Page 7 of the Schedule, Assets and Update Information
http://ia801505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.55.0.pdf
Monday, October 26, 2015
Monday, October 19, 2015
Unethical SCUM attorney Marc Randazza files bankruptcy to stall the inevitable, meanwhile the wife and Randazza Legal Group runs off with any assets that are not already offshore.
This summary is not available. Please
click here to view the post.
How many BRIBES did Marc Randazza take and screw over his own client?
"....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."
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/#comment-654707
SPOLIATION OF EVIDENCE
TAKING BRIBES
GETTING INTO CLIENTS BANK ACCOUNTS, HACKING CLIENTS EMAILS, INVASION OF PHONE RECORDS, OH AND Lot's more Randazzle indiscretions .. and he tried to set up others for crimes that never even remotely happened.
Randazza had the courts, big and small media, high profile legal writers, and much more attacking people who committed no crime, and they only thing they did was EXPOSE Marc Randazza. All the while he was doing what sure seems to be ILLEGAL behavior. And to think what he did to my life, simply because he was butthurt over a domain name.
Attorneys like Randazza need to GO TO JAIL and to NOT ever have clients again in ANY WAY.
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/#comment-654707
SPOLIATION OF EVIDENCE
TAKING BRIBES
GETTING INTO CLIENTS BANK ACCOUNTS, HACKING CLIENTS EMAILS, INVASION OF PHONE RECORDS, OH AND Lot's more Randazzle indiscretions .. and he tried to set up others for crimes that never even remotely happened.
Randazza had the courts, big and small media, high profile legal writers, and much more attacking people who committed no crime, and they only thing they did was EXPOSE Marc Randazza. All the while he was doing what sure seems to be ILLEGAL behavior. And to think what he did to my life, simply because he was butthurt over a domain name.
Attorneys like Randazza need to GO TO JAIL and to NOT ever have clients again in ANY WAY.
Why is Randazza NOT in Jail
"He is a total villain, anything for money, no matter who or whom he takes it from. Lifted 50-100,000 from me and then walks away leaving me with nothing after three of high billing.
Pull his licenses and put him in jail, maybe buy him a dictionary to look up the word honesty"
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/#comment-654707
Pull his licenses and put him in jail, maybe buy him a dictionary to look up the word honesty"
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/#comment-654707
Randazza WIPED Evidence, hid information, TOOK Bribes and has caused unknown MASSIVE amount of damage to his client Liberty Media. Then he files bankruptcy and is still representing CLIENTS? WoW, Marc Randazza sure SEEMS to be above the LAW. We shall See.
"He’s going to be liable for more, too, as soon as E/L figures out how much damages he caused them for the post-employment violations of fiduciary duty. Wiping the laptop meant they may have had to recreate litigation in other cases, not just the Oron one–potentially jacking up the amount owed significantly."
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/#comment-654707
Shouldn't Randazza have 2 million in liability insurance in every state he is licensed, where is his liability carrier in the paying of damages to his client?
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/#comment-654707
Shouldn't Randazza have 2 million in liability insurance in every state he is licensed, where is his liability carrier in the paying of damages to his client?
the Oron bribe ($75,000)
Take a Look
http://fightcopyrighttrolls.com/2015/07/09/marc-randazza-must-pay-600k-for-clear-and-serious-breaches-of-fiduciary-duty-against-his-former-client/comment-page-1/#comment-654707
Got a Tip?
ReverendCrystalCox@gmail.com
Much more to be discovered about the Oron Bribe, COMING SOON
http://fightcopyrighttrolls.com/2015/07/09/marc-randazza-must-pay-600k-for-clear-and-serious-breaches-of-fiduciary-duty-against-his-former-client/comment-page-1/#comment-654707
Got a Tip?
ReverendCrystalCox@gmail.com
Much more to be discovered about the Oron Bribe, COMING SOON
Marc Randazza SUES, Bullies, Threatens and harasses unhappy clients. His buddies, attorney thugs, media connections and more help him HARASS those who he TERRORIZES and ruins there life.
Where is the FTC, the Bar Association, the Department of Justice, the Nevada Bar or the Nevada Attorney General? Well you see it's all about REVENGE. Whoever stands up to RANDAZZA, and Roca Labs did, well they get investigated, they get selective prosecution.
Marc Randazza has BIG Connections, and favors owed and he has no sense of what is the right thing to do, even for himself or his family. He gets angry, say over a 10$ domain name he was to damn dumb to buy and he throws money at it, legal fees, filings, mailings, and tons of time, year after year just to teach that person a lesson and ends up with all kinds of EGG on his big dumb face.
So while you are all gloating about the FTC and Roca Labs, that does not make Marc Randazza right nor lawful and the TRUTH will keep coming regarding your alleged First Amendment HERO.
Marc Randazza has BIG Connections, and favors owed and he has no sense of what is the right thing to do, even for himself or his family. He gets angry, say over a 10$ domain name he was to damn dumb to buy and he throws money at it, legal fees, filings, mailings, and tons of time, year after year just to teach that person a lesson and ends up with all kinds of EGG on his big dumb face.
So while you are all gloating about the FTC and Roca Labs, that does not make Marc Randazza right nor lawful and the TRUTH will keep coming regarding your alleged First Amendment HERO.
Why does the Nevada Bar nor the Attorney General jump in to Fight Back against Rogue Abusive attorneys like Marc Randazza who sue, bully and threaten those who criticize or review him or his law firm.
The FTC would not do something like jump in and protect an online speaker. I wish they would but come one, Marc Randazza gets his way WAY to often.
http://www.cbsnews.com/news/ftc-lawsuit-roca-labs-weight-loss-powder-gag-clause-customers-sued/
Marc Randazza is down right GIDDY about what the FTC is doing to Roca Labs. However, attorneys like Marc Randazza do the same thing to anyone who tells on him, reviews him badly, speaks critical of them and that is not so amusing. Marc Randazza SUES people like me, Crystal Cox, and Alexandra Mayers when we give our opinion of him, his wife or his law firm.
He digs into my bank accounts, threatens me, lies about me under oath, gets my phone records, threatens ex's, friends, clients and customers. And yet there is NO FTC to go after him, hmmm imagine that. Legal Clients NOT protected but Dieters are?
http://www.cbsnews.com/news/ftc-lawsuit-roca-labs-weight-loss-powder-gag-clause-customers-sued/
Marc Randazza is down right GIDDY about what the FTC is doing to Roca Labs. However, attorneys like Marc Randazza do the same thing to anyone who tells on him, reviews him badly, speaks critical of them and that is not so amusing. Marc Randazza SUES people like me, Crystal Cox, and Alexandra Mayers when we give our opinion of him, his wife or his law firm.
He digs into my bank accounts, threatens me, lies about me under oath, gets my phone records, threatens ex's, friends, clients and customers. And yet there is NO FTC to go after him, hmmm imagine that. Legal Clients NOT protected but Dieters are?
Friday, October 16, 2015
Reply to Opposition of Liberty Media from Larson Law Firm
Read the Whiny Gibberish Below. Guess these guys are trying to convince the courts that their client is not, well at least UNETHICAL.
http://ia601505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.51.0.pdf
http://ia601505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.51.0.pdf
Tuesday, October 13, 2015
Opposition from Liberty Media; Liberty Media Opposes Larson & Zirzow, LLC as Attorneys for the Debtor. I, Crystal Cox of course claimed that Marc Randazza planned bankruptcy for a very long time, and he had hired Larson long ago. Larson has no Business being Marc Randazza's attorney, take a look.
"EXCELSIOR MEDIA CORP., AND LIBERTY
MEDIA HOLDINGS, LLC.’S OPPOSITION
TO DEBTOR’S APPLICATION TO EMPLOY
AND RETAIN COUNSEL NUNC PRO TUNC
TO THE PETITION DATE."
"Excelsior Media Corp., and Liberty Media Holdings, LLC (collectively “E/L” or
“Creditors”), by and through its attorney of record, hereby submit this opposition to debtor Marc
John Randazza’s (“Randazza” or “Debtor”) Application to Employ and Retain Larson & Zirzow,
LLC (“L&Z”) as Attorneys for The Debtor Nunc Pro Tunc to the Petition Date (the “Application”)
on the grounds:
(a) no showing is made to support a nunc pro tunc order;
(b) L&Z has received payments which may constitute voidable preferences under section 457 of the Bankruptcy Code;
(c) the application does not establish that the fees already paid, and for which nunc pro tunc approval is sought, are reasonable; and (d) there is no support for the proposition that the court should approve
the retention of a professional before the circumstances for which the retention is sought have
occurred.
This Opposition is based upon the following memorandum of points and authorities, the
declaration of Wendy M. Krincek, all pleadings and papers on file in this action, and such argument
as may be presented at the hearing thereon.
I. INTRODUCTION
On August 28, 2015, Debtor Marc John Randazza filed a voluntary petition under Chapter
11 of the Bankruptcy Code. Debtor is an attorney licensed in the states of Arizona, California,
Colorado, Florida, Massachusetts, and Nevada. Creditors E/L, are affiliated entities comprising a
larger online entertainment firm whom formerly employed Debtor as its in-house general counsel
from 2009 through 2012.
Debtor resigned his employment at E/L effective August 29, 2012, under contentious
circumstances caused in chief by numerous instances of professional and ethical misconduct
perpetrated by Debtor, at the expense of E/L.
In the latter half of 2012, Debtor initiated a frivolous arbitration action against E/L for
unsubstantiated claims under Judicial Arbitration and Mediation Services, Inc. (“JAMS”) case No.
1260002283 before the Hon. Stephen E. Haberfeld (Ret.) (the “Arbitrator”). In response, E/L filed
counterclaims against Debtor stemming from flagrant violations of professional conduct, barred by
ethical rules, which resulted and continues to result in harm to E/L.
On February 9 through 13, 2015, the Arbitrator held in-person evidentiary sessions on the
merits of the parties’ respective claims, counterclaims, and contentions. After weighing the relevant
evidence and testimony, the Arbitrator rendered his Interim Arbitration Award (“IAA”) on June 3, 2015. A true and correct copy of the IAA is attached hereto as Exhibit 1. The IAA found firmly for E/L, and awarded E/L in excess of $1 million dollars, subject to an additional award for costs and attorneys fees upon application therefor.
In an effort to avoid payment of the entire monetary component of the IAA, and before the
IAA could be confirmed by the state court, Debtor, by and through its counsel L&Z, initiated
settlement negotiations with E/L.
During these negotiations, Debtor consistently used the threat of a bankruptcy petition in an attempt to negotiate a sum of payment significantly reduced from that awarded to E/L in the IAA.
Not only did Debtor use the threat of bankruptcy as a cudgel, but he and his allegedly estranged wife have initiated sealed divorce proceedings, and dissipated assets.
After weeks of feigned negotiation, and several attempts to have the hearing confirming the
IAA continued, Debtor filed his petition for Chapter 11 reorganization on August 28, 2015 - the eve
before the IAA could be confirmed. Debtor attempted delay for two reasons:
(1) in a misguided effort to stay the award of attorneys fees by the Arbitrator, as well as the confirmation of the IAA by the state court; and (2) to push the date of petition out more than 90 days, so that Debtor’s fraudulent, improper, and preferential transfers could not be clawed back, including payments to his attorneys L&Z.
According to Debtor’s schedules filed on September 11, 2015, Debtor has deposited with
L&Z sums totaling $94,000. [ECF 15] On September 22, 2015, L&Z filed the instant Application
to Employ and Retain Larson & Zirzow, LLC as Attorneys for the Debtor Nunc Pro Tunc to the
Petition Date. [ECF 18, 19]
According to the retainer agreements and statements made therein, L&Z entered into
representation of Debtor as of June 11, 2015 for “pre-bankruptcy settlement negotiations and to
attend a settlement conference. The Debtor paid L&Z a flat fee of $10,000.00 for this engagement.”
[ECF 18 at ¶7]
L&Z also purports to have been retained, via two separate retainer agreements, for
representation in both a bankruptcy action, and a potential adversary proceeding. The first retainer agreement was for preparation and filing of the voluntary petition for relief as debtor and debtor in
possession in a bankruptcy case commenced under Chapter 11 of Title 11 of the United States
Code; the second was for potential nondischargeability litigation. [ECF 18, Exhibit 2, and 3,
respectively]. Of particular import, the Application is silent as to how much of each of the retainer
agreements were paid, when, or for what amounts.
L&Z’s Application is deficient as it relates to exactly what the scope of services are that it
has billed for as of yet. In fact, L&Z only informs as to the fact that it has received a total sum of
$94,000 for legal services in connection with Debtor’s Chapter 11 case. “Of this sum, L&Z billed
and was paid the sum of $26,908.82 prior to the Petition Date, and L&Z currently holds in trust the
remainder sum of $67,091.18 (the “Remaining Retainer”) a portion of which has been allocated
pursuant to the Representation Agreements for potential adversary proceedings.” [ECF 18 at ¶16
(emphasis added)] This Application utterly fails to identify and delineate what services were
provided totaling $26,908.82.
In any event, all transfers were made within 90 days of the filing of Debtor’s Petition. As
such, the “pre-bankruptcy” retainer fees charged and collected by L&Z constitute an avoidable
preferential transfer, and the funds must be clawed back to the estate. As a result, L&Z will lose
their status as “disinterested parties” and are therefore not qualified to serve as attorneys for the
Debtor.
L&Z’s employment as attorneys for the debtor in possession in a Chapter 11 case is
governed by § 327(a) of the Bankruptcy Code, which requires court approval for the attorney's
employment. The bankruptcy court is charged with “ensur[ing] that attorneys who represent the
debtor do so in the best interests of the bankruptcy estate.” In re Park–Helena Corp., 63 F.3d 877,
880 (9th Cir.1995). Under § 327, an attorney for a debtor cannot “hold or represent an interest
adverse to the estate”; he or she must be a “disinterested person.” 11 U.S.C. § 327(a).
Any creditor of the estate, or anyone with “an interest materially adverse to the interest of the estate ... by reason of any direct or indirect relationship to, connection with, or interest in, the debtor,” is not a disinterested person. 11 U.S.C. §§ 101(14)(A), (C).
A “creditor” includes any “entity that has a claim against the debtor that arose at the time of or before the order for relief concerning the debtor.” § 101(10)(A). A “claim” includes any “right to payment.” § 101(5)(A).
To enable the Bankruptcy Court to evaluate an attorney's potential employment, Rule
2014(a) requires that an application for employment of an attorney under § 327 “shall be
accompanied by a verified statement of the person to be employed setting forth the person's
connections with the debtor, creditors, any other party in interest, their respective attorneys and
accountants, the United States trustee, or any person employed in the office of the United States
trustee.” Fed. R. Bankr.P. 2014(a). This disclosure requirement is applied “strictly.” Park–Helena,
63 F.3d at 881.
An attorney approved for employment under § 327 must apply for interim or final
compensation, which is subject to approval of the Bankruptcy Court. 11 U.S.C. §§ 328–31; see also
In re Chapel Gate Apartments, Ltd., 64 B.R. 569, 575 (Bankr.N.D.Tex.1986) (noting that “fees in
bankruptcy cases ... are subject to review, modification, and outright cancellation by the Court”).
Rule 2016(a) requires an attorney seeking compensation and/or reimbursement of expenses to file
an application “setting forth a detailed statement of
(1) the services rendered, time expended and expenses incurred, and
(2) the amounts requested.” The fee application must also include, inter alia, “a statement as to what payments have theretofore been made or promised to the applicant for services rendered or to be rendered in any capacity whatsoever in connection with the case, [and] the source of the compensation so paid or promised.” Id.
After notice and a hearing, the court may award “reasonable compensation for actual, necessary services rendered,” as well as “reimbursement for actual, necessary expenses.” §330(a)(1).
Separate from, and in addition to, a fee application, § 329(a) further requires a debtor's
attorney to “file with the court a statement of the compensation paid or agreed to be paid, if such
payment or agreement was made after one year before the date of the filing of the petition, for
services rendered or to be rendered in contemplation of or in connection with the case by such attorney, and the source of such compensation.”
Rule 2016(b) requires the attorney to file such a statement “within 14 days after [a petition is filed],” along with supplemental statements “within 14 days after any payment or agreement not previously disclosed.” The court may approve any reasonable compensation agreement, including on a retainer and/or hourly basis. §328(a).
However, once an attorney has disclosed his or her “compensation paid or agreed to be paid,” the
court may “cancel any such agreement, or order the return of any such payment” if the court
determines that it “exceeds the reasonable value of any such services.” §329(b).
The court may also “deny allowance of compensation for services and reimbursement of expenses [...] if, at any time [...], such professional person is not a disinterested person, or represents or holds an interest adverse to the interest of the estate with respect to the matter on which such professional person is employed.” §328(c).
If a debtor seeks approval for the employment of a professional on a nunc pro tunc basis, as
Mr. Randazza does here, the test is even stronger. “A professional may receive court approval of
employment “nunc pro tunc” where the professional did not receive prior approval, as long as such
after-the-fact court approval is limited to exceptional circumstances. Applying for nunc pro tunc
approval does not alleviate the professional from meeting the requirements of §327; the professional
still must show that it was disinterested.
The Ninth Circuit allows retroactive (nunc pro tunc) awards of fees for services rendered without prior court approval where: (1) the applicant has a satisfactory explanation for the failure to receive prior judicial approval; and (2) the applicant has benefitted the estate in some significant manner. These strict requirements are not to be taken lightly ‘lest it be too easy to circumvent the statutory requirement of prior approval.’” In re Mehdipour, 202 B.R. 474,479 (9Th Cir. BAP, 1996).
A. L&Z Makes No Effort to Explain Why it is Seeking Nunc Pro Tunc Approval.
The application to employ L&Z seeks nunc pro tunc approval to employ and retain the firm.
However, the application makes no effort to explain why prior judicial approval was not obtained or to establish that L&Z has benefitted the estate in some significant manner.
It appears that the request for nunc pro tunc approval is an effort to protect the $10,000 lump sum payment made pursuant to what the Application terms “Retainer 1.” “Retainer 1” appears to have nothing to do with the bankruptcy case and, thus is likely an avoidable preferential transfer.
This would not only subject the payment to recapture by the estate but also make L&Z a potential creditor. Since L&Z does not supply any detailed information on the nature of the work it performed in exchange for the $10,000, it cannot be determined whether it is reasonable, whether it benefitted the estate or whether it had any relation to the bankruptcy case.
As such, the Court should not approve, on a nunc pro tunc basis, the employment of L&Z
under “Retainer 1.”B. L&Z Potentially Holds An Interest Adverse To The Estate And Therefore Must Be Disqualified.
Because L&Z received pre-petition payment from the Debtor, under conditions that may
subject those payments to a later avoidance action, L&Z cannot satisfy the “disinterested person”
requirement. See, 11 U.S.C. § 327(a). Id. The Bankruptcy Code includes as a “disinterested
person,” someone who “does not have an interest materially adverse to the interest of the estate or of any class of creditors or equity security holders, by reason of any direct or indirect relationship
to, connection with, or interest in, the debtor…, or for any other reason.” 11 U.S.C. §1101(14)(E).
Prior representation of the debtor does not, of itself, merit disqualification. See, 11 U.S.C. §1107(b)
(“A person is not disqualified for employment under section 327 of this title by a debtor in
possession solely because of such person’s employment by or representation of the debtor before
the commencement of the case.”).
A debtors' counsel—or any estate professional- who is the beneficiary of a preference is in a
precarious position:
First, if [the debtor's counsel] actually did receive an avoidable preference then he
would be ineligible to be paid anything from the estate unless and until he returns
that preference. Second, if [the debtors' counsel] actually did receive an avoidable
preference then he would probably be ineligible for employment, no matter how
completely he disclosed the relevant facts, at least until he returns the preference
... As one court has put it, he would be unlikely to sue himself.
Movitz v. Baker (In re Triple Star Welding, Inc.), 324 B.R. 778, 793 (9th Cir.BAP2005), partially
abrogated on other grounds, Dye v. Brown (In re AFI Holdings, Inc.), 530 F.3d 832 (9th
Cir.2008)(citing Staiano v. Pillowtex (In re Pillowtex, Inc.) 304 F.3d 246, 254 (3d Cir.2002)).
The Ninth Circuit has adopted the test set out in In re Pillowtex, declaring that “where there
is a ‘facially plausible’ preference claim then the preference issues must be resolved before
proposed counsel can be employed (or compensated).” In re Triple Star Welding, 324 B.R. at 794
(citing In re Pillowtex, 304 F.3d at 254)).
An essential element of a preference claim is that the payment at issue was “made while the
debtor was insolvent.” 11 U.S.C. § 547(B)(3). Section 547(f) supplies a presumption that debtors
are insolvent “on and during the 90 days immediately preceding the date of the filing of the
petition.” 11 U.S.C. § 547(f).
According to L&Z’s own Application, Debtor transferred $10,000 to L&Z on or about June 11, 2015 – 78 days prior to Debtor’s Petition. [ECF 18 at ¶7] L&Z collected additional funds in prior to Debtor’s Petition as well, including having billed, and collected, an additional $16,908.82 in retainer fees for which it provides no explanation or accounting therefor. L&Z also conspicuously fails to provide any date as to when the $16,908.82 was billed and/or collected, though it concedes that said amount was collected “prior to the Petition date.” [ECF 18 at ¶16]
L&Z contends that it holds an additional sum of $67,091.18 which has been allocated to
representation in potential adversary proceedings. [ECF 18 at ¶16] Again, no date of billing or
collection has been provided, though it again concedes the $67,091.18 was collected “prior to the
Petition date.” [ECF 18 at ¶16] In any event, the amounts owed and collected by L&Z were within
the 90 days prior to Debtor’s Petition.
In In re First Jersey Securities, Inc., 180 F.3d 504 (3d Cir.1999), the U.S. Trustee objected
to retention of the counsel proposed by the debtor in possession on the ground that counsel had
received a preferential payment, constituting an interest adverse to the estate. Notwithstanding that
both the bankruptcy court and the district court had approved counsel's retention, the court reversed.
The court stated “[w]here there is an actual conflict of interest ... disqualification is mandatory.” Id.
at 509 (citing In re Marvel Entertainment, 140 F.3d at 476). Then, in language that E/L here emphasizes, the court stated “[a] preferential transfer to [debtor's counsel] would constitute an
actual conflict of interest between counsel and the debtor, and would require the firm's
disqualification.” 180 F.3d at 509 (emphasis in original).
An avoidable preference is defined in section 547(b) of the Bankruptcy Code as:
any transfer of an interest of the debtor in property-(1) to or for the benefit of a
creditor; (2) for or on account of an antecedent debt owed by the debtor before
such transfer was made; (3) made while the debtor was insolvent; (4) made-(A)
on or within 90 days before the date of the filing of the petition; ... (5) that enables
such creditor to receive more than such creditor would receive [in a Chapter 7
distribution]. 11 U.S.C. § 547(b).
Because L&Z has taken and retained payments that may be preferential – as they were
collected within the 90 days prior to Debtor’s Petition – and it will not be advising Debtor to seek
recovery of payments made to L&Z, an actual conflict of interest exists today, and will continue to
exist if L&Z’s retention is approved. See 11 U.S.C. §101(10)(A) (creditor is an “entity that has a
claim against the debtor that arose at the time of or before the order for relief concerning the
debtor.”); §101(5)(A) (claim is a right to payment). And, therefore, L&Z is not disinterested for the
purposes of § 327(a). See In re Kings River Resorts, Inc., 342 B.R. 76, 88 (Bankr.E.D.Cal.2006)
(“A professional holding a potential prepetition claim against a debtor ... is a creditor of the estate
and therefore not ‘disinterested’ ....”).
C. The Application Does Not Contain a Detailed Description of the Work
Performed and the Amount Charged to Determine the Reasonableness of the
Fees Already Paid.
The application does not satisfy Rule 2016(a)’s requirement that an attorney seeking
compensation and/or reimbursement of expenses to file an application “setting forth a detailed
statement of
(1) the services rendered, time expended and expenses incurred, and
(2) the amounts requested.” In fact, L&Z nowhere detail how much they have been paid under what is termed “Retainer 2” – the retainer governing the filing and processing of the Chapter 11 case. Yet, L&Z hopes to obtain nunc pro tunc approval of the fees charged and collected without ever having to make the showing required under Rule 2016(a). This is improper.
If the court is not presented with detailed facts demonstrating how much was charged, for what services, and how it was charged, it cannot make the necessary determination that it was reasonable and benefitted the estate. The entire application must be denied for this reason alone.
D. The Court Should Not Approve a Retainer Agreement For Work That May Not
Be Performed.
The request for approval of what is termed “Retainer 3” is wholly unsupported by logic and
law. Apparently, the Debtor has paid L&Z a retainer of $30,000 – monies that are assets of the
estate – to hold in case L&Z is required to represent the Debtor in a potential adversary proceeding.
The Debtor cites to no authority that supports seeking, let alone obtaining, court approval to retain a
professional just in case an adversary proceeding is filed. The proper way to proceed would be for
the Debtor to return to court with an application to employ counsel to represent it in an adversary proceeding once that adversary proceeding is actually filed. "
"III. CONCLUSION
Because L&Z billed and collected sums from the Debtor’s in the 90-day period proceeding
Petition, such sums paid are preferential transfers and subject to clawback to the estate. As such,
L&Z will have a claim against the Debtor for sums owed pre-petition, will be a creditor of the
estate, and therefore not a disinterested party. L&Z’s Application must be denied on these grounds."
Vaughn M. Greenwalt
Attorneys for Creditors,
Excelsior Media Corp., and
Liberty Media Holdings, LLC."
Source and Filing
http://ia801505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.38.0.pdf
MEDIA HOLDINGS, LLC.’S OPPOSITION
TO DEBTOR’S APPLICATION TO EMPLOY
AND RETAIN COUNSEL NUNC PRO TUNC
TO THE PETITION DATE."
"Excelsior Media Corp., and Liberty Media Holdings, LLC (collectively “E/L” or
“Creditors”), by and through its attorney of record, hereby submit this opposition to debtor Marc
John Randazza’s (“Randazza” or “Debtor”) Application to Employ and Retain Larson & Zirzow,
LLC (“L&Z”) as Attorneys for The Debtor Nunc Pro Tunc to the Petition Date (the “Application”)
on the grounds:
(a) no showing is made to support a nunc pro tunc order;
(b) L&Z has received payments which may constitute voidable preferences under section 457 of the Bankruptcy Code;
(c) the application does not establish that the fees already paid, and for which nunc pro tunc approval is sought, are reasonable; and (d) there is no support for the proposition that the court should approve
the retention of a professional before the circumstances for which the retention is sought have
occurred.
This Opposition is based upon the following memorandum of points and authorities, the
declaration of Wendy M. Krincek, all pleadings and papers on file in this action, and such argument
as may be presented at the hearing thereon.
MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
On August 28, 2015, Debtor Marc John Randazza filed a voluntary petition under Chapter
11 of the Bankruptcy Code. Debtor is an attorney licensed in the states of Arizona, California,
Colorado, Florida, Massachusetts, and Nevada. Creditors E/L, are affiliated entities comprising a
larger online entertainment firm whom formerly employed Debtor as its in-house general counsel
from 2009 through 2012.
Debtor resigned his employment at E/L effective August 29, 2012, under contentious
circumstances caused in chief by numerous instances of professional and ethical misconduct
perpetrated by Debtor, at the expense of E/L.
In the latter half of 2012, Debtor initiated a frivolous arbitration action against E/L for
unsubstantiated claims under Judicial Arbitration and Mediation Services, Inc. (“JAMS”) case No.
1260002283 before the Hon. Stephen E. Haberfeld (Ret.) (the “Arbitrator”). In response, E/L filed
counterclaims against Debtor stemming from flagrant violations of professional conduct, barred by
ethical rules, which resulted and continues to result in harm to E/L.
On February 9 through 13, 2015, the Arbitrator held in-person evidentiary sessions on the
merits of the parties’ respective claims, counterclaims, and contentions. After weighing the relevant
evidence and testimony, the Arbitrator rendered his Interim Arbitration Award (“IAA”) on June 3, 2015. A true and correct copy of the IAA is attached hereto as Exhibit 1. The IAA found firmly for E/L, and awarded E/L in excess of $1 million dollars, subject to an additional award for costs and attorneys fees upon application therefor.
In an effort to avoid payment of the entire monetary component of the IAA, and before the
IAA could be confirmed by the state court, Debtor, by and through its counsel L&Z, initiated
settlement negotiations with E/L.
During these negotiations, Debtor consistently used the threat of a bankruptcy petition in an attempt to negotiate a sum of payment significantly reduced from that awarded to E/L in the IAA.
Not only did Debtor use the threat of bankruptcy as a cudgel, but he and his allegedly estranged wife have initiated sealed divorce proceedings, and dissipated assets.
After weeks of feigned negotiation, and several attempts to have the hearing confirming the
IAA continued, Debtor filed his petition for Chapter 11 reorganization on August 28, 2015 - the eve
before the IAA could be confirmed. Debtor attempted delay for two reasons:
(1) in a misguided effort to stay the award of attorneys fees by the Arbitrator, as well as the confirmation of the IAA by the state court; and (2) to push the date of petition out more than 90 days, so that Debtor’s fraudulent, improper, and preferential transfers could not be clawed back, including payments to his attorneys L&Z.
According to Debtor’s schedules filed on September 11, 2015, Debtor has deposited with
L&Z sums totaling $94,000. [ECF 15] On September 22, 2015, L&Z filed the instant Application
to Employ and Retain Larson & Zirzow, LLC as Attorneys for the Debtor Nunc Pro Tunc to the
Petition Date. [ECF 18, 19]
According to the retainer agreements and statements made therein, L&Z entered into
representation of Debtor as of June 11, 2015 for “pre-bankruptcy settlement negotiations and to
attend a settlement conference. The Debtor paid L&Z a flat fee of $10,000.00 for this engagement.”
[ECF 18 at ¶7]
L&Z also purports to have been retained, via two separate retainer agreements, for
representation in both a bankruptcy action, and a potential adversary proceeding. The first retainer agreement was for preparation and filing of the voluntary petition for relief as debtor and debtor in
possession in a bankruptcy case commenced under Chapter 11 of Title 11 of the United States
Code; the second was for potential nondischargeability litigation. [ECF 18, Exhibit 2, and 3,
respectively]. Of particular import, the Application is silent as to how much of each of the retainer
agreements were paid, when, or for what amounts.
L&Z’s Application is deficient as it relates to exactly what the scope of services are that it
has billed for as of yet. In fact, L&Z only informs as to the fact that it has received a total sum of
$94,000 for legal services in connection with Debtor’s Chapter 11 case. “Of this sum, L&Z billed
and was paid the sum of $26,908.82 prior to the Petition Date, and L&Z currently holds in trust the
remainder sum of $67,091.18 (the “Remaining Retainer”) a portion of which has been allocated
pursuant to the Representation Agreements for potential adversary proceedings.” [ECF 18 at ¶16
(emphasis added)] This Application utterly fails to identify and delineate what services were
provided totaling $26,908.82.
In any event, all transfers were made within 90 days of the filing of Debtor’s Petition. As
such, the “pre-bankruptcy” retainer fees charged and collected by L&Z constitute an avoidable
preferential transfer, and the funds must be clawed back to the estate. As a result, L&Z will lose
their status as “disinterested parties” and are therefore not qualified to serve as attorneys for the
Debtor.
II. L&Z’S APPLICATION IS INSUFFICIENT TO SATISFY THE TEST FOR
APPROVAL OF HIRING OF PROFESSIONALS.
L&Z’s employment as attorneys for the debtor in possession in a Chapter 11 case is
governed by § 327(a) of the Bankruptcy Code, which requires court approval for the attorney's
employment. The bankruptcy court is charged with “ensur[ing] that attorneys who represent the
debtor do so in the best interests of the bankruptcy estate.” In re Park–Helena Corp., 63 F.3d 877,
880 (9th Cir.1995). Under § 327, an attorney for a debtor cannot “hold or represent an interest
adverse to the estate”; he or she must be a “disinterested person.” 11 U.S.C. § 327(a).
Any creditor of the estate, or anyone with “an interest materially adverse to the interest of the estate ... by reason of any direct or indirect relationship to, connection with, or interest in, the debtor,” is not a disinterested person. 11 U.S.C. §§ 101(14)(A), (C).
A “creditor” includes any “entity that has a claim against the debtor that arose at the time of or before the order for relief concerning the debtor.” § 101(10)(A). A “claim” includes any “right to payment.” § 101(5)(A).
To enable the Bankruptcy Court to evaluate an attorney's potential employment, Rule
2014(a) requires that an application for employment of an attorney under § 327 “shall be
accompanied by a verified statement of the person to be employed setting forth the person's
connections with the debtor, creditors, any other party in interest, their respective attorneys and
accountants, the United States trustee, or any person employed in the office of the United States
trustee.” Fed. R. Bankr.P. 2014(a). This disclosure requirement is applied “strictly.” Park–Helena,
63 F.3d at 881.
An attorney approved for employment under § 327 must apply for interim or final
compensation, which is subject to approval of the Bankruptcy Court. 11 U.S.C. §§ 328–31; see also
In re Chapel Gate Apartments, Ltd., 64 B.R. 569, 575 (Bankr.N.D.Tex.1986) (noting that “fees in
bankruptcy cases ... are subject to review, modification, and outright cancellation by the Court”).
Rule 2016(a) requires an attorney seeking compensation and/or reimbursement of expenses to file
an application “setting forth a detailed statement of
(1) the services rendered, time expended and expenses incurred, and
(2) the amounts requested.” The fee application must also include, inter alia, “a statement as to what payments have theretofore been made or promised to the applicant for services rendered or to be rendered in any capacity whatsoever in connection with the case, [and] the source of the compensation so paid or promised.” Id.
After notice and a hearing, the court may award “reasonable compensation for actual, necessary services rendered,” as well as “reimbursement for actual, necessary expenses.” §330(a)(1).
Separate from, and in addition to, a fee application, § 329(a) further requires a debtor's
attorney to “file with the court a statement of the compensation paid or agreed to be paid, if such
payment or agreement was made after one year before the date of the filing of the petition, for
services rendered or to be rendered in contemplation of or in connection with the case by such attorney, and the source of such compensation.”
Rule 2016(b) requires the attorney to file such a statement “within 14 days after [a petition is filed],” along with supplemental statements “within 14 days after any payment or agreement not previously disclosed.” The court may approve any reasonable compensation agreement, including on a retainer and/or hourly basis. §328(a).
However, once an attorney has disclosed his or her “compensation paid or agreed to be paid,” the
court may “cancel any such agreement, or order the return of any such payment” if the court
determines that it “exceeds the reasonable value of any such services.” §329(b).
The court may also “deny allowance of compensation for services and reimbursement of expenses [...] if, at any time [...], such professional person is not a disinterested person, or represents or holds an interest adverse to the interest of the estate with respect to the matter on which such professional person is employed.” §328(c).
If a debtor seeks approval for the employment of a professional on a nunc pro tunc basis, as
Mr. Randazza does here, the test is even stronger. “A professional may receive court approval of
employment “nunc pro tunc” where the professional did not receive prior approval, as long as such
after-the-fact court approval is limited to exceptional circumstances. Applying for nunc pro tunc
approval does not alleviate the professional from meeting the requirements of §327; the professional
still must show that it was disinterested.
The Ninth Circuit allows retroactive (nunc pro tunc) awards of fees for services rendered without prior court approval where: (1) the applicant has a satisfactory explanation for the failure to receive prior judicial approval; and (2) the applicant has benefitted the estate in some significant manner. These strict requirements are not to be taken lightly ‘lest it be too easy to circumvent the statutory requirement of prior approval.’” In re Mehdipour, 202 B.R. 474,479 (9Th Cir. BAP, 1996).
A. L&Z Makes No Effort to Explain Why it is Seeking Nunc Pro Tunc Approval.
The application to employ L&Z seeks nunc pro tunc approval to employ and retain the firm.
However, the application makes no effort to explain why prior judicial approval was not obtained or to establish that L&Z has benefitted the estate in some significant manner.
It appears that the request for nunc pro tunc approval is an effort to protect the $10,000 lump sum payment made pursuant to what the Application terms “Retainer 1.” “Retainer 1” appears to have nothing to do with the bankruptcy case and, thus is likely an avoidable preferential transfer.
This would not only subject the payment to recapture by the estate but also make L&Z a potential creditor. Since L&Z does not supply any detailed information on the nature of the work it performed in exchange for the $10,000, it cannot be determined whether it is reasonable, whether it benefitted the estate or whether it had any relation to the bankruptcy case.
As such, the Court should not approve, on a nunc pro tunc basis, the employment of L&Z
under “Retainer 1.”B. L&Z Potentially Holds An Interest Adverse To The Estate And Therefore Must Be Disqualified.
Because L&Z received pre-petition payment from the Debtor, under conditions that may
subject those payments to a later avoidance action, L&Z cannot satisfy the “disinterested person”
requirement. See, 11 U.S.C. § 327(a). Id. The Bankruptcy Code includes as a “disinterested
person,” someone who “does not have an interest materially adverse to the interest of the estate or of any class of creditors or equity security holders, by reason of any direct or indirect relationship
to, connection with, or interest in, the debtor…, or for any other reason.” 11 U.S.C. §1101(14)(E).
Prior representation of the debtor does not, of itself, merit disqualification. See, 11 U.S.C. §1107(b)
(“A person is not disqualified for employment under section 327 of this title by a debtor in
possession solely because of such person’s employment by or representation of the debtor before
the commencement of the case.”).
A debtors' counsel—or any estate professional- who is the beneficiary of a preference is in a
precarious position:
First, if [the debtor's counsel] actually did receive an avoidable preference then he
would be ineligible to be paid anything from the estate unless and until he returns
that preference. Second, if [the debtors' counsel] actually did receive an avoidable
preference then he would probably be ineligible for employment, no matter how
completely he disclosed the relevant facts, at least until he returns the preference
... As one court has put it, he would be unlikely to sue himself.
Movitz v. Baker (In re Triple Star Welding, Inc.), 324 B.R. 778, 793 (9th Cir.BAP2005), partially
abrogated on other grounds, Dye v. Brown (In re AFI Holdings, Inc.), 530 F.3d 832 (9th
Cir.2008)(citing Staiano v. Pillowtex (In re Pillowtex, Inc.) 304 F.3d 246, 254 (3d Cir.2002)).
The Ninth Circuit has adopted the test set out in In re Pillowtex, declaring that “where there
is a ‘facially plausible’ preference claim then the preference issues must be resolved before
proposed counsel can be employed (or compensated).” In re Triple Star Welding, 324 B.R. at 794
(citing In re Pillowtex, 304 F.3d at 254)).
An essential element of a preference claim is that the payment at issue was “made while the
debtor was insolvent.” 11 U.S.C. § 547(B)(3). Section 547(f) supplies a presumption that debtors
are insolvent “on and during the 90 days immediately preceding the date of the filing of the
petition.” 11 U.S.C. § 547(f).
According to L&Z’s own Application, Debtor transferred $10,000 to L&Z on or about June 11, 2015 – 78 days prior to Debtor’s Petition. [ECF 18 at ¶7] L&Z collected additional funds in prior to Debtor’s Petition as well, including having billed, and collected, an additional $16,908.82 in retainer fees for which it provides no explanation or accounting therefor. L&Z also conspicuously fails to provide any date as to when the $16,908.82 was billed and/or collected, though it concedes that said amount was collected “prior to the Petition date.” [ECF 18 at ¶16]
L&Z contends that it holds an additional sum of $67,091.18 which has been allocated to
representation in potential adversary proceedings. [ECF 18 at ¶16] Again, no date of billing or
collection has been provided, though it again concedes the $67,091.18 was collected “prior to the
Petition date.” [ECF 18 at ¶16] In any event, the amounts owed and collected by L&Z were within
the 90 days prior to Debtor’s Petition.
In In re First Jersey Securities, Inc., 180 F.3d 504 (3d Cir.1999), the U.S. Trustee objected
to retention of the counsel proposed by the debtor in possession on the ground that counsel had
received a preferential payment, constituting an interest adverse to the estate. Notwithstanding that
both the bankruptcy court and the district court had approved counsel's retention, the court reversed.
The court stated “[w]here there is an actual conflict of interest ... disqualification is mandatory.” Id.
at 509 (citing In re Marvel Entertainment, 140 F.3d at 476). Then, in language that E/L here emphasizes, the court stated “[a] preferential transfer to [debtor's counsel] would constitute an
actual conflict of interest between counsel and the debtor, and would require the firm's
disqualification.” 180 F.3d at 509 (emphasis in original).
An avoidable preference is defined in section 547(b) of the Bankruptcy Code as:
any transfer of an interest of the debtor in property-(1) to or for the benefit of a
creditor; (2) for or on account of an antecedent debt owed by the debtor before
such transfer was made; (3) made while the debtor was insolvent; (4) made-(A)
on or within 90 days before the date of the filing of the petition; ... (5) that enables
such creditor to receive more than such creditor would receive [in a Chapter 7
distribution]. 11 U.S.C. § 547(b).
Because L&Z has taken and retained payments that may be preferential – as they were
collected within the 90 days prior to Debtor’s Petition – and it will not be advising Debtor to seek
recovery of payments made to L&Z, an actual conflict of interest exists today, and will continue to
exist if L&Z’s retention is approved. See 11 U.S.C. §101(10)(A) (creditor is an “entity that has a
claim against the debtor that arose at the time of or before the order for relief concerning the
debtor.”); §101(5)(A) (claim is a right to payment). And, therefore, L&Z is not disinterested for the
purposes of § 327(a). See In re Kings River Resorts, Inc., 342 B.R. 76, 88 (Bankr.E.D.Cal.2006)
(“A professional holding a potential prepetition claim against a debtor ... is a creditor of the estate
and therefore not ‘disinterested’ ....”).
C. The Application Does Not Contain a Detailed Description of the Work
Performed and the Amount Charged to Determine the Reasonableness of the
Fees Already Paid.
The application does not satisfy Rule 2016(a)’s requirement that an attorney seeking
compensation and/or reimbursement of expenses to file an application “setting forth a detailed
statement of
(1) the services rendered, time expended and expenses incurred, and
(2) the amounts requested.” In fact, L&Z nowhere detail how much they have been paid under what is termed “Retainer 2” – the retainer governing the filing and processing of the Chapter 11 case. Yet, L&Z hopes to obtain nunc pro tunc approval of the fees charged and collected without ever having to make the showing required under Rule 2016(a). This is improper.
If the court is not presented with detailed facts demonstrating how much was charged, for what services, and how it was charged, it cannot make the necessary determination that it was reasonable and benefitted the estate. The entire application must be denied for this reason alone.
D. The Court Should Not Approve a Retainer Agreement For Work That May Not
Be Performed.
The request for approval of what is termed “Retainer 3” is wholly unsupported by logic and
law. Apparently, the Debtor has paid L&Z a retainer of $30,000 – monies that are assets of the
estate – to hold in case L&Z is required to represent the Debtor in a potential adversary proceeding.
The Debtor cites to no authority that supports seeking, let alone obtaining, court approval to retain a
professional just in case an adversary proceeding is filed. The proper way to proceed would be for
the Debtor to return to court with an application to employ counsel to represent it in an adversary proceeding once that adversary proceeding is actually filed. "
"III. CONCLUSION
Because L&Z billed and collected sums from the Debtor’s in the 90-day period proceeding
Petition, such sums paid are preferential transfers and subject to clawback to the estate. As such,
L&Z will have a claim against the Debtor for sums owed pre-petition, will be a creditor of the
estate, and therefore not a disinterested party. L&Z’s Application must be denied on these grounds."
Vaughn M. Greenwalt
Attorneys for Creditors,
Excelsior Media Corp., and
Liberty Media Holdings, LLC."
Source and Filing
http://ia801505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.38.0.pdf
Randazza Legal Group; Marc Randazza Bankruptcy; Liberty Media Motion to Appear
"Motion to Appear Pro Hac Vice Filed by VAUGHN MICHAEL GREENWALT on behalf of LIBERTY MEDIA HOLDINGS, LLC, EXCELSIOR MEDIA CORP. (Attachments: # 1 Designation of Local Counsel)(GREENWALT, VAUGHN) (Entered: 10/02/2015)"
Filing
http://ia801505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.31.0.pdf
Filing
http://ia801505.us.archive.org/20/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.31.0.pdf
Thursday, October 8, 2015
Interested Parties in the Case, yet I, Crystal Cox was only allowed a counter complaint against Marc Randazza, not other parties nor the law firm he worked for when he represented me.
Per Docket Entry 7, the following are interested parties
Marc J. Randazza – Plaintiff
Jennifer Randazza – Plaintiff
Natalia Randazza – Plaintiff
Randazza Legal Group – Plaintiff Marc J. Randazza’s Law Firm
Yet I, Crystal Cox was only allowed to Countersue Marc Randazza, this is clearly a court error.
https://drive.google.com/file/d/0Bzn2NurXrSkiM3lCSlh5MEVraHc/view?usp=sharing
Clearly as a matter of LAW I should be able to counter sue Jennifer Randazza, Randazza Legal Group and this includes Ronald Green and California attorney D. Gill Sperlein, Gill Sperlein, who owns part of Randazza Legal Group. Yet Marc Randazza's bankruptcy attorney wants to protect all those parties as an attorney for one of them.
Not that the LAW applies to Randazza Legal Group, Just Sayin'
Marc J. Randazza – Plaintiff
Jennifer Randazza – Plaintiff
Natalia Randazza – Plaintiff
Randazza Legal Group – Plaintiff Marc J. Randazza’s Law Firm
Yet I, Crystal Cox was only allowed to Countersue Marc Randazza, this is clearly a court error.
PLAINTIFF’S CERTIFICATE OF INTERESTED PARTIES
https://drive.google.com/file/d/0Bzn2NurXrSkiM3lCSlh5MEVraHc/view?usp=sharing
Clearly as a matter of LAW I should be able to counter sue Jennifer Randazza, Randazza Legal Group and this includes Ronald Green and California attorney D. Gill Sperlein, Gill Sperlein, who owns part of Randazza Legal Group. Yet Marc Randazza's bankruptcy attorney wants to protect all those parties as an attorney for one of them.
Not that the LAW applies to Randazza Legal Group, Just Sayin'
Lying, Fraud on the Court Complaint, LANHAM Act, filed by Randazza Legal Group on behalf of Plaintiff Jennifer Randazza, infant child and Marc Randazza.
Here is the Lanham Act Complaint Randazza Legal Group filed to get around the First Amendment
My ex- attorney, Marc Randazza, filed this multi-million dollar complaint and STOLE my intellectual property to stop me from griping about him, reviewing him, calling him and his wife names and exercising my Free Speech Rights, my First Amendment Rights. And in the name of the Lanham Act.
Here is the Original Complaint against me and iViewit Video Technology inventor Eliot Bernstein.
https://drive.google.com/file/d/0Bzn2NurXrSkiTGcyTXZGZkMxbW8/view
Attorney Marc Randazza knew these lies were malicious and deliberate. He was my attorney and is a First Amendment expert. He knew this lawsuit was only to defame me, harass me, intimidate and bully me. This has been going on for years and now Marc Randazza files for bankruptcy to avoid counterclaims, after years of irreparable harm. He has a large list of co-conspirators, check out those I tried to countersue and how each one is connected to Marc J. Randazza.
My ex- attorney, Marc Randazza, filed this multi-million dollar complaint and STOLE my intellectual property to stop me from griping about him, reviewing him, calling him and his wife names and exercising my Free Speech Rights, my First Amendment Rights. And in the name of the Lanham Act.
Here is the Original Complaint against me and iViewit Video Technology inventor Eliot Bernstein.
https://drive.google.com/file/d/0Bzn2NurXrSkiTGcyTXZGZkMxbW8/view
Attorney Marc Randazza knew these lies were malicious and deliberate. He was my attorney and is a First Amendment expert. He knew this lawsuit was only to defame me, harass me, intimidate and bully me. This has been going on for years and now Marc Randazza files for bankruptcy to avoid counterclaims, after years of irreparable harm. He has a large list of co-conspirators, check out those I tried to countersue and how each one is connected to Marc J. Randazza.
Macquarie Holdings, Manwin, Blackstone.. lot's of money in Porn?
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Tuesday, October 6, 2015
Look at this Jackass, On and On, Yammer Yammer .. World's most Hypocritical Lying Attorney. Marc Randazza thinks it is a good thing for him that the FDA, Marc's alleged Buddies, are after Roca Labs. It does not change the Truth about Marc Randazza.
Consumers have a Right to Review You BET they Do.
It is a First Amendment ISSUE, oh yeah, unless you are a client of Marc Randazza and want to gripe about or review him, then it's LANHAM Act, game on and your First Amendment Rights are Stripped.
Check out this Gibberish.
"This is a First Amendment case,"said the website's attorney Marc Randazza. "The consumer has the right to share information. My client has a right to share that information."
Source
http://www.cbsnews.com/news/ftc-lawsuit-roca-labs-weight-loss-powder-gag-clause-customers-sued/
Ya YOU Evil Fuckhead, Consumers do have that right, yet those who have shared information about YOU and your corrupt, unconstitutional, evil, perverted, sick, lawless ways YOU sue them, invade their privacy, threaten them, make bomb threats to third parties, stalk them, hire investigators to follow them, SUE THEM, get into their phone records and bank accounts, shut down their rip off reports, shut down and / or steal their domain names, blogs, gripe sites and rip off reports.
But yeah umm duh, the consumer has rights to "share that information" as long as it's not about you or your EVIL law firm or co-conspirators. Then YOU personally ruin their life, quality of life and cause them years of suffering.
Regardless of what the FDA says in this case, or the issues that play out as a matter of LAW. Never forget what Roca Labs said about Marc Randazza and his gang stalking attorney buddies is TRUE and they have done it over and over to affect court case, bully and intimidate litigants and ruin lives in any way they can to get the outcome of their court case that they want.
I also ALLEGED that Marc Randazza has an IN, if not many, with Big Pharma, and connections at the FDA who will do as he wishes.
Kenneth White recently said:
"Roca Labs is mistaking aggression for strategy. Randazza, by filing his notice of related case, has alerted the federal court hearing the PissedConsumer.com case that Roca Labs is flailing around suing opposing lawyers, which will not go over well. Roca Labs has hired what appears to be an improbably matriculated Muppet to champion their case, despite a patent lack of qualifications. Roca Labs thinks that suing Marc Randazza to shut him up is going to end well. They should have asked Raanan Katz or Crystal Cox how that would turn out."
yes ASK Crystal Cox. I am Pleased with how things have turned out SO FAR. I have Exposed a THUG of a lying hypocritical asshole attorney, and hey I am just a one girl.
Hey Hypocritical LAWLESS Asshole Ken White, IT IS NOT aggressive to stand up to aggression. We are defending ourselves against YOUR ILLEGAL Attacks. There are tons of related cases. Randazza is unethical, and acts outside of the law in the same way over and over. The proof is EASY to see.
Tell the TRUTH. Do the RIGHT Thing.
Win or Lose ROCA LABS is the Tipping Point. As there is NO DENYING what YOU Randazza Legal Groupies do acting in conspiracy, aiding and abetting.
Whether the courts "believe" it or not, well that will be what it will be. But there is so much proof now, for you to keep Yammering the LIE is simply futile.
Ken White seems to think if you lie over and over it becomes the TRUTH, that is SIMPLY not a Reality based Notion or course of action as I See it.
Roca Labs Says:
"Despite being an Officer of the Court and a practicing member of the Florida Bar, RANDAZZA has waged his war against ROCA by intentionally and maliciously publishing many false and defamatory statements in his pleadings, with the intent to share them to his contacts in the media, and indeed by directly speaking to the media about ROCA with the intent to have them publish false, misleading and defamatory articles about ROCA, and by harassing and making derogatory statements about ROCA via his personal social media sites including his Twitter account"
Source and Full Legal Action against First Amendment PORN Attorney Marc Randazza aKa scumbag, hypocritical asshole, liar, and lawless.
https://s3.amazonaws.com/s3.documentcloud.org/documents/1357796/246279896-roca-labs-randazza-complaint.pdf"
It is a First Amendment ISSUE, oh yeah, unless you are a client of Marc Randazza and want to gripe about or review him, then it's LANHAM Act, game on and your First Amendment Rights are Stripped.
Check out this Gibberish.
"This is a First Amendment case,"said the website's attorney Marc Randazza. "The consumer has the right to share information. My client has a right to share that information."
Source
http://www.cbsnews.com/news/ftc-lawsuit-roca-labs-weight-loss-powder-gag-clause-customers-sued/
Ya YOU Evil Fuckhead, Consumers do have that right, yet those who have shared information about YOU and your corrupt, unconstitutional, evil, perverted, sick, lawless ways YOU sue them, invade their privacy, threaten them, make bomb threats to third parties, stalk them, hire investigators to follow them, SUE THEM, get into their phone records and bank accounts, shut down their rip off reports, shut down and / or steal their domain names, blogs, gripe sites and rip off reports.
But yeah umm duh, the consumer has rights to "share that information" as long as it's not about you or your EVIL law firm or co-conspirators. Then YOU personally ruin their life, quality of life and cause them years of suffering.
Regardless of what the FDA says in this case, or the issues that play out as a matter of LAW. Never forget what Roca Labs said about Marc Randazza and his gang stalking attorney buddies is TRUE and they have done it over and over to affect court case, bully and intimidate litigants and ruin lives in any way they can to get the outcome of their court case that they want.
I also ALLEGED that Marc Randazza has an IN, if not many, with Big Pharma, and connections at the FDA who will do as he wishes.
A bit on Previous Posts I have made on this site, regarding Roca Labs
Kenneth White recently said:
"Roca Labs is mistaking aggression for strategy. Randazza, by filing his notice of related case, has alerted the federal court hearing the PissedConsumer.com case that Roca Labs is flailing around suing opposing lawyers, which will not go over well. Roca Labs has hired what appears to be an improbably matriculated Muppet to champion their case, despite a patent lack of qualifications. Roca Labs thinks that suing Marc Randazza to shut him up is going to end well. They should have asked Raanan Katz or Crystal Cox how that would turn out."
yes ASK Crystal Cox. I am Pleased with how things have turned out SO FAR. I have Exposed a THUG of a lying hypocritical asshole attorney, and hey I am just a one girl.
Hey Hypocritical LAWLESS Asshole Ken White, IT IS NOT aggressive to stand up to aggression. We are defending ourselves against YOUR ILLEGAL Attacks. There are tons of related cases. Randazza is unethical, and acts outside of the law in the same way over and over. The proof is EASY to see.
Tell the TRUTH. Do the RIGHT Thing.
Win or Lose ROCA LABS is the Tipping Point. As there is NO DENYING what YOU Randazza Legal Groupies do acting in conspiracy, aiding and abetting.
Whether the courts "believe" it or not, well that will be what it will be. But there is so much proof now, for you to keep Yammering the LIE is simply futile.
YOUR game is OVER. The TRUTH IS OUT.
Ken White seems to think if you lie over and over it becomes the TRUTH, that is SIMPLY not a Reality based Notion or course of action as I See it.
Marc Randazza is the one that uses AGGRESSION instead of strategy.
Randazza bullies, he sues, he threatens, he steals banking and wire information, he calls your ex's and threatens them, he calls your customer and clients and threatens them, he forces information from your church, he violates your constitutional rights, he violates your privacy rights, he endangers your life, makes your private emails public, violates your client rights, allegedly threatens to throw bombs if he can get away with it rumor has it, and he posts the make and models of porn insiders cars and hopes death upon them.
Randazza is dangerously, violently, above the law AGGRESSIVE and so his his THUG gang stalking groupies and Randazza seems to think it's "Strategy".
100% FACT BELOW
"Despite being an Officer of the Court and a practicing member of the Florida Bar, RANDAZZA has waged his war against ROCA by intentionally and maliciously publishing many false and defamatory statements in his pleadings, with the intent to share them to his contacts in the media, and indeed by directly speaking to the media about ROCA with the intent to have them publish false, misleading and defamatory articles about ROCA, and by harassing and making derogatory statements about ROCA via his personal social media sites including his Twitter account"
Source and Full Legal Action against First Amendment PORN Attorney Marc Randazza aKa scumbag, hypocritical asshole, liar, and lawless.
https://s3.amazonaws.com/s3.documentcloud.org/documents/1357796/246279896-roca-labs-randazza-complaint.pdf"
NOW That is FACT whether a Court Agrees or NOT does not change that it is fact and the Randazza Legal Groupies do it over and over, year after year, case after case, target after target.
Marc Randazza uses the First Amendment to RUIN Lives, and if they right back he sues them, this enables him to pry into every corner of their life, relationships, family, business, bank accounts, church, phone records and to put them under constant threat and fear by him and his buddies.
Sunday, October 4, 2015
Marc Randazza is the BAD Guy in the Roca Labs Fiasco, Period. Regardless of the FDA
Randazza has NO ETHICS...
another eMail Exhibit lingering around the web
https://assets.documentcloud.org/documents/2086851/131-6.pdf
another eMail Exhibit lingering around the web
https://assets.documentcloud.org/documents/2086851/131-6.pdf
and The world's MOST hypocritical law firm strikes again. The Lanham Act should NOT be used by a Plaintiff to Violate the First AMENDMENT, oh yeah unless that Plaintiff is Marc Randazza or Jennifer Randazza of course, represented by Randazza Legal Group.
Can you Imagine a Plaintiff Misusing the Lanham Act to VIOLATE the First Amendment Rights of their VICTIM, other wise known as the Defendant?
Well Check out this Crap
https://randazza.wordpress.com/2015/10/02/lanham-act-doesnt-get-you-around-the-first-amendment/
" the Order should go in any First Amendment lawyer’s files — because this isn’t the first time I’ve seen a plaintiff try and get creative with the Lanham Act in free speech cases."
As you read this BULLSHIT, keep in mind that Marc Randazza, Randazza legal group sued iViewit Inventor Eliot Bernstein and Investigative Blogger Crystal Cox, me, for Millions, and took our intellectual property through an unconstitutional TRO and the Lanham Act for this blatant violation of our First Amendment Rights.
Randazza v. Cox has been removed from Archive.org, guess he wants to make the mess go away somehow, but the motions will all be uploaded elsewhere soon and the TRUTH will NEVER go away.
So no worries, the Order most certainly will be used to FIGHT back against Rogue, Lawless, Unconstitutional Attorneys such as Marc Randazza and the gang at Randazza Legal Group.
SO here is the Order that will be yet ANOTHER defense in the Randazza v. Cox case, District of Nevada. Ya know the Cause of Action Lanham Act.
Order Granting Motion for Summary Judgement
https://drive.google.com/file/d/0Bzn2NurXrSkiTWpFN2F4ZUhVdk0/view
Special Order Motion to Strike ( See Randazza is a BULLY, and a hypocrite. He has no facts to sue but still does and takes property and ruins lives, but then RLG gets the courts to rule the opposite for their own clients.)
https://drive.google.com/file/d/0Bzn2NurXrSkiRXZiV3N5dk9yRG8/view?usp=sharing
Marc Randazza nor his wife or child had ANY material FACTS to have sued Eliot Bernstein and Crystal Cox, yet they did.
Somehow our life, our life work, our personal and intellectual property, our quality of life, our health was / is of no worth to Marc Randazza and Randazza Legal Group. Yet the Randazza family and law firm gets far reaching unconstitutional rights and to use the power of the courts to oppress us, sue us, torment and harass us and yeah in the name of the LANHAM ACT.
...
Well Check out this Crap
https://randazza.wordpress.com/2015/10/02/lanham-act-doesnt-get-you-around-the-first-amendment/
" the Order should go in any First Amendment lawyer’s files — because this isn’t the first time I’ve seen a plaintiff try and get creative with the Lanham Act in free speech cases."
As you read this BULLSHIT, keep in mind that Marc Randazza, Randazza legal group sued iViewit Inventor Eliot Bernstein and Investigative Blogger Crystal Cox, me, for Millions, and took our intellectual property through an unconstitutional TRO and the Lanham Act for this blatant violation of our First Amendment Rights.
Randazza v. Cox has been removed from Archive.org, guess he wants to make the mess go away somehow, but the motions will all be uploaded elsewhere soon and the TRUTH will NEVER go away.
SO here is the Order that will be yet ANOTHER defense in the Randazza v. Cox case, District of Nevada. Ya know the Cause of Action Lanham Act.
Order Granting Motion for Summary Judgement
https://drive.google.com/file/d/0Bzn2NurXrSkiTWpFN2F4ZUhVdk0/view
Special Order Motion to Strike ( See Randazza is a BULLY, and a hypocrite. He has no facts to sue but still does and takes property and ruins lives, but then RLG gets the courts to rule the opposite for their own clients.)
https://drive.google.com/file/d/0Bzn2NurXrSkiRXZiV3N5dk9yRG8/view?usp=sharing
Marc Randazza nor his wife or child had ANY material FACTS to have sued Eliot Bernstein and Crystal Cox, yet they did.
Somehow our life, our life work, our personal and intellectual property, our quality of life, our health was / is of no worth to Marc Randazza and Randazza Legal Group. Yet the Randazza family and law firm gets far reaching unconstitutional rights and to use the power of the courts to oppress us, sue us, torment and harass us and yeah in the name of the LANHAM ACT.
...
Friday, October 2, 2015
Check out the Latest Legal Threat to me, Crystal Cox by yet another attorney of Marc J. Randazza. No worries this one was paid up front. So Let the Games Begin.
I have legal rights as a former client of Randazza Legal Group.
The lawsuit against me took domain names with the name Randazza Legal Group in the domain name. Ronald Green worked with Marc Randazza in representing me, Crystal Cox.
Jennifer Randazza and child SUED me for millions and still holds my personal property, not to mention has put my life in constant stress, duress and harassment for years. Yet Marc Randazza files bankruptcy and all my rights are allegedly stripped, even with other Plaintiffs.
Why is Marc Randazza's liability insurance NOT dealing with this?
What agency really does protect the clients of Rogue, Lawless attorneys such as Marc Randazza?
Marc Randazza illegally, unethically and unconstitutionally STOLE my intellectual property rights, my search engine placement and that on top of years of malicious harassment and then the SHITHEAD gets to file bankruptcy and freeze everything, even claims against other Plaintiff's ????
He and his baby and wife get to keep sue-ing me for millions and keep my personal PROPERTY, and counterclaims, motions, and yada yada fighting for my lawful, constitutional rights well that is NOT ALLOWED?
Well I DISAGREE.
The courts may protect guys like Marc J. Randazza but they will NOT due so without being exposed for it, even if that exposing does nothing. The Truth remains to be the truth.
Here is my First Communication from Marc J. Randazza's Bankruptcy attorney:
To Download
https://drive.google.com/file/d/0Bzn2NurXrSkiZXhDRDZqeEJoakk/view
I, of course will not vacate. The courts will most likely dismiss my motions anyway. However, I do have a right to request from the courts that they take actions against Ronald Green, Randazza Legal Group and Jennifer Randazza, as they are involved in my case. Jennifer Randazza sued me and does not get to file divorce, run off with assets, and I have no counterclaims allowed?
The above attorney does not represent Jennifer Randazza but is still threatening me?
Well I guess I will soon be getting some sancations and have to pay some attorney fees from my NO Money homeless status that Ronald Green, Randazza Legal Group and Jennifer Randazza, along with Marc J. Randazza put me in.
How can Marc Randazza stop his claims against ME with a stay for him going bankrupt? I know the loopholes allow for this but it is not ethical nor constitutional. Attorneys should not be allowed to do this, as a matter of law.
How does he work the system and always end up on top while he violates his clients rights over and over?
THE Law does apply to attorneys like Marc Randazza, no matter what attorneys like Larson may think.
I allege this bankruptcy a fraud on the courts and on Randazza Legal Group clients. And including Jennifer Randazza and Ronald Green personally and professionally. As they both are / were part of Randazza Legal Group and own part and sued me.
So I let Mr. Bankruptcy Attorney know that he does not represent Jennifer Randazza in this case, guess he got confused a bit, and so No, NOPE, Nada. So I expect for them to rough me up soon. Stay Tuned, I will probably get a Million dollar sanction, and have to pay a Zillion in attorney fees. Hmmm.. Good Luck with that.
Stay Tuned
Oh and here are the motions I filed. Not sure how Marc Randazza's bankruptcy attorney can speak on behalf of Jennifer Randazza, Ronald Green and Randazza Legal Group, but hey I guess lawyers know the law right?
I asked the courts to reconsider allowing my right of due process to counterclaim Jennifer Randazza and to add Ronald Green and Randazza Legal Group and Marc Randazza's bankrutpcy attorney claims this is pursuing Marc. Well it's NOT. And it is not several motions, it was a motions to add the above and a motion asking the court permission to file another.
Motion to Reconsider
https://docs.google.com/document/d/17UXoEQnzh1yDOD1B84tk1WiP98U5sDEPaivXsllj-wE/edit?usp=sharing
Motion requesting Court Permission to file Motion
https://docs.google.com/document/d/1W25Zcla7clT7HekZLRo2BRvM5XcIQn4CRXZtxRzjnJk/edit?usp=sharing
The lawsuit against me took domain names with the name Randazza Legal Group in the domain name. Ronald Green worked with Marc Randazza in representing me, Crystal Cox.
Jennifer Randazza and child SUED me for millions and still holds my personal property, not to mention has put my life in constant stress, duress and harassment for years. Yet Marc Randazza files bankruptcy and all my rights are allegedly stripped, even with other Plaintiffs.
Why is Marc Randazza's liability insurance NOT dealing with this?
What agency really does protect the clients of Rogue, Lawless attorneys such as Marc Randazza?
Marc Randazza illegally, unethically and unconstitutionally STOLE my intellectual property rights, my search engine placement and that on top of years of malicious harassment and then the SHITHEAD gets to file bankruptcy and freeze everything, even claims against other Plaintiff's ????
He and his baby and wife get to keep sue-ing me for millions and keep my personal PROPERTY, and counterclaims, motions, and yada yada fighting for my lawful, constitutional rights well that is NOT ALLOWED?
Well I DISAGREE.
The courts may protect guys like Marc J. Randazza but they will NOT due so without being exposed for it, even if that exposing does nothing. The Truth remains to be the truth.
Here is my First Communication from Marc J. Randazza's Bankruptcy attorney:
To Download
https://drive.google.com/file/d/0Bzn2NurXrSkiZXhDRDZqeEJoakk/view
I, of course will not vacate. The courts will most likely dismiss my motions anyway. However, I do have a right to request from the courts that they take actions against Ronald Green, Randazza Legal Group and Jennifer Randazza, as they are involved in my case. Jennifer Randazza sued me and does not get to file divorce, run off with assets, and I have no counterclaims allowed?
The above attorney does not represent Jennifer Randazza but is still threatening me?
Well I guess I will soon be getting some sancations and have to pay some attorney fees from my NO Money homeless status that Ronald Green, Randazza Legal Group and Jennifer Randazza, along with Marc J. Randazza put me in.
How can Marc Randazza stop his claims against ME with a stay for him going bankrupt? I know the loopholes allow for this but it is not ethical nor constitutional. Attorneys should not be allowed to do this, as a matter of law.
How does he work the system and always end up on top while he violates his clients rights over and over?
THE Law does apply to attorneys like Marc Randazza, no matter what attorneys like Larson may think.
I allege this bankruptcy a fraud on the courts and on Randazza Legal Group clients. And including Jennifer Randazza and Ronald Green personally and professionally. As they both are / were part of Randazza Legal Group and own part and sued me.
So I let Mr. Bankruptcy Attorney know that he does not represent Jennifer Randazza in this case, guess he got confused a bit, and so No, NOPE, Nada. So I expect for them to rough me up soon. Stay Tuned, I will probably get a Million dollar sanction, and have to pay a Zillion in attorney fees. Hmmm.. Good Luck with that.
Stay Tuned
Oh and here are the motions I filed. Not sure how Marc Randazza's bankruptcy attorney can speak on behalf of Jennifer Randazza, Ronald Green and Randazza Legal Group, but hey I guess lawyers know the law right?
I asked the courts to reconsider allowing my right of due process to counterclaim Jennifer Randazza and to add Ronald Green and Randazza Legal Group and Marc Randazza's bankrutpcy attorney claims this is pursuing Marc. Well it's NOT. And it is not several motions, it was a motions to add the above and a motion asking the court permission to file another.
Motion to Reconsider
https://docs.google.com/document/d/17UXoEQnzh1yDOD1B84tk1WiP98U5sDEPaivXsllj-wE/edit?usp=sharing
Motion requesting Court Permission to file Motion
https://docs.google.com/document/d/1W25Zcla7clT7HekZLRo2BRvM5XcIQn4CRXZtxRzjnJk/edit?usp=sharing
Attorneys are not above the LAW. Attorneys should NOT be aided and abetted by Bankruptcy Courts to cause malicious, deliberate, willful, premeditated harm to their clients and then get a free pass clearing the slate for them to do it to more clients.
Say your attorney deliberately, knowingly violates your rights, defames you, harasses and threatens you, ruins your business, family and friend connections. He lies about you to big media, to radio and in legal blogs and courts around the world. He provides false sworn statements to the courts, conspires with people and companies on all sides of the case, and puts your life under constant harassment and duress for years. Then he SUES you for millions when you speak out or reach out to authorities for help. You countersue him and prove that he is the bad guy, then he cry babies to the bankruptcy courts to protect his harmful, deliberate, MALICIOUS, privacy and rights violating, constitutional violating actions against you.
Then he is CLEARED and continues making money, harming clients and life goes on. While he has ruined yours.
It is NOT ok for Attorneys to do this to their clients or former clients. It is cruel, deliberate, malicious harm done to their client and then the attorney, Marc in this case, sues them and when the client countersues, and they get caught then they simply file for bankruptcy.
If the courts allow this then there is no need for laws protecting attorney's clients, no need for ethics or the bar association, as attorneys will do as they please and maliciously harm their clients or former clients with willful intent and then simply file bankruptcy so the client cannot exercise their rights.
I continue to try and expose injustice in the courts. This is my filing objecting to Marc Randazza having the courts clean his slate. Odds are he will get the courts to do as he wants, as usual. However, at least I have told the truth to the best of my ability in the hopes that he creates no more victims.
Here is my filed OBJECTION.
https://drive.google.com/file/d/0Bzn2NurXrSkiakxiVU8tZjU4OVk/view?usp=drive_web
Then he is CLEARED and continues making money, harming clients and life goes on. While he has ruined yours.
It is NOT ok for Attorneys to do this to their clients or former clients. It is cruel, deliberate, malicious harm done to their client and then the attorney, Marc in this case, sues them and when the client countersues, and they get caught then they simply file for bankruptcy.
If the courts allow this then there is no need for laws protecting attorney's clients, no need for ethics or the bar association, as attorneys will do as they please and maliciously harm their clients or former clients with willful intent and then simply file bankruptcy so the client cannot exercise their rights.
I continue to try and expose injustice in the courts. This is my filing objecting to Marc Randazza having the courts clean his slate. Odds are he will get the courts to do as he wants, as usual. However, at least I have told the truth to the best of my ability in the hopes that he creates no more victims.
Here is my filed OBJECTION.
https://drive.google.com/file/d/0Bzn2NurXrSkiakxiVU8tZjU4OVk/view?usp=drive_web
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