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FILED
C;\SE NUt\-tBER: ng 11-0204 ng-0435 ng-0434
STATE BAR OF NEVAI>A
NORTIU:: RN NEVADA DlSCIPUNARY BOARD
n Rc Math:r of:
.ACHARY BARKER COUGHLIN, ESQ.
cvada Bar No: 9473
)
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) ng 11-0104 ng-0435 ng-0434 motion to
) bi furcate ) 0 ) 5 11
)
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couehlin's I>ESIGNATION Of' WITNESSES ANI> SUMMARY OF EVIDENCE
PLEASE TAKE NOTICE that the following is a summary of evidence and list of witnesses which may
be offered against Respondent at the time of the formal hearing on the above-entitled complaint.
Coughlin reserves any and all objections to matters not included in the Complaint (or even in the
greivances themselves from being testfied to or evidence put on directedto, lack of notice. etc .. . .Dr.
Vieth. et al not reasonably related to any allegations)
A. Documentary Evidence 1. Any and all documentation contained in the State Bar of Nevada's tile
regarding gnevance tiles NG12-0204, NG12-0435 and NG12-0434, except for screening materials
and ~ r Counsel work product. Pursuant to SCR 105 (2)(c) Respondent may .inspect the State Bar
tile up to three (3) days prior to the hearing. Seet attached Exhibit 1 (cd/dvd of relevant materials,
that will be further supplemented later. and incorproated by reference everything previously sent to
anyone with the SBN, including emails and links to videos/skydrives, etc).
B Witnesses and Brief Statement of Facts
1 Judge Dorothy Nash Holmes will appear by phone to testify With regard to Respondent's conduct
in connection with Case No. 1/-TR-26800 12 in Reno Municipal Court.
2.
Judge Kenneth R Howard is expected to testify about Respondent's conduct in connection With
Ii Case No. II CR21176 21
1
13. Dr. Matt Merhss is expected to testify about the situation leading up to Respondent's arrest for
., trespassing and his lies before and after the face
,
II
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2$ Attorney !ichard :ill' Es?$' is e5"ected to testimony with regard to !es"ondent.s
conduct in connection with Case No$ C*II#13;0<$
4$ Scott Co""a' =arshall for the !eno =unici"al Court is e5"ected to testify aout
!es"ondent.s disru"tive ehavior on =arch 00'01, 0$
;$ !eno City Attorney )aniel 7ong' Pam !oerts' Allison O!maas' and Chris :a@lett#STevens are
e5"ected to testify aout !es"ondent.s conduct in !eno
9ustice Court$
>$ Steve Tuttle' !eno 9ustice Court em"loyee' is e5"ected to testify aout !es"ondent.s
conduct when visiting the court com"(5$
<$ Karen Stancil' !eno 9ustice Court em"loyee' is e5"ected to testify aout !es"ondent.s
conduct when visiting the court com"le5and various matters related to Coughlin in the !9C$$
A$ !oin -a(er' !eno 9ustice Court em"loyee' is e5"ected to testify aout !es"ondent.s conduct
when visiting the court com"le5 and various matters related to Coughlin in the !9C$
,1$ )r$ !ichard T$ -issett is e5"ected to testify aout the e5amination he "erformed on
!es"ondent in "re"aration for a com"etency hearing in Case No$ ,0#13>;$
,,$ )r$ =ary !$ *ieth is e5"ected to testify aout the e5amination she "erformed on
!es"ondent in "re"aration for a com"etency hearing in Case No$ ,0#13>;$
,0$ A memer of the staff of the State -ar of Nevada Ethics )e"artment is
e5"ected to testify as Custodian of !ecords regarding documentation contained in the records of the
State -ar of Nevada and !es"ondent.s disci"line and licensure history$
,3$ Bachary -$ Coughlin is e5"ected to testify regarding the facts and circumstances in all three
disci"linary matters$ The State -ar of Nevada reserves the right to su""lement this disclosure$
,2$ Steve Tuttle' !9C administrator is e5"ected to testify aout various matters related to Coughlin in
the !9C$
,4$ )r$ -ill )avis of La(e.s Crossing e5"ected to testify aout the e5amination he "erformed on
!es"ondent in "re"aration for a com"etency hearing in Case No$ ,0#13>;$
,;$ )r$ Sally 8armer "ected to testify aout the e5amination he "erformed on
!es"ondent in "re"aration for a com"etency hearing in Case No$ ,0#13>;$
,>$ Kevin Kelly' stri" clu ownin. Character and 8itness Committee Chairman is e5"ected to testify
regarding the im"erissile matters related to Peter Christiansen.s Cre"resentationC of Coughlin
etween 0110#0114$
,<$ =i(e !owe' ditto what Kelly will to $
)ear ),1 9udge Elliot' 9udge 8lanagan' and the Second 9udicial )istrict Court Cler( of Court 9oey
Orduna :asitings' 7)C Custodian of !ecords' Associate Cler( of Court 9ulie 7iseD
Included in the relevant materials and information sought is the legal asis for incarcerating in Cr,0#
13>; &des"ite ))A Eoung violating N!S ,><$214Fs mandatory stay' in his moving for a G=otion for
!evocation of -ailH &des"ite 7)C! ,A re?uiring a hearing e set' Coughlin never got one in cr,,#
01;2' nor in cr,0#,0;0 &oth 9udge Elliot a""eals involving "ro se Coughlin' nor did Coughlin get a
hearing in cv,,#13;0<' well' there was two hearings on :illFs fraudulent =otion for Order to Show
cause' ut that it not what wdcr ,A is invo(ing+Coughlin etween a"ril ,Ath' 01,0 to A"ril 0;' 01,0
&during which time the I21'141 attorneys fees motion resulting in an Order awarding it in C*,,#
13;0< was filed+ for a""ealing a summary eviction as a "ro se tenant 'a""arently deemed residential
tenant with rnet of less than I,K a month+ also' des"ite Chief Civil Cler( (constantly re%ecting
CoughlinFs filign under wdcr ,1' Coughlin was actually sanctioned yet another I4K y his former
cowor(er
' 9udge 8lanagan &whom declined to recuse himself form the order to show cause hearings des"ite'
argualy' Coughlin re?ueting as much' in violation of nrs 00$131&3+J ut !CS6KLS in the Car"entier
v Aames case &that !ichard hill co"ied CoughlinFs 9anuary ,3th' 01,0 filing on in cv1<#1,>1A in hills
,6026,0 grievance to ar counsel against CoughlinJwhich Coughlin was su%ect to custodial arrest
for %aywal(ing y r"d and hill on ,6,06,0' and another arrest for Gmisuse of A,,H on ,6,26,0'
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coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE
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seemingly connected to filing in car"entier matter of ,6,36,0J violated 7)C! ,< and
3<LM<,A2N!uleLM<,A2NLM<,A2N$Ca"tion for all "leadings and other legal documents$
Every document sumittedLM<,A2NLM<,A2N ,$ for filing in the family division shall ear the
following ca"tionD
GIN T:E 8A=ILE )I*ISION
O8 T:E SECON) 9O)ICIAL )IST!ICT COO!T O8 T:E STATE O8 NE*A)A
IN AN) 8O! T:E COONTE O8 7AS:OEH
7here there filings said Gcounty of clar(HJCoughlin was the one attorney who "ointed that outJ$:e
is sanctioned I4KP And the 7)C continues to re%ect CoughlinFs filings under 7)C! ,< and ,1 at a
remar(ale rateP
8urther' ca"low 310 "$0d >44 made unnecessary the seemingly fraudulent 36<6,0 affidavit of service
y wcso machen' y way of rmc marshal harley &%udge nash holmes 36,06,0 comments in court
seem to indicate Gsummary criminal contem"tH finding "remised u"on G"ee"ing TomH style "eering
through restroom stall walls y !=C =arshal :arley &or some other =arshal' li(e Scott Co""a'
involved in the im"ermissile Gsearch incident to arrestH y !=C a a full day after attorneyFs "ro se
criminal defenantFs smart"hone and micro sd card oo(ed into wCdc "ro"erty on 060>6,0Jviolates
state v dia@Janyways' no Gsummary contem"tH finding ased u"on allegations of GdissessemlignH
smart"hone in restroom stall' where no !=C =arshal' :arley or Co""a or otherwise' signed an
affidavit detailing facts su""orting contem"t$ In re oliver re?uires such contem"t e' in every
element' in the Gimmediate view and "resence of the courtH si5th amendment right violated' nrs
,<A$1,1#141 violated' etc$' etc$and m
ost of this ng,0#1234 involves %udge nash holmes denying Coughlin right to a""eal final a""ealale
summary criminal contem"t finding from 060>6,0$' in re oliver' denied si5th amendment right to
counsel' and Coo(' 0;> us 4,> at 43; &as did %udge 8lanagan in 36036,0 contem"t hearing of
Coughlin+' notifying Coughlin of 36036,0 hearing on hillFs order to show cause motion in cv,,#13;0<
efore 9udge 8lanagan &nrc" 4;&g+ ad faith affidavits should result in e5"ense awards and
contem"t finding against hill' "erha"s' a(er' and stewartJnot I21K in attorneys fees against
Coughlin' de novo review and hearing re?uired y wcdr ,A not "rovidedJ$"lus in rmc ,, tr 0;<11
%udge nash holmes violates nrs ,<A$1,1 y refusing to transmit record on a""eal and transcri"t in
res"onse to Coughlin filign a notice of a""eal on 36>6,0 &rmcFs garder' rother to 9udge Linda
/ardner' whose A"ril 011A Order got Coughlin fired from 7ashoe Legal services &;131, ;13,> case
in n$ s$ ct$+' she "assed her order
to her rother' he "assed it to 9udge Nash :olmes' she filed ng,0#1234 on ehalf of all rmc %udges'
and a""arently family court 9udge L$ /ardner &Coughlin filed mandamus to that order in 42<22+$
Also' why is Coughlin thrown in %ail ased u"on GevaluationH filed on 26,<6,0 y dr$ ill davis &where
davis denies any res"onsiility for the letter he signed' saying he didnFt write it' and didnFt sumit it
for filingP :e SI/NE) IT and La(es filed it' argualy shouldFnt even e filed' and should e an
affidavity if Coughlin was incarcerated for contem"t Gnot in courtFs "resenceH nrs$ 00$121
Incarcerating Coughlin from a"ril ,A to a"ril 0;th' 01,, in cr,0#13>;' and refusing to even loo( at the
authority Coughlin attem"t to sumit res"ecting tailoring com"etency orders' hi"aa rights &also'
Order was not sufficiently clear' nor any violation thereof y Coughlin' under :ouston v <th %udicial
dist2rict court to su""ort < days in %ail and wdcd denying Coughlin his medication and right to file
court documents' resulting in I21K attorney fees award y 9udge 8lanagan in cv,,#13;0<J$"lus
=:CFs iondo lied aout asis for CoguhlinFs removal in =:,0#1130 in her letters to !9C$ Also nrc"
3>&+&0+&d+ incarceration wrongful &civil rule' ut "erha"s instructive+ In lieu of any of the foregoing
orders or in addition thereto' an orderLM<,A2N&)+ treating as a contem"t of court the failure to oey
any orders e5ce"t an order to sumit to a "hysical or mental e5aminationH
)ated this 3,st day of Octoer' 01,0D
QQQQQQQQQQQQQQQQQQQQQQQQQQ
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coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE
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Bachary -ar(er Coughlin' Es?$ &Nevada law license tem"orarily sus"ended' OSPTO license in tact'
and given "ermission to issue su"oenas y S-N Chief -ar Counsel )avid Clar(' Es?$+
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coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE
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PROOF OF SERVICE
STATE O8 QQQQQQQQQQQQQQQQQQQQ +
+ ss$
COONTE O8 QQQQQQQQQQQQQQQQQQ +
I' QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ' eing first duly sworn' de"oses and saysD
That affiant is a citi@en of the Onited States' over ,< years of age' and that affiant received the
within Su"oena on the QQQQ day of QQQQQQQQQQQQQQQQQQQQQQQQQQQ' 01 QQQQ' and "ersonally
served a co"y of the same u"on QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ
on the QQQQQQQ day of QQQQQQQQQQQQQQQQQQQQQQQQQQQQQ' 01 QQQQQ$
)ECLA!ATION
This document does not contain the Social Security Numer of any "erson$
I declare' under "enalty of "er%ury under the Law of the State of Nevada' that the foregoing is
true and correct$
QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ
Signature of Person =a(ing Service
QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ
)ate
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coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE
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INDEX TO EXHIBITS
!" EXHIBIT ! VARIOUS RE#EVANT MATERIA#S ON A CD$DVD
- 545 -
coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE