1 3 13 ROA From RMC NRS 189.030(1) Violation No Transcript Etc CR13-0011-3389237 Ocr

7/27/2019 1 3 13 ROA From RMC NRS 189.030(1) Violation No Transcript Etc CR13-0011-3389237 Ocr

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1 1375Reno Municipal ourt2 Post Office Box 1900Reno, Nevada 895053 775)334-259045678

IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

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IN AND FOR THE COUNTY OF WASHOE

ZACHARY BARKER COUGHLINAPPELLANT,

vs Case NoCity o Reno, City Attorney, A MuniclpI orporation Department No

RESPONDENT.

CERTIFIED COPY OF DOCKET

03 JULY 2012: Criminal Complaint issued upon the oath ofRENO POLICE OFFICER,AJWEAVER, RPD CASE NO 12-12728).Charge: 1

R.M.C. Code 08.12.020 DISTURBING THE PEACECharge: 2

R.M.C. Code 06.14.130.B UNSECURED LOADCbarge: 3

R.M.C. Code 06.06.555.A INSURANCE REQIRED OWNER

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05 JULY 2012: The defendant appeared for arraignment via video and was representedby Keith Loomis. The defendant entered a Not Guilty plea to all 3 charges. Bail set t S3000.00 cash only.Legal defender Keith Loomis was appointed and a trial date was set for August 23 2012 t I :00 p.m. inDepartment One ofthe Reno Municipal Court.

16 JULY 2012: The Court received a motion for change of plea. A new arraignment wasset for JULY 19 2012 t 8:30 a.m. for the defendant to be seen via videos.

17 JULY 2012: The Court received a motion regarding bail. Motion to be heard July19 2012 via video arraignments.

19 JULY 2012: Defendant appeared for hearing and did not change plea. A bailhearing was held. The request for O.R. was denied. Bail set t S1000.00 cash only on Disturbing tbe Peacecharge. On remaining charges defendant to be released on O.R. Bench trial remains scheduled forAUGUST 23 2012 t 1:00 p.m.

21 JULY 2012: Defendant posted S1000.00 bail.

2 AUGUST 2012: Defendant provided proof of insurance.

9 AUGUST 2012: Motion to Withdraw as Counsel filed by attorney Keith Loomis. MotionGranted.

13 AUGUST 2012: Trial set for August 23 2012 t 1 00 p.m. in Department One of theReno Municipal Cour t continued by Court. New trial date set for SEPTEMBER 4 2012 8:00 a.m. LegalDefender Henry Sotelo was appointed. Notice sent certified mail.

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20 AUGUST 2012: Additional Criminal Complaint Trespass) filed by Reno City Attorney.Charge 4: R.M.C. Code 08.10.010 TRESPASS. Amended Criminal Complaint was alsofiled, Charge 1: is amended from RM C Code 08.12.020 to 08.12.020 d)

4 SEPTEMBER 2012 The defendant appeared for bench trial and was represented by Legaldefender Henry Sotelo. Insurance was dismissed, proof was provided. Trespass and Disturbing the Peacewere dismissed. Cash Bail Exonerated. Trial on Unsecured Loads to be continued for City to amendcbarge, or file motion to dismiss. Hearing set for SEPTEMBER 17,2012.

18 SEPTEMBER 2012 Motion filed by Defense counsel Henry Sotelo. Motion requesting duedate of dismissal be continued, pending Justice Cour t psychological evaluation and Competency Hearingin the Reno Justice Court on OCTOBER 15 1012. Motion Granted.

1 OCTOBER 2012 Motion to Withdraw as Counsel filed by attorney Henry Sotelo.

3 OCTOBER 2012 Motion to withdraw as Counsel granted.

15 OCTOBER 2012 Amended Criminal Complaint Filed by Reno City Attorney. Charge 2 is

30 OCTOBER 2012 New tria l date set for DECEMBER 03,2012. Defendant noticed bycertified mail.

3 DECEMBER 2012 The defendant appeared pro per. Trial held. Court took case underadvisement.

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5 DECEMBER 2012 Order is issued by Court. Defendant found Guilty of N.R.S. 484D.850 (2)Unseeured Loads. Defendant to pay 175.00 by Deeember 17, 2012 at 4:30 p.m. Appeal Bond set at175.00.

21 DECEMBER 1012 Defendant faxed notiee of appeal.

27 DECEMBER 2012 No fine paid, no appeal bond filed.

Mu Ie al Judge, Department One

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1 I Cassandra Jackson Court Administrator ofth. Reno Municipal Court do hereby certify thatthe attached copy of Criminal Case Number 12 CR 12420 21 is a full true and correct copy of said2 document.3456789111121314151617181922122232425262728

Court Administrat

SUBSCRffiED AND SWORN BEFORE MEthis 2 r Day of J a . n u t : l ~ 2013

State of Nevada - County of Washoe

'Ci MAYA'SHERMAN'OO 'l1 i Notary Pub6c State of Navada l1 Ajlpointment RoconIod WsshoeCounty i; No: 8900B62-2-Expi 'AprlI19 2013;, : ".'''

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CERTIFICATE OF MAILING2 Pursuant to NRCP 5 b), I certify that I am an employee of the Reno Municipal Court and that on3456789

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this date I deposited for mailing at Reno, Nevada a true copy of the attached document addressed to:

ZACHARY BARKER COUGHLIN1471 E 9T Street

Reno, Nevada 89512AND

Via Inter- office Mail:Reno City Attorney

Alison Ormaas

A CARTER

DEPARTMENT ONE CLERKRENO MUNICIPAL COURT

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tIom zacncougnlln 12 Zl 12 l1 3lao p of 6

F A C S I M L EDate 12/21/2012To 1699ac9c-69bl-4598-88f6-30dd36ee7a98generaI693298From zachcoughlinSubject from zachcoughlin tel and fax 949 667 7402 1471 e 9th st in 12 cr12420 motion for new trial notice o appeal


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1 CASE NO. 12 CR 124202 DEPARTMENT 1345

I LEDE 5 2 12

T ~ : ~ ~ ~ ~ ~ ~ A ~ ~ ~Reno Municipal ourt v k:d=Dep . On.

6 IN THE MUNICIPAL COURT OF THE CITY OF RENO,78

COUNTY OF WASHOE, STATE OF NEVADA

9 CITY OF RENO,10 Plaintiff,11 vs. OR ER12 ZACHARY BARKER COUGHLIN,13 Defendant.14 /15 Mr. Coughlin appeared for trial in Department One of the Reno Municipal Court on September 4, 20 12.16 He was represented by Henry Sotelo, Esq. Deputy City Attorney Brian Sooudi represented the City17 Of Reno. Three of he charges in this case had been resolved prior to this trial. The only matter that was18 in issue was a violation of he Reno Municipal Code 6.14.130B, unsecured load . Prior to the start of19 the trial Mr. Sotelo offered an oral motion to dismiss because the Reno Municipal Code section under20 which his client was charged 6.14.130 B applied only to trucks and not the defendant's Honda car.21 The trial was continued to allow Mr. Sotelo to file a written motion and for the City to respond. On22 October 1, 2012 Mr. Sotelo, Esq. filed a motion to be relieved as counsel under Nevada Supreme Court23 Rule 46. This motion was granted. The remaining charge was a traffic violation without possibility ofa24 jail sentence upon conviction, therefore the Court did not appoint another attorney at the Court s2526

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1 expense. On October 15,2012 the City filed an amended complaint including a proper certificate o2 service. This amended complaint was sent to the address in the case file.3 On October 30, 2012 the Court sent a notice of resetting the trial by certified mail, return receip4 requested. This was returned marked return to sender . The Court checked Mr Coughlin's addres5 listed with the Nevada Department ofMotor Vehicles, it did not list any new address. On November 56 2012 the Court received an e-mail from the Defendant that provided a new address. The Court sent 7 new notice of trial setting by certified mail return receipt requested. The trial date was scheduled fo8 December 3, 2012.9 On December 3, 2012 Mr Coughlin appeared as required for trial. He appeared n Pro Per. The City o

10 Reno was represented by Deputy City Attorney Alison Onnaas. When the case was calledMr Coughli11 offered several oral motions. First he moved for a mistrial without any supporting authorities. Th12 motion was denied since there had not been a trial. Next Mr. Coughlin moved for a dismissal for lack o13 trial notice. The Court explained the procedure for providing notice. Mr. Coughlin stated that he did no14 pick up the notice until 2 days prior to trial. The motion was denied because the notice was properly sen15 and it is not the Court s fault that he didn't pick up his mail. Mr. Coughlin then offered an oral petitio16 to disqualify this Judge for unclear concerns about possible prejudice. Mr. Coughlin did not follow th17 statute regarding disqualification of a Judge other than a Supreme Court Justice. The Defendant ha18 three (3) months to file such a written petition for disqualification. Mr Coughlin infonned the Cou19 that one of the other Judges on the Reno Municipal Court had testified at his State Bar of Nevad20 Discipline hearing and that she stated that all of he judges believed that he should be disciplined for hi21 prior behavior. This Judge did not testify nor did this Judge authorize a fellow judge to make tha22 statement. Additionally, that hearing was on November 14,2012 with over two (2) weeks from tha23 hearing without a proper written petition to disqualify this Judge. The petition was denied. Mr. Coughli24 asked for a continuance for lack of discovery of photos that the City had. The City indicated that th25 226


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1 photos were not part of its case and showed no evidence about this alleged traffic violation. Lastly, Mr2 Coughlin objected to the filing of he amended complaint. The Court noted that the amended complain3 was properly filed with a certification ofservice. The fact that the post office did not forward the mail i4 not in the power of the City Attorney. Additionally, the amended complaint simply amended the cod5 section from the Reno Municipal Court to the Nevada Revised Statute incorporated into the Ren6 Municipal Code. There was not a substantial change in the language of the complaint.7 The trial was then held. The City called two witnesses: Sgt. Dye and Officer Weaver ofthe Reno Polic8 Department. Sgt. Dye who was an officer on the date of the alleged violation had been promoted9 testified that he and Officer Weaver were together in a marked police vehicle at the intersection o

10 Summit Ridge and the offramp from McCarran Blvd. As they waited for a silver Honda to pass them h11 saw a large plastic tub f lloff the trun area and a vehicle that was following brake and swerve to mis12 the tub which ended up in the travel portion of Summit Ridge. Mr. Coughlin pulled over and Sgt. Dy13 drove up behind the silver Honda and turned on his overhead lights to show the driver that he was bein14 pulled over by the officers and for safety. Officer Weaver, who was the passenger in the police vehicle15 approached the driver of the Honda and recognized him from previous contacts. Officer Weaver als16 testified that he saw the tub fall off the back of the silver Honda. The City rested. Mr. Coughlin calle17 Officer Weaver to testify about the other contacts between them. The City objected for lackofrelevanc18 and the Court sustained the objection. Mr. Coughlin asked no further questions. He rested the Defens9 case without any further testimony.

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1 The only testimony presented to the Court established that a large plastic tub fell off of Mr. Coughlin'2 car causing a hazard to traffic. Mr. Coughlin is found guilty o this offense. The standard fine for thi3 violation is 175.00 which this Court imposes. The Defendant must pay the fine by December 17 20124 at 4:30 p.m. to the Reno Municipal Court. The 175.00 will also be the amount ofthe appeal bond.5 This order dated and signed this 5th day of December 2012.6789

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CERTIFICATE OF M ILINGPursuant to NRCP 5(b), I certify that I am an employee o the Reno MunicipalCourt and that on this date I deposited for mailing at Reno, Nevada a true and correctcopy o the attached document addressed to:

Via Certified mail, return receipt requested:Zachary Barker Coughlin1471 E. 9th StreetReno, Nevada 89512Via inter-office mail:Reno City AttorneyAlison Ormaas

Dated this 5th day o December, 2012.

Maya e an Judicial AssistantDepartment One

U.S. Postal SerVice ..CERTIFIED MAIL , RECEIPT .Domestic Mall Only No Insumnce Coverage Provided). . .I OFF ICI L

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II I, I, I , , I , I, I I, II, I .... ..Zachary Barker Coughlin1471 E 9Th St =:]Reno, NV 89512-2906 --=[ 1 ]=--


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iJUDGE S CONFIDENTIAl,;; NOTESII1?/3/2012

Court : 12 CR 12420 2 BENCH TRIALCOUGHLIN, ZACHARY BARKER

DOB: 09 27 1976

Agency ' RPD 12.12728Case Status: OPEN Booking : 10621Case Judge: DEPT 1Amt Due: 0.00 (as of 11/26/2012BOND INFORMATION

1000.00 CASH ONLY ON DTP CHARGE ONLY7/21/2012 9/4/2012 EXONERATED 1,000,00 CASHB127239/0NLY FOR CHARGE 1 DISTURBING THE PEACE.1;3 2612 FORM L COMPL IN i FILE V l i iHE COO i

7/5/20127/5/20127/5/20127/5/20127/19/20127/19/20128/13/20128/13/20129/4120129/4/201210/312012

ADDITIONAL CASE INFORMATION: OFFICERS DYE AND WEAVER PRESENT IN COURTLEGAL DEFENDER APPOINTED; KEITH LOOMISPRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED, WAS EXPLAINED HIS/HER RIGHTS BY THE JUDGE INDICATED THAT HE/SHEUNDERSTOODADDITIONAL CASE INFORMATION:PRESENT IN COURT FOR THE CITY OF RENO: PAM ROBERTS FOR THE DEFENSE:KEITH LOOMISLEGAL DEFENDER APPOINTED; HENRY SOTELOLEGAL DEFENDER RELIEVEDDISMISSED WITH PROOF/AFFIDAVITPRESENT IN COURT FOR THE CITY OF RENO: BRIAN SOOUDI FOR THE DEFENSE: HENRY SOTELOLEGAL DEFENDER RELIEVED

Amended: 4840.850.2 OPERATE VEHICLE WITH UNSECURED LOADPlea: NOT GUILTY 715112 Disp: Jail: 0FinesIFee.: Amt Paid: Amt Waived:Cited Speed: Zone: Location: SUMMIT RIDGEIMCCARRAN

otes: CONTINUED FOR DEFENSE TO FILE MOTION TO DISMISS

Suspended: 0Bal: 0


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ty AttorneyP.O. Bol1900eno Y 89505

CERTIFICATE OF SERVICEPursuant to NRCP 5 b), I certify that I m an employee o the Reno City

Attorney, Reno, Nevada, and that on the 11th. day ofObtober, 2012 I deposited for mailing at:Reno, Nevada, first class postage prepaid, a true and correct copy o the foregoing documentaddressed to:

Zachary CoughlinP.O. BOX 3961Reno NV 89505

Legal Secretary, Criminal Division

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10 01 12 09:20AM HP L .JET FAX \p.Ol.-..../

HENRYN. SOTELO930 Evan AvenueReno, NV 89512

FILEDRENO MUNICIPAL COURl2012 OCT -I AM II: 04

; ~ i E ; . ; 1 , _'L.. ( . , _ J .' _ ,_ . jBY I ~ v - ~ - ~

Phone 775) 453-2919 - Fax 775) 870-1506Facsimile Cover Sheet

To: Clerk of the CourtFrom: Henry N. SoteloAttn: Clerk of the Court

Fax No: 334-3824Date: 10 1 2012Client: Zachary Coughlin, DefendantPages: 5


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10101 12 09:20AM. HP U- ''>.JET FAX p.02-'--"--_._.--. - .....IN TIiE MUNICIPAL COU/IT OF THE CITY OF RENO

COUNTY Of WASHOE, STATE OF NEVADAFILEDR NO MUNICIPAL ca

OTY OF RENO, Plaintiff 2tl20CT - , MCase No. 12CR 12420 2 .s. I', t. " ,""'- fiji If , 'Dept No. BY- ,acharyCoulhllO. DefendantName FIrst, Middle, lest) D [1;\

PO BOil 3961. R.no. Nv. 89505City, State, Zip9/27/1976Date of Birth MOTIONComes now the undersigned and here make the following request:

MOTION TO SE: REl.IEVjp AS COUNSElThis Motion is based on the following;HENRY SOTELO. ESQ., has reprC$ented ZACHARY COUOHLIN sillce August 13, 2012, alld has performedlegal services in that regard. Circumstances havo developed which have led to the breakdown ofcommunicatioll5 between Attorney and the Client, a difference ofopinion and deterioration of theAttorney/Client relationship, Nevada Supreme Court. Rule 46 provides:

The attorney in an action or special proceeding lilly be cbanged at any time before judgmentor final determination as fbllows:1. Upon consent of the attorney, approved by the: client.2. J. pQ l the order of the coun or ilIdge thereof QO the APplication Qftbe attorney or the client.After judgment or final detennination, an attorney may withdraw as attorney of record at anytime upon the attorney's filing a withdrawal, with or without the client's consent.

(empbasis added). HENRY SOTELO, ESQ., moves this Court to issue an Order allowing the withdrawal ofcounsel. There has not yet been a final determination in this case, therefore, the Court's permission is ,necessary. Nllvada Rules of ProfessIonal Conduct t.t, b} stales:

(b) Except as stated In paragraph (c), a Iawyor may withdraw from representing a client if:(1) Withdrawal can be accomplished without matorial adverse effect on th ) interests of theclient;2) The client persists in a COUIlIC of action involving the lawyer's services that the lawyerreasonably believes is criminal or fraudulent;3) The l i e n ~ has used the lawye(s services to poIpetrate a crime or fraud;4) A lient 111$1 1 "POll takillg actJOII that the a w y ~ t OtISldus repugnant or with ",hichthe low),"" hils ..nJaltullltal dlsn/fl'el1mtlnt;


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10 01 lZ 09:Z0AM P LA' "-J :T FAX p 03

(5) The client tails subslantilll1y to fulfill an obligation to the lawyer regllfding the lawyer sservices and has been given reasonable warning that the lawyer will withdraw unless Iheobligation is fulfilled;(6) The :representation will result in an unreuonable financial burden on the lawyer or hasbeen :rendered unreasonably difficult by the client; or(7) Qtkef good ctuae o,. P/lhtlmwal exhbi.(emphasis added)

HENRY SOTELO. ESQ" 8Mes 8Ufficient r e a ~ l l s eKist roc pennitting HENRY SOTELO, "ESQ to w;thd ...wfrom representation at this time.HENRY SOTELO. ESQ, asserts it would be impossible for him to provide suitable and competentrepresentarion for ZACHARY COUGHLlN as the client insisLs upon taking a course of action that the lawyerconsiders repugnant and with which the lawyer has a fundamental disagreement. rn addition. ZACHARYCOUGHLIN and HENRY SOTELO, ESQ. are unable to engage in tbe type of open communication that wouldbe helpful in providing a reasonable


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10/01/12 09:20AM liP U >.JET F X p.O'

WRGOOD CAUSE APPEARING IT IS HEREBY ORDERED that the motion be:

X oranted en ied .thcr

t..9r v. .. -ay Dilworth Judge. Dept. One


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10/01/12 09:20AM HP LJ JET fAX p u ~

PROO O SERVICE1 the undersigned, hereby declare:

According to R.M.C.R 5 H) I hereby certify that am over eighteen years of age and nota party to the within cause. I am an employee of Henry Sotelo at the address is 930 Evans Street,Reno, NV 89512. On October 1 2012 I served a true and correct copy of the MOTION byfacsimile transmission to the following:

Clerk: of the Reno Municipal Court775.3343824

Sotelo


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''''0tJNlCIP u COtJI TP O.IOXIM-7 1 ~ ) ~ 1 2 9 0

CERTIFICATE OF MAILINGPursuant to NRCP 5 b), I certify that I am an employee o the Reno MunicipalCourt Ltd that on this date I deposited for mailing at Reno, Nevada a true and correctcopy o the attached document addressed to:

Zachary CoughlinP.O. Box 3961Reno, NV 89505Via e-mail to:Reno City AttorneyBrian SooudiLegal DefenderHenry Sotelo

Dated this 3rd day o October, 2012.

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ep 17 12 07:47p

DA#4320682

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. STr'/E Tifj' fREIW JUS neE ~ U ~ T34 IN TIm JUSTICE COURT OF RENO O W N ~ k ti ? f * ~

COUNTY OF WASHOE, STATE OF NEVADA67 THE STATE OF NEVADA,8 Plaintiff,9 VS.

10 ZACHARY BARKER COUGHLIN,Defendant.

2

Case No. RCR 2011-063341Dept. No.2

13 ORDER FOR COMPETENCY EVALUATION PURSUANT TO NRS 178,415

p 2

14 Upon motion of counsel for Defendant herein and good cause appearingI s therefor,15 IT IS HEREBY ORDERED that the Defendant be examined by a psychiatrist or17 other person who is especially qualified by the Division of Menta Health and Developmental18 Services of the Department of Health and Human Services pursuant to NRS 178.417, for the19 purpose of determining:20 I. If the Defendant is not of sufficient mentality to be able to undezstand21 the nature of the criminal charge(s) against him;22 2 If, because of menIal insufficiency. the Defendant is not able to aid and23 assist counsel in the defense interposed Upon the trial or against the pronouncement of the24 judgment thereafter and if the Defendant is able, if he chooses to assist and cooperate with25 counsel.26


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HE - l : So t .e l o--..J

~ < ; 8 7 7 8 7 8 p 3

IT IS ORDERED that the Defendant is to appear for the mental health2 evaluation and cooperate wim me evaluator on me date and time set for said evaluation.3 IT IS FURTHER ORDERED that the evaluator should review alI prior4 evaluatioos in conducting the examination pursuant to this Order in particular the actions of5 the Defendant at the Nevada Adult Mental Health Services and his conduct in the court during6 the several proceedings that he has been involved in.789

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IT IS FUTHER ORDERED that the Defendant is to appear before theHonorable Peter J. Sferrazza of the Reno Justice Court Department No.2 on the JSIll day ofOcloher 2012 al the hour of9:00 a.m. fOT a competency evaluation hearing.

D T E D t h i s ~ a Y O f s e p t 2.

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Court : 12 CR 12420 2Case Status: OPENCase Judge: DEPT 1Amt Due: $0.00 (as of 8/22/2012BOND INFORMATION

I

BENCH TRIALCOUGHLIN ZACHARY BARKER

DOB: 09 27 1976

Agency ' RPD 12-12728Booking : 10621

7/5120127/5/20127/5/20127/512012

ADDITIONAL CASE INFORMATION: OFFICERS DYE AND WEAVER PRESENT IN COURTLEGAL DEFENDER APPOINTED; KEITH LOOMIS

7/19120127/19120128113120128/13/2012

PRESENT IN COURT FOR THE CITY OF REND: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED WAS EXPLAINED HIS/HER RIGHTS BY THE JUDGE & INDICATED THAT HE/SHEUNDERSTOODADDITIONAL CASE INFORMATION:PRESENT IN COURT FOR THE CITY OF RENO: PAM ROBERTS FOR THE DEFENSE:KEITH LOOMISLEGAL DEFENDER APPOINTED; HENRY SOTELO. LEGAL DEFENDER RELIEVED

Jail: 0 Suspended: 0Amt Paid: Amt Waived: Bal: 0

Cited Speed: Zone Location: SUMMIT RIDGE/MCCARRANAccidentN

, ) ~ Q Y I el /,IWAL w.,. J .J_

Oat.: 8/2212012 Print Oat.: 8/2212012Agonep : 1212128 COURT CASE : 12 CR 1242 2


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7 312012

3 2012

06.14.1308 SECURE LOADS AND COVERS ON LOADSPlea: NOT GUILTY 7 5 12Fines/Fee.:Cited Speed: Zone:ccidentN

Notes:

Disp: Jail: 0Amt Paid: Amt Waived:Location: SUMMIT RIDGEIMCCARRAN

06.06.555A SECURED VEHICLE INSURANCE) REQUIRED OWNERPlea: NOT GUILTY 715112 Disp: Jail:Fines/Fee.: Amt Paid: Amt Waived:Cited Speed: Zone: Location: SUMMIT RIDGEIMCCARRANccidentN

Notes:

08.10.010 TRESPASSINGPlea.Fines Fees:Cited Speed: Zone:AccidentN

Notes:

Dlsp: Jail:Amt Paid: Amt W aived:Location: SUMMIT RIDGEIMCCARRAN

- END OF RECORD BARKER

Date: 8 2212012 Print Date: 8 2212012 AgencJ#:12.12728

Suspended: aBal:

Suspended:eal: 0

Suspended:6al: 0

OURT CAS' : l2CR 1242 2


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IN THE M _AICIPAL COURT OF THE CIT\ - F RENOCOUNTY OF WASHOE, STATE OF NEVADAONE SOUTH SIERRA STREET RENO NV 89505

Mailing: P.O. Box 1900, Reno NV 89505 PHONE (775)334-2290 FAX (775)334-3824

vs.DEFENDANT: COUGHLIN, ZACHARY BARKERCourt Case : 12 CR 12420 21 DOB: 09127 1976

Accident :Status: OPEN

Language: ENGLISHgency : RPD 12-12728 Booking : 10621Attorney: SOTELO, HENRY

7131201271512012

7151201271512012711912011

FORMAL COMPLAINT FILED WITH THE COURTLEGAL DEFENDER APPOINTED: KEITH LOOMIS: 9468 DOUBLE R BLVD SUITE A, RENO, NEVADA 89511PHONE (775) 853-7212PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT HE/SHEWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.

IT ISHEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT HIMIHER IN ANY AND ALL PROCEEDINGS ON THIS MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAYBE REQUIRED TO PAY FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODA Y'S DATE. IN THE EVENT THAT THIS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.IF THE DEFENDANT HAS WITNESSES THAT HEISHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF HISIHER CASE, THE DEFENDANT MUST CONTACT HISIHERATTORNEY.PRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED WAS EXPLAINED HISIHER RIGHTS BY THE JUDGE AND INDICATED TIIA THElSHE UNDERSTOOD THEM COMPLETELY.PRESENT IN COURT FOR THE CITY OF RENO: PAM ROBERTS FOR THE DEFENSE:KEITH LOOMIS

BARKER Agency : 11-11728Print Date: 9 412012

COURT CASE : 12 CR 12420 21fendant Initials Data Date: 9 412012 Page 1 of4


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8113/1011 LEGAL DEFENDER APPOJh..-ED: HENRY SOTEWj 930 EVANS STREET, k.JIO NEVADA 89512 PHONE (775)525-1529PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT HEiSHEWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.IT IS HEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT HlMlHER IN ANY AND ALL PROCEEDINGS ON m S MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAYBE REQUIRED TO PAY FEES FOR REPRESENT ATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODA Y'S DATE. IN THE EVENT THAT THIS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.

8 1312012

IF THE DEFENDANT HAS WITNESSES THAT HEISHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF HISIHER CASE, THE DEFENDANT MUST CONTACT HISIHERATTORNEY.LEGAL DEFENDER RELIEVED: KEITH LOOMISIT IS HEREBY ORDERED THAT THE LEGAL DEFENDER BE RELIEVED FROM HISIHER ASSIGNMENT TO THISCASE.

9 412012 DISMISSED ON PROOFIAFFIDAVITCharge 3: SECURED VEHICLE (INSURANCE) REQUIRED OWNER9/4/2012 PRESENT IN COURT FOR THE CITY OF RENO: BRIAN SOOUDI FOR THE DEFENSE: HENRY SOTELO

Offense Dt: 0710312012Arrest Dt: 0712112012Plea:Disposition: 09/04/2012 - DISMISSEDCharge 2: 06.14.130B - SECURE LOADS AND COVERS ON LOADSOffense Dt: 07/0312012Arrest Dt:Plea: 07/0512012 - NOT GUILTYDisposition

Jail Days: 0Suspended Days: 0

PCN :Jail Days: 0Suspended Days: 0

WRT :

r ~ ' T ' T T n FOR FILE MOTION TO DISMISSCharge 3: 06 06 SSSA - SECURED VEHICLE (INSURANCE) REQUIRED OWNEROffense Dt: 07 0312012Arrest Dt:Plea:Disposition: 0910412012 - DISMISSEDCharge 4: 08.10.010 - TRESPASSINGOffense Dt: 07 0312012Arrest Dt:Plea:

09/04/2012 - DISMISSED

Additional FeesSupervision Fee Subtotal Supv Fee(,) Due:

540.00

540.00

Agen.yH, 11 12728Print Date' 9 412012efendant Initials:

PCNH: WRT :Jail Days: 0Suspended Days: 0

peNH WRT :Jail Days: 0Suspended Days: 0

540.00 SO OO

540.00 50.00

COURT CASE : 12 CR 12410 21Data Date: 9/4/2012 Pagelof4


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07 2112012

7 5 20127 512012

0711912012 BAIL SET BY JUDGE09/0412012 EXONERATED

1000.00 CASH ONLY ON DTP CHARGE ONLY0712112012 ACTIVE BAIL09/0412012 EXONERATED

B127239 0NLY FOR CHARGE 1 DISTURBING THE PEACE.

BAIL SET AT: 53000.00 CASH ONLY TOTAL (SI000.00 CASH EACH COUNT)OWN RECOGNIZANCE RELEASE REQUEST DENIEDBAIL SET AT: 51000.00 CASH ONLY ON DISTURBING THE PEACE CHARGE

51,000.00 CASH ONLY5 1,000.00 CASH ONLY

$ 1,000.00 CASH ONLY$ 1,000.00 CASH ONLY

7119 2012711912012 OR RELEASE - RELEASED ON OWN RECOGNIZANCE SECURE LOADS AND INS REQUIRED CHARGES ONLY

Next Proof Dt:Balance: 1Completed Dt: Jul 19, 2012

WHILE IC IF THE MAY 2012 EVAL CANNOT BEPROVIDED

Next ProofDt:BalanceCompleted Dt:

F AlLURE TO COMPLY WITH THE CONDITIONS OF BAIL AS DESCRIBED IN THIS ORDER WILL RESULT IN THE ISSUANCE OF AF AlLURE TO COMPLY WARRANTOR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT OF COURT ANDIOR BAlLREVOCATION. FOR FURTHER INFORMATION. CONTACT THE SENTENCE COMPLIANCE WINDOW LOCATED ON THE FIRSTFLOOR OF THE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NV (775) 334-2290.THE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITH THEBAlLlFFSIMARSHALS AND ALL COURT STAFF.THE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEARANCES AND COURT-ORDERED PROGRAMS ON TIME ANDALCOHOL AND DRUG FREE.THE DEFENDANT SHALL KNOW HISIHER COURT DATE AND MAINTAIN CONTACT WITH HISIHER ATTORNEY.PRIOR TO CHANGING HISIHER ADDRESS OR PHONE NUMBER, THE DEFENDANT SHALL NOTIFIY THE COURT OF SUCHCHANGE.OBEY ALL LAWS.

0710512012 ADDITIONAL CASE INFORMATION: O F i i c I ~ R S0711912012 ADDITIONAL CASE INFORMATION:0812712012 MISC NOTES: GREEN USPS CARD RECEIVED. PLACED IN D-I BLACK FOLDER.THE HONORABLE JAY DILWORTHJUDGE S SIGNATURE: DATE:

COUGHLIN, ZACHARY BARKER Ageney : 12-11728Prin t Date: 9 412012

COURT CASE : 12 CR 12420 21Data Date: 9 4 2012 Page 3 of4


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You are ordered by the Court to arrive druWmtohol free and on time for all Court hearings ah-court related programs. Failure toappear in Court will result in the issuance of a warrant for your arrest. Any violation of his instant order may result in contemptproceedings and the filing 'of additional criminal charges. In accordance with NRS 22.010, it is a misdemeanor for any person to fail,refuse or neglect to comply with the terms of any order issued by the Municipal Court Judge. This order will remain in effect until theCourt issues another order superseding it.I UNDERSTAND AND PROMISE TO OBEY THIS ORDER. DEFENDANT:

DATE:. TIME:I, THE SWORN INTPRETER HAVE FULLY INTERPRETED THIS ORDER TO THEDEFENDANT: DATE:. TIME:RECEIVED BY DEPUTY: DATE:. TIME:ISSUED BY MARSHAL: DATE: TIME:

Agency : lU728Print Date: 9 411012efendant Initials:

COURT CASE : 12 CR 1242021Data Date: 9 411012 Page 4 of4


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12345678910

IN THE MUNICIP L COURT OF THE CITY OF RENOCOUNTY OF WASHOE STATE O NEVADA

CITY OF RENO Plaintiff,

C ; ' ~ h k n lDefendant. I

DECLARATION OF INSURANCECOVERAGE

CASE NO.

1I I declare under penaltyofperjury that the vehicle I was driving at the timeof he offense12 giving rise to the instant insurance violationwas insured as required by NRS 485.187 on the date .13 and time of he offense. I understand that the information related to insurance coverage provided14 herein will be verified with the insurance company. I understand that if he information provided15 in this Declaration is false that I may be held in contempt of court and subject to a fine ofnot16 more than $500.00 or twenty-five (25) days jail, or both. Additionally, I understand that any17 person who misrepresents the validity of any policy, bond or other evidence of financial18 responsibility required under Chapter 485 of the Nevada Revised Statutes is guilty of a19 misdemeanor that is .punishable by up to six 6) months in jail andlor a fine not to exceed20 $1,000.00. RMC 6.06.557.

22 S i g n a t u r e : _ ~ . . d ~ s , . . . . . ~ ~23 YOU must ovide the following information:

21Date: - - r ~ f - E f ~ ~ z . ; . . - - - - -

2425 Insurance c o m p a n y : - - - , - , l J ' - - - , L . 5 / j t 1 i " : 1 1 4 = ~ - - - - - - - - - - - _ ' 6 1 \ \26 Address: 4-. \\,--/- l ,27 PolicyNumber ________ ~ ~ ~ /28 ;_I', _ ' clop""''' w n b ~ poQ< OR s.-e d t61f1 I C;


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fiLEDRENO MUNICiPA (OUP r

, U T O M O ~ ~ ~ ~ " ' ; ~ ~ S ~ N ' C E - ' ~ c i ( ~ ; n ~ " ~ ~ a ~ ~ i : { R o : r ' ' ~ _ ' ~ ' ~ f : : ~ ~ , ~ ~ ~ ~ ~ \ >This I ~ ' - : = & t l t i ~ e " ' i d 8 R C . ; ' . ~ l j ' l ' ; ' l n s u n t n c e for yoor vehicle. The card is validonly a S l : : ~ i ; ~ ~ t . ~ ~ ~ ~ ~ . r u n a l n s In ~ o , r C : _ . _ -;> '..YOI. may;tilJifequlred to PrOdLice your identll1caUon:t:'atd at vehicle registration r ' n S j j e c t i ~ n ~

~ J ; ' ~ , ~ ; t ; ~ : ~ . - : ~ ~ ~ ~ ~ : : _ J ~ C , ~ ~ ~ ~ : J . ~ ~ J n ~ r ~ : _ : ; ~ : ~ ~ , ~ : ~ ~ ~ ~ ; ~ , ; . ~ : ~ ~ e r i f O r C ' e m e n t , r,. ~ ~ ' ~ ~: '.1 KEEP A,COPY OF THE lD CARD IN YOUR VEHICLE AT All TIMES.

r

.-:.

- - : : : ; . : , : . : t , : : - - - - - - ~ ~ - - - - - ~ - - - - - - ..- .....- ~ 1 ...... ..... . _ : _ ; ~ . . . . Tu . ,U .

_' NEVADA EVrOENct or MOTOR VEHICLE LIABlun INSURAN(~ ~ C a v u : A G [ MEETS R E ~ U I R E M E N T S Of NIlS 485.185. THIS CARD HAS: ~ : , A : U A S ' ? ~ [ ' Y r ; ~ R I E ~ E V : f A ~ ~ S J ~ ~ ~ E ~ g : O ~ S = J r::"RODVCffON ON OEMAHD.N_ .v.C:HARV e C O ~ G H L I N, -422 E9TH 81 UNIT 2RENO NV 89&12-2979,

P';IIC)' flUnlMr 009852196CEn.nJ 0 . . . 2118112Eotplr.tlon Oat 08.J181121996 HONDA, v ; ~ l c j r l i & : r i ; i f i f l f l S t ~ ~ ,lHGC056J01A23S22-4

USA/ . CASUALTV INsuAANcE COMPANYPOLICY SERVICE /800>531 B11 1 ',,,aClAIMS 18(0) 531 sm

7104 3


35/65

FILEDIN THE MUNICIPAL COURT OF THE G.IIDY4r(1)ItIREN( )F'COUNTY OF WASHOE STATE d ~ ; . g . M A r l \

CITY OF RENO. _ _ ~ _

Plaintiff,vs.

Zachary CoughlinDefendant.

DOB September 27, 1976-----------------------------

BY_ -.----.-- - . 'AD JflONALCRIMINAL COMPLAINT

CASE NO. 12-12728DEPT NO.1

I, Brian Sooudi, Deputy City Attorney, hereby complain and say that Zachary Coughlinhas committed the crime of Trespass to wit.

That said defendant on or about July 3, 2012, in the City of Reno, State of Nevada, inthe vicinity of 1680 Sky Mountain Drive did go upon the land of another with the intent to vex orannoy the owner r occupant thereof. Zachary Coughlin did vex and annoy the maintenanceemployee for the apartment complex, Milan Krebs, by making statements that included; If [he]went near his garage again [he'd] be sorry and continuing to do so would be a 'mistake.Zachary Coughlin said this while following Milan Krebs and video recording him.D All of which is in violation of NRS ---,- as adopted by Section1.04.015 of the Reno Municipal Code.[gJ All of hich is in violation of 8.10.010 of the Reno MuniCipal Code.

Pursuant to NRS 171.102, I hereby declare upon information and belief and underpenalty of perjury that the foregoing is true and correct to the best of my knowledge .

. August 16, 2012ConlPla i f l (Dated)

3 09


36/65

1 CERTIFICATE OF SERVICE2 Pursuant to NRCP 5 b), I certify that I am an employee o the Reno City3 Attorney, Reno, Nevada, and that on the 16 th day o August, 2012, I deposited for mailing at4 Reno, Nevada, first class postage prepaid, a true and correct copy o the foregoing document5 addressed to:678910111213141516171819202122232425262728

ttorneyP.O. ox 1900NV 89505

Henry Sotelo, Esq,930 Evans StreetReno, NY 89512

Legal Secretary, Criminal Division \

1


37/65


38/65

I CERTIFICATE OF SERVICE2 Pursuant to NRCP 5 b), I certify that I am an employee o the Reno City3 Attorney Reno Nevada and that on the 16th day o August 2012 I deposited for mailing at4 Reno Nevada fIrSt class postage prepaid a true and correct copy o he foregoing document5 addressed to:67891011123

141516171819202122232425262728

City ttorneyP.O. BOII900NV 89505

Henry Sotelo Esq.930 Evans StreetReno NY 89512

. .


39/65

-

RENO MUNICIPAL COURT

MR. ZACHARY COUGHLINP.O. BOX 3961Reno, NV 89505Re: Case No. 12 CR 1242021

Dear ZACHARY COUGHLIN:

DEPARTMENT ONEJAY DILWORTH, JUDGE

CITY OF RENONEVADA

August 13 2012

The above referenced case was set for August 23rd at 1 00 PM. Your court appointedattorney, Keith Loomis has withdrawn as council, and therefore we have reset your trialfor a new date with a new legal defender. Your trial date is September 4, 2012at 8:00 am in courtroom B Department One of the Reno Municipal Court. A CourtAppearance slip is attached for your records, Please note that your Legal Defender onthe above referenced case is Henry Sotelo, Esquire. You may contact your attorney at775) 525-1529. Any request for a continuance must be filed in writing no later than ten10) days prior to your trial date.

FAILURE TO APPEAR AS SCHEDULED MAY RESULT IN ISSUANCE OF AWARRANT FOR YOUR ARREST.

Sincerely,

A. CarterDepartment One Clerk

P.O. BOX 1900, RENO, NEVADA 89505 775) 3342590, FAX 775) 326-5110. TDD 7751 334-2298


40/65

IN THF:-w UNICIPAL COURT OF THE C'h--Y OF RENOCOUNTY OF WASHOE, STATE OF NEVADA

ONE SOUTH SIERRA STREET RENO NV 89505Mailing: P.O. Box 1900 Reno NY 89505 PHONE (775)334-2290 FAX (775)334-3824

CITY OF RENO, PLAINTIFFVS.DEFENDANT: COUGHLIN ZACHARY BARKERCourt Case#: 12 CR 12420 21Agency#: RPD 12-12728

DOB: 09/27/1976Accident#: Booking#: 10621 Status: OPENLanguage: ENGLISH

Attorney: SOTELO, HENRY

7/3/2012715/2012

7/5120127/512012711912012

FORMAL COMPLAINT FILED WITH THE COURTLEGAL DEFENDER APPOINTED: KEITH LOOMIS: 9468 DOUBLE R BLVD SUITE A, RENO, NEVADA 89521PHONE (775) 8537222PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT HE/SHEWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.IT ISHEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT HIMIHER IN ANY AND ALL PROCEEDINGS ON THIS MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAY BE REQUIRED TO PAY FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODAY'S DATE. IN THE EVENT THAT THIS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.IF THE DEFENDANT HAS WITNESSES THAT HE/SHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF HISIHER CASE, THE DEFENDANT MUST CONTACT HISIHERATTORNEY.PRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED, WAS EXPLAINED HISIHER RIGHTS BY THE JUDGE AND INDICATED TIIA THE/SHE UNDERSTOOD THEM COMPLETELY.PRESENT IN COURT FOR THE CITY OF RENO: PAM ROBERTS FOR THE DEFENSE:KEITH LOOMIS

Initials:COURT CASE : 12 CR 12420 21

Data Date: 8/1312012 Page 1 of3


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8 13 2012

8113 2012

LEGAL DEFENDER525-1529 HENRY SOTELO; 930 EVANS NEVADA 89512 PHONE (775)

PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT HEISHEWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.IT IS HEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT IDMIHER IN ANY AND ALL PROCEEDINGS ON TIDS MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAY BE REQUIRED'TO PAY FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODAY'S DATE. IN THE EVENT THAT TIDS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.IF THE DEFENDANT HAS WITNESSES THAT HEISHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF IDSIHER CASE, TH DEFENDANT MUST CONTACT HISIHERATTORNEY.LEGAL DEFENDER RELIEVED: KEITH LOOMISIT IS HEREBY ORDERED THAT TH LEGAL DEFENDER BE RELIEVED FROM HISIHER ASSIGNMENT TO THISCASE.

Offense Dt: 07 0312012Jail Days: 0Suspended Days

Arrest Dt: 07 2112012Plea: 07 0512012 - NOT GUILTYDispositionCharge 2: 06.14.I30B - SECURE LOADS AND COVERS ON LOADS PCN : WRT :Jail Days: 0Offense Dt: 07 03 2012 Suspended Days: 0Arrest Dt:Plea: 07/0512012 - NOT GUILTYCharge 3: 06,06.555A - SECURED VEHICLE (INSURANCE) REQUIRED OWNER PCN : WRT :Jail Days: 0Offense Dt: 07 03 2012 Suspended Days: 0Arrest Dt:Plea: 07 0512012 - NOT GUILTY

Supv Fee(s) Due:540.00 $0.00

0711912012 BAIL SET BY JUDGE CASH ONLY1000.00 CASH ONLY ON DTP CHARGE ONLY

07 2112012 0712112012 ACTIVE BAIL S 1,000.00 CASH ONLYB127239/0NLY FOR CHARGE 1 DISTURBING THE PEACE.

Agency : 11-11728Print Date: 811312012efendant Initials:

COURT CASE : 12 CR 12420 21Data Date: 8 1312012 Page 2 of


42/65

7 5 20127 512012

BAIL SET AT: ONLY TOTAL ($1000.00 CASH EACH C OvI'lT )OWN RECOGNIZANCE RELEASE REQUEST DENIEDBAIL SET AT: $1000.00 CASH ONLY ON DISTURBING THE PEACE CHARGE19 2012

7 1912012 OR RELEASE - RELEASED ON OWN RECOGNIZANCE SECURE LOADS AND INS REQUIRED CHARGES ONLY===:

Next Proof Dt:Balance: 1Completed Dt: Jul19, 2012WHILE IC IF THE MAY 2012 EV AL CANNOT BEPROVIDEDNext Proof Dt:BalanceCompleted Dt:

FAILURE TO COMPLY WITH THE CONDITIONS OF BAIL AS DESCRIBED IN TIllS ORDER WILL RESULT IN THE ISSUANCE OF AFAILURE TO COMPLY WARRANT OR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT OF COURT ANDIOR BAILREVOCATION. FOR FURTHER INFORMATION, CONTACT THE SENTENCE COMPLIANCE WINDOW LOCATED ON THE FIRSTFLOOR OF THE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NY (775) 334-2290.THE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITH THEBAILIFFSIMARSHALS AND ALL COURT STAFF.THE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEARANCES AND COURT-ORDERED PROGRAMS ON TIME ANDALCOHOL AND DRUG FREE.THE DEFENDANT SHALL KNOW HISIHER COURT DATE AND MAINTAIN CONTACT WITH HISIHER ATTORNEY.PRIOR TO CHANGING HISIHER A DDRESS OR PHONE NUMBER, THE DEFENDANT SHALL NOTlFIY THE COURT OF SUCHCHANGE.OBEY ALL LAWS.

ADDITIONAL CASE INFORMATION: OFFICERS DYE AND Wh.AV :K07 1912012 ADDITIONAL CASE INFORMATION:

THE HONORABLE JAY DILWORTHJUDGE S SIGNATURE: DATE:

You are ordered by the Court to arrive alcohol free and on time for all Court hearings and Court related programs. Failure toappear in Court will result in the issuance f a warrant for your arrest. Any violation of his instant order may result n contemptproceedings and the filing of additional criminal charges. In accordance with NRS 22.010, it is a misdemeanor for any person to fail,refuse or neglect to comply with the terms of any order issued by the Municipal Court Judge. This order will remain in effect until theCourt issues another order superseding it. ... / Jl.. /

I UNDERSTAND AND PROMISE TO OBEY THIS ORDER. DEFENDANT: l l t 2 t ~ e u h t i e . . e (DATE: TIME:I, THE SWORN INTPRETER HAVE FULLY INTERPRETED TillS ORDER TO THEDEFENDANT: D A T E : _ ~ r - - - - __ TIME:RECEIVED BY DEPUTY: 6t. _________ A T E : ; _ _ = = 8 ~ a . L J ~ c ; o J . 2 : . . / ~ Z ' = = - , . . J T I M E :ISSUED BY MARSHAL:

T: COUGHLIN, ZACHARY BARKER Age : 12-12728Print Date: 811312012

DATE: l ~ TIME:COURT CASE : 12 CR 12420 21

Data Date: 8 1312012 Page 3 of3


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--..

1 I certify that this document does not contain2 t h e c ~ u m e r of any person3 Keith Loomis, EsqState Bar No. 19124 9468 Double R Blvd. Ste. A5 Reno, NY 89511775) 853-72226 Attorney for Defendant789

10111213141516171819202122

IN THE MUNICIPAL COURT OF THE CITY OF RENOCOUNTY OF WASHOE STATE OF NEVADA

CITY OF RENO, A Municipal Corporation CASE NO. 12 R 12420Plaintiff DEPT. NO.1Vs.

Zachary CoughlinDefendant.

MOTION T WITHDR W S COUNSEL FOR DEFEND NTI Keith Loomis, as counsel for the defendant Zachary Coughlin hereby request

that the court relieve me as counsel for Mr. Coughlin, the defendant in this matter. Ipreviously represented Mr. Caughlin earlier this year in Case No 12 CR 26405 after Mr.Puentes was allowed to withdraw as counsel. That representation resulted in Mr.Caughlin ultimately requesting that he allowed to represent himself. That request was23

24 granted. I was again appointed to represent Mr. Caughlin on or about July 5 2012 in25 the present matter. Without going into the details of our relationship, so as to avoid

having Mr. Coughlin viewed with either favor or disfavor by the Court, that relationship1


44/65

1 has broken down to the extent that further representation will be rendered unreasonably2 difficult. Under Rule of Professional Conduct 1,16 a lawyer may withdraw as counsel3 for a defendant if the client insists on taking actions which the lawyer finds repugnant or4 with which the lawyer has a fundamental disagreement (Rule 1.16(b)(4) or other good5 reason for withdrawal exists(Rule 1.16(b)(7, There are a number of requests that Mr6 Coughlin has made with which this writer fundamentally disagrees. The relationship7 has also become fairly adverse to the point that representation of Mr. Coughlin has8

become very difficult. I have discussed by withdrawal from the case with Brian Sooudi9of the City Attorney s Office who indicates he has no objection to the withdrawal.1

Dated this - , ? 5 ~ f _ h . . l . - _ d y of ~Keith Loomis

123

145 Mr. Coughlin s mailing address is:6 Zachary CoughlinP.O. Box 39617 Reno, V 89505

181922122232425

Attorney for Zachary Coughlin

2


45/65

123

4 CERTIFICATE OF SERVICE BY MAIL5

6 I hereby certify that I am an employee o the Law Office o Keith Loomis and that7 on the day oA.,,,, , 2012, pursuant to NRCP 5(b), I served copies o the

foregoing document ~ m r e d8 MOTION TO WITHDR W9 Upon the following persons by depositing copies o the same in the U.S. Mails,

10 addressed to them as follows:

23

Reno City Attorney s OfficeCriminal DivisionP Box 1900Reno, NV 89505

14 Zachary CaughlinP.O Box 3961Reno, NV 895055678920

222232425

3


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IN THk-MUNICIPAL COURT OF THE CN Y OF RENO f '\COUNTY OFWASHOE STATE OF NEVADA VONE SOUTH SIERRA STREET, RENO NY 89505 C \ \ t -

Mailing: P.O. Box 1900, ReDo, NY 89505 PHONE (775)334-2290 FAX 1 5 3 l i - 3 ~

VS.DEFENDANT: COUGHLIN, ZACHARY BARKERCOurt Case#: 12 CR 12420 21AgeDcy#: RPD 12-12728 DOB: 09127 1976Accident#: Booking#: 10621 Status: OPENLanguage: ENGLISHAttorney: LOOMIS, KEITH

IN-CUSTODY VIDEOARRAlGNMENTS

JUDGE GARDNER E Thu, lui 5, 2012 8030 am ARRAlGNMENT HEARING HELDIN-CUSTODY VIDEOARRAIGNMENTS JUDGE GARDNER E Thu, Jul19 2012 8:30 am BAIL HEARING HELD

7 3 201271512012

7151201271512012

711912012

FORMAL COMPLAINT FILED WITH THE COURTLEGAL DEFENDER APPOINTED; KEITH LOOMIS: 9468 DOUBLE R BLVD SUITE A, RENO, NEVADA 89521PHONE (775) 853-7222PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT H ISHWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.

IT ISHEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT HIMIHER IN ANY AND ALL PROCEEDINGS ON TmS MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAY BE REQUIRED TO PAY FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODA Y'S DATE. IN THE EVENT THAT THIS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.IF THE DEFENDANT HAS WITNESSES THAT HElSHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF HlSIHER CASE, THE DEFENDANT MUST CONTACT mSIHERATTORNEY.PRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED, WAS EXPLAINED mSIHER RIGHTS BY THE JUDGE AND INDICA TED THATHEiSHE UNDERSTOOD THEM COMPLETELY.PRESENT IN COURT FOR THE CITY OF RENO: PAM ROBERTS FOR THE DEFENSE:KEITH WOMIS

Offense Dt: 0710312012Jail Days: 0Suspended Days: 0ArrcstDt:

Plea: 07105 2012 - NOT GUILTYCharge 2: 06.14.130B - SECURE LOADS AND COVERS ON LOADSOffense Dt: 0710312012Arrest Dt:

BARKERInitials: ------------------ Agency#: 12-12728Print Date: 711912012

PCN#: WRT#:Jail Days: 0Suspended Days: 0

COURT CASE #: 12 CR 12420 21Data Date: 711912012 Pagelof3


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Plea: 071OS/10ll - NOT Guk ryDispositionCharge 3: 06 06 SSSA - SECURED VEHICLE INSURANCE) REQUffiED OWNER PCN : WRT :Jail Days: 0Offense Dt 07/0312012 Suspended Days: 0Arrest Dt:Plea: 07/0512012 - NOT GUILTYDisposition:

Next ProofDt:Balance:Completed Dt: Jul 19, 1012WHILE IC IF THE MAY 2011 EV AL CANNOT BE

Next ProofDt:Balance:Completed Dt:FAILURE TO COMPLY WITH THE CONDITIONS OF BAIL AS DESCRIBED IN THIS ORDER WILL RESULT IN THE ISSUANCE OF AFAILURE TO COMPLY WARRANT OR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT OF COURT AND OR BAILREVOCATION. FOR F U R T H ~ INFORMATION, CONTACT THE SENTENCE COMPLIANCE WINDOW LOCATED ON THE FIRSTFLOOR OF THE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NV 775) 334-2290.

THE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITH THEBAlLIFFSIMARSHALS AND ALL COURT STAFF.THE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEARANCES ND COURT-ORDERED PROGRAMS ON TIME NDALCOHOL AND DRUG FREE,THE DEFENDANT SHALL KNOW HISIHER COURT DATE AND MAINTAIN CONTACT WITH HISIHER ATTORNEY,PRIOR TO CHANGING HISIHER ADDRESS OR PHONE NUMBER, THE DEFENDANT SHALL NOTIFIY THE COURT OF SUCHCHANGE.OBEY ALL LAWS.

Initials: Print nate: 7/19/2012 nata nate: 711912012 Page 2 of3


48/65

You are ordered by the Court to arrive diuglalcohol free and on time for all Court hearings and Court related programs. Failure toappear in Court will result in the issuance of a warrant for your arrest. ny violation of this instant order may result in contemptproceedings and the filing of additional criminal charges. In accordance with NRS 22.010 it is a misdemeanor for any person to failrefuse or neglect to comply with the terms of any order issued by the Municipal Court Judge. This order will remain in effect until theCourt issues another order superseding it.I UNDERSTAND AND PROMISE TO OBEY THIS ORDER. DEFENDANT:. DATE: TIME:I TIlE SWORN INTPRETER HAVE FULLY INTERPRETED THIS ORDER TO THEDEFENDANT: DATE: TIME:RECEIVED BYDEPUTY: DATE: TIME:ISSUED BY MARSHAL, DA TE, TIME,

EFENDANT: COUGHLIN, ZACHARY BARKERefendant Initials: ------------------ AgeneyN: 12-12728Print Date, 7119 2012 COURT CASE N 12 CR 12420 21Data Date: 7119 2012 Page 3 of


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I

iJUDGE'S C0NFIDENTIAL NOTES ,ICourt#: 12 CR 12420 21Case Status: OPENCase Judge: DEPT 1BOND INFORMATION

?i/19/2012IN-CUSTODY VIDEO ARRAIGNMENTSCOUGHLIN, ZACHARY BARKER

DOB: 09/27/1976

7/3/2012 7/512012 BAIL SET BY JUDGE $ 3 000.00FORM L COMPL iN i FILeD V l i iHE OOk i

Agency#: RPD 12-12728Booking#: 10621

CASHADDITIONAL CASE INFORMATION: OFFICERS DYE AND WEAVER PRESENT IN COURTLEGAL DEFENDER APPOINTED; KEITH LOOMISPRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMIS

713120 27/5120127/5120127/5120127/512012 THE DEFENDANT APPEARED, WAS EXPLAINED HIS/HER RIGHTS BY THE JUDGE & INDICATED THAT HE/SHEUNDERSTOOD

CHARGES Total Bail Amt: 1,4157/3/2012 08.12.020 DISTURBING THE PEACEiII Plea: NOT GUILTY 7/5/12 DiSp: Jail: 0 Suspended: 0Bal: 0ines/Fees: Amt Paid: AmtWaived:Cited Speed: Zone: Location: SUMMIT RIDGEIMCCARRAN

-J,{r- fVtL WO /A r1c i.?S 1c..H ... ( ).J) eel ll - 7 7 -7Notes:

b.41 C . b 1I'IO.J'lO fZ ;i... 641 ' , G jLINS . d ~: 71312012 - - ~ - - - 0 6 . 1 4 . 1 3 0 B . SECURE LOADS ANC COVERS ON L O A D S ' - ' - - ' - - ~ - - ~ - ~ - ---0'1I Plea: NOT GUILTY 7/5/12 Disp: Jail: 0 Suspended: 0

Fines/Fees: Amt Paid: Amt Waived: 8al: 0Cited Speed: Zone. Location: SUMMIT RIDGE/MCCARRAN

Notes:

. ~ . ~ . . ---- . w: J . = L l ~DEFENDANT: COUGHLIN, ZACHARY BARKERData Dale: 7/1912012 Print Dale: 7/1912012

Agency#: 12 12728 ~ 1 t 5 T


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7 3 2012 06006o555A - SECURED VEHICLE (INSURANCE) REQUIRED OWN RPlea: NOT GUILTY 7 5 12 Disp: Jail: 0Fines/Fees: AmI Paid: AmI Waived:Cited Spe'oj: Zone: location: SUMMIT RIDGE/MCCARRAN

Notes:

- END OF RECORD -BARKER7 1912012 . Print Date: 7 19 2012 Agency : 12-12128

Suspended: 0Bal: 0

COURT CASE : 12 CR 12420 2


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R e q U e S ~ O n nhjfLName G o U r J L ~ f P 2itf l l ~ i (

Last) Middle Initial First)HU : _ loo31........ Cell If?Inmate Request PLEASE E SPIECIIF

Response ~ z fo

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Courts ransportationJUt 6 2 12

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IN THh \ I U N I C I P AL COURT OF THE CIlY OF RENOCOUNTY OF WASHOE, STATE OF NEVADl

ONE SOUTH SIERRA STREET, RENO, NV 89505 .Mailing: P.O. Box 1900, Reno, NY 89505 PHONE (775)334-2290 FA 775 ) l - k

VS.DEFENDANT: COUGHLIN, ZACHARY BARKERCourt Case : 12 CR 12420 21Agency : RPD 12-12728

DaB 09 2711976Accident : Booking : 10621

Status: OPENLanguage: ENGLISH

Attorney: LOOMIS, KEITH

71312012715/2012

715120127/512012

FORMAL COMPLAINT FILED WITH THE COURTLEGAL DEFENDER APPOINTED; KEITH LOOMIS: 9468 DOUBLE R BLVD SUITE A, RENO, NEVADA 89521PHONE (775) 853-7222PLEASE ALLOW APPROXIMATELY 3 WEEKS BEFORE CONTACTING YOUR ATTORNEY SO THAT HEiSHEWILL HAVE ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST YOU WITH YOUR CASE.

IT ISHEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TOREPRESENT HIMIHER IN ANY AND ALL PROCEEDINGS ON THIS MATTER IN THE RENO MUNICIPAL COURT.IT IS FURTHER ORDERED THAT THE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION ANDMAY BE REQUIRED TO PAY FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILLREMAIN IN EFFECT FOR SIX MONTHS FROM TODAY'S DATE. IN THE EVENT THAT THIS ORDER EXPIRES,THE DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.IF THE DEFENDANT HAS WITNESSES THAT HEISHE WOULD LIKE TO HAVE WITNESSES PRESENT, ORWOULD LIKE TO DISCUSS THE DEFENSE OF HISIRER CASE, THE DEFENDANT MUST CONTACT HISIRERATTORNEY.PRESENT IN COURT FOR THE CITY OF RENO: JILL DRAKE FOR THE DEFENSE: KEITHN LOOMISTHE DEFENDANT APPEARED, WAS EXPLAINED HISIRER RIGHTS BY THE JUDGE AND INDICATED THATHEiSHE UNDERSTOOD THEM COMPLETELY.

Offense Dt: 07/03/2012o

Suspended Days: 0Arrest Dt:Plea: 07/0512012 - NOT GUILTYDisposition:Charge 2: 06.14.130B - SECURE LOADS AND COVERS ON LOADSOffense Dt: 0710312012Arrest Dt:Plea: 07/0512012 - NOT GUILTY

Charge 3: 06.06.SSSA SECURED VEHICLE (INSURANCE) REQUIRED OWNER

Defendant Initials Print Date: 7/512012------------------

PCN :Jail Days: 0Suspended Days: 0

PCN :Jail Days: 0

Data Date: 71512012

WRT :

WRT :

Page 1 of


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Offense Dt: 07/0312012 Suspended Days: 0Arrest Dt:Plea: 07/05/2012 - NOT GUILTYDisposition

Next ProofDt:Balance: 1Completed Dt:

WHILE IC IF THE MAY 2012 EVAL CANNOT BEPROVIDEDNext Proof Dt:BalanceCompleted Dt:F AlLURE TO COMPLY WITH THE CONDITIONS OF BAIL AS DESCRIBED IN THIS ORDER WILL RESULT IN THE ISSUANCE OF AFAILURE T COMPLY WARRANT OR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT OF COURT AND/OR BAlLREVOCATION. FOR FURTHER INFORMATION, CONTACT THE SENTENCE COMPLIANCE WINDOW LOCATED ON THE FIRSTFLOOR OF THE RENO MUNICIPAL COURT ONE SOUTH SIERRA ST RENO NV (775) 334-2290.

THE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITH THEBAlLIFFSIMARSHALS AND ALL COURT STAFF.THE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEARANCES AND COURT-ORDERED PRCGRAMS ON TIME ANDALCOHOL AND DRUG FREE.THE DEFENDANT SHALL KNOW HIS/HER COURT DATE AND MAINTAlN CONTACT WITH HISIHER ATTORNEY.PRIOR TO CHANGING HISIHER ADDRESS OR PHONE NUMBER THE DEFENDANT SHALL NOTIFIY THE COURT OF SUCHCHANGE.OBEY ALL LAWS.

You are ordered by the Court to arrive drug/alcohol free and on time for all Court hearings and Court related programs. Failure toappear in Court will result in the issuance of a warrant for your arrest. Any violation of this instant order may result in contemptproceedings and the filing of additional criminal charges. In accordance with NRS 22.010, it is a misdemeanor for any person to failrefuse or neglect to comply with the terms of any order issued by the Municipal Court Judge. This order ,ill remain in effect until theCourt issues another order superseding it.UNDERSTAND AND PROMISE TO OBEY THIS ORDER. D E : F E ~ m A N DATE: TIME:

DEFENDANT: COUGHLIN, ZACHARY BARKERefendant Initials ------------------ Agency : 12-12728Print Date: 71512 12 COURT CASE N 12 CR 12420 21Data Date: 715/2012 Page 2 of


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I THE SWORN INTPRETER HAVE FliLLY INTERPRETED THIS ORDER TO THEDEFENDANT: DATE:, TIME:RECEIVED BY DEPUTY: DATE: TIME:ISSUED BY MARSHAL: DATE: TIME:

DEFENDANT: COUGHLIN, ZACHARY BARKER Agency : 12-12728Print Date: 7 512012Defendant Initials:

COURT CASE : 12 CR 12420 21Data Date: 11512012 Page J of3


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I

- -

. /ICourt#: 12 CR 12420 21Case Status: OPENCase Judge: ARR JOG

JUDGE'S C O ~ F I D E N T I A L NOTES7 ~ 5 2 0 1 2INCUSTODY VIDEO ARRAIGNMENTS

COUGHLIN, ZACHARY BARKEROOB: 09/2711976Ij3l Ui FvkM LWMPt iNi FitEOVYiiR iRECOoRi

CHARGES

Agency#: RPD 12.12728Booking#: 10621

Total Bail Amt:I 713/2012 08.12.020 - DISTURBING THE PEACE

IIIIiII

Plea:Fines/Fees:Cited Speed: Zone:

Notes:

J> I A Jc / dill'S

Oi Op:Amt Paid: Amt Waived:Location: SUMMIT RIOGE/MCCARRAN

Jail: 0 Suspended: 0Bal: 0

RIGHTS EXPLAIi'-iLD.P.N.G.g f . . t A ~


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I 7 3 2012 OS OS 55SA - SECURED VEHICLE (INSURANCE) REQUIRED OWNERPlea:Fines Fees:Cited Speed:

Notes:

COUGHLIN, ZACHARY BARKER71512012 Print Date: 71512012

Zone:

Disp: Jail: 0Amt Paid:location

AmtWaivedSUMMIT RIDGE/MCCARRAN

Suspended: 0Bal: 0

- END OF RECORD - AgencY': 1212728

RI HTS EXPLAINED.P.N.G

COURT CASE : 12 CR 12420 21


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v.

~CASE 11 \'2-\'2.17 t?

IN THE MUNICIPAL COURT OF THE CITY OF RENOCOUNIT OF WASHOE, STAlE OF NEVADA

Plaintiff,CQuG.tl.tut--l 2A


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CASE # 1212728IN THE MUNICIPAL COURT OF THE CITY OF RENOCOUNTY OF WASHOE, STATE OF NEVADA

CITY OF RENO,v.

Coughlin, Zachary

9f27n6DO SSN

Plaintiff,

Defendant

0' r IT'" r , , ~ p ( j j C r l l f ' \ ~ ;; : : ~ : . f ' , n l . , r ; , U l t . ~ ~ , . . t . ~ h :lCRIMINAL COMPLAINT(GENERAL)

I, A.J. Weaver, Badge 9469, hereby complain and say that Zachary Coughlin hascommitted the crime ofUnsecured load to wit:That said defendant on or about July 3,2012, in the City ofReno. State of Nevada, in thevicinity ofSummit Ridge Drive and the McCarran BI. overpass:

Operated a motor vehicle with a plastic stomge tub resting on the rear trunk lid unsecured whiledriving eastbound on Summit Ridge. The storage tub fell off the rear of the vehicle landing inthe middle of Summit Ridge causing a small SUV to brake and swerve around it.

o All ofWhich is in violation ofNRS1.04.015 of the Reno Municipal Code. as adopted by section[gI AU of which is in violation of 6.14.130.B of he Reno MunicipalCodeI therefore request that said Defendant be dealt with according to law.I hereby declare upon information and belief under penalty of perjlll)' pursuant to NRS171.102, that the foregoing is true and correct to the best ofmy knowledge.

w, --.. ~ ' I LRevlud91 6


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CASE 1212728IN THE MUNICIPAL COURT OF THE CITY OF RENOCOUNTY OF WASHOE, STATE OF NEVADA

CITY OF RENO, Plaintif(v

Coughlin, Zachary Defendant09127176DOB SSN

- 1

, . ~ , , 1 Tj: niCDOQiTIN': , ~ ' ' ~ ; ' ' ' ' ~ - ' , : : . J 4 . ' ~ ~ U t . , . : , I , ~ , . , , CRIMINAL COMPLAINTGENERAL)

I, AJ Weaver, Badge 9469, hereby complain and say that Zachary Coughlin hascommitted the crime of insurance required owner) to wit:That said defendant on or about July 3,2012, in the City ofReno, State ofNevada, in thevicinity of Summit Ridge Drive and the McCarran BI. overpass:

Operated a motor vehicle without current proofof valid vehicle insurance.

All ofwhich is in violation ofNRS1.04.015 of the Reno Municipal Code. as adopted by section

Z All ofwhich is in violation of6 06 5SS A of he Reno MunicipalCoder herefore request that said Defendant be dealt with according to law.I hereby declare upon information and belief under penalty of perjury pursuant to NRS171.1 02, that the foregoing is true and correct to the best ofmy knowledge.

1-?'-11.(Date)

l r lled 91 6


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AIUUi'Sl' REPORT AND -"---'"."'-.../ DEClAXATION OF PllOBABLE CAUSERIGINAL

ftQro,-----------------

REl810IlISllB 1lHA1IOH IS IIESIlIIC1ED lOCI IIA\IAl JIJI1I1CE _ ONLY. SECONIWIYWHEREFORE. 0ecIanInI1 8QIME 1h8I a findng be made by a ma g _ 1h8I JlIIIbabI': ; O f l ' . _ ' _ ) : f I 1 r 1 J l a l 1 . . d l a r g e l a a j ' d e ~ . DEClARANT -G. >.REVIEWED FOR I FIOBAIllE CAUSe (PC)

RP 12 9974CCASB /J /l7J g

DATE BYTlOH TO JlN.CJ NJNAL AGENCIES IS PRafI8/TED.A, I\d; aaId _ tor prellmlnaJy hearing (11 dlarge 10 aA i 1.0. 'i1. f

PC FOUND 0 PC HOT FOUND 0 DATE _______m.tE _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ MAGISTRATEDEFENDANT ORDERED RElEASED. DATE MAGISTRATES-308 (REVISED 106)


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vDECLARATION SUPPLEMENT

PAGE CASE: 1212728Details:On July 3, 2012, at approximately 0925 hours, the defendant identified as Zachary Coughlin,followed victim Milan Krebs as he completed his daily 1asks as a maintenance worker at theNorthwind Apartments.The defendant followed the victim for approximately 5minutes. During the time the defendantfollowed victim, he continuously yelled at him. According to the victim, the defendant yelled athim, Ifyou mess with my garage again, you will be sony. The defendant also yelled at thevictim it would be a mistake to mess with him. The victim believed the defendant wasthreatening him or attempting to bait him into a fight. The defendant's conductand words werecalculated to provoke violence or a violation o he law by the victimThe victim believed the defendant was threatening him with physical harm The victim told mehe is familiar with the defendant and believes he regularly displays unstable behavior.On July 3, 2012, at approximately 1041 hours, the defendant was seen driving a vehicle on apublic street toward the Northwind Apartments. The defendant had two large plastic tubs(approximately 3feet y l.5feet) riding on the top o his vehicle's trunk. The tubs wereunsecured and fell off the vehicle into the roadway as he drove. The tubs posed an immediatetraffic hazard and caused other drivers to swerve to avoid colliding with them.When the defendant was stopped for his traffic violation, he was not able to provide currentproof of insurance.The defendant was arrested for disturbing the peace, because he used conduct to provoke thevictim to fight and caused the victim to feel threatened. He was also charged with unsecuredload because he drove his vehicle on a public street with cargo that was unsecured and actuallyfell into the roadway. He was charged with insurance required because he did not have proof ofinsurance inside his car.Over the past few weeks, the defendant has been involved in multiple contacts with the victim.The contacts have all been similar in nature to the one the defendant and the victim on this date.The defendant was arrested and booked for the listed charges because he was likely to continueto commit acts of disturbing the peace upon the victim.

WHEREFORE, Declarant requests that finding be made by magistnrtc that probable cause existS to hold said person forprellmlnlU) hearing (ifchll 8e i felony or _ misdcmea/llH ) or for rial (ifchugc is a mlsdemconQr).REVIEWED FOR PROBABLE CAUSE (PC)PC FOUND PC NOT FOUNDDATIl _ MAGISTRATB P A G E ~ O F 1DEFENDANT ORDERED RELEASED, DATE: MAGlSTRATE


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j.

O R I G I N ~ L

PRINTCLEARl..Y

RESIDENCE ( Inlet, Cily. Slate. Zip)ADDRESS

O'ndiano Asian1/

~ . -..:..I.U.' .n.L UIDECLARATION OF PROBABU -USEV

COllllTO J1JBI5I)ICI10N . L ; f < ~ m _ c . - = - _RPO 12 997 4C

CASEI 1 J ~ / l 7 J 8~ m n __________________ _I KA/ALIAS

J The urodotslQilOO. a police oflicer. of . _ undar penally of porjuty.lhaIlI1e eIendant,haS beon arreatad on probable C8lIII8 andis subject,to detention fo,II1. aboVe-llate I oIIeneapenonaJIy or upon IntonneIIon and belief Ihis ofIicer learned Ihe foUowIng Iact8 end circumstances which support 111 arrest and detention:

A8.STO DATE BYDISSEMINATION IS RESTRICTED TO CRIMINAL JUSTlCE AGENCIES ONLY. SECONDARY I S S E ~ n O N TO NON-CRIMINAL AGENCIES IS PROHIBITED.

WHEREFORE. Declarant requests that a finding be made by a magistrate that p r o b a b l e ~ Sf b ~ 0 1 1 said person for preliminary.' hearing chfelony or gross misdemeanor) or for t r i a ~ a r g e is a misdemeanor). c A - . I.D.# li.f:,age t of DEClARANT ...A \..REVIEWED FOR PROBAB'.E.CAUSE (PC) /PC FOUND 0 PC NOT FOUND 0 DATE IME MAGDEFENDANT ORDERED RELEASED. DATE MAG


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ON: 7/2112012 @ 6:34:23PMNAME: COUGHUN,ZACHARY WC H03 47

DRIVER'S LICENSE: 08040977589/2711976BOOKING NUMBER: 1210621

OLSSTATE: NV

RECEIPT BI27239 ARRESTING AGENCY ICASE : RPD 12 12728 COUGHLlN ZACRARYCHARGI: LITERAL: DISTURBING PEACE (BR Level: MISDEMEANOR

RMC COURT CASE : 12CR12420ONE SOUTH SIERRA ST, RENO, NY 89520

AMOUNT: $ 1,000.00BY: JARED D SWANSON

4 8 E N T E R P R I S ~ B L \ ~ O Z E M A N MT 59718

BOND FEE: $ tf 2 INT: ,;-L HALEY, SHERIFf CLERK:- h '

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