richard G. HIll, Esq., within appeal of summary eviction in RJC
















rev2011-001708 by Judge Sferrazza page 387
3 -Order After Trial by Judge Linda Gardner of 4/10/09 in DV08-01168 that WLS cited as the sole
reason for firing Coughlin from domestic violence attorney position page 392
4 -Contempt Order 2 28 12 Judge Holmes 26800 Order Finding Defendant in Contempt and Imposing
Sanctions, page 407
5 -Order attached to Complaint 3 12 12 Judge Holmes attached to Complaint Order 26800 fed clear
and convincing burden for RPC standard by SBN page 412
6 -Letter dated February 14, 2012 to Mr. Coughlin from Mr. King 2 14 12 partial letter from SBN
King excised Hill's 1 14 12 ng12-0204 grievance, so no notice of it, not pled page 419
7 -Two-page letter dated March 9, 2011 from Mr. Coughlin to State Bar Coughlin's 3 9 12 fax to
SBN regarding delayed receipt of 2 14 12 letter from King re Hill's grievance page 421
8 -Two page letter dated March 14, 2012 from Judge Holmes to SBN Northern Office 3 14 12
complaint against Coughlin to SBN North page 424
9 -Affidavit of Poverty 3 7 12 Affidavit of Poverty lacking caption or certification by RMC D3 page
427
10-Order in Case 11 CR 22176 RMC Judge Howard 12 15 11 Order denying IFP for Transcript
Preparation and New Trial and Recusal page 431
11- Order for Summary Punishment RMC Judge Howard 11 30 11 Order for Summary Contempt
incident to defense of 60838 conviction page 543
12-Order Affirming Ruling of RMC Judge Elliott 3 15 12 Order Affirming RMC Judge Howard's
conviction in candy bar petty larceny CR11-2064 page 439
13-Order Granting Respondent's Motion to Dismiss Appeal Judge Elliott 8 27 12 CR12-1262 Order
Dismissing Appeal of Trespass Conviction by Judge William Gardner in RMC 11 CR 26405 page 444
14-New Verified Response Coughlin 11 14 12 New Verified Response after Chair Echeverria's
threatening misstatements of the law re default page 448
15-Declaration Verified Response with two DVD discs Coughlin's 11 15 12 Declaration and Verified
Response page 509
16-Emergency Ex Parte Motion Chair Echeverria's 11 14 12 incomplete and secretive exhibit entered
sua sponte, in his attempt to one up Judge Nash Holmes as to transmogrifying a plenary formal
disciplinary hearing into a summary contempt/disciplinary hearing, where no copy of Exhibit 16 was
presented to Coughlin at the time Exhibit 16's admission, and copy incomplete lacking discs page 543
and where that which is represented in Exhibit 16 is an incomplete copy of the filing itself (an "edit",
Bar Counsel King might say, if Coughlin was seeking it's admission, where the Exhibits that were
attached to what Exhibit 16 purports to be, are not present (because neither the SBN nor the Panel
Chair (and Panel Member Kent indicated he wouldn't care to review any materials on an attachments in
cd/dvd form ever submitted by Coughlin anyways) seem to be able to burn a cd/dvd very easily, much
less review the materials collected therein and presented by Coughlin in various filings),
8/23/12 SBN V. Z. COUGHLIN SCR 105 COMPLAINT, NG12-0204, 0434, 0435:
"PLEASE TAKE NOTICE that pursuant to Supreme Court Rule ("SCR)105(2) a VERIFIED
RESPONSE OR ANSWER to this Complaint must be filed with the Office of Bar Counsel, State Bar
of Nevada, 9456 Double R Boulevard, Ste. B, Reno, Nevada, 89521, within twenty (20) days of service
of this Complaint. Procedure regarding service is addressed in SCR 109. Complainant, State Bar of
Nevada ("State Bar"), by and through its Assistant Bar Counsel Patrick O. King, is informed and






believes as follows:
Zachery Coughlin ("Respondent"), Bar number 9473, is a member of the State Bar of Nevada
admitted on March 25, 2005. Respondent's date of birth is September 27, 1976. The address that
Respondent has on file with the State Bar of Nevada, in accordance with Rule of Professional Conduct
("RPC") 79(1 )(a) is Post Office Box 3961, Reno NV 89505. Respondent engaged in acts of
misconduct warranting the imposition of professional discipline. The State Bar alleges as follows:
1. Multiple grievances were received by the Office of Bar Counsel between the period of
January 14 and March 15, 2012, concerning Respondent. Due to the serious allegations of misconduct,
grievance files were opened and an investigation was initiated by Assistant Bar Counsel Patrick King.
2. Respondent was advised of the grievances via U.S. mail, e-mail and by a brief meeting with
Mr. King at the State Bar Office in Reno. Respondent did not cooperate with the investigation and
rather than respond to the grievances as requested, Respondent sent non-responsive and disparaging e-
mails.
3. Respondent has not made a request to be placed on disability status, nor has he acknowledged
that he may have mental infirmity, illness, or addiction.
4. The investigation of the grievances against Respondent shows a serious pattern of
misconduct.
5. On September 9, 2011, Respondent shoplifted a candy bar and cough drops a Wal-Mart store
with an approximate value of fourteen dollars ($14.00). On November 30, 2011, Municipal Court
Judge Kenneth R. Howard found Respondent guilty of the offense Petit Larceny, a violation of RMC
8.10.040. Respondent appealed the judgment of The judgment of conviction was affirmed on appeal.
See Exhibit 1.
6. During the trial Respondent's conduct was so disruptive that Judge Howard Respondent in
direct contempt of Court and sentenced him to serve three (3) days in See Exhibit 2.
7. On August 20, 2011, Respondent was arrested on a second larceny charge for stealing a cell
phone. Those charges are currently pending in Reno Justice Court.
8. Respondent was again arrested on January 13, 2012, for allegedly abusing 911 services, a
gross misdemeanor.
9. On February 21. 2012. Respondent filed a document entitled, Notice of Appearance Entry of
Plea of NOt guilty , Waiver of Arraignment, Motion to Dismiss, etc. in one of his pending criminal
matters, Case No. RCR-2012 065630, City of Reno v. Zachary Coughlin. The document clearly shows
Respondent's unprofessional, disruptive conduct, and lack of respect for the court and opposing
counsel.
10. Respondent was arrested on November 13, 2011 by Reno Police Department and charged
with trespassing, a misdemeanor, for which he was later convicted.
11. The circumstances leading to the above-mentioned arrest are as follows: at an hearing
Justice of the Peace Peter Sferrazza ordered that Respondent vacate the home he was renting effective
November 1, 2011. After the locks were changed and the notice was posted on the front door the owner,
Dr. Merliss, discovered that someone had broken into the home and was barricaded in the basement.
The Reno Police tried to coax whoever was in the basement to open the door. Dr. Merliss was forced to
kick open the door where the Reno Police found Respondent. Respondent had broken into the home
and living in the basement. Respondent was arrested for criminal trespass and was subsequently
convicted of that charge.
12. Respondent, representing himself as co-counsel, filed a 36-page motion to dismiss on March
5, 2012. The motion was denied by Judge William Gardner and was determined to be without merit.
The motion, on its face, demonstrates that Respondent lacks competence to practice law.
13. Once Respondent was evicted, an order was obtained to remove his belongings from the
home. Respondent interfered with the contractor who was hired to remove Respondent's personal
belongings. The police were called and after talking with Respondent they recommended that he find






something else to do. Respondent refused to their advice and was subsequently arrested by the Reno
police.
14. In the case of City of Reno vs. Zachary Barker Coughlin, Case No. 11 TR 26800 21, a trial
was held on a traffic citation issued to Respondent. The matter was called at approximately 3:00 p.m.
and concluded without a verdict at about 4:30 p.m. after the court held Respondent in criminal
contempt of court for his behavior and activities committed in the direct presence of the court during
trial.
15. In a March 12, 2012 Order, Municipal Court Judge Dorothy Nash Homes found by "clear
and convincing evidence" that Mr. Coughlin committed numerous acts of attorney misconduct. See
Exhibit 3. Judge Holmes explained in her Order that after Respondent served his five-day contempt of
court sanction imposed by the court on February 27, 2012, Respondent fax-filed to the court a 224-page
document. Judge Holmes found that the document contained rambling references to his personal life
and was incoherent.
16. In her Order, Judge Homes found by clear and convincing evidence that Respondent
violated Rule of Professional Conduct ("RPC") 1.1 (Competence), RPC 1.3 (Diligence), RPC 3.1
(Meritorious Claims and Contentions), RPC 3.2 (Expediting Litigation), RPC 3.3(a) (Candor toward
the Tribunal), RPC 3A(e) (Fairness to Opposing Party and Counsel). RPC 8.4 (c) (Engaging in
Dishonesty. Fraud. Deceit or Misrepresentation) and RPC BA(d) Engage in conduct that is Prejudicial
to the Administration of Justice).
17. Respondent filed Affidavits of Poverty in Support of his Motion to Proceed Informa
Pauperis, wherein he fails to disclose that he is a licensed attorney and instead under Employment and
Self-Employment he identifies himself as a "Jack of All Trades".
18. Despite a claim of poverty in the above mentioned affidavits, Respondent told the Court that
his incarceration for contempt would adversely affect his clients.
19. On March 22, 2012, Respondent appeared at the Reno Municipal Court wearing (smiley
face) flannel pajamas. Respondent became argumentative and Marshals were called to were called to
ask him to leave.
25. On April 10, 2009, District Judge Linda Gardner of the Second Judicial District Court
executed an "Order After Trial," in case No. DV08-01168. In that case, Respondent represented the
Defendant/Counter Claimant. In her Order Judge Gardner explained Respondent's inappropriate
behavior in part as follows: The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic
and disrespectful presentation at trial; Mr. Coughlin's inability to understand a balance sheet; his failure
to conduct discovery and his lack of knowledge with regard to the rules of evidence and trial procedure.
All of this was compounded with a continuously antagonistic presentation of the case that resulted in a
shift from a fairly simple divorce case to a contentious divorce trial lasting an excessive amount of
time.
27. In light of the forgoing Respondent violated RPC 1.1 (Competence); RPC 1.2 (Diligence);
RPC 3. 1 (Meritorious Claims and Contentions): RPC 3.3 (Candor to the Tribunal): RPC 3.4 (Fairness
to Opposing Party and Counsel); RPC 3.S (Impartiality and Decorum of the Tribunal); RPC 4. 1
(Truthfulness in Statements to Others): RPC 4.4 (Respect for the Rights of Third Persons); RPC SA
(Relations with Opposing Counsel); RPC 8.1 (Disciplinary Matters); RPC 8.2 (Judicial and Legal
Officials); and RPC 8.4 (Misconduct).
WHEREFORE, Complainant prays as follows:
1. That a hearing be held pursuant to Nevada Supreme Court Rule 105:
2. That Respondent be assessed the costs of the disciplinary proceeding pursuant to Supreme
Court Rule 120(1); and
3.That pursuant to Supreme Court Rule 102, such disciplinary action be taken by Northern
Nevada Disciplinary Board against Respondent as may be deemed appropriate the circumstances."

INDEX TO EXHIBITS 8/23/12 Complaint SBN v. Coughlin, NG12-0204, NG12-0434, NG12-0435:
1. Exhibit 1: -11/30/11 RMC Judge Howard Judgment of Conviction and Court Order in 22176 candy
bar; -3/15/12 Judge Elliott Order Affirming Ruling of the RMC in appeal CR11-2064
2. Exhibit 2: 11/30/11 RMC Judge Howard Order for Summary Punishment of Contempt Committed
in View and Presence of the Court in 11 CR 22176
3. Exhibit 3: 3/12/12 RMC Judge Nash Holmes Order of 3/12/12 with "clear and convincing"
language.








Coughlin's Objections to particular FINDINGS OF FACT
Exhibit 16 should have only been admitted if a legible copy of it was produced alogn with all
exhibits (including cd/dvds listed and or attached thereto, rule of completeness, and both of Coughlins's
Exhibits 14 and 15 should have been includedin 16, and Coughlin was not provided a copy at the time
16 was introduced of Exhibit 16.1
follows:
"Coughlin is an attorney licensed to practice law in the State of Nevada"...if that is correct,
than even with Coughlin proving the SBN/NNDB?Panel gave him the power to issue his
own subpoenas, the Motions to Quash and objections by Kandaras and DDA Watts-Vial
were ineffective and contempt and continuance should have sprung forth. Coughlin has
been told by SBN he is "a former attorney" and "temporarily suspened". Further, it is
patnetly inaccurate and or negligent to find that "At all relevant times prior to and at the
time of the filing of the Complaint in this matter, the Respondent's principle office,,,,
was Post Office Box 3961, Reno, NV 89505" Wrong. Wrong. Wrong. See Coughlin's trail
of paper to the SBN informing it the many address changes stemming form the initial
wrongful summary eviction Coughlin filed with the SBN a Change of Address:
("all times relevant", considering NG12-0435 is apparently the three and half year old attorney's
fee sanction of 4/14/09 by Judge L. Gardner, would go back a ways...but:
"FW: member attorney address change? From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/21/11 4:27 AM To: suzannew@nvbar.org Dear Suzanne, I forgot to
included my Suite number earlier, #2: 817 N. Virginia St., suite #2, Reno NV 89501. From:
zachcoughlin@hotmail.com To: suzannew@nvbar.org Subject: member attorney address
change Date: Mon, 21 Nov 2011 03:51:34 -0800 Dear Suzanne, I am writing to indicate that
I have changed my address. I don't know whether it will be a temporary or permanent
change. I am seeking a stay of an eviction order in Reno Justice Court from my home law
office, where I argued a retaliatory eviction defense, amongst others....for now I am set up at
the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501. Richard G. Hill,
Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I
have a temporary cell of 775 229 6737, though email is probably more reliable and quicker,
it remains zachcoughlin@hotmail.com. Further, I still have my voxox.com fax number of
949 667 7402. Sincerely, Zach Coughlin, Esq. 121 River Rock St. Reno, NV 89501 775 338
8118 Licensed in Nevada"
"Subject: member attorney address change From: Zach Coughlin
(zachcoughlin@hotmail.com) Sent: Sat 12/31/11 12:09 AM To: suzannew@nvbar.org
Dear Ms. Walters, Sorry to have to do this again, but I am writing to update my address
again, it is: PLEASE NOTE, I HAVE A NEW, NEW ADDRESS for all purposes and to
please be listed at www.nvbar.org: Zach Coughlin, Esq. 1422 E. 9TH ST. #2 RENO, NV
89512 tel: 775 338 8118 fax: 949 667 7402 ZachCoughlin@hotmail.com Nevada Bar No:
9473"
"RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.Zach










Coughlin (zachcoughlin@hotmail.com) 4/16/12 To: suzannew@nvbar.org,
patrickk@nvbar.org, davidc@nvbar.org, glennm@nvbar.org Dear Suzanne, Thanks...I check
the portal and notice that too, sorry I meant to write you back and say "nevermind"...I am
sorry to have had to change my address so much recently, I know it is probably more
work for the Bar. Sincerely, Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505,
tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
From: SuzanneW@nvbar.org To: zachcoughlin@hotmail.com Subject: RE: CORRECTION
CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ. Date: Mon, 16 Apr 2012
21:44:47 +0000 That is what we have Zach From: Zach Coughlin
[mailto:zachcoughlin@hotmail.com] Sent: Monday, April 16, 2012 2:39 PM To: Suzanne
Walters; support@baralliance.com; renodirect@reno.gov; courtadmin@washoecourts.us;
courttech@washoecourts.us; joey.hastings@washoecourts.us;
joey.orduna@washoecourts.us; craig.franden@washoecourts.us;
kstancil@washoecounty.us; stuttle@washoecounty.us; rbaker@washoecounty.us Subject:
CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
Dear State Bar of Nevada, 2nd Judicial District Court, Reno Justice Court, et al, Please
let me clarify and or change my recent communication. In my last correspondence I made a
misstatement based upon my misreading of SCR 79. Please allow me to correct that. My
preferred mailing address and my SCR 79 address should be the same, as listed directly
below: Zach Coughlin, Esq. PO BOX 3961 Reno, NV 89505 Tel: 775 338 8118 Fax: 949
667 7402 email: ZachCoughlin@hotmail.com website:
www.ZachCoughlinEsq.wordpress.com please make all the above information my preferred
mailing address and publicly available. As for any alternate mailing address, please change
that to: Zach Coughlin, Esq. 945 W. 12th St. Reno, NV 89503 I will attempt to make these
changes myself at the "portal" found at www.nvbar.org in the member section, however, I
am contacting you now in an abundance of caution. Sincerely, Zach Coughlin, Esq., PO
BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473"
"Subject: my new address? Zach Coughlin (zachcoughlin@hotmail.com) 10/23/12
To: patrickk@nvbar.org, davidc@nvbar.org, rosec@nvbar.org, complaints@nvbar.org Dear
Bar Counsel, I am still very afraid of retaliation by local law enforcement, and due to
my status as a domestic violence victim. In the past, I have offered to assistn you in
getting me served appropriately, but have received no follow up. Further, the SBN, via
Investigator/Clerk Peters and otherwise have made representations that I have relied upon to
the extent that another certified mail SCR 105 Complaint would be sent out shortly after my
communications with Peters on September 11th, 2012 or so where she admitted to receiving
in the mail the one she said she sent on August 23rd, 2012. Whatever the SCR 109
implications, the SBN's promises made by Peters are binding in that regard... Nonetheless, I
now feel forced to provide you my address and expose myself to even greater danger,
particularly where, some might say, the SBN has a vested interest in discrediting me now, a
motive, a bias, some might say (I take no position in that regard at the current time). Please
note my new phone number as well. While Mr. King has referred to some upcoming
SCR 105 hearing (a "combo hearing" akin to the one's, including a Trial that DDA Young
and his crew of Washoe County Public Defenders have been trying to run on me this year,
including attempting to hold a Trial on May 7th, 2012 in RCR2011-0063341 where the
Order finding me competent and remanding jurisdiction to the Justice Court in CR12-0376
was only signed, entered, and file stamped on May 9th, 2012...A big no-no under NRS
178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for given his








communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and
12 CR 12420. This could be your Waterloo, so I hope you will investigate this properly.
Especially considering the Order granting Loomis' withdraw in the criminal trespass case
Mr. King just filed an SCR 111 petition in occurred during the pendency of such an
evaluation on May 8th, 2011 (lots going on between May 7th-May 9th, 2012, here!) and the
fact that Loomis and or the RMC ramrodded a Trial setting of June 18th, 2012 on May 8th,
2012 as well, well before Coughlin's competency was determined...and to the extent King
indicates NG12-0204 and NG12-0435 rely on "Orders" entered or rendered during periods
in which NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no
good. Please don't make my address public yet or disseminate it in any way. Sincerely, Zach
Coughlin 1471 E. 9th St. Reno, 89512 Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com"
Note: Coughlin's SCR 79 address was update via the online portal in March 2010 to 121
River Rock St., Reno, NV 89501.
"Subject: Address Change To see messages related to this one, group messages by
conversation. Zach Coughlin (zachcoughlin@hotmail.com)7/07/09 To:
suzannew@nvbar.org Outlook Active View 1 attachment (16.3 KB) Change of Address for
Zach Coughlin Esq.pdfDownload Download as zip Dear Suzanne, Please accept the
attached Change of Address (which I sent as a fax as well, just in case). Please note it now
includes a fax number. Sincerely, Zach Coughlin, Esq. (931 Forrest St, Reno, NV 89503
listed on SCR 79 form attached"
"RE: Address Change Zach Coughlin (zachcoughlin@hotmail.com)5/28/09 Photos To:
suzannew@nvbar.org Outlook Active View 2 attachments (total 411.7 KB) state bar change
of address pdf.pdf Download all as zip Dear Ms. Walters, I have looked through my email
and do not see such an email. I did reply to an email from you indicating that my earlier fax
only contained the notice of insurance, and not the Change of Address form. So, I emailed
you my signed Change of Address form. I hope there was not a problem with it. I am
attaching another copy to this email. Please let me know if there is any problems with these
attachments. Sincerely, Zach Coughlin, Esq. My new contact information is: Zach
Coughlin, Esq. 945 W. 12th St. Reno, NV 89503 Tel: 775 338 8118 email:
zachcoughlin@hotmail.com I do not have a fax at this time. Subject: Re: RE: Address
Change From: suzannew@nvbar.org To: zachcoughlin@hotmail.com CC: Date: Tue, 26
May 2009 20:06:58 +0000 Hi Zach, Did you receive my last email regarding your scanned
change of address form? Suzanne Walters Member Services Assistant suzannew@nvbar.org
State Bar of Nevada 600 E. Charleston Blvd. Las Vegas, NV 89104 (702) 317-1430 direct
(702) 382-2075 fax (702) 382-2200 main (800) 254-2797 toll free On Wednesday, May 20,
2009 12:32:28 PM, Zach Coughlin wrote: Dear Suzanne, Thank you for letting me know.
Please accept the attachment to this email as it contains my change of address form, signed.
Sincerely, Zach Coughlin, Esq. tel 775 338 8118"
The thing is, Pat King is one of the most important lawyers in the entire state...but only
because of what a terrible lawyer he is and the fact that his job as bar counsel has so much
say in how the practice of law in Nevada is protected, cultivated, and refined. While it
might be asking a bit much of King to address a culture of permissiveness as to police
misconduct, and the longstanding cronyism that infests Disciplinary Boards and State Bar






Committees (Character and Fitness Committee Chairman and decade long member of said
C&FC Kevin Kelly, Esq. nearly destroyed Coughlin's career ten years ago, all to fee Mark
Tratos' garguantuan ego, and all while owning and running a monolithic Las Vegas Strip
Club, the Spearmint Rhino.
One cannot understate the many ways in which that rev2011-001708 case provides
an example of what happens when none of the due process safeguards or protections most
civilized jurisdiction affords tenants (not to mention tenants combining both their residence
and place of business)...destruction, a human cost that extends far beyond the intial tenant
and his family, but, as here, into thousands and thousands of dollars of local resources
addressing the fallout attendant to the RJC demanding Coughlin deposit $2,275 in rent
escrow disallowed under Nevada Law (until the RJC complies with JCRCP 83 and gets
such a local rule published and approved by this Court, to provide a corollary to JCRLV
Rule 44), then presents a pastiche of summary dispossesory proceedings and plenary
unlawful detainers the feature only those aspects least advantageous to a tenant (prohibited
from asserting counter or cross-claims, nor NRS 40.253(6) "the court shall make no further
Order" application upon Judge Sferrazza ruling that Coughlin had "established a genuine
issue of material fact" (something Baker and Hill dispalyed a lack of candor about in
assiting Judge Sferrazza in remixing that Order on at the "Trial" on 10/25/12, which was
then recharacterized as a mere continuation of the opporutnity Coughlin had to establish a
prima facie showing as to the variosu defenses he proferred...then to Order Coughlin evicted
(if Judge Sferrazza felt compelled to "give" Coughlin more time than usual (or, even
allowable under NRS 40.253 before the Order provides the Sheriff is to "remove" from the
property all present at the River Rock office (notice the Order does not say "you are warned
that you will be trespassing if you remain", and it does not tell the tenant "you are being
Ordered to leave"...it merely directs the Sheriff to "remove" all those there (somethign City
Attorney Hazlett-Stevens, eSq. an Baker had a bit of trouble getting right during Hazlett's
direct examination of Baker at the trespass trial on 6/18/12 from which RMC Judge W.
Gardner refused to recuse himself.... in compliance with SCR 79 When Coughlin has
provided both Bar and Panel (see the over 1,000 page collection of emails from Coughlin to
@nvbar.org addresses replete with an index and the attachmetns or skydrive links included
thereto and therein, included Coguhlins' prescription medication history showing he was
unable to afford two pyschotropic medications on August 2nd, 2011 (Adderall (taken for
ADHD and treatement resistant depression) and Wellbutrin (buproprion) take for Major
Depressive Disorder and though to help via an off lable use for some Obsessive Compulsive
tendencies Couglin has exhibited throught his lifetime. Life many individuals with ADHD
and OCD, Coughlin tends to gravitate to activities requiring and or providign a high degree
of stimulation, and in certain contexts, actually has a hyperfocus somewhat common
amongst this population. Coughlin had some success as a basketball player in high school,
being listed twice in USA Today as one of the ten or so players from Nevada recognized
nationally, and Coughlin is the only player from a high school in Nevada to be listed for
anything in the National Federation of High School's Record Book Boys Basketball section
for is 65.4% shooting percentage in 1995 for Reno HS (Coughlin graduated from Reno
High School as the school's then all-time leading scorer with 1,468 points and his 661 points
in 1995 is still the most in a season for any player from that, Nevada's older high school).
and was arrested on 8/20/11 for the what became a petty larceny charge in 063341, which the
RJC allowed DDA Young to amend to include a receiving stolen property charge despite
being provide mandatory authority in State v. Shepp which made the charging document
deficient in light of it alleging Coughlin to have received the property he allegedly stole








from himself...Coughlin did not steal anything, regardless, or commit any sort of theft of
"serious offense". It was fraudulent for Pat King to stand behind Hearing Exhibit 1 at 0001,
lines 7-10 and maintain that (and demonstrative of the laissez fair approach the Panel has
taken, though with a troubling willinness to Quash Supboenas Ex Parte, etc., etc. THIS
CASE WAS LARGELY ABOUT SUMMARY EVICTIONS AND THAT FALLOUT
FROM THE BOTTOM DWELLER APPROACH NEVADA HAS RESPECTING
TENANT'S RIGHTS IN AMERICAN JURISPRUDENCE, FURTHER CHANGE OF
ADDRESS ISSUES WERE INTEGRAL TO COUGHLIN'S SCR 105(2)(C) DUE
PROCESS DEFICIENCY ARGUMENTS.
"Subject: SCR 111 Zach Coughlin (zachcoughlin@hotmail.com) 2/22/12 To:
glennm@nvbar.org, davidc@nvbar.org From: Zach Coughlin
(zachcoughlin@hotmail.com) Sent: Wed 2/22/12 10:19 PM To: glennm@nvbar.org;
davidc@nvbar.org Dear Bar Counsel Clark and Assistant Bar Counsel Machado, I contacted
you and the State Bar of Nevada recently (about a month ago) in regard to SCR 111. I had to
move recently and moved in with two individuals who I ultimately wound up getting
Protection Orders against, and they have interferred with my ability to receive my mail
with absolute certainty (I have received much of my mail, and have pending
correspondences/requests with the Postmaster for Reno, NV to obtain a permanent and
newly rekeyed lock and key to access my mailbox...I have been informed by USPS Reno
Postmaster agent named Mr. Heister that if I fax him proof of my location at 1422 E. 9th St.
#2, he will then allow me to get a mailbox key made...I faxed him proof and will call him
again tomorrow to see how much longer I must wait....if its much longer I will make
alternate arrangments, however, I am an electronic filer in both courts that I am appearing in
(NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that
you or the State Bar of Nevada may have for me or may have mailed to me be, if
possible, copied to me via my fax number or email address. Sincerely, Zach Coughlin,
Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473"
"supplemental FW: Attorney reporting under SCR 111? From: Zach Coughlin
(zachcoughlin@hotmail.com) Sent: Mon 1/23/12 4:19 PM To: davidc@nvbar.org Dear
Bar Counsel Clark, I am not sure it applies under SCR 111, but I was also found guilty (in
the same matter in Reno Municipal Court 11 CR 22176) of NRS 22.030: "NRS 22.030
Summary punishment of contempt committed in immediate view and presence of
court;affidavit or statement to be filed when contempt committed outside immediateview
and presence of court; disqualification of judge. 1. If a contempt is committed in the
immediate viewand presence of the court or judge at chambers, the contempt may be
punished summarily. If the court or judge summarily punishes a person for a contempt
pursuant to this subsection, the court or judge shall enter an order that: (a) Recites the facts
constituting the contempt in theimmediate view and presence of the court or judge; (b)
Finds the person guilty of the contempt; and (c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge
at chambers, an affidavit must be presented to the court or judge of the facts constituting the
contempt, or a statement of the facts by the masters or arbitrators. 3. Except as otherwise
provided in this subsection, if a contempt is not committed in the immediate view and


presence of the court, the judge of the court in whose contempt the person is alleged to be
shall not preside at the trial of the contempt over the objection of the person. The provisions
of this subsection do not apply in: (a) Any case where a final judgment or decree of the
court is drawn in question and such judgment or decree was entered in such court by a
predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings
for the violation of the judgment or decree. (b) Any proceeding described in subsection 1 of
NRS 3.223, whether or not a family court has been established in the judicial district." My
understanding of the expressed rationale for the Contempt finding is that it related to my
saying "Wow" in relation to a particular ruling of the Court, and continuing lines of inquiry
after the Court rule against me on a particular objection, as well as, I believe, "derogating
the authority of the Court". Sincerely, Zach Coughlin From: zachcoughlin@hotmail.com To:
davidc@nvbar.org Subject: Attorney reporting under SCR 111 Date: Mon, 23 Jan 2012
15:17:52 -0800 Dear Bar Counsel Clark, It has recently come to my attention that Nevada
Supreme Court Rule 111 may apply to a criminal conviction I received (and for which an
appeal is currently pending) in Reno Municipal Court in case RMC 11 CR 22176 for the
offense of petit larceny of a chocolate bar and some cough drops.
Supreme Court has obligation in disciplinary proceeding to look beyond label given
to attorney's conviction to true nature of facts, in order to determine whether underlying
circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar
of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Sincerely, Zach Coughlin, Esq.
1422 E. 9th St. #2 RENO, NV 89512 tel: 775 338 8118 fax: 949 667 7402
ZachCoughlin@hotmail.com Nevada Bar No: 9473"
T284: BY MR. COUGHLIN: Q Can you tell me more about some of the procedural violations
and due process violations that have been attendant to this proceeding? A Sure. Answer,
sure, I would love to. Mr. King and/or Miss Peters, who seem to have signed certificates of
mailings for both the State Bar, and for the panel chair, which might be what the rule entails,
but they have mailed out and/or purported to serve upon me a notice of hearing and
designation of witnesses summary of evidence that they purport was placed in the mail by
certified mail on October 12th. However, upon reviewing the USPS Website track and
confirm system, it indicates that the first scanning of that item into the UPS system was on
October 16th. I moved. On approximately September 27th-ish I moved. SCR 79, I believe,
requires that I update my (Page 285) address within 30 days for the State Bar. Not
necessarily a physical address, as Mr. King seemed to indicate earlier, but I believe a
mailing address. I believe I did that, in that I believe it was -- at least with the CLE board I
believe I updated the address sometime around October 10th, maybe earlier. I know, and I
believe it's in the materials that I have submitted on file in this matter, that I believe it was
October 23rd I sent an e-mail to the State Bar, and it might have been a fax to Mr. King, and
I typically copy Mr. Clark on it that said, you know what, I haven't wanted to give out my
address because I'm afraid of local law enforcement. I've been incarcerated ten times this
year. There seems to be a clear-cut retaliatory animus against me, and I just haven't felt
comfortable. And I have been adjudged a victim of domestic violence, sometime, I believe,
in February 2012. MR. ECHEVERRIA: Mr. Coughlin, your question was addressed to







procedural violations, and now you're wandering away and talking about incarcerations.
Would you focus on the question? Have you finished your answer to your question? MR.
COUGHLIN: No, sir. They go to the address. And the reason I bring that up, and I'm sorry I
had to go off into that is that that DowSoE and notice of Page 286 hearing that he purports.
He by way, I believe, of Laura Peters, signed the certificate of mailing saying the2
certified mail version was put in the mail on the 12th.At first scan on the tracking
confirm on the 416th it shows on -- USPS track and confirm is on-line.You can type in
the number of the certified mail. It6 shows the first time it was placed in my mailbox
was7 October 22nd.I believe the reason it took five days was9because I filed a change
of address from my post office10 box, which was expiring. I changed it to my new
physical11 address on East Ninth Street. So I changed it from the12 P.O. Box 3961. I
know I submitted it in my hand via hand13 delivery to the Vassar station on, I'm
pretty sure on14 October 5th, because that was the day my post office box15 was
supposed to run out; I submitted that change of address.It's my understanding it can
take some time for those to actually process. You get the yellow stickers. And I believe
that might be the reas on that it20 took from scanning that DowSoE notice of hearing on21
October 16th all the way to October 22nd before it was available in my, either in my
mailbox or my new physical address or I was still getting mail in my old P.O. box.And in
fact the key is still working right now. Page 287 MR. ECHEVERRIA: Let me just try to
help you. You have about -- I'll afford you two more minutes if you would like to address
other issues. Specifically I'm interested in having you address the issues the supreme court
asked us to look at, and that is what the nature and extent of the punishment should be. Do
you have any questions on that topic? MR. COUGHLIN: Well, I think getting this whole
hearing thrown out is in my best interests. And the fact that all the procedural safeguards of
SCR 1052(c) have been violated is my best avenue to do that. Further, I believe the extent to
which this court has -- I'm testifying right now, so I'm going to get this in. Mr. King has
evinced a -15 MR. ECHEVERRIA: You have told us your view of Mr. King. I'm asking you
-17 MR. COUGHLIN: I'm going to the notice of intent to take default, whether I got it. MR.
ECHEVERRIA: Mr. Coughlin, I'm asking you specifically. Do you wish to present any
evidence with respect to the supreme court's directive that this panel is to determine the
nature and extent of any punishment you should suffer as a member of the State Bar? MR.
VELLIS: Or any mitigation. Page 288 MR. ECHEVERRIA: Or any mitigation? MR.
COUGHLIN: Mitigation. I've been diagnosed and treated with ADD. I hate admitting this
on the record. Also major depressive disorder. My girlfriend of 4 1/2 years, my domestic
partner, in August -- no. She finally graduated in June -- no, May 15th. Two days later she
moved out. She hadn't told me for at least, I believe May and June, she took the rent portion
that I normally gave her and she would forward on, and instead she kept it and started a new
life with it when she moved out. I wasn't aware of that until sometime in August. August
11th the landlord sent me an e-mail. I was arrested on August 20th for the iPhone thing that
there's a trial on the 19th. 17 days later I was arrested on the Walmart thing. August 2nd I
canceled an appointment with Dr. Yasar, my psychiatrist, because I couldn't afford it or the
medications. I reached out to my family. There was some ill will incident of the breakup of
my domestic relationship. I didn't receive any help from anybody. I went off my
medications because I couldn't afford them. I did make several calls to NAMS, but given the
sensitivity of being on these medications and a lawyer, a professional, and the prejudice
attendant thereto, and the Page 289 fact that even if I went to NAMS they wouldn't cover
the ADD medication, and they would cover the antidepressant, which is also somewhat of a
dual-use medication. But long story short, I was running out of money, and I decided a lot
due to money, some due to desire to take a medication holiday. Just see, when you take




these things long enough, sometimes you want to see what it's like not taking them. I went
off those medications, probably too abruptly, at the start of August. MR. ECHEVERRIA:
What year? MR. COUGHLIN: '11. Within like 20 days all of a sudden the iPhone arrest
that's pending right now, and I maintain my innocence on that. It sounds like a ridiculous
law school effect pattern. But essentially if this is a hypothetical exam in law school, it
would be some guy finds an iPhone on the ground in a skate plaza in downtown Reno at
11:15 at night on a Saturday, and holds it aloft offering it up to the denizens of the skate
plaza. Then he says something to the effect of, come on, somebody, claim this. I'm going to
throw it into the river. And at that time people will allege that I claimed the phone. And then
there's some suggestions -- there's some ambiguity, some might say, as to whose phone it is
at Page 290 that point. Whether it would be in the river, is that lost, mislaid property is
larceny. Does a police officer have a right to coerce you into consenting to search. There is a
video -- I gave you a video of the arrest -5 MR. ECHEVERRIA: Could you focus for us on -
6 MR. COUGHLIN: The mitigation. MR. ECHEVERRIA: -- the factors -- let me ask this
question. Do you believe that any of the issues that you have described impair your ability
to practice law and adequately represent clients? MR. COUGHLIN: I believe when I'm not
under such -- getting arrested, spending six days in jail, getting out, finding an eviction
notice on my door. An eviction which I would maintain is against the law, a summary
eviction, where nonpayment of rent is not pledged against a commercial tenant. There's laws
against that for a reason, because it can murder your business, and it's a huge fallout
personally. So I get arrested. Spend six days in jail. I maintain it's a wrongful arrest. I might
not have done everything perfect, but I do believe if you look at it, look at the criminal law,
you might agree with me the arrest was wrongful. Page 291 MR. ECHEVERRIA: My
question was not whether that arrest is valid or invalid, but whether or not the conditions
that you described you feel you suffer from impair your ability to practice law and/or
represent, adequately represent clients? MR. COUGHLIN: No. No. And I think if you had
been with me through all this you would be impressed -8 MR. ECHEVERRIA: Do you have
-9 MR. COUGHLIN: -- by my dedication to my clients and the level of work product I
churn out, especially considering the remuneration I've received from those clients. I have
basically worked for minimum wage doing people's custody, people's foreclosure defense,
adversary proceedings in bankruptcy. And there was a noncompete case I think -- I'm not
happy with how my life has gone. I'm not happy with all this drama and problems with the
courts. But -18 MR. ECHEVERRIA: While we're on that. Do you recognize any symptom
of validity in some of the language used by Judges Gardner, Judge Nash Holmes, and their
orders in which they find you in contempt? Do you recognize that there may be some
validity in what they say? MR. COUGHLIN: I think it is important to know Page 292 when
to just accept what the judge says for the dignity of the court, and to know that fine line
between standing up for what you think is right, and not continuing to push past the point
where it's -- my own best interests or where it damages the standing or appearance of the
legal profession in general. MR. ECHEVERRIA: Do you feel a sense of remorse for the
way you conducted yourself in front of judges, both Judges Gardner and Judge Nash
Holmes? MR. COUGHLIN: Yes. MR. ECHEVERRIA: How so? MR. COUGHLIN: I wish
the result had been different. I think my heart was in the right place though. You know,"
I was standing up for the -14 MR. ECHEVERRIA: Do you feel that any -15 MR. COUGHLIN:
-- the domestic violence victim in the Joshi case, because I felt she deserved a swing at the
bat for alimony. She said that she was looking to me and imploring me to advocate on her
behalf there. With respect to the Judge Nash Holmes case, there's a lot of ancillary matters
that this panel told me they simply don't find relevant. MR. ECHEVERRIA: Do you regret






any of the conduct that you exhibited in either Judge Linda Gardner's, Judge Gardner or
Judge Nash Holmes' courtroom? Page 293 MR. COUGHLIN: Sure. MR. ECHEVERRIA:
What conduct do you regret having entered? MR. COUGHLIN: I do think it would have
been preferable for me to have been able to better articulate to Judge Gardner the basis for
the position I took. I think my position -- I generally cited to an ALR article that I had
reviewed previous to that trial for which the title was something to the effect of a domestic
duty, impermissible to set it off with a debt, a duty greater than a debt accorded greater
significance under the law. But I didn't give her the presentation that a more"
Mental or emotional disturbance as defense to or mitigation of charges against attorney in
disciplinary proceeding, 26 A.L.R.4th 995 Validity and application of regulation requiring
suspension or disbarment of attorney because of mental or emotional illness, 50 A.L.R.3d
1259 Trial Strategy Mental or Emotional Disturbance as Defense or Mitigating Factor in
Attorney Disciplinary Proceeding, 46 Am. Jur. Proof of Facts 2d 563 Proof of narcissistic
personality disorder in mitigation of neglect and misrepresentation charges. Mental or
Emotional Disturbance as Defense or Mitigating Factor in Attorney Disciplinary
Proceeding, 46 Am. Jur. Proof of Facts 2d 563 15 to 26 Nonprofessional misconduct.
Defending Lawyers in Disciplinary Proceedings, 31 Am. Jur. Trials 633 6 Forms Am. Jur.
Pleading and Practice Forms, Attorneys at Law 59
2. "Coughlin was admitted as a member of the State Bar of Nevada on March 25, 2005" is
true, and he has now prior disciplinary record, though he has not been practicing law
continuously since 2005, in fact, for the most part, he worked a Hale Lane (now Holland &
Hart) for almost 5 months in 2005 ("creative differences" led to the band breaking up, but
Coughlin has nothing but appreciation for those marchants of swagger at Hale Lane who
gave him a start, helped him cut his teeth in the meat grinder of commercial litigation, and
were good for some laughs (though Coughlin's former senior partner/mentor of sorts at Hale
Lane, Judge Flanagan, surely will not be accused of "taking it easy" on his former junior
associate in light of the forty large attorney fee award levied against Coughlin the pro se
appellant of a summary eviction...However, Judge Flanagan is a crafty one (though you
wouldn't think he would become such a great judge one day if you were around to see some
of his line calls in the Tuesday night men's tennis leauge at Caughlin Club back 'round 'out
'90...I kid, I kid) and King and HIll were left to merely quote from Judge Flanagan's 6/25/12
Order the parts in which Judge Flanagan is merely quoting from HIll's associate's Motion
incident ot detailing the procecural hisotry of the case and the various arguments put
forward by the parties. Further, that Order specifically finds that Coughlin failed to file and
Opposition (Coughlin would have, but he was busy beign beaten by WCSO's Deputies in
jail incident to Judge Elliott "just not believing you when you say you will fully comply
with the Lake's Crossing Evaluator's, so I am going to remand you into custody for a
month" just to be sure Coughlin was successfully coerced out of any semblance of medical
privacy rights...(see official transcript of 4/19/12 hearing in cr12-0376)...Point it, Judge
Flanagan did not every actually find Coughiln was vexatious or abusive or any of that in his
6/25/12 Order. The Order simply recounted the arguments made by the parties as the to
Attorney's Fees Motion by Hill on 4/19/12, noted that Coughlin failed to Oppose it timely
(Coughlin did oppose it, just likely too early (in January before it was even filed), and too
late (when Couglin was released from the 8 day stay in County jail over the hissy fit Lake's
Crossing evaluator Bill Davis, Ph.D. threw upon Coughlin noting "I will have to check my
records on that" to Davis' first question, at which point Davis stood up from the table and





stormed off to write his lie filled letter about how Coughlin "threatened him with litigation"
despite the only the Coughlin said in that regard was he heard of some doctors who had
disclosed they take anti-depressants being unable to obtain malpractice insurance in
reference to Davis's previous question (Davis misleads in writing with the graceful elan of a
mid-season form WCPD Jim Leslie, and if he starts boning up on the LSAT now, he could
really do some broken field running by the time he passes the bar and gets on with the
NNDB.
3. On September 9, 2011, Coughlin shoplifted a candy bar and cough drops from a Wal-Mart
store with an approximate value of fourteen dollars ($14.00). On November 30, 2011,
Municipal Court Judge Kenneth R. Howard found Coughlin guilty of the offense of Petit
Larceny, a violation of RMC 8.10.040. Coughlin appealed the judgment of conviction. On
March 15, 2012, the Honorable District Court Judge Steven P. Elliot affirmed the judgment
of conviction on appeal. See Hearing Exhibit 1 at 0002, 5, lines 11-15; (State Bar of
Nevada vs. Zachary B. Coughlin, Esq., Case No: NGI2-0204, NGI2-0435, NGI2-0434,
Complaint at P2 (filed August 23, 2012).
4. Coughlin's conduct during the trial of the petit larceny case on November 30, 2011, in which
Coughlin appeared in propria persona, was so disruptive that Judge Howard found Coughlin
in direct contempt of court and sentenced him to jail that same day to be released on
December 3, 2011 at 8:00 PM. Judge Howard specifically found Coughlin's conduct to be
disorderly and was either contemptuous or behavior insolent toward the judge in that
Coughlin refused:
"... to obey directives of the Judge, continuing lines of inquiry after being advised by the Court to
refrain from doing so; demeaning the Court with statements such as "WOW" in response to court
rulings; laughing during testimony and further questioning the court and its authority."
See Hearing Exhibit 11 ORDER FOR SUMMARY PUNISHMENT OF CONTEMPT COMMITTED
IN THE IMMEDIATE VIEW AND PRESENCE OF THE COURT, November 30, 2011.
5. On June 7, 2012 the Suprem Court of the State of Nevada upon petition of Bar Counse
pursuant to SCR 111, ordered Coughlin temporarily suspended from the practice of law in
Nevada. The Order futher directed that the matter be referrred to the Appropriate
disciplinary board, as mandated by SCR 111 (8), with directions for the board to institute a
formal hearing "before a hearing panel in which the sole issue to be determined shall be the
extent of the discipline to be imposed." In the Matter of Discipline of ZACHARY B.
COUGHLIN, Esq., Bar No. 9473, No. 60838, June 7, 2012.
6. On November 15, 2011 Coughlin was arrested and charged with three violations of the
Reno Municipal Code. The charges of Failure to Provide Evidence of Security or Insurance (a violation
of RMC 6.06.555(a)) and Failure to Provide Vehicle Registration (a violation of RMC 6.06.560(a))
were dismissed at arraignment. On February 27, 2012 a trial was held in Reno Municipal Court before
the Honorable Judge Dorothy Nash Holmes on the remaining charge of a Right of Way Stop Sign
violation at an intersection (a violation of RMC 6.06.170(a)). Coughlin again appeared in propria
persona. The trial commenced at 3 p.m. and was concluded by the Court at 4:30 p.m., without a verdict,
after the court held Coughlin in criminal contempt of court for his behavior and activities committed
during the course of the trial and in the presence of the Court. See Hearing Exhibit 4. ORDER
FINDING THE DEFENDANT IN CONTEMPT OF COURT AND IMPOSING SANCTIONS.
7. Judge Nash Holmes ordered Coughlin into custody on February 27, 2012 and to be
incarcerated at the Washoe County Regional Detention Facility for the term of five (5) days.
Alternatively Coughlin could pay a fine of $500. The Court's sentence was based on its detailed







findings regarding Coughlin's conduct in his own defense.
"The court finds that defendant's contemptuous conduct consisted of his rude, sarcastic,
inappropriate, insubordinate, disrespectful, antagonistic, deceitful, disruptive, argumentative and
childish behavior during trial, all of which appeared to be done to vex and annoy the court, the
witness, and the opposing party, and to disrupt the trial process. The court finds that the following
occurred, and constitute contempt: 1) defendant's mimelike, clownish antics of making faces at the
court; sagging down into his seat and hanging his head; looking behind himself and inside his coat
as if searching for a better way to ask a question; rolling his eyes; and mimicking others words; 2)
defendant's incessant arguing with the court, talking over the court, and interrupting the court; 3)
defendant's repeatedly restating matters after being told by the court to "move on" or "ask the next
question;" 4) defendant's repeatedly injecting allegations of bribery, perjury, and police retaliation
into the matter after the court instructed him not to, and directed him to limit himself to issues
pertaining to the facts of the "Boulevard Stop;" 5) defendant's repeatedly trying to insert" Richard
Hill" into his questions and statements when such person was not relevant to the proceeding and the
defendant had been ordered to stop discussing that; 6) defendant's disregarding the rules of evidence
and court procedure by continually posing improper questions after being directed by the court to
properly phrase his questions 7) defendant's continually accusing the court of denying him the right
or ability to ask questions and telling the court to "give me a list of questions you want me to ask;"
8) defendant's suggesting that the court "tell me what would make you happy;" 9) defendant's lying
to the court in response to direct questions posed by the court with regard to his recording the
proceedings; and 10) defendant's failing and refusing to properly examine the witness, despite
numerous admonitions by the court to stop repeating questions, misstating answers, injecting
irrelevant material, arguing with the witness and mischaracterizing the testimony."
See Hearing Exhibit ORDER FINDING THE DEFENDANT IN CONTEMPT OF COURT AND
IMPOSING SANCTIONS.
8. The trial of the matter was continued to March 12, 2012. Coughlin failed to appear and
failed to contact the court to explain or excuse his absence. However, after serving the five-day
Contempt of Court sanction and after being released from custody, Coughlin fax-filed a 224-page
document entitled "Notice of Appeal of Summary Contempt Order; Motion to Return Personal Property
Confiscated by Reno Municipal Courts and Its Marshalls; Motion for New Trial and to Alter or Amend
Summary Contempt Order." See Hearing Exhibit 5, ORDER, P 2, lines 1-6.
9. Judge Nash Holmes observed that the pleading filed by Coughlin failed to address
most of the topics listed in the caption. Rather, she observed, the document contained rambling
references to Coughlin's personal life, his father's football career in college; dozens of pages of
string citations taken from the internet and other unrelated references. Judge Nash Holmes found
the pleading to be disjointed and incoherent and a "pathetic demonstration of what might once have
been legal and academic prowess that appears to now be greatly damaged." See Hearing Exhibit 5,
ORDER, P2, lines 9-15; P2, lines 16-20.
10. Judge Nash Holmes also found that Coughlin, after being released from custody
following the February 27, 2012 Contempt of Court incarceration, filed other nonsensical pleadings
including a 218 page document:
"...purported to be yet another motion in this case entitled "Motion to Return Cell Phones; Motion to
Set Aside Summary Contempt Order; and Notice of Appeal of Summary Contempt Order." With
scant discussion of, or relevance to, the above captioned matter, said document mostly argues
against Judge Howard in a Department 4 case and again contains more than 200 pages of string legal
citations; lyrics to rocks (sic) songs; Mr. Coughlin's personal family history; discussion of an
eviction case and another contempt case; disjointed legal citations and other nonsensical matters that
have no apparent relevance to his traffic citation case.






11. After observing that Coughlin's conduct had been inappropriate, bizarre, dishonest,
irrational and disruptive, Judge Nash Holmes concluded, by clear and convincing evidence,
that Coughlin had committed numerous acts of attorney misconduct, including, but not
limited to, violating Rules of Professional Conduct 8.4(c), 8.4(d), 3.3(a), 3.1, 3.2, 3.4(c), 1.3
and 1.1. See Hearing Exhibit 5, ORDER, P,3, lines 25-26; P4, lines 5-23.
12. Judge Nash Holmes also concluded that Coughlin violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011 by surreptitiously recording
the traffic court proceedings without advance permission and lying to the court when
questioned regarding the matter by denying that he had done so. See Hearing Exhibits,
ORDER, P,4, lines 24-28.
13. Judge Nash Holmes ordered, among other orders, that the traffic court matter be continued
and all proceedings relating to the traffic court matter be tolled pending referral of the matter to the
State Bar of Nevada. See Hearing Exhibit 5, ORDER, P,4, lines 7- 18,
14. On March 14, 2012, Judge Nash Holmes referred the matter of Coughlin to State Bar
Counsel David Clark and suggested the matter had some urgency. See Hearing Exhibit 8,
Letter dated March 14, 2012 from Reno Municipal Court Judge Dorothy Nash Holmes to
Office of State Bar Counsel, Nevada State Bar.
15. Judge Holmes testified at the hearing of this disciplinary matter that one of the purposes of
her March 14, 2012 Order was to provide the panel to hear this matter with clear and convincing
evidence, based on her experience and background as an attorney, prosecutor and judge that Coughlin
had violated numerous provisions of the Nevada Rules of Professional Conduct. See
Transcript of Proceedings of Wednesday, November 14, 2012, P 137, L 22 -P 138, L 9.
16. U.S. Bankruptcy Judge Bruce Beesley was called to testify at the hearing of this matter.
During the time frame 2011 to 2012, Coughlin appeared before Judge Beesley two or three
times as an attorney representing clients in a bankruptcy matter. On one occasion Coughlin
appeared wearing a T-shirt and a tie and no jacket. See Transcript of Proceedings of
Wednesday, November 14, 2012, P 10, L 10-16. Coughlin had filed a pleading in the
bankruptcy matter, on behalf of his client. Judge Beesley testified that the pleading was
"lengthy, didn't make any sense, and just sort of rambled through a great deal of irrelevant
stuff." See Transcript of Proceedings of Wednesday, November 14,2012, P 10, L 24 -P 11, L
1. On other occasions, although Coughlin appeared polite and intelligent, his pleadings and
arguments didn't make any sense. See Transcript of Proceedings of Wednesday, November
14,2012, P 11, L2-7
17. Judge Beesley became concerned, wrote a letter to the State Bar explaining his experience
with Coughlin and indicated that he did not believe Coughlin, in his current state, was able to
adequately represent his clients. See Transcript of Hearing Wednesday, November 14, 2012,P 13, L 24 -
P 14, L 7.
18. In Judge Beesley's opinion, Coughlin is not competent to practice law. See Transcript of
Proceedings of Wednesday, November 14,2012,PIS, L 11 -15.
19. State Bar Counsel called attorney Richard Hill to testify at the hearing of this matter: Mr.
Hill has been a member in good standing with the State Bar of Nevada for 33 years. See Transcript of
Proceedings of Wednesday, November 14, 2012, P 36, L 22 P 37 L 4. Mr. Hill was retained by Dr.
Merliss to assist Dr. Merliss in a landlord tenant dispute with his tenant Coughlin. See Transcript of
Proceedings of Wednesday, November 14, 2012, P 37, L14 -20. Mr. Hill represented Dr. Merliss in
Reno Justice Court and Washoe County District Court and two appeals to the Nevada Supreme Court in
the matters involving Dr. Merliss and Coughlin. See Transcript of Hearing Wednesday, November
14,2012,P 39, L 13 -24. Mr. Hill has also reviewed filings in of a case in which Coughlin is involved
with Washoe Legal Services. See Transcript of Proceedings Wednesday, November 14,2012, P 39, L 25
P 40, L 3.
20. In the eviction proceeding between Dr. Meriiss and Coughlin, Mr. Hill's firm obtained an
eviction order allowing Coughlin one week to vacate the premises. Ultimately, Coughlin
failed to comply with the eviction order and was convicted of criminal trespass. See
Transcript of Hearing Wednesday, November 14, 2012, P 41, L 18 -P 44, L 12.
21. On behalf of his client Dr. Merliss, Mr. Hill sought and obtained an order in favor of Dr.
Merliss and against Coughlin awarding Dr. Merliss attorney's fees in the amount of
$42,065.50. Washoe District Court Judge Patrick Flanagan entered the order on June 25,
2012. See Transcript of Proceedings of Wednesday, November 14, 2012, P 47, L 3-7. -See
Hearing Exhibit 2, P 3, L 10-11. The motion seeking attorney's fees was based on
Coughlin's conduct in the defense of the eviction matter, which conduct was characterized
as frivolous and vexatious and presumably so found by Judge Flanagan. See Hearing
Exhibit P 2, L 8-13; P 3, L 4-11.
22. Based on Mr. Hill's experience and background, his review of the pleadings in the litigation
between Dr. Merliss and Coughlin and his review of the pleadings in Coughlin's litigation
with Washoe Legal Services, Mr. Hill is of the opinion that Coughlin is not competent to
practice law. See Transcript of Hearing Wednesday, November 14, 2012, P 39, L 1 -12.
23. Based on Mr. Hill's experience in litigating with Coughlin, Coughlin was not truthful with
either counsel or the court. See Transcript of Hearing Wednesday, November 14, 2012,P 53,
L 6 -16. Mr. Hill felt that Coughlin's filings were abusive, at one point calling Mr. Hill's
associate a lichen. Coughlin has accused Mr. Hill of bribing the Reno Police Department to
have Coughlin arrested. Mr. Hill's staff is terrorized by Coughlin. See Wednesday,
November 14, 2012, P 54, L 4 -15.
24. State Bar Counsel called attorney Paul Elcano to testify at the hearing of this matter. Mr.
Elcano is the executive director of Washoe Legal Services that provides legal services to
indigents. See Transcript of Hearing Wednesday, November 14, 2012, P 88, L 25 -P 89, L
14. Coughlin was employed by Washoe Legal Services from August 29, 2007 to May 11,
2009. See Transcript of Hearing Wednesday, November 14, 2012, P 93, L 17 -20. Mr.
Ejcano became aware of an order entered by Judge Gardner on April 10, 2009 in the matter
of Joshi v Joshi and, as a result, reviewed the taped transcript of the hearing. See Transcript
of Hearing Wednesday, November 14,2012, P 94, L 22 -P 95, L 6.
25. Judge Gardner's order in the Joshi matter indicated that Coughlin had conducted no
discovery in the case and failed to present any documentary evidence at the trial of the
matter on behalf of his client Mrs. Joshi. See Hearing Exhibit P 12, L 4 -6. After
commenting on various negative aspects of Coughlin's representation of his client Mrs.
Joshi, (See Hearing Exhibit P 12, L 9 -P 13, L 40) Judge Gardner specifically held:
"The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic and disrespectful
presentation at trial; Mr. Coughlin's inability to understand a balance sheet; his failure to conduct
discovery; and his lack of knowledge with regard to the rules of evidence and trial procedure. All of
this was compounded with a continuously antagonistic presentation of the case that resulted in a
shift from a fairly simple divorce case to a contentious divorce trial lasting an excessive amount of
time. "
See Hearing Exhibit P 13, L 5 -10
26. Judge Gardner sanctioned Coughlin personally and awarded attorney's fees to Mr. Joshi in







the amount of $934 to be paid personally by Coughlin within 30 days of the order. See
Hearing Exhibit P 13, L 14 -17
27. Based on the order and Coughlin's conduct in the Joshi matter, Coughlin was tenninated by
Washoe Legal Services. See Transcript of Hearing Wednesday, November 14, 2012, P 110,
L7-8 28, In Mr. Elcano's opinion, Coughlin is not competent to practice law. See Transcript
of Hearing Wednesday, November 14, 2012, P 94, L 3 -8.
29. State Bar Counsel called Coughlin to testify at the hearing of the matter. Coughlin was
questioned with regard to a letter dated February 14, 2012 from Assistant Bar Counsel King
to Coughlin in which Bar Counsel forwarded to Coughlin correspondence received from
Richard G. Hill. See Transcript of Hearing Wednesday, November 14, 2012, P 163, L 13 -P
164, L 23. See Hearing Exhibit 6. Coughlin's response, dated March 9, 2012, asked for
additional time in which to respond. See Hearing Exhibit 7. No evidence was presented that
Coughlin substantively responded to Bar Counsel's letter of February 14, 2012 prior to the
filing of the Complaint in this matter. Coughlin failed to directly respond to Bar Counsel's
questions inquiring if Coughlin ever subsequently responded to Bar Counsel's letter of
February 14, 2012. See Wednesday, November 14, 2012, P 169, L 13 -P 172, L 16.
30. Coughlin also failed to directly respond to questioning regarding whether or not he had
substantively responded, prior to the filing of the Complaint in this matter, to a letter forwarded to him
from Bar Counsel regarding the letter received by the Nevada State Bar from Judge Dorothy Nash
Holmes and dated March 14, 2012. See Transcript of Hearing Wednesday, November 14, 2012, P 174,
L 13 -P 180, L 4. See Hearing Exhibit 8.
31. On March 7,2012 Coughlin caused to be filed an "Affidavit of Poverty in Support of Motion
to Proceed Informa Pauperis." See Hearing Exhibit 9. In his Affidavit, Coughlin represented that he
was self-employed as a "Jack of all Trades." See Hearing Exhibit 9. The Affidavit does not identify Mr.
Coughlin as a lawyer or identity any income from the practice of law. See Hearing Exhibit 9.
32. The record also indicates that Coughlin had also filed a motion on November 14, 2011 to
proceed In Forma Pauperis in case number I1CR 22176 pending in the Reno Municipal Court before
Judge Kenneth R. Howard. See Hearing Exhibit 10. Judge Howard's Order denying Coughlin's motion
specifically noted that Coughlin's "affidavit of poverty" did not identify any income from the practice
of law yet Coughlin had implied to the court when sentenced to incarceration for contempt that his
incarceration would adversely affect his clients. See Hearing Exhibit 10, P 2, L 19 -23.
33. Although Coughlin claims to suffer the impairment of attention deficit disorder, for
which he is prescribed medication and which medication he took on the day of his hearing, he does not
feel he needs any additional help. See Transcript of Hearing Wednesday, November 14, 2012, P 199, L
13 -P 204, L 9.
34. On August 23, 2012, the State Bar of Nevada filed its Complaint in this matter and served it upon
Respondent Coughlin by Certified Mail to his address then registered with the State Bar of Nevada. See
Docket. Complaint.
35. Not having received a response to the Complaint, on October 9, 2012 the State Bar of
Nevada filed and served on Respondent Coughlin, by certified mail, a "Notice of Intent to
Proceed on a Default Basis." The Notice attached an additional copy of the Complaint and
indicated that unless a responsive pleading to the Complaint was received by the State Bar
by October 24, 2012, the matter would proceed on a default basis. See Docket, Notice of
Intent to Proceed on a Default Basis.
36. On October 31, 2012 Panel Chair Echeverria issued the Panel's Order denying Coughlin's
"Motion to Dismiss" filed October 16, 2012; Denying Coughlin's "Motion for Order to Show Cause








Regarding Improper Attempt by Bar Counsel and, Possibly, NNDB to Delay and Obstruct Hearing
Required by Courts (sic) June 7, 2012 Order in Case No. 60838 and Coughlin's SCR 102(4)(d) Petition
in Case 61426 filed October 2, 2012; Granting Coughlin's Motion to Review and Inspect Bar Records
filed October 16, 2012 and Denying Coughlin's Motion to Bifurcate Hearing and Motion to Dismiss for
(sic) Complaint (sic) Failure to Sufficiently State the Charges with Specificity and Support and for
Utter Failure of Bar Counsel to Perform Reasonable Investigation." See Order Dated October 31, 2012.
In that Order, Chairman Echeverria further ordered that the Formal Hearing would proceed on a default
basis unless Coughlin filed a Verified Answer to the Complaint by November 9, 20 12. See Order
Dated October 31,2012, P 2, L 7-10.
37. Again on November 7, 20 12, Chairman Echeverria, in an Order Granting the State Bar's
Motion to Quash certain Subpoenas reminded Coughlin that unless a Verified Answer to the Complaint
was filed by 5:00 p.m. on November 9,20 12 the panel would proceed on a default basis. See Pleadings
Docket Order Dated November 7, 2012, P 2, L 8 -13.
38. Following a lengthy attempt to determine whether or not Coughlin believed he had
filed a timely verified answer or response to the State Bar's Complaint, Coughlin attempted, at the
hearing of the matter, to transform a pleading previously filed in the Reno Municipal Court into a "New
Verified Response (sic) Pre-Hearing Motion to Dismiss/Summary Judgment, Memorandum of Law
(See Hearing Exhibit 14) and to transform an "Emergency Ex Parte Motion to Dismiss ... " previously
dated November 12, 20 12 and altered at the hearing to reflect a date of November 14, 2012 into a
"Declaration and Verified Response." See Hearing Exhibits 15 and 16. See Transcript of Hearing
Wednesday, November 14,2012, P 244, L 16 -P 270, L II.
39. During the course of the hearing of this matter Coughlin continued to demonstrate a pattern
of conduct similar to, if not identical to, conduct in other forums for which he had repeatedly been
sanctioned. See Transcript of Hearing Wednesday, November 14,2012. Pleadings in this matter filed by
Coughlin were exceedingly lengthy, demonstrated a lack of focus and understanding of the issues
involved, were rambling and incoherent and contained discussion of irrelevant issues. See, e.g Hearing
Exhibits 14, 15, 16. See also, Pleadings Docket Motion for Order to Show Cause ... " dated October
2,2012; "Motion to Review and Inspect Bar Records ... " Filed October 16, 2012; Pleading entitled
"Well Would You Look at That ... " dated November 7,2012; "Emergency Ex Parte Motion To Dismiss
or Quash ... " Filed November 13,2012.
40. Coughlin's conduct at the hearing included conduct not reflected in the transcript of
the proceedings by way of facial gestures, body language, voice intonation and volume. See Transcript
of Hearing Wednesday, November 14, 2012, P 181, L 19-P 182, L 1.
CONCLUSIONS OF LAW
Based on the foregoing Findings of Fact,the Panel hereby issues the following Conclusions of Law:
(A) The Panel was designated by the northern Nevada Disciplinary Board Chair to adjudicate the
Complaint filed by the State Bar of Nevada against Zachary B. Coughlin,Case Nos. NGI2-0204, NG12-
0435 and NG12-0434 and to determine the extent of the discipline to be imposed pursuant to the
Nevada Supreme Court Order of Temporary Suspension and Referral to Disciplinary Board entered in
Case No. 60838, In the Matter of Discipline of Zachary B. Coughlin, Esq., Bar No. 9473, entered June
7,2012.
(B) The Panel has jurisdiction over the Respondent and the subject matter of these proceedings. See
Nev. Sup. Ct. R. 99.
(C) Venue in this matter is properly with the Northern Nevada Disciplinary Board and in the County
of Washoe, State ofNevada. Nev. Sup. Ct. R. 105.


(D) Coughlin received notice and a copy of the Complaint, notice of his right to respond, as
well as notice of the evidence and witnesses upon which the State Bar intended to rely at a formal
hearing. Notice of the formal hearing was served on Coughlin. Coughlin appeared in the matter, filed
numerous motions, appeared at the hearing of the matter, cross-examined witnesses and testified on
behalf of the State Bar and on his own behalf. Accordingly, the State Bar complied with the procedural
requirements of SCR 105.
(E) Coughlin was afforded ample opportunity to prepare a verified answer or response to the
allegations of the Complaint and failed to timely do so. See Findings of Fact 34, 3S and 36.
Accordingly, the matter could proceed on a default basis and the allegations of the Complaint deemed
admitted. SCR 10S(2) Notwithstanding the fact that the matter could have been decided on a default
basis, the Panel permitted the State Bar and Coughlin to present evidence.
(F) Submitted to the panel for decision are the following issues:
(1) Whether Coughlin violated RPC 1.1 (Competence).
(2) Whether Coughlin violated RPC 1.2 (Diligence).
(3) Whether Coughlin violated RPC 3.1 (Meritorious Claims and Contentions) (4)
Whether Coughlin violated RPC 3.3 (Candor to the Tribunal).
(5) Whether Coughlin violated RPC 3.4 (Fairness to Opposing Party and Counsel)
(6) Whether Coughlin violated RPC 3.5 (Impartiality and Decorum of the Tribunal)
(7) Whether Coughlin violated RPC 3.5A (Relations with Opposing Counsel)
(8) Whether Coughlin violated RPC 4.1 (Truthfulness in Statements to Others)
(9) Whether Coughlin violated RPC 4.4 (Respect for the Rights of Third Persons)
(10) Whether Coughlin violated RPC 8.1 (Disciplinary Matters)
(11) Whether Coughlin violated RPC 8.2 (Judicial and Legal Officials)
(12) Whether Coughlin violated RPC 8.4 (Misconduct)
(13) The extent of the discipline to be imposed pursuant to SCR 111 as a result of
Coughlin's conviction of the "serious" crime of Petit Larceny.
(G) The State Bar must prove by clear and convincing evidence that Coughlin violated RPC 1.1,
1.2,3.1, 3.3, 3.4,3.5,4.1,4.4, 5A (sic),8.1,8.2,and 8.4. See Nev Sup. Ct. R. 105(2)(e); In re Stuhff, 108
Nev. at 633-634, 837 P.2d at 856; Gentile v State Bar, 106 Nev. 60, 62, 787 P.2d 386,387 (1990).
Competence
(H) RPC 1.1 states "A lawyer shall provide competent representation to a client. Competent
representation requires the legal knowledge, skill, thoroughness and preparation reasonably necessary
for the representation."
(I) The record clearly and convincingly establishes that Coughlin lacks the competency to
represent clients, including himself.
(J) First, the record demonstrates severe criticism by the trial court in the handling of the Joshi
matter, including Coughlin's lack of understanding of a balance sheet, his failure to conduct discovery,
his lack of knowledge of the rules of evidence and trial procedure. Supra' 25





(K) Second, Judge Beesley testified that the pleadings filed by Coughlin on behalf of his client in a
bankruptcy case were "lengthy, didn't make any sense, and just sort of rambled through a great deal of
irrelevant stuff." Judge Beesley also testified that Coughlin's pleadings and arguments on behalf of his
client "didn't make any sense." Supra ' 16 Judge Beesley became concerned enough about Coughlin's
competency as a lawyer that he contacted the State Bar. Supra' 17
(L) Third, Judge Nash Holmes questioned Coughlin's competency as a lawyer and in her Order
fmding Coughlin in Contempt of Court noted that Coughlin disregarded the rules of
evidence, continually imposed improper questions, failed to properly examine witnesses,
repeatedly asked the question, misstated answers, injected irrelevant material, argued with
witnesses and mischaracterized testimony. Supra' 7
(M) Fourth, Judge Nash Holmes found that Coughlin's pleadings failed to address topics
listed 'in the caption, contained rambling references to Coughlin's personal life and other
irrelevant material, were overly lengthy, disjointed and incoherent. Supra' 9 & 10
(N) Fifth, the State Bar called two judges and two practicing attorneys (Couglin NOTE:Elcano is not
listed as an "active attorney" at www.nvbar.org, nor has he been for over 5 years), each with significant
experience with Coughlin and each of whom rendered an expert opinion regarding Coughlin's
competency as a lawyer. Judge Beesley testified that in his opinion, Coughlin was not competent to
practice law. Supra 18. Judge Nash Holmes testified that in her opinion, Coughlin violated numerous
Rules of Professional Conduct including his lack of competency to practice law. Supra 15. Attorney
Richard Hill also testified that in his opinion Coughlin is not competent to practice law. Supra 22
Attorney Paul Elcano, who once supervised Coughlin as a lawyer and ultimately terminated him from
Washoe Legal Services, also testified that, in his opinion, Coughlin is not competent to practice law.
Supra 28
(O) Sixth, the record establishes that Coughlin offered no expert opinion or evidence as to his
competency.
Diligence
(P) RPC 1.2 states "A lawyer shall act with reasonable diligence and promptness in
representing a client." The record is less clear as to whether or not Coughlin violated RPC 1.2 on more
than on occasion.
(R) Judge Howard, in the Joshi case, certainly found that Coughlin failed to conduct discovery
on behalf of his client in that matter. Supra 25
(S) The record and Pleading Docket in this case establish that Coughlin failed to provide a
verified responsive pleading even in the defense ofms own disciplinary action. Supra 38
(T) The record and Pleading Docket in this case establish that Coughlin habitually files
numerous, untimely and repetitive motions
Meritorious Claims and Contentions
(U) RPC 3.1 in pertinent part states "A lawyer shall not bring or defend a proceeding, or assert
or controvert an issue therein, unless there is a basis in .law and fact for doing so that is not frivolous,
which includes a good faith argument for an extension, modification or reversal of existing law."
(V) The record clearly and convincingly establishes that Coughlin continuously and
repetitively files irrelevant pleadings. Pleadings unrelated to the issue at hand and continuously and
repetitively injects irrelevant matters into proceedings.
(W) Judge Nash Holmes found, for example, that Coughlin repeatedly injected allegations of
bribery, perjury and police retaliation in a simple traffic case involving the failure to stop at a stop sign.
Supra 7 She also found that Coughlin repeatedly injected attorney Richard Hill into questions and
statements when Mr. Hill was in no way involved in the traffic citation trial. Supra 7 She also found





that pleadings filed subsequent to Coughlin's incarceration were lengthy (more than 200 pages)
contained scant discussion of, or relevance to, the matter and contained irrelevant discussion of facts
unrelated to the proceedings at hand. Supra. 10
(X) The record establishes that in the Merliss eviction action, Coughlin's conduct was so
vexatious and frivolous as to result in substantial sanction of attorney's fees. Supra 21 See
Hearing Exhibit 2, P 2, L 8 -13; P3, L 4 -11.
(Y) The Pleading Docket in this matter establishes also that Coughlin's filings, even in his own
defense of the disciplinary matter, inject lengthy, irrelevant facts and legal issues into this proceeding.
Candor to the Tribunal
(Z) RPC 3.3(a)(1) states "A lawyer shall not knowingly: (m)ake a false statement of fact or law
to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal
by the lawyer."
(AA) The record clearly and convincingly establishes that Coughlin violated RPC 3.3(a)(l) when he
lied to Judge Nash Holmes as to whether or not he was surreptitiously and without permission to record
(sic) the proceeding. Supra 7. Of note, Coughlin did not deny that he had lied to Judge Nash Holmes.
Instead, his cross examination of Judge Nash Holmes focused on how she had learned of the true facts.
See Transcript of Hearing Wednesday, November 14, 2012, P 139, L
(BB) Attorney Richard Hill testified that based on his experience in litigating with Coughlin,
Coughlin was not truthful with either counsel or the Court. Supra Paragraph 23.
(CC) The record also establishes that Coughlin was less than candid with the Court in two
separate applications to proceed in forma pauperis, when he failed to disclose his true
occupation as an attorney and instead indicated he was self-employed as a "Jack of all
Trades" and failed to identify any income from the practice of law after having represented
to the court that his incarceration would adversely affect his clients. Supra 31 & 32
Fairness to Opposing Party and Counsel
(DD) RPC 3.4(c) states "A lawyer shall not: (k)nowingly disobey an obligation under the
rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists."
(EE) The record clearly and convincingly establishes that Coughlin has a clear and
continuing pattern of knowingly ignoring and disobeying instructions from the Court.
(FF) In his Order of Contempt, Judge Howard found that Coughlin refused to obey directives of
the Judge and continued lines of questioning after being instructed to refrain from doing
so. Supra 4
(GG) Judge Nash Holmes, in her Order of Contempt, found that Coughlin incessantly argued
with the Court, interrupted the Court, repeatedly restated matters after having been admonished to
refrain from doing so, disregarded directives to ask properly phrased questions and disobeyed
numerous admonitions by the court to stop repeating questions, misstating answers, injecting irrelevant
material, arguing with the witness and mischaracterizing testimony. Supra 7 tribunal."
(HH) The transcript of the hearing in this matter clearly demonstrates that Coughlin repeatedly
and incessantly interrupts witnesses, counsel, Panel members and Panel Chairman and refuses to heed
admonitions to refrain from doing so. See generally of Wednesday, November 14, 2012.












Impartiality and Decorum of the Tribunal
(II) RPC 3.5(d) states "A lawyer shall not engage in conduct intended to disrupt a tribunal.
(JJ) The disruption must have occurred in the courtroom. One cannot disrupt a tribunal with
conduct outside of the courtroom. In re Michael Stuhff, 108 Nev. 629, 837 P.2d 853 (1992)
(KK) The record overwhelmingly, clearly and convincingly establishes that Coughlin repeatedly
conducts himself in a manner that is disruptive of the tribunal while in the courtroom.
(LL) The various orders of contempt or imposing sanctions issued by Judges Kenneth Gardner (sic),
Linda Gardner, Dorothy Nash Holmes and Patrick Flanagan each describe a similar pattern of conduct
and behavior that is intentionally disruptive of the tribunal. Supra 4,7, 10, 21 and 25
(MM) The transcript of the proceedings in this matter reveal a continuation of a similar pattern of
conduct by Coughlin despite his having been sanctioned twice with an adverse award of attorney's fees
and twice by incarceration. See generally Transcript of Wednesday, November 14, 2012.
Relations with Opposing Counsel
(NN) RPC 3.5A states "When a lawyer knows or reasonably should know the identity of a
lawyer representing an opposing party, he or she should not take advantage of the lawyer by causing
any default or dismissal to be entered without first inquiring about the opposing lawyer's intention to
proceed." (Judge Linda Gardner's former law partner Gayle Kern, Esq. in RJC Rev2012-000374,
perhaps? "It is absolutely fair, Your Honor..." to RJC Judge Jack Schroeder when he entered a default
summary eviction on 3/15/12 against Coughlin despite Coughlin having filed a Tenant's Answer of
substantial length and substance and Coughlin appearing, perhaps even on time, on 3/15/12 for the
Hearing (and an unlawful interruption of essential services hearing had already taken place against
Kern's client, though only the property manager showed up to play lawyer for PTTHHOA).
(OO) Although the State Bar pled a violation of RPC 3.5A in its Complaint, no evidence was
presented that Coughlin ever violated the rule. Accordingly, the Panel finds that the State Bar failed to
meet its burden of proof on this issue as an evidentiary matter but finds that as a matter of default the
violation may be deemed admitted.
Truthfulness in Statements to Others
(PP) RPC 4.1 (a) states "In the course of representing a client a lawyer shall not knowingly: (a)
(m)ake a false statement of material fact or law to a third person."
(QQ) Although the evidence established that Coughlin knowingly made false statements to
Court and Counsel (See (AA), (BB) and (CC no evidence was presented that Coughlin knowingly
made false statements of material fact or law to a third person. Accordingly, the Panel finds that the
State Bar failed to meet its burden of proof on this issue as an evidentiary matter but finds that as a
matter of default the violation may be deemed admitted. (this is a nonsense argument, especially where
the Panel and SBN pat themselves on the back for, allegedly, providing sufficient due process to
Coughlin/fulfilling SCR 105...its one or the other...but the Panel doesn't get to purport that Coughlin
default where it is also trumpeting the feats of due process it demonstrated....).
Respect for the Rights of Third Persons
(RR) RPC 4.4(a) states '"In representing a client, a lawyer shall not use means that have no
substantial purpose other than to embarrass, delay, or burden a third person... " (uh...like Hill's
allegations of finding a "crack pipe and a bag of weed" or a "vial of something" and "a large quantity of
pills"?).
(SS) The record establishes clearly and convincingly that in the Merliss eviction action,
Coughlin conducted himself in a manner that was abusive, vexatious and for purposes of delay. The
matter was a simple eviction action that apparently lasted through several proceedings at the Municipal





Court level, an appeal to the District Court and two appeals to the Nevada Supreme Court and which
also resulted in Coughlin's conviction for criminal trespass. Supra 19 and 20 Coughlin's conduct in
the proceedings was so egregious that Judge Flanagan ordered Coughlin to pay Dr. Merliss $42,065.50,
an amount that is still unpaid. Supra 21
(TT) The record also establishes that Coughlin habitually prolongs proceedings unnecessarily;
files lengthy, irrelevant, nonsensical pleadings requiring court, staff and counsel to spend unnecessary
effort in evaluating and/or responding to the pleadings. Supra 4, 7, 8, 9, 10, 11, 16, 21, 23, 25, 27,
39 and 40
Disciplinary matter
(UU) RPC 8.1(b) provides, in pertinent part, " ... a lawyer ... in connection with a disciplinary
shall not: (b) ... knowingly fail to respond to a lawful demand for information from an
(VV) The record clearly and convincingly establishes that Coughlin knowingly failed to
respond to the State Bar's request for information in the disciplinary proceeding and failed to timely file
a required verified responsive answer or pleading to the Complaint.
(WW) First, Coughlin asked for an extension of time to respond to the letter of February 14,
(XX) Second, Coughlin failed to respond to a subsequent letter from the State Bar regarding the
Complaint filed with the Bar by Judge Nash Holmes. Supra 30
(YY) Third, Coughlin ignored SCR 105(2) when he failed to timely file a verified response or
answer to the Complaint, despite several warnings to do so. Supra 34, 35, 36, 37, 38 Coughlin
compounded this violation when he attempted, during the course of the hearing in this matter, to
transform a pleading previously filed in Reno Municipal Court into a "New Verified Response (sic)
Pre-Hearing Motion to Dismiss/Summary Judgment, Memorandum of Law by crossing out the original
caption and handwriting the "new" caption. Supra 38
Coughlin also attempted, during the hearing, to transform a pleading he had filed the day before the
hearing entitled "Emergency Ex Parte Motion to Dismiss ... " by handwriting the words "Declaration
and Verified Response ... " onto the caption of the pleading. Supra 38
(ZZ) The conduct described herein not only demonstrates a lack of cooperation with the State
Bar, but a lack of competency as well.
Judicial and Legal Officials
(AAA) RPC 8.2(a) states "A lawyer shall not make a statement that the lawyer knows to be
false or with reckless disregard as to its truth or falsity concerning the qualifications or integrity of a
judge, adjudicatory officer or public legal officer. ..
(BBB) During the course of the hearing, Coughlin accused Judge Nash Holmes of lying during
her testimony. Coughlin has expressed similar views concerning Judge Nash Holmes in various
pleadings filed in this proceeding as well as others. Coughlin has also uttered other derogatory remarks
about various judges with whom he has interacted.
(CCC) The State Bar presented scant evidence on this issue and no evidence from which the
panel could conclude that the expressions were knowingly false as opposed to an expression of opinion.
While the conduct displayed is, in the view of the Panel reprehensible, the Panel concludes that the







State Bar failed to meet its burden of proof on the issue as an evidentiary matter but fmds that as a
matter of default the violation may be deemed admitted.
Misconduct
(DDD) RPC 8.4 provides (in pertinent parts):
It is professional misconduct for a lawyer to :
(a) Violate or attempt to violate the Rules of Professional Conduct...
(b) Commit a criminal act that reflects adversely on the lawyer's honesty, trustworthiness
or fitness as a lawyer in other respects;
(c) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation;
(d) Engage in conduct that is prejudicial to the administration of justice.
(EEE) The Pleadings, Hearing Exhibits and Transcript of these proceedings overwhelmingly,
clearly and convincingly establish a repeated, unrelenting and obstinate pattern of misconduct by
Respondent Coughlin evincing numerous and repeated violations of several provisions of RPC 8.4 in
violation of RPC 8.4(a). (So, would that not be something not noticed or plead in the Complaint, and
therefore, only appropriate in some future disciplinary hearing, if any? Otherwise, is that not
transmogrifying what is required to be a plenary hearing into one of a summary nature?).
(FFF) Coughlin was convicted of petit larceny on November 30, 201 1, a violation of RPC
8.4(b). Such violation is sufficient alone to trigger application of SCR 111. The Nevada Supreme Court
referred the matter to the appropriate disciplinary panel for a determination of the extent of punishment
that should follow from the conviction. Supra 5
(GGG) The record also establishes that Coughlin was convicted of criminal trespass in the
prolonged eviction proceedings involving Dr. Merliss, a violation of RPC 8.4(b). Supra 20
(HHH) The Complaint in this matter alleges that Coughlin has been arrested and is awaiting
trial on . a larceny charge involving a cell phone and on a charge of abusing 91 1 emergency
procedures. However, no evidence was presented on these charges but as a matter of default the
allegations may be deemed admitted and would constitute additional violations of RPC 8.4(b).
(JJJ) The record, as described at length above, establishes several violations ofRPC 8.4(c).
See (AA), (BB), (CC), (AAA), (BBB) and (CCC).
(KKK) The entire record in this matter is replete with instances demonstrating that Coughlin's
conduct is prejudicial to the administration of justice. Coughlin has been repeatedly sanctioned
monetarily and by way of incarceration for his conduct, has repeatedly filed lengthy, irrelevant and
nonsensical pleadings requiring staffs, courts and counsel to expend needless and unnecessary time in
responding to such pleadings, has repeatedly disrupted proceedings and failed to follow instructions
and admonitions of the courts. The record establishes that the pattern of conduct continues despite the
severe sanctions administered and continues up to and during the disciplinary process and hearing of




this matter.
The Extent of the to be imposed pursuant to SCR 111 As a Result of Conviction of the "Serious"
Crime of Petit Larceny.
(LLL) The matter of the referral from the Supreme Court was considered in conjunction with
the allegations in the Complaint filed by the State Bar. While the conviction at issue in the Supreme
Court Order of June 7, 2012 may not alone warrant the discipline recommended in this Panel's
recommendations, taken as a whole and in conjunction with the numerous and repeated other violations
of the Rules of Professional Conduct, warrant, in this Panel's view, the discipline recommended herein.
DECISION AND RECOMMENDATION
In assessing the form of discipline to recommend, the Panel has accounted for a number of
aggravating and mitigating factors that must be considered. The Panel finds that the State Bar has
shown by clear and convincing evidence the presence of at least eight of the eleven aggravating
circumstances to be considered in accordance with the provisions of SCR 102.5(1).
"SCR Rule 102.5. Aggravation and mitigation. Aggravating and
mitigating circumstances may be considered in deciding what
sanction to impose and may be admitted into evidence at a
disciplinary hearing. 1. Aggravating circumstances are any
considerations or factors that may justify an increase in the
degree of discipline to be imposed. The following list of
examples is illustrative and is not exclusive: (a) prior disciplinary
offenses; (b) dishonest or selfish motive; (c) a pattern of
misconduct; (d) multiple offenses; (e) bad faith obstruction of the
disciplinary proceeding by intentionally failing to comply with
rules or orders; (f) submission of false evidence, false statements,
or other deceptive practices during the disciplinary hearing; (g)
refusal to acknowledge the wrongful nature of conduct; (h)
vulnerability of victim; (i) substantialexperience in the practice of
law; (j) indifference to making restitution; (k) illegal conduct,
including that involving the use of controlled substances. 2.
Mitigating circumstances are any considerations or factors that
may justify a reduction in the degree of discipline to be imposed.
The following list of examples is illustrative and is not exclusive:
(a) absence of a prior disciplinary record; (b) absence of a
dishonest or selfish motive; (c) personal or emotional problems;
(d)timely good faith effort to make restitution or to rectify
consequences of misconduct; (e) full and free disclosure to
disciplinary authority or cooperative attitude toward proceeding;
(f) inexperience in the practice of law; (g) character or reputation;
(h) physical disability; (i) mental disability or chemical
dependency including alcoholism or drug abuse when: (1) there
is medical evidence that the respondent is affected by chemical
dependency or a mental disability; (2) the chemical dependency
or mental disability caused the misconduct; (3) the respondent's
recovery from the chemical dependency or mental disability is
demonstrated by a meaningful and sustained period of successful
rehabilitation; and (4) the recovery arrested the misconduct and


recurrence of that misconduct is unlikely; (j) delay in disciplinary
proceedings; (k) interim rehabilitation; (l) imposition of other
penalties or sanctions; (m) remorse; (n) remoteness of prior
offenses. 3. Factors which should not be considered as either
aggravating or mitigating include: (a) forced or compelled
restitution; (b) agreeing to a client's demand for improper
behavior; (c) withdrawal of grievance against the lawyer; (d)
resignation prior to completion of disciplinary proceedings; (e)
grievant's recommendation as to sanction; (f) failure of injured
client to complain."
Another mitigating factor that Coughlin likely has yet to fully or
perhaps mention at all is that incident to his 9/9/11 custodial
arrest he met and subsequently bailed out of jail a 22 year old
man name Matthew Sean Marks, posting his cash bail of $700
with the understanding that Marks (who comes across a very
capable, sincere, and intelligent, and whose father owns
Spindleshanks restaurant on Tahoe's North Shore, but whose
mother subsequently admitted to Coughlin's that her son Marks is
"a very gifted compulsive liar with a terrible addiction to
methamphetamine) would perform enough hours of work at
approximately $12.00 an hours within the three weeks
immediately following Coughlin bailing him out to work off the
whatever portion of the $700 bail Coughlin posted for him that
would not be refunded by either the RMC or RJC, with the
understanding the "probably" about $500 of that $700 would, in
fact, immediately be returned by the RMC or RJC on the
condition that Marks immediately establish and start making
good on a payment plan to address some minor traffic violation
(such as failing to register with the DMV within 30 days of
moving either to an address within Nevada or to a different
address within Nevada) that, due the Mark's failure to appear,
ultimately became a bench warrant. Coughlin made a terrible
decision to post that $700 bail for Marks at a time when Coughlin
very much needed to get something out of that $700. Coughlin
took a chance on someone, thought it could be a win-win, and
was likely overly sympathetic to Marks given Coughlin's
experience just weeks prior thereto in being unable to bail out for
nearly 7 days incident to the August 20th, 2011 arrest, an
incarceration which had devastating effects upon Coughlin's life
and law practice and seems to have irrevocably damaged his
relationship with his immediate family, the Bar, and his former
significant other incident to a wrongful arrest that involved
misconduct by material witnesses and the arresting officer RPD
Nick Duralde and an officer on scene, Ron Rosa.
Immediately upon Coughlin bailing Marks out, Marks
began failing to live up to the bargain. He failed to appear for
work the next day. Arriving more than 24 hours late the
following day, Marks had clearly been up for at least 24 hours,



exhibited signs of methamphetmine use and was largely
completely useless for the jobs Coughlin had bargained with him
to do. Further, Marks soon began describing to Coughlin
intricate an failry believable scenarios wherein Marks may be
wanted for a recent murder, incident to which associates or
former associates of his may want to murder him to cover up
their own culpability in that regard, etc., etc. all of which added
up to, if not an outright release by Coughlin of Marks from his
obligations, certainly a significant level of discomfort for
Coughlin in having Marks around, however, ultimately (and
Coughlin made reasonably diligent attempts to ascertain whether
Mark's "story" was true and or whether Coughlin had any duty to
inform law enforcement and or was otherwise therin obligated to
take some action). Coughlin does not and has never had or
smoked "crack" or methamphetmine or anything of that sort, nor
has he every had a "crack pipe" lying around his former home
law office. While there was another very brief period in August
wherein Coughlin "hired" or traded a couple days on the bed on
his front porch and then perhaps two days utilizing the bed in the
quasi-basement to a local named Howard Patrick Jackson (whom
Coughlin also had served (as captured on video tape no less)
Washoe Legal Services with the Summons and Cmplaint in
CV11-01955, provided to Judge Elliott as an Exhibit, along with
armed services veteran Mr. Jacksons signed Declaration of
Service of the Summons and Complaint (which Judge Elliott
quashed for was seems like insufficient reasons)..however, Mr.
Jackson did not seem like a crack or methamphetamine user,
rather he seemed to have a drinking problem...and regardless,
Richarg G. Hill, Esq.'s 11/21/11 Declaration in his associate's
Order to Show Cause in the summar eviction case 1708 (which
seems to violate NRCP 56(e) for being vexatiously baseless)
really just seemed to be a knee-jerk, retaliatory reaction by Hill
(along with his fraudulent or bordering on fraud police report to
the RPD that he attached as an exhibit and included what he
believed to be Coughlin's social security number and birth date,
unredacted) to Coughlin quoting in a filing the statement made
by RPD Officer Chris Carter, Jr. that was made in response to
Coughlin asking him if he "was on Richard G. Hill's payroll,
too?, to which Officer Carter said what he said, and Coughlin
later quoted him verbatim, but to which Coughlin either
immediately or shortly thereafter made indication that Carter's
position may well be that he was being sarcastic, etc., etc.
Regardless, immediately following that Hill started in with his
allegation of finding a "crack pipe and bag of weed" at the former
homw law office (despite Hill having tetsified that he went to the
office on numerous occasions following the 11/1/11 lockout and
never mentioning allegedly finding such contraband previous to
that, nor did he mention it to RPD Officer Carter or Sargent
Lopez during the custodial criminal trespass arrest of Coughlin



on 11/13/12 (and Hill was captured on the video tapes being
filmed by Hill himself and landlord Merliss at the arrest scene
imploring Officer Carter to charge Coughlin with "a felony" for
"breaking and entering" ("ahh...you can't blame a guy for tryin'...I
don't do any criminal work...." a chortling Hill is capture saying
to Officer Carter, whom chided Couglhin "your're not the victim
here!" upon Coughlin asking clarifying questions as to Carter's
probable cause analysis and "ruling" that service of the Lockout
Order was sufficient and or that the Order itself was not void at
the time of any such service...."
Frankly it is embarrassing the extent to which Bar Counsel King has at least tacitly accepted a
multitude of instances of misconduct on Hill's part, for which King has been provided reams of
documentation, filings, audio, and video evidence, and official transcripts of court hearings/trials to
support Coughlin's allegation against both Hill and Baker. Additionally, "Investigator" Peters has
gone to great lengths to avoid being placed on notice of such malfeasance by Hill and Baker, even
adding Coughlin to her "blocked sender's list" in her email account. Peters has admitted to Coughlin
that she does not take her "Investigator" title or position at the SBN seriously, and both she and King
seem to only be willing to "investigate" allegations of misconduct when they are made by the rich and
powerful against solo practitioners whom are neither. They are both dishonest, cowardly, shallow,
feckless opportunists whom do not possess the level of integrity required of their positions, which is
probably exactly the reason why they were hired. Their misconduct incident to the express
misrepresentation made to Coughlin concerning his being allowed to issue his own subpoenas
(seemingly motivated in part by their discomfort in having Coughlin around the SBN at all in light of
the fact that everytime Coughlin presented at the SBN Peters or King would seem to make some
mental error revealing a practice of theirs that was not fair or honest), the representation that the
8/23/12 mailing would never be put forward to the NNDB or Panel as satisfying SCR 109, and that a
SCR 109 mailing of the Complaint would go out to Coughlin on 9/12/12, and that Coughlin was
granted permission to fax filed by the Panel/NNDB/SBN/and Clerk of Court of the SBN, the
falsehoods made in Peters sworn 10/9/12 Affidavit of Laura Peters nonsensically and false asserting
that Coughlin emailed his Motion to Dismiss prior to the communication between he and Peters on
9/11/12 (that is not true, and further, Coughlin has provided fax logs in addition to proof of emails,
and the emails themselve sent to the SBN that proved he faxed in his Motion to Dismiss (faxed to the
SBN and NNDB Chairman Susich), for the first time, on 9/17/12 (and copied it to the email addresses
held out to the public by Peters, King, and Susich, and from which Coughlin had received previous
correspondences and sent correspondences to that were replied to in detail...). Page 216 of the
12/24/12 filing by the SBN is particularly fraudulent when considering the circumstances around it.
One, no such page was included in the bates stamped 3,200 hundred page SCR 105(2)(c)-lite
production mailed by Bar Counsel's or its agent in a Sierra Legal Duplicating box on 11/7/12, though
the USPS printout on page 216 of Volume 1 is directed to the 10/9/12 Notice of Intent to Take Default
that Coughlin has made such a big issue of incident to the USPS downtown station counter attendant
"Tim" failing to find it in the back room on at least one previous occasion when Coughlin presented
for that certified mailing (which was not sent in duplicate via first class mail by the SBN, as admitted
to in ther Certificate of Mailing on that filing (which departs, curiously, from the previous practice of
the SBN in this matter), and for which that same attendant "Tim" ( tall man with glasses who has
worked their for years and years) did eventually retrieve that certified mailing (with a tracking number
ending in 5458) but refused to release it to Coughlin in light of it having insufficient postage
(Coughlin personally eye witnessed that the 8.5 x 11 inch manilla envelope had the SBN's red Pitney
Bowes printed postage theron, with a date of 10/9/12 indicated and a postage of $1.25 cents specified,


which was obviously insufficient for a certified mailing of that size (given the full size envelope,
though it did not appear to contain therein more than, at most 20 sheets of paper, if that) given
Coughlin's experience in these matters revealing that such a certified mailing would always cost at
least $5.25....Coughlin personally eye witnessed USPS counter attendant "Tim" make a handwritten
notation on that mailings envelopes that it was being "returned to sender/insufficient postage" and
Couglin shortly therafter, in writing and verbally to King at the SBN's Office placed the SBN on a
LITIGATION HOLD NOTICE to maintain that envelope with Tim's handwritten notation detailing
the insufficient postage thereon and the fact that such a deficiency was indicated as the reason for that
mailign being "returned to sender". King smugly laughed at Coughlin placing him and the SBN on a
LITIGATION HOLD NOTICE, mockingly asking "what's a "litigation hold notice" and generally
indicating that Coughlin should not hold his breath waiting for King to own up to the SBN's error and
mistake, even where it would be fraudulent for the SBN to fail to do so, and where the SBN, in so
doing, severely compromised the level of due process accorded Coughlin herein and damaged
Coughlin's interests, particularly considering the express representations made to Coughlin on 9/11/12
by Clerk of Court Peters/SBN/NNDB/Panel that a default woud absolutely not take against Coughlin
until the certified mailing of 9/12/12 that Peters expressly represented to Coughlin woud be sent the
following day was returned to sender as unclaimed, at which point a Notice of Intent to Take Default
would be served on Coughlin consistent with the manner required for service of a Complaint itself
within SCR 109, and thereafter 14 days plus 3 days for constructive notice by mailing must pass prior
to any default being taken against Coughlin, as expressly indicated by Peters on 9/11/12, where she
further expressly indicated that it was within her power to issue such express representations and
make the calls thereto.
Regardless, the curious and dubious place on page 216 of "Volume 1" in the SBN's 12/24/12
filign in 62337 further reveals the extent to which the SBN is attempting to mislead this Court and the
Panel. wherin the unsigned return receipt requested card for that certified mailing has been placed
over (also curious is the fact that page 216 of Volume 1 is not a part of any of entries in the SBN's
"Index Alphabetical List of Documents", which, apparently is the only such instance of such a
fugitive, rogue entry.
This issue and the SBN's fraudulent failure to file in Coughlin's filings submitted by fax where
Coughlin was given express permission to file by that method have become very improtant here,
particularly where the Chair's 12/14/12 FOFCOL apparently purports to find Coughlin to have
admitted numerous RPC violations in light of some alleged failure to comply with some alleged
requirement that a "Verified Answer" be filed by Coughlin where the Chair alleges Coughlin to have
failed to have done so previously, even where Coughlin's filings do, in fact, contain a blanket denial of
all of the allegations where Coughlins issues the caveat that, in the event his Motion to Dismiss is not
allowable or recognized, he is denying all allegations to avoid any accusation of default or attempt to
finding Coughlin therein. Additionally, the inclusion of the an unsigned, unsworn Reno Carson
Messenger "receipt", which appears to be some attempt at being a quasi Affidavit of Attempted
Service (though, which, is clearly insufficient for that purpose, lacing even the NRS 53.045 language
that woudl obviate any notary requirement...where no signature at all is contained therein, and where
there is cursory conclusory notations therin, and where Coughlin has provided the Panel and SBN
proof of his having called and written Reno Carson Messenger service, includign a 10/3/12 email to
Reno Carson and at least one call wherein Coughlin left a voice mail, and a a 10/6/12 email by
Coughlin to the SBN seeking to and offering to meet the SBN's process serve somewhere (to allow
Coughlin to give his then very recently obtained new address and location a longer period of
anonymity given the extreme fear Coughlin felt in relation to the 10 wrongful incarcerations he has
faced this yeard and all the concomitant abuse and misconduct he has been subjected to by local law
enforcment and the two former housemates against whom Master Edmonsdon entered TPOs in
Coughlin's favor on 1/23/12 in FV12-00187 and FV12-00188, in additon to the numerous written









corrspondences to the SBN by Coughlin requesting all filings or correspondences be copied to
Coughlin via fax and or email in light of a variety of issues (which King and the SNB consistently
refused to do, despite one of the rationale for Coughlin's request relating to his status as a domestic
violence victim whose mail had been interferred with between January 2012 and May 2012 by his
former housemates, and perhaps, one other individual. The USPS Track & Confrim site
reveals the following for the certified mailing with the tracking number 70102780000354295484 that
the SBN purports to attach to the 10/9/12 file stamped Notice of Intent to Take Default:
"YOUR LABEL NUMBER SERVICE STATUS OF YOUR ITEM DATE &
TIME LOCATION FEATURES
70102780000354295458 Delivered November 08, 2012, 10:28 am RENO, NV
89521 Certified Mail
Notice Lef t November 07, 2012, 1:17 pm RENO, NV 89521
Notice Lef t October 10, 2012, 11:09 am RENO, NV 89505
Arrival at Unit October 10, 2012, 8:18 am RENO, NV 89503
Processed through
USPS Sort Facility
October 10, 2012, 4:51 am RENO, NV 89510"
The other thing is that by virtue of the bates stamping on the SBN's 12 24 12 Volume 1 "page
216" the SBN's action reveal that at the time at which the SBN was putting together the Record on
Appeal (which necessarily was done after the 11/14/12 Hearing, and After Coughlin's 11/7/12 Well
Would You Look at That...filing wherein Coughlin details the BIG issue attendant to the returned to
sender in light of the SBN's affidaving insufficient postage thereto 10/9/12 Notcie of Intent to Take
Default (which did not included the Reno Carson one page tack on for which the SBN seems to be
attempting to have appear as having been an Exhibit to that 10/9/12 NOITD filing, given there is not
Index to Exhibits and no indication that such Reno Carson one page printout was a part of that
filing...in which case, its just some document the SBN is slipping int the file and claiming to have been
a "part of the record", which is impermissilbe, especially where is was not part of the mailing to
Coughlin on 10/9/12 and was not provived to Coughlin at all until is was included with the 3,200 pages
of documentation to which constructive notice thereof may only be found upon Couglin a scant one
judicial day before the hearing. Chair Echeverria further reveals himself to be completely unfit to be a
Panel Chair, or even a member of the NNDB where he curtly dismisses the fact that Coughlin was
provided nowhere near the amount of time to review or have access to such materials as required by
SCR 105(2)(c) and the enormous prejudice such a fraudulent and obstructionist approach by Bar
Counsel King woudl necessarily have to any Respondent's defense against the charges alleged,
particularly where, as her, the SBN's Complaint is an "everything and the the kitchen sink affair"
alleging 12 different RPC rules as having been violated (with not indication of how many violations of
each of those 12 different rules are alleged to have been committed or even a single "fact" cited to state,
with any particularity, what exactly supports any such accusation. But to be even more clear, Coughlin
DID NOT LIE TO JUDGE NASH HOLMES DURING THE 2/27/12 TRIAL, AND JUDGE NASH
HOLMES SHOULD NOT BE PERMITTED TO SUMMARILY CONVICT COUGHLIN OF SOME
RPD VIOLATION SIMPLY BASED UPON SOME "FEELING" OR INTUITION SHE HAS OR
HAD AND WHERE NO EVIDENCE OR DUE PROCESS WAS ACCORDED TO COUGHLIN
INCIDENT TO JUDGE NASH HOLME'S RECKLESSY, ALLEGATIONS TO WHICH SHE WAS
CAUGHT UPON COUGHLIN CROSS-EXAMINING HER OFFEREING CONTRADICTORY AND
PRE-TEXTUAL RATIONALE AND SUPPORT FOR HERE DECISION TO HOLD COUGHLIN IN
CONTEMPT AND HAVE HIM STRIP SEARCH AND OR HAVE HER MARSHAL RETURN TO







THE RMC THE NEXT DAY, AND CONDUCT A SEARCH AND SEIZURE NOT INCIDENT TO
ARREST WHERE NO ORDER OR WARRANT JUSTIFIED DOING SO. FURTHER, A
DECEMBER 18TH, 2011 MAILING FROM THE RMC TO COUGHLIN AT HIS THEN 817 N.
VIRGINIA ST. ADDRESS DISPAROVES JUDGE NASH HOLMES CLAIMS REGARDING
ATTEMPTING TO SERVE COUGLIN HER 2/28/12 ORDER WHERE SHE HAD IT MAILED TO
ONE ADDRESS ONLY, THE 121 RIVER ROCK ADDRESS FOR WHICH SHE AND THE RMC
KNEW WAS NO LONGER VALID FOR COUGHLIN.
"First, while there have been no formal prior disciplinary proceedings by the State Bar, the
record establishes that Coughlin has been disciplined by way of sanctions on at least four prior
occasions." The rule is clear, and the SBN could not establish any "prior disciplinary offenses".
Further, the SBN's misconduct in its DowSoE incident to
Second, the record reflects, at least with respect to the Merliss matter and the two criminal trials,
that the pattern of conduct was for selfish reasons: to preserve an unlawful tenancy and to delay and
prolong criminal convictions.
Third, the record clearly and convincingly establishes that the pattern of misconduct is consistent
and includes, without limitation: the disruption of the proceedings; the refusal to heed the directions
and admonitions of the court; the injection of irrelevant material and matters; the filing of lengthy,
irrelevant and nonsensical pleadings; the willingness to lie to court and counsel and the inability to
understand and follow the rules of evidence and procedure.
Fourth, the record clearly and convincingly establishes that Coughlin has committed multiple
violations of the Rules of Professional conduct, as more fully discussed above. Fifth, the record clearly
and convincingly establishes that Coughlin engaged in a bad faith obstruction of the disciplinary
process by failing to file the pleading required by SCR 105(2) and instead filing several lengthy,
irrelevant and nonsensical pleadings, mostly pleadings filed in other matters, and refiled in the
disciplinary action under a similar but different caption. In some instances, Coughlin simply crossed
out the case name and hand wrote the names of the parties in the disciplinary proceeding.
Sixth, the record clearly and convincingly establishes that Coughlin has refused to acknowledge the
wrongful nature of his conduct despite having been sanctioned on at least four prior occasions.
Seventh, the record clearly and convincingly establishes that Coughlin has shown a complete
indifference to making restitution and has so far ignored orders to do so.
Eighth, the record clearly and convincingly establishes that so factors to be present. While the Panel
finds that there is a lack of prior public discipline by the State Bar, the Panel notes that Coughlin has
been publicly criticized in the Joshi matter, has been heavily sanctioned with an adverse award of
substantial attorney's fees in the Merliss matter, and has been incarcerated at least twice for criminal
contempt of court. Although there has been an absence of prior public discipline by the State Bar, there
have been multiple instances of judicial censure and sanction.
"Although Coughlin suggested at the hearing that he may have personal or emotional problems or a
mental disability, he denied that he needed further help". (why no citation to anything in the record
to support such a key issue?) "Furthermore, no medical evidence was presented regarding the
potential impact of a mental disability, no evidence that the disability was the cause of the
misconduct, no evidence of recovery by rehabilitation and no evidence that a recovery has arrested the
misconduct and that a recurrence is unlikely to occur." None of those findings or conclusions are
accurate. Coughlin did present and further attempt to present medical evidence directed to the interplay
between the two conditions he receives pyschiatric treatment for (Major Depressive Disorder (MDD)












and Attention Deficit Hyperactivity Disorder (ADHD), including the citations to scholarly texts in his
6/18/12 and 8/13/12 filing sin 60838 and 61426 related to both dextromethorphan (DXM),
psychoactive ingredient in the Duract Cough Melts Coughlin was convicted of "petty larceny of a
candy bar and some cough drops" incident to the 9/9/11 arrest by tribal police in violation of NRS
171.1255, particularly where the City Attorney, Wal-Mart, and the RSIC Officers admitted at trial that
Wal-Mart did not make a citizen's arrest of Coughlin, but rather, the tribal police arrested Coughlin
upon RSIC Officer Crawfords patently false allegation that Coughlin failed to provide his driver's
license upon request, and therefore Crawford lacked sufficient identifying information for Coughlin to
issue a citation, and was thereby justified in making a custodial arrest of Coughlin (wherein Officer
Crawford testified that he found a half a foil package insert of the exact same package of Duract
Cough Melts which both Crawford and Wal-Mart's Frontino testified to under oath as not having been
an item with a UPC included in those items Coughlin selected and ultimately paid $83.82 for shortly
before Wal-Mart's Frontino asking Coughlin if he would return with Frontino to Wal-Mart's Loss
Prevention Office for further discussions. Wal-Mart's Frontino testified that neither he nor anything
associated with Wal-Mart made a citizens arrest upon Coughlin at any point nor made any attempt to
force Coughlin to go to the LP Office or otherwise detain Coughlin in any manner.
http://en.wikipedia.org/wiki/Recreational_use_of_dextromethorphan
http://www.erowid.org/chemicals/dxm/dxm_dose.shtml
http://www.addforums.com/forums/showthread.php?t=32164 Wellbutrin & Adderall: The
Perfect Combo for My ADD?
Depression may also coexist with attention-deficit hyperactivity disorder (ADHD), complicating
the diagnosis and treatment of both.[16] ^ Brunsvold GL, Oepen G. Comorbid Depression in
ADHD: Children and Adolescents. Psychiatric Times. 2008;25(10).
The terms "refractory depression" and "treatment-resistant depression" are used to describe
cases that do not respond to adequate courses of at least two antidepressants.[194]
I^ Wijeratne, Chanaka, Sachdev, Perminder. Treatment-resistant depression: Critique of
current approaches. Australian and New Zealand Journal of Psychiatry. 2008;42(9):751
62.doi:10.1080/00048670802277206. PMID 18696279.n many major studies, only about 35%
of patients respond well to medical treatment. It may be difficult for a doctor to decide when
someone has treatment-resistant depression or whether the problem is due to coexisting
disorders, which are common among patients with major depression.[195] ^ Barbee
J G. Treatment-Resistant Depression: Advances in Assessment. Psychiatric Times.
2008;25(10).
^Hallowell EM, Ratey J J . Delivered from distraction: Getting the most out of life with Attention
Deficit Disorder. New York: Ballantine Books; 2005. ISBN 0-345-44231-8. p. 25355.
For many years Coughlin had problems with chronic pain, localized chiefly in his upper
thoracic region and neck. For a time Coughlin was prescribed narcotic analgesics. LCL's Coe Swobe
once said to Coughlin as a meeting your're not still taking that crap are you? in reference to a
medication Coughlin had been taking. While Coughlin is sympathetic to those whom deal with chronic
pain issues, and feels somewhat cowardly for making this point, he does not take any pain medication
presently and has not since 2007, finding that to a large extent his chronic pain issues between the ages
of approximately 17 to 30 years old were largely due to being 6 foot 4 inches tall and sitting in chairs
most of his life for extremely long periods of time studying, recording, composing, or playing musical
instruments, or doing legal work that were ill suites to his physique. Coughlin now primarly does such
work in a supine position (and recalls a fine law professor from UNLV's Boyd School of Law's Lynne's




Henderson whose class he enjoyed a great deal taking a similar approach to dealing with chronic pain
issues: http://www.law.unlv.edu/sites/default/files/faculty/resumes/Henderson%20Resume%20Revised
%204-2012.pdf
1.
^a b Nutt DJ . Relationship of neurotransmitters to the symptoms of major depressive
disorder. Journal of Clinical Psychiatry. 2008;69 Suppl E1:47. PMID 18494537.
Amongst the
These potentially mitigating factors are weak at best and do not excuse the well established
numerous and repeated violations of the Rules of Professional Conduct and do not outweigh the
aggravating circumstances established overwhelmingly by the State Bar.
RECOMMENDATIONS
The Panel recommends that the Respondent be ordered:
(1) Irrevocably disbarred by the Supreme Court. While irrevocable disbarment is clearly the
harshest form of discipline, the unusual circumstances here, compounded by the repetitive nature of the
misconduct prior . to and even during the disciplinary process and hearing, clearly warrant the level of
punishment recommended.
(2) That his temporary suspension be continued pending final resolution of this matter.
(3) Within three (3) days of the effective date of disbarment, to demonstrate to Bar that he has
placed all his Nevada clients with other counsel, otherwise concluded the representation, or
with the assistance of Bar Counsel thereafter attempted to expeditiously aid any remaining
client in finding new counsel.
(4) To pay the costs associated with these proceedings pursuant to SCR 120. "