Wednesday, November 18, 2015

Who is Jamie Profit? Why does the State of Nevada allow Randazza Legal Group Lawyers to do whatever they wish no matter who they harm?

I have reported Ron Green and the rest of the Gang at Randazza Legal Group many times, yet the Nevada Bar and the Nevada Courts still are protecting them, why?

Though the authorities, judges and other attorneys know, Ronald D. Green has been able to cause serious harm and massive stress to the lives of countless people, mostly those in or having been in Porn.  Ron Green, along with J. Malcom DeVoy, Sean Tompkins and Marc Randazza have been protected by courts and Judges in many state and why?

 They harass people to the point of breaking, settling in cases and sometimes suicide. And all this to ensure that their clients needs are met, they make money, or to fulfill some sick fetish.

Below is a Statement from Monica Foster aKa Alexandra Mayers in her Nevada Case where Marc Randazza's wife Jennifer Brochey Randazza sued her. (Ya know the one where Marc Randazza, in his bankruptcy documents stated as a potential asset for HIM.)

Also remember in the Randazza v. Cox and Bernstein where Jennifer Randazza and Marc Randazza sued me, Crystal Cox and Eliot Bernstein to shut us up, I asked the Nevada Courts for a protective order for me and for those threatened by Ronald Green, Sean Tompkins, J. Malcom DeVoy, Ken White and Marc Randazza such as Monica Foster Alexandra Mayers and Desi Foxx aKa Diana Grandmason. I gave the Nevada Courts proof and they rejected my request, took no action and protected these rogue and unethical attorneys.

Protective Order Request I filed in Randazza v. Cox
http://ia600304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.47.0.pdf

1 of 13 Exhibits of Proof I gave the Nevada Courts and they Ignored, Docket Entry 47
http://ia600304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.47.5.pdf

Docket Entry 67 named NOTICE Emergency Notice to Court of Violent Actions of Counter Defendant, again I let the courts know people were in danger of these same men.
Below is one such threat from Sean Tompkins, in connection to Ronald Green
http://ia600304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.87.7.pdf

The Courts did Nothing. Now we have this filed with the Nevada Courts on November 18th, 2015. When will the courts take these thugs serious.

"STATEMENT

I, Defendant Alexandra Melody Mayers officially state to the court that plaintiff Jennifer
Brochey Randazza’s attorney Ronald D. Green (Nevada bar # 7360) has habitually
stalked, harassed, bullied, intimidated, defamed, “trolled”, antagonized & libeled me on
social media since the year of 2012 (2 years PRIOR to this frivolous and fraudulent
lawsuit being filed).

In the following memorandum of points and authorities is evidence of attorney Ronald D.
Green’s aggressive and unethical actions towards me - which all point to plaintiff
Jennifer Brochey Randazza’s lawsuit being no more than an abuse of the Nevada State
court system to harass, extort and sextraffick me back into the pornographic industry
system via “legal” means and “legal” debt bondage (via a monetary judgement).

MEMORANDUM OF POINTS AND AUTHORITIES

1. The photograph on Randazza.com of attorney Ronald D. Green (Nevada state bar
number 7360) and the photograph on the Twitter.com social media account
@JamieProfit are the exact same person (exhibit A).

2. Beginning in the year 2012 (exhibit B) Ronald D. Green aka “JamieProfit” began
posting UNSOLICITED rude, threatening, harassing, vulgar & defamatory tweets
DIRECTLY to my twitter account “MonicaFoster”.  Though I blocked him, he
has continued up into the year 2015.

3. Beginning in the year 2012 (exhibit C) Ronald D. Green has routinely
communicated directly with the social media (online) and offline stalkers &
bullies who have routinely threatened me (individuals which I have named in my
various case A-14-699072-C dept 32 replies, motions, oppositions and statements
– Ari Scott Bass aka Michael Whiteacre, Sean Matthew Tompkins aka
TRPWL, Tristan Stadtmuller & Marc Randazza).

4. Ronald D. Green aka “JamieProfit” appears to working to establish himself as an
organized crime attached pornographic industry journalist. He has written several
comments on Sean Matthew Tompkins aka TRPWL’s revenge porn and
defamatory website TheRealPornWikiLeaks.com (which serves the purpose of
stalking and bullying various targets – including myself). Sean Matthew
Tompkins is the individual who purchased my father’s full name Ivan Mayers
(exhibit D) as a domain name to point directly to a gay porn section of
TheRealPornWikiLeaks.com. Ronald D. Green has conducted a pornographic
industry interview with the well known pornographer who has gone on record as
being insensitive in regards to racism against Blacks / African-Americans (such as
myself) in the pornographic industry known as “Mike Quasar”.

As of current, Ronald D. Green aka Jamie Profit follows hundreds of pornographic industry
professionals via his twitter account @JamieProfit.

DATED this 18th day of November, 2015.
Pursuant to NRS 53.045, I declare under penalty of
perjury that the foregoing is true and correct.

Alexandra Mayers
/s/ Alexandra Mayers
Defendant, In Proper Person"

Source
https://drive.google.com/file/d/0Bzn2NurXrSkiSkFWcEFldEJxV3M/view?usp=sharing

Exhibit Below

Ronald D. Green aka JamieProfit on Twitter 




Marc Randazza Bankruptcy Docket
http://ia601505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.docket.html

Randazza v. Cox and Bernstein Docket
http://ia600304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

Saturday, July 11, 2015

Liberty Media Holdings Wins Dispute Against Former Attorney Marc Randazza

Arbitrator cites Randazza’s “clear and serious breaches of ±duciary duty” in judgment against him (Full Interim Award can be viewed at http://www.LibertyVsRandazza.com)
Las Vegas, NV - A two and a half year arbitration dispute between Excelsior Media and Liberty Media Holdings - the parent company of the “Corbin Fisher” brand - and their former in-house general counsel, Marc Randazza, resulted in an award in favor of the companies and against Randazza on June 3, 2015, with the arbitrator determining Randazza had violated his fiduciary duties owed to them as their attorney and employee, committed numerous ethical violations, breached his employment contract, and caused them hundreds of thousands of dollars in damages over the course of his employment and on through the binding-arbitration proceedings.

The dispute between Randazza and his former employer and client began on August 13, 2012, when company executives discovered Randazza had attempted to secure for himself a $75,000 bribe from an opposing party in copyright infringement litigation.

According to the arbitration’s award, “… Mr. Randazza had been involved in and
successfully concluded negotiations for a bribe in the amount of $75,000, to be paid to Mr. Randazza by the other side in connection with resolution of high-importance litigation…”.

Randazza’s reaction to the discovery of his attempts to secure this bribe was to wipe his company-issued laptop of all data, refuse to hand over the company’s legal files, seize approximately $550,000 worth of the company monies being held in his client trust account, and resign his employment from the company.

Randazza followed up these acts with an arbitration demand, attempting to sue the companies for severance pay and millions in damages over what the arbitrator would ultimately determine were “… disputed, disproved, and unproved allegations…” of discriminatory conduct and sexual harassment against him.

Seeing through Randazza’s claims of discrimination and sexual harassment, the arbitrator - a former federal magistrate judge - ruled “… Mr. Randazza made highly-charged, sexually based ‘core allegations’… which were in the main disproved or not proved.

That failure of proof undermined and impaired Mr. Randazza’s credibility concerning all of his testimony and his claims related to his contentions.”

From the outset, the companies contended Randazza’s claims of discrimination and harassment were entirely fabricated, with Randazza’s goal being to overwhelm his former employer and clients with legal expenses and use the outrageous allegations to intimidate them into capitulation and a settlement.

The arbitrator would eventually agree, in full, with the companies, stating in the award, “The evidence established at hearing was that Mr. Randazza intended that his allegations would induce the company to authorize a settlement ±nancially favorable to Mr. Randazza.”

The arbitrator continued, “Mr. Randazza’s miscalculation… led to an ultimately successful counterattack by E/L, via counterclaims in this arbitration, centering on ethical and legal challenges to Mr. Randazza’s conduct as the company’s general counsel and litigation counsel during his employment by E/L.”

Once the arbitration was underway, the companies went on to discover numerous other instances of misconduct, ethically-prohibited actions, and violations of his employment agreement by Randazza, giving rise to the counterclaims brought against him.

The companies’ counterclaims against Randazza involved repeatedly engaging in attempts to secure bribes from multiple opposing parties in litigation, the illegal use of a hacker to access [prior adverse party] Oron’s computer data, engaging in a host of prohibited conflicts of interest (including representing Liberty’s competitors and tube sites violating Liberty’s copyrights), concealing his representation of adverse parties from the company, building up his personal legal practice in violation of his employment agreement, spoliation of evidence to cover up his ethical violations (including erasing data on company-owned laptops and seizing a company-owned iPhone), and taking
control of client funds in his trust account.

The arbitrator ruled in favor of the companies on all its counterclaims, determining Randazza had indeed engaged in these egregious acts and, in doing so, caused considerable harm to his former employer and client.

The companies’ expert witness in the case, the past Chairman of the Nevada State Bar Committee on Ethics and Professional Responsibility, testi±ed in the arbitration that Randazza’s use of a hacker to illegally access Oron’s privileged e-mails with their attorneys and other con±dential information was one of Randazza’s most glaring ethical
violations.
The expert witness would also provide substantial testimony regarding the inappropriate, unethical, and prohibited attempts by Randazza to secure bribes for himself and his engagement in numerous con²icts of interest while representing and being employed by the company.

During the course of his full-time, salaried employment with the company from June 2009 through August 2012, Randazza took on numerous outside clients and built up his private practice, in violation of his employment agreement with the company.

In his ruling, the arbitrator determined Randazza’s work for outside clients was
“significantly beyond the contractually-permitted scope under his employment agreement”, further specifically pointing out such work was “undisclosed (and thus unconsented-to)” and many of these clients’ “interests were actually and
potentially adverse to E/L’s interests”.

The companies argued, and the arbitrator ruled, “The extent of Mr. Randazza’s
contractual material breaches made them also breaches of Fduciary duty”.
Included among these con±icts of interest, all of which the company argued and the arbitrator agreed Randazza had failed to disclose and had attempted to conceal, was Randazza’s representation of XVideos/XNXX, a tube site on which Liberty’s copyrighted material was regularly being discovered.

Ironically, while a full-time employee of the company in 2009, Randazza had spent signiFcant time researching XVideos/XNXX’s corporate structure and ownership as the company was considering Fling suit against them for copyright infringement.

Unbeknownst to his employer and client, Randazza would abandon any efforts at
representing them against XVideos/XNXX, and instead would become XVideos/XNXX’s attorney in exchange for a 5-Fgure retainer fee.

Over the course of nearly 3 years, when informed by his fellow coworkers of infringements of Liberty’s copyrights being discovered on XVideos/XNXX properties, Randazza would direct inquiries, claim the tube site(s) was insulated from litigation, and that Corbin Fisher material being discovered on the tube site(s) was even “fair use” - while not disclosing he’d taken the tube site(s) on as his own clients mere months after becoming a full-time employee.

During the arbitration, Randazza admitted that when company executives decided he should look at Fling suit against XVideos/XNXX for copyright infringement, he ended up disclosing their plans to XVideos/XNXX and tipping them off that a suit was being considered.

The arbitrator had considerable amounts of evidence upon which to base his findings, including material recovered by a forensic examiner hired by the company to retrieve data from the company-owned laptop Randazza wiped and the company-owned iPhone he was issued, tens of thousands of e-mails, text-message transcripts, and other documents discovered and presented through the course of the arbitration.

The arbitration proceedings also included video-taped and transcribed depositions, and 5 consecutive full days of in-person hearings.

The arbitrator would reference much of the evidence, as well as Randazza’s own questionable conduct during the arbitration, in his rulings against him.

Stating Randazza’s failure of proof of his allegations against the companies “undermined and impaired Mr. Randazza’s credibility concerning all of his testimony and his claims and related contentions”, the arbitrator went on to reference con±icting statements and testimony Randazza made in the arbitration, as well as in statements to a state bar in response to a complaint the companies had Fled against him, and in sworn statements to Nevada’s Equal Opportunity Employment Commission.

After the June 3, 2015 ruling by the arbitrator, at least one state bar has reopened an investigation in to Randazza’s conduct, with disciplinary action being a possible outcome.

Due to the nature and extent of Randazza’s breaches of Fduciary duty against his former employer and client, the arbitrator awarded considerable damages to the companies.

Ruling they were entitled to damages for spoliation and conversion (regarding the improper seizure by Randazza of client funds held in his attorney trust account and destruction of evidence on company-owned computers); the companies were entitled to recover damages “at least in the amount of $275,000” resulting from Randazza’s improper conduct during litigation against Oron (including Randazza’s attempts to solicit, arrange, and secure personal bribes from them and his use of a hacker against them without his client’s knowledge or authorization); Randazza was unjustly enriched by pursuing and acquiring monies for and to himself from multiple 3rd parties without his employer’s knowledge when he was supposed to be working on their behalf; the companies are entitled to disgorgement for the considerable amount of time Randazza was employed by them and receiving salary and bonuses, while actually performing work for other clients; the arbitrator also ruled Randazza had to promptly release all of the companies’ funds being improperly held in Randazza’s client trust account.

The arbitrator further ordered the prompt initiation of an audit of Randazza’s trust accounts, and the return of a company laptop Randazza continued to retain.

As of July 8th, 2015, Randazza had still failed to meet most all of the conditions of the arbitrator’s ruling.

The full Interim Award can be viewed at http://www.LibertyVsRandazza.com.

Inquiries may be directed to press@libertymediaholdings.com

Excelsior Media and Liberty Media Holdings are involved in the production, ownership, and distribution of adult content primarily under the “Corbin Fisher” brand. Marc Randazza was the salaried, in-house General Counsel for the companies from June 2009 to August 2012.

Source

Source
https://docs.google.com/document/d/1F-Z_0HgvfCkZETW4sPU9mdo7IRgLcgPXQhdrTAp0UOM/pub

Marc Randazza of Randazza Legal Group accepts a BRIBE? Yes Folks Marc Randazza Really does negotiate with the Opposition and AGAINST his clients best interest. Just As in Randazza v. Cox

"Mr. Randazza had been involved in and successfully concluded negotiations for a bribe in the amount of $75,000, to be paid to Mr. Randazza by the other side in connection with resolution of high-importance litigation, commonly referred to as the "Oron litigation," which had been initiated and pursued on behalf of E/L by Mr. Randazza, as E/L's counsel of record."

Source
http://fightcopyrighttrolls.com/2015/07/09/marc-randazza-must-pay-600k-for-clear-and-serious-breaches-of-fiduciary-duty-against-his-former-client/comment-page-1/

AND

https://drive.google.com/file/d/0Bzn2NurXrSkiMV9xcl9qeVdpSUU/view

Also Check Out
https://twitter.com/RandazzaExposed

Marc Randazza has a clear pattern of abuse and violations against his clients. Marc Randazza of Randazza Legal Group has a history of unethical behavior, breach of fiduciary duties and violations of his clients rights; and NOT just Blogger Crystal Cox.

Marc Randazza and Randazza Legal Group SHOULD have RICO Claims against them. They have a clear pattern of client abuse, breach of fiduciary duties and violating their clients rights.

"
Marc Randazza must pay $600K+ for “clear and serious breaches of fiduciary duty” against his former client.

Today I was tipped about an interim arbitration award of more than $600,000 against attorney Mark John Randazza of Las Vegas. This amount was awarded to his former employer, a gay pornography studio Corbin Fisher/Liberty Media, in a civil dispute surrounding Randazza’s August 2012 scandalous departure from this company, where he was employed as an in-house general counsel for three years.

Marc Randazza

The June 3, 2015 judgment was written by a former magistrate judge and currently an experienced and respected arbitrator Stephen E. Haberfeld.

The arbitrator determined that Randazza had violated his fiduciary duties owed to the studio as its attorney and employee, committed numerous ethical violations, breached his employment contract, and caused it hundreds of thousands of dollars in damages over the course of his employment.

Those violations include an attempt to secure for himself a $75,000 bribe from an opposing party in a copyright infringement litigation (Liberty Media v. Oron), spoliation of evidence, representing potentially adversary clients (tube sites that infringe upon Liberty Media’s content) in violation of the employment contract, taking control of client funds in his trust account, and so on.

We criticized Randazza on more than one occasion. Together with German IP harvesters (Matthias Schroeder Padewet et al), Randazza committed dozens of shakedown lawsuits against alleged file sharers from June 2009 to August 2012. We covered some of these cases; tech media (Techdirt, TorrentFreak) also paid attention.

Randazza is regarded as a hero by many respected and honest people, primarily for his First Amendment work (for example, instrumenting the best anti-SLAPP law in the country). However, if you purport to do noble work, you don’t do it with your hands that dirty. Otherwise you let your allies down the big way by giving fatal ammunition to the foes."

Source
http://fightcopyrighttrolls.com/2015/07/09/marc-randazza-must-pay-600k-for-clear-and-serious-breaches-of-fiduciary-duty-against-his-former-client/comment-page-1/

Interim Arbitration Award Against Marc John Randazza
https://drive.google.com/file/d/0Bzn2NurXrSkiMV9xcl9qeVdpSUU/view?usp=sharing




Also Check Out
https://twitter.com/RandazzaExposed

AND

http://www.libertyvsrandazza.com/pr/


Interim Arbitration Award Against Marc John Randazza; Marc Randazza must pay $600K+ for “clear and serious breaches of fiduciary duty” against his former client

Click Below to Download Interim Arbitration Award Against Marc John Randazza
https://drive.google.com/file/d/0Bzn2NurXrSkiMV9xcl9qeVdpSUU/view?usp=sharing

Also Check Out
http://fightcopyrighttrolls.com/2015/07/09/marc-randazza-must-pay-600k-for-clear-and-serious-breaches-of-fiduciary-duty-against-his-former-client/comment-page-1/

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.

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





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.