1 4 13 607 Exhibit 1 12 13 12 0204 62337 SBN King's Email Fwd WCPD Leslie's Possible Veiled or Indirect Threat of Violence, King Expresses Concern for Our Staff to SBN President Flaherty

7/30/2019 1 4 13 607 Exhibit 1 12 13 12 0204 62337 SBN King's Email Fwd WCPD Leslie's Possible Veiled or Indirect Threat o…

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Laura Peters

From

Sent

To

Subject

This feels that his law firm staff was threatened lach

I am concerned our

Please advise.

Patrick King

From: Jim [mailto:[email protected]]Sent: Wednesday December 2012 2:50 PM

To: Patrick King

Subject: FW: The Three wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17 2012 to Coughlin in

r c r 2 1 2 ~ 6 5 6 3

Mr King:

The below email from Mr Coughlin contains a at the end of the first paragraph to a website containing a video

clip from the movie Cape Fear Please advise whether any action is required of our office or yours regarding this

possible veiled or indirect threat of violence against attorneys in this office by Mr. Coughlin.

Thank you

James B Leslie

Chief Deputy Public Defender

Washoe County Public

350 South Center Street

Fifth Floor

NV 89509

1 · 8 ~ 7 6 2 · 8 3 1Direct Dial: 775·337·4828

7 7 5 ~ 33 7 4 8 5 6

Office



f

2012 to in

to the State where none was

ones of a quality that I remember when my life featured moments like the bir th

twins .. but that was your wrecked shop on my existence. What shall be my

Do you mind if I put my arm around .... http://t inyurLcom/bgmlfdr

Bosler

cases and gag them he

to provide the client the of 9 calls DDA

~ U L U U J U and

Jimmy

no that would make it so hard to

to up this or



Attached are the materials in the and we had made an

copy of

up and you never

transmittal

you in response to your Please note that the cover letter was

it up. Note also that the July encloses a copy of

the very same documents which you received.

your

hand

removed from the 911 case, we are The attached materials were at our front

Since to retrieve we the copy final closure of our file.

No response to this transmittal is required from you.

James B. Leslie, Esq.

So, while Dogan states on 7 27 12 in 65630 Your Honor, I have never even spoken with Judge Dorothy Nash

Holmes .. he coyly f ils to indicate whether he spoke with anyone with the RMC, Marilyn Tognoni, included, or why his

2 28 12 fax to Coughlin was so insistent that it was Lake's Crossing's Bill Davis, Ph.D. who must conduct the

Competency Evaluation , or how it was Judge Clifton's 2/27/12 Order for Competency Evaluation could have possibly

known and included Judge Elliott as the randomly assigned judge to that Competency Case in C R 1 2 ~ 3 7 6 (Judge Elliott

on Committee to Aid Abused Women's Board, (CAAW) ..Judge Elliott presiding over Coughlin's wrongful terminat ion

lawsuit against WCDA s Office ECR Partner, Washoe Legal Services, its Executive Director Paul Elcano, and CAAW, in

C V l l ~ 1 9 5 5 .. .Judge Elliott fails to disclose conflict or recuse himself, Judge Elliott manages to randomly be assigned

Coughlin's two criminal appeals from RMC convictions (the W a l ~ M a r t candy bar pet ty larceny leading to a 6 months, so

far, temporary suspension of Coughlin's law license in 11 cr 22176 in the RMC, then c r 1 1 ~ 2 6 4 in the appeal Judge Elliott

canned based upon a civil statute requiring a down payment for the preparation of transcripts and Elliott's contention

that he need not address the merits of Coughlin's appeal given the lack of a written transcript (Coughlin paid for the

audio cd, and its not even that the RMC is a court of record anyways, and the RMC distributes to defendants

instructions sheets and enforces house rules the preparation of transcripts that require one utilizing the

services of RMC official Pam (whom up on Coughlin twice, and refused to prepare the

in cr and where the RMC refused to even

the audio have it made available to

didn't

R e v 2 1 1 ~ 1 7 8and incarcerated between

in with

a video and other evidence





records show no not on that means the ball is in

your court to show how to Sferrazza on in court were not a lack of

candor to the tribunal and How Leslie Tibbals' on service therein is not

attached 12 19 11 which includes:

FOR DISCOVERY

or any or

of which is known or by the exercise of due

includes any video and audio

emergency and any ( Hen:>1rr

Jim then there is you chiming in, in your role as "standby counsel" attempting to aid the Court and DDA Young in

from me my Fifth Amendment rights at the 9:06 am mark on the transcript from 11/20/12 ("Your Honor, IIremind the Court that' am here to jump in in my role as standby counsel anytime the Court's feels he is dragging his

feeL .He is wasting County assets " ..very Atticus Finch, Jim).

So then there is Jim's 10/3/12 subpoena to Ecomm/Kelley Wood ..and given he was counsel of record until 10/22/12,

yet completely failed to turn over anything (responsive or not) in relation to that subpoena, and the fact that the entire

Suppression Motion turned on what information the RPD received from dispatch", and the fact that the audio of the

"radio traffic" between the RPD and Dispatch on that night (or at least the portions of it I have been able to extract from

the powers that be) reveal, one no report of a possible fight was received by RPD (they were on the scene by the time

the 11:27:11 pm text was sent to the displays in their vehicles, and the one audible "radio traffic

recording contains no

mention of anything beyond "check for possible larceny of a cell phone that just occurred suspect still on the scene also

reports of a loud verbal disturbance .. ". Then there is Jim and Goodnight completely whi ffing on the detaining

argument in addition to the whole "assuming we win on the pat down, make sure to oppose the notation that there

was sufficient probable cause for an arrest and search incident thereto ... ", not to mention that it was Coughlin (whose

Jim managed to cheerfully announce "The Public Defender's Office is not joining in on those fugitive

documents...", despite the Filings by Goodnight that do just that...) that pointed out the whole NRS 171.360

basis for throwing out the search (which Jim managed to not cite to or quote from in his closing argument as the

Jim did manage to ask Cory Goble questions on cross that were designed to do nothing

more than establish a citizen's arrest sufficient to rebut the NRS 171.360 basis for throwing out the arrest and fruits

culled therefrom.

then there is your

redacted version of the

to 1 f T 1 1 ~ 1 r



clandestine status conference fallout with Nash

hours after secured his nPT pnH Evaluation in 065630

in a as a

on an ethics violation wherein she

violation that Bar Counsel had her earlier in the that window the 1:00 pm start time

the citation trial in 11 tr 26800 and the 3:30 pm eventual start time includes the 1:25 pm courthouse

{by RMC Marshal on WCSO hired by

was RPD

to Tarter

Jr. ... and Marshal Harley was

summary eviction from Coughlin's former law (where RPD Carter made the trespass arrest now

Ct. case 61901), on behalf of Deputy Machen, in the room within the Courtroom Bof the RMC,

Coughlin, an having already been served it). However, the only filing by Coughlin that could be said to quote rock

lyrics is the 2/21/12 filing in Dogan's case 065630 (the one where Dogan had appeared as attorney of record then failed

to show up for a hearing on 2/13/12, then retaliated against Coughlin for Coughlin's 2 21 12 filing in 065630 by movingfor a Competency Evaluation and basically doing absolutely nothing on the case for the next 9 months besides raping

from Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach Young at the 4/19/12 hearing in

CR12-0376 (one of 3 criminal appeals Judge Elliot was randomly assigned in which Coughlin is a party .. to go along

with the wrongful termination suit by Coughlin that Judge Elliot presided over in CV11·01955 wherein Coughlin sued

CAAW and WlS, despite Judge Elliot sitting on CAAW's Board, and where Judge Elliot, the Panel Chair at Coughlin's

formal disciplinary hearing of 11/14/12, and Washoe legal Service's Paul Elcano all went to Stanford together, and

where Judge Elliot worked for Panel Chair John Echeverria's father's law firm, Echeverria and Osborne). Then there is

Linda Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from Mental Health Court in MH12-

0032, where the MHC's Rene Biondo and Sharon Dollarhide lied about what medications were listed as accepted or not

in the materials provided by Goodnight and or the MHC along with the contract entered into with Coughlin, whom was

into the MHC. Then there is WCPD Joe Goodnight and Jennifer Rains refusal to file anything directed towards

enforcing the MHC s contract with Coughlin, wherein they both demonstrated they know what side their bread is

buttered on and indicated there just isn't a basis for seeking reconsideration of Judge Breen's Order . Judge Peter

Breen, MD.

with anyone else at the Reno Municipal Court about

indicated he never with Nash Holmes, in his

away with Jim leslie in the area

Sferrazza of the attendant to his earlier

attestations



seemed to have to admit that the use

matter ..but rather linda

to her that she not mail out any written notice to

in r c r 2 0 1 2 ~ 0 6 7 9 8 0 or rcr2012·065630

in any much less in tA, r 'T IM'

had been noticed on the Jim

away

I have a Trial this case r c r 2 0 1 2 ~ 0 6 5 6 3 0 . You have continued in your way to how you

the r c r 2 0 1 1 ~ 0 6 3 3 4 1 case where Joe was counsel of record until you had him removed on

a video trial at

4:30 pm on July 2012 while I was in custody (pursuant to an arrest on July

' .... f PTlT Kim Bradshaw, she of the custodial jaywalking arrest along with RPD

the Mr. when you place a gag order on the associates you claim to

petulantly, and retaliatorily to work the cases you have snatched back from your

Fortier's email to me February 6th, 2012 may have contributed to Mr. Dogan's confusion in failing to

on 13th, which begat my filing of February 2012, which Mr. procurring the

February 27th, 2012 Order for Competency Evaluation, which begat the 5 day summary incarceration forsummary/plenary/criminal/civil/transmogrified disciplinary hearing on an ethics violation/what is jurisdiction? Order by

RMC Judge Nash Holmes on 2/27/12 at 4:40 pm ... which begat NG12-0434, and probably 0435 (the SBN v. Coughlin SCR

105 Complaint of 8/23/12).

However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag order on you. Mr. Leslie sent this

email today with a 56 page pdf file purporting to be my file . I as now a former client, have rights to my file . I have

requested my file in writing from your office on numerous occasions, and given your removal as counsel of record on

11/22/12 (amazingly Mr. Dogan probably managed to say 200 words on a case that he had been counsel of record on for

nearly a year, and had not managed to file a single document in that case R C R 2 0 1 2 ~ 0 6 5 6 3 0 and had managed to

upset that a client would take issue with his missing the 2/13/12 Hearing, even though WCPD Fortier's 2/6/12 email

makes the mat ter was to Mr Dogan at that point, and he had already sat down and discussed the case

with Coughlin for over one hour on or about February 8th, 2012, where Coughlin went to check in with Mary Watson,

by WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and

her client. They did, she was taken into custody.

and that



a former ass

in CVl out his per se conflict of interest to

every wrinkle in service and or

process a movie a non over 18 years age a senior at

whose Executive Director Paul Elcano went to with Elliot and the Panel Chair of

State Bar John Echeverria in the late 1960sH and

Echeverria and Osborne Board of

whose Executive Director

rn""Jt>,rl" ::l the Panel Chair

worked at John

served on the Board for CAAW, and was a

in to

Also, Mr. while the 56 page pdf you finally sent me was it that hard to click , load a 2 mb pdf

and hit on an email to me? No debatin', no arguing about whether Leslie and left the package at the desk,

whether Dogan already gave it to Coughlin, or whether Dogan then changed his story and said Leslie gave it to Coughlin,

whether Coughlin picked it up, no claims by Jessica the Receptionist of anyone kickin' furniture ..nothing likethat, just a digitally verifiable means of ascertaining what you transmitted and when ... was that so hard? Heck, Jim, you

could probably just email those ECOMM recordings too ..and if attachment size is an issue, sign up for a

www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive functionality, and up to 100

mb attachments via plan email, and over 25 free gb of storage on the Skydrive, etc., etL. . But its Leslie finally sent the

56 page client's file on or about 12/7/12, yet he failed to include the insipid Motion of 11/26/12 by DDA Young

(wherein, just after Judge Clifton finishes telling Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even

think about the other two RJC shotgunnin' style splatter paint prosecutions by DDA Young, as they are just not relevant

to this proceeding ...and anytime Coughlin would point out specific basis for undertaking a recusal or conflict analysis vis

a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or the WCDA, Judge Clifton would say your're losing

me ... your're losing me ... as if Coughlin was speaking in tongues all the sudden ...

while Coughlin is reportedly not even allowed to email DDA Young about cases not even before Judge Clifton, or

something like that...DDA Young is able to an unnoticed, ex parte, emergency Motion to Prho

Zach

1471 9th t



CC

911 Case

Date: 7 Dec 2012 17:09:08 +0000

Mr

Attached are ernup materials in the case that you had and had made an

copy of for you in response to your Please note that the cover letter was for your

up and you never it up. Note also that the

transmittal of the very same documents which you received.

Since we have been removed from the 911 case we are closing our

desk. Since you failed to retrieve them, we provide the attached

No response to this transmittal is required from you.

James B. Esq.

Chief Deputy Public Defender

Washoe County Public Defender s Office

350 South Center Street

Fifth Floor

NV 89509

encloses a copy of the hand

The attached materials were at our front

copy before final closure of our file.



If you are not the you are th t any

any action reliant on said contents are CONFIDENTI L and

communication in error us at to return of the transmittal.

Thank you.

Documents

1 4 13 607 Exhibit 1 12 13 12 0204 62337 SBN King's Email Fwd WCPD Leslie's Possible Veiled or Indirect Threat of Violence, King Expresses Concern for Our Staff to SBN President Flaherty