Monday, May 4, 2015

Marc Randazza DOES Bully People to Suppress their Speech. He did that to me, Crystal Cox and to Whistleblower Alexandra Mayers and to Inventor Eliot Bernstein. Senate Bill 444 Nevada and the unethical, unconstitutional attorney Marc Randazza who advocates the bill and helped write the Nevada SLAPP Law.

Marc Randazza is flat out full of shit in his testimony regarding this Senate Bill. Anyone that can read all the details of Randazza v. Cox or Randazza v. Mayers can clearly see that he is a First Amendment BULLY Flat out.

Here is his SHADY, Bullshit Testimony
https://www.youtube.com/watch?t=104&v=jajveO6eahM

Marc Randazza SHOULD be Liable to me and his other victims. 

 Marc Randazza uses the SLAPP Laws to Bully People such as me, Crystal Cox. 

 IT IS my RIGHT to SUE Marc Randazza and NOT his right to use Nevada SLAPP to STOMP my constitutional rights to counterclaim, to sue my former attorney.

Here is Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

I, Crystal Cox have Proved that there is CLEAR and Convincing Evidence that Marc Randazza knowingly posted false information about me WORLDWIDE. He is liable to me for this and is using Nevada SLAPP to protect himself as my former attorney to defame me.

Attorney Marc Randazza uses his power in the courts to file a defaming, flat out lying legal action against his former client AND then use those files to file other legal actions, complaints and a worldwide defamatory campaign.

Nevada SLAPP Suit to Chill the Speech of Blogger Crystal Cox, Speaking CRITICAL of asshole, rogue, lawless attorney Marc Randazza of Randazza Legal Group.

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

Defendant Crystal Cox's Affirmative Defense in the ALLEGATIONS against her by her her former attorney Marc Randazza of Randazza Legal Group.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.268.0.pdf


First Amendment Trumps Trademark Law, Randazza should have known that.

Trademark Law should NOT be used to TRAMPLE First Amendment Rights
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.268.0.pdf

Attorney Marc Randazza claims to the courts that he did not represent Crystal Cox, yet he discussed the case with attorney Eugene Volokh and claimed to be representing me, and even discussed filing motions and get court transcripts in moving forward.

Eugene eMail to Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.263.0.pdf

eMail between Cox, Volokh and Randazza, Clearly showing that Randazza and Volokh were acting as Cox's attorney and discussing court motions and transcripts moving forward, and keeping the client, me, in the loop.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.258.0.pdf


Marc Randazza  of Randazza Legal Group lied to the world deliberately painting Crystal Cox and Eliot Bernstein to be criminals, felony extortionist. Yet clearly as seen below Marc Randazza of Randazza Legal Group did not, himself believe he was being EXTORTED in any way, but that Cox was only asking for a job, and being unreasonable in his opinion.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.261.0.pdf


Marc Randazza of Randazza Legal Group agrees to represent Crystal Cox, yet LIES in sworn statements to the court that he did indeed represent me.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.259.0.pdf





https://docs.google.com/document/d/1ZxTmp7zZ7HcNaOXXZYoNyTaEH9uuh0bPUUuzMgSQ8uk/edit



My personal Experience with Marc Randazza as my Lawyer
http://unethicalscumattorney.blogspot.com/2015/04/my-personal-experience-with-nevada.html

For more Check Out the Links Below
http://unconstitutionalattorney.blogspot.com

http://unethicalscumattorney.blogspot.com/2015/04/crystal-cox-counterclaims-declaration.html

Nevada SLAPP Case where Marc Randazza sued me, Crystal Cox to SUPRESS my SPEECH and take my online sites speaking critical of him, then when I counter claim he uses Nevada SLAPP.
"Randazza first moves to dismiss Cox’s counterclaims under Nevada’s anti-SLAPP law, NRS 41.660"

Marc Randazza filed a SLAPP lawsuit against his former client Crystal Cox to suppress her speech. Yet he tries to claim SLAPP as a defense against her defamation and malpractice claim. And does this wayyyy after she filed those claims.

Court Says,  "I find Randazza’s special motion to dismiss was not filed by NRS 41.660’s 60-day deadline and that the filing delay is not supported by good cause. I therefore deny the special motion to dismiss. I also deny Randazza’s motion to strike Cox’s answer and enter default because claimdispositive sanctions are presently unwarranted. Cox has not been explicitly warned that such sanctions could issue if she continues to disregard court rules and file frivolous motions, and I decline to take such a draconian step without first warning her of this possibility."

THE COURT DENIED RANDAZZA MOTIONS TO DISMISS COX'S COUNTERCLAIM OVER AND OVER. YET HE DESPERATELY KEEPS BEGGING FOR ANOTHER WAY.

COURT SAYS;   "A. Special Motion to Dismiss [Doc. 224] Randazza specially moves for dismissal of Cox’s remaining counterclaims for defamation and malpractice under NRS 41.660, which provides protections for defendants in Strategic Lawsuits Against Public Participation (SLAPP).

Succinctly, “[a] SLAPP suit is a meritless lawsuit that a party initiates primarily to chill a defendant’s exercise of his or her First Amendment free speech rights.” 

A SLAPP claimant typically seeks “to obtain a financial advantage over one’s adversary by increasing litigation costs until the adversary’s case is weakened or abandoned.”5 NRS 41.660 provides a special, expedited procedure for obtaining the dismissal of SLAPP suits.

But to obtain this relief, the special motion to dismiss “must be filed within 60 days after service of the complaint, which period may be extended by the court for good cause shown.”

The 60-day period “runs from the filing of the most recent amended [counterclaim].” Randazza’s special motion is late.

Cox’s last operative iteration of her counterclaims was filed on February 24, 2014, giving Randazza until April 28, 2014, to file a timely special motion under NRS 41.600. But he waited an additional four months—until August 15, 2014—to finally file it. I find Randazza’s excuse for the delay unavailing. Randazza first moved to dismiss Cox’s claims under FRCP 12(b)(6) or strike them in March 2014, and I resolved those motions in May."

CLEARLY Randazza is the one who filed a Strategic Lawsuits Against Public Participation (SLAPP) against his former client Crystal Cox and not the other way around. 

"a] SLAPP suit is a meritless lawsuit that a party initiates primarily to chill a defendant’s exercise of his or her First Amendment free speech rights.” 

.. and that is just what Randazza did to his former Client Crystal Cox, yet begs the court to dismiss her VALID claims as if she filed the SLAPP SUIT.

Randazza filed a SLAPP suit  “to obtain a financial advantage over one’s adversary by increasing litigation costs until the adversary’s case is weakened or abandoned.”

He filed the case against Cox, and harassed her non-stop for nearly 3 years now. She is homeless, penniless and has no attorney, he is the one that took her intellectual property, her livlihood, and pressured her to abandon the case and do what he told her to do.

Then he files yet again to dismiss Crystal Cox's claims, as if SLAPP has anything to do with malpractice really. And the court denies this claim, as seen at the link below.

http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.241.0.pdf

Randazza then, assumedly scared shitless, filed a time stalling frivolous motion to the Ninth Circuit to appeal the above FAIR and JUST ruling as a matter of law.

Here is the Randazza v Cox, and counterclaims docket
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

So after the District of Nevada yet again DENIES his whiny dribble, then Mr. super duper Randazza whines to the Ninth circuit court as if he is the injured party. Hmmm ..

Here is the DOCKET for the Ninth Circuit Randazza whiny dribble appeal of the Judicial Decision above that `DENIED him super powers to squash litigants rights of due process.
http://ia601503.us.archive.org/3/items/gov.uscourts.ca9.15-15610/gov.uscourts.ca9.15-15610.docket.html


Nevada Anti-Slapp Laws and Marc Randazza

BELOW IS A BIT FROM THE RANDAZZA v. COX COUNTERCOMPLAINT

Crystal Cox, Pro Se, sued Marc Randazza, her former attorney, for malpractice and for defamation.

This Post is in regard to Exhibit 22 regarding Ken White's unlawful attack on Blogger Crystal Cox.

The Point of Sharing this is to show what these guys do to people like me, there are many of us out there, and what they say about these attorneys who gang up on targets to affect the outcome of court cases, to intimidate litigants and affect settlements is true.

Click Below for Exhibit 22 of Randazza v. Cox, Clearly Showing that Kenneth White of Popehat.com was working with attorney Marc Randazza to Deliberately Destroy the Life of Crystal Cox. This is in clear violation of law and the rights of former client.

Click Below to See Exhibit Post from Kenneth P. White's defamatory blog Popehat.com
https://docs.google.com/file/d/0Bzn2NurXrSkiU29GUEZTR2ZycnM/edit

Here is a Bit More on Exhibit 22 Above.

Exhibit 22 a blog post from Popehat.com which is a legal blog by First Amendment Attorney Kenneth P. White of the Law Firm, Brown, White and Newhouse out of California.

Kenneth P. White has a reputation of suing on the Painting in False Light statute in California, and seems to get the laws about posting false statements as if they are facts. Yet he deliberated attacked anti-corruption blogger Crystal Cox and came to the odd defense of Porn Attorney Marc Randazza, who clearly, flat out lied to him about Crystal Cox, Investigative Blogger.

Ken White is a friend and close associate of Marc Randazza and works with the Free Speech Coalition alongside Randazza, seems to take Marc Randazza's word as if it were LAW, Flat out Fact and with total disregard for the constitutional rights of Marc Randazza's victims, such as Investigative Blogger Crystal Cox. 

Kenneth White deliberately, willfully, wantonly painted Anti-Corruption blogger Crystal Cox in false light, knowing full well that what he posted was false statements of fact.  

And knowing full well that it was illegal to "gang up" on Randazza Legal Group's former client Crystal Cox. This violates attorney ethics and the law, as well as the constitutional rights of Crystal Cox.  Ken White is an attorney, he KNOWS the law and he is bound to attorney Ethics of which he CLEARLY violated.

Kenneth P. White took the word of Marc J. Randazza and deliberately, knowingly, defamed Crystal Cox MALICIOUSLY and with total disregard for the rights of Blogger Crystal Cox, her side of the story, the truth, or the Law.


Randazza v. Cox, counterclaim (Cox v. Randazza) Exhibit 21 shows an email from Marc Randazza, Crystal Cox's former attorney, offering her help, even if in the background and saying he respected her.

"Subject From To Date Crystal, RE:  from  Pre  Se  Defendant  Crystal  L.  Cox mjr@randazza.com  <mjr@randazza.com> Crystal  L.  Cox  <savvybroker@yahoo.com> 

Fri,  Dec  16,  2011  at  12:55  PM 

"I  want  to  address  a  few things: First  and  foremost,  if  you  feel  that  I  did  not  treat  you  respectfully,  I  humbly  apologize.    

I  do  not  wish  to  leave  that  undiscussed.    

People  like  you  are  important  for  the  future  of  citizen  journalism,  and  I  wish  to  see  you  succeed.   I  also  want  to  correct  a  misperception  here.    

I  did  not  tell  anyone  that  I  represented  you,  for  certain.    I  did  tell  the opposing  counsel  that  I  thought  a  deal  might  be  brokered  -  but  that  I  wanted  to  speak  to  him  first  (to  test  his  waters  with respect  to  a  possible  mutually  agreeable  resolution). 

 Finally,  I  want  to  make  it  clear  that  our  discussion  about  money  was  in  terms  of  "costs."    I  thought  that  I  made  it  clear that  my  bills,  my  fees  (my  income)  would  be  waived.    All  that  I  was  asking  you  about  being  able  to  pay  was  out  of pocket  reimbursement  of  expenses.   

Despite  the  contents  of  this  email,  I  wish  to  let  you  know  that  I  am  sill  willing  to  lend  a  hand  in  any  way  -  even  in  the background.   - Marc"

Exhibt 17 of Cox's Counterclaims against Marc Randazza, suing him for Malpractice and Defamation, is linked below.

https://docs.google.com/file/d/0Bzn2NurXrSkiY00tM3lidGw0M2M/edit

Exhibit 17 was a private email from Blogger Crystal Cox, taking her former attorney at his word of offering help, and asking him for a possible job or job recommendation.

A partial email thread was posted on Ken White's blog, Popehat.com and made to look as if it were the felony crime of extortion, when as Exhibit 17 clearly shows Randazza said flat out that he had no issue with Cox asking for a job and admits to that clearly.  This part of the email thread was initially, maliciously, unethically, unlawfully left out to paint Cox as a CRIMINAL.
Ken White posted this confidential email and painted Cox in false light knowing the laws very well, as he is an attorney.  Ken White got this email from the only person who had it, which was Randazza. And posted the email in a public forum to deliberately defame Blogger Crystal Cox to teach her a lesson for not doing as Marc Randazza DEMANDED of her.

This exhibit proves that Cox's former attorney Marc Randazza deliberately and intentionally defamed Blogger Crystal Cox and is also guilty of malpractice as well as making false and defamatory statements to third parties.

Ken White claimed that Cox had targeted a 3 year old. This was malicious and deliberate defamation against Blogger Crystal Cox, with total disregard of the facts. As Crystal Cox never had a blog about a 3 year old. There is NO basis in fact that Cox attacked a toddler, it NEVER even remotely happened. 


Exhibit 22, Popehat.com blog by California Attorney Kenneth P. White of Brown, White and Newhouse CLEARLY shows yet again that Investigative Blogger Crystal Cox was hailed a "champion", a hero of free speech, and that after the malicious defamation campaign of Marc Randazza and Kenneth White, Cox was the villain, the felon, the extortionist and a monster who attacks a three year old.


Exhibit 22 remarks on Forbes Kashmir Hill and New York Times David Carr turning over rocks to find the truth. Yet Randazza is who told them Cox had extorted him, and had a blog about his child. Randazza made false and defamatory statements to third parties and is guilty of defamation. And Randazza was Cox's attorney and had a duty and obligation to protect COX and not to ruin her life.


Exhibit 22 shows First Amendment Ken White of Brown, White and Newhouse in California, claiming that Litigant Crystal Cox's private email to attorney David Aman, in her pro se capacity after she was sued for 10 million dollars offer a settlement AND her private email to her former attorney Marc Randazza asking for a job was extortionate.

This is CLEARLY a Blog Post of DEFAMATION.  As Kenneth P. White did no fact checking. He simply BELIEVED the Rants of a disgruntled, humiliated, FIRED, former attorney of Investigative Blogger Crystal Cox.

Ken White is GUILTY of Defamation. It is not an EXCUSE that he simply believed his associate, attorney Marc Randazza and posted false statements of fact. 

Kenneth P. White of Brown, White and Newhouse CLEARLY painted Crystal Cox in false light and clearly BROKE the law of Assault, Slander, Defamation. 

And I would say, Ken White is even possibly guilty of Criminal Defamation as Exhibit 22 shows, he did this to target Blogger Crystal Cox in a clear civil conspiracy with other attorneys, including Marc Randazza.

Exhibit 22 shows that Kenneth White of Brown, White and Newhouse posted FALSE Statements of FACT and with clear vile defamatory hatred toward Crystal Cox, wishing her to be cockroach stomped.

Exhibit 22 proves that  Kenneth P. White, California First Amendment Attorney and Nevada attorney Marc Randazza was acting with other attorneys to target Crystal Cox, and deliberately render her powerless.

And these same attorneys DO THIS SAME THING to others they want to Silence, Intimidate, or pressure into a settlement of some kind.

Here is a quote from Exhibit 22:

"First, every time Crystal Cox attacks someone, we can band together — as bloggers did for Marc Randazza when Crystal Cox attacked him — and write fair and factual posts about the target. That substantially blunted Crystal Cox's attempt to destroy Randazza's reputation by spamming numerous nutty blogs about him, pushing her efforts off the first page. 

As a team, we can render Crystal Cox powerless and largely irrelevant. More speech works . (Now you know why I put up that mysterious Popehat Signal.) 

It might be nice to start by offering this gesture to X, her victim in the Oregon case. But if you're out there — if she's gone after you, or threatened to — we can help you, too. We'll throw up the Popehat Signal and gather a more-speech team and flush her off the first pages of your search results."

Crystal Cox is an Investigative Blogger, she did not attack, she reported on and exposed corruption in her unique style. 

Exhibit 22 proves that these attorneys banded together to go after Blogger Crystal Cox. They did this in Civil Conspiracy to render Cox powerless, irrelevant and to stomp her like a cockroach. 

They did this while intentionally, deliberately, wilful and wantonly, knowing that what they posted was not based in adjudicated fact and was malicious defamation.

Kenneth P. White Initiated a Campaign to DESTROY Crystal Cox's Domain name network and intellectual property, she had build over 16 years. 

Exhibit 22 also says: " Third, we can search for other victims. The emails to X's lawyer and to Randazza are two data points — but showing a remarkably similar approach. Has she done this other times? There's a way to find out — we use reverse whois directories , plug in her name and addresses and email addresses and known associates, and find every domain she has ever registered. I've already started. Then we see whether the domains were used to attack someone. If they were, we start contacting the targets and asking questions — like "has Crystal Cox offered you reputation management services?" 

Why would we want to see if Crystal Cox has sent emails to others like the ones she sent to Randazza and X? Well, two reasons, really. 

The first is civil. 

If Volokh succeeds in getting Crystal Cox a new trial on appeal — or if anyone else sues her — a pattern of such communicationswill be very probative of her intent in making false statements about people when she sets up multiple blogs about them. Under Federal Rule of Evidence 404(b) , such "other bad acts" evidence is generally inadmissible — unless it is probative of intent, or knowledge, or motive, or lack of accident, or similar factors. What could be more probative of Crystal Cox's malicious intent than a pattern of such communications — like the pattern we already see in the two described above? And the second reason to investigate further "reputation manager" offers?

Exhibit 22 proves that these attorneys acted together to destroy Cox's intellection property, online reputation, to paint her in false light and deliberately, willfully and wantonly ruin her life, with total disregard for the law and for their duty and obligations to society as attorneys. 

They acted in a pattern of communication, not Crystal Cox.

Exhibit 22 proves that these attorneys were targeting Crystal Cox's domain names, prying into her private information and launching an attack. All based on the third party false and defamatory statements made by Crystal Cox's vengeful former attorney, Marc Randazza.

Exhibit 22 shows that Randazza sued Cox to create a pattern and history to attempt to set up his former client Cox, of which he owed client attorney duties to.  They were creating a false "pattern and history" using privileged emails to attorneys that were not extortion and should not have been posted online, period, as a matter of law.


Click Below to Read Marc J. Randazza attorney emailing his former client Crystal Cox. He emails Blogger Crystal Cox, his former client, after she fired him.  Randazza apologizes and offers help, even if in the background. Yet later, Crystal Cox asks for help and he takes the email out of a thread of emails and deliberately, defames his former client in a malicious worldwide media and legal attack.



A Bit more on What Exhibit 17, in Crystal Cox's counterclaims of Malpractice and Defamaton against Randazza prove;

Exhibit 17 shows that, though Crystal Cox's former attorney Marc Randazza was clearly upset that his former client Blogger Crystal Cox registered the domain name he did not believe she had a reasonable or ethical right to own, Randazza did not tell her he believed it was against the law, or extortion in any way. And in fact CLEARLY, Specifically says that he does not mind that Crystal Cox asked him for a job.

Randazza is well known for defending the rights of individuals to have domain names with other people's names in it, such as the Glenn Beck case he was in. And to gripe about whom ever they please, well protected under the coveted First Amendment

Crystal Cox, assumed that Marc Randaza would have no issue with her owning a domain name that he had decades to purchase if he had wanted, and after she had read his legal arguments in the Glen Beck case and thought, at the time he was a true proponent of Free Speech rights for all.

Crystal Cox, herself, had already won a WIPO claim for the right to own a domain name with 3 different Proskauer Rose attorneys in it. So why in the world would she believe that Randazza's would be different.

Though clearly later shown, WIPO did favor Marc Randazza. Check Out Exhibit 2
WIPO COMPLAINT (clear defamation from attorney Marc Randazza, regarding iViewit 
Inventor Eliot Bernstein and blogger Crystal Cox.

WIPO Complaint Randazza Filed 
https://docs.google.com/file/d/1PqcfV_loGIe_S7Y2oBZTDshtDwq00cRQ_UReJkHsxFsbYAc3g_q23jrEQmqczdCnIiLuGni50YxVmh-H/edit

And Below is the world wide defamation publication by WIPO'S Peter Michaelson, friend of Marc Randazza, in which he accuses Cox and Bernstein of the Felony Crime of Extortion with NO ADJUDICATED

WIPO DEFAMATORY PUBLICATION
http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2012-1525


Motion in Limine for above Exhibit
https://docs.google.com/document/d/11dKxWMPPXsSIQH20o1AL88InEYKBP8fYezVOOumeyjk/edit

It is clear to see from this blog post that Marc Randazza, Crystal Cox's former attorney maliciously lied about her, defamed her and iViewit inventor Eliot Bernstein with full knowledge he was doing it. As it's clear in Randazza's email to Cox that he knew she was merely asking for a job. But flat out LIED in sworn documents to WIPO, with malicious and deliberate intent.


In fact Exhibit 17 shows clearly, without a doubt that Randazza did not believe he was being extorted, but that in fact, he believed Cox was unreasonable and unethical for registering the domain name, but that she was just asking for a job.

This Exhibit proves that Randazza, with full knowledge of it being false, interviewed and flat out lied, made false and defamatory statements to NPR, Forbes, the New York Times, WIPO, the Czech Courts, Tracy Coenen and the Fraud Files, Kenneth White attorney blogger of Popehat.com and numerous other well connected bloggers, and Media around the world.   As well as made these false and defamatory statement in courts and on his own blog. KNOWING full well that it was false.

RANDAZZA gave blogger attorney Kenneth P. White of Popehat.com Cox's personal, privileged, private email to her former attorney who told her to let him know if he could help her in any way, and he used this email to paint Crystal Cox in false light, deliberately not posting the whole email thread which showed that he knew Cox was asking for a job.

Therefore because Cox would not simply turn over a domain name he thought she had no right to own, he went on NPR, interviewed with the New York Times, Forbes, Popehat.com, and he viciously, deliberately, knowing it was false, lied, made false statements to WIPO who used their global clout to ruin the lives of Eliot Bernstein and Crystal Cox and accuse them worldwide and nationwide, in legal blogs, in big and small media, that Crystal Cox and Eliot Bernstein ( who never was even in the email) had extorted him, which is a felony crime.

CLEARLY Crystal Cox is entitled to relief for the damage Randazza has caused her, though Cox has no attorney or way to articulate this evidence on a legal basis. Cox has valid claims and exhibit 17 further proves this.

Exhibit 17 shows that Randazza was "deeply offended" and that he did not think Cox was reasonable or ethical. However, Randazza clearly never claimed Cox was extorting him, nor did he believe this at the time. Yet later, in retaliation, he deliberately defamed Cox in a widespread, malicious, willful and wanton campaign of revenge, harassment, and widespread posting and speaking false and defamatory statements against Cox to third parties. 

This ruined Cox's life, quality of life and business. This also put Crystal Cox in constant danger, duress and up against massive, widespread hate in big and small media around the world.  And simply for registering a domain name and asking for a job.

Randazza has caused Cox irreparable damage.

Exhibit 17 shows Counter Defendant Marc Randazza Say, "Asking me for a job, or a recommendation?  That doesn't bother me in the least."  Yet because Cox did not do as he told her to, he retaliated and ruined her life. And told countless media that he was not only bothered by it but put in terror, stress and extreme duress over it. Which was untrue and Exhibit 17 shows this.

Randazza swore to WIPO that Cox had extorted him and did all the things published worldwide in Exhibit 2. Randazza made false and defamatory statements to third parties, willfully and wanton and with full knowledge that they were not true.


Marc Randazza is friends with Trademark attorney Peter Michaelson (INTA). He has been seen with him at INTA meetings. Peter Michaelson was the Sole WIPO panelist that decided on this decision. He took Marc Randazza at his word, because he knew him and trusted him.


This exhibit proves the damage Randazza deliberately, maliciously caused his former client Crystal Cox, and that he made false statements to WIPO knowing full well they were false.


Randazza got the New York Times, Philly Law Blog, Forbes and others to post defamatory statements about Cox, then he used those articles as exhibits in his WIPO complaint, as some sort of proof.


PAY ATTENTION TO THE ENTIRE RANDAZZA v. COX CASE AND COUNTER CLAIMS AS THIS PROVES WHAT THESE ATTORNEYS DO TO MANY.


MOTION IN LIMINE EXHIBIT 17
https://docs.google.com/document/d/1I159SAmI5r4zRJOwt28a_fG8XsNDu5TTFZMg1q9wSEk/edit


MOTION IN LIMINE EXHIBIT 22
https://docs.google.com/document/d/1Jux23ASWFxziaZRI9JvWmQi1rCxiYBVnJPHRsNnaCkk/edit


MOTION IN LIMINE EXHIBIT 2
https://docs.google.com/document/d/11dKxWMPPXsSIQH20o1AL88InEYKBP8fYezVOOumeyjk/edit


Randazza v. Cox, District of Nevada, 2:12-cv-02040.  Docket Link Below

Case Cause:15:1125 Trademark Infringement (Lanham Act)
Nature of Suit:840 Trademark

http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

MARC RANDAZZA KNOWING PUBLISHED AND MADE WORLDWIDE FALSE STATEMENTS 
ABOUT ME, BLOGGER CRYSTAL COX AND THEN USED NEVADA SLAPP TO ATTEMPT 
TO STOP ME FROM A COUNTERCLAIM. 
Posted by at No comments:

Thursday, January 8, 2015

First Amendment Attorney Marc Randazza of Randazza Legal Group SAYS that Preliminary Injunctions are unconstitutional, they are unlawful prior restraint, they are "patently unconstitutional", they are clearly an "unconstitutional remedy". Especially if there was no prior First Amendment Adjudication.


Let's Look at the RULING and Marc Randazza's 
Big Preliminary Injunction VICTORY

A Bit from Marc Randazza's Victory APPEALING an alleged unconstitutional preliminary injunction against his client. Even though Marc Randazza himself used an unconstitutional preliminary injunction against me, Crystal Cox and stole my search engine ranking, my intellectual property, my blogs and then proceeded to violate my privacy rights, constitutional rights, civil rights and to harass and defame me for years.

""Irina Chevaldina appeals an order granting a preliminary injunction to “enjoin tortious interference, stalking, trespass and defamatory blogs” entered in favor of Raanan Katz and the other named appellees, plaintiffs in the circuit court. We vacate the order and injunction. "

Source
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf


" In this appeal, we review a temporary injunction in the circuit court action
which determined that “the Defendants have blogged extensively about the
Plaintiff and many of these blogs are arguably defamatory. Although ultimately a
defamation trial will be held, this Court ORDERS the Defendants not to enter
defamatory blogs in the future.”

The court determined that:

Plaintiffs have a substantial likelihood of ultimately prevailing on the
merits of their claims, and there is a substantial threat of irreparable
injury to the Plaintiffs if injunctive relief is not granted, that the
threatened injury to Plaintiffs outweighs whatever damage the
injunction would cause the Defendants, and that the injunction would
not be adverse to the public interest."

Source
3dca.flcourts.org/Opinions/3D12-3189.op..pdf

In Randazza v. Cox there was no "substantial likelihood of ultimately prevailing on the
merits of their claims" and there certainly was no First Amendment Adjudication BEFORE Plaintiff Marc Randazza seized Blogger Crystal Cox's intellectual property.

See the Link Below that shot down all of Plaintiff Randazza's unsupported causes of action
in a Denial of a Summary Judgement in Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf

The Ruling Goes on to Say;

"A temporary injunction “should be granted only sparingly and only after the moving party has alleged and proved facts entitling it to relief.” Liberty Fin. Mortg. Corp. v. Clampitt, 667 So. 2d 880, 881 (Fla. 2d DCA 1996)."
3dca.flcourts.org/Opinions/3D12-3189.op..pdf

Yet attorney, Plaintiff Marc Randazza proved NO FACTS in Randazza v. Cox and Bernstein, yet he filed gag orders, injunctions, stole blogs, shut down sites, and even redirected my blogs to a post on his blog defaming and lying about me. Why do the courts protect Marc Randazza when he is clearly violating law and the constitutional rights of his victims?


"In order to establish the right to a temporary injunction the moving party must show: the likelihood of irreparable harm; the unavailability of an adequate remedy at law; the substantial likelihood of success on the merits;

the threatened injury to the petitioner outweighs the possible harm to the respondent; and the granting of the temporary injunction will not disserve the public interest. E.g., City of Miami Beach v. Kuoni Destination Mgmt., Inc., 81 So. 3d 530, 532 (Fla. 3d DCA 2012). 

We review the temporary injunction for an abuse of the trial court’s discretion. Angelino v. Santa Barbara Enters., 2 So. 3d 1100, 1103 (Fla. 3d DCA

A. Injunction Against Tortious Interference and Defamatory Blogs Injunctive relief is not available to prohibit the making of defamatory or libelous statements. See, e.g., Vrasic v. Leibel, 106 So. 3d 485, 486 (Fla. 4th DCA 2013).

A temporary injunction directed to speech is a classic example of prior restraint on speech triggering First Amendment concerns. Id.

There is, however, a limited exception to the general rule where the defamatory words are made in the furtherance of the commission of another intentional tort. E.g., Murtagh v. Hurley, 40 So. 3d 62 (Fla. 2d DCA 2010); Zimmerman v. D.C.A. at Welleby, Inc., 505 So. 2d 1371 (Fla. 4th DCA 1987). "

Source of Ruling
3dca.flcourts.org/Opinions/3D12-3189.op..pdf


Yet Plaintiff Marc Randazza was easily GRANTED an unconstitutional preliminary injunction against Blogger Crystal Cox and iViewit inventor Eliot Bernstein, why?

Well connected First Amendment Attorney Marc Randazza FLAT OUT lied about me, perjured himself over and over and Judge Gloria Navarro took him at his word and NO PROOF and stole my search engine ranking, my intellectual property, my work product and caused me irreparable harm to myself, my business and my relationships.

Here is the Unconstitutional TRO Filing  (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.2.0.pdf

Added Flat out Lies to TRO  (Randazza Filing)
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.6.0.pdf

REPLY with more Lies and Attacks regarding the TRO  (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.12.0.pdf

Another REPLY (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.28.0.pdf

ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction against Defendant Blogger Crystal Cox in favor of Marc Randazza.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.14.0.pdf

Another ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction Just in case the FIRST ONE was not heard.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.41.0.pdf


My, Defendant Crystal Cox's Response and Objection to Unconstitutional TRO / Motion for Preliminary Injunction

Defendant Crystal Cox's  Objection
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.29.0.pdf

Defendant Crystal Cox's  REPLY to Response
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf

Randazza et al v. Cox et al
District of Nevada 2:12-cv-02040

Cause;  15:1125 Trademark Infringement (Lanham Act)

Nature Of Suit:  840 Trademark

1) VIOLATION OF INDIVIDUAL CYBERPIRACY PROTECTIONS
– 15 U.S.C. § 8131

2) CYBERSQUATTING - 15 U.S.C. §
1125(d)

3) RIGHT OF PUBLICITY – NRS
597.810

4) COMMON LAW RIGHT OF
PUBLICITY

5) COMMON LAW RIGHT OF
INTRUSION UPON SECLUSION

6) CIVIL CONSPIRACY



Other Preliminary Injunctions Judge Gloria Navarro Gave Randazza Legal Group
even though they are allegedly "Rare" and Unconstitutional 



"ViaView, Inc. v. Chanson et al"

"Court Description: ORDER Granting 6 EX PARTE MOTION for Temporary Restraining Order filed by ViaView, Inc. IT IS FURTHER ORDERED that Defendants shall have until 12/7/2012 to file Response to 6 Motion for Preliminary Injunction.

Plaintiff shall file reply by 12/21/2021. Motion Hearing set for 1/2/2013 02:30 PM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 11/30/12. (Copies have been distributed pursuant to the NEF - EDS)"

Source


In SOME Cases, a Preliminary Injunction is Unconstitutional and Marc Randazza DEFENDS that position. Yet he used an unconstitutional Injunction to steal my work product, my intellectual property, my search engine ranking and my online content.


Preliminary Injunction are Unconstitutional Depending on Which Side your Attorney is On.

Opening Brief in the Irina Chevaldina Appellate Case No. 3D12-3189, Attorney Marc Randazza. 


In the District of Nevada, Judge Gloria Navarro's court, the Most Important thing is the Attorneys Pay Check, and the Law, the Constitutional Rights of Defendants, Due Process seems to be Irrelevant.

Judge Gloria Navarro seems to CLEARLY favors Randazza Legal Group as far as I see it.

These attorneys sue whoever they want, they get their attorney fees, intellectual property, fines paid to them and what ever they want in the MAGICAL Land La La Lawless Land of Judge Gloria Navarro of District of Nevada. 

More Research Links on that Topic



Liberty Media Holdings LLC v. FF Magnat Limited




"The Plaintiff has shown a substantial likelihood of success on the merits of its claims sufficient for the Court to issue a limited Temporary Restraining Order. Plaintiff alleges copyright infringement, contributory copyright infringement, vicarious copyright infringement and inducement of copyright infringement. (Compl., ECF No. 1.)

To show a substantial likelihood of prevailing on the merits of a copyright infringement claim, Plaintiff must show that: (1) it owns the copyright to which its infringement claims relate; and, (2) Defendants violated one of the Plaintiff's exclusive rights in the works. See Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991);

Latimer v. Roaring Toyz, Inc., 601 F.3d 1224, 1232-33 (11th Cir. 2010); Sid &amp; Marty Krofft Television Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1162 (9th Cir 1977); Educational Testing Servs. v. Katzman, 793 F.2d 533, 538 (3d Cir. 1977). These two factors have been clearly established by the Plaintiff."

Source of Above Judge Gloria Navarro RULING Favoring the SAME Plaintiff


Marc Randazza does not and did NOT have "substantial likelihood of success on the merits of its claim". Yet he was favored over his TARGET / his Victims.

Why is no FBI Agent, Dept. Of Justice Agent, the Nevada Attorney General, or the U.S. Attorney General Looking at all this?

It sure seems to VIOLATE the Rights of the Targets, the Defendants in some sort of pattern of "shakedown", in my Opinion

More Research on the Liberty Media Holdings LLC v. FF Magnat Limited and this Same  Attorney, who sure is GOOD at Showing Alleged "merits" of winning, Before a Defendant has any First Amendment Adjudication or Right to Due Process.




Love this Part "Emergency MOTION for Temporary Restraining Order by Plaintiff Liberty Media Holdings LLC. Motion ripe 6/20/2012."

I get threats of death, violence and Judge Gloria Navarro IGNORES my Real Emergency. Yet Gloria Navarro allows Randazza Legal Group to abuse the process and get emergency protective orders and Injunctions.

Frozen Accounts, Preliminary Injunctions, FORCED Attorney Fees and whatever Randazza Legal Group wants they get, WHY?

"Section 505 of the Copyright Act grants district courts discretion to award “
a reasonable attorney's fee to the prevailing party as part of the costs"

Randazza Legal Group sues their TARGET, and the Judge Forces their VICTIM to PAY the ATTORNEYS outrageous Fee's.  And if you Don't Judge Gloria Navarro will Freeze your Accounts. Pattern and History, I THINK SO.. in my NON-Attorney OPINION.

Don't Forget Liberty Media Holdings allegedly is infringing on the iViewit Technology and many companies owned, at least in part by Liberty Media Holdings are named in iViewit Technology. Randazza SUED Eliot Bernstein and got a Preliminary Injunction against him as well, with NO First Amendment Adjudication.

The Full Hypocritical Filing of Marc Randazza Regarding the 
Unconstitutional actions of Preliminary Injunctions.
Page 8 of above;

"This appeal Seeks to cure an unlawful prior restraint on the Appellant’s First Amendment rights, improperly imposed by the lower court. On November 19, 2012, the circuit court enjoined Appellant from writing, “defamatory” blogs 'in the future, despite expressly making “no findings of facts as to actual ‘violations of law by the [Appellants], except that [Appellants] have blogged extensively about the Appellee] and many of these blogs are arguably defamatory.” (RÃ/14)

The circuit court made this decision Without following the mandates of Florida Rule of Civil Procedure 1.610. However, even if it had, the injunction is patently unconstitutional."

                      WOW, "the injunction is patently unconstitutional", it is "unlawful prior restraint", EXCEPT for when Marc Randazza uses it against a Blogger he wants to SUPPRESS the SPEECH of.
                
Page 10

"Months and months of litigation, thousands of dollars, and thousands of pages of documents later, RKA sought a clearly unconstitutional remedy - an injunction against alleged defamation prior to any court determination that the speech at issue was even legally capable of defamatory meaning, much less Whether it was actually defamatory, privileged, or otherwise protected by the First Amendment. (R Vl-6)

The resulting lnjunction Order was so over-broad and subject to abuse, that the RKA even sought an order for contempt based upon Chevaldina doing no more than reporting the existence of the Order itself."

All that money to seek a "clearly unconstitutional remedy"? And Marc Randazza defends the opposite position he took to constitutionally violate Crystal Cox an Eliot Bernstein?

Full Hypocritical Motion Linked Below

Attorney Marc Randazza sought a "clearly unconstitutional remedy , "injunction ..prior to any court determination" from Crystal Cox and Eliot Bernstein, even though that "speech" was protected under the First Amendment and with NO First Amendment Adjudication. 

Randazza Legal Group, Marc Randazza stole massive online content, work product, intellectual property and used the lawsuit to violate my privacy rights, harass me, defame me, lie about me, harass me and to post private emails, get my bank account and wire records, harass and bully my church, threaten my ex's, get private proprietary business information from customers and clients and to put me and my sources under constant attack, threats, stalking, harassing, bullying and defaming for over 2 years now and counting. He did this as an "officer of the court". Clearly abusing his power.


Marc Randazza and Randazza Legal Group are
CLEARLY acting outside of the Law and are Violating
the rights of citizens every single day.

And they are using Judges, Attorneys, 
Investigators, Officers of the Court, and Thugs to do it,
in my Opinion.

EXPOSE Randazza Legal Group.

I say Indict Marc Randazza, J. Malcom DeVoy,
Michael Whiteacre, Ronald Green, Sean Thomas, 
and others I ALLEGE are acting in Civil and Criminal 
Conspiracy with them every single day.


Some More Fun on Preliminary Injunctions and Marc Randazza
http://crystalcoxmedia.blogspot.de/2013/03/pro-se-litigant-investigative-blogger.html


Marc Randazza of Randazza Legal Group had NO CASE against Crystal Cox or Eliot Bernstein, as is easily seen in the Denial of a Summary Judgement which CLEARLY shoots down every cause of action of the Plaintiff as a matter of LAW.


More on that at the Link Below
http://ethicscomplaint.blogspot.com/2014/12/randazza-v-cox-lanham-act-trademark.html


Here is the RULING that Denied the Summary Judgement
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
Posted by at  No comments: 

Tuesday, December 9, 2014

Randazza V. Cox Lanham Act, Trademark Infringement, District of Nevada; Plaintiff Marc Randazza HAS no Case against Blogger Crystal Cox and NEVER Did.

Randazza et al v. Cox et al
District of Nevada 2:12-cv-02040

Cause;  15:1125 Trademark Infringement (Lanham Act)

Nature Of Suit:  840 Trademark

Below is a Video of me, Crystal Cox discussing
the Original Complaint and Reading some of it.


Here is a Link to the Original Complaint attorney Marc Randazza filed against Blogger Crystal Cox to shut down and steal her gripe sites exercising her Free Speech Rights over him.

Below is a DENIAL of a Summary Judgement in Which
Shoots Down ALL of Marc Randazza, Plaintiff's ALLEGED "cause of action".


Below is a Video of Me Reading the Denial of Randazza's Summary



Here is the Entire Docket
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

Randazza et al v. Cox et al
District of Nevada 2:12-cv-02040

Cause;  15:1125 Trademark Infringement (Lanham Act)

Nature Of Suit:  840 Trademark

1) VIOLATION OF INDIVIDUAL
CYBERPIRACY PROTECTIONS
– 15 U.S.C. § 8131

2) CYBERSQUATTING - 15 U.S.C. §
1125(d)

3) RIGHT OF PUBLICITY – NRS
597.810

4) COMMON LAW RIGHT OF
PUBLICITY

5) COMMON LAW RIGHT OF
INTRUSION UPON SECLUSION

6) CIVIL CONSPIRACY

Posted by at No comments:
Subscribe to: Posts (Atom)