"REQUEST NO. 3:
Anyway phone records, emails, faxes, mail, or records of documentation of any kind between
you and anyone, including and not limited to Judge Marco Hernandez, Michael Spreadbury, ...., Martin Cain, Lara Pearson, Alexandria Mayers, Sean Boushie, Peter L. Michaelson, Eric Turkewitz, Leo Mulville, Jordan Rushie, Kenneth P. White, Ari Bass aKa Michael Whiteacre, Sean Tompkins, Eugene Volokh, Liberty Media Company and all associates, any Porn company what so ever, Stephen Lamont, Pamela Simon, Ted Bernstein, Alan Rose or any other party, in which you made statement to about Crystal Cox in any way and especially whereby you accused Cox of criminal activity.
"RESPONSE TO REQUEST NO. 3:
Counterdefendant objects to Request No. 3 on the grounds that the request is unintelligible,
overly broad, unduly burdensome, vague, ambiguous, lacks specificity, and requests documents
which are neither relevant nor reasonably calculated to lead to the discovery of admissible
Counterdefendant further objects as the request seeks documents which are protected by
the attorney/client privilege and/or work product privilege. Furthermore, some of the documents
requested are, or should be, in Cox’s possession – for example, communications with Eugene
Volokh, her attorney. Such discovery requests should be directed at him. "
Source of Marc Randazza Response
Odd that Marc Randazza is claiming attorney client protection when he claims he was not my attorney. He STOLE my work product but seems to think his "work product" has value and worth but mine can just be STOLEN ???
INTERROGATORY NO. 21:
Did you have phone conversations with Eugene Volokh and state that you represented Cox and
discuss with him your strategy, or a deal you were trying to make with the opposition, Plaintiff’s
attorney David Aman?
"Counterdefendant objects to Interrogatory No. 21 on the grounds that it is vague, ambiguous,
overly broad, not limited in time and scope, and seeks information which is neither relevant nor
reasonably calculated to lead to the discovery of admissible evidence.
Counterdefendant further objects because this interrogatory is in excess of the 25 allowable
interrogatories pursuant to Rule 33(a) of the Federal Rules of Civil Procedure. As a result,
Counterdefendant is not required to respond to the same. Subject to and without waiving the
foregoing objections, Counterdefendant responds as follows:
Counterdefendant spoke with Eugene Volokh in December 2011.
Randazza informed Volkokh that if he was going to represent Cox, that Randazza would gladly bow out, and defer to Volokh to handle the case.
Volokh, however, said that he would prefer that Randazza co-counsel the case with him due to Volokh’s stated lack of litigation experience. Counterdefendant and Volokh discussed possible strategies that he and Volokh thought might be good ideas during that call.
Counterdefendant and Volokh both discussed the fact that Cox’s interests would be better served
Source ( Page 18 )
Why in the world would you would you "bow out" Mr Randazza if you were NEVER My attorney in the first place? What gives you the right to choose for me, make decision for me and to bow out as my attorney if you are saying that you were not my attorney ??? Hmmm
How in the world does attorney Marc Randazza have the legal right to bow out and to "defer" me, the client to another attorney and then defer to that attorney on the case?