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IN THE SUPREME COURT OF THE STATE OF NEVADA

ZACH COUGHLIN;

Appellant.

vs.

SBN Respondents

.

))))))

Supreme Court No: 62337

NOTICE OF IRREGULARITIES

Coughlin hereby files this and Declares under penalty of perjury pursuant to

NRS 53.045 that everything within this filing and attached to it is true to the best of

his knowledge, and that any matters stated upon information and belief herein

Coughlin reasonably believes them to be true and that all materials attached are true

and correct copies of what they purport to be.

Dated this 7 17 13

/s/ Zach Coughlin, signed electronically Zach Coughlin, Esq.

Appellant

- 1/3 -NOTICE

Electronically FiledJul 18 2013 10:21 a.m.Tracie K. LindemanClerk of Supreme Court

Docket 62337 Document 2013-21067

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Proof of Service:On this date, I, Zach Coughlin electronically served a true and correct copy of the foregoing document to all registered efilers, and to those whom are not I placed a true and correct copy of the foregoing document in the usps mail on this date: David Clark via Eflexmailed to Pat King at Bar's Northern Office, EPO permitting

DATED THIS: Dated thi 7 17 13

/s/ Zach Coughlin Zach Coughlin Appellant

- 2/3 -NOTICE

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INDEX TO EXHIBITS:

1. Exhibit 1: various relevant materials.

- 3/3 -NOTICE

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IN THE SUPREME COURT OF THE STATE OF NEVADA

ZACH COUGHLIN;

Appellant.

vs.

SBN Respondents

))))))

Supreme Court No: 62337

NOTICE AND DECLARATION AS TO SBN CLERK OF COURT PETERS AND ASSISTANT BAR COUNSEL KING'S PICK AND ROLL COMBO;

MOTION TO PROCEED IN FORMA PAUPERIS IN THIS APPEAL AND ANY PROCEEDINGS TO BE CONDUCTED IN THE TRIAL COURT; MOTION TO

REQUIRE KING TO BECOME AND EFILER SUFFICIENT TO AMELIORATE CURRENT CIRCUMSTANCES WHERE RPD AND CITY OF RENO ATTORNEYS ARREST AND PROSECUTE COUGHLIN FOR EVEN

ALLEGEDLY SERVING FILING ON THE SBN (WHICH IS AN ARM OF THE COURT UNDER WATERS, ANYWAYS)

Petitioner, ZACHARY BARKER COUGHLIN, representing himself files this Notice for the de novo review, noting to the failure of NNDB Chairman Susich, apparently, to follow SCR 110(3)-(4)'s requirement that he notify a District Court judge of the contempt attendant to a variety of individuals and entities failing to respond to Coughlin's SCR 110 subpoenas for the 11/14/12 formal disciplinary hearing

And to give, uh, credit, where it is due, City of Reno Prosecutor Dan Wong, Esq. is Glass Plus on the boards...currently subjecting Coughlin to two different baseless prosecutions in the Reno Municipal Court, even where Wong "happily" admits that he would prosecute Coughlin for alleged violation of the jurisdictional prerequisites devoid Reno Justice Court Workplace Harassment TPO/EPO obtained against Coughlin by the SBN on 12/20/12 in RCP2012-000607

- 1/71 -NOTICE AND DECLARATION

Docket 62337 Document 2013-21067

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MOTION FOR LEAVE TO FILE OPPOSITION TO SCR 111(4) PETITION IN 61901,

7 C.J.S. Attorney & Client IV. Professional Conduct and Supervision Thereof 41. Generally 42. Canons of ethics and codes of professional responsibility 43. Standards of conduct 44. Aiding administration of justice 45. Solicitation of clients 46. Advertising, letterheads, and listings 47. Protection and representation of clients 48. Exercise of independent judgment; conflicting interests 49. Preserving funds and property of client 50. Preserving confidences and secrets 51. Zealous advocacy; assertion of frivolous claims 52. Making of extrajudicial statements 53. Dealings with opposing counsel, parties, witnesses, and jurors 54. Dealings with opposing counsel, parties, witnesses, and jurorsComm. with repd party 55. Dealings with opposing counsel, parties, witnesses, and jurorsEmployees of parties 56. Influencing official action; prior public employment 57. Fees, compensation, and sale of practice 58. Miscellaneous activities or conduct 59. Methods of enforcement; disqualification 60. Determination of grounds for disqualification

V. Discipline, Suspension, and DisbarmentA. In General

61. Generally 62. Power of particular courts, committees, and agencies 63. Defenses 64. --Limitations and laches 65. --Personal problems or mental disabilities 66. --Settlement with, or absence of objection by, client

B. Grounds1. In General

67. Generally 68. Moral turpitude, dishonesty, and corruption 69. Want or loss of moral character 70. Mental or physical illness, alcoholism, or drug addiction

- 2/71 -NOTICE AND DECLARATION

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71. Fraud in procuring admission 72. Criminal offenses and conviction thereof 73. --Effect of pendency of criminal proceedings 74. --Effect of acquittal or pardon 75. --Effect of appeal and reversal; post-conviction relief 76. Misconduct in nonprofessional capacity 77. Misconduct as public officer or judge

2. Professional Misconduct 78. Generally 79. Misconduct in relation to client 80. --Disregard of client's interests; representation of conflicting interests 81. --Improper dealing with funds; misappropriation 82. Misconduct in relation to other attorneys 83. Misconduct in relation to court 84. Deception of court and obstruction of justice 85. Misuse, falsification, or alteration of records and papers 86. Misconduct in relation to disciplinary authorities 87. Solicitation of clients and advertising 88. Miscellaneous grounds

C. Proceedings, Disciplinary Order, and Punishment1. In General

89. Generally 90. Nature, form, and purpose of proceedings 91. Functions and qualifications of persons conducting proceedings 92. Applicable forms and rules of procedure 93. Notice 94. Preliminary investigations and proceedings 95. Disclosure, discovery, and examination; confidentiality of proceedings

2. Parties and Pleadings 96. Persons entitled to prosecute; parties 97. Charges; issues, proof, and variance 98. Answer

3. Evidence and Burden of Proof 99. Generally 100. Presumptions and burden of proof 101. Admissibility of evidence 102. --Weight and sufficiency 103. Degree of proof 104. Evidence of particular misconduct

4. Trial or Hearing a. In General

105. Generally 106. Questions of law and fact; dismissal

- 3/71 -NOTICE AND DECLARATION

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107. Deliberations, scope of inquiry, and verdict or findings b. Disciplinary Board Hearing and Judicial Review

108. Hearing and determination by referee, committee, or board 109. Review by court 110. --Scope of review

5. Disciplinary Order and New Trial 111. Decision and judgment or order 112. --On review of action of referee, commissioner, committee, or board 113. New trial and rehearing

6. Appellate Review 114. Review of judgment on appeal 115. Scope of review and determination of case

7. Punishment 116. Generally 117. Circumstances considered in fixing punishment 118. Particular offenses or misconduct 119. --Misconduct in relation to client

8. Costs and Effect of Judgment 120. Costs 121. Operation and effect of judgment or order 122. --Practice in other jurisdictions

D. Reinstatement After Disbarment or Suspension1. In General

123. Generally 124. Discretion of court and scope of inquiry 125. --Controlling factors 126. Effect of pardon or reversal of conviction

2. Procedure 127. Application for reinstatement 128. --Evidence and burden of proof 129. --Findings, conclusions, and judgment

How ironic it is that the allegation Merliss's counsel made in his 2/24/12 Answering Brief in the Appeal to the Dist. Ct. that Coughlin "failed to raise" the issues of his being a commercial tenancy sufficient to prohibit, under NRS 40.254, the use of the summary procedures in NRS 40.253 where a no cause eviction was plead (and clearly, at no point did Merliss amend his pleadings or "unlawful detainer affidavit" sufficient to make his action for possession one based on non-payment of rent, and the trial court may not amend the landlord's pleadings for him, especially where the landlord's attorney, fearful of the NRCP Rule 11 implications attendant to making any such claims of rent owing and expressly indicating that he

- 4/71 -NOTICE AND DECLARATION

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was pursuing a "no-cause eviction" under NRS 40.254 (with such statutory section specifically cited in the very "unlawful detainer affidavit" admitted as one of the landlord's exhibits during the 10/25/11 proceeding, in addition to in the landlord's attorney's 10/19/11 Declaration (which expressly indicated it was being filed in an attempt to satisfy the requirements of NRS 40.254(2)) and decidedly not alleging any rent was owed, nor seeking an award of any rent. Dubiously (and a fine review of this matter likely reveals an alarming degree of judicial misconduct), the RJC, in addition to appearing to attempt to plead non-payment on behalf of the landlord (incident to conducting a sua sponte interrogation of Coughlin at the initial 10/13/11 proceeding upon the problem of the landlord failing to show up and his counsel not being an appropriate witness sufficient to permit Coughlin an opportunity to "test the truthfulness and sufficiency" of some "unlawful detainer affidavit" which had not even been filed (or, apparently, even provided to Coughlin until, at the earliest, the day before the 10/25/11 proceeding), also seemed to attempt to coax the landlord into seeking an award of past rent out of the "rent escrow" deposit ordered pursuant to NRS 118A.355(5) (and Coughlin's pleading a commercial tenancy clearly precluded any such application). Such brings up the illegitimacy of requiring a tenant (particularly a commercial tenant) to make such a rent escrow deposit (based upon a statutory section found in NRS 118A, the "Residential Landlord Tenant Act") especially where the "unlawful detainer affidavit" manifest from the record (not "you failed to raise it" bar where it is manifest from the record that Coughlin did in fact raise such issues in the trial court)...ironic considering that Merliss's attorney's are the one's against whom the "you failed to raise it" or DCR 13(3) bar (which was applied, mistakenly to Coughlin in the appeal in Flanagan's 6/25/12 award of attorney's fees, to which an excusable neglect analysis is required (to whatever extent Coughlin's 1/14/12 "standing order going forward" Opposition to any attorney fee motion ever brought by Hill or his associate is not recognized) considering the inequity attendant to the summary 8 day incarceration by Judge Elliott in CR12-0376 starting the very day, 4/19/12 that the Motion for Attorney Fees/Sanctions in the appeal to the Dist Ct. appealed herein was filed, not to mention the NRS 178.405 mandatory stay violations committed by the WCPD, WCDA's Office, and, however coincidentally, Judge Sferrazza where they attempted to hold a trial on the very day the deadline to file an Opposition to that 4/19/12 Motion for Atty Fees/Sanctions feel due, 5/7/12 in the convictions now on appeal in CR12-2025 (that trial was within the criminal prosecution of Coughlin for some half-baked "lost, mislaid, or abandoned property" as not only petit larceny (but, ridiculously,considering a "thief cannot receive from himself the fruits of his larceny", a "receiving stolen property" charge an subsequent conviction for both charges as well, despite Judge Sferrazza being provided both Shepp and Staab sufficient to undermine the receiving charge, especially where there was zero allegation that the man allegedly finding the phone on the ground had "stolen" it, much less any assertion that Coughlin "knew" such man had "stolen" any such item Coughlin thereafter was said to have been freely

- 5/71 -NOTICE AND DECLARATION

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given by said man) allegedly retrieved by Coughlin from one finding an iPhone on the ground in downtown Reno, whom then loudly announced to all in the plaza in front of City Hall that he would "throw it in the river" if someone did not immediately claim the phone). While Coughlin filed many documents which may appropriately be viewed as functional equivalents thereof, any view that Coughlin failed to timely file, or otherwise seek to address later an such failure to file, a Reply to the 2/24/12 Answering Brief in the appeal clearly must view any such failure as satisfying the "good cause" or "excusable neglect" standard. This is particularly true where at the time such Reply would have been due Coughlin was incarcerated, wrongfully, incident to the summary contempt 5 day incarceration he was subjected to (even where he pleaded with Judge Holmes (not to mention the prejudice to his case brought by a similar refusal (consider NCJC Rule 2.15) by RMC Judge Howard to grant a stay of any sort as to his own 3 day summary contempt incarceration of Coughlin between 11/30/11 and 12/3/11) that a failure to accord a stay of any length at all would not only prejudice him (especially where self representing as a license attorney in a number of matters (and if In Re Schaeffer allows for applying RPC's against attorneys where proceeding pro se, then the traditional rule essentially requiring a stay of any summary contempt incarceration of an attorney (to avoid prejudice to his clients/interference with the orderly administration of justice in the other matters wherein the attorney is appearing) should have applied to the summary incarceration of Coughlin on 2/27/12 not only in light of Coughlin representing clients other than himself, but also in light of the matters wherein Coughlin was self representing, as a licensed attorney whom subsequently had a bevy of RPC's applied scattershot to his self representation therein. To hold otherwise would be tantamount to the SBN and Bench seeking to have it both ways. (During the relevant times involved herein, Coughlin was represneting clients, including a single father living in Florida in UIFSA and custody matters, in Jones v. Harris; foreclosure defense clients in Carpentier v. Aames; debtors in adversary proceedings in the NVB before the same Judge Beesley (hard to cross examine a "judge as witness" (wait, SBN/Panel, didn't the 11/2/12 Motion to Quash Coughlin's subpoenas on judges and the 11/7/12 Ex Parte Order granting it rule one couldn't "question judges as to their though processes"? Law of the case? How then were Judge Beesley and Judge Holmes able to testify about their thought process (but only to the extent doing so suited the agenda of the SBN/Panel) at that hearing:

HEARING - Vol. I, (Pages 135:22 to 138:9) BY MR. KING: Q -- paragraph 3, and this is partly for the purpose of laying a foundation, did you actually write it? It says, "He has not practiced law in this case in a manner that demonstrates his competence, professionalism, preparation, consideration for the court, the witnesses or his opposing counsel. He has been very disrespectful to the court." Did you write that? A Yes, I did write that. Q And then you made a list, you actually went so

- 6/71 -NOTICE AND DECLARATION

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far as on Page 4 as to be very specific in listing the rules of professional conduct that you were saying he violated? A Yes, I did. Q You listed 8.4, engaged in dishonesty, fraud, deceit or misrepresentation. Because I'm limited in time, I'm not going to read them all, but I'm going to ask that Exhibit Number 5 be admitted. MR. ECHEVERRIA: Objection, Counsel? MR. COUGHLIN: Yeah. This looks totally different than the one that's in the file. What's going on here? Why is this one all blurry and illegible, and this one like pristine clean, Pat? MR. ECHEVERRIA: What is the objection, Mr. Coughlin? MR. COUGHLIN: If this wasn't propounded. MR. ECHEVERRIA: This wasn't what? MR. COUGHLIN: This version wasn't propounded earlier. MR. ECHEVERRIA: It was attached to the complaint. MR. COUGHLIN: This is clear. The problem is the one he's always attached to the complaint is not clear. THE WITNESS (JUDGE HOLMES): Mr. Echeverria, that was also provided to Mr. Coughlin. At the time that order was entered, I had him served up in jail when he was being held for contempt -- MR. COUGHLIN: No, you didn't. THE WITNESS: -- mailed to his house as well. MR. COUGHLIN: No, she didn't. MR. ECHEVERRIA: Thanks, Judge. I'm going to admit Exhibit 5. It was the order attached to the complaint. It was provided as Bates numbers 1804 through 1809 to the documents copied and produced for Mr. Coughlin. So Exhibit 5 is admitted. (Exhibit 5 admitted into evidence.) BY MR. KING: Q Judge Holmes, was it your intention -- you made these findings by clear and convincing evidence, which is the standard of proof necessary for disciplinary proceedings. Was it your intention that this order be accepted by the panel as proof of his -- as irrefutable proof of his violation of these rules? A Yes, it was. And I'm not intending to substitute myself for the panel . I understand, and did understand, that it was their job to conclude that. But I did want to tell them that in my experience, and based on my judicial position, I did find that established by that particular level of proof. And I do believe that it has that, in my experience with him ". Regardless of the fact that it is not true, and the the Certificate of Service for that 2/28/12 Order contains no indication that Coughlin was served any such Order "at the jail", the SBN in no way notice-pled the idea or factual contention that the RMC's failure to serve Coughlin the 2/28/12 Order (the RMC received as "return to sender" the one version it mailed to Coughlin, which was mailed to an address that the RMC knew was no longer good, and where the RMC thereafter failed to remail such Order to the address which it had been informed by Coughlin was current) would somehow be countered by Judge Nash Holmes, curiously, and conveniently, all the sudden remembering that she had this one Order from nine months prior served on Coughlin while he was in jail, over, above, and beyond having it "mailed to his house as well" (glossing over the bit about having it mailed to an address Judge Holmes knew was outdated, and the failure to attempt any alternate service thereof upon receiving such wrongly address mailing back marked "no longer at this address".

- 7/71 -NOTICE AND DECLARATION

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Also, it is particularly rich that immediately after the SBN's King address some undefined "finding" in the 3/12/12 Order by Judge Holmes that Couglin had violated RPC 8.4 that King himself then immediately thereafter engages in just such misconduct where he attempts to slip into the record a version of that Order that excises all the notice/legibility issues inherent to his attaching to the 8/23/12 Complaint a far different version of that Order, one that represents a very off center photocopying of such order replete with the last five lines or so of every page completely illegible due to being incredibly faint and blurry (which is especially problematic when considering those parts of that Order which were illegible in the version attached the the Complaint by King (ironic this legibility issue pops up here considering the wholesale dismissals of Coughlin's suit against witness Elcano's own WLS, et al in 60302, and 60317) comprise a major percentage of those excerpts from that Order relied upon by the Panel in its 12/14/12 FOFCOL or testified to by Judge Holmes. Due process. Notice. Opportunity to be heard.

Judge Beesley whom testified at Coughlin's 11/14/12 formal disciplinary hearing (though Beesley could not remember much of anything in the way of specifics to support his outrageously negligent contention that Coughlin resulting in a ridiculous and shameful recommendation by the SBN and NNDB Panel to permanently disbar Coughlin now appeal in 62337 (consider the inequity of the events of March 2012 in Coughlin's life and practice in comparison to the actions and testimony at his 11/14/12 formal disciplinary hearing of Judge Beesley and RMC Judge Holmes (in addition to her 3/14/12 greivance letter against Coughlin to the SBN.

HEARING - Vol. I, (Pages 10:6 to 11:7) BRUCE BEESLEY Having been first duly sworn, testified as follows: DIRECT EXAMINATION BY MR. KING: Q Judge Beesley, can you explain to the panel your knowledge in this relevant time frame 2011-2012 regarding Mr. Coughlin and his conduct in your court? A Mr. Coughlin appeared in my court a couple of times, at least two or three times. The first time I recall him coming to my court he came in, he was wearing, I think, a T-shirt and a tie, and no jacket. And he indicated that he had been evicted from his residence or his office, indicating it was not because of not paying the rent, and that that was why he wasn't what I would consider appropriately dressed. I apologize. I don't have my letter in front of me. But my recollection is that he had filed a pleading on behalf of his client in regard to some aspect of a bankruptcy case, and that the pleading was lengthy, didn't make any sense, and just sort of rambled through a great deal of irrelevant stuff. I had him a couple other times in my court and had the same experience, that -- he was dressed appropriately the other times I had him there, and he was very polite and appeared to be a very intelligent man. But his pleadings didn't make any sense. His arguments didn't make any sense."

- 8/71 -NOTICE AND DECLARATION

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HEARING - Vol. I, (Page 24:14 to 24:19) Q You would be referring to the T-shirt and tie incident? A Yes. Q With a suit jacket on though? A Yeah. And your apology was satisfactory, although I thought your appearance was odd."

HEARING - Vol. I, (Page 15:10 to 15:20) BY MR. KING: Q Have you formed an opinion, your Honor, as to whether or not Mr. Coughlin is competent to practice law? A (Judge Beesley): Yes. Q And what is that opinion? A I don't believe he is, unfortunately. MR. KING: Thank you very much. I have no further questions. I really appreciate your time. The panel in these settings may ask you questions or they may have questions for you, as well as, I suspect, Mr. Coughlin." Note the SBN's complete and utter lack of effort to gather a single shred of specific factual testimony or documentation to support the testimony it elicited from Judge Beesley.

HEARING - Vol. I, (Page 16:1 to 16:18) CROSS-EXAMINATION BY MR. COUGHLIN: Q Good morning, Judge Beesley, your Honor. A Morning. Q I'm sorry to hear you feel that way about me, sir, but I would like to ask you a few questions. A Certainly. Q I would bet that your statements are made out of concern. A They are. Q So I appreciate that, sir. And I don't mean for my reactions this morning to indicate anything other than a complete and utter... -- a complete and utter respect for you, sir. A I don't take it any other way. Q Thank you, sir. But it's out of a profound respect for the law and due process that I'm acting the way I am."

HEARING - Vol. I, (Pages 22:10 to 23:18) ow that I did that. Q What review did you undertake of my work product and filings in your court to come to your opinions? A I looked through two or three pleadings that you had filed in, I think you had one or perhaps two cases, and read them. And I observed you arguing in court. Q When specifically? A I don't recall. Q Was your testimony earlier today that the first time you recall being aware of me was when I appeared at the March 15th hearing in Cado Company v. Keller at 2:30 P.M. shortly after being evicted at gunpoint by the Washoe County Sheriffs -- A I actually think you had appeared in front of me one time before that. But that was my first strong recollection of you appearing in front of me. Q And it was that brief interaction whereupon you formed your opinion that I wasn't fit to practice? A No. I thought it was odd, but I do understand that people have adversity in their lives sometimes, which happens -- Q You took it to be adversity rather than misconduct by the sheriff? MR. ECHEVERRIA: Mr. Coughlin, you interrupted the witness. MR. COUGHLIN: Yes. MR. ECHEVERRIA: Go ahead, Judge. THE WITNESS: And I believe that you had filed some pleading in that case. And I went to the pleadings, and they frankly didn't make any sense. And I think you subsequently filed

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pleadings in other cases which also didn't make any sense, and I became concerned."

HEARING - Vol. I, (Pages 22:10 to 23:18) ow that I did that. Q What review did you undertake of my work product and filings in your court to come to your opinions? A I looked through two or three pleadings that you had filed in, I think you had one or perhaps two cases, and read them. And I observed you arguing in court. Q When specifically? A I don't recall. Q Was your testimony earlier today that the first time you recall being aware of me was when I appeared at the March 15th hearing in Cado Company v. Keller at 2:30 P.M. shortly after being evicted at gunpoint by the Washoe County Sheriffs -- A I actually think you had appeared in front of me one time before that. But that was my first strong recollection of you appearing in front of me. Q And it was that brief interaction whereupon you formed your opinion that I wasn't fit to practice? A No. I thought it was odd, but I do understand that people have adversity in their lives sometimes, which happens -- Q You took it to be adversity rather than misconduct by the sheriff? MR. ECHEVERRIA: Mr. Coughlin, you interrupted the witness. MR. COUGHLIN: Yes. MR. ECHEVERRIA: Go ahead, Judge. THE WITNESS: And I believe that you had filed some pleading in that case. And I went to the pleadings, and they frankly didn't make any sense. And I think you subsequently filed pleadings in other cases which also didn't make any sense, and I became concerned."

HEARING - Vol. I, (Pages 24:20 to 25:17) Q Do you recall a hearing prior to that in that same Cado Company v. Keller wherein Cado sought to amend their adversary proceeding charges, and there was maybe a five- to ten-minute hearing on that incident to which I submitted about a 15-page motion addressing the salient points of law in that setting? A I cannot place it in the context of that case. But I do remember you submitting a motion describing some points of law on something, and I didn't think that that was competent work, frankly. Q You're referring to which motion? A I don't know. I don't have any motion in front of me. Q So you have a fairly strong opinion on it, yet you don't recall any specifics. Would that be an accurate assessment of your testimony? A What I recall is that your appearance in court was odd, and your pleadings were not truly comprehensible, and that and further inquires made me concerned that you were having some difficulties that prevented you from serving your client appropriately. Q Did you find any of my work competent? A I don't believe I did."

HEARING - Vol. I, (Pages 26:25 to 28:1) BY MR. COUGHLIN: Q Your Honor, I'd like to narrow down some of these assessments you've made vis-a-vis when they

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occurred. A Unless you can show me the document, I don't think I can help you with that. (NOTE: that may have been an attempt at humor by Judge Beesley considering he was testifying by phone, as did Judge Holmes...similarly, King alluded to Judge Holmes "authenticating" an Order over the phone) Q But you've testified pretty definitively here today. So wouldn't that indicate some negligence on your behalf in that regard? MR. KING: Objection. Argumentative. MR. ECHEVERRIA: Sustained. BY MR. COUGHLIN: Q Your Honor, do you have any specific points of law or issues with which you can elucidate why you question my competency to practice in your court? MR. KING: Objection. Asked and answered. MR. ECHEVERRIA: Sustained. BY MR. COUGHLIN: Q Do you recall any of my work product in Cadle Company? A Not specifically, no. I remember a fairly lengthy brief that you filed which, I think, was that case, that I thought was rambling, addressing points of law which weren't relevant. I think had some discussions of historical matters and some discussions of perhaps constitutional law, but it wasn't really relevant to the matter that was in front of me."

HEARING - Vol. I, (Pages 28:11 to 29:17) BY MR. COUGHLIN: Q Your Honor, on Cadle Company, wouldn't it indicate a fairly high level of skill, particularly for one who hadn't been practicing in a bankruptcy setting for very long at all for, one, to deduce that in that case Cadle had issues with respect to the fact that they had not renewed a dormant foreign judgment in that under the Texas statute at issue, given the fact that the judgment was over ten years old, and within the two years under the statute within which they had to take some act to revive a dormant judgment, they failed to do so. Wouldn't the fact that I pointed that out in a brief, and specifically cited to relevant legal research with respect to what particular acts would qualify as reviving a dormant judgment in that respect, wouldn't that indicate some level of competency? A (Judge Beesley): I did not ever say that I did not think you are highly intelligent. I think you are. But intelligence and legal competence are not the same thing. I think you have a significant lack of ability to focus on the issues at hand, but you're very smart. Q If I pointed out, which I believe I did in that case, that Cadle Co., by having a vice president file an affidavit seeking to register a foreign judgment, that their doing so violated NRCP 11, in that a corporation such as Cadle Co. is not entitled to appear pro se, to wit through a vice president who is not an attorney, wouldn't that evince some level of capability as an attorney sufficient to avoid having a federal judge respond to Mr. King's imploring him to badmouth me at a hearing? MR. KING: Objection. Argumentative. MR. ECHEVERRIA: Sustained. MR. KING: Thank you."

HEARING - Vol. I, (Page 3:15 to 3:18) Formal Hearing Exhibits:... Ex. 2 (3/30/12 Order in appeal of summary eviction from former home law office involving Hill's firm awarding $42,065 attorney fee award)...Ex.3 4/13/09 Order After Trial

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("received" as a greivance in the SBN on 3/15/12)... Ex. 6 - Letter dated February 14, 2012 to Mr. Coughlin from SBN's Mr. King pages 159 165... Ex.7 - Two-page letter dated March 9, 2012 from Mr. Coughlin to State Bar pages 165 169 8 - Two page letter dated March 14, 2012 from Judge Holmes to Mr. Clark (SBN) pages 171 175..."

HEARING - Vol. I, (Page 49:11 to 49:16) MR. COUGHLIN: The rule says I'm to have no less than 30 days from service of the notice of the hearing to inspect, up to within three days of the hearing, these materials. Mr. King refused to let me see these materials for months, going all the way back to March."

HEARING - Vol. I, (Pages 96:17 to 98:6) Q Which judge signed that order? A Judge Linda Gardner, who is a family court judge in Washoe County, Nevada. Q What is the date that she signed the order? MR. COUGHLIN: You say it's been marked, Pat, you haven't entered it yet? MR. KING: That's correct. MR. ECHEVERRIA: He hasn't offered it yet. MR. COUGHLIN: Just a -- BY MR. KING: Q The date next to her signature? A April 10th, 2009. MR. KING: I'm going to move that this order, a certified copy of which has been produced, be admitted as Exhibit No. 3. MR. COUGHLIN: I'll object, sir. It just looks substantially different than what I have seen of this order. Further, the received on it is not certified, and that goes to a material issue here to the extent that this is purportedly a ghost grievance. We don't know how this materialized at the State Bar. We don't know if it involves some brother and sister judicial -- well, we actually kind of do know that Judge Linda Gardner passed it to her brother, the administrator of muni court who presided over the trespass conviction. And he admits passing to Judge Nash Holmes -- MR. ECHEVERRIA: What's the objection? MR. COUGHLIN: -- the day before March 15th on this filed her grievance with the State Bar. MR. ECHEVERRIA: What is the objection? MR. COUGHLIN: I want to know exactly where and how Mr. King got this order. Why the 5 on this March 15th looks so odd and different than the previous versions where -- it looks like somebody drew the 5 in a little darker, Pat. MR. ECHEVERRIA: So your objection is what, sir? MR. COUGHLIN: He's talking about it being certified, and all this and that. I would like some more information about that. How is it certified?"

HEARING - Vol. I, (Pages 98:7 to 105:9) MR. KING: I asked the witness -- I was going to ask the witness -- the witness identified this as a document he recognized that was signed by the judge. The witness testified that he heard the hearing. BY MR. KING: Q Why did this matter to you -- MR. COUGHLIN: No, he said it's certified. .... MR. ECHEVERRIA: What's the objection? MR. COUGHLIN: It's not certified,... MR. COUGHLIN: Well, he said it was certified. So my objection is, let's see the proof. Did you get it from Joey or

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Gina Hastings or did you get it from the clerk of court of the muni court? MR. ECHEVERRIA: Mr. Coughlin. I'm not going to entertain questions between and among the lawyers. If you have a question, direct it to the panel or the witness. The objection is this lacks foundation? MR. COUGHLIN: No. That this certification hadn't been proved or even spoken to besides ... MR. COUGHLIN: -- certified . MR. ECHEVERRIA: -- position that only legal documents can be admitted that are certified? MR. COUGHLIN: Well, I didn't make a position on that. My position is he said it was certified. So I'm contesting that. MR. ECHEVERRIA: Is this certified? MR. KING: Let me get the clerk to bring the certification copies, unless she gave them to you already, which I understood she did. Did she bring you copies? MR. ECHEVERRIA: This particular one is not certified. Do you have one that's certified? MR. KING: I have already introduced -- the copies do not show that it's certified. MR. COUGHLIN: Your Honor, if I can quickly interject for the record, I mean that not disrespectful. MR. ECHEVERRIA: Are we on the record? Are you getting this, Ms. Reporter? THE COURT REPORTER: Yes. MR. ECHEVERRIA: Go ahead. MR. KING: Mr. Chairman, I'll lay -- I understood, and since this has been filed with the courts that we have certified copies. Since the copy I gave you is not certified, I'm going to lay a foundation a different way and withdraw the representation that the copy I gave is a certified copy. MR. COUGHLIN: Yeah. And that's just another basis for all -- the 13th time on the clock. I'm going to say formally yes, I think a recusal is appropriate. And I think, Pat, you need to consider whether that's fraud, to be saying it's certified, backtracking once you get caught on it. But I'm just going to put that out for the record. MR. ECHEVERRIA: Let's deal with this. Are you now making a motion that I should recuse myself? MR. COUGHLIN: Do you think you should? MR. ECHEVERRIA: No. Are you making that motion? MR. COUGHLIN: Yeah, I think so. Probably. MR. ECHEVERRIA: Well, then articulate your position. I'd like to hear it. MR. COUGHLIN: I think it's been set forth enough. MR. ECHEVERRIA: Set forth what? MR. COUGHLIN: You've admitted to being childhood friends. There's a rather odd suggestion that you didn't know you both went to Stanford in 1966 despite being childhood friends, and being in northern Nevada practicing law or members of the legal community. And I would like to know any other relevant nexus between the two of you. MR. ECHEVERRIA: So your basis for moving that I should recuse myself is that I knew Mr. Elcano as a childhood friend, and we were at the same school together? MR. COUGHLIN: And the fact that Mr. King has worn every different hat he's wanted to wear here. The fact he just said something was certified, then he backtracks and -- you asked me for my basis. MR. ECHEVERRIA: Mr. Coughlin, I'm asking you to focus on your motion for recusal. Is it your position that legally any judicial officer must recuse themselves if he happens to have -- MR. COUGHLIN: I'm not going to get narrowed down into if you were childhood friends. I'm telling you my basis, and that is that there is too much funny business going on here. MR. ECHEVERRIA: Overruled. MR. COUGHLIN: I'd like to set forth specifically. MR.

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ECHEVERRIA: I've asked you to three times, and you won't do it. MR. COUGHLIN: You want to narrow it down just if you were childhood friends, and I want to go with the totality of the circumstances. MR. ECHEVERRIA: Articulate your case, sir. I've asked you to. THE WITNESS: SCR 105's been thrown out the window. You've ruled on motions before I've even had a chance to oppose them or file a reply to an opposition. You claim that NRCP is applicable here. Yet under NRCP when I file a motion to bifurcate, and he filed an opposition, and I get three days for mailing under 6-C, and he purports to file it on the 24th, and you rule on it when? On the 30th? Don't I get five days, plus three for mailing to file my opposition to preserve for appeal? MR. ECHEVERRIA: So should we disregard the motions you filed without giving the State Bar the opportunity to respond timely? I had two motions shoved under my door last night. Should those be disregarded under your legal reasoning? Because you did not offer the State Bar the opportunity to respond. MR. COUGHLIN: Well, that -- MR. ECHEVERRIA: Yes or no, Mr. Coughlin? MR. COUGHLIN: It's not a yes or no. MR. ECHEVERRIA: Yes, it is. MR. COUGHLIN: That would entail figuring out whether or not 30 days prior to the hearing -- MR. ECHEVERRIA: Let's focus on the issues back. You've made a motion now to require me to recuse myself. MR. COUGHLIN: Yeah. MR. ECHEVERRIA: You made it on the basis that, one, Mr. Elcano and I knew each other as childhood friends. And two, that we attended the same school together, apparently. And you say it's suspicious that I did not know that. Anything else? MR. COUGHLIN: Every -- MR. ECHEVERRIA: Anything else? MR. COUGHLIN: Every aspect of SCR 1052(c) has been violated by your orders. And the way this thing has been run, you have thrown out every last procedural due process substantive protection accorded me for my property right under the 14th Amendment. You have insulted me by the way you have run this panel. MR. KING: Mr. Chairman -- MR. COUGHLIN: And I find out you're childhood friends with a guy I'm suing. MR. ECHEVERRIA: I'm childhood friends with justice -- MR. COUGHLIN: And you went to Stanford together in '66, and you didn't know that. And let me guess. Are you on the Basque board too for UNR? And Paul tells us he's Basque every five minutes you talk to him. MR. KING: Mr. Chairman. My experience with Mr. Coughlin is if this is allowed to continue, he will be thrilled, and it will go on for eight hours. My witness has a limited time. MR. COUGHLIN: And your office is a stone's throw from the State Bar. MR. KING: I need to move forward, because the witness has limited time, with your permission. MR. COUGHLIN: I like you personally. I think you're a charming guy. I do, your Honor. Just like Mr. Elcano. But the clock chimed 13 times. And if I don't put into the record what is it going to say on appeal? They are trying to merge me here. Let's be honest. So if it's a merging that's going on here, I'm going to preserve everything for the record. MR. ECHEVERRIA: I'm going to overrule your motion for recusal. The supreme court has already ruled that the fact that a judge knows a witness or a lawyer is not, in and of itself, grounds for recusal.

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That's been decided and litigated in this state. So the motion for recusal is overruled. Mr. King, proceed to lay the foundation for Exhibit 3."

SBN Asst Bar Counsel Patrick O. King, Esq. and his SBN "Clerk of Court" Laura Peters run a heck of a pick and roll. Similar to the old bait and switch they ran vis a vis Peters representing to Coughlin that he could file and serve the Clerk of Court and SBN via faxing documents to the SBN (and Peters specifically indicated that she would file stamp in such documents submitted for filing by Coughlin via fax (9/11/12), only to have Peters subsequently, if not lie (she was allowed to avoid answering any tough questions in that regard by virtue of the 11/7/12 Panel Chair Echeverria Order granting King's Ex Parte Emergency Motion to Quash Coughlin's subpoenas on both King and Peters)

HEARING - Vol. I, (Pages 154:3 to 156:1) BY MR. COUGHLIN: Q Did you or anybody with your court, the Reno Municipal Court, transmit or otherwise deliver Judge Linda Gardner's April 2009 order sanctioning me to the State Bar of Nevada? A (Judge Holmes): I'm sorry. Deliver to whom? MR. ECHEVERRIA: The State Bar, Judge. THE WITNESS: Oh. After -- let me explain quickly. My trial was my first experience in exposure to Mr. Coughlin. After everything happened, and I held him in contempt, then Judge Gardner told me that his sister, Judge Gardner, has a life experience with Mr. Coughlin, and he provided me a copy of her opinion from a couple years earlier. And that may have been in the package I forwarded to the court. I forwarded everything I could possibly include that would show Mr. Coughlin's ability to practice law. Including Mr. Coughlin's 200-page motion that he faxed to the court. MR. ECHEVERRIA: Thank you, Judge. It's now 12:22, and we'll excuse you. And we appreciate you taking the time -- MR. COUGHLIN: Can I ask one more question about the pending -- MR. ECHEVERRIA: Mr. Coughlin -- MR. COUGHLIN: -- competency evaluation or -- MR. ECHEVERRIA: Mr. Coughlin. MR. COUGHLIN: -- with the trial? It's a good question. MR. ECHEVERRIA: It's an interruptive question, and it's improper conduct. MR. COUGHLIN: You're not going to let her answer that, huh? You are not going to make her answer that? MR. ECHEVERRIA: I'm sorry. I continue to talk while you're trying to interrupt. Judge, thank you for your testimony. MR. COUGHLIN: She held a trial with a pending competency evaluation in violation of law. MR. ECHEVERRIA: Quit interrupting, Mr. Coughlin."

(It was Judge Nash Holmes whose 5 day summary incarceration of Coughlin between 2/27/12-3/2/12 prevented Coughlin from filing a Reply to the 2/24/12 Answering Brief hearing (to which Hill, in testifying at Coughlin's formal disciplinary proceeding on 11/14/12 claimed Coughlin's "failure to oppose" matters

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alleged in his associates Answering Brief (which, as manifest from the record, are completely untrue, like in 60302 vis a vis the service of process issue) (such as the patently incorrect allegations therein that Coughlin "never raised" the issue of his commercial tenancy prohibiting the use of summary eviction procedures where such action was plead as a NRS 40.254 "no-cause summary eviction" (much less the incredible attempts Judge Holmes and the SBN/NNDB Panel to find Coughlin violated RPC 1.1 "the duty of competence within "Part 1 Lawyer-Client Relationship" of the NRPC), and RPC 1.2 or 1.3 (speaking of competence, its hard to tell which rule the SBN/Judge Holmes alleged Coughlin violated given the mixing of the numeric identifier of RPC 1.3 with the title of RPC 1.2 (expediting litigation versus Diligence) found in the SBN's 8/23/13 Complaint (see 62337) (much less, in transmogrifying a "simple traffic citation" trial into some absurd summary disciplinary hearing (see the 3/12/12 Order in RMC 11 TR 26800 and 62337... "Judges Gone Wild").

As to judges refusing stays to practicing attorneys representing clients where the seek to summarily incarcerate such attorney's (in a remarkably similar display of the kind of negligence born only of a steady diet of absolute immunity (what's next? Surgical immunity?), the overwhelmingly majority viewpoint in the law is that such is highly disfavored. In her 3/14/12 grievance against Coughlin to the SBN, Judge Holmes is completely blase as to whether or not Coughlin's indications to her on the record on 2/27/12 that he was representing clients and had hearings upcoming the would be prejudiced and disordered as a result of the denial of any stay at all were true or not (and if you have ever been to the Washoe County Jail, you known how completely unrealistic it is to think one will be able to conduct business from there, 10 days for your stamps, paper, and calling cards to arrive in the mail, one may not access their own credits card, in their possession at the time of arrest and booking, to add money to their commissary "books". One may not receive even a single sheet of paper from a Deputy. Coughlin was routinely place directly into "Administrative Segregation" sufficient to sharply curtail his "tier time", preventing his making any phone calls to arrange for the avoidance of prejudice or disorder to the clients he was representing and in the case such representation arose). Laughably, Judge Holmes feigns being "fearful" that if Coughlin's representations to her that he was actively representing clients were true (she glossed over Coughlin's indications that the denial of a stay of such summary contempt incarceration would damage their interests and disorder the matters in which such representation arose in) that Coughlin could "be doing real damage to their liberty or property interests".

Probably not as much damage as denying a stay of a summary contempt incarceration of an outrageous five days (we are not talking Houston being handcuffed for an hour in the 8JDC Family Court) to an attorney actively representing clients would cause, no? But then, as with the denial of any such stay

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under the exact same circumstances (summary contempt incarcerations or unnoticed revocation of Couglin's bail (the one on 4/19/12 is not all that clear, as asking a HIPAA question about seeking to know to just what extent the "competency" evaluators at Lake's Crossing have a blank check into the entirety of one's medical/mental health care records where simply performing a NRS 178.425 evaluations that really fails to necessitate the inordinately invasive/retaliatory approach taken by Bill Davis, Ph.D. and Sally Farmer, Ph.D.) by RMC Judge Howard between 11/30/11-12/3/11 and Judge Elliott between 4/19/12-4/26/12, and RJC Judge Clifton between 2/12/13-2/16/13 (5 days in jail for allegedly being late to court where Coughlin was, again, summarily incarcerated between 2/1/13-2/5/13 incident to a warrantless arrest after 7 pm in violation of NRS 171.136 premised upon a NRS 211A.125 allegation of having violated his probation by failing to check in with DAS on 1/23/13 where DAS wrote Coughlin on 1/24/13 admitting that Coughlin had checked in, but that the RJC Bailiff's in their overstepping application of an already completely specious 12/20/12 Administrative Order 2012-01 by, wait for it....Judge Sferrazza (whom, in that order, remixed the State of Nevada's Constitution where that Order indicated Art.6 Sec. 6 imbued "Nevada courts" with the jurisdiction therein that is only accorded to "District courts", which is a signficant distinction when considering that Order was entered (not in a "case" per se, with an opposing party in the caption, or upon a complaint and subsequent motion made by a "party") by a justice court judge...with such jurisdictional largesse being apparent again in a 11/28/12 summary "Order" in "ALL CASES ALL DEPARTMENTS" that purported to base its summary revocation of Coughlin's right to submit filings by fascimile (a privilege, apparently, the RJC accords unequally among litigants and ), had prevented Coughlin from accessing the DAS Office).

HEARING - Vol. I, (Pages 99:21 to 100:21) MR. ECHEVERRIA: Is this certified? MR. KING: Let me get the clerk to bring the certification copies, unless she gave them to you already, which I understood she did. Did she bring you copies? MR. ECHEVERRIA: This particular one is not certified. Do you have one that's certified? MR. KING: I have already introduced -- the copies do not show that it's certified. MR. COUGHLIN: Your Honor, if I can quickly interject for the record, I mean that not disrespectful. MR. ECHEVERRIA: Are we on the record? Are you getting this, Ms. Reporter? THE COURT REPORTER: Yes. MR. ECHEVERRIA: Go ahead. MR. KING: Mr. Chairman, I'll lay -- I understood, and since this has been filed with the courts that we have certified copies. Since the copy I gave you is not certified, I'm going to lay a foundation a different way and withdraw the representation that the copy I gave is a certified copy. MR. COUGHLIN: Yeah. And that's just another basis for all -- the 13th time on the clock. I'm going to say formally yes, I think a recusal is appropriate. And I think, Pat, you need to consider

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whether that's fraud, to be saying it's certified, backtracking once you get caught on it. But I'm just going to put that out for the record..."

While the 12/24/12 ROA places the 10/9/12 Affidavit of Laura Peters at pages 38-39, the 2/13/13 version of the ROA places the same at pages 33-34, which is especially odd considering that the file stamp on that Affidavit of Laura Peters on at ROA 38 is earlier in time than the file stamp on the Notice of Formal Hearing and DoWSoE on page 33. This is even more odd given that the original placement in the ROA of 12/14 put such 10/9/12 Affidavit of Laura Peters in a position after a later dated document (the Notice of Formal Hearing, that is, of 10/12/12 was place after the 10/9/12 Affidavit of Laura Peters, which, was actually placed in the OBC's 11/7/12 production of documents in lieu of SCR 105(2)(c)'s jurisdictional requirements being met. In that 11/7/12 production (which Coughlin sought to introduce as evidence at the formal hearing, but was not even allowed to have marked), that 10/9/12 Affidavit of Laura Peters was placed after the 10/24/12 Opposition to Respondent's Motion to Bifurcate Hearing/Motion to Dismiss, and after the 10/30/12 Order Appointing Formal Hearing Panel and 10/31/12 Order, indicating that, regardless of when it was filed stamped or notarized, it was not placed in the formal pleadings file until, at the earliest, 10/31/12. This is extremely prejudicial (especially where the SBN/Panel are now asserting a default basis/admission of misconduct theory) when view in combination with the SBN's refusal to allow Coughlin to take advantage of the right to inspect, up to 3 days prior to the hearing (which, arguably meant up to and through November 9th, 2012), all that to which he was entitled to inspect under SCR 105(2)(c) (the waiver of service of and Subpoenas on Elcano and Beesley would have been helpful to see, Beesley's supposed letter to the OBC and dating thereof, etc., and all the suspect redactions or privileged and withheld ommissions from what was actually produced to Coughlin on 11/7/12 (which only included materials up to 10/31/12, as such was sent to the printers the morning of 11/1/12, as admitted to verbally by Peters and in writing by King). The second ROA persists with inserting at bates 32 some quasi-Affidavit of Attempted service that is neither signed (and was not, given the lack of any Index to Exhibits or cover page for any exhibit) attached to that 10/9/12 Notice of Intent to Take Default found immediately preceding it in the ROA (Coughlin, of course, only first received any version of that 10/9/12 NOITTD upon finding it bates stamped among some 3,200 other pages of documents in the production of 11/7/12). As such, page 32 of the ROA should be stricken.

There is not even a name assigned to the various statements (unsworn, of course) made therein for the various dates detailed. Especially with regard to the lack of notice to Coughlin that such would be put forward as evidence (that found on page 32 of the ROA makes another appearance within FHE 1 at page 1736...and now it becomes clear why the Index on page 1699 to FHE 1 has been photocopied in a manner to completely obscure what it details...that was done to obfuscate the reality that the SBN held out to the Panel page 1736 as being included in that which

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was originally mailed to Coughlin (with insufficient postage placed thereon resulting in the USPS refusing to release it to Coughlin, which Coughlin promptly notified the SBN of and placed the SBN on a Litigation Hold Notice with respect to the contents and envelope of that mailing, which was returned to sender with a handwritten notation detailing the insufficiency of postage placed thereon, made by USPS Downtown Postal Station longtime employee Tim (tall, fifties, glasses). Coughlin is filing herewith a version of what the SBN did file with this Court on 12/24/12 (though, in an apparent attempt to coerce payment up front for the Transcript and certified copy of the Formal Hearing Exhibits (including Exhibit 16, that Coughlin was not provided the day of the hearing, and where none of the Exhbits were marked as provided to Coughlin), and has affixed bates stamping thereto, such that the 574 page Volume 3 of 12/14/12 is bates stamped to continue where page 1098 of Volume 2 left off. As such, the Index to the FH1 Index of Documents that is too blurry to read on the second ROA's page 1699 is much more readable at what would have been bates stamp page 2001 in the first ROA filed. And therein is revealed an attempt by the SBN to hold out that quasi-Affidavit of Service found at page 32 of the second ROA, included again, as an Exhibit to the 10/9/12 Notice of Intent to Take Default. However, as detailed above, it is not at all clear that such Reno/Carson Messenger Service receipt was actually included therewith, (though, a review of pages 2001 from the first ROA and page 1736 of the second ROA would give one that impression, despite the unlikelihood of that, given the RCMS receipt is dated 10/6/12, adn does nto appear to have been faxed to the SBN, and would, therefore, unlikely have made its way to the SBN in time to be affixed to the 10/9/12 purported mailing of the 10/9/12 NOITTD.

And, it is important to recall, as admitted to on page 1098 of the first ROA of 12/24/12, that SBN Clerk of Court Laura Peters only mailed the first 2 of 3 volumes of that ROA to Coughlin (and that ROA and the second ROA failed to comply with the requirement in NRAP that the Clerk of Court certify the contents of such ROA, and, regardless, the SBN's negligent, at best, preparation of the ROA here is risable. And, really, in the 2/13/13 ROA, what would purportedly be Exhibit 1, starting at page 1699, is not marked in any way to indicate that it is Exhibit 1, and as such, should be stricken in its entirely. It appears from reviewing the first ROA filed (since stricken by the 2/7/13 Order) that the SBN excised an essentially blank (though ink wasting dark red or black page) that had affixed to it an Exhibit 1 sticker from the ROA filed on 2/13/13. You can be entirely certain that the Panel and SBN applied every single ticky tack little reason for striking something or ruling as inadmissible something Coughlin sought to introduce into evidence, and such an approach should be applied to the SBN's Exhibit 1 beginning on page 1699 in the 2/13/13 ROA, through 1750 (or if not stricken, at perhaps ruled as inadmissible, particularly given the apparent Sierra Glass violation incident to pages 1727 and 1736 as detailed above). The SBN failed to include a 60 page Index in the Volume 3 that it never provided me incident to the 12/24/12 filing. Further, many cd/dvd attachments to my filings in that matter, I am told, by Clerk Castillo,

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are not in the ROA. I believe the ROA is deficient in this matter, perhaps fraudulently so. All of the SBN's histrionics and melodrama related to the Extended Order of Protection obtained from an RJC that is entirely to conflicted here to be making rulings limiting the means by which I am able to communicate with an opposing party and or file documents or seek extensions or stipulations where time is of the essence...and not just with an opposing party, but with a "Clerk of Court" as the SBN's Laura Peters hold herself out to be, as does the SBN and OBC hold her out. In an effort to avoid an ex parte communications accusations (though Bar Counsel King readily admits to having those all the time with the Panel...and to controlling the Clerk of Court Peters (coercing her into the 10/9/12 Affidavit of Laura Peters, which, according to the bates stamps of the "file" provided by the SBN on 11/8/12 was only placed into the "file" on 10/31/12, as the filings in the interim between those dates have a bates stamping indicating that 10/9/12 Affidavit of Laura Peters (which lacks a caption and is not attached to any filing by the SBN or Panel). If the SBN and or Clerk of Court Peters is going to be eliminating a 60 page index from the Official Transcript, or dropping in page 216 on Volume 1 (which is hugely inappropriate considering the fact that page 216 of Volume 1 is a USPS Track & Confirm printout the SBN printed just after Coughlin alerted it to the fact that the downtwon Reno postal station at first failed to find, then refused to provide Coughlin with the SBN's 10/9/12 mailing to Couglhin given the insufficiency of the postage attached thereto, and the circumstances related to the SBN placing insufficient postage on that 10/9/12 Notice of Intent to Take Default and receiving it back from the USPS with a "insufficient postage"/return to send handwritten note that Coughlin personally saw USPS downtown station counter clerk "Tim" affix to that large manilla package (which brings up the fact that the Reno Carson Messenger Service unsworn quasi-Affidavit of Attempted service was not a part of that 10/9/12 NOITD, either, meaning that page 32 of Volume 1 (the Reno Carson Messenger Service Receipt) of the 12/24/12 ROA is another instance of the SBN/OBC/Clerk of Court Peters/NNDB/Panel (my point is...there is no point of distinction between any of those entities...they all bleed together completely, with the main characteristic they share being that Bar Counsel Pat King is permitted to fraudulent and coerce them around into doing his bidding as an attack dog for the rich and powerful....Peters signs the Certificates of Service for all involved....Chair Echeverria's Office is in the SBN's back parking lot...Peter's grants Coughlin permission to file by fax on 9/11/12 at 4:48 pm (and a review of all emails and fax confirmations involved, and, uh...some other things makes clear that Peters 10/9/12 Affidavit of Laura Peters is an extremely troubled document, as is Bar Counsel's holding out the 8/23/12 Complaint and Affidavit of Service therein by Peters as something other than a fraudulent assertion of service violative of RPC 3.3, 3.4, and many of the provisions in the Model Code of Conduct for Judicial Employees in the State of Nevada: http://www.courtethics.org/Nevada%20Model%20Code%20of%20Conduct.pdf In that Model Code the appearance of impropriety is referenced at length.

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On that note, I reference the "Dispositional Order' entered by Clerk Lindeman that Richard G. Hill, Esq. conveniently referenced in his testimony at the formal disciplinary 11/07/2012 Order/Dispositional - Order Dismissing Appeal Filed Order Dismissing Appeal. To date, appellant has not paid the filing feeor otherwise responded to this court's notice. Accordingly, cause appearing, this appeal is dimissed. 12-35194 Further, why is Coughlin's Motion for Order to Show Cause on page 44 of Vol 1 not file stamped, even where the Panel Chair ruled on it in his 10/31/12 Order? Is it permissible to issue a Briefing Schedule on 12/24/12 where Motion for New trial, NRCP 52, NRCP 59 tolling motions are pending? Also, while the 2/13/13 version of the ROA indicates that from pages 797-1347 is Coughlin's Motion for Mistrial (Notice that 10/9/12 Affidavit of Laura Peters is Whopper Chocked, etc. (again, for some totally unexplained reason the SBN merely indicates such filing was Not Filed in the entry for such in the Alphabetical Index, despite such filing being properly submitted for filing on 12/3/12). So, so, the 2/13/13 ROA's version of that filing totals 550 pages, while the 12/24/12 version extends from 613-1068, therefore totalling only 455 pages...the SBN fails to explain at all where from or why there is now an additionaly 95 pages associated with such filing. Beyond all of that, the multitude of Coughlin's filing have been rendered illegible due to the SBN's fraudulent fiddling with the scanner and copier settings. NRAP 11 requires the output of such to be equal to that of a laser printer, which requires at least 300 dpi, and clearly, the SBN has gone beyond just scanning Coughlin's filings in at the lowest setting possible (75dpi), but rather has taken to adjusting the resolution, sharpness, contrast, shrinking and also settings available to those whom wish to obscure the record to achieve an impermissible advantage. Beyond this, King has sought to obviate the due process problems (lack of notice, insufficiency of service of process, and of the process itself...see 60302) associated with his attaching to his 8/23/12 Complaint Orders wherein portions thereof are entirely illegible.

Also missing from both versions of the ROA filed by the OBC is Couglhin's 11/9/12 AFFIDAVIT OF ZACH COUGHLIN AND SUPPLMENTAL TO DESIGNATION OFWITNESS AND SUMMARY OF EVIDENCE; MOTION FOR RECUSAL OF PANEL CHAIR ECHEVERRIA; and EMERGENCY EX PARTE MOTION TO DISMISS THE 11/14/12 HEARING OR OTHERWISE RECOGNIZE THE LACK OF JURISDICTION TO HOLD IT GIVEN THE NUMEROUS VIOLATIONS OF SCR 105 BY THE PANEL AND THE SBN (6 pages with Exhibit 1 attached as disc). Defendant Zachary Coughlin (hereinafter "Defendant") is charged with Violation of a Temporary or Extended Order for Protection Against Harassment in the Workplace, a violation of NRS 33.350 as incorporated by Reno Municipal Code Section 1.04.015. See Amended Criminal Complaint filed March 7, 2013. It is alleged, interalia, that: The Reno Justice Court issued a Temporary Order for the Protection Against Harassment in the Workplace on December 20, 2012, with an expiration date of January 4, 2013 (RJC RCP2012-000607). The TPO Order prohibited the Defendant or an agent of the Defendant

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from Contacting (versus prohibiting Coughlin from "harassing") the State Bar of Nevada's Northern Office only (going so far as to prevent Coughlin from even mailing in the US mail harassing materials to the SBN, and, perhaps, any materials), and failed to list the SBN's Northern Officer's fax number therein (and the TPO Application upon which such Order issued failed to list the fax number for the Northern Office as well). The Defendant was not served this Order on December 26, 2012, contrary to the RCA's assertions in its Motion. For an RCA seeking to take Coughlin to task over phenomenally suspect, and de minimis, at best, alleged violations of this TPO/EPO, it sure is willing to overlook a number of deficiencies in the performance of the RJC, the RJC Bailiffs, the SBN and its Clerk of Corut, RPD Detective Ytrubidde, the arresting RPD officers, etc., etc. as they relate to their respective roles in this matter and the void and voidable nature of the two protection orders in question. Sort of a do what we say not as we do type approach. A "we're above the law, ourselves, see" kind of attitude. Further, the RCA failed to turn over the Brady material attendant to the missing Proof of Service page for such 12/20/12 TPO in RCP12-607, in the RCA's initial purported (yet still not technically served) discovery to Coughlin, wherein the 12/26/12 Proof of Service by the RJC's Bailiff Anthony English was missing therefrom, in a tacit admission by the RCA that it knows such purported service was woefully insufficient (the order itself directed specific members of law enforcement (not among them were the RJC Bailiff, whom by the way, as parties, also purported to effect service of a TPO against Coughlin by "Washoe County", and really, the Public Defenders Office is an independent contractor, as such, Washoe County has no standing to move on its behalf or on behalf of any of the WCPD's employees for a Workplace TPO), and therefore the RCA is violating RPC 3.8 and Brady in maintaining both of these prosecutions in addition to being a willing accomplice to the criminal misconduct being committed by the State Bar of Nevada's OBC Asst. Bar Counsel King and "Clerk of Court"/Investigator/Paralegal, Laura Peters, whom admit to throwing away or otherwise failing to fulfill her duties as "Clerk fo Court" for the State Bar of Nevada in formal disciplinary proceedings (as both Peters and King have held Peters out to be "Clerk of Court of the State Bar of Nevada).

Further, the TPO application was violative of the requirement that one's employer file it on behalf of a specific employee (as Laura Peters filled it out originally in her own handwriting then used white out over her signature...replacing it with Pat King's, and regardless, the TPO/EPO sought to protect them both, and authority to so file such an application necessarily needed to be issued by a member of the SBN's Board of Directors (or possibly, even, Watters and SCR 99, the Nevada Supreme Court, as the SBN is merely an "arm of the Court", not merely upon Pat King, or even David Clark's permission), whom would then need to file such application on behalf of such employees as King or Peters or whatever unnamed employee the RCP12-607 application purports to, in all its unattributed hearsay and vagueness, seek protection for (NNDB Panel Chair Echeverria's staff, non-sensically, seems to be the party for whom the SBN is seeking protection, for

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which, clearly, its lacks standing to apply for one on behalf of Echeverria, his staff, or anyone with the NNDB), beyond that the SBN's TPO application fails to comply with the statutory requirement that it specifically name which employees it seeks to protect and why, or provide an factual specifics as to why such an application is justified). Further, the SBN's TPO Application failed to contain a verification and or a sworn Declaration as to any facts whatsoever, much less of the level necessary to satisfy NRS 33.250. Simply put, nothing in any of the Exhibits or the Exhibit 1 "Summary" attached to the SBN's TPO is incorporated by reference into the 8 page TPO Application's verfication (neither the required incorporating language is included, nor are the materials contained in the Exhibit 1 placed on the statutorily, court mandated "Continuation" Page, not to mention that the Application and Exhibit 1 contain absolutely no attribution as to whom purportedly wrote the "Summary" in Exhibit 1 to the TPO Application (and curiously, especially where the employee for whom the employer is purportedly seeking the protection (apparently Laura Peters?) is precluded from applying for such protection on their own behalf, the "Summary" in Exhibit 1 of the TPO Application refers to Pat King in the third person, which is strange considering its is Kign signing the verification on page 8 of the TPO Application and there is otherwise no attribution for the writer of the "Summary" included in Exhibit 1 of the TPO applciation (which consists almost of unattributed hearsay alluding to unnamed non SBN employees in vague, unsupported terms). Further, by virtue of the admissions made by both the SBN and its Clerk of Court Peters and RCA Chief Criminal Deputy City Attorney Wong, a level of complicity and prosecutorial misconduct is evinced in Clerk of Court Peters failure to include the two purported filings in question in the record on appeal transmitted from NG12-0204,0434,0435 to the NSCT in 62337 (ie, those purported filings of 1/3/13 and 1/17/13):

"III. Title, Tenure, Removal, or Suspension C. Removal or Suspension from Office 1. Removal from Office 21. Grounds for removalParticular applications , Clerks of Courts k8 Examples of sufficient grounds for removing a clerk of court from office include: misappropriation of funds to the clerk's personal use[FN1] a conviction of theft in office giving rise to a statutory disqualification[FN2] the failure to maintain proper records and accounts[FN3] making disparaging statements about a judge[FN4] an offense involving moral turpitude[FN5] willful misconduct in office[FN6] failure to follow to the letter and in the utmost good faith the direction of the judge[FN7] misfeasance in office or neglect of official duty tantamount to fraud[FN8] [FN1] Lewis v. State ex rel. Evans, 387 So. 2d 795 (Ala. 1980). [FN2] State ex rel. Corrigan v. Haberek, 35 Ohio St. 3d 150, 518 N.E.2d 1206 (1988). [FN3] In re Overstreet, 851 S.W.2d 458 (Ky. 1993). [FN4] Voigt v. Savell, 70 F.3d 1552 (9th Cir. 1995). [FN5] Lewis v. State ex rel. Evans, 387 So. 2d 795 (Ala. 1980). [FN6] In re Antonelli, 429 Mass. 644, 711 N.E.2d 104 (1999). [FN7] State ex rel. Core v. Merrifield, 202 W. Va. 100, 502 S.E.2d 197 (1998). [FN8] Commonwealth ex rel. Attorney General v. Furste, 288 Ky. 358, 156 S.W.2d 198 (1941).

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AMJUR CLERKSOFCT 21" 44. Breach of duty affecting rights of litigants West's Key Number Digest West's Key Number Digest, Clerks of Courts k64.1 A court clerk's breach of a duty to perform the ministerial functions of the clerk's office will not prejudice the rights of those dealing with the court concerning an action or matter then pending. This principle frequently applies where a party seeks enforcement of,[FN1] or relief from a judgment affected by some mistake or default of the clerk,[FN2] or where the clerk's failure affects compliance with filing or recording deadlines critical to the party's matter.[FN3] In the absence of a duty,[FN4] or when the negligence of another intervenes,[FN5] relief is denied, even with reliance on the clerk's promises or statements,[FN6] particularly those gratuitous in nature with no relation to the clerk's duties.[FN7] A clerk of court may be liable personally and on an official bond,[FN8] subject to the constraints of potential immunity.[FN9] [FN1] Gilliam v. Gilliam, 43 So. 3d 615 (Ala. Civ. App. 2010). [FN2] McGee v. Hicks, 303 Ga. App. 130, 693 S.E.2d 130 (2010), cert. granted, (Sept. 20, 2010) and aff'd but criticized on other grounds, 11 Fulton County D. Rep. 2069, 2011 WL 2610368 (Ga. 2011). [FN3] Williams v. T.D.C.J.-I.D., 142 S.W.3d 308 (Tex. 2004). [FN4] Trala v. Melmar Industries, Inc., 254 A.2d 249 (Del. Super. Ct. 1969). [FN5] Maginn v. City of Glendale, 72 Cal. App. 4th 1102, 85 Cal. Rptr. 2d 639 (2d Dist. 1999). [FN6] Libert v. Turzynski, 129 Ill. App. 2d 146, 262 N.E.2d 741 (1st Dist. 1970). [FN7] Trala v. Melmar Industries, Inc., 254 A.2d 249 (Del. Super. Ct. 1969). [FN8] 55, 61. [FN9] 58 to 60. AMJUR CLERKSOFCT 44 2. Custody and Care of Records Topic Summary Correlation Table References 50. Generally West's Key Number Digest West's Key Number Digest, Clerks of Courts k69 Trial Strategy Locating Public Records, 2 Am. Jur. Trials 409 12 to 15 (records of county clerk) The clerk of court is the custodian of court records,[FN1] with the duty or function to make and keep an accurate record[FN2] and docket[FN3] of the proceedings in the court,[FN4] the court's orders and judgments,[FN5] all documents submitted to the clerk,[FN6] records used in appeals,[FN7] and all documents used by the court in its decision-making capacity.[FN8] A clerk of court does not have independent ownership of court records,[FN9] and has a ministerial duty to permit the inspection and copying of the court's records in civil cases.[FN10] [FN1] Lapeer County Clerk v. Lapeer Circuit Court, 469 Mich. 146, 665 N.W.2d 452 (2003); State v. McCraine, 214 W. Va. 188, 588 S.E.2d 177 (2003). [FN2] In re Strickhausen, 994 S.W.2d 936 (Tex. App. Houston 1st Dist. 1999). Clerk is responsible for maintaining traffic files for the judge or magistrate. Speight v. Presley, 2008 OK 99, 203 P.3d 173 (Okla. 2008). Clerk must maintain an accurate record of the date of filing. Laidlaw Energy and Environmental, Inc. v. Town of Ellicottville, 60 A.D.3d 1284, 875 N.Y.S.2d 668 (4th Dep't 2009). [FN3] Stewart v. Kentucky Lottery Corp., 986 S.W.2d 918 (Ky. Ct. App. 1998) (electronic computerized "case history" or docket sheet). [FN4] Copley Press, Inc. v. Superior Court, 6 Cal. App. 4th 106, 7 Cal. Rptr. 2d 841 (4th Dist. 1992). [FN5] State ex rel. Core v. Merrifield, 202 W. Va. 100, 502 S.E.2d 197 (1998). [FN6] Sullivan v. Eighth Judicial Dist. Court In and For County

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of Clark, 111 Nev. 1367, 904 P.2d 1039 (1995). [FN7] In re Strickhausen, 994 S.W.2d 936 (Tex. App. Houston 1st Dist. 1999). [FN8] In re Search Warrant #5077/91, 96 Ohio App. 3d 737, 645 N.E.2d 1304 (10th Dist. Franklin County 1994). [FN9] Lapeer County Clerk v. Lapeer Circuit Court, 469 Mich. 146, 665 N.W.2d 452 (2003). [FN10] Lapeer County Clerk v. Lapeer Circuit Court, 469 Mich. 146, 665 N.W.2d 452 (2003). Clerk acted in judicial capacity when making court records available to the public. Rieger v. Montgomery Cty. Clerk of Courts, 2009-Ohio-426, 2009 WL 242668 (Ohio Ct. App. 2d Dist. Montgomery County 2009).

AMJUR CLERKSOFCT 50 49. Documents deficient in form, substance, or timeliness West's Key Number Digest West's Key Number Digest, Clerks of Courts k69 When a court clerk receives documents which are not in proper form, the clerk must file and stamp those documents with the date on which they were received.[FN1] A clerk of a court may not reject a pleading for form,[FN2] general informality,[FN3] originality,[FN4] lack of statutory authorization for the filing,[FN5] or on substantive grounds,[FN6] unless the clerk acts under specific rule or statutory authority to reject pleadings that lack certain documents.[FN7] The lack of a civil case cover sheet is not a sufficient omission to reject a filing.[FN8] A filing, untimely on its face, is nonetheless a filing that requires action by the court clerk, leaving to the court the ultimate question of timeliness or other merit.[FN9] [FN1] Glauner v. State, 107 Nev. 482, 813 P.2d 1001 (1991). The clerk of court properly assigned new case number to a claim where the complaint did not identify itself as a renewal of a prior counterclaim. Meyer v. Minster Farmers Coop. Exchange Co., Inc., 2009-Ohio-4933, 2009 WL 2986971 (Ohio Ct. App. 3d Dist. Shelby County 2009). [FN2] Hooker v. Sivley, 187 F.3d 680 (5th Cir. 1999); Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010). [FN3] In re Smith, 270 S.W.3d 783 (Tex. App. Waco 2008). [FN4] Gehring v. Goodman, 25 Misc. 3d 802, 884 N.Y.S.2d 646 (Sup 2009) (copies of affidavits). [FN5] Estate of Johnson v. Ciarpelli, 71 A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010) (filing within clerk's authority without guidance by law). [FN6] Hooker v. Sivley, 187 F.3d 680 (5th Cir. 1999); McKeown v. Bailey, 731 A.2d 628 (Pa. Super. Ct. 1999). [FN7] Blundon v. Taylor, 364 Md. 1, 770 A.2d 658 (2001); Cable v. Hatfield, 202 W. Va. 638, 505 S.E.2d 701 (1998). [FN8] Maginn v. City of Glendale, 72 Cal. App. 4th 1102, 85 Cal. Rptr. 2d 639 (2d Dist. 1999). [FN9] In re Smith, 270 S.W.3d 783 (Tex. App. Waco 2008). AMJUR CLERKSOFCT 49 V. Powers and Duties C. Particular Powers and Duties 1. Filing and Recording of Papers Topic Summary Correlation Table References 47. Generally West's Key Number Digest West's Key Number Digest, Clerks of Courts k64 to 69 Forms Am. Jur. Legal Forms 2d 58:4, 58:6 to 58:8 (Certificate of Clerk Recordation or Authentication of Document) Am. Jur. Pleading and Practice Forms, Clerks of Court 7, 11 to 19 (Clerk's Certificate or AffidavitFiling or Recording of Documents) It is the official duty of the clerk of a court to record[FN1] or file all the papers in a cause presented by the parties, and to indorse the correct date of the filing on them.[FN2] The duty is purely

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ministerial[FN3] and the clerk may not refuse to perform except on the order of the court.[FN4] Caution: A clerk may refuse to accept a filing for nonpayment of filing fees unless a credit or waiver is allowed,[FN5] or where certain necessary documents are omitted from the filing,[FN6] and statutes or court rules may expressly authorize the clerk to refuse to accept papers for filing where a complaint is submitted by a person who has been found to be a "vexatious litigator."[FN7] Observation: A policy adopted by a clerk of court, that papers submitted for filing after regular hours would not be filed until the following day, complied with statutory guidelines and was within the clerk's discretion.[FN8] [FN1] Nash v. Campbell County Fiscal Court, 2011 WL 1620587 (Ky. 2011). [FN2] Estate of Johnson v. Ciarpelli, 71 A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010); In re Simmonds, 271 S.W.3d 874 (Tex. App. Waco 2008). [FN3] Benson v. District Clerk, 331 S.W.3d 431 (Tex. Crim. App. 2011) (writ of habeas corpus). [FN4] Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010); In re Smith, 270 S.W.3d 783 (Tex. App. Waco 2008). [FN5] 37, 38. [FN6] 49. [FN7] In re Smith, 270 S.W.3d 783 (Tex. App. Waco 2008). [FN8] Hartford Citizens for Responsible Government v. City of Hartford Bd. of Zoning Appeals, 313 Wis. 2d 431, 2008 WI App 107, 756 N.W.2d 454 (Ct. App. 2008).. AMJUR CLERKSOFCT 47

It is important to note that the SBN's Laura Peters emailed Couglin a version of the TPO Application that was materially different than the one it utlimately filed in that on page 6 of 6 of Form B-3 (the 12/20/12 TPO Application), the version Peters emailed Coughlin did not check the I FURTHER REQUEST that this Court set a hearing date for an Extended Order as soon as possible. ?? Yes ?? No (NOTE: neither box was checked on the copy of the application Laura Peters emailed to Coughlin on 12/19/12, however, the version the SBN filed did check the Yes box requesting a hearing date for an Extended Order as soon as possible). Further, the SBN never actually filed the EPO Application that one is directed to (by the form) and required to (under the statute) Further, King's DECLARATION on page 6 thereof fails to actually identify just whom it is that King is apparently the AUTHORIZE AGENT of, ie, whether it be he is the SBN's authorized agent or, perhaps, the authorized agent of some particular employee (even himself) for which he seeks to file such application. Such lack of specificity fails to satisfy the jurisdictional prerequisite presented in NRS 33.250(1) where such requires King specify that he is the authorized agent of the employer. Perhaps the biggest failure of King's TPO application resides where it completely fails to identify anything sufficient to meet the requirements of NRS 33.250(2)(c), which requires that such verified application must included, without limitation: (c) A detailed description of the events that allegedly constituted harassment in the workplace and the dates on which these events occurred. A few glaring problems with King's application appear where he fails to list any other location for the SBN beyond its Reno office. As such, would that not imply Coughlin is permitted to call, email, fax, or venture to the Las Vegas main office of the SBN? Further, King lists the

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main phone number of the SBN under the fax number section, and completely fails to list the Northern Office of the SBN's fax number at all, which could be taken as an exclusion thereof from those numbers to which Coughlin was, apparently not to contact the SBN by fax...However, given that Chair Echeverria's own use of the term contact in his 11/16/12 Order would, to be legal, necessarily need to at least allow for Coughlin to obtain a transcript of the 11/14/12 formal disciplinary hearing under the procedures set out in SCR 119, which require Coughlin to SCR Rule 119. Additional rules of procedure. 1. Record. The record of a hearing shall be made available to the attorney at the attorneys expense on request made to bar counsel... 3. Other rules of procedure. Except as otherwise provided in these rules, the Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases. Perhaps Clerk of Court/Paralegal/Investigator Laura Peters is not aware of NRCP 52, or NRCP 59, or NRCP 60, or DCR 13(7), etc., etc., or NRAP 10, and NRAP 11, or all the other various reasons why opposing counsel and the filing office of the SBN would necessarily continue to have business (which would, obviously, involve Coughlin contacting the SBN, the Clerk of Court of the Northern Office of the SBN, and the Office of Bar Counsel, in addition to the NNDB and Panel) to conduct even after the 11/14/12 hearing, and even after the 12/14/12 entry of the Panel's Findings of Fact; Conclusions of Law which lacks any indication in the title thereof that it is a decision sufficient to invoke SCR 105(3)'s procedural mechanisms. (It is ironic, that lack of congruity between the title of the 12/14/12 FOFCOL and the FOFCOL citing to Hill and Judge Holmes criticisms of Coughlin's work to the effect that the titles of his filings, at times, bore little to no relation to the content therein). Further, the transcript of the 11/14/12 formal disciplinary hearing itself e