Marc Randazza FILED a SLAPP Lawsuit against a Former Client and acting as a HERO For Nevada Anti-SLAPP Laws? What a Hypocritical Asshole Marc Randazza is? Brian Sandoval was replaced as Las Vegas JUDGE by Judge Gloria Navarro. Judge Navarro has made sure that Marc J. Randazza is ABOVE THE Anti-Slapp Laws of Nevada in his Suing of Blogger Crystal Cox. Now Marc Randazza PRETENDS to PROMOTE Neveda Anti-SLAPP Law, EXPECT for when it comes to him being the one criticized. Then it's Judge Gloria Navarro and the Nevada Courts to the rescue to PROTECT the SLAPPER.

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Whiny Ass Copyright Porn Thug Evil Lawyer , Marc Randazza, uses DMCA, yet another in a long line of Speech Chilling Tactics, to attempt to SUPPRESS online speech that does not flatter him.

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Randazza Legal Group and Marc Randazza abuse the Power of the Courts for their own intellectual property thieving and First Amendment Rights Violating Motives.

Attorney Marc Randazza uses Protective Orders, Civil Lawsuits and TRO's to Chill Speech, Suppress Speech, Violate First Amendment Rights and all at the same time as falsely advertising to be a Free Speech Advocate and First Amendment Rights, FOR ALL, attorney.

Las Vegas based Attorney Marc Randazza of Randazza Legal Group uses the courts as his private play ground to bully those who dare to exercise their Free Speech rights and speak out about him, his "friends" and "associates", his law firm or his wife.

Marc Randazza does this while at the same time, PRETENDING, to advocate Free Speech for ALL.

Marc Randazza uses Protective Orders to get GAG ORDERS on those who exercise their First Amendment rights talking about him, or those who create a PARODY making fun of him. He does this while at the same time flat out lying that he is an advocate for the Free Speech rights of ALL.

Marc Randazza is certainly NOT for the First Amendment rights of Monica Foster / Alexandra Mayers NOR of me, Crystal Cox.  

Marc Randazza used an unconstitutional preliminary TRO's (alleged "Temporary" Restraining Orders"" to simply shut down massive blogs (speech) of mine and that "TEMPORARY" was well over 2 years now. He flat out misused the courts to STEAL intellectual property, STEAL search engine ranking, and suppress speech. He did this claiming Trademark rights. Yet they were clearly blogs that were "Gripe Site" and "Sucks Sites" of which he has previously defended.

Marc Randazza not only STOLE my intellectual property, my search engine ranking, and violated my First Amendment rights but he used all my decades of work and proprietary knowledge against me pointing the servers illegally to a blog post on his blog and his buddies blogs lying about me, defaming me, falsely accusing me of criminal activity and ruining my real estate career, my quality of life, my online business and ALL because he did not APPROVE of the online "SPEECH" I was using in griping about him and his wife.

Marc Randazza files a protective order with the courts, files a civil suit then uses that to ATTACK his target. He is then an officer of the court and can pry into your private life as deep as he wants. He uses this power to harass your church, publicize your home address, get your bank and wire records, get your phone records, harass clients and customers, harass and bully ex's, constantly question you, have you followed and abuse the power of the courts to ruin your life, business and relationships.

Attorney Marc Randazza, who is allegedly connected to the mafia. Marc Randazza DOES protect the rights of pedophiles to write guides on pedophiles, does associate with and said to employ Sean Tompkins and Ari Bass (Michael Whiteacre) to bully, threaten, stalk, harass and put "real fear" into those who Marc Randazza does not like, Marc Randazza does talk about the death of his targets and he bullies, threatens, lies about, criminal defames his targets such as me and Alexandra Mayers. He does REAL STUFF to ruin lives, and yet he pretends he is the victim, scared of us and the courts, judges give him his way, give him an illegal and unethical protective order which he uses as a GAG ORDER and a way to suppress SPEECH and steal intellectual property.

Yet Attorney Marc Randazza claims to be afraid of a woman me, and another woman in a separate protective order, Monica Foster / Alexandra Mayers and this fear is so bad he gets a protective order against us when he is the one that is breaking the law, bullying us, intimidating us, violating our rights and abusing the courts to do it.

Attorney Marc Randazza abuses the power of the courts, is above the law and the question becomes why? Why do Las Vegas judges give Marc Randazza super powers in the courts to abuse, stalk, bully, steal intellectual property, intimidate, threaten and all with the power of a TRO / a Protective Order that he gets the minute he asks based on his "STATED" fear or his STATED Trademark Violation. This is CLEARLY against the law but Attorney Marc Randazza and Randazza Legal Group's victims have NO RIGHTS in a COURT OF LAW. Only Mr. Randazza has rights and these rights violate the constitution of the United States and violate the LAW. Oh well Attorney Marc Randazza controls your courts and DOES NOT ABIDE BY THE LAW. That Fact sure seems to be clear to me.

Las Vegas based Lawyer Marc Randazza falsely claims to be an advocate for Free Speech Rights for ALL and for the First Amendment Rights of ALL even pedophiles and even in the domain name GlenBeckRapedANDmurderedayounggirlin1990.com YET he suppresses the speech of those he does not like or approve of and he uses the power of the courts to do it.

Marc Randazza of Randazza Legal Group claims to be a Trademark expert, he falsely advertises his expertise in this field, yet he FALSELY sued me, Crystal Cox, his former client claiming a Trademark violation against him, his wife, and his toddler.  Randazza did this with willful and wanton intend to harass, bully, intimidate, cause harm and ruin the life of his target, in this case me, his former client Blogger Crystal Cox. Randazza either is NOT a Trademark Law expert or he is and he used that expertise to commit fraud on the court and sue a former client claiming a cause of action of Trademark Law of which he clearly had no legal rights.

Why? He did this in order to try and shut me up because I was exercising my free speech rights and First Amendment rights to have gripe sites against  him, call his wife a slut and review his legal practice and law firm with sucks sites. Randazza STOLE those sites and blogs that were in the top 10 search for Marc Randazza and Randazza Legal Group and he used a protective order, a TRO to do it. No muss, No fuss; he says he is in fear and the courts simply give him his wish, it's MAGIC.

Marc Randazza of Randazza Legal Group claims to be an expert in intellectual property law yet he did not own his Trademark nor his wife, nor child and sued me claiming he had a Trademark. Marc Randazza did not even own his name as a dotcom yet FALSELY advertised that he is a Domain Name expert.

Marc Randazza and Randazza Legal Group make False claims daily, yet for some reason they get away with it. Marc Randazza and Randazza Legal Group are not ethical, do not operate under the color of law as far as I see it and are unconstitutional. Marc Randazza and Randazza Legal Group have super powers in the courts, it seems, and are oddly protected by Judges across the United States and probably in other countries. And for some reason they still get away with their INJUSTICE.

I will soon be filing a DOJ and FBI complaint regarding all of these issues. As Soon as I can. 

I BELIEVE it is against the law to make False Claims in Advertising.
http://www.law.cornell.edu/uscode/text/31/3729

Randazza makes fraudulent claim of being an advocate for ALL speech, False Claims of being a Trademark Expert and Intellectual Property Expert. In my Opinion of Course.

Randazza Legal Group Makes False Claims, as proven in the willful, wanton, deliberate with full knowledge of it's falsehood frivolous, invasive, rights violating legal actions against  Crystal Cox, Monica Foster / Alexandra Mayers, Desi Fox / Diana Grandmason and Eliot Bernstein, iViewit Inventor. 

I say NO more Randazza Above the LAW.

Please Send tips to ReverendCrystalCox@Gmail.com 

District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights. Crystal Cox Objection to Summary Judgement.

Document 80, District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights.

Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT

"Notice To Court: This Court has DENIED requests to sign a conflict of Interest

Disclosure, though requested several times by Pro Se Defendant / Pro Se Counter Plaintiff

Crystal L. Cox. Any action forward by Judge Gloria M. Navarro or Judge Peggy A. Leen, who

refuses to admit/deny conflicts and rules forward will be charged with Obstruction of Justice

through conflicts of interest, violations of attorney and judicial cannons in order to Deny Due

Process via aiding and abetting the alleged civil and criminal conspiracy through Fraud on the

Court.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox intend to file criminal complaints

against any officer of the court, including opposing counsel, who violates any law or ethical

statues in order to perpetrate the fraud through obstruction via conflicts, or has violated any law

already in previous rulings affecting me, Pro Se Defendant, Pro Se Counter Defendant Crystal

Cox.

Therefore every ruling of this court on a motion without conflict disclosure will be charged for

each and every act a in a criminal complaint, forthcoming.

Judge Gloria Navarro is alleged by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox to be

acting in criminal and civil conspiracy with Plaintiff / Counter Defendant Marc J. Randazza and

ALL Connected Co-Conspirators and Counter Defendants of District of Nevada Case

2:12-cv-02040-GMN-PAL and therefore this court has a duty to notify all applicable authorities,

bond carriers, insurance carriers, AND State and Federal Auditors of the liability of this allegation

in a Federal Court Proceeding.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox object to Plaintiff’s MOTION

FOR SUMMARY JUDGMENT.

Plaintiff Claims I have not disputed facts, when I, Pro Se Defendant / Pro Se Counter Plaintiff

Crystal L. Cox have disputed Plaintiff’s Allegations over and over to the absolute best of my

ability. Plaintiffs / Counter Defendants have not Disputed ONE Allegation I have Claimed against

them in my Counter Complaint, however.

Plaintiff has not made one valid point of law in which entitles them to a Summary Judgement,

instead Plaintiff has used this MOTION FOR SUMMARY JUDGMENT as further harassment,

intimidation, defamation to Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox, “genuinely” dispute ALL claims in

Plaintiff’s claims against me and have repeatedly.

Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has not had a “campaign” in bad faith to

harass Plaintiff. Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has fought back against

Plaintiff and Counter Defendants attack on her. This court should not grant summary judgement

to Plaintiff, as Plaintiff has simply used the courts in bad faith to ATTACK a blogger he does not

like, or approve of her blog content and to wipe out his competition in the search engines by

using the courts.

Plaintiff and Co-Conspirators have taunted me, harassed, me, defamed me, attacked me

constantly and the only way I have to fight back is to post my proof online. It is a violation of my

Freedom of Expression and my First Amendment Rights to stop the flow of information on my

blogs, to delete my blogs, redirect my domain names and harass me.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Plaintiff continues to LIES to this court and to publicly defame me in court documents, as I did

NOT extort Plaintiff. I asked Plaintiff for a Job, and he was upset at a Domain Name I owned and

then contacted the Plaintiff in Obsidian V. Cox and conspired to set me up for extortion in

revenge for me owning a domain name he did not approve of. If he thought he had a Trademark

then why not just take the name from me, Pro Se Defendant / Pro Se Counter Plaintiff Crystal

Cox or from Monica Foster when she owned it.

Plaintiff offered Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox and Monica Foster for

the domain name and we both turned him down.

There was no Cyber Extortion and if Plaintiff really believes this and has evidence of this then

Plaintiff should file a criminal complaint so that I, Pro Se Defendant / Pro Se Counter Plaintiff

Crystal Cox, am entitled to due process of law. Instead Plaintiff is abusing his power over the

courts and simply stating I am guilty of extortion with no proof, no evidence of Extortion.

I did not offer Reputation Services and then attack Plaintiff in the search engines to retaliate. I

asked for a job, he said no and then demanded I turn over domain names. I stood up for myself

and he conspired with others to ruin me and to make it look like I was guilty of the crime of

extortion.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, was not on trial for extortion, never

had due process of law for this accusation, never had a criminal investigation, yet Counter

Defendant / Plaintiff Marc Randazza and Co-Conspirators continue to publicly state that I am

guilty of extortion. Why not file criminal charges, and then if a court of law convicts me of

extortion, then publish Crystal Cox is an Extortionist. Defendant / Plaintiff Marc Randazza and

Co-Conspirators did not do this, they simply attacked me, painted me in false light and made me

look to be an extortionist when that is not true.

I have made a living from Real Estate and from Online Supplements, My Anti-Corruption Blogs

have been to give victims of corruption a voice. The search engine management offer in the

Obsidian V. Cox case was part of a Settlement Negotiation, a month after a legal threat, and a

week after a 10 Million Dollar Lawsuit was filed against me. There were approx. 10 Settlement

Offers in that case. Those emails were between two attorneys negotiating a settlement, I was

Pro Se and acting in my Pro Se Capacity, and this ONE email out of 5 was used out of context

to defame and harass, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, and to retaliate

against me, AFTER David Aman, Tonkon Torp, Opposing Counsel had already won a 2.5 Million

Dollar Judgement.

Counter Defendant / Plaintiff Marc Randazza saw those eMails, he had ALL my files, and he

negotiated with David Aman, Tonkon Torp on my behalf in the Obsidian Case. As per those he

told in the First Amendment Bar that he represented me and was negotiating a deal.

Counter Defendant / Plaintiff Marc Randazza acted with intentional harm against Pro Se

Defendant / Pro Se Counter Plaintiff Crystal Cox,, when he broadcast that I am an Extortionist

and continues to accuse me, using the courts to further harass and defame me and State that I

am guilty of a crime that I am NOT guilty of nor have been charged with, little own prosecuted for.

Counter Defendant / Plaintiff Marc Randazza does not have the legal or constitutional right to, in

retaliation, hate or whatever reason to simply accuse who ever he please of a crime and then

broadcast that accusation as fact, BEFORE an innocent victims, such as Pro Se Defendant /

Pro Se Counter Plaintiff Crystal Cox is permanently harmed and defamed.

Counter Defendant / Plaintiff Marc Randazza had my personal information, confidential details of

my life and my strategy, and Defendant / Plaintiff Marc Randazza knew that I had not been on

trial for extortion nor charged with extortion, he had seen ALL my files. Counter Defendant /

Plaintiff Marc Randazza had requested all these files as email records show, BEFORE he

negotiated with David S. Aman, Opposing Counsel in the Obsidian V. Cox case.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox am one woman. Counter Defendant /

Plaintiff Marc Randazza has a strong blog, several online sites that are very strong, and lots of

connections with other attorneys and big media. When he posted that I was an Extortionist, the

only way I had to post the facts, and to save my reputation was to start multiple blogs. The more

I started, the more he got deleted. 

This is not a “Google Bomb”, it is an internet marketing tactic to get my story found in the search engines. Instead of using co-conspirators as the Plaintiff does in this case and in Rakofsky V. the Internet, I am simply use my own sites and post in my own name. 

This is not a Google Bomb nor cybersquatting, it is online competition in the search engines, in which Plaintiff Marc Randazza used this court to simply wipe out all my work, and without any due process or First Amendment Adjudication.

Counter Defendant / Plaintiff Marc Randazza states that “"Defendants Crystal L. Cox (“Cox”) and

Eliot Bernstein (“Bernstein”) registered the Infringing Domain Names (as defined in ECF #1 at

6-7) in an attempt to extort Plaintiffs and in violation of the Anti-cybersquatting Consumer

Protection Act (the “ACPA”) (15 U.S.C. § 1125(d)), individual cyberpiracy protections (15 U.S.C.

§ 8131), and rights of publicity under the laws of the State of Nevada Plaintiffs, as well raised

common law claims of intrusion upon seclusion and publicity and civil conspiracy. Plaintiffs’

claims arise from Defendants’ registration and use of Plaintiffs’ personal names as Internet

domain names."

Plaintiff flat out lies to this court, as Plaintiff knows full well that Eliot Bernstein never registered

those domain names. Plaintiff deliberately lies in court documents to defame and harass

Defendants Crystal L. Cox and Defendant Eliot Bernstein. Counter Defendant / Plaintiff Marc

Randazza is very familiar with Obsidian V. Cox, and Plaintiff knows that there are documents

filed as to how and why Defendant Eliot Bernstein got those domain names. Yet, Counter

Defendant / Plaintiff Marc Randazza deliberately lies to this court in retaliation. Counter

Defendant / Plaintiff Marc Randazza represents clients who LITERALLY owe Eliot Bernstein

billions of dollars. This lawsuit naming iViewit Founder Eliot Bernstein is simply to attempt to

discredit, harass, defame and intimidate Eliot Bernstein and to remove blogs that expose the

iViewit Technology theft, with is the biggest technology crime in the world, EVER.

Counter Defendant / Plaintiff Marc Randazza knowingly lies about domain names being

registered to Extort him somehow, that has no TRUTH what so ever to it. Neither Defendant

EVER asked Marc Randazza for money and said they would post “bad faith” or anything at all if

he did not pay, there WAS not Extortion. Counter Defendant / Plaintiff Marc Randazza continues

to use court documents, Big Media, blogs and more to defame, taunt, harass, retaliate, bully and

paint in false light, Defendant / Counter Plaintiff Crystal L. Cox and Defendant Eliot Bernstein.

There is not VIOLATION of the Anti-cybersquatting Consumer Protection Act (the “ACPA”) (15

U.S.C. § 1125(d)), there was NO bad Faith. There was and is not rights of publicity under the

laws of the State of Nevada Plaintiffs and even if the Nevada courts found this to be so, then the

blogs could be banned ONLY In Nevada.

Counter Defendant / Plaintiff Marc Randazza is an expert in this industry, Plaintiff knows that he

is lying to this court deliberately to defame, attack and paint Defendants in false light.

Counter Defendant / Plaintiff Marc Randazza is NOT a household name and does not have an

automatic, exclusive right over the the name “Randazza” or “Marc Randazza” and Plaintiff Does

not have a Right to exclude ONE investigative Blogger from reporting on, publishing, using the

name Randazza” or “Marc Randazza”.

Counter Defendant / Plaintiff Marc Randazza, as in the Domain Name

GlenBeckRapedAndMurderedAYoungGirlIN1990.com and other Domain Name Cases, has

himself represented the domain name owner and argued in favor of the constitutional and lawful

right of the domain owner to own that domain name. 

Yet, in a complete opposite, hypocritical defense in this case, Counter Defendant / Plaintiff Marc Randazza claims that CCC has no right to own such a name with the name Randazza in it, as that name is his and his alone to use. 

As if to say no reporter, no news, no blog, no media can utter the word “Randazza” or “Marc Randazza” without his exclusive permission and that simply is not true.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza Says "Specifically, Cox registered Plaintiff

Randazza’s personal name, under which he has conducted business at his well-known law firm,

in multiple domain names and attempted to extort Plaintiff, as is her demonstrated modus

operandi (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by

Blogger, attached as Exhibit B) by offering her “reputation management services” in order to “fix”

Randazza’s business reputation that she, herself, harmed."

Counter Defendant / Plaintiff Marc Randazza disturbingly continues to involve his young

daughter, as if to get sympathy from the courts and public at large. Counter Defendant / Plaintiff

Marc Randazza knows full well that CCC never had a blog regarding his daughter, never posted

ONE WORD regarding her, and yet Counter Defendant / Plaintiff Marc Randazza used his own

daughter to paint ccc in false light and defame me, make me look like a monster to the public

and use her to STEAL blogs he has no right to. 

Counter Defendant / Plaintiff Marc Randazza gave picture of his young daughter to big media and flat out lied that I had blogged about her when I did not EVER publish anything in regard to his daughter.

Counter Defendant / Plaintiff Marc Randazza even added his daughter to this lawsuit as a

Plaintiff, that is SICK. I, Defendant / Counter Plaintiff Crystal L. Cox have not mentioned her

name and I have not counter sued Plaintiff’s Daughter and Wife, deliberately, as neither had

anything to do with Counter Defendant / Plaintiff Marc Randazza’s hate, rage and retaliation

tactics against Defendant / Counter Plaintiff Crystal L. Cox . Counter Defendant / Plaintiff Marc

Randazza continues to use court dockets to lie about and defame Defendant / Counter Plaintiff

Crystal L. Cox. And he continues to use his young child as a weapon in the courts, SICK.

Counter Defendant / Plaintiff Marc Randazza claims that owning a person’s name in a domain

name is fine if it’s his client, yet wages a retaliation legal war against Defendant / Counter Plaintiff

Crystal L. Cox for owning such a Name. Counter Defendant / Plaintiff Marc Randazza LIES to

this court in AGAIN stating that I tried to extort his well known law firm. First of all he is NOT well

known, not a common household name. Secondly, I, Defendant / Counter Plaintiff Crystal L.

Cox, NEVER ever attempted to use a domain name to Extort Marc Randazza, as email records

show I told him I would not SELL the domain name at ANY price and in FACT gave it to

Investigative Blogger Monica Foster to help expose human trafficking, bad things happening to

kids in porn, prostitution rings, whistleblower retaliation and all that she exposes on

PornNewsToday.com.

Monica Foster aKa Alexandria Melody, was threatened by Marc Randazza and Co-Conspirators /

Counter Defendants, she was in fear of her life and therefore I told her I would take the domain

name back. Shortly after that, Counter Defendant / Plaintiff Marc Randazza filed a fraudulent

WIPO Claim, and then filed this Lawsuit in retaliation.

Counter Defendant / Plaintiff Marc Randazza claims this “by offering her “reputation

management services” in order to “fix” Randazza’s business reputation that she, herself,

harmed.” This is FALSE. I never EVER offered to “FIX” Randazza’s business reputation, email

records show that I, Defendant / Counter Plaintiff Crystal L. Cox, never said that. Counter

Defendant / Plaintiff Marc Randazza continues to use his power in the courts to defame and flat

out lies about Cox.

I, Defendant / Counter Plaintiff Crystal L. Cox, never wrote ONE word about Marc Randazza

when I sent the email asking for a Job. I posted blogs regarding Counter Defendant / Plaintiff

Marc Randazza AFTER he contacted the Plaintiff and the Judge in my Obsidian V. Cox case

and conspired to set me up for a Crime, I started the blogs AFTER that to Defend Myself from

his RAGE and retaliation.

Counter Defendant / Plaintiff Marc Randazza should not be able to simply LIE to a court and

because he is an attorney, it is taken as fact. Counter Defendant / Plaintiff Marc Randazza

should not be able to submit blogs to the courts of his co-conspirators and have those blog

posts used as evidence to harm his intended target, defendant.

Counter Defendant / Plaintiff Marc Randazza is flat out lying about Defendant / Counter Plaintiff

Crystal L. Cox Extorting him. Email records and communications PROVE there was no

Extortion. YET, Counter Defendant / Plaintiff Marc Randazza continues to use motions in the

courts to attack, defame, taunt, harass, bully and paint Defendant / Counter Plaintiff Crystal L.

Cox in false light INTENTIONALLY.

Counter Defendant / Plaintiff Marc Randazza continues to use Kashmir Hill’s post about CC to

defame CC.” (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by

Blogger, attached as Exhibit B) “

Kashmir Hill of Forbes is from AboveTheLaw.com, and Counter Defendant / Plaintiff Marc

Randazza is their attorney. Kashmir Hill of Forbes is a co-conspirator and that article is

DEFAMATION with actual malice. Kashmir Hill of Forbes is liable for the defamation in that post.

Counter Defendant / Plaintiff Marc Randazza knows the information is false, yet uses Kashmir

Hill’s post as some sort of evidence that Defendant / Counter Plaintiff Crystal L. Cox did

something unlawful or prove that Defendant / Counter Plaintiff Crystal L. Cox extorted him, or did

something that would warrant deletion of massive online content, stealing domain names,

removing blogs, redirecting servers and constantly attacking and harassing Defendant / Counter

Plaintiff Crystal L. Cox .

Counter Defendant / Plaintiff Marc Randazza told me Defendant / Counter Plaintiff Crystal L.

Cox, that if I did not GIVE him the Domain Name he wanted, he would make me an ENEMY. Now

that’s Extortion and he sure did follow through. Counter Defendant / Plaintiff Marc Randazza has

RUINED my life, with ACTUAL MALICE, actual knowing of the Facts of the Matter.

Counter Defendant / Plaintiff Marc Randazza Constantly Accuses Defendant / Counter Plaintiff

Crystal L. Cox of being involved in a conspiracy that does not exist, meanwhile he daily

conspires to harm Defendant / Counter Plaintiff Crystal L. Cox, retaliate, defame, intimidate and

ruin Defendant / Counter Plaintiff Crystal L. Cox Facts, Documented Facts and Evidence SHOULD be at Issue in this Case. Instead Plaintiff simply supplies this court with blog posts and words of co-conspirators, in which are NOT documented FACT.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza blogs about Defendant / Counter Plaintiff Crystal L.

Cox and constantly discusses his opinion of me on twitter, facebook, and encourages others to

publish online about me, make videos lying about me and defaming me.

Plaintiff Stating this “Another District Judge, Marco Hernandez of the District of Oregon,

euphemistically described Cox’s scheme as repairing the damage she had caused for a

“tasteful” fee. Obsidian Finance Group LLC v. Cox, 2012 WL 1065484 (D. Ore. 2012).” Is

defamatory. I was not on trial for extortion, this was in regard to a settlement negotiation

communication, and has nothing to do with the material facts of Randazza V. Cox. This is

placed in a Motion for a Summary Judgement, with Malice, to further paint Counter Plaintiff /

Defendant Crystal Cox in false light, defame her, harass and intimidate her.

Counter Plaintiff / Defendant Crystal Cox posted remarks and poked fun at what Plaintiff Marc

Randazza had said about his own wife, in a drunken tryst post on his own blog. Counter Plaintiff

/ Defendant Crystal Cox never EVER posted anything online regarding Marc Randazza’s child,

he himself did that.

Again Counter Defendant / Plaintiff Marc Randazza uses the court docket, abuses his power,

and defames, harasses Counter Plaintiff / Defendant Crystal Cox.

Counter Defendant / Plaintiff Marc Randazza Says, “Plaintiffs are not the only victims of the Cox

scheme. Ms. Cox has targeted several dozen other victims, registering their full names as

domain names and falsely accusing them of any manner of wrongdoings.” This is false and

defamatory and has nothing to do with the material facts of Randazza V. Cox. I am a reporter,

an investigative blogger, what Plaintiff refers to as victims, are subjects of my stories, and yes, of

course I get the best keyword rich domain name I can to get strong in the search engines, that is

taught in EVERY book and class regarding SEO and Internet Marketing. I have never asked for

MONEY to remove any information, no have I ever written a story with the intention to ask for

money to remove it. Nor has I ever stated that if you don’t pay me, I will post bad stuff. That is

simply further defamatory fraud on the courts. I am an investigative blogger exposing corruption

in New Media, with the best possible marketing techniques I know of. I have not extorted anyone

nor received payment from anyone to remove information I have written.

Counter Defendant / Plaintiff Marc Randazza is discriminating against Citizen Journalists and

Bloggers not affiliated with Big Media. The New York Times, Forbes and other Big Media posts

stories daily on companies, individuals and they are not called victims. Often times the The New

York Times, Forbes and other Big Media are asked to remove information or even sued for

inaccurate information, this is not deemed Extortion. Why are my Investigative Blogs called

Extortion? 

The reason is because those I expose for alleged corruption and the tips I get on them

in which I post, they don’t like this information out there, so they claim me an Extortionist, when I

have Extorted NO ONE, and received no money for such, nor been under investigation for the

crime of Extortion, yet Counter Defendant / Plaintiff Marc Randazza and Counter Defendant

Ronald Green continue to use this court docket to defame me and flat out state as fact that I

have committed Extortion when I have not had due process, nor a criminal investigation or trial

regarding this allegation. Yet Counter Defendant / Plaintiff Marc Randazza State it as fact.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza State “Just as she has done with Plaintiff Marc

Randazza, Cox then offers her “reputation services” to the people whose names she has

registered. See Obsidian Finance Group, LLC v. Cox, 2012 WL 1065484 (D. Ore 2012)

(“[D]efendant offered ‘PR,’ ‘search engine management,’ and online reputation repair services to

Obsidian Finance, for a price of $2,500 per month ... 

The suggestion was that defendant offered to repair the very damage she caused for a small but tasteful monthly fee”);” I object to this statement, Obsidian V. Cox was a CIVIL trial regarding defamation, it had NOTHING to do with Extortion, which would be a Criminal Trial. This $2500, was one sentence pulled from 5 emails between Pro Se Defendant Crystal Cox, acting in her Pro Se Capacity and David S. Aman, Tonkon Torp Opposing Counsel. These 5 emails were a Settlement Negotiation in response to a Cease and Desist Legal Threat and sent after a 10 Million Dollar Defamation Lawsuit had been filed by David S. Aman, Tonkon Torp on behalf of Federal Bankruptcy Trustee Kevin Padrick and his Company Obsidian Finance Group.

This one sentence, has been used out of context to retaliate on a Reporter exposing the clients

of Counter Defendant / Plaintiff Marc Randazza and Counter Defendant David. S. Aman. The

facts of the case are all of record, and Extortion was not a material fact. Also I, Counter Plaintiff /

Defendant Crystal Cox object to speculation stating that “The suggestion was that defendant

offered to repair the very damage she caused for a small but tasteful monthly fee” this is false, I

only offered any negotiation, AFTER I had been threatened with a 10 Million Dollar Legal Action.

This was a negotiation settlement communication to try and STOP the next several years of my

life from being in legal action. The Plaintiff made 8 Settlement Offers to me, and they are not

deemed Extortion yet the Plaintiff offered I pay them $5000 every time I mention their name and

that I blame my whistleblower and her father for my posts, which is illegal. This is all a matter of

record.

Regarding this, “Randazza’s name functions as a trademark. Randazza is an individual, an

attorney, a legal author, and a resident of Clark County, Nevada. (ECF #1 ¶23;Randazza Decl. ¶

1). Plaintiff is the owner and managing partner of RLG, with offices located in Nevada, Florida,

and Arizona. (ECF #1 ¶ 23; Id.). Since 2008, RLG has done business using Marc Randazza’s

personal name as a source identifier for its services. (ECF #1 ¶ 23).”

Counter Defendant / Plaintiff Marc Randazza has NO Trademark or exclusive right to use the

word “Randazza” or Marc Randazza. “Randazza’s name” does NOT function as a Trademark

anymore then I can say no one can use the name Crystal Cox in the reporting of my case or

their opinion of my case. It is not a Trademark violation to report on Marc Randazza.

Counter Defendant / Plaintiff Marc Randazza says, “Cox registered the Infringing Domain Names

with the intent to capitalize on the use of Plaintiff Randazza’s personal name, extort money from

Plaintiffs, and engage witness intimidation. (Exhibit H; Blog post asking for $5 million for sale of

<marcrandazza.me>, attached as Exhibit M; ECF #12-4 video from Cox admitting witness

intimidation, a relevant transcript of which is attached as Exhibit N). In fact, the profit in Ms. Cox’s

endeavor flows directly from her extortion scheme.”

I Counter Plaintiff / Defendant Crystal Cox, Object to that statement. I joked about $5 Million just

after I bought MarcRandazza.me, I titled the post here Kittty Kitty, it was a Parody. I had just

bought it for 10 Dollars, there was no blog on it or value in it. Counter Defendant / Plaintiff Marc

Randazza is trying to make it look like I offered the name for that real price, and that is not True.

However, people buy and sell domain names every day, and can buy and sell LEGALLY for

whatever price they want. Even if their is a possible Trademark. Godaddy has thousands of

domain names on auction sites that have other peoples names or possible trademark names in

them, they sell them all the time. It is not illegal nor has it cause and harm to the Plaintiff.

No Domain Names were EVER bought to tamper with a witness, they were purchased to

report on a story, period.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I Counter Plaintiff / Defendant Crystal Cox, have never had an Extortion scheme nor have I ever

taken in ANY money they could possible be mistook as Extortion. If Counter Defendant / Plaintiff

Marc Randazza really believes this and has convinced this court I am guilty of Extortion then why

not file Criminal Charges, give me an Criminal Attorney and due process under law, BEFORE

publishing widely that I, Counter Plaintiff / Defendant Crystal Cox and Eliot Bernstein are Guilt of

Extortion, as if already convicted. And then Using this Court to further that false defamatory

statement as fact, when it is not fact.

“On December 10, 2011, Crystal Cox registered <marcrandazza.com> in the publicly

available Whois information. (See Exhibit K). On January 16, 2012, Cox sent an email to Plaintiff

stating that she had purchased his personal name as a domain name. (See Exhibit H). She then

asked Plaintiff to purchase her “reputation management services” in an attempt to extort money

from Plaintiff. (See Exhibit H). This is her modus operandi. See Obsidian Finance Group, LLC v.

Cox, 2012 WL 1065484 (D. Ore)

This statement is not true. The New York Times was already defaming me, and there was no

way I would have sent anything that would have even remotely have suggested extortion. I asked

Marc Randazza for a Job, plain and simply. I had the dotcom at issue when he was my attorney,

to report on my own story. He said he did not want to hire me then he proceeded to act and

defame me so I used the name to report on him, expose him and warn the public at large, as a

Public Service.

Counter Defendant / Plaintiff Marc Randazza offered to buy the domain name from me and from

Monica Foster, we both said no. I told him I would not sell for any price, this is NOT extortion.

Plaint then launched into a year long and continued retaliation. Counter Defendant / Plaintiff Marc

Randazza also asked me what I wanted from him, email records prove that. Plaintiff said that I

made my point, if I was an extortionist I would have demanded money, I rejected his offers,

Plaintiff Retaliated over and over.

Counter Defendant / Plaintiff Marc Randazza says, “Defendant Cox will not stop until she is

satisfied that she has successfully intimidated Plaintiff or until he pays the requested ransom.”.

I, Counter Plaintiff / Defendant Crystal Cox, OBJECT to this, I never offered an ransom request,

this is fraud on the courts. Also why would I, over any other reporter, have to be singled out to

stop reporting on, having an opinion on, or making fun of Marc Randazza?

This violated my constitutional and civil rights.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Plaintiff / Defendant Crystal Cox NEVER had “bad faith” intend. My Intent is to report on

and expose corruption in the United States Judicial System. I have been dedicated to this for

over 7 years, at great personal cost. I have been fighting and exposing corruption and Counter

Defendant / Plaintiff Marc Randazza has painted me to look like the criminal, when the truth is I

am reporting on, exposing the crimes.

Regardless of the Defamatory Lies in publications by Counter Defendant / Plaintiff Marc

Randazza and Counter Defendants, Investigative Blogger Counter Plaintiff / Defendant Crystal’s

purpose was ALWAYS, SOLELY to expose corruption, parody corruption, provide “speech

critical” of those I alleged participated in these corrupt activities and to try and make the world a

better place doing what I could to help give justice to victims of corruption.

Counter Defendant / Plaintiff Marc Randazza has no trademark on the name Marc Randazza

and has no right to MarcRandazza.com or any of the Domain Names he stole from Counter

Plaintiff / Defendant Crystal Cox Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as his allegations are all FALSE and Defamatory.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Marco Randazza is the Plaintiffs “Handle”, “Persona” Online, NOT Marc Randazza.

It is unlawful and unconstitutional to ban an investigative blogger, a journalist from writing a last

name on her online media. Marc Randazza, is not the only Marc Randazza in the world, nor

does he have an exclusive right on the use of “Randazza”

There are many people with that last name. Plaintiff has no right to exclude ANY blogger,

journalist, to not use his name or last name. That would be like me saying no one can utter can’t

the last name Cox on anything ever. It is ridiculous, and unconstitutional, as well as selective

prosecution.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Plaintiff Marc Randazza has no Trademark on the name “Marc Randazza”.

Plaintiff Marc Randazza uses the Trade Name, Marco Randazza as his Twitter and

YouTube User Name, as well as his username on his own blog, and many other forums,

blogs, news sites and social networks, NOT Marc but MARCO, .

Plaintiff Marc Randazza uses the Trade Name, Marco Randazza on Best Tweets, in Penn.

News Articles, on Flickr, in Gloucester Times, on multiple YouTube accounts, on the Legal

Satyricon as his username on his own blog, on the DNF forum, on yFrog, and many other

sites and sources.

Plaintiff Marc Randazza had / has no ™ posted at his blog regarding the name Marc

Randazza as being trademarked and Plaintiff Attorney Marc Randazza had no Trademark

when Defendant Crystal L. Cox purchased MarcRandazza.com to use as PR for Defendant

Crystal Cox’s highly public First Amendment Case, that will set a precendence that is a

“Game Changer” for ALL New Media, Bloggers, and Citizen Journalist.

Defendant Crystal L. Cox “actions” as Plaintiff calls it, were a “legitimate purpose” and that

purpose was originally to provide PR for her own court case of which Plaintiff Marc

Randazza was, at that time to be her attorney and acted on her behalf in negotiations with

Opposing Counsel, David S. Aman of Tonkon Torp Law Firm. Obsidian Finance Group vs.

Crystal Cox is the biggest Free Speech case any one, independent blogger has ever seen,

Obsidian V. Cox. Which is the only case of it’s kind to distinguish the rights of bloggers vs.

the rights of traditional media. Obsidian V. Cox will hopefully end the “Monopoly on Free

Speech” in which according to Plaintiff Marc Randazza to Defendant Crystal Cox that “Big

Media” told him, they make more money with a Monopoly on Free Speech.

Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as

his allegations are all FALSE and Defamatory.

There never was an Extortion Scheme. Counter Defendant / Plaintiff Marc Randazza has simply

used his money, power and influence to ruin the life of and bankrupt a female blogger who he did

not agree with.

I, Counter Plaintiff / Defendant Crystal Cox OBJECT to Plaintiff’s Motion for Summary

Judgement in it’s Entirety.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Source and Full Court Filing

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.80.0.pdf

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.

MARC RANDAZZA used Nevada SLAPP Laws to suppress my speech and to deny my constitutional rights. He used Nevada's Anti-Slapp Laws to try and STOP a malpractice suit and a defamation suit whereby I, Crystal Cox, have CLEAR AND CONVINCING prove he defamed me.

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

Marc Randazza Used Nevada Laws to try and Get Trademark Law to STOP someone from griping about him. He used Nevada Law to steal my intellectual property and STEAL my First Amendment Rights.

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

Nevada Bar Complaint I filed against Marc Randazza - Randazza Legal Group

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.

Exhibit 22 shows the Federal Law they were going for, to sue me in civil court and set me up for a crime.

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.

Exhibit 17
https://docs.google.com/file/d/0Bzn2NurXrSkiY00tM3lidGw0M2M/edit

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.

Exhibit 17 CLEARLY shows that counter defendant Marc Randazza did not have an issue with Cox asking him for a Job.

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.