Tuesday, October 31, 2017
Be Reminded Creditors to Check out Randazza vs. Cox as a BIG part of that case is about Marc Randazza (Debtor) claiming that I, Crystal Cox used a Proxy to hide Assets such as Domain Names, yet I don't believe that Randazza has listed Domain Names or Web Properties as Assets on His Bankruptcy. I will be filing more in the Bankruptcy Courts regarding this, Stay Tuned, for now be aware there are More Assets.
Much more Coming Soon on this Topic in Great Detail
Sunday, October 29, 2017
In Randazza v. Cox, Nevada Judge Gloria Navarro issued an unconstitutional TRO against Blogger Crystal Cox and Gave Marc Randazza massive online content and intellectual property. Thereby shutting down Cox's speech and flat out stealing blogs, online content and redirecting MY WORK and PROPERTY to Randazza's Legal Blog SLAMMING me and Promoting him and his law firm. In that Case it was OK and seemingly Lawful for a Federal Judge to go ahead and take my Constitutional Rights. Check Out this case below where WORLDS Most Hypocritical Lawyer Marc Randazza Makes the OPPOSITE CASE AGAIN.
"In the motion to dissolve the order, attorney Marc Randazza points out that fashioning a libel lawsuit as a tortious interference lawsuit doesn't change the ultimate goal of the litigation: to silence criticism."
"Judge Decides Free Speech Is Still A Right;
Dumps Prior Restraint Order Against Mattress Review Site
Source of Above and Full Hypocritical Filing
"Before the court are Plaintiff’s Motion for Order to Show Cause Why Defendants Should
"For the foregoing reasons, and for those expressed in the parties’ briefing and oral
Questions or Tips??? eMail me at ReverendCrystalCox@Gmail.com
"Judge Decides Free Speech Is Still A Right;
Dumps Prior Restraint Order Against Mattress Review Site
A couple of weeks ago, a federal judge in Utah decided prior restraint was the best way to handle a recently-filed defamation suit against Honest Mattress Reviews by Purple Innovations, makers of the Purple Mattress.
Purple's lengthy filing contained numerous allegations of harm caused by Honest Mattress Reviews' extended commentary on the white plastic powder covering every mattress Purple ships. It also alleged HMR was just a front for site owner Ryan Monahan's brand management work with Purple's competitor, Ghostbed. Rather than give HMR a chance to respond, the judge decided the review site could publish nothing further about Purple or the lawsuit. It wasn't even allowed to refer to its previous rating of Purple's mattress.
Honest Mattress Review didn't care much for this decision -- one it had been given no chance to contest. It immediately posted an article about the case and offered to comply with the letter of the order, but perhaps not its spirit.
This temporary order commands that we take down all reviews, and even cease rating this company with a rating of “Poor.” Yes, indeed, we are no longer even permitted to rate this company as Poor. I guess we will change its rating to “💩.”[...]Do you trust a company that, rather than compete in the marketplace, decides that it will just try and sue negative reviews out of existence?
Purple Innovations immediately returned to court, demanding it find HMR in contempt of its order, in particular pointing to the poo emoji and HMR's claims about the unconstitutionality of the order and Purple's alleged disingenuousness in filing the libel suit.
That review has since been reinstated and given this header image.
And HMR has published a long list of court documents it has filed in this case. This includes a motion to dissolve the restraining order and a preliminary examination of the powdery substance Purple claims is harmless and that HMR claims could be hazardous to purchasers' health.
The action is a quintessential SLAPP suit designed to suppress negative consumer journalism. Plaintiffs have cleverly attempted to disguise this defamation claim as a Lanham Act claim – presumably to ensure the availability of Federal Court jurisdiction and to try to side-step the clear case law that cuts against them in defamation actions. But, no matter how eloquently someone may call a “dog” a “chicken,” it will never lay eggs. And styling a specious defamation claim as a Lanham Act claim does not remove the underlying speech from the protections afforded by the First Amendment.
He also points out that Purple's claims that the plastic packing dust is harmless haven't been supported by anything Purple's willing to let customers and competitors view. Instead, it's only made vague assertions about its safety. And those statements are ultimately meaningless when examined closely.
Plaintiff sells mattresses that are made of a rubber honeycomb, which they then dust with a powder that they claim is made of plastic and has been shown to be polyethylene microspheres. In other words, someone who sleeps on these mattresses would be expected to inhale these microspheres. The Plaintiff claims that it is “non toxic” and “food grade” plastic – but this does not assuage the concerns. After all, a plastic fork is “food grade” and “non toxic” but you most certainly would not want to actually eat it. The same goes for what a person wants to put in their lungs. It was reasonable to be concerned about this “plastic powder” since (a) if the particles that make up this plastic “powder” are of a certain size, they will pass through the alveoli into the bloodstream; or (b) if they are a bit larger, they will simply lodge themselves inside the lungs.
To support its claims, HMR put a Harvard Professor of Pathology to work. Dr. John Godleski's report[PDF] is far from complete at this point, but what's contained in his preliminary examination of the powder doesn't appear to agree with Purple's assertions of harmlessness.
By Fourier Transformed Infrared spectroscopy (FTIR), the white powder particles were shown to be polyethylene, and the purple frame was found to be polyethylene-polypropylene copolymer. The foam portion of the mattress is still understudy, but has characteristics of butadiene, and may be a form of butadiene polymer.Polyethylene is a common plastic formed into many structures. As inhalable microspheres, these have the potential to cause respiratory irritation especially when inhaled in large numbers as shown in my laboratory (1- 4). In addition, polyethylene has been associated with allergy in the form of either asthma or contact dermatitis in sensitized individuals (5-7). Based on this assessment, it is important for consumers to be aware of the composition of this fine particulate matter in the mattress which may be released into the air and has the potential for the development of respiratory or dermal hypersensitivity in some individuals.
Also included in the filed documents is an affidavit that undercuts Purple's claims about HMR's site owner being a competitor's "brand manager." This is central to Purple's Lanham Act claims -- the claims it's using to sidestep anti-SLAPP motions. The affidavit from the competitor (Ghostbed) notes HMR's site owner has never been directly employed by Ghostbed and that Ghostbed told him to stop referring to himself as its "brand manager" after noticing that statement on his Twitter profile.
The judge presiding over the case appears to have been overwhelmed by the pile of documents landing on his desk. A short order [PDF] issued on the 15th shows what can happen when a normally adversarial process is allowed to be, you know, adversarial.
For the reasons set forth in the parties’ briefing and at oral argument, the court finds a lack of “clear and unequivocal” support for a right to relief that is necessary for the entry of the “extraordinary remedy” of a preliminary injunction. Greater Yellowstone Coal v. Flowers, 321 F.3d 1250, 1256 (10th Cir. 2003). As such, the court hereby grants Defendants’ motions to dissolve the Temporary Restraining Order (Dkt. No. 36), and denies Plaintiff’s oral Motion to convert the Temporary Restraining Order into a Preliminary Injunction. The court similarly denies Plaintiff’s Motion for Leave to Conduct Expedited Discovery (Dkt. No. 39) and Motion for Order to Show Cause Why Defendants Should not be Held in Contempt (Dkt. No. 17). The court further denies Defendants’ request for sanctions, finding that such sanctions are not warranted here.
The restraining order is lifted and HMR's turd-laced post isn't in danger of being found contemptuous. The lawsuit should continue in a more constitutional fashion from this point forward.
Source
"Conclusion and Relief Sought
Because Defendants are likely to succeed on a motion to vacate the TRO, before this Court or on appeal, a stay of the TRO is warranted. Defendants’ fundamental First Amendment rights must not be stymied by the speculations of a Plaintiff who wishes to shut down discussion rather than answer legitimate questions, no matter how hyperbolically raised. Plaintiff has no likelihood of success on its underlying claims and was not entitled to the TRO.
Case 2:17-cv-00138-DB Document 28 Filed 03/09/17 Page 23 of 25
- 24 -
The exigency and urgency of dissolving this temporary restraining order can not be
overstated. Even a temporary suppression of First Amendment rights is itself irreparable harm.
However, given that this is information consumers need to make an informed decision about the health risks inherent in use of the Purple Mattress, even a temporary suppression of this information could be the proximate cause of actual illness or injury."
" Plaintiff is clearly aggressively intent on suppressing this information. At this point, the reporting has been shored up by the expert report of Dr. Godleski. The Purple Mattress, as currently manufactured, appears to be a public health hazard. This Court should abide no further censorship. "
Source of Above and Full Hypocritical Filing
Judge Grants Randazza's Order. To bad I did not have this judge when Randazza got a TRO against me in Randazza v. Cox
"Before the court are Plaintiff’s Motion for Order to Show Cause Why Defendants Should
not be Held in Contempt (Dkt. No. 17), Defendants Ryan Monahan and Honest Reviews, LLC’s
Emergency Motion to Stay and Dissolve Temporary Restraining Order (Amended) (Dkt. No. 28), Defendant Ghostbed Inc.’s Motion to Dissolve the Temporary Restraining Order (Dkt. No. 36),
"For the reasons set forth in the parties’ briefing and at oral argument, the court finds a
lack of “clear and unequivocal” support for a right to relief that is necessary for the entry of the “extraordinary remedy” of a preliminary injunction. Greater Yellowstone Coal v. Flowers, 321 F.3d 1250, 1256 (10th Cir. 2003). As such, the court hereby grants Defendants’ motions to dissolve the Temporary Restraining Order (Dkt. No. 36), and denies Plaintiff’s oral Motion to convert the Temporary Restraining Order into a Preliminary Injunction. "
"For the foregoing reasons, and for those expressed in the parties’ briefing and oral
arguments, Docket Numbers 17 and 39, as well as Plaintiff’s oral Motion to convert the
Temporary Restraining Order into a Preliminary Injunction, are hereby DENIED. Docket
Number 28 and the portion of Docket Number 36 requesting dissolution of the Temporary
Restraining Order are GRANTED. Defendants’ request for sanctions is DENIED."
Source of Above and Full Judicial Order
Check out Randazza v. Cox Docket and See how to REALLY use prior restraint to suppress speech and flat out steal online content AND top search engine placement.
Lot's More Coming SOON on how to us a TRO effectively to Steal Content, Steal Search Engine Placement, Steal Intellectual Property and More. As inspired by Randazza Legal Group, Marc Randazza, J. DeVoy and Ronald Green.
Saturday, October 28, 2017
Marc Randazza did NOT have a reasonable or even a high probability of prevailing at a Trial. Yet Judge Gloria Navarro gave him my PROPERTY and Search Engine Ranking just like that.
Marc Randazza NEVER had a Case against Crystal Cox, yet he STOLE my Intellectual Property, my Online Content, My Search Engine Ranking and directed my work product, my property to a blog post on his law blog SLAMMING ME.
Marc Randazza did NOT have a reasonable or even a high probability of prevailing on the causes of action he sued me for. Yet Judge Gloria Navarro gave Marc Randazza my PROPERTY. Nearly 5 years have passed and he has used my intellectual property to direct traffic to his legal blog for his own benefit. Judge Navarro did this through an UNCONSTITUTIONAL TRO.
Marc Randazza had NO VALID CLAIMS as clearly seen in the DENIAL of his Summary Judgement, Document 200, as seen below.
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
Here we are 5 years later and no end in sight. Seems to me that sure is a good way to steal websites, blogs, online content, search ranking, intellectual property while at the same time defaming your target on your own blog with their domain names now linking to you. And you wipe out critical speech in one be UNCONSTITUTIONAL swoop.
Marc Randazza NEVER had a Case against, yet he used his power as an officer of the court to steal my property and ruin my life.
In cases such as Randazza v. Cox, when someone disputes a name, as I have had this happen before, well it is locked and stays pointed to the servers it is pointed at until due process, until a court ruling on said names. Not with Randazza, he had Godaddy give him the names and let him redirect servers to his HATEFUL, Defaming Blog about me, Crystal Cox, his former Client.
Marc Randazza did NOT have a reasonable or even a high probability of prevailing on the causes of action he sued me for. Yet Judge Gloria Navarro gave Marc Randazza my PROPERTY. Nearly 5 years have passed and he has used my intellectual property to direct traffic to his legal blog for his own benefit. Judge Navarro did this through an UNCONSTITUTIONAL TRO.
Marc Randazza had NO VALID CLAIMS as clearly seen in the DENIAL of his Summary Judgement, Document 200, as seen below.
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
Here we are 5 years later and no end in sight. Seems to me that sure is a good way to steal websites, blogs, online content, search ranking, intellectual property while at the same time defaming your target on your own blog with their domain names now linking to you. And you wipe out critical speech in one be UNCONSTITUTIONAL swoop.
Marc Randazza NEVER had a Case against, yet he used his power as an officer of the court to steal my property and ruin my life.
In cases such as Randazza v. Cox, when someone disputes a name, as I have had this happen before, well it is locked and stays pointed to the servers it is pointed at until due process, until a court ruling on said names. Not with Randazza, he had Godaddy give him the names and let him redirect servers to his HATEFUL, Defaming Blog about me, Crystal Cox, his former Client.
Thursday, October 26, 2017
Supporter Of Revenge Porn, Attorney Marc Randazza Facing IMMINENT Disbarment Hearing In Nevada – 100% VERIFIED!
" We are pleased to tell you all that on April 19, 2016, a screening panel of the Nevada State Bar unanimously voted to accept this grievance and to initiate disbarment proceedings against Randazza.
The State Bar will file a disciplinary complaint shortly. Randazza will have a chance to respond to that and then a date for a formal hearing will be set. Evidence is presented at the hearing, and a three-member panel (2 attorneys & 1 lay person) will decide on what discipline (if any) to impose on Randazza.
That assumes that there is no agreed-upon discipline recommended by the parties (i.e. a plea bargain). If that happens, a “conditional guilty plea” agreement would be prepared and be presented to a three-member panel, and they would either accept it, accept it with modifications, or reject it."
"We would invite you to check it out. It’s pretty funny what a piece of garbage this Randazza guy is and what a total criminal and an ass-clown he turned out to be – Seriously, 100% VERIFIED!"
Source and Lot's of Good Reading about the World's most Hypocritical Attorney Marc Randazza
http://www.viaviewfiles.net/uncategorized/supporter-revenge-porn-attorney-marc-randazza-facing-disbarment-nevada-100-verified/
Marc Randazza Bar Complaint
https://fightcopyrighttrolls.files.wordpress.com/2016/08/marc_randazza_casenoobc15-0747.pdf
The State Bar will file a disciplinary complaint shortly. Randazza will have a chance to respond to that and then a date for a formal hearing will be set. Evidence is presented at the hearing, and a three-member panel (2 attorneys & 1 lay person) will decide on what discipline (if any) to impose on Randazza.
That assumes that there is no agreed-upon discipline recommended by the parties (i.e. a plea bargain). If that happens, a “conditional guilty plea” agreement would be prepared and be presented to a three-member panel, and they would either accept it, accept it with modifications, or reject it."
"We would invite you to check it out. It’s pretty funny what a piece of garbage this Randazza guy is and what a total criminal and an ass-clown he turned out to be – Seriously, 100% VERIFIED!"
Source and Lot's of Good Reading about the World's most Hypocritical Attorney Marc Randazza
http://www.viaviewfiles.net/uncategorized/supporter-revenge-porn-attorney-marc-randazza-facing-disbarment-nevada-100-verified/
Marc Randazza Bar Complaint
https://fightcopyrighttrolls.files.wordpress.com/2016/08/marc_randazza_casenoobc15-0747.pdf
Marc J. Randazza, Randazza Legal Group Tactics Used by Attorneys to Bully and Harass Litigants by Blogger Crystal Cox
#MarcRandazza #RandazzaLegalGroup #JudicialRetaliation #GangStalkingAttorneys
Have a Marc Randazza Tip? eMail me at ReverendCrystalCox@Gmail.com
Have a Marc Randazza Tip? eMail me at ReverendCrystalCox@Gmail.com
Complaint for Nondischargeability of Debts Filed by LIBERTY MEDIA HOLDINGS, LLC, EXCELSIOR MEDIA CORP. vs. MARC JOHN RANDAZZA
"83 Filed: 11/30/2015,
Entered: 11/30/2015
Complaint Adversary case 15-01193.
Complaint for Nondischargeability of Debts Filed by LIBERTY MEDIA HOLDINGS, LLC, EXCELSIOR MEDIA CORP. vs. MARC JOHN RANDAZZA
(Attachments: # 1 Discovery Plan # 2 Adversary Proceeding Procedures # 3 Exhibit 1- IAA) (62 (Dischargeability - 523(a)(2), false pretenses, false representation, actual fraud)(67 (Dischargeability - 523(a)(4), fraud as fiduciary, embezzlement, larceny)(GREENWALT, VAUGHN) (Entered: 11/30/2015).
Source and More
https://www.plainsite.org/dockets/2nc6vzk35/nevada-bankruptcy-court/marc-john-randazza/
COMPLAINT
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.83.0.pdf
Entered: 11/30/2015
Complaint Adversary case 15-01193.
Complaint for Nondischargeability of Debts Filed by LIBERTY MEDIA HOLDINGS, LLC, EXCELSIOR MEDIA CORP. vs. MARC JOHN RANDAZZA
(Attachments: # 1 Discovery Plan # 2 Adversary Proceeding Procedures # 3 Exhibit 1- IAA) (62 (Dischargeability - 523(a)(2), false pretenses, false representation, actual fraud)(67 (Dischargeability - 523(a)(4), fraud as fiduciary, embezzlement, larceny)(GREENWALT, VAUGHN) (Entered: 11/30/2015).
Source and More
https://www.plainsite.org/dockets/2nc6vzk35/nevada-bankruptcy-court/marc-john-randazza/
COMPLAINT
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.83.0.pdf
"“Everybody deserves to have their constitutional rights defended,” Randazza said"
Oh UNLESS you are Speaking Critical of Marc Randazza, his Law Firm Randazza Legal Grop or his wife. But ya everyone else.
Source of Quote
https://www.seattletimes.com/nation-world/first-amendment-lawyer-defending-neo-nazi-website-publisher/
Source of Quote
https://www.seattletimes.com/nation-world/first-amendment-lawyer-defending-neo-nazi-website-publisher/
the Audacity to Believe that he is qualified to teach others a thing or two. Don't Ya Just Love this Summary Judgement DENIAL proving Marc Randazza's malicious intent in Suing Blogger Crystal Cox.?
"On his blog, he goes to great lengths to explain “why [he has] the audacity to believe that [he is] qualified to teach [others] a thing or two.”
He touts himself as having “experience and expertise in all areas of First Amendment and entertainment law matters.”
He boasts about “get[ting] to fight ‘the good fight’ – protecting all of our First Amendment freedoms,” and openly proclaims that he has “represented adult entertainment establishments against socially conservative communities.”
Randazza v. Cox, Summary Judgement DENIAL Because the Randazzas' had no claims and simply filed this lawsuit to harass Crystal Cox and Eliot Bernstein. So it pretty much HIGHLIGHTS the Collusion that Judge Gloria Navarro had with Randazza in giving him my Intellectual Property, wiping out my online content, stealing search engine placement, violating my due process rights and claiming that Randazza would likely prevail so Navarro Granted Randazza's TRO and gave him my property and online content and let Randazza take the name 5 years ago and counting and he redirected my intellectual property to a blog post where he maliciously defamed me, Crystal Cox, his former client.
Source, Doc. 200
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
He touts himself as having “experience and expertise in all areas of First Amendment and entertainment law matters.”
He boasts about “get[ting] to fight ‘the good fight’ – protecting all of our First Amendment freedoms,” and openly proclaims that he has “represented adult entertainment establishments against socially conservative communities.”
Randazza v. Cox, Summary Judgement DENIAL Because the Randazzas' had no claims and simply filed this lawsuit to harass Crystal Cox and Eliot Bernstein. So it pretty much HIGHLIGHTS the Collusion that Judge Gloria Navarro had with Randazza in giving him my Intellectual Property, wiping out my online content, stealing search engine placement, violating my due process rights and claiming that Randazza would likely prevail so Navarro Granted Randazza's TRO and gave him my property and online content and let Randazza take the name 5 years ago and counting and he redirected my intellectual property to a blog post where he maliciously defamed me, Crystal Cox, his former client.
Source, Doc. 200
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
Wednesday, October 25, 2017
Marc Randazza Bankruptcy Challenges by Liberty Media
Marc Randazza Bankruptcy and Liberty Media
"In the meantime, Randazza's old employer, Liberty Media, is challenging his Nevada court filing seeking Chapter 11 bankruptcy protection. In that filing, Randazza claimed assets of up to $10 million, and liabilities of up to $50 million. Randazza included in his liabilities a potential $10 million judgement against him in a lawsuit with a blogger, Crystal Cox of Washington; $1 million to Liberty; as well as another $1 million judgement against him in a lawsuit he's embroiled in with Roca Labs of Largo, Florida."
Source and More
http://1701news.com/node/1183/so-who-klingon-lawyer-marc-randazza.html
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 andhis allegedly estranged wife have initiated sealed divorce proceedings, and dissipated assets."
"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."
"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.”
"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 second was for potential nondischargeability litigation. "
"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)."
Source and Full Filing
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.38.0.pdf
Liberty Media Move for Order to Modify Stay
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.0.pdf
Doc. 60-2 to above Motion
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.2.pdf
Motion to Confirm Arbitration Award Exhibit - 60-6
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.6.pdf
Liberty Media Reply
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.80.0.pdf
COMPLAINT by Liberty Media and Others to Determine Non-Dischargeable Debt
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.83.0.pdf
Doc. 120 filed by Liberty Media, First Amended Complaint, Demand for Jury Trial
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.120.0.pdf
Marc Randazza Bankruptcy Case Docket
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.docket.html
Doc. 148 Settlement
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.148.0.pdf
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.157.0.pdf
EX PARTE APPLICATION FOR ORDER DIRECTING EXAMINATION
PURSUANT TO FED.R.BANKR.P.2004 OF MARC J. RANDAZZA
"Creditors Excelsior Media Corp. (“Excelsior”) and Liberty Media Holdings, LLC
(“Liberty” and together with Excelsior, “Creditors”), by and through their counsel, James D.
Greene, Esq. of Greene Infuso, LLP pursuant to section 105 of the Bankruptcy Code and Rule
2004 of the Federal Rules of Bankruptcy Procedure and Rule 2004 of the Local Rules of
Bankruptcy Practice and Procedure, hereby apply to the Court for entry of order directing Debtor
Marc J. Randazza (“Debtor”) to appear for and submit to examination under oath before certified court reporter at the office of Greene Infuso, LLP, 3030 South Jones Blvd. Suite 101, Las Vegas, Nevada 89146 on a date and time to be determined, providing that notice of said examination is to be provided no less than 10 judicial days before such examination date. In support of this
application (“Application”), Creditors state as follows:
Above Order Granted
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.188.0.pdf
Doc. 191 Liberty Media SUPPLEMENTAL BRIEF IN SUPPORT
OF MOTION FOR ORDER CONFIRMING INTERIMARBITRATION AWARD
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.191.0.pdf
CAN YOU SAY PATTERN AND HISTORY ???
"In the meantime, Randazza's old employer, Liberty Media, is challenging his Nevada court filing seeking Chapter 11 bankruptcy protection. In that filing, Randazza claimed assets of up to $10 million, and liabilities of up to $50 million. Randazza included in his liabilities a potential $10 million judgement against him in a lawsuit with a blogger, Crystal Cox of Washington; $1 million to Liberty; as well as another $1 million judgement against him in a lawsuit he's embroiled in with Roca Labs of Largo, Florida."
Source and More
http://1701news.com/node/1183/so-who-klingon-lawyer-marc-randazza.html
Liberty Media Opposition Motion (Doc. 38)
"In an effort to avoid payment of the entire monetary component of the IAA, and before theIAA 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 andhis allegedly estranged wife have initiated sealed divorce proceedings, and dissipated assets."
"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."
"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.”
"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 second was for potential nondischargeability litigation. "
"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)."
Source and Full Filing
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.38.0.pdf
Liberty Media Move for Order to Modify Stay
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.0.pdf
Doc. 60-2 to above Motion
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.2.pdf
Motion to Confirm Arbitration Award Exhibit - 60-6
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.6.pdf
Liberty Media Reply
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.80.0.pdf
COMPLAINT by Liberty Media and Others to Determine Non-Dischargeable Debt
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.83.0.pdf
Doc. 120 filed by Liberty Media, First Amended Complaint, Demand for Jury Trial
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.120.0.pdf
Marc Randazza Bankruptcy Case Docket
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.docket.html
Doc. 148 Settlement
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.148.0.pdf
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.157.0.pdf
EX PARTE APPLICATION FOR ORDER DIRECTING EXAMINATION
PURSUANT TO FED.R.BANKR.P.2004 OF MARC J. RANDAZZA
Doc. 187
(“Liberty” and together with Excelsior, “Creditors”), by and through their counsel, James D.
Greene, Esq. of Greene Infuso, LLP pursuant to section 105 of the Bankruptcy Code and Rule
2004 of the Federal Rules of Bankruptcy Procedure and Rule 2004 of the Local Rules of
Bankruptcy Practice and Procedure, hereby apply to the Court for entry of order directing Debtor
Marc J. Randazza (“Debtor”) to appear for and submit to examination under oath before certified court reporter at the office of Greene Infuso, LLP, 3030 South Jones Blvd. Suite 101, Las Vegas, Nevada 89146 on a date and time to be determined, providing that notice of said examination is to be provided no less than 10 judicial days before such examination date. In support of this
application (“Application”), Creditors state as follows:
LEGAL ARGUMENT
An examination pursuant to Bankruptcy Rule 2004 can be ordered [o]n motion of any
party in interest.” In re Stasz, 387 B.R. 271, 273 n.3 (B.A.P. 9th Cir. 2008); see also In re Lifeco
Inv. Grp., Inc., 173 B.R. 478, 480 (Bankr. D. Del 1994), quoting Fed. R. Bankr. P. 2004(a).
Bankruptcy Rule 2004 further provides that the Court may order the examination and the
production of documentary evidence concerning any matter that relates “to the liabilities and
financial condition of the debtor, or to any matter which may affect the administration of the
debtor’s estate, or… any other matter relevant to the case or tot the formulation of a plan.” Fed.
R. Bankr. P. 2004(b); see also In re Dinubilo, 177 B.R. 932, 936 n.6 (E.D. Cal. 1993) (noting that
“[u]nder Rule 2004, a court may order the examination of any person on motion of any party in
interest.”).
Generally, examinations under Bankruptcy Rule 2004 are for the “purpose of
discovering assets and unearthing frauds.” In re Rafsky, 300 B.R. 152, 153 n.2 (Bankr. D. Conn.
2003) (citation omitted); In re N. Plaza LLC, 395 B.R. 113, 122 n.9 (S.D. Cal. 2008).
The scope of a Bankruptcy Rule 2004 examination is “unfettered and broad,” as the plain
language of the rule indicates. See 9 Collier on Bankruptcy ¶ 2004.02[1] at 2004-6 (15th ed. Rev.
1997); In re Dinublilo, 177 B. R. at 939 quoting In re GHR Energy Corp., 33 B.R. 451, 453
(Bankr. D. Mass. 1983).
The broad latitude of Bankruptcy Rule 2004 examination furthers the purpose of the rule, which is “to allow the court to gain a clear picture of the condition and the whereabouts of the bankrupt’s estate. In re Int’l Fibercom, Inc., 283 B.R. 290, 292 (Bankr. D. Ariz. 2002) (permitted Bankruptcy Rule 2004 examination aimed at “obtaining information that will … potentially uncover additional claims that may exist for the benefit of the estate”); see also In re W & S Investments, Inc., 985 F.2d 577 (9th Cir. 1993) (“Bankruptcy Rule 2004 is a broadly construed discovery device…”); In re French, 145 B. R 991, 992 (Bankr. D.S.D. 1992) (“Bankruptcy Rule 2004… does not offer the procedural safeguards available under Rule 26 of the Federal Rule Rules of Civil Procedure.”)."
"The information and documents which Creditors seek through this Application relate to
matters that are clearly with the permitted scope of Rule 2004, including: (i) property of the
Debtor’s bankruptcy estate; (ii) transactions and business dealings involving the Debtor and
family members and corporate entities; (iii) potential claims the Creditor may have against third
parties; and (iv) other matters affecting the administration of the Debtor’s estate."
Source and Full Document
Above Order Granted
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.188.0.pdf
Doc. 191 Liberty Media SUPPLEMENTAL BRIEF IN SUPPORT
OF MOTION FOR ORDER CONFIRMING INTERIMARBITRATION AWARD
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.191.0.pdf
CAN YOU SAY PATTERN AND HISTORY ???
"Randazza took on other clients without Liberty's consent" ya I, Crystal Cox, was probably one of them.
"But it appears the Randazza who spoke to Law360 is much more like the real Randazza that others have experienced, compared to the one who is representing LCS. In fact, last November, Ars Technica reporter Joe Mullin published a 3,000-word exposé on the Las Vegas attorney headlined "Bribery, gay porn and copyright trolls: The rise and fall of lawyer Marc Randazza."
The story highlighted an arbitration action Randazza initiated against his former employer, Liberty Media, accusing them of a number of things, including shooting a porn film in his office. Randazza sought hundreds of thousands of dollars from Liberty, but actually lost the case. Not that the attorney walked away with nothing, but the arbiter instead found Randazza owed Liberty at least $600,000 — and according to Randazza's bankruptcy filing in Nevada, up to $1 million — for a variety of claims, according to Ars Technica, including:
• Randazza "secretly negotiated" a $75,000 bribe from a defendant in a legal action;
• Randazza did unauthorized outside work while working for Liberty;
• And Randazza kept a $55,000 payment in a legal action he's actually most famous for, that should've instead went to Liberty.
That $55,000 payment was part of what is known as the Righthaven cases, where a company founded by a Nevada lawyer formed partnership agreements with newspapers as a way to crack down and collect revenue from blogs and online news sites that repurposed those stories.
Randazza became a darling of free press advocates when he defended many of those sites, helping to bring down Righthaven, which courts ultimately ruled had no standing to file the copyright suits in the first place.
Randazza did that work while working for Liberty, with the company's blessing. But then Randazza took on other clients without Liberty's consent, according to arbitration reports.
He sometimes even took on clients who Liberty was in legal squabbles with. One of those clients was a Youtube-style porn site known as Xvideos, which Liberty was cracking down on to stop its content from being pirated there.
Liberty claimed Randazza accepted a $35,000 retainer fee from Xvideos to represent them as well as additional monthly payments, while telling Liberty they shouldn't sue the site.
Instead, Randazza hatched a plan to go after individual people who downloaded Liberty content illegally through torrent sites, according to reports. Under this program, Randazza would locate an individual content pirate, and offer an "amnesty" of paying $1,000 to stop and not be sued by Liberty. "Dozens" of people paid the amnesty fee, a Liberty executive told Ars Technica, to the point where Randazza allegedly wanted to expand the program ... and charge a higher amnesty fee.
The program backfired before that next phase could begin. Bloggers who had once sided with Randazza were suddenly against him, including some gay-themed blogs that said Randazza was extorting people who might be "outed" if they instead chose to fight the lawsuit.
When the popular blog Queerty lashed out at Liberty and its legal strategy, saying it could actually nudge closeted teenagers and others toward suicide, Randazza himself spoke up.
"Liberty Media produces straight content too," Randazza said. "So any thieving little shit who gets caught can very easily lie to his parents that he was looking at straight porn."
Except Queerty pointed out that's not true — a lawsuit would have to state specifically what the offender had downloaded, which its sexual orientation audience would be obvious.
"The gay porn studio threatening to sue illegal file sharers doesn't seem too concerned that its lawsuits against some 40,000 so-far-anonymous BitTorrent users might out closeted gay teens who live in violent homophobic households," Queerty"
Source and More
http://1701news.com/node/1183/so-who-klingon-lawyer-marc-randazza.html
The story highlighted an arbitration action Randazza initiated against his former employer, Liberty Media, accusing them of a number of things, including shooting a porn film in his office. Randazza sought hundreds of thousands of dollars from Liberty, but actually lost the case. Not that the attorney walked away with nothing, but the arbiter instead found Randazza owed Liberty at least $600,000 — and according to Randazza's bankruptcy filing in Nevada, up to $1 million — for a variety of claims, according to Ars Technica, including:
• Randazza "secretly negotiated" a $75,000 bribe from a defendant in a legal action;
• Randazza did unauthorized outside work while working for Liberty;
• And Randazza kept a $55,000 payment in a legal action he's actually most famous for, that should've instead went to Liberty.
That $55,000 payment was part of what is known as the Righthaven cases, where a company founded by a Nevada lawyer formed partnership agreements with newspapers as a way to crack down and collect revenue from blogs and online news sites that repurposed those stories.
Randazza became a darling of free press advocates when he defended many of those sites, helping to bring down Righthaven, which courts ultimately ruled had no standing to file the copyright suits in the first place.
Randazza did that work while working for Liberty, with the company's blessing. But then Randazza took on other clients without Liberty's consent, according to arbitration reports.
He sometimes even took on clients who Liberty was in legal squabbles with. One of those clients was a Youtube-style porn site known as Xvideos, which Liberty was cracking down on to stop its content from being pirated there.
Liberty claimed Randazza accepted a $35,000 retainer fee from Xvideos to represent them as well as additional monthly payments, while telling Liberty they shouldn't sue the site.
Instead, Randazza hatched a plan to go after individual people who downloaded Liberty content illegally through torrent sites, according to reports. Under this program, Randazza would locate an individual content pirate, and offer an "amnesty" of paying $1,000 to stop and not be sued by Liberty. "Dozens" of people paid the amnesty fee, a Liberty executive told Ars Technica, to the point where Randazza allegedly wanted to expand the program ... and charge a higher amnesty fee.
The program backfired before that next phase could begin. Bloggers who had once sided with Randazza were suddenly against him, including some gay-themed blogs that said Randazza was extorting people who might be "outed" if they instead chose to fight the lawsuit.
When the popular blog Queerty lashed out at Liberty and its legal strategy, saying it could actually nudge closeted teenagers and others toward suicide, Randazza himself spoke up.
"Liberty Media produces straight content too," Randazza said. "So any thieving little shit who gets caught can very easily lie to his parents that he was looking at straight porn."
Except Queerty pointed out that's not true — a lawsuit would have to state specifically what the offender had downloaded, which its sexual orientation audience would be obvious.
"The gay porn studio threatening to sue illegal file sharers doesn't seem too concerned that its lawsuits against some 40,000 so-far-anonymous BitTorrent users might out closeted gay teens who live in violent homophobic households," Queerty"
Source and More
http://1701news.com/node/1183/so-who-klingon-lawyer-marc-randazza.html
Marc Randazza KNOWS Nothing of being "intellectually honest "
""That would have been the intellectually honest thing to do, and would have been much simpler," Randazza told Law360"
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/
"Instead, someone padded their time entries for the month, which is between them and their client."
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/
Speaking of PADDING time entries, suing people and making courts pay their legal fees
to do it, check out this BILL. Ronald Green and Randazza Legal Group Sued me .. and well..
they WANT PAID.
http://unethicalscumattorney.blogspot.com/2017/10/retaliatory-ripoff-reject-rat-ronald.html
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/
"Instead, someone padded their time entries for the month, which is between them and their client."
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/
Speaking of PADDING time entries, suing people and making courts pay their legal fees
to do it, check out this BILL. Ronald Green and Randazza Legal Group Sued me .. and well..
they WANT PAID.
http://unethicalscumattorney.blogspot.com/2017/10/retaliatory-ripoff-reject-rat-ronald.html
Marc Randazza IS using Bankruptcy Courts to avoid consequences, NAILED IT.
""Randazza is on the record condemning others for attempting to use bankruptcy as a means to avoid judgments and avoid the consequences of their own wrongdoings," Dunlap said. "Now we’re seeing Randazza do precisely what he chided others for doing in the past."
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/3/
Source and Full Document
https://arstechnica.com/tech-policy/2015/11/how-copyright-lawyer-marc-randazza-got-famous-lost-friends-and-went-broke/3/
Hey Crystal I Apologize humbly. You are IMPORTANT. I Wish you to Succeed. Let me Know IF I CAN LEND A HAND. Flat out Malicious Lies from my Former Attorney Marc Randazza. Ask the Dude for a JOB and he cries EXTORTION to the world. Lend a Hand? ya RIGHT.
"Crystal,
I want to address a few things:
First and foremost, if you feel that I did not treat you respectfully, I humbly apologize. I do not wish
to leave that un-discussed. People like you are important for the future of citizen journalism, and I wish to see you succeed.
I also want to correct a misperception here. I did not tell anyone that I represented you, for
certain. I did tell the opposing counsel that I thought a deal might be brokered - but that I wanted
to speak to him first (to test his waters with respect to a possible mutually agreeable resolution).
Finally, I want to make it clear that our discussion about money was in terms of "costs." I thought
that I made it clear that my bills, my fees (my income) would be waived. All that I was asking you
about being able to pay was out of pocket reimbursement of expenses.
Despite the contents of this email, I wish to let you know that I am sill willing to lend a hand in any
way - even in the background.
-Marc"
I want to address a few things:
First and foremost, if you feel that I did not treat you respectfully, I humbly apologize. I do not wish
to leave that un-discussed. People like you are important for the future of citizen journalism, and I wish to see you succeed.
I also want to correct a misperception here. I did not tell anyone that I represented you, for
certain. I did tell the opposing counsel that I thought a deal might be brokered - but that I wanted
to speak to him first (to test his waters with respect to a possible mutually agreeable resolution).
Finally, I want to make it clear that our discussion about money was in terms of "costs." I thought
that I made it clear that my bills, my fees (my income) would be waived. All that I was asking you
about being able to pay was out of pocket reimbursement of expenses.
Despite the contents of this email, I wish to let you know that I am sill willing to lend a hand in any
way - even in the background.
-Marc"
Link to Original
Oh and Of course he lies as he did tell Eugene Volokh and others he represented me, as eMail evidence clearly shows and phone calls between me and Eugene Volokh. Lies Lies, Officer of the Court ABOVE THE LAW.
Rogue Unconstitutional Nevada Judge Gloria Navarro Gave Marc Randazza an Unconstitutional TRO.
I Did the best I could to Defend Myself, but Had NO Constitutional Rights whatsoever.
"An impermissible prior restraint against Defendant Crystal Cox is unconstitutional. An
impermissible prior restraint against Defendant Crystal Cox is impermissible when it issued a
preliminary injunction against future speech, and seized intellection property, content, blogs and
domain names of Defendant Crystal Cox."
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.34.0.pdf
DENIED OF COURSE
Officer of the Court Marc Randazza would not LIE to the Court Would He?
Naaaaa....
"An impermissible prior restraint against Defendant Crystal Cox is unconstitutional. An
impermissible prior restraint against Defendant Crystal Cox is impermissible when it issued a
preliminary injunction against future speech, and seized intellection property, content, blogs and
domain names of Defendant Crystal Cox."
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.34.0.pdf
DENIED OF COURSE
Officer of the Court Marc Randazza would not LIE to the Court Would He?
Naaaaa....
Oh and Check this out, dozens and dozens of blogs and domain names. Massive Online Content, Search Engine Placement and Ronald Green of Randazza Legal Group decides the value somehow and puts that in the court?? WTF??
Ever Wonder how to Use a TRO to Steal Online Content, Intellectual Property, Someone's Work Product and Proprietary Methods? And completely IGNORE the First Amendment? Wonder No More. Let Attorney Marc Randazza Show you the Way.
How to Side Step that Pesky First Amendment by using an Unconstitutional TRO, inspired by my former Unconstitutional, First Amendment Attorney Marc J. Randazza, Attorney Ronald Green and the Randazza Legal Group Law Firm.
Check out the Court Ruling Below whereby Randazza successfully WON is argument that A TRO is Unconstitutional.
"No. 3D12-3189 Lower Tribunal No. 11-17842,
Irina Chevaldina, Appellant,
vs.
R.K./FL Management, Inc., et al.,Appellee"
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf
Absolutely Unconstitutional TRO Motion filed by my former attorney Marc Randazza. He was successful in using this Unconstitutional TRO to steal my intellectual property, my work product, my search engine placement, my online content, and flat out steal blogs and domain names with NO First Amendment Adjudication whatsoever
Click Below to Read, and You too Can STEAL Content, Search Engine Placement and Intellectual Property via a TRO.
Case 2:12-cv-02040-GMN-PAL Document 2 Filed 11/28/12
Also Check Out links below for Tips and Trick to use the Power of the Courts to your Benefit. No worry about those bad reviews or Gripe Sites, just get a TRO and WaLa you OWN the Constitutional Rights and Property of anyone you please.
"First Amendment Attorney Marc Randazza of Randazza Legal Group SAYS that Preliminary Injunctions are unconstitutional, they are unlawful prior restraint, they are "patently unconstitutional", they are clearly an "unconstitutional remedy". Especially if there was no prior First Amendment Adjudication."
http://unethicalscumattorney.blogspot.com/2017/10/first-amendment-attorney-marc-randazza.html
"Pro Se Litigant Investigative Blogger Crystal Cox Pokes a BIT of FUN at the OUTBREAK of Preliminary Injunctions, Sweeping Rapidly, Seemingly Out of Control, through the District of Nevada, yet Granny Goose Alleges these RULINGS are an "extraordinary remedy". Crystal Cox Calls BULLSHIT. ViaView , Inc. Plaintiff v. BLUE MIST MEDIA; ERIC S. CHANSON; KEVIN C. BOLLAERT; CODY ALVIAR; ROY E. CHANSON; and AMY L. CHANSON ~ Randazza V. Cox, Who Will be NEXT?"
http://unethicalscumattorney.blogspot.com/2017/10/pro-se-litigant-investigative-blogger.html
"Marc Randazza Defends Rush Limbaugh in ALLEGED Free Speech Rights, While Marc Randazza TAKES away the Rights of Free Speech and First Amendment Rights of ALL Bloggers and Citizens Journalists."
http://whistleblowermediacrystalcox.blogspot.com/2012/03/marc-randazza-defends-rush-limbaugh-in.html
First Amendment Attorney Marc J. Randazza SUES blogger Crystal L. Cox to Suppress her Speech. 5 years later wants her to pay his legal fees for his Unconstitutional Retaliatory Lawsuit against her. $350,000 to SUE a Blogger over a $10 Domain Name that Trademark Attorney, Domain Name, First Amendment Expert Marc Randazza was to damn dumb to buy. WOW. Check out these BILLS folks. All to suppress the speech of someone speaking critical of big baby Marc Randazza.
http://unconstitutionalattorney.blogspot.com/2017/10/first-amendment-attorney-marc-j.html
A Trademark Attorney, First Amendment Expert SUES a former client claiming a Trademark Infringement on Gripe Sites.
https://unconstitutionalattorney.blogspot.com/2015/04/a-trademark-attorney-first-amendment.html
Oh and Don't Miss the Infamous Kaplan Letter where Hypocritical Attorney Marc Randazza and his law firm Randazza Legal Group really lay it on thick. (The opposite argument he made in suing me, Crystal Cox, his former client.)
https://drive.google.com/file/d/0Bzn2NurXrSkiZEFJQW95MXNFQUU/view?usp=sharing
Much more Details Coming soon, so that you to Can use the Power and Privilege of our Court System to get a TRO against your enemy speaking critical of you and not have to concern yourself with the First Amendment or any kind of actual factual due process.
Detailed Step By Step How To Coming Soon
Check out the Court Ruling Below whereby Randazza successfully WON is argument that A TRO is Unconstitutional.
"No. 3D12-3189 Lower Tribunal No. 11-17842,
Irina Chevaldina, Appellant,
vs.
R.K./FL Management, Inc., et al.,Appellee"
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf
Absolutely Unconstitutional TRO Motion filed by my former attorney Marc Randazza. He was successful in using this Unconstitutional TRO to steal my intellectual property, my work product, my search engine placement, my online content, and flat out steal blogs and domain names with NO First Amendment Adjudication whatsoever
Click Below to Read, and You too Can STEAL Content, Search Engine Placement and Intellectual Property via a TRO.
Case 2:12-cv-02040-GMN-PAL Document 2 Filed 11/28/12
Also Check Out links below for Tips and Trick to use the Power of the Courts to your Benefit. No worry about those bad reviews or Gripe Sites, just get a TRO and WaLa you OWN the Constitutional Rights and Property of anyone you please.
"First Amendment Attorney Marc Randazza of Randazza Legal Group SAYS that Preliminary Injunctions are unconstitutional, they are unlawful prior restraint, they are "patently unconstitutional", they are clearly an "unconstitutional remedy". Especially if there was no prior First Amendment Adjudication."
http://unethicalscumattorney.blogspot.com/2017/10/first-amendment-attorney-marc-randazza.html
"Pro Se Litigant Investigative Blogger Crystal Cox Pokes a BIT of FUN at the OUTBREAK of Preliminary Injunctions, Sweeping Rapidly, Seemingly Out of Control, through the District of Nevada, yet Granny Goose Alleges these RULINGS are an "extraordinary remedy". Crystal Cox Calls BULLSHIT. ViaView , Inc. Plaintiff v. BLUE MIST MEDIA; ERIC S. CHANSON; KEVIN C. BOLLAERT; CODY ALVIAR; ROY E. CHANSON; and AMY L. CHANSON ~ Randazza V. Cox, Who Will be NEXT?"
http://unethicalscumattorney.blogspot.com/2017/10/pro-se-litigant-investigative-blogger.html
"Marc Randazza Defends Rush Limbaugh in ALLEGED Free Speech Rights, While Marc Randazza TAKES away the Rights of Free Speech and First Amendment Rights of ALL Bloggers and Citizens Journalists."
http://whistleblowermediacrystalcox.blogspot.com/2012/03/marc-randazza-defends-rush-limbaugh-in.html
http://unconstitutionalattorney.blogspot.com/2017/10/first-amendment-attorney-marc-j.html
A Trademark Attorney, First Amendment Expert SUES a former client claiming a Trademark Infringement on Gripe Sites.
https://unconstitutionalattorney.blogspot.com/2015/04/a-trademark-attorney-first-amendment.html
Oh and Don't Miss the Infamous Kaplan Letter where Hypocritical Attorney Marc Randazza and his law firm Randazza Legal Group really lay it on thick. (The opposite argument he made in suing me, Crystal Cox, his former client.)
https://drive.google.com/file/d/0Bzn2NurXrSkiZEFJQW95MXNFQUU/view?usp=sharing
Much more Details Coming soon, so that you to Can use the Power and Privilege of our Court System to get a TRO against your enemy speaking critical of you and not have to concern yourself with the First Amendment or any kind of actual factual due process.
Tuesday, October 24, 2017
First Amendment Attorney Marc Randazza of Randazza Legal Group SAYS that Preliminary Injunctions are unconstitutional, they are unlawful prior restraint, they are "patently unconstitutional", they are clearly an "unconstitutional remedy". Especially if there was no prior First Amendment Adjudication.
"Let's Look at the RULING and Marc Randazza's
A Bit from Marc Randazza's Victory APPEALING an alleged unconstitutional preliminary injunction against his client. Even though Marc Randazza himself used an unconstitutional preliminary injunction against me, Crystal Cox and stole my search engine ranking, my intellectual property, my blogs and then proceeded to violate my privacy rights, constitutional rights, civil rights and to harass and defame me for years.
""Irina Chevaldina appeals an order granting a preliminary injunction to “enjoin tortious interference, stalking, trespass and defamatory blogs” entered in favor of Raanan Katz and the other named appellees, plaintiffs in the circuit court. We vacate the order and injunction. "
Source
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf
" In this appeal, we review a temporary injunction in the circuit court action
which determined that “the Defendants have blogged extensively about the
Plaintiff and many of these blogs are arguably defamatory. Although ultimately a
defamation trial will be held, this Court ORDERS the Defendants not to enter
defamatory blogs in the future.”
The court determined that:
Plaintiffs have a substantial likelihood of ultimately prevailing on the
merits of their claims, and there is a substantial threat of irreparable
injury to the Plaintiffs if injunctive relief is not granted, that the
threatened injury to Plaintiffs outweighs whatever damage the
injunction would cause the Defendants, and that the injunction would
not be adverse to the public interest."
Source
3dca.flcourts.org/Opinions/3D12-3189.op..pdf
In Randazza v. Cox there was no "substantial likelihood of ultimately prevailing on the
merits of their claims" and there certainly was no First Amendment Adjudication BEFORE Plaintiff Marc Randazza seized Blogger Crystal Cox's intellectual property.
See the Link Below that shot down all of Plaintiff Randazza's unsupported causes of action
in a Denial of a Summary Judgement in Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
The Ruling Goes on to Say;
"A temporary injunction “should be granted only sparingly and only after the moving party has alleged and proved facts entitling it to relief.” Liberty Fin. Mortg. Corp. v. Clampitt, 667 So. 2d 880, 881 (Fla. 2d DCA 1996)."
3dca.flcourts.org/Opinions/3D12-3189.op..pdf
Yet attorney, Plaintiff Marc Randazza proved NO FACTS in Randazza v. Cox and Bernstein, yet he filed gag orders, injunctions, stole blogs, shut down sites, and even redirected my blogs to a post on his blog defaming and lying about me. Why do the courts protect Marc Randazza when he is clearly violating law and the constitutional rights of his victims?
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Well connected First Amendment Attorney Marc Randazza FLAT OUT lied about me, perjured himself over and over and Judge Gloria Navarro took him at his word and NO PROOF and stole my search engine ranking, my intellectual property, my work product and caused me irreparable harm to myself, my business and my relationships.
Here is the Unconstitutional TRO Filing (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.2.0.pdf
Added Flat out Lies to TRO (Randazza Filing)
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.6.0.pdf
REPLY with more Lies and Attacks regarding the TRO (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.12.0.pdf
Another REPLY (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.28.0.pdf
ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction against Defendant Blogger Crystal Cox in favor of Marc Randazza.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.14.0.pdf
Another ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction Just in case the FIRST ONE was not heard.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.41.0.pdf
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My, Defendant Crystal Cox's Response and Objection to Unconstitutional TRO / Motion for Preliminary Injunction
Defendant Crystal Cox's Objection
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.29.0.pdf
Defendant Crystal Cox's REPLY to Response
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf
.jpg)
Originally Posted at
http://marcrandazzalied.blogspot.com/2014/12/first-amendment-attorney-marc-randazza.html
Big Preliminary Injunction VICTORY
A Bit from Marc Randazza's Victory APPEALING an alleged unconstitutional preliminary injunction against his client. Even though Marc Randazza himself used an unconstitutional preliminary injunction against me, Crystal Cox and stole my search engine ranking, my intellectual property, my blogs and then proceeded to violate my privacy rights, constitutional rights, civil rights and to harass and defame me for years.
""Irina Chevaldina appeals an order granting a preliminary injunction to “enjoin tortious interference, stalking, trespass and defamatory blogs” entered in favor of Raanan Katz and the other named appellees, plaintiffs in the circuit court. We vacate the order and injunction. "
Source
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf
" In this appeal, we review a temporary injunction in the circuit court action
which determined that “the Defendants have blogged extensively about the
Plaintiff and many of these blogs are arguably defamatory. Although ultimately a
defamation trial will be held, this Court ORDERS the Defendants not to enter
defamatory blogs in the future.”
The court determined that:
Plaintiffs have a substantial likelihood of ultimately prevailing on the
merits of their claims, and there is a substantial threat of irreparable
injury to the Plaintiffs if injunctive relief is not granted, that the
threatened injury to Plaintiffs outweighs whatever damage the
injunction would cause the Defendants, and that the injunction would
not be adverse to the public interest."
Source
3dca.flcourts.org/Opinions/3D12-3189.op..pdf
In Randazza v. Cox there was no "substantial likelihood of ultimately prevailing on the
merits of their claims" and there certainly was no First Amendment Adjudication BEFORE Plaintiff Marc Randazza seized Blogger Crystal Cox's intellectual property.
See the Link Below that shot down all of Plaintiff Randazza's unsupported causes of action
in a Denial of a Summary Judgement in Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf
The Ruling Goes on to Say;
"A temporary injunction “should be granted only sparingly and only after the moving party has alleged and proved facts entitling it to relief.” Liberty Fin. Mortg. Corp. v. Clampitt, 667 So. 2d 880, 881 (Fla. 2d DCA 1996)."
3dca.flcourts.org/Opinions/3D12-3189.op..pdf
Yet attorney, Plaintiff Marc Randazza proved NO FACTS in Randazza v. Cox and Bernstein, yet he filed gag orders, injunctions, stole blogs, shut down sites, and even redirected my blogs to a post on his blog defaming and lying about me. Why do the courts protect Marc Randazza when he is clearly violating law and the constitutional rights of his victims?
"In order to establish the right to a temporary injunction the moving party must show: the likelihood of irreparable harm; the unavailability of an adequate remedy at law; the substantial likelihood of success on the merits;
the threatened injury to the petitioner outweighs the possible harm to the respondent; and the granting of the temporary injunction will not disserve the public interest. E.g., City of Miami Beach v. Kuoni Destination Mgmt., Inc., 81 So. 3d 530, 532 (Fla. 3d DCA 2012).
We review the temporary injunction for an abuse of the trial court’s discretion. Angelino v. Santa Barbara Enters., 2 So. 3d 1100, 1103 (Fla. 3d DCA
A. Injunction Against Tortious Interference and Defamatory Blogs Injunctive relief is not available to prohibit the making of defamatory or libelous statements. See, e.g., Vrasic v. Leibel, 106 So. 3d 485, 486 (Fla. 4th DCA 2013).
A temporary injunction directed to speech is a classic example of prior restraint on speech triggering First Amendment concerns. Id.
There is, however, a limited exception to the general rule where the defamatory words are made in the furtherance of the commission of another intentional tort. E.g., Murtagh v. Hurley, 40 So. 3d 62 (Fla. 2d DCA 2010); Zimmerman v. D.C.A. at Welleby, Inc., 505 So. 2d 1371 (Fla. 4th DCA 1987). "
Source of Ruling
Yet Plaintiff Marc Randazza was easily GRANTED an unconstitutional preliminary injunction against Blogger Crystal Cox and iViewit inventor Eliot Bernstein, why?
Well connected First Amendment Attorney Marc Randazza FLAT OUT lied about me, perjured himself over and over and Judge Gloria Navarro took him at his word and NO PROOF and stole my search engine ranking, my intellectual property, my work product and caused me irreparable harm to myself, my business and my relationships.
Here is the Unconstitutional TRO Filing (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.2.0.pdf
Added Flat out Lies to TRO (Randazza Filing)
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.6.0.pdf
REPLY with more Lies and Attacks regarding the TRO (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.12.0.pdf
Another REPLY (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.28.0.pdf
ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction against Defendant Blogger Crystal Cox in favor of Marc Randazza.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.14.0.pdf
Another ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction Just in case the FIRST ONE was not heard.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.41.0.pdf
My, Defendant Crystal Cox's Response and Objection to Unconstitutional TRO / Motion for Preliminary Injunction
Defendant Crystal Cox's Objection
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.29.0.pdf
Defendant Crystal Cox's REPLY to Response
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf
Randazza et al v. Cox et al
District of Nevada 2:12-cv-02040
Cause; 15:1125 Trademark Infringement (Lanham Act)
Nature Of Suit: 840 Trademark
1) VIOLATION OF INDIVIDUAL CYBERPIRACY PROTECTIONS
– 15 U.S.C. § 8131
2) CYBERSQUATTING - 15 U.S.C. §
1125(d)
3) RIGHT OF PUBLICITY – NRS
597.810
4) COMMON LAW RIGHT OF
PUBLICITY
5) COMMON LAW RIGHT OF
INTRUSION UPON SECLUSION
6) CIVIL CONSPIRACY
Other Preliminary Injunctions Judge Gloria Navarro Gave Randazza Legal Group
even though they are allegedly "Rare" and Unconstitutional
"ViaView, Inc. v. Chanson et al"
"Court Description: ORDER Granting 6 EX PARTE MOTION for Temporary Restraining Order filed by ViaView, Inc. IT IS FURTHER ORDERED that Defendants shall have until 12/7/2012 to file Response to 6 Motion for Preliminary Injunction.
Plaintiff shall file reply by 12/21/2021. Motion Hearing set for 1/2/2013 02:30 PM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 11/30/12. (Copies have been distributed pursuant to the NEF - EDS)"
Source
In SOME Cases, a Preliminary Injunction is Unconstitutional and Marc Randazza DEFENDS that position. Yet he used an unconstitutional Injunction to steal my work product, my intellectual property, my search engine ranking and my online content.
Preliminary Injunction are Unconstitutional Depending on Which Side your Attorney is On.
Opening Brief in the Irina Chevaldina Appellate Case No. 3D12-3189, Attorney Marc Randazza.
In the District of Nevada, Judge Gloria Navarro's court, the Most Important thing is the Attorneys Pay Check, and the Law, the Constitutional Rights of Defendants, Due Process seems to be Irrelevant.
Judge Gloria Navarro seems to CLEARLY favors Randazza Legal Group as far as I see it.
These attorneys sue whoever they want, they get their attorney fees, intellectual property, fines paid to them and what ever they want in the MAGICAL Land La La Lawless Land of Judge Gloria Navarro of District of Nevada.
More Research Links on that Topic
Liberty Media Holdings LLC v. FF Magnat Limited
"The Plaintiff has shown a substantial likelihood of success on the merits of its claims sufficient for the Court to issue a limited Temporary Restraining Order. Plaintiff alleges copyright infringement, contributory copyright infringement, vicarious copyright infringement and inducement of copyright infringement. (Compl., ECF No. 1.)
To show a substantial likelihood of prevailing on the merits of a copyright infringement claim, Plaintiff must show that: (1) it owns the copyright to which its infringement claims relate; and, (2) Defendants violated one of the Plaintiff's exclusive rights in the works. See Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991);
Latimer v. Roaring Toyz, Inc., 601 F.3d 1224, 1232-33 (11th Cir. 2010); Sid & Marty Krofft Television Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1162 (9th Cir 1977); Educational Testing Servs. v. Katzman, 793 F.2d 533, 538 (3d Cir. 1977). These two factors have been clearly established by the Plaintiff."
To show a substantial likelihood of prevailing on the merits of a copyright infringement claim, Plaintiff must show that: (1) it owns the copyright to which its infringement claims relate; and, (2) Defendants violated one of the Plaintiff's exclusive rights in the works. See Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991);
Latimer v. Roaring Toyz, Inc., 601 F.3d 1224, 1232-33 (11th Cir. 2010); Sid & Marty Krofft Television Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1162 (9th Cir 1977); Educational Testing Servs. v. Katzman, 793 F.2d 533, 538 (3d Cir. 1977). These two factors have been clearly established by the Plaintiff."
Source of Above Judge Gloria Navarro RULING Favoring the SAME Plaintiff
Marc Randazza does not and did NOT have "substantial likelihood of success on the merits of its claim". Yet he was favored over his TARGET / his Victims.
Why is no FBI Agent, Dept. Of Justice Agent, the Nevada Attorney General, or the U.S. Attorney General Looking at all this?
It sure seems to VIOLATE the Rights of the Targets, the Defendants in some sort of pattern of "shakedown", in my Opinion
More Research on the Liberty Media Holdings LLC v. FF Magnat Limited and this Same Attorney, who sure is GOOD at Showing Alleged "merits" of winning, Before a Defendant has any First Amendment Adjudication or Right to Due Process.
Love this Part "Emergency MOTION for Temporary Restraining Order by Plaintiff Liberty Media Holdings LLC. Motion ripe 6/20/2012."
I get threats of death, violence and Judge Gloria Navarro IGNORES my Real Emergency. Yet Gloria Navarro allows Randazza Legal Group to abuse the process and get emergency protective orders and Injunctions.
Frozen Accounts, Preliminary Injunctions, FORCED Attorney Fees and whatever Randazza Legal Group wants they get, WHY?
"Section 505 of the Copyright Act grants district courts discretion to award “
a reasonable attorney's fee to the prevailing party as part of the costs"
Randazza Legal Group sues their TARGET, and the Judge Forces their VICTIM to PAY the ATTORNEYS outrageous Fee's. And if you Don't Judge Gloria Navarro will Freeze your Accounts. Pattern and History, I THINK SO.. in my NON-Attorney OPINION.
Don't Forget Liberty Media Holdings allegedly is infringing on the iViewit Technology and many companies owned, at least in part by Liberty Media Holdings are named in iViewit Technology. Randazza SUED Eliot Bernstein and got a Preliminary Injunction against him as well, with NO First Amendment Adjudication.
The Full Hypocritical Filing of Marc Randazza Regarding the
Unconstitutional actions of Preliminary Injunctions.
Page 8 of above;
"This appeal Seeks to cure an unlawful prior restraint on the Appellant’s First Amendment rights, improperly imposed by the lower court. On November 19, 2012, the circuit court enjoined Appellant from writing, “defamatory” blogs 'in the future, despite expressly making “no findings of facts as to actual ‘violations of law by the [Appellants], except that [Appellants] have blogged extensively about the Appellee] and many of these blogs are arguably defamatory.” (RÃ/14)
The circuit court made this decision Without following the mandates of Florida Rule of Civil Procedure 1.610. However, even if it had, the injunction is patently unconstitutional."
WOW, "the injunction is patently unconstitutional", it is "unlawful prior restraint", EXCEPT for when Marc Randazza uses it against a Blogger he wants to SUPPRESS the SPEECH of.
Page 10
"Months and months of litigation, thousands of dollars, and thousands of pages of documents later, RKA sought a clearly unconstitutional remedy - an injunction against alleged defamation prior to any court determination that the speech at issue was even legally capable of defamatory meaning, much less Whether it was actually defamatory, privileged, or otherwise protected by the First Amendment. (R Vl-6)
The resulting lnjunction Order was so over-broad and subject to abuse, that the RKA even sought an order for contempt based upon Chevaldina doing no more than reporting the existence of the Order itself."
All that money to seek a "clearly unconstitutional remedy"? And Marc Randazza defends the opposite position he took to constitutionally violate Crystal Cox an Eliot Bernstein?
Full Hypocritical Motion Linked Below
Attorney Marc Randazza sought a "clearly unconstitutional remedy , "injunction ..prior to any court determination" from Crystal Cox and Eliot Bernstein, even though that "speech" was protected under the First Amendment and with NO First Amendment Adjudication.
Randazza Legal Group, Marc Randazza stole massive online content, work product, intellectual property and used the lawsuit to violate my privacy rights, harass me, defame me, lie about me, harass me and to post private emails, get my bank account and wire records, harass and bully my church, threaten my ex's, get private proprietary business information from customers and clients and to put me and my sources under constant attack, threats, stalking, harassing, bullying and defaming for over 2 years now and counting. He did this as an "officer of the court". Clearly abusing his power.
Marc Randazza and Randazza Legal Group are
CLEARLY acting outside of the Law and are Violating
the rights of citizens every single day.
And they are using Judges, Attorneys,
Investigators, Officers of the Court, and Thugs to do it,
in my Opinion.
EXPOSE Randazza Legal Group.
Originally Posted at
http://marcrandazzalied.blogspot.com/2014/12/first-amendment-attorney-marc-randazza.html
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