Wednesday, April 15, 2015

My Personal Experience with Nevada Attorney Marc Randazza and the Randazza Legal Group Law Firm by Blogger Crystal Cox, Randazza's former client and target of a SLAPP suit he filed to silence me, steal my blogs, and suppress my First Amendment Rights.

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Randazza v. Cox; Court DENIES yet another begging blathering motion to dismiss Cox's VALID Defamation and Malpractice CLAIMS. Court DENIES and RANDAZZA then whines to the Ninth Circuit.

"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

Hypoocrite Attorney Marc Randazza filed a frivolous SLAPP lawsuit in Nevada to SUPPRESS the Free Speech and First Amendment Rights of Investigative Blogger Monica Foster. Yet he pretends to love all Free Speech

Marc Randazza has engaged in a campaign to "scrub" consumer review sites against him. I, Crystal Cox was harmed by Marc Randazza, he acted as my attorney. I have every right to review him, yet he removed massive online sites of mine, sued me for millions, sued one of my sources of corruption, and has engaged in massive harassment and legal actions in multiple courts to scrub the internet of sites reviewing him, yet files this motion in exact opposite of his own hypocritical actions.

Marc Randazza has violated the rights of Blogger Crystal Cox and yet presents the opposited case in District Court State of Nevada, County of Clark Eighth Judicial District A-14-69 8267- C.
as he sues blogger Monica Foster / Alexandra Mayers to SUPPRESS HER FIRST AMENTMENT RIGHTS IN A NEVADA SLAPP SUIT.

THE CASE BELOW RANDAZZA BENEFITS FROM SLAPP LAWS. \

Yet with US, his victims, he uses the SLAPP law to shield from countercomplaints when he clearly files SLAPP SUITS.



Marc Randazza has engaged in a campaign to "scrub" consumer review sites of any negative reviews by filing a SLAPP baseless lawsuit against Crystal Cox, Eliot Bernstein, and Alexandra Mayers.

Marc Randazza of Randazza Legal Group filed Randazza v. Cox and Randazza v. Godaddy to suppress my free speech, harass my sources, remove negative online content about him and his law firm in the hopes of intimidating me, Crystal Cox and my sources Eliot Bernstein, Diana Grandmason and Alexandra Mayers (Monica Foster).

All in this harassing case above is exactly what Marc Randazza and Randazza Legal Group has done to blogger Crystal Cox.

Crystal Cox moves to dismiss based on SLAPP and is Denied, Marc Randazza of Randazza Legal Group moves to dismiss, claims SLAPP and prevails and now sues for legal fees, WOW.

Marc Randazza is NOT above the LAW and should not have special privileges to sue bloggers and prevail on Nevada SLAPP law he, himself got into law. Look Deep folks, Marc Randazza is a LIAR, a THUG, a hypocrite, a rights violating attorney, and a seriously UNCONSTITUTIONAL LAWYER.




Nevada attorney Marc Randazza clearly Admits to having BEEN Blogger Crystal Cox's attorney yet swore to a federal court that he was NOT. Marc Randazza agrees to "bow out" as Crystal Cox's attorney then claims he was NEVER her attorney in the first place.

Attorney Marc Randazza continues to FLAT OUT LIE in Court Motions and Claim he was not Crystal Cox's attorney yet there is so much proof that he was her attorney and that he harmed Cox, deliberately and maliciously to retaliate against his former client and SUPPRESS her Free Speech.


"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
evidence.

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
https://docs.google.com/file/d/0Bzn2NurXrSkiUHBIcDltaWRKQ28/edit

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?

RESPONSE TO INTERROGATORY NO. 21:

"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
through settlement."

Source ( Page 18 )
https://drive.google.com/file/d/0Bzn2NurXrSkiM0hkaW9IYVV2VGc/view?usp=sharing


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?

WOW, Marc Randazza world's biggest Hypocrite Attorney.