Blogger Crystal Cox Files Bar Complaint in Nevada Against Marc Randazza of Randazza Legal Group, her former attorney.

Nevada Bar Complaint

Complaining Party:   Crystal L. Cox

Phone:  406-624-9510

eMail;  SavvyBroker@yahoo.com

P.O Box 2027

Port Townsend, WA 98368

Name of Attorney: Marc J. Randazza

Law Firm:   Randazza Legal Group

Bar Number 12265

Phone Number:  702-420-2001

3625 S. Town Center Dr.

Las Vegas, NV  89135

Filed April 28th 2015

How Marc Randazza came to be my attorney

On or about December 10th, 2011, one of the Bloggers on my Independent Blog Network, contacted me regarding his contacting an attorney named Marc Randazza. (See Exhibit 18).  Before this, I had never heard of Marc Randazza.

I had just lost a major free speech case ( Obsidian Finance Group vs. Cox), on November 28th, 2011 and expressed that I intended to appeal to the Ninth Circuit.  The blogger thought Marc Randazza would be a good fit and may represent me for Free on my Ninth Circuit appeal, as he had just had some TSA case in the media and seemed to be very pro Free Speech rights for all citizens.

I agreed to have a 3 way phone conversation regarding the possibility of me agreeing to allow Mr. Randazza to represent me, in what had quickly become a high profile First Amendment Case that affected the rights of all citizens, bloggers, whistle blowers, and citizen journalists.

On December 6th, 2011 I had previously spoke to UCLA Law Professor Eugene Volokh. He called me and asked if he could represent me on my Appeal of Obsidian Finance Group v. Crystal Cox and with absolutely no cost to me. I agreed that he could represent me.

Eugene Volokh is a law professor and does not practice law regularly. So he had to get the final approval of the law firm Mayer Brown LLP. Therefore I had not had firm representation yet from him when I spoke with Marc Randazza. And was open to both or either of them representing me on my Ninth Circuit Appeal, at that time.

Discussion on that First Call

On my representation conference call with Marc Randazza, we discussed my strategy for my appeal, as well as my strengths and weaknesses and what I was willing to do and not willing to do.

Randazza told me I had made a mess of the case and he would have to look over all the documentation to decide if he would be able to take my case. Randazza told me that Big Media had a monopoly on Free Speech and that is just the way it is.

Randazza attempted to get me to not appeal, by telling me it was best for all of society if I did not appeal. Randazza asked me my strategy, what I was open to in moving forward, and what I was not. He questioned me on many aspects of my intentions for my appeal.

Randazza told me that he represented the Media Association for Bloggers and may have a conflict of interest in representing me, and that he would get back to me after I gave him all of the documents of my case and he checked with them.

Attorney Marc Randazza Representation of Cox

As Exhibit 19 shows, on December 14th, 2011 Randazza confirmed his representation of me, Crystal Cox.

At this time Randazza had already began representation, he spoke to the opposition in my Obsidian case. He had already put in time and material, he had tried to broker a deal of which I had no idea of the details, and he was discussing his representation with other First Amendment attorneys. He also told these attorneys he was representing me on appeal before this date.

On December 15th, 2011,  As Exhibit 20 shows, my attorneys Marc Randazza and Eugene Volokh were working with, and keeping me in the loop on their representation of me and the case strategy moving forward. They were discussing ordering court documents filing a motion for a new trial, and had phone calls discussion, as well as email communication on how to best move forward with my case. They were both representing me at that time and in talks about the case with the courts, other attorney and me, as the record shows.

Thereafter, it came to my attention that Randazza had contacted Oregon attorney David Aman, the opposition in my Obsidian case, and had been negotiating (brokering) a deal that would stop my appeal and somehow change the status of the judgement .  Eugene Volokh told me this in a phone call and in emails of Dec. 15th, 2011, in Exhibit 1.

Also in Exhibit 1 and that phone call Eugene Volokh told me that Randazza was discussing, with other First Amendment bar attorneys that he represented me and was trying to broker a deal.

I had no knowledge of the details of this negotiation, nor any terms of it and Randazza did not have my permission to present a deal of any kind yet. Especially one without me knowing the detail.

Therefore, at this time,  I decided to Fire Marc Randazza specifically on the grounds that he was presenting (brokering) deals, discussing motions to be filed, and presenting options to the opposition in my case with total disregard for what I wanted, my needs, or keeping me informed on the details of those deal / negotiations that fully affected me. And treating me with complete disrespect.

As seen in Exhibit 21, On December 16th 2011 at 9:21 am, I fired attorney March Randazza. I told him he does not represent me and that only Eugene Volokh represents me, from this moment.

I would have kept Randazza on with Volokh had he not lied to me, berated me, and presented deals to the opposition without my permission or knowledge of what they were, in my  $2.5 million dollar judgment and the appeal case.

Randazza retaliated against me plain and simple, and Exhibit 21 proves that he did so with intent, maliciously and after claiming, offering to be of any kind of help.

Also seen in Exhibit 21,  On December 16th 2011 at 12:55 PM Randazza says he has no issue with me doing that and offers to help me in the future in anyway he can.

Exhibit 21 shows that Marc Randazza claims to respects me, apologized if I felt not treated well and said the following:  "People like you are important for the future of citizen journalism, and I wish to see you succeed."

Overview of my Grievance

My basic complaint is that a man I thought was my attorney, whom I gave private information, strategy, and shared my strengths and weaknesses with, used all I gave him against me to attempt to broker a deal that was not in my best interest, but in the interest of his porn clients.

All with total disregard for what I wanted and had expressed to him were my want  case goals. Randazza violated my constitutional rights, my rights as a litigant, and treated me  extreme disrespect.

I fired this attorney who had talked down to me, lied to me, misrepresented me, gave away my secrets and strategies, tried to trick me into not appealing my $2.5 million dollar judgement and  tried to broker a deal without my knowledge or consent, and against my best interest.

Exhibit 21 shows Randazza admitting to brokering a deal, allegedly on my behalf, he said this: , "I did tell the opposing counsel that I thought a deal might be brokered".

After I fired him on On December 16th 2011, and he emailed me and said to let him know if he could help me in any way, even if in the background. I continued my case with Eugene Volokh.

Then on January 16, 2012, taking my former attorney at his word of offering help, in any way, even if in the background, I emailed him asking for a job or a job recommendation.  He emailed me back and attacked me, as seen in Exhibits. And even though his return email clearly showed him upset, he said he did know I was asking for a job. However, after this, he used a part of the email thread, gave it to the media, as well as legal bloggers, and international review boards, and then multiple courts, and painted me, his former client out to be a criminal.  

He did not file a criminal complaint, yet used his media and legal connections to paint me as guilty for the crime of extortion. He violated my.rights of due process, my constitutional rights, and he deliberately, with full knowledge of it being false, defamed me and made false statements to third parties around the world. Including NPR, Forbes, the New York Times, Legal and Fraud Experts, WIPO (international publications, domain names and intellectual property law), and he used his knowledge of First Amendment Law, and his connection to legal bloggers and big and small media to paint me out as a criminal worldwide.

It is my belief, that Randazza owed me a duty to keep my email private and to not do anything adverse to my well being. He has now embarked on a 3 year campaign to harass me, intimidate me, sue me, lie to courts and media about me, and flat out ruin my life, family, relationships, reputation and quality of life.

I relied on what my former attorney said about my case, my best interest, moving forward, and that he would follow through with what was my wishes and of my best good. I relied on my former attorneys word offering help to me even if in the background. Yet when I emailed him, taking him up on that offer. He took that private email and gave it to legal bloggers, courts, WIPO and to big and small media widespread, painting me in false light, lying about me KNOWING what the truth was and has since ruined my life.

I took my  former attorney, who claimed to humbly respect me, apologized, saying people like me were need, at his word. I  truly believed that Randazza was sincere in letting him know if he could help me, even in the background. I had lost my home, lost my income and needed a job, this was the help I truly needed. I simply asked Randazza if he knew anyone or would hire me for PR work and he maliciously, deliberately and knowing the truth painted to the world that I had extorted him and that I and iViewit Inventor Eliot Bernstein were felony, criminal extortionist, as a matter of fact.  Knowing full well that he did not believe this, he simply want to teach me a lesson, intimidate me retaliate against me, punish me for not doing as he told me and choosing him as my lawyer in my landmark ruling, and ruin my life purposely with willful wanton intent.

I relied on the legal advice of Marc Randazza.

Randazza, my former attorney obstructed my justice, violated my due process rights and my constitutional rights.  Marc Randazza was negligent in his legal representation of me, Crystal Cox and severely negligent in his duty of care, ethics and actions to harm me for years after my appeal, where he represented me.  This negligence cause me injury, defamed me, caused me irreparable harm, rendered my homeless, penniless and incited word wide hate.

A lawyer shall use tactics that are legal, honest and respectful of courts and yet Randazza deliberately lied to the courts to paint me in false light, to ruin my life and business, and to severe my family and business connections. He used his clout, legal knowledge and credibility to abuse me, violate my due process rights, violate my constitutional rights and completely destroy my life, business, reputation and personal relations with deliberate intent and full knowledge of what he was portraying about me was not true. He himself did not even belief it, as Exhibit 17 clearly shows, he knew I was ONLY asking for a job, and said he did not mind that.

A lawyer shall act with integrity and professionalism, maintaining his overarching responsibility to ensure civil conduct. Yet Randazza clearly did not do this.

A lawyer's duty to the court relates to his status as a professional who serves, not only clients, potential clients and former clients but also the public interest. Historically, a professional was distinguished from a tradesperson by a public declaration – demonstrated today by the oath taken at admission to the Bar – to serve others and devote their intellect and efforts to the public good.  Marc Randazza clearly failed in his duty to me, the court and the public.

A lawyer's duty to the court also relates to the profession's independence, or what

has been described as "the high degree of autonomy that lawyers experience from  external controls other than those imposed by self-regulation." Self-regulation is a privilege that comes with substantial obligations that are intended to protect the rights of individuals.

Randazza clearly has not maintained integrity as an officer of the court, but instead has used his power in the courts to retaliate against those whom he has a personal issue with or those who exercise their Free Speech rights and speak critical of him or his wife, as is our First Amendment Right.

He has used the power the courts have give him to issue false subpoena, scare and bulLy people into giving privileged, private information, and to file legal actions to use money, reputation and other tactics to force those he sues, litigants (targets) into taking whatever action he is trying to force them into, be it a settlement, removing gripe sites, taking down parody or graphics that poke fun at him, report on his cases representing the porn industry or really anything he disapproves of.

The duty to the court is also important because there are consequences for lawyers

who do not uphold it. This is demonstrated by the penalties attached to civil and criminal

contempt.  Yet for some reason, the courts seem to protect Marc Randazza thought he clearly, and in pattern and history across many states, does this same thing to victim after victim and has managed to not have contempt charges against him, though I have told the courts over and over what this attorney has done to me and to others in which I personally know of.

A lawyer has a duty to use tactics that are legal, honest and respectful. This duty

is often referred to as the duty of candour. Under this umbrella of a lawyer's duty to the court, lawyers are primarily responsible for ensuring that they do not employ strategies that will mislead the court; this includes misleading the court on evidentiary and legal points as well as making use of tactical strategies that are likely to affect a case.

Yet Randazza deliberate gave many courts, media, legal bloggers, NPR, Forbes, New York Times, WIPO and more, false information, false sworn statement of facts and he deliberately gave the courts false information regarding me, his former client and did so in his wife's case through his law firm, against porn industry whistleblower Alexandra Mayers.  Randazza repeatedly misleads the court and flat out lies to the court about his targets. He then uses these lies in media to force settlements, ruin lives, set people up for crimes and put them under massive, endless stalking, harassment and stress.

Randazza submitted false evidence to the courts regarding me. He did this in Randazza v. Cox in the District of Nevada, he did this in WIPO statements, in CZECH court statements, he did this to big and small media, in legal publications and on National Radio.

Marc Randazza deliberately misled the courts on laws, such as the TRO that stole my intellectual property and other laws in Randazza v. Cox. This is unlawful, unconstitutional and unethical.

Lawyers must respect the court. Respect comes in all forms – preparedness and timeliness are one aspect of consideration. Being familiar with the facts and law applicable to your case, and knowing your client's position is the most fundamental display of respect for the court process. This duty to the court is, in effect, an overlapping duty of competency we have to the client. A lawyer should not abuse the court process. A lawyer should not unreasonably raise or defend an action for which there is no legal justification.

Randazza sued me to bully, intimidate and suppress my speech. He should not have abused the court process with no real legal justification, yet he did.

Randazza knew my position in my appeal, yet went against my wishes and behind my back to strike a deal that would be good for the future and at that time current cases of his other clients, the large porn companies he represented. With this he completely violated my rights of dues process and duties owed to me as his former client, potential client, or current client.

Attorney Marc Randazza clearly disrespected the court process and, in his arrogance and disrespect of the court and the laws, completely violated my rights as a former client, a litigant and a U.S. citizen.

When dealing with others, a lawyer shall be courteous, civil and act in good faith with all persons with whom he deals with during the course of practice. Yet Marc Randazza incited world wide hate against me, filed Amicus Briefs, went on NPR, filed sworn statements, spoke to big and small media and maliciously, deliberately with willful and wanton intent incited hated, spread defamatory malicious lies, and did not act civil, not courteous and NOT in good faith.

A lawyer's duty of civility extends to those individuals who are integral to our legal process – such as witnesses.  Yet Marc Randazza threatened, bullied, sued, and maliciously attacked my church, those I worked for, ex's, those I minister to and did not act with civility at all.

Marc Randazza owed me a ''standard of care'' in which he clearly breached.

Legal Malpractice is a breach by an attorney in the standard of care or in the standard of conduct that is applicable to all attorneys.  Clearly Randazza breached his standard of care when it comes to me, Crystal Cox.

Details and Explanation of my Grievance

On January 16, 2012 at 2:30 pm I emailed my former attorney Marc Randazza, and asked him if he or anyone he knew would hire me for PR services. As, with my case, I had lost my home, my, business, my way to make money, and I was struggling.  Randazza had emailed me prior and told me that people like me were important, and that if he could help in any way, even if only in the background, to let him know.

Exhibit 21 shows Randazza saying, "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."

Randazza emailed me back and demanded that I give him a domain name that he thought I had no right to own. When I refused, he became enraged.

On January 16, 2012 2:36 PM, Randazza emailed me and said ‘’You want to make an enemy of me, really?’’ As Exhibit 17 clearly shows.

On Jan 17, 2012 at 6:52 AM, Marc Randazza emailed me, as seen in Exhibit 17 and expressed his frustration with me, his anger, and the fact that he did not mind me asking for a job. Which shows he clearly knew and fully believed that I was asking for a job.

Yet, he gave a part of this email thread to Kenneth P. White, attorney and legal blogger at Popehat.com, he leaked it to Forbes, NPR, the New York Times and claimed it was the crime of Extortion.  My former attorney, was so vengeful he then contacted the opposition and offered to give information about me to help them win their case AGAINST ME. All this with total disregard for my rights as his client, former client or his potential client.

On March 7th, 2012,  my former attorney Marc Randazza contacted Tonkon Torp Law Firm, the Opposition in my Obsidian case and he offered to give testimony that would set me up for the crime of Extortion and thereby help them to win the Ninth Circuit appeal.

Clearly, this was unethical, unlawful and unconstitutional. This violated my rights as a former client, and with total disregard for my rights as a litigant in the case, a case of which he had my inside information, my secrets, my strategy and had negotiated on my behalf.

Randazza initiated and was planning on giving a deposition against me, a client he had represented in that same case.

Approx. March 30th, 2012, Marc Randazza began publishing false and defamatory statements on his legal blog accusing me of having a blog about his child, attacking an infant and being an extortionist. None of which were true in any way nor adjudicated fact.

As noted above, Randazza clearly did not, himself, believe I had tried to extort him but was only asking for a job. Therefore he deliberately, willfully and with malicious intent painted me in false light on his blog, and from there to media around the world.

On April 2nd 2012,  Forbes Reporter Kashmir Hill began publishing false and defamatory statements claiming that I had attacked Randazza’s child, had a blog about his child, and had extorted Randazza. My former attorney told FORBES, a household name, that I was a criminal, and he painted me out to be evil, and therefore ruined my life, my relationships, my business. And he did so, ALL, with knowledge it was false and with malicious intent.

On April 3rd 2012, Randazza Legal Group attorney Jordan Rushie published false and defamatory statements, accusing me of being a scammer, and extortionist and painting me out to be a very bad person who had committed crimes.

Jordan Rushie of Randazza Legal Group did this in an article on Philly Law Blog Titled "The Evolution of Crystal Cox: Anatomy of a Scammer", dated, April 3rd 2012.  Jordan Rushie posted false and defamatory statements regarding Cox being guilty of extortion and attacking a three year old. This blog post is the top Google search for my name, and was posted with deliberate intent to ruin my life, my business, harm my legal case, pressure me to settle, stop my appeal, intimidate me, bully me, and harass me.

Randazza Legal Group attorney Jordan Rushie also has a hate blog against me with the domain name Crystal-Cox.com.

On April 6th 2012, Bob Garfield, NPR reporter interviewed my former attorney Marc Randazza on  New York Public Radio. The show was called “COMBATING "BAD" SPEECH WITH MORE SPEECH”, Dated, April 06, 2012.  On the Media, as Exhibits show.  

Bob Garfield and Marc Randazza stated false and defamatory, slanderous statements maliciously to the entire world, in a nationally syndicated radio show. With full knowledge it was false and with deliberate, malicious intent to harm me.

Bob Garfield and Marc Randazza accused me of attacking a child online, of being guilty of extortion, and all manner of unethical and criminal activity. These  false and defamatory statements in this world wide medium of communication has caused me immeasurable, irreparable damage.

On April 14th 2012, my former attorney Marc Randazza filed a Protective Order Against me in the Las Vegas Courts. I have and had never met the man. He was the one attacking, threatening and bullying me and using gangs of attorneys, fraud investigators, big and small media and radio to harass, defame and intimidate me. Yet he files for a protective order against me, his former client of which he had duties and Obligations to.

On April 27th, 2012, my former attorney, Marc Randazza continues to interfere in my Ninth Circuit case and try and set me up, exposes my secrets to the opposition and even works with them to attempt to seize my alleged assets to cover my $2.5 million dollar judgement.

Randazza had no ethical, moral, constitutional or lawful reason to be working with the opposition in my case, directly against my best interest. He was my former attorney, he counseled me in the case, he worked on motions, transcript ordering, negotiations and then he works with the opposition to cause me harm.

Randazza helped the opposition, Tonkon Torp Lawyer David Aman to help them attempt to seize domain names, Randazza recommends receiver Lara Pearson, as he had previously used her in the Righthaven case out of Nevada. My former attorney that was under oath to act in my best interested, advised the Opposition’s attorney David Aman to use Lara Pearson as a receiver to come for my alleged assets. There was no other way an Oregon attorney would have chose this exact person. Randazza continued his campaign to harm me.

Randazza continued to tell legal bloggers, law firms, reporters, radio and more that I had extorted him and harmed his child, his family. He did so with full knowledge of it being false.

On May 11th 2012, the Opposition in the case Obsidian Finance Group v. Crystal Cox out of the District of Oregon, filed a multi-million dollar legal action against Eliot Bernstein. Eliot Bernstein had not been a defendant in that case, was not named anywhere in that case, and the jury had happened 6 months prior and found Cox liable for $2.5 million at that time. This lawsuit was filed as an addendum to District of Oregon 3:11-cv-00057-HZ , Docket Entry 136-138.  The motion / lawsuit was denied, however from that moment on Eliot Bernstein was named on the docket as a defendant in the case and as having a $2.5 million dollar judgement against him, clearly defaming him, harming his multi-billion dollar technology actions and causing him harassment, stress and endangerment to him and his family.

This legal action was due to Marc Randazza’s accusations against Cox and Bernstein and leading the opposition in the Obsidian case to believe that we had extorted him and we had assets that the Opposition could come for. Randazza created this and counseled the opposition in this case on these matters.

On Jun 18th 2012, Marc Randazza filed a Czech court complaint against me and Eliot Bernstein, who invented iViewit, a video technology that the porn industry uses, and someone who I have been reporting on for over 5 years.

This complaint was to initiate a domain name dispute. In this case, Marc Randazza stated false and defamatory statements and claimed that I and Eliot Bernstein had extorted him. He painted me, his former client, in false light and he drug in others whom I had reported on.

Marc Randazza used the articles and blogs of Forbes Kashmir Hill, attorney Jordan Rushie and New York Times reporter David Carr’s false and defamatory statements as his evidence to steal the intellectual property. Even though he himself had created that alleged evidence by telling them flat out lies, knowing full well they were lies about his former client, and even though they are hearsay.

Essentially using his own interviews with them as purported and believed evidence, though it was false and defamatory statements of fact with willful, wanton, deliberate and malicious intent.

On July 27th 2012, Marc Randazza filed a WIPO (World Intellectual Property Organization)  complaint out of Switzerland against me and Eliot Bernstein, to initiate a domain name dispute.

In this case, Marc Randazza stated false and defamatory statements to a third party concerning me. He again used Forbes Kashmir Hill, Jordan Rushie and David Carr’s false and defamatory statements, hearsay, as his evidence to steal my intellectual property.

Clearly knowing it was false, Marc Randazza stated in sworn statements to WIPO that Crystal Cox and Eliot Bernstein were guilty of Extortion and had also extorted him personally, yet attorney Marc Randazza had filed no criminal charges against either of us nor was I given due process of law in these very serious allegations, that my former attorney swore that I was guilt of and had participated in, according to him, as a matter of fact.

As the record shows Big and Small Media as well as attorney bloggers, radio shows, international intellectual property law, legal publications, the associated press, small and large bloggers and publishers and more picked up the story or were directly told by Randazza false and defamatory statements and told to post his version of the facts, which, as Exhibits show, were clearly false and defamatory and with full knowledge of the law and their falsehood.

On November 28th, 2012,  My former attorney Marc Randazza filed a Trademark claim against me in the District of Nevada. Case 2:12-cv-02040-JAD-PAL, in order to steal massive online content, domain names and blogs and to chill my online speech that spoke critical of him, reviewed him and his law firm and discussed what he had done to me and to others who have by then contacted me.

Marc Randazzza claimed that I had violated his Trademark with my Gripe sites complaining about how he had treated me, griping about him, and making fun of him and his law firm.

On December 14th, 2012, Judge Gloria Navarro GRANTED Randazza’s

Ex Parte Motion for Temporary Restraining Order and Motion for Preliminary Injunction and gave him my intellectual property, my gripe sites, with NO first amendment  adjudication whatsoever. They simply stripped my rights of due process and constitutional rights.

Judge Gloria Navarro used the hearsay evidence that Marc Randazza gave her to make this ruling. And that evidence was the Jordan Rushie blog, Forbes and other legal blogs that he himself had told personally that I was guilty of extortion, and had attacked his infant child. And the WIPO ruling, containing his flat out (sworn) lies that I, and Eliot Bernstein were criminal extortionists and had caused him personal harm.

Judge Gloria Navarro used this non-adjudicated hearsay as adjudicated factual evidence and seized massive blogs, domain names, and online content of which gave Randazza top search engine placement. With total disregard for my rights.

Judge Gloria Navarro also ruled that the domain name servers be allowed to be changed and the domains given to Randazza without adjudication. Randazza then used all my blog posts, my hard work, my decades of proprietary knowledge, and search engine placement to redirect to ONE blog post on Randazza’s esteemed legal blog attacking and defaming me, accusing me of illegal behavior and harming children.

Marc Randazza filed this legal action, a SLAPP suit, against me in the District of Nevada. Randazza’s attorney of record in the case was Ronald D. Green of Randazza Legal Group. This harassing case is ongoing to this day.

Randazza filed this case to stifle my speech, chill my speech, remove blogs that spoke critical of him and his law firm or made fun of him, steal domain names that he did not want me to have and essential, completely violate my rights of due process of law, my rights as his former client, my First Amendment Rights and my Free Speech Rights.

Marc Randazza, my former attorney made sworn court statements that I had extorted him and he gave these sworn, false and defamatory statements as his evidence to federal court with full knowledge that they were false.

My former attorney, Marc Randazza did not file criminal charges with the “authorities’’. Nor did he  file charges with the attorney general or any other body of authority, regarding his allegations that I and Eliot Bernstein had extorted him, was guilty of extortion or had been in ANY prior case where I was investigated and found guilty of the felony crime of extortion.  

Instead Randazza used his power of the courts and legal knowledge to cause me and Eliot Bernstein harm, harass and defame us worldwide.

Marc Randazza, an attorney of  law, would certainly know how to file criminal charges. Yet instead, Marc Randazza violated the rights of his former client and did not file criminal charges and thereby allow me due process of law. Instead, this well known attorney used world renowned media outlets such as Forbes, the New York Times and NPR, and an international, highly reputable publication put out by WIPO as his court of law, judge and jury and simply pronounced that I and iViewit Inventor Eliot Bernstein was guilty of the felony  crime of extortion.

On Nov. 30th 2012, attorney and colleague of Marc Randazza, Peter L. Michaelson, Sole WIPO Panelist, made his ruling AGAINST me and Eliot Bernstein, based SOLELY on the false and defamatory, deliberate, malicious lies of my former attorney Marc Randazza. And the evidence he submitted to WIPO, which was hearsay articles in media where he himself had told them that I and Eliot Bernstein was a criminal extortionist.

This WIPO ruling was published worldwide in a highly esteemed intellectual property publication and defamed me thoroughly causing me irreparable harm.

WIPO then published false and defamatory statements to a third party concerning me  and iViewit Video Technology Inventor Eliot Bernstein in a WIPO publication, which has a widespread, international reader base.

In this publication, WIPO panelist, attorney Peter L. Michaelson flat out accused us of the Crime of Extortion, with no due process of law whatsoever.

After attorney Peter L. Michaelson’s false and defamatory statements were published in an International WIPO complaint decision,  Marc Randazza via his attorney Ronald D. Green of Randazza Legal Group, used this publication as judicial evidence in the District of Nevada case to harm me and Bernstein and flat out steal our intellectual property, even though my former attorney Marc Randazza was the one who made the Statements to WIPO in the first place.  

At this point the statements in the WIPO publication made by Defendant Peter L. Michaelson of Defendant WIPO BECAME official evidence and proof in Defendant Randazza’s case against Plaintiff Cox and Eliot Bernstein (then District of Nevada Case 2:12-cv-02040-GMN-PAL).

Next, Judge Gloria Navarro used the “evidence”, “legal commentary” and slough of false and defamatory statements made by Randazza as justification to give massive domain names and intellectual property to Marc Randazza in a preliminary injunction. This wiped out thousands of links, wiped out the search engine ranking of mine, deleted massive amounts of content that I had created online, and damaged my intellectual property and online media. This action by a federal judge also caused a  backlash of defamation, harassment, retaliation and loss of reputation, clients, friends and family, of which has been going on for over 3 years now and I have no way to recover.

It has rendered me homeless, penniless, and with no way to rent a home, get clients or secure income to survive. My former attorney painted me to the world as a criminal, a scammer, an extortionist and someone who harms children.

I am an anti-corruption blogger and defend the rights of children as well as all victims of corruption. Randazza knew this and said people like me are needed, important and he respected me, then he turned right around and painted a lie to the world and deliberately, maliciously ruined my life. And with deliberate, inside personal knowledge that what he was saying was indeed false statements of fact.

On January 3, 2013 the Multnomah County Sheriff in the State of Oregon had scheduled a courthouse steps sale on my right to appeal my Ninth Circuit case and thereby revoke my 2.5 million judgement and also follow through with the ruling on this important issue of bloggers having equal rights as a matter of law as main stream news journalists and the institutional press.

My appeal had already been filed long before. Yet the opposition had just learned that they may be able to SEIZE my constitutional right to appeal, as an asset to satisfy the

If this were to happen there would no longer be a Ninth Circuit Cas. It was filed in an Oregon court of which was not connected to the lower court case or the Ninth Circuit case, thereby trying to slip in an auction of my rights, to literally steal my right to appeal.

I was my own attorney in the part of the case that dealt with my assets, or any judgement being satisfied. So I contacted Eugene Volokh, my Ninth Circuit attorney, he then filed a motion to STAY the sale, filed in the District of Oregon 3:11-cv-00057-HZ at Document 145.

We won the motion to stay and stopped the sale just in time.

Apparently it is legal to do this in some states and not in others.

On February 11th, 2013 I had a phone conversation with Florida Attorney Todd Levine. I asked him about procedures such as this. He told me that it used to be popular in the State of Florida. This action of seizing people’s right to appeal in lieu of their debt / judgement in the original case.  

My former attorney, Marc Randazza, having been a Florida attorney for a long time, and starting his career there, had been very familiar with this process (scheme) in which violated the constitutional rights of litigants to appeal a case.

Randazza had counseled, provided information to and basically gave attorney advice to the Opposition in my case that went against my best good, and to completely shut me down in my Ninth Circuit appeal. With total disregard that he had been my counsel prior to this and owed me a duty of ethics, no conflicts of interest, no disclosure of my information in any way.

On February 21st, 2013, Docket entry 87 of Randazza v. Cox, shows Exhibits of Marc Randazza emailing CPA, and Summit Bankruptcy whistleblower Stephanie DeYoung bullying her into giving him Defendant my financial information, and any information on a Church that he claimed  I had started.

Stephanie DeYoung was never my CPA and  I had not yet started a church at this time,  Randazza, acting as his own attorney, attempted to get DeYoung to give my private financial information, threatening to subpoena her, sue her and other bullying tactics.

On May 13th 2013, Eliot Bernstein filed a motion regarding fraud on the court, and included his being harassed by my former attorney Marc Randazza, See Case Number 1:07-cv-11196-SAS, Bernstein v. Appellate Division First Department , Southern District of New York. Page 56-81 (Exhibit V)

On January 17, 2014, Ninth Circuit Case: 12-35238  ID: 8964107, Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, Circuit Judges accused me of having a history of posting things online and seeking money for a retraction. They did this in an appeal ruling, in which I won. My $2.5 million judgement was overturned. I was headed back to the lower court pro se. These Judges used a New York Times article by David Carr, which is legally hearsay, as adjudicated fact, and simply threw into the ruling that I had a history of extortionate behavior.

My former attorney conspired with others to paint this picture to the world. The New York Times article was NOT adjudicated fact, nor was it any part of the lower court ruling, or case. Yet Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz sought out this article and used it, as evidence, as if adjudicated fact, and painted me out to be a criminal, with complete denial of due process as I am entitled, as a matter of law and constitutional rights. My former attorney Marc Randazza maliciously painted me out to be a bad person, a felony extortionate and one who attacks infants.

Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, simply adding lib, and throwing in these unadjudicated statements was unlawful and prejudiced me as I was heading back to the lower court Pro Se. So I asked my Ninth Circuit attorney Eugene Volokh to file an appeal and seek a retraction of these criminal allegations by an esteemed panel of higher court judges.

As an activist litigant, I did not want this to happen to other investigative bloggers, whistleblowers, and citizen journalists, so I appealed through my attorney. As I felt this was my duty and obligation.

On January 27th 2014, Randazza Legal Group (RLG) issued a subpoena to Godaddy, the Notice of Subpoena was District of Nevada, and signed by “Law Clerk” at RLG, signature cannot be made out, and no printed name.The actual subpoena to Godaddy said “District of Arizona” on the documents, and stated that a C. DeRose at 5131 N. 40th St, A310, Phoenix AZ would examine all financial data, electronically stored information, billing data, IP data, server data, all phone numbers, and contact of anyone associated with accounts or to the specified people that Randazza wanted personal, financial and intellectual property information on; to be examined on Feb. 7th, 2014.

The Exhibit to this subpoena was a District of Nevada document stating further persona, private,and financial data that RLG was commanding that Godaddy turn over to them in regard to Crystal Cox.

This Subpoena gave RLG access to the private and financial information of porn industry insiders, whistleblowers such as Monica Foster aKa Alexandra Mayer and Diana Grandmason,both exposing RLG and their connections to Organized Crime in the Porn Industry, prostitution forced on porn actors, pedophiles connected to RLG and the activities of the Free Speech Coalition and RLG to move the porn industry to Las Vegas.

This Subpoena also gave RLG access to the private data and financial information of iViewit inventor Eliot Bernstein.

On January 27th 2014, Randazza Legal Group (RLG) issued a District of Nevada subpoena to Verizon Wireless, the actual Subpoena is District of Northern Texas, this subpoena commands Verizon, though Klemchuk Kubasta LLP 8150 N. Central Expressway, 10th Floor Dallas, TX to be allowed to inspect documents requested on February 10th, 2014.

The Exhibit to the subpoena, a District of Nevada document COMMANDING that Verizon give Marc Randazza, My personal private information, phone numbers, personal calls, business calls, billing and payment information, data that breaches the privacy of countless individuals and companies, lawyers, media, clients, customer, and my friends.

This subpoena also gave Randazza access to phone numbers and data of sources whom had told Cox of issues of organized crime, prostitution and more in which Cox was reporting on connected to RLG, the Free Speech Coalition and the Organized Crime in Porn. Including delicate and private information, texts, phone numbers, contacts of those who have been threatened by RLG and connections.

The Subpoena also requested all other numbers on the account thereby unjustly data mining Cox’s family, friend, business partners, and personal relationships.

The Subpoena also allowed Randazza to access who may help Cox pay her bills, or help her to have a phone. As Cox has no money, no home and is penniless due to the relentless actions of Cox. This compromises the private information of those helping Cox to have a lifeline, a phone. This could also give RLG access to where Cox is located at all times and as Cox has stated many times to the courts, my  life is in and had been in danger, under constant duress and threats by those in the porn industry connected to Randazza and this is potentially life or death to Cox and her sources.

Cox claims Randazza issued a false instrument, impersonated a Subpoena and has caused Cox and those connected to her irreparable harm.

Randazza used his role in this case and as an officer of the court to get people in Cox’s life to give him private information in which he used, not to win this case, but to set Cox up for the crime of extortion, and to broadcast what he found such as private church trips, money Cox got in handouts, and used his power to expose Cox’s personal life, home address, phone number, clients, those she ministers to and her sources inside the porn industry.

Randazza got subpoenas to get personal information of Diana Grandmason, certified human trafficking victim and Monica Foster, adult industry insider and investigative blogger, this had nothing to do with the lanham act, trademark or the merits of this case.

On January  31st 2014 Cox Appealed her Ninth Circuit Case Win: ID: 8961401 Docket Entry: 48, Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz had accused Cox of having a history of extortionate behavior in a Ninth Circuit ruling. This was not adjudicated fact nor a part of the Obsidian v. Cox case or appeal.  Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz simply used a Ninth Circuit ruling to paint Cox as a criminal to the world.

This case filing sought a retraction of the words in which were taken from New York Times article, which was hearsay and stated that I had a history of posting online and then seeking a retraction. Of which I had no history whatsoever before this case painted me in that false light, with deliberate,  malicious intention.

This case filing ENRAGED my former attorney Marc Randazza. As his WIPO case, his case in the District of Nevada against me, his interviews with NPR, the New York Times and Forbes and his statements to many legal bloggers and multiple media would all be discredited if the judges retracted this defamatory statement that had NO relevance to the case.

So my former attorney, who legally, morally, constitutionally and ethically was sworn to NOT seek that is which in opposition of my best interest, filed a hateful, rageful, accusatory, defamatory Amicus Brief to the Ninth Circuit AGAINST me.

On February 3rd 2014, Marc Randazza Cox's filed, Obsidian Finance Group, LLC v. Crystal Cox: Brief of Amicus Curiae, Ninth Circuit Case: 12-35238  ID: 8964107 Dkt Entry: 49-3.  

It is unconstitutional and unethical for Randazza to file court motions such as this, in direct opposition to the best interest of his former client. Not only that, he lied under oath regarding me, his former client. Knowing full well it was false, Randazza accused me of extorting him, when clearly the email at Exhibit 17 shows that he knew I was asking for a job. Randazza did this maliciously to influence a higher court ruling and to further ruin and defame Crystal Cox.

Marc Randazza used the Ninth Circuit courts in a fraud on the court actions, whereby he deliberately lied and misled higher court Judges to influence them to accuse me of criminal activity of which I had never been under investigation for or adjudicated for.

On February 26th, 2014, Martin Cain, another person I had previously reported on, filed: BRIEF OF AMICUS CURIAE MARTIN CAIN, Ninth Circuit Case: Case: 12-35238

ID: 8994409 Docket Entry: 55-1. The Attorney who filed this brief was sought out for and paid for by Marc Randazza.

This Amicus Brief was filed by:

Allan B. Gelbard, Esq.

Law Offices of Allan B. Gelbard

15760 Ventura Blvd., Suite 801

Encino, CA 91436

Allan B. Gelbard is a colleague of Randazza and was secured and paid for by Marc Randazza himself. This was in direct violation of my rights as Randazza’s former client.

On or about March 5th 2014, Marc Randazza, my former attorney filed, Randazza et al. v. GoDaddy LLC et al., case number 2014-5636-CA-01, in the Circuit Court for the Eleventh Judicial Circuit of Florida.

Randazza filed this lawsuit in Florida, as he is a Florida attorney as well, and wanted to use Florida laws that would favor his agenda to obtain my personal information, billing information, phone information, and home address.  He also used this legal action to obtain private information, attack and harass Eliot Bernstein (iViewit Inventor), Porn Industry Bloggers and Whistle blowers Diana Grandmason and Alexandra Mayers. Diana Grandmason is also a registered Human Traffic Victim. I often used their blogs as sources of posts on my blogs. Randazza retaliated against them as well for this.

Diana Grandmason and Alexandra Mayers are Whistleblowers and should have Federal and State Protection in this regard. They are constantly harassed by Randazza Legal Group and those connected to Marc Randazza as well as Randazza himself. These 2 women are porn industry insiders and have reported on organized crime in the porn industry for years. I have picked up a few of their stories, and had Randazza do the same thing to me in which he and his associates did to them and other porn industry whistleblowers. They are in constant danger, under constant threats and duress by Randazza and those connected to him.

Randazza et al. v. GoDaddy LLC et al, Florida, was a legal filing for a bill of pure discovery, so he could set us all up for the felony crime of extortion, he claimed to the media it was to ''bring extortion claims against a group of individuals allegedly behind a collection of defamatory websites''.

Marc Randazza also told media ''that a group led by Crystal L. Cox, a blogger at the center of a notable recent defamation case, has conspired to extort money from him by buying website domain names related to his and his family members' names, filling them with false and harmful statements and seeking payment for retractions of the statements''.

My former attorney, did this maliciously and deliberately, knowing full well that it was not true in any way. And that I had been given no due process on these allegations.

This legal action, Randazza et al. v. GoDaddy LLC et al, targeted information from GoDaddy, Web.com Group Inc. and SoftLayer Technologies Inc. that Randazza claimed was relevant to his claims.

Yet, this was really used to get private information on us all to use to attack us further, defame us, harass us, intimidate us, bully us and sue us in other courts. And as he himself has stated over and over, to set us up for the crime of extortion as a group.

At this time Randazza told Law360  ''Cox is a “well-documented extortionist,” Randazza says, also describing her as “by her own claim” homeless and living in a church property''

Randazza also claimed to Law360 that ''Cox enlisted the help of other individuals, including Eliot I. Bernstein of Florida, Alexandera A. Mayers of Las Vegas and Diana Grandmaison of Florida''

AND

“Together, the tortfeasors continue to assist and aid one another in publishing false and harmful statements about plaintiffs in a constantly shifting configuration of straw ownership in order to avoid detection by plaintiffs, legal liability for their unlawful actions and to conceal the true ownership of these websites and domain names,” Randazza says.

My former attorney knew this was false, yet maliciously kept up his life ruining harassment campaign against me.

These two women were targeted in the same way as I was and in their research they came across me, and me them. So Randazza targeted them along with me to stifle free speech, to flat out STOP the flow of information online that painted him in a less than favorable light.

Randazza and his Associates have stalked Alexandra Mayers and Diana Grandmason for years, and due to their connection to higher ups in the Porn Industry, they have had no State or Federal Protection. Randazza has posted the make and model of Alexandra’s car, her home address and wished he Death. I have even been told that he has said that if he thought it would only kill her he would throw a Molotov cocktail into her home.

On or about March of 2014, Marc Randazza contacted people I had worked for, got my pay documents by threatening to sue them. Then posted this in court motions which he leaked to online media and is now accessible to the world.

My former attorney got my information unethically and by intimidating people and then broadcast it to the world via court motions he filed then posted on his and other legal blogs of his conspirators.

Around this same time Randazza, harassed, threatened, bullied and attacked my church. He scared them into giving him my home address, church trips, banking information, phone information and then he posted this information online and in court motions which his co-conspirators then broadcast world wide.

All this put me in danger. And though I could not rent a home due to Randazza’s defamation nor get any more clients to have an income. From that point I could no longer living in the church housing, as I was in fear of my life, I was followed by a Private Investigator hired by Marc Randazza, and under constant bullying and attacks from his associates via phone, text, email, threats to my kneecaps, threats to coming to my home, and constant online hate and extreme defamation.

Since May of 2013 I have been homeless, having been unable to live in church housing or rent a home. I have no way to make a living, and eat via social programs and church handouts.

Also around this time, Randazza contacted and bullied, threaten to sue, and harassed my ex’s, my former church associates, and other people and threatened to sue them if they did not tell him all they knew about me. Randazza used his Nevada SLAPP suit against me as his authority to these folks to make them give him my private information which he used to harm me.

On March 12th 2014 (Document 181-1), District of Nevada Randaza v. Cox,  my former attorney Randazza filed yet another sworn declaration with the court, and flat out lied in this court documents, that Cox had Extorted him and his family.

Exhibit 17 is an Email from Marc Randazza to his former client Crystal Cox that proves he did not think his client's email to him was trying to extort him, but instead merely asking for a job.

On April 10th, 2014 Randazza filed a SLAPP lawsuit against Porn Industry Insider, Whistle Blower and Investigative Blogger Alexandra Melody Mayers in District Court, Clark County, Nevada, Eighth Judicial District, Case A-14-699072-C.

This lawsuit was to suppress her speech, shut down her blogs and remove her parody of him online. It was also to harass her, bankrupt her, intimidate her and teach her a lesson.

My former attorney Marc Randazza had claimed that I owned RandazzaNews.com and that I had created a parody of his daughter 30 years into the future. Yet he then sued Alexandra Mayers, claiming it was her. Randazza sued he to stifle her speech, shut down her blogs speaking critical of him and stop the flow of information online regarding him and his wife Jennifer Randazza.

Randazza v. Mayers A-14-699072-C, District Court, Clark County, Nevada, Eighth Judicial District, Department 32, was filed in order to teach Alexandra Mayers a lesson for supporting me, and helping to keep me visible and safe from those in the porn industry who had threatened me, intimidated me, bullied me and constantly attacked me online.

This case was for Defamation and False Light, and was a SLAPP suit designed to chill the speech of this blogger whom had tried to help me stay safe.

Nevada attorney Marc J. Randazza, has been involved in prostitution, organized crime, and pornography. All who try and report on him are shut down somehow by him and his associates.

On April 8th 2014 , I filed a Supreme Court Appeal regarding Ninth Circuit Case: 12-35238  ID: 8964107 whereby Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, accused me of having a history of posting things online and seeking money for a retraction. This was flat out false and based only on a New York Times article, of which Randazza himself had created the media storm that painted me, his former client out to be a criminal extortionist and he brought in IViewit Video Technology Inventor Eliot Bernstein. This case was Docketed on April 16, 2014, with the Supreme Court of the United States, see Crystal Cox, Petitioner;  v.Obsidian Finance Group, LLC, et al.;   Case (12-35238, 12-35319)

AT this time Randazza v. Cox is still going on in the state of Nevada. I cannot afford an attorney and simply do the best I can to continue to fight for my life and stand up for my rights and the rights of Randazza’s other victims.

Nevada Rules of Professional Conduct Randazza Violated

CLIENT-LAWYER RELATIONSHIP

Randazza did not abide by my decisions concerning representation. He did not consult with me before proposing a deal allegedly on my behalf and in my best interest with the opposition, and he sought EXTREME retaliation when I chose to longer have him represent me as his client. This is a Violation of Rule 1.2.

Randazza did not abide by my wishes of wanting to appeal and pursued a settlement with the opposition of which he did not include me in the details of this negotiation.

Randazza acted in representations of Cox, without informed consent. And therefore violated Rule 1.2

Randazza did not discuss with me any actions that he thought I may have taken that he thought were criminal, of which, as my attorney he is obligated to. Instead he used his power over the courts and his clout with the media to defame me, and abuse me massive stress and irreparable harm.

If he thought I engaged in any criminal activity, it was his lawful and ethical duty to discuss this with me, instead of simply tell the world and the courts I was guilty of a crime with no adjudication or due process.

Rule 1.2.  Scope of Representation and Allocation of Authority Between Client and Lawyer.

     (a) Subject to paragraphs (c) and (d), a lawyer shall abide by a client’s decision concerning the objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. A lawyer shall abide by a client’s decision whether to settle a matter.

     (b) A lawyer’s representation of a client, including representation by appointment, does not constitute an endorsement of the client’s political, economic, social or moral views or activities.

     (c) A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.

     (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.

 Rule 1.5.  Fees.

Randazza violated rule 1.5 as he told me he was representing me for FREE, Pro Bono, then he turned around and wanted money to travel, to file documents, for hotels and more. Knowing full well that I had NO MONEY.

Rule 1.6.  Confidentiality of Information.

  Attorney Marc Randazza revealed ALL of my private information, strategy and secrets, not only to the opposition without informed consent but to the entire world.

He violated Rule 1.5 in revealing my information without informed consent as the chronology above clearly shows.

Randazza also violated Rule 1.5 in putting me in physical harm, inciting hate among his peers and the world. And encouraging threats, harassment and online attacks of me. As well as physical threats of coming to my town, of taking out my knee caps, text threatening of knowing where I live and more.

Randazza published my home address to the world and used court motions to attack me, then gave those to media to defame me and expose my personal information and home address to the world.  All the while claiming I had harmed an infant child, lying about me and inciting world wide HATE.

Also under this rule, if he thought I had committed a crime then he went about handling it, completely unethical and in violation of my due process rights.

Randazza did not make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the representation of a client. Therefore he violated Rule 1.5.

(a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by paragraphs (b) and (d).

  (b) A lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary:

         (1) To prevent reasonably certain death or substantial bodily harm;

         (2) To prevent the client from committing a criminal or fraudulent act in furtherance of which the client has used or is using the lawyer’s services, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take suitable action;

         (3) To prevent, mitigate, or rectify the consequences of a client’s criminal or fraudulent act in the commission of which the lawyer’s services have been or are being used, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take corrective action;

         (4) To secure legal advice about the lawyer’s compliance with these Rules;

         (5) To establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client; or

         (6) To comply with other law or a court order.

         (7) To detect and resolve conflicts of interest arising from the lawyer’s change of employment or from changes in the composition or ownership of a firm, but only if the revealed information would not compromise the attorney-client privilege or otherwise prejudice the client.

  (c) A lawyer shall make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the representation of a client.

  (d) A lawyer shall reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary to prevent a criminal act that the lawyer believes is likely to result in reasonably certain death or substantial bodily harm.

Rule 1.7.  Conflict of Interest: Current Clients.

  I Randazza had a conflict of interest or felt that Cox was a criminal and did not want to represent her, then he should not have done so. Instead of getting her private information, strategy and secrets and then ruining her life, as details above, clearly show.

It is also a conflict of interest for Randazza Legal Group to represent Marc Randazza in suing his former client in the District of Nevada Randazza v. Cox case, as this law firm represented Cox and had a duty and obligation to her before representing another party to sue her, even if that party was one of their partners or own attorneys.

Randazza should not have sued me, nor represented himself doing so with the same law firm that represented me prior.

Rule 1.7 was clearly violated by Randazza

Rule 1.7

(a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest. A concurrent conflict of interest exists if:

         (1) The representation of one client will be directly adverse to another client; or

         (2) There is a significant risk that the representation of one or more clients will be materially limited by the lawyer’s responsibilities to another client, a former client or a third person or by a personal interest of the lawyer.

  (b) Notwithstanding the existence of a concurrent conflict of interest under paragraph (a), a lawyer may represent a client if:

         (1) The lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client;

         (2) The representation is not prohibited by law;

         (3) The representation does not involve the assertion of a claim by one client against another client represented by the lawyer in the same litigation or other proceeding before a tribunal; and

         (4) Each affected client gives informed consent, confirmed in writing

Rule 1.8.  Conflict of Interest: Current Clients: Specific Rules.

Attorney Marc Randazza should not have engaged in any activity adverse to me, his former client and as seen above he engaged in many.

(a) A lawyer shall not enter into a business transaction with a client or knowingly acquire an ownership, possessory, security or other pecuniary interest adverse to a client unless:

         (1) The transaction and terms on which the lawyer acquires the interest are fair and reasonable to the client and are fully disclosed and transmitted in writing in a manner that can be reasonably understood by the client;

         (2) The client is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel on the transaction; and

         (3) The client gives informed consent, in a writing signed by the client, to the essential terms of the transaction and the lawyer’s role in the transaction, including whether the lawyer is representing the client in the transaction.

  (b) A lawyer shall not use information relating to representation of a client to the disadvantage of the client unless the client gives informed consent, except as permitted or required by these Rules.

 

  (d) Prior to the conclusion of representation of a client, a lawyer shall not make or negotiate an agreement giving the lawyer literary or media rights to a portrayal or account based in substantial part on information relating to the representation.

  (e) A lawyer shall not provide financial assistance to a client in connection with pending or contemplated litigation, except that:

         (1) A lawyer may advance court costs and expenses of litigation, the repayment of which may be contingent on the outcome of the matter; and

         (2) A lawyer representing an indigent client may pay court costs and expenses of litigation on behalf of the client.

  (f) A lawyer shall not accept compensation for representing a client from one other than the client unless:

         (1) The client gives informed consent;

         (2) There is no interference with the lawyer’s independence of professional judgment or with the client-lawyer relationship; and

         (3) Information relating to representation of a client is protected as required by Rule 1.6.

  (g) A lawyer who represents two or more clients shall not participate in making an aggregate settlement of the claims of or against the clients, or in a criminal case an aggregated agreement as to guilty or nolo contendere pleas, unless each client gives informed consent, in a writing signed by the client. The lawyer’s disclosure shall include the existence and nature of all the claims or pleas involved and of the participation of each person in the settlement.

  (h) A lawyer shall not:

         (1) Make an agreement prospectively limiting the lawyer’s liability to a client for malpractice unless the client is independently represented in making the agreement; or

         (2) Settle a claim or potential claim for such liability with an unrepresented client or former client unless that person is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel in connection therewith.

  (i) A lawyer shall not acquire a proprietary interest in the cause of action or subject matter of litigation the lawyer is conducting for a client, except that the lawyer may:

         (1) Acquire a lien authorized by law to secure the lawyer’s fee or expenses; and

         (2) Contract with a client for a reasonable contingent fee in a civil case.

 

  (l) A lawyer shall not stand as security for costs or as surety on any appearance, appeal, or other bond or surety in any case in which the lawyer is counsel.

  (m) While lawyers are associated in a firm, a prohibition in the foregoing paragraphs, with the exception of paragraph (j), that applies to any one of them shall apply to all of them.

  [Added; effective May 1, 2006.]

Attorney Marc Randazza stole my intellectual property, defamed me intentionally and maliciously, and caused me serious hardship.

Marc Randazza did not have a contract where he lined out any fees, yet he expected me to pay for things of which I had no real understanding and claimed to be representing me Pro Bono, for FREE.

Marc Randazza used private information, privileged information against me.

Marc Randazza had no right to portray me to the media as  he did.

Marc Randazza also violated the above rule in trying to negotiate deals, settlement and representation matters WITHOUT my consent or knowledge.  I CLEARLY did not give  Marc Randazza informed consent.

Marc Randazza violated Rule 1.8 in massive widespread conflicts of interest.

Rule 1.9.  Duties to Former Clients.

 

Marc Randazza of Randazza Legal Group represented me in pretty much the same issues exactly as RLG then represented  Marc Randazza in claims as a Plaintiff against me. This is a violation of this rule.

Marc Randazza and his law firm acted materially adverse to my interests. And did so with full knowledge and deliberate intent. This violates Rule 1.9

Marc Randazza used inside and privileged information he gained while representing me, against me to sue me. Which violates Rule 1.9.

Marc Randazza used information against me to my disadvantage. Which violates this rule.

Marc Randazza acquired protected information from me then used this to defame me, set me up for a crime, paint me out to the world as a criminal, sue me, take my blogs and intellectual property, interfere with my appeal, violated my due process laws, violated my constitutional rights, suppress my speech, harass, bully and defame me and my sources and to try and STOP my Ninth Circuit appeal against my will and my rights.  This violates Rule 1.6 and 1.9.

Marc Randazza revealed information about me, without my informed consent.

(a) A lawyer who has formerly represented a client in a matter shall not thereafter represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client gives informed consent, confirmed in writing.

  (b) A lawyer shall not knowingly represent a person in the same or a substantially related matter in which a firm with which the lawyer formerly was associated had previously represented a client:

         (1) Whose interests are materially adverse to that person; and

         (2) About whom the lawyer had acquired information protected by Rules 1.6 and 1.9(c) that is material to the matter;

         (3) Unless the former client gives informed consent, confirmed in writing.

  (c) A lawyer who has formerly represented a client in a matter or whose present or former firm has formerly represented a client in a matter shall not thereafter:

         (1) Use information relating to the representation to the disadvantage of the former client except as these Rules would permit or require with respect to a client, or when the information has become generally known; or

         (2) Reveal information relating to the representation except as these Rules would permit or require with respect to a client.

Rule 1.10.  Imputation of Conflicts of Interest.

 

Marc Randazza and his law firm RLG violated 1.10 in representing, Marc Randazza and his wife and child in suing me, their former client.

(a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.9, or 2.2, unless the prohibition is based on a personal interest of the prohibited lawyer and does not present a significant risk of materially limiting the representation of the client by the remaining lawyers in the firm.

  (b) When a lawyer has terminated an association with a firm, the firm is not prohibited from thereafter representing a person with interests materially adverse to those of a client represented by the formerly associated lawyer and not currently represented by the firm unless:

         (1) The matter is the same or substantially related to that in which the formerly associated lawyer represented the client; and

         (2) Any lawyer remaining in the firm has information protected by Rules 1.6 and 1.9(c) that is material to the matter.

  (c) A disqualification prescribed by this Rule may be waived by the affected client under the conditions stated in Rule 1.7.

  (d) Reserved.

  (e) When a lawyer becomes associated with a firm, no lawyer associated in the firm shall knowingly represent a person in a matter in which that lawyer is disqualified under Rule 1.9 unless:

         (1) The personally disqualified lawyer did not have a substantial role in or primary responsibility for the matter that causes the disqualification under Rule 1.9;

         (2) The personally disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

         (3) Written notice is promptly given to any affected former client to enable it to ascertain compliance with the provisions of this Rule.

  [Added; effective May 1, 2006.]

Rule 1.12.  Former Judge, Arbitrator, Mediator or Other Third-Party Neutral.

 

Even if Marc Randazza did not believe he represented me, which he falsely claims, then he was at least acting as an arbitrator, mediator or other third party neutral in his counsleing me via phone and email, his email saying he would represent me, his negotiations with the opposition and his communications acting as my attorney with Eugene Volokh.

Which violates Rule 1.12.

(a) Except as stated in paragraph (d), a lawyer shall not represent anyone in connection with a matter in which the lawyer participated personally and substantially as a judge or other adjudicative officer, or law clerk to such a person or as an arbitrator, mediator or other third-party neutral, unless all parties to the proceeding give informed consent confirmed in writing.

  (b) A lawyer shall not negotiate for employment with any person who is involved as a party or as lawyer for a party in a matter in which the lawyer is participating personally and substantially as a judge or other adjudicative officer, or as an arbitrator, mediator or other third-party neutral. A lawyer serving as a law clerk to a judge or other adjudicative officer may negotiate for employment with a party or lawyer involved in a matter in which the clerk is participating personally and substantially, but only after the lawyer has notified the judge or other adjudicative officer.

  (c) If a lawyer is disqualified by paragraph (a), no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in the matter unless:

         (1) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

         (2) Written notice is promptly given to the parties and any appropriate tribunal to enable them to ascertain compliance with the provisions of this Rule.

  (d) An arbitrator selected as a partisan of a party in a multi-member arbitration panel is not prohibited from subsequently representing that party.

Rule 1.18.  Duties to Prospective Client.

 

Marc Randazza claims in sworn statements that he was not my attorney. Yet he emailed me that he would take representation, he attempted to broker deals, he advised me on the phone and in emails about court transcripts, he told many attorneys he represented me, he discussed filing court motions with attorney Eugene Volokh, and counseled me on my case.

Therefore it is no excuse to have harmed me, defamed me, interfered with my business and personal relationships, only because he thought he was not acting as my attorney prior. Clearly he owed me the same standard of care as a potential client.  And Marc Randazza knew this full well as a seasoned attorney with his own law firm and in multiple states.

Marc Randazza violated Rule 1.18 and did not have my informed consent for his disclosure of my private emails, negotiation tactics, strategy, nor to provide information that caused me harm. And to do so deliberately with malicious intent.

Mr. Randazza claims, under oath, that he was not my attorney. I fully believe he was. However, if he were to convince this board that he was not my attorney, then clearly he was brokering deals allegedly on my behalf, clearly he was working with other attorneys (Eugene Volokh) and with the courts to file a motion for a new trial, as the email evidence shows, and in this was at least a third party neutral, a mediator, or I was a potential client. In that he owed me a duty to not harm me, not post my private emails to him, not paint me out to the world to be a criminal with no adjudicated facts, not offer to testify against me, not file amicus briefs in opposition to my best interest, not lie about me and defame me, protect  my rights and strategy in my case, and act with integrity as to my best interest.

If Randazza was not my attorney, then he was negotiating with the opposition, giving them my secrets, strategy, strengths and weakness without authorization from me.

Rule 1.18

(a) A person who consults with a lawyer about the possibility of forming a client-lawyer relationship with respect to a matter is a prospective client.

  (b) Even when no client-lawyer relationship ensues, a lawyer who has learned information from a prospective client shall not use or reveal that information, except as Rule 1.9 would permit with respect to information of a former client.

  (c) A lawyer subject to paragraph (b) shall not represent a client with interests materially adverse to those of a prospective client in the same or a substantially related matter if the lawyer received information from the prospective client that could be significantly harmful to that person in the matter, except as provided in paragraph (d). If a lawyer is disqualified from representation under this paragraph, no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in such a matter, except as provided in paragraph (d).

  (d) When the lawyer has received disqualifying information as defined in paragraph (c), representation is permissible if:

         (1) Both the affected client and the prospective client have given informed consent, confirmed in writing, or:

         (2) The lawyer who received the information took reasonable measures to avoid exposure to more disqualifying information than was reasonably necessary to determine whether to represent the prospective client; and

               (i) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

               (ii) Written notice is promptly given to the prospective client.

  (e) A person who communicates information to a lawyer without any reasonable expectation that the lawyer is willing to discuss the possibility of forming a client-lawyer relationship, or for purposes which do not include a good faith intention to retain the lawyer in the subject matter of the consultation, is not a “prospective client” within the meaning of this Rule.

  (f) A lawyer may condition conversations with a prospective client on the person’s informed consent that no information disclosed during the consultation will prohibit the lawyer from representing a different client in the matter. If the agreement expressly so provides, the prospective client may also consent to the lawyer’s subsequent use of information received from the prospective client.

  (g) Whenever a prospective client shall request information regarding a lawyer or law firm for the purpose of making a decision regarding employment of the lawyer or law firm:

         (1) The lawyer or law firm shall promptly furnish (by mail if requested) the written information described in Rule 1.4(c).

         (2) The lawyer or law firm may furnish such additional factual information regarding the lawyer or law firm deemed valuable to assist the client.

         (3) If the information furnished to the client includes a fee contract, the top of each page of the contract shall be marked “SAMPLE” in red ink in a type size one size larger than the largest type used in the contract and the words “DO NOT SIGN” shall appear on the client signature line.

  [Added; effective May 1, 2006; as amended; effective April 4, 2014.]

COUNSELOR

Rule 2.1.  Advisor. 

     Marc Randazza violated Rule 2. Even if Marc Randazza was NOT my attorney as he claims in court, then he was at the very east my counselor. Marc Randazza counseled me on my case, and yet turned around and deliberate caused me malicious, willful, wanton harm.

If not a counselor then at least an Advisor, Third Party Neutral or an Intermediary. And still owed me a duty of care, in which he clearly violated.

Rule 2.1.  Advisor.  In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In rendering advice, a lawyer may refer not only to law but to other considerations such as moral, economic, social and political factors, that may be relevant to the client’s situation.

  [Added; effective May 1, 2006.]

  Rule 2.1 (former Supreme Court Rule 167) is the same as ABA Model Rule 2.1.

     Rule 2.2.  Intermediary.

  (a) A lawyer may act as intermediary between clients if:

         (1) The lawyer consults with each client concerning the implications of the common representation, including the advantages and risks involved, and the effect on the attorney-client privileges, and obtains each client’s consent to the common representation;

         (2) The lawyer reasonably believes that the matter can be resolved on terms compatible with the clients’ best interests, that each client will be able to make adequately informed decisions in the matter and that there is little risk of material prejudice to the interests of any of the clients if the contemplated resolution is unsuccessful; and

         (3) The lawyer reasonably believes that the common representation can be undertaken impartially and without improper effect on other responsibilities the lawyer has to any of the clients.

  (b) While acting as intermediary, the lawyer shall consult with each client concerning the decisions to be made and the considerations relevant in making them, so that each client can make adequately informed decisions.

  (c) A lawyer shall withdraw as intermediary if any of the clients so requests, or if any of the conditions stated in subsection 1 is no longer satisfied. Upon withdrawal, the lawyer shall not continue to represent any of the clients in the matter that was the subject of the intermediation.

  [Added; effective May 1, 2006.]

Model Rule Comparison—2006

  Rule 2.2 (formerly Supreme Court Rule 168) is based on 1983 Model Rule 2.2. The ABA House of Delegates deleted Model Rule 2.2 and incorporated it into the comments to Model Rule 1.7 in 2002. The Rule has been retained in Nevada because Nevada has not adopted comments to the Rules and the Rule provides some guidance in clarifying conflict of interest concerns.

     Rule 2.3.  Evaluation for Use by Third Persons.

  (a) A lawyer may provide an evaluation of a matter affecting a client for the use of someone other than the client if the lawyer reasonably believes that making the evaluation is compatible with other aspects of the lawyer’s relationship with the client.

  (b) When the lawyer knows or reasonably should know that the evaluation is likely to affect the client’s interests materially and adversely, the lawyer shall not provide the evaluation unless the client gives informed consent.

  (c) Except as disclosure is authorized in connection with a report of an evaluation, information relating to the evaluation is otherwise protected by Rule 1.6.

  [Added; effective May 1, 2006.]

Model Rule Comparison—2006

  Rule 2.3 (formerly Supreme Court Rule 169) is the same as ABA Model Rule 2.3.

     Rule 2.4.  Lawyer Serving as Third-Party Neutral.

  (a) A lawyer serves as a third-party neutral when the lawyer assists two or more persons who are not clients of the lawyer to reach a resolution of a dispute or other matter that has arisen between them. Service as a third-party neutral may include service as an arbitrator, a mediator or in such other capacity as will enable the lawyer to assist the parties to resolve the matter.

  (b) A lawyer serving as a third-party neutral shall inform unrepresented parties that the lawyer is not representing them. When the lawyer knows or reasonably should know that a party does not understand the lawyer’s role in the matter, the lawyer shall explain the difference between the lawyer’s role as a third-party neutral and a lawyer’s role as one who represents a client.

ADVOCATE

     

Marc Randazza acted as my advocate. He spoke with other attorneys, my colleagues, and he told me that people like me are important. He was an advocate for me and turned around and acted with contention, revenge and retaliation.  Marc Randazza sued me in a frivolous, life altering oppressive lawsuit. He violated my First Amendment Rights, my rights of due process and acted in extreme against my best interest.

Marc Randazza put me in danger, rendered me homeless and with no way to rent a home nor to get clients and resume my life. as he painted me out as a scammer, and a felony criminal extortionist to the world. Therefore no one would hire me, rent to me and I lost all business and personal connections.

Marc Randazza violated Rule 3.1 in bringing claims against me. And in attempting to set me up for criminal claims.

Rule 3.1.  Meritorious Claims and Contentions.  A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for the defendant in a criminal proceeding, or the respondent in a proceeding that could result in incarceration, may nevertheless so defend the proceeding as to require that every element of the case be established.

Marc Randazza violated rule 3.7 in offering to be deposed for the opposition in my appeal case.

Rule 3.7.  Lawyer as Witness.

  (a) A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary witness unless:

         (1) The testimony relates to an uncontested issue;

         (2) The testimony relates to the nature and value of legal services rendered in the case; or

         (3) Disqualification of the lawyer would work substantial hardship on the client.

  (b) A lawyer may act as advocate in a trial in which another lawyer in the lawyer’s firm is likely to be called as a witness unless precluded from doing so by Rule 1.7 or Rule 1.9.

  [Added; effective May 1, 2006.]

TRANSACTIONS WITH PERSONS OTHER THAN CLIENTS

Marc Randazza violated Rule 4.1 and LIED deliberately to others regarding me.  As the above chronology clearly shows Marc Randazza knowingly made false statements of fact to others, including and not limited to:  WIPO, Forbes, NPR, the New York Times, the Ninth Circuit court, Florida District Court, Nevada State and Federal Court, multiple legal bloggers and law firms, forensic investigators, my friend, my ex’s, my pastor, my church, my phone vendor, my domain registrar, and more Third Parties.

Marc Randazza did this with deliberate intention and deliberate knowledge that the false statements of fact were false.  

Rule 4.1.  Truthfulness in Statements to Others.  

In the course of representing a client a lawyer shall not knowingly:

  (a) Make a false statement of material fact or law to a third person; or

  (b) Fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 1.6.

  [Added; effective May 1, 2006.]

Rule 4.4.  Respect for Rights of Third Persons.

 

Marc Randazza deliberately and with clear intention used every mean he could to embarrass, delay, and burden third parties to get private personal information about me. He did this in regard to and not limited to Diana Grandmason, Alexandra Mayers, Stephanie DeYoung, my church, my Pastor, my church secretary, and more. He pressured and threatened them until they gave information to him.

Rule 4.4

(a) In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.

  (b) A lawyer who receives a document or electronically stored information relating to the representation of the lawyer’s client and knows or reasonably should know that the document or electronically stored information was inadvertently sent shall promptly notify the sender.

Marc Randazza also violated Rule 4.4 in taking my private email to him and sending it to media, to legal bloggers and claiming it was extortion. Knowing full well that the full email thread showed him saying that he knew I was asking for a job.

LAW FIRMS AND ASSOCIATIONS

     Rule 5.1.  Responsibilities of Partners, Managers, and Supervisory Lawyers.

  (a) A partner in a law firm, and a lawyer who individually or together with other lawyers possesses comparable managerial authority in a law firm, shall make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance that all lawyers in the firm conform to the Rules of Professional Conduct.

  (b) A lawyer having direct supervisory authority over another lawyer shall make reasonable efforts to ensure that the other lawyer conforms to the Rules of Professional Conduct.

  (c) A lawyer shall be responsible for another lawyer’s violation of the Rules of Professional Conduct if:

         (1) The lawyer orders or, with knowledge of the specific conduct, ratifies the conduct involved; or

         (2) The lawyer is a partner or has comparable managerial authority in the law firm in which the other lawyer practices, or has direct supervisory authority over the other lawyer, and knows of the conduct at a time when its consequences can be avoided or mitigated but fails to take reasonable remedial action.

  [Added; effective May 1, 2006.]

     Rule 5.2.  Responsibilities of a Subordinate Lawyer.

  (a) A lawyer is bound by the Rules of Professional Conduct notwithstanding that the lawyer acted at the direction of another person.

  (b) A subordinate lawyer does not violate the Rules of Professional Conduct if that lawyer acts in accordance with a supervisory lawyer’s reasonable resolution of an arguable question of professional duty.

Marc Randazza and Randazza Legal Group violated Rule 5.1 and 5.2.

INFORMATION ABOUT LEGAL SERVICES

   Marc Randazza violated Rule 7.1, 7.2 in misleading me that he was an advocate for the free speech of all. He made false statements of being a trademark and first amendment expert then used this law to attack me and as the District of Nevada case, docket entry 200 shows, Marc Randazza did not have a legitimate Trademark claim against me and violated my First Amendment Rights.

Marc Randazza violated my rights in violations of this rule as I was clearly mislead as to what he was an advocate for and what he was an expert in.  Turned out he was not an expert in Trademark, First amendment or domain law.

 Rule 7.1.  Communications Concerning a Lawyer’s Services.  A lawyer shall not make a false or misleading communication about the lawyer or the lawyer’s services. A communication is false or misleading if it:

  (a) Contains a material misrepresentation of fact or law, or omits a fact necessary to make the statement considered as a whole not materially misleading;

  (b) Is likely to create an unjustified or unreasonable expectation about results the lawyer can or has achieved, which shall be considered inherently misleading for the purposes of this Rule, or states or implies that the lawyer can achieve results by means that violate the Rules of Professional Conduct or other law;

  (c) Compares the lawyer’s services with other lawyers’ services, unless the comparison can be factually substantiated; or

  (d) Contains a testimonial or endorsement which violates any portion of this Rule.

  [Added; effective May 1, 2006; as amended; effective September 1, 2007.]

Model Rule Comparison—2007

  Rule 7.1 (formerly Supreme Court Rule 195) is the same as ABA Model Rule 7.1 except that paragraphs (b) through (d) are Nevada specific and have no counterpart in the Model Rule. The 2007 amendments changed language in paragraphs (b) and (d) only.

     Rule 7.2.  Advertising.

  (a) Subject to the requirements of Rule 7.1, a lawyer may advertise services through the public media, such as a telephone directory, legal directory, newspaper or other periodical, billboards and other signs, radio, television and recorded messages the public may access by dialing a telephone number, or through written or electronic communication not involving solicitation as prohibited by Rule 7.3.

  These Rules shall not apply to any advertisement broadcast or disseminated in another jurisdiction in which the advertising lawyer is admitted if such advertisement complies with the rules governing lawyer advertising in that jurisdiction and the advertisement is not intended primarily for broadcast or dissemination within the State of Nevada.

  (b) If the advertisement uses any actors to portray a lawyer, members of the law firm, clients, or utilizes depictions of fictionalized events or scenes, the same must be disclosed. In the event actors are used, the disclosure must be sufficiently specific to identify which persons in the advertisement are actors, and the disclosure must appear for the duration in which the actor(s) appear in the advertisement.

  (c) All advertisements and written communications disseminated pursuant to these Rules shall identify the name of at least one lawyer responsible for their content.

  (d) Every advertisement and written communication that indicates one or more areas of law in which the lawyer or law firm practices shall conform to the requirements of Rule 7.4.

  (e) Every advertisement and written communication indicating that the charging of a fee is contingent on outcome or that the fee will be a percentage of the recovery shall contain the following disclaimer if the client may be liable for the opposing parties’ fees and costs: “You may have to pay the opposing parties’ attorney fees and costs in the event of a loss.”

  (f) A lawyer who advertises a specific fee or range of fees shall include the duration said fees are in effect and any other limiting conditions to the availability of the fees. For advertisements in the yellow pages of telephone directories or other media not published more frequently than annually, the advertised fee or range of fees shall be honored for no less than one year following publication.

  (g) A lawyer may make statements describing or characterizing the quality of the lawyer’s services in advertisements and written communications. However, such statements are subject to proof of verification, to be provided at the request of the state bar or a client or prospective client.

  (h) Any statement or disclaimer required by these rules shall be made in each language used in the advertisement or writing with respect to which such required statement or disclaimer relates; provided, however, the mere statement that a particular language is spoken or understood shall not alone result in the need for a statement or disclaimer in that language.

  (i) Statement regarding past results.  If the advertisement contains any reference to past successes or results obtained, the communicating lawyer or member of the law firm must have served as lead counsel in the matter giving rise to the recovery, or was primarily responsible for the settlement or verdict. The advertisement shall also contain a disclaimer that past results do not guarantee, warrant, or predict future cases.

  If the past successes or results obtained include a monetary sum, the amount involved must have been actually received by the client, and the reference must be accompanied by adequate information regarding the nature of the case or matter and the damages or injuries sustained by the client, and if the gross amount received is stated, the attorney fees and litigation expenses withheld from the amount must be stated as well.

 

 

Randazza has Duties to Cox as a former client

   Marc Randazza and Randazza Legal Group owed me a duty, a standard of care, and had obligations to me as a former client. Marc Randazza and Randazza Legal Group violated Rule 1.9 and seriously acted adversely against me.

Rule 1.9.  Duties to Former Clients.

     (a) A lawyer who has formerly represented a client in a matter shall not thereafter represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client gives informed consent, confirmed in writing.
     (b) A lawyer shall not knowingly represent a person in the same or a substantially related matter in which a firm with which the lawyer formerly was associated had previously represented a client:
            (1) Whose interests are materially adverse to that person; and
            (2) About whom the lawyer had acquired information protected by Rules 1.6 and 1.9(c) that is material to the matter;
            (3) Unless the former client gives informed consent, confirmed in writing.
     (c) A lawyer who has formerly represented a client in a matter or whose present or former firm has formerly represented a client in a matter shall not thereafter:
            (1) Use information relating to the representation to the disadvantage of the former client except as these Rules would permit or require with respect to a client, or when the information has become generally known; or
            (2) Reveal information relating to the representation except as these Rules would permit or require with respect to a client.
     [Added; effective May 1, 2006.]

Rule 1.7.  Conflict of Interest: Current Clients.

     (a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest. A concurrent conflict of interest exists if:
            (1) The representation of one client will be directly adverse to another client; or
            (2) There is a significant risk that the representation of one or more clients will be materially limited by the lawyer’s responsibilities to another client, a former client or a third person or by a personal interest of the lawyer.
     (b) Notwithstanding the existence of a concurrent conflict of interest under paragraph (a), a lawyer may represent a client if:
            (1) The lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client;
            (2) The representation is not prohibited by law;
            (3) The representation does not involve the assertion of a claim by one client against another client represented by the lawyer in the same litigation or other proceeding before a tribunal; and
            (4) Each affected client gives informed consent, confirmed in writing.
     [Added; effective May 1, 2006.]

Marc Randazza and Randazza Legal Group violated Rule 1.7 in representing him and his family in suing me , a former client, and violated this rule with other aspects of this complaint.  It was directly adverse for Randazza Legal Group to represent Marc Randazza, Jennifer Randazza and their daughter in claims against me, their former client.  

Marc Randazza and Randazza Legal Group acted with serious conflicts of interest.

CLIENT-LAWYER RELATIONSHIP

    Marc Randazza and Randazza Legal Group did not provide competent representation to me as the record shows. Marc Randazza violated Rule 1.1 and 1.2.

Rule 1.1.  Competence.  A lawyer shall provide competent representation to a client. Competent representation requires the legal knowledge, skill, thoroughness and preparation reasonably necessary for the representation.
     [Added; effective May 1, 2006.]


     Rule 1.2.  Scope of Representation and Allocation of Authority Between Client and Lawyer.
     (a) Subject to paragraphs (c) and (d), a lawyer shall abide by a client’s decision concerning the objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. A lawyer shall abide by a client’s decision whether to settle a matter. In a criminal case, the lawyer shall abide by the client’s decision, after consultation with the lawyer, as to a plea to be entered, whether to waive jury trial and whether the client will testify.
     (b) A lawyer’s representation of a client, including representation by appointment, does not constitute an endorsement of the client’s political, economic, social or moral views or activities.
     (c) A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.
     (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.
     [Added; effective May 1, 2006.]

Marc Randazza violated Rule 1.3 and was negligent in his diligence in representing me, promptly informing me, communicating with me, respecting me and my wishes, being reasonable on consulting me regarding my objectives, and keeping me informaiton..

Rule 1.3.  Diligence.  A lawyer shall act with reasonable diligence and promptness in representing a client.
 

  Rule 1.3 (formerly Supreme Court Rule 153) is the same as ABA Model Rule 1.3.
     Rule 1.4.  Communication.
     (a) A lawyer shall:
            (1) Promptly inform the client of any decision or circumstance with respect to which the client’s informed consent is required by these Rules;
            (2) Reasonably consult with the client about the means by which the client’s objectives are to be accomplished;
            (3) Keep the client reasonably informed about the status of the matter;
            (4) Promptly comply with reasonable requests for information; and
            (5) Consult with the client about any relevant limitation on the lawyer’s conduct when the lawyer knows that the client expects assistance not permitted by the Rules of Professional Conduct or other law.
     (b) A lawyer shall explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation.

Randazza had a duty to Cox to keep information Confidential

Marc Randazza violated Rule 1.6 in his disclosure of my secrets and strategy to the opposition in my case without my permission and with using private emails and information from me to him and him to me, as a weapon against me in courts and mass media to bully me, harass me, intimidate me and ruin my life and business.

Rule 1.6.  Confidentiality of Information.
     (a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by paragraphs (b) and (c).
     (b) A lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary:
            (1) To prevent reasonably certain death or substantial bodily harm;
            (2) To prevent the client from committing a criminal or fraudulent act in furtherance of which the client has used or is using the lawyer’s services, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take suitable action;
            (3) To prevent, mitigate, or rectify the consequences of a client’s criminal or fraudulent act in the commission of which the lawyer’s services have been or are being used, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take corrective action;
            (4) To secure legal advice about the lawyer’s compliance with these Rules;
            (5) To establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client; or
            (6) To comply with other law or a court order.
     (c) A lawyer shall reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary to prevent a criminal act that the lawyer believes is likely to result in reasonably certain death or substantial bodily harm.
     [Added; effective May 1, 2006.]

     Rule 1.10.  Imputation of Conflicts of Interest.
    

Marc Randazza violated Rule 1.10 in knowingly representing a client in adverse to me, which in this case was his law firm representing him, his wife and his daughter as clients against me, their former client.

(a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.9, or 2.2, unless the prohibition is based on a personal interest of the prohibited lawyer and does not present a significant risk of materially limiting the representation of the client by the remaining lawyers in the firm.
     (b) When a lawyer has terminated an association with a firm, the firm is not prohibited from thereafter representing a person with interests materially adverse to those of a client represented by the formerly associated lawyer and not currently represented by the firm unless:
            (1) The matter is the same or substantially related to that in which the formerly associated lawyer represented the client; and
            (2) Any lawyer remaining in the firm has information protected by Rules 1.6 and 1.9(c) that is material to the matter.
     (c) A disqualification prescribed by this Rule may be waived by the affected client under the conditions stated in Rule 1.7.
     (d) Reserved.
     (e) When a lawyer becomes associated with a firm, no lawyer associated in the firm shall knowingly represent a person in a matter in which that lawyer is disqualified under Rule 1.9 unless:
            (1) The personally disqualified lawyer did not have a substantial role in or primary responsibility for the matter that causes the disqualification under Rule 1.9;
            (2) The personally disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and
            (3) Written notice is promptly given to any affected former client to enable it to ascertain compliance with the provisions of this Rule.
     [Added; effective May 1, 2006.]

Even if Randazza were to oddly prevail at claiming he was not Coxs attorney, then he was at least a third party neutral.

Rule 1.12.  Former Judge, Arbitrator, Mediator or Other Third-Party Neutral.
     (a) Except as stated in paragraph (d), a lawyer shall not represent anyone in connection with a matter in which the lawyer participated personally and substantially as a judge or other adjudicative officer, or law clerk to such a person or as an arbitrator, mediator or other third-party neutral, unless all parties to the proceeding give informed consent confirmed in writing.
     (b) A lawyer shall not negotiate for employment with any person who is involved as a party or as lawyer for a party in a matter in which the lawyer is participating personally and substantially as a judge or other adjudicative officer, or as an arbitrator, mediator or other third-party neutral. A lawyer serving as a law clerk to a judge or other adjudicative officer may negotiate for employment with a party or lawyer involved in a matter in which the clerk is participating personally and substantially, but only after the lawyer has notified the judge or other adjudicative officer.
     (c) If a lawyer is disqualified by paragraph (a), no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in the matter unless:
            (1) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; andNevada Bar Complaint

Complaining Party:   Crystal L. Cox

Phone:  406-624-9510

eMail;  SavvyBroker@yahoo.com

P.O Box 2027

Port Townsend, WA 98368

Name of Attorney: Marc J. Randazza

Law Firm:   Randazza Legal Group

Bar Number 12265

Phone Number:  702-420-2001

3625 S. Town Center Dr.

Las Vegas, NV  89135

Filed April 28th 2015

How Marc Randazza came to be my attorney

On or about December 10th, 2011, one of the Bloggers on my Independent Blog Network, contacted me regarding his contacting an attorney named Marc Randazza. (See Exhibit 18).  Before this, I had never heard of Marc Randazza.

I had just lost a major free speech case ( Obsidian Finance Group vs. Cox), on November 28th, 2011 and expressed that I intended to appeal to the Ninth Circuit.  The blogger thought Marc Randazza would be a good fit and may represent me for Free on my Ninth Circuit appeal, as he had just had some TSA case in the media and seemed to be very pro Free Speech rights for all citizens.

I agreed to have a 3 way phone conversation regarding the possibility of me agreeing to allow Mr. Randazza to represent me, in what had quickly become a high profile First Amendment Case that affected the rights of all citizens, bloggers, whistle blowers, and citizen journalists.

On December 6th, 2011 I had previously spoke to UCLA Law Professor Eugene Volokh. He called me and asked if he could represent me on my Appeal of Obsidian Finance Group v. Crystal Cox and with absolutely no cost to me. I agreed that he could represent me.

Eugene Volokh is a law professor and does not practice law regularly. So he had to get the final approval of the law firm Mayer Brown LLP. Therefore I had not had firm representation yet from him when I spoke with Marc Randazza. And was open to both or either of them representing me on my Ninth Circuit Appeal, at that time.

Discussion on that First Call

On my representation conference call with Marc Randazza, we discussed my strategy for my appeal, as well as my strengths and weaknesses and what I was willing to do and not willing to do.

Randazza told me I had made a mess of the case and he would have to look over all the documentation to decide if he would be able to take my case. Randazza told me that Big Media had a monopoly on Free Speech and that is just the way it is.

Randazza attempted to get me to not appeal, by telling me it was best for all of society if I did not appeal. Randazza asked me my strategy, what I was open to in moving forward, and what I was not. He questioned me on many aspects of my intentions for my appeal.

Randazza told me that he represented the Media Association for Bloggers and may have a conflict of interest in representing me, and that he would get back to me after I gave him all of the documents of my case and he checked with them.

Attorney Marc Randazza Representation of Cox

As Exhibit 19 shows, on December 14th, 2011 Randazza confirmed his representation of me, Crystal Cox.

At this time Randazza had already began representation, he spoke to the opposition in my Obsidian case. He had already put in time and material, he had tried to broker a deal of which I had no idea of the details, and he was discussing his representation with other First Amendment attorneys. He also told these attorneys he was representing me on appeal before this date.

On December 15th, 2011,  As Exhibit 20 shows, my attorneys Marc Randazza and Eugene Volokh were working with, and keeping me in the loop on their representation of me and the case strategy moving forward. They were discussing ordering court documents filing a motion for a new trial, and had phone calls discussion, as well as email communication on how to best move forward with my case. They were both representing me at that time and in talks about the case with the courts, other attorney and me, as the record shows.

Thereafter, it came to my attention that Randazza had contacted Oregon attorney David Aman, the opposition in my Obsidian case, and had been negotiating (brokering) a deal that would stop my appeal and somehow change the status of the judgement .  Eugene Volokh told me this in a phone call and in emails of Dec. 15th, 2011, in Exhibit 1.

Also in Exhibit 1 and that phone call Eugene Volokh told me that Randazza was discussing, with other First Amendment bar attorneys that he represented me and was trying to broker a deal.

I had no knowledge of the details of this negotiation, nor any terms of it and Randazza did not have my permission to present a deal of any kind yet. Especially one without me knowing the detail.

Therefore, at this time,  I decided to Fire Marc Randazza specifically on the grounds that he was presenting (brokering) deals, discussing motions to be filed, and presenting options to the opposition in my case with total disregard for what I wanted, my needs, or keeping me informed on the details of those deal / negotiations that fully affected me. And treating me with complete disrespect.

As seen in Exhibit 21, On December 16th 2011 at 9:21 am, I fired attorney March Randazza. I told him he does not represent me and that only Eugene Volokh represents me, from this moment.

I would have kept Randazza on with Volokh had he not lied to me, berated me, and presented deals to the opposition without my permission or knowledge of what they were, in my  $2.5 million dollar judgment and the appeal case.

Randazza retaliated against me plain and simple, and Exhibit 21 proves that he did so with intent, maliciously and after claiming, offering to be of any kind of help.

Also seen in Exhibit 21,  On December 16th 2011 at 12:55 PM Randazza says he has no issue with me doing that and offers to help me in the future in anyway he can.

Exhibit 21 shows that Marc Randazza claims to respects me, apologized if I felt not treated well and said the following:  "People like you are important for the future of citizen journalism, and I wish to see you succeed."

Overview of my Grievance

My basic complaint is that a man I thought was my attorney, whom I gave private information, strategy, and shared my strengths and weaknesses with, used all I gave him against me to attempt to broker a deal that was not in my best interest, but in the interest of his porn clients.

All with total disregard for what I wanted and had expressed to him were my want  case goals. Randazza violated my constitutional rights, my rights as a litigant, and treated me  extreme disrespect.

I fired this attorney who had talked down to me, lied to me, misrepresented me, gave away my secrets and strategies, tried to trick me into not appealing my $2.5 million dollar judgement and  tried to broker a deal without my knowledge or consent, and against my best interest.

Exhibit 21 shows Randazza admitting to brokering a deal, allegedly on my behalf, he said this: , "I did tell the opposing counsel that I thought a deal might be brokered".

After I fired him on On December 16th 2011, and he emailed me and said to let him know if he could help me in any way, even if in the background. I continued my case with Eugene Volokh.

Then on January 16, 2012, taking my former attorney at his word of offering help, in any way, even if in the background, I emailed him asking for a job or a job recommendation.  He emailed me back and attacked me, as seen in Exhibits. And even though his return email clearly showed him upset, he said he did know I was asking for a job. However, after this, he used a part of the email thread, gave it to the media, as well as legal bloggers, and international review boards, and then multiple courts, and painted me, his former client out to be a criminal.  

He did not file a criminal complaint, yet used his media and legal connections to paint me as guilty for the crime of extortion. He violated my.rights of due process, my constitutional rights, and he deliberately, with full knowledge of it being false, defamed me and made false statements to third parties around the world. Including NPR, Forbes, the New York Times, Legal and Fraud Experts, WIPO (international publications, domain names and intellectual property law), and he used his knowledge of First Amendment Law, and his connection to legal bloggers and big and small media to paint me out as a criminal worldwide.

It is my belief, that Randazza owed me a duty to keep my email private and to not do anything adverse to my well being. He has now embarked on a 3 year campaign to harass me, intimidate me, sue me, lie to courts and media about me, and flat out ruin my life, family, relationships, reputation and quality of life.

I relied on what my former attorney said about my case, my best interest, moving forward, and that he would follow through with what was my wishes and of my best good. I relied on my former attorneys word offering help to me even if in the background. Yet when I emailed him, taking him up on that offer. He took that private email and gave it to legal bloggers, courts, WIPO and to big and small media widespread, painting me in false light, lying about me KNOWING what the truth was and has since ruined my life.

I took my  former attorney, who claimed to humbly respect me, apologized, saying people like me were need, at his word. I  truly believed that Randazza was sincere in letting him know if he could help me, even in the background. I had lost my home, lost my income and needed a job, this was the help I truly needed. I simply asked Randazza if he knew anyone or would hire me for PR work and he maliciously, deliberately and knowing the truth painted to the world that I had extorted him and that I and iViewit Inventor Eliot Bernstein were felony, criminal extortionist, as a matter of fact.  Knowing full well that he did not believe this, he simply want to teach me a lesson, intimidate me retaliate against me, punish me for not doing as he told me and choosing him as my lawyer in my landmark ruling, and ruin my life purposely with willful wanton intent.

I relied on the legal advice of Marc Randazza.

Randazza, my former attorney obstructed my justice, violated my due process rights and my constitutional rights.  Marc Randazza was negligent in his legal representation of me, Crystal Cox and severely negligent in his duty of care, ethics and actions to harm me for years after my appeal, where he represented me.  This negligence cause me injury, defamed me, caused me irreparable harm, rendered my homeless, penniless and incited word wide hate.

A lawyer shall use tactics that are legal, honest and respectful of courts and yet Randazza deliberately lied to the courts to paint me in false light, to ruin my life and business, and to severe my family and business connections. He used his clout, legal knowledge and credibility to abuse me, violate my due process rights, violate my constitutional rights and completely destroy my life, business, reputation and personal relations with deliberate intent and full knowledge of what he was portraying about me was not true. He himself did not even belief it, as Exhibit 17 clearly shows, he knew I was ONLY asking for a job, and said he did not mind that.

A lawyer shall act with integrity and professionalism, maintaining his overarching responsibility to ensure civil conduct. Yet Randazza clearly did not do this.

A lawyer's duty to the court relates to his status as a professional who serves, not only clients, potential clients and former clients but also the public interest. Historically, a professional was distinguished from a tradesperson by a public declaration – demonstrated today by the oath taken at admission to the Bar – to serve others and devote their intellect and efforts to the public good.  Marc Randazza clearly failed in his duty to me, the court and the public.

A lawyer's duty to the court also relates to the profession's independence, or what

has been described as "the high degree of autonomy that lawyers experience from  external controls other than those imposed by self-regulation." Self-regulation is a privilege that comes with substantial obligations that are intended to protect the rights of individuals.

Randazza clearly has not maintained integrity as an officer of the court, but instead has used his power in the courts to retaliate against those whom he has a personal issue with or those who exercise their Free Speech rights and speak critical of him or his wife, as is our First Amendment Right.

He has used the power the courts have give him to issue false subpoena, scare and bulLy people into giving privileged, private information, and to file legal actions to use money, reputation and other tactics to force those he sues, litigants (targets) into taking whatever action he is trying to force them into, be it a settlement, removing gripe sites, taking down parody or graphics that poke fun at him, report on his cases representing the porn industry or really anything he disapproves of.

The duty to the court is also important because there are consequences for lawyers

who do not uphold it. This is demonstrated by the penalties attached to civil and criminal

contempt.  Yet for some reason, the courts seem to protect Marc Randazza thought he clearly, and in pattern and history across many states, does this same thing to victim after victim and has managed to not have contempt charges against him, though I have told the courts over and over what this attorney has done to me and to others in which I personally know of.

A lawyer has a duty to use tactics that are legal, honest and respectful. This duty

is often referred to as the duty of candour. Under this umbrella of a lawyer's duty to the court, lawyers are primarily responsible for ensuring that they do not employ strategies that will mislead the court; this includes misleading the court on evidentiary and legal points as well as making use of tactical strategies that are likely to affect a case.

Yet Randazza deliberate gave many courts, media, legal bloggers, NPR, Forbes, New York Times, WIPO and more, false information, false sworn statement of facts and he deliberately gave the courts false information regarding me, his former client and did so in his wife's case through his law firm, against porn industry whistleblower Alexandra Mayers.  Randazza repeatedly misleads the court and flat out lies to the court about his targets. He then uses these lies in media to force settlements, ruin lives, set people up for crimes and put them under massive, endless stalking, harassment and stress.

Randazza submitted false evidence to the courts regarding me. He did this in Randazza v. Cox in the District of Nevada, he did this in WIPO statements, in CZECH court statements, he did this to big and small media, in legal publications and on National Radio.

Marc Randazza deliberately misled the courts on laws, such as the TRO that stole my intellectual property and other laws in Randazza v. Cox. This is unlawful, unconstitutional and unethical.

Lawyers must respect the court. Respect comes in all forms – preparedness and timeliness are one aspect of consideration. Being familiar with the facts and law applicable to your case, and knowing your client's position is the most fundamental display of respect for the court process. This duty to the court is, in effect, an overlapping duty of competency we have to the client. A lawyer should not abuse the court process. A lawyer should not unreasonably raise or defend an action for which there is no legal justification.

Randazza sued me to bully, intimidate and suppress my speech. He should not have abused the court process with no real legal justification, yet he did.

Randazza knew my position in my appeal, yet went against my wishes and behind my back to strike a deal that would be good for the future and at that time current cases of his other clients, the large porn companies he represented. With this he completely violated my rights of dues process and duties owed to me as his former client, potential client, or current client.

Attorney Marc Randazza clearly disrespected the court process and, in his arrogance and disrespect of the court and the laws, completely violated my rights as a former client, a litigant and a U.S. citizen.

When dealing with others, a lawyer shall be courteous, civil and act in good faith with all persons with whom he deals with during the course of practice. Yet Marc Randazza incited world wide hate against me, filed Amicus Briefs, went on NPR, filed sworn statements, spoke to big and small media and maliciously, deliberately with willful and wanton intent incited hated, spread defamatory malicious lies, and did not act civil, not courteous and NOT in good faith.

A lawyer's duty of civility extends to those individuals who are integral to our legal process – such as witnesses.  Yet Marc Randazza threatened, bullied, sued, and maliciously attacked my church, those I worked for, ex's, those I minister to and did not act with civility at all.

Marc Randazza owed me a ''standard of care'' in which he clearly breached.

Legal Malpractice is a breach by an attorney in the standard of care or in the standard of conduct that is applicable to all attorneys.  Clearly Randazza breached his standard of care when it comes to me, Crystal Cox.

Details and Explanation of my Grievance

On January 16, 2012 at 2:30 pm I emailed my former attorney Marc Randazza, and asked him if he or anyone he knew would hire me for PR services. As, with my case, I had lost my home, my, business, my way to make money, and I was struggling.  Randazza had emailed me prior and told me that people like me were important, and that if he could help in any way, even if only in the background, to let him know.

Exhibit 21 shows Randazza saying, "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."

Randazza emailed me back and demanded that I give him a domain name that he thought I had no right to own. When I refused, he became enraged.

On January 16, 2012 2:36 PM, Randazza emailed me and said ‘’You want to make an enemy of me, really?’’ As Exhibit 17 clearly shows.

On Jan 17, 2012 at 6:52 AM, Marc Randazza emailed me, as seen in Exhibit 17 and expressed his frustration with me, his anger, and the fact that he did not mind me asking for a job. Which shows he clearly knew and fully believed that I was asking for a job.

Yet, he gave a part of this email thread to Kenneth P. White, attorney and legal blogger at Popehat.com, he leaked it to Forbes, NPR, the New York Times and claimed it was the crime of Extortion.  My former attorney, was so vengeful he then contacted the opposition and offered to give information about me to help them win their case AGAINST ME. All this with total disregard for my rights as his client, former client or his potential client.

On March 7th, 2012,  my former attorney Marc Randazza contacted Tonkon Torp Law Firm, the Opposition in my Obsidian case and he offered to give testimony that would set me up for the crime of Extortion and thereby help them to win the Ninth Circuit appeal.

Clearly, this was unethical, unlawful and unconstitutional. This violated my rights as a former client, and with total disregard for my rights as a litigant in the case, a case of which he had my inside information, my secrets, my strategy and had negotiated on my behalf.

Randazza initiated and was planning on giving a deposition against me, a client he had represented in that same case.

Approx. March 30th, 2012, Marc Randazza began publishing false and defamatory statements on his legal blog accusing me of having a blog about his child, attacking an infant and being an extortionist. None of which were true in any way nor adjudicated fact.

As noted above, Randazza clearly did not, himself, believe I had tried to extort him but was only asking for a job. Therefore he deliberately, willfully and with malicious intent painted me in false light on his blog, and from there to media around the world.

On April 2nd 2012,  Forbes Reporter Kashmir Hill began publishing false and defamatory statements claiming that I had attacked Randazza’s child, had a blog about his child, and had extorted Randazza. My former attorney told FORBES, a household name, that I was a criminal, and he painted me out to be evil, and therefore ruined my life, my relationships, my business. And he did so, ALL, with knowledge it was false and with malicious intent.

On April 3rd 2012, Randazza Legal Group attorney Jordan Rushie published false and defamatory statements, accusing me of being a scammer, and extortionist and painting me out to be a very bad person who had committed crimes.

Jordan Rushie of Randazza Legal Group did this in an article on Philly Law Blog Titled "The Evolution of Crystal Cox: Anatomy of a Scammer", dated, April 3rd 2012.  Jordan Rushie posted false and defamatory statements regarding Cox being guilty of extortion and attacking a three year old. This blog post is the top Google search for my name, and was posted with deliberate intent to ruin my life, my business, harm my legal case, pressure me to settle, stop my appeal, intimidate me, bully me, and harass me.

Randazza Legal Group attorney Jordan Rushie also has a hate blog against me with the domain name Crystal-Cox.com.

On April 6th 2012, Bob Garfield, NPR reporter interviewed my former attorney Marc Randazza on  New York Public Radio. The show was called “COMBATING "BAD" SPEECH WITH MORE SPEECH”, Dated, April 06, 2012.  On the Media, as Exhibits show.  

Bob Garfield and Marc Randazza stated false and defamatory, slanderous statements maliciously to the entire world, in a nationally syndicated radio show. With full knowledge it was false and with deliberate, malicious intent to harm me.

Bob Garfield and Marc Randazza accused me of attacking a child online, of being guilty of extortion, and all manner of unethical and criminal activity. These  false and defamatory statements in this world wide medium of communication has caused me immeasurable, irreparable damage.

On April 14th 2012, my former attorney Marc Randazza filed a Protective Order Against me in the Las Vegas Courts. I have and had never met the man. He was the one attacking, threatening and bullying me and using gangs of attorneys, fraud investigators, big and small media and radio to harass, defame and intimidate me. Yet he files for a protective order against me, his former client of which he had duties and Obligations to.

On April 27th, 2012, my former attorney, Marc Randazza continues to interfere in my Ninth Circuit case and try and set me up, exposes my secrets to the opposition and even works with them to attempt to seize my alleged assets to cover my $2.5 million dollar judgement.

Randazza had no ethical, moral, constitutional or lawful reason to be working with the opposition in my case, directly against my best interest. He was my former attorney, he counseled me in the case, he worked on motions, transcript ordering, negotiations and then he works with the opposition to cause me harm.

Randazza helped the opposition, Tonkon Torp Lawyer David Aman to help them attempt to seize domain names, Randazza recommends receiver Lara Pearson, as he had previously used her in the Righthaven case out of Nevada. My former attorney that was under oath to act in my best interested, advised the Opposition’s attorney David Aman to use Lara Pearson as a receiver to come for my alleged assets. There was no other way an Oregon attorney would have chose this exact person. Randazza continued his campaign to harm me.

Randazza continued to tell legal bloggers, law firms, reporters, radio and more that I had extorted him and harmed his child, his family. He did so with full knowledge of it being false.

On May 11th 2012, the Opposition in the case Obsidian Finance Group v. Crystal Cox out of the District of Oregon, filed a multi-million dollar legal action against Eliot Bernstein. Eliot Bernstein had not been a defendant in that case, was not named anywhere in that case, and the jury had happened 6 months prior and found Cox liable for $2.5 million at that time. This lawsuit was filed as an addendum to District of Oregon 3:11-cv-00057-HZ , Docket Entry 136-138.  The motion / lawsuit was denied, however from that moment on Eliot Bernstein was named on the docket as a defendant in the case and as having a $2.5 million dollar judgement against him, clearly defaming him, harming his multi-billion dollar technology actions and causing him harassment, stress and endangerment to him and his family.

This legal action was due to Marc Randazza’s accusations against Cox and Bernstein and leading the opposition in the Obsidian case to believe that we had extorted him and we had assets that the Opposition could come for. Randazza created this and counseled the opposition in this case on these matters.

On Jun 18th 2012, Marc Randazza filed a Czech court complaint against me and Eliot Bernstein, who invented iViewit, a video technology that the porn industry uses, and someone who I have been reporting on for over 5 years.

This complaint was to initiate a domain name dispute. In this case, Marc Randazza stated false and defamatory statements and claimed that I and Eliot Bernstein had extorted him. He painted me, his former client, in false light and he drug in others whom I had reported on.

Marc Randazza used the articles and blogs of Forbes Kashmir Hill, attorney Jordan Rushie and New York Times reporter David Carr’s false and defamatory statements as his evidence to steal the intellectual property. Even though he himself had created that alleged evidence by telling them flat out lies, knowing full well they were lies about his former client, and even though they are hearsay.

Essentially using his own interviews with them as purported and believed evidence, though it was false and defamatory statements of fact with willful, wanton, deliberate and malicious intent.

On July 27th 2012, Marc Randazza filed a WIPO (World Intellectual Property Organization)  complaint out of Switzerland against me and Eliot Bernstein, to initiate a domain name dispute.

In this case, Marc Randazza stated false and defamatory statements to a third party concerning me. He again used Forbes Kashmir Hill, Jordan Rushie and David Carr’s false and defamatory statements, hearsay, as his evidence to steal my intellectual property.

Clearly knowing it was false, Marc Randazza stated in sworn statements to WIPO that Crystal Cox and Eliot Bernstein were guilty of Extortion and had also extorted him personally, yet attorney Marc Randazza had filed no criminal charges against either of us nor was I given due process of law in these very serious allegations, that my former attorney swore that I was guilt of and had participated in, according to him, as a matter of fact.

As the record shows Big and Small Media as well as attorney bloggers, radio shows, international intellectual property law, legal publications, the associated press, small and large bloggers and publishers and more picked up the story or were directly told by Randazza false and defamatory statements and told to post his version of the facts, which, as Exhibits show, were clearly false and defamatory and with full knowledge of the law and their falsehood.

On November 28th, 2012,  My former attorney Marc Randazza filed a Trademark claim against me in the District of Nevada. Case 2:12-cv-02040-JAD-PAL, in order to steal massive online content, domain names and blogs and to chill my online speech that spoke critical of him, reviewed him and his law firm and discussed what he had done to me and to others who have by then contacted me.

Marc Randazzza claimed that I had violated his Trademark with my Gripe sites complaining about how he had treated me, griping about him, and making fun of him and his law firm.

On December 14th, 2012, Judge Gloria Navarro GRANTED Randazza’s

Ex Parte Motion for Temporary Restraining Order and Motion for Preliminary Injunction and gave him my intellectual property, my gripe sites, with NO first amendment  adjudication whatsoever. They simply stripped my rights of due process and constitutional rights.

Judge Gloria Navarro used the hearsay evidence that Marc Randazza gave her to make this ruling. And that evidence was the Jordan Rushie blog, Forbes and other legal blogs that he himself had told personally that I was guilty of extortion, and had attacked his infant child. And the WIPO ruling, containing his flat out (sworn) lies that I, and Eliot Bernstein were criminal extortionists and had caused him personal harm.

Judge Gloria Navarro used this non-adjudicated hearsay as adjudicated factual evidence and seized massive blogs, domain names, and online content of which gave Randazza top search engine placement. With total disregard for my rights.

Judge Gloria Navarro also ruled that the domain name servers be allowed to be changed and the domains given to Randazza without adjudication. Randazza then used all my blog posts, my hard work, my decades of proprietary knowledge, and search engine placement to redirect to ONE blog post on Randazza’s esteemed legal blog attacking and defaming me, accusing me of illegal behavior and harming children.

Marc Randazza filed this legal action, a SLAPP suit, against me in the District of Nevada. Randazza’s attorney of record in the case was Ronald D. Green of Randazza Legal Group. This harassing case is ongoing to this day.

Randazza filed this case to stifle my speech, chill my speech, remove blogs that spoke critical of him and his law firm or made fun of him, steal domain names that he did not want me to have and essential, completely violate my rights of due process of law, my rights as his former client, my First Amendment Rights and my Free Speech Rights.

Marc Randazza, my former attorney made sworn court statements that I had extorted him and he gave these sworn, false and defamatory statements as his evidence to federal court with full knowledge that they were false.

My former attorney, Marc Randazza did not file criminal charges with the “authorities’’. Nor did he  file charges with the attorney general or any other body of authority, regarding his allegations that I and Eliot Bernstein had extorted him, was guilty of extortion or had been in ANY prior case where I was investigated and found guilty of the felony crime of extortion.  

Instead Randazza used his power of the courts and legal knowledge to cause me and Eliot Bernstein harm, harass and defame us worldwide.

Marc Randazza, an attorney of  law, would certainly know how to file criminal charges. Yet instead, Marc Randazza violated the rights of his former client and did not file criminal charges and thereby allow me due process of law. Instead, this well known attorney used world renowned media outlets such as Forbes, the New York Times and NPR, and an international, highly reputable publication put out by WIPO as his court of law, judge and jury and simply pronounced that I and iViewit Inventor Eliot Bernstein was guilty of the felony  crime of extortion.

On Nov. 30th 2012, attorney and colleague of Marc Randazza, Peter L. Michaelson, Sole WIPO Panelist, made his ruling AGAINST me and Eliot Bernstein, based SOLELY on the false and defamatory, deliberate, malicious lies of my former attorney Marc Randazza. And the evidence he submitted to WIPO, which was hearsay articles in media where he himself had told them that I and Eliot Bernstein was a criminal extortionist.

This WIPO ruling was published worldwide in a highly esteemed intellectual property publication and defamed me thoroughly causing me irreparable harm.

WIPO then published false and defamatory statements to a third party concerning me  and iViewit Video Technology Inventor Eliot Bernstein in a WIPO publication, which has a widespread, international reader base.

In this publication, WIPO panelist, attorney Peter L. Michaelson flat out accused us of the Crime of Extortion, with no due process of law whatsoever.

After attorney Peter L. Michaelson’s false and defamatory statements were published in an International WIPO complaint decision,  Marc Randazza via his attorney Ronald D. Green of Randazza Legal Group, used this publication as judicial evidence in the District of Nevada case to harm me and Bernstein and flat out steal our intellectual property, even though my former attorney Marc Randazza was the one who made the Statements to WIPO in the first place.  

At this point the statements in the WIPO publication made by Defendant Peter L. Michaelson of Defendant WIPO BECAME official evidence and proof in Defendant Randazza’s case against Plaintiff Cox and Eliot Bernstein (then District of Nevada Case 2:12-cv-02040-GMN-PAL).

Next, Judge Gloria Navarro used the “evidence”, “legal commentary” and slough of false and defamatory statements made by Randazza as justification to give massive domain names and intellectual property to Marc Randazza in a preliminary injunction. This wiped out thousands of links, wiped out the search engine ranking of mine, deleted massive amounts of content that I had created online, and damaged my intellectual property and online media. This action by a federal judge also caused a  backlash of defamation, harassment, retaliation and loss of reputation, clients, friends and family, of which has been going on for over 3 years now and I have no way to recover.

It has rendered me homeless, penniless, and with no way to rent a home, get clients or secure income to survive. My former attorney painted me to the world as a criminal, a scammer, an extortionist and someone who harms children.

I am an anti-corruption blogger and defend the rights of children as well as all victims of corruption. Randazza knew this and said people like me are needed, important and he respected me, then he turned right around and painted a lie to the world and deliberately, maliciously ruined my life. And with deliberate, inside personal knowledge that what he was saying was indeed false statements of fact.

On January 3, 2013 the Multnomah County Sheriff in the State of Oregon had scheduled a courthouse steps sale on my right to appeal my Ninth Circuit case and thereby revoke my 2.5 million judgement and also follow through with the ruling on this important issue of bloggers having equal rights as a matter of law as main stream news journalists and the institutional press.

My appeal had already been filed long before. Yet the opposition had just learned that they may be able to SEIZE my constitutional right to appeal, as an asset to satisfy the

If this were to happen there would no longer be a Ninth Circuit Cas. It was filed in an Oregon court of which was not connected to the lower court case or the Ninth Circuit case, thereby trying to slip in an auction of my rights, to literally steal my right to appeal.

I was my own attorney in the part of the case that dealt with my assets, or any judgement being satisfied. So I contacted Eugene Volokh, my Ninth Circuit attorney, he then filed a motion to STAY the sale, filed in the District of Oregon 3:11-cv-00057-HZ at Document 145.

We won the motion to stay and stopped the sale just in time.

Apparently it is legal to do this in some states and not in others.

On February 11th, 2013 I had a phone conversation with Florida Attorney Todd Levine. I asked him about procedures such as this. He told me that it used to be popular in the State of Florida. This action of seizing people’s right to appeal in lieu of their debt / judgement in the original case.  

My former attorney, Marc Randazza, having been a Florida attorney for a long time, and starting his career there, had been very familiar with this process (scheme) in which violated the constitutional rights of litigants to appeal a case.

Randazza had counseled, provided information to and basically gave attorney advice to the Opposition in my case that went against my best good, and to completely shut me down in my Ninth Circuit appeal. With total disregard that he had been my counsel prior to this and owed me a duty of ethics, no conflicts of interest, no disclosure of my information in any way.

On February 21st, 2013, Docket entry 87 of Randazza v. Cox, shows Exhibits of Marc Randazza emailing CPA, and Summit Bankruptcy whistleblower Stephanie DeYoung bullying her into giving him Defendant my financial information, and any information on a Church that he claimed  I had started.

Stephanie DeYoung was never my CPA and  I had not yet started a church at this time,  Randazza, acting as his own attorney, attempted to get DeYoung to give my private financial information, threatening to subpoena her, sue her and other bullying tactics.

On May 13th 2013, Eliot Bernstein filed a motion regarding fraud on the court, and included his being harassed by my former attorney Marc Randazza, See Case Number 1:07-cv-11196-SAS, Bernstein v. Appellate Division First Department , Southern District of New York. Page 56-81 (Exhibit V)

On January 17, 2014, Ninth Circuit Case: 12-35238  ID: 8964107, Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, Circuit Judges accused me of having a history of posting things online and seeking money for a retraction. They did this in an appeal ruling, in which I won. My $2.5 million judgement was overturned. I was headed back to the lower court pro se. These Judges used a New York Times article by David Carr, which is legally hearsay, as adjudicated fact, and simply threw into the ruling that I had a history of extortionate behavior.

My former attorney conspired with others to paint this picture to the world. The New York Times article was NOT adjudicated fact, nor was it any part of the lower court ruling, or case. Yet Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz sought out this article and used it, as evidence, as if adjudicated fact, and painted me out to be a criminal, with complete denial of due process as I am entitled, as a matter of law and constitutional rights. My former attorney Marc Randazza maliciously painted me out to be a bad person, a felony extortionate and one who attacks infants.

Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, simply adding lib, and throwing in these unadjudicated statements was unlawful and prejudiced me as I was heading back to the lower court Pro Se. So I asked my Ninth Circuit attorney Eugene Volokh to file an appeal and seek a retraction of these criminal allegations by an esteemed panel of higher court judges.

As an activist litigant, I did not want this to happen to other investigative bloggers, whistleblowers, and citizen journalists, so I appealed through my attorney. As I felt this was my duty and obligation.

On January 27th 2014, Randazza Legal Group (RLG) issued a subpoena to Godaddy, the Notice of Subpoena was District of Nevada, and signed by “Law Clerk” at RLG, signature cannot be made out, and no printed name.The actual subpoena to Godaddy said “District of Arizona” on the documents, and stated that a C. DeRose at 5131 N. 40th St, A310, Phoenix AZ would examine all financial data, electronically stored information, billing data, IP data, server data, all phone numbers, and contact of anyone associated with accounts or to the specified people that Randazza wanted personal, financial and intellectual property information on; to be examined on Feb. 7th, 2014.

The Exhibit to this subpoena was a District of Nevada document stating further persona, private,and financial data that RLG was commanding that Godaddy turn over to them in regard to Crystal Cox.

This Subpoena gave RLG access to the private and financial information of porn industry insiders, whistleblowers such as Monica Foster aKa Alexandra Mayer and Diana Grandmason,both exposing RLG and their connections to Organized Crime in the Porn Industry, prostitution forced on porn actors, pedophiles connected to RLG and the activities of the Free Speech Coalition and RLG to move the porn industry to Las Vegas.

This Subpoena also gave RLG access to the private data and financial information of iViewit inventor Eliot Bernstein.

On January 27th 2014, Randazza Legal Group (RLG) issued a District of Nevada subpoena to Verizon Wireless, the actual Subpoena is District of Northern Texas, this subpoena commands Verizon, though Klemchuk Kubasta LLP 8150 N. Central Expressway, 10th Floor Dallas, TX to be allowed to inspect documents requested on February 10th, 2014.

The Exhibit to the subpoena, a District of Nevada document COMMANDING that Verizon give Marc Randazza, My personal private information, phone numbers, personal calls, business calls, billing and payment information, data that breaches the privacy of countless individuals and companies, lawyers, media, clients, customer, and my friends.

This subpoena also gave Randazza access to phone numbers and data of sources whom had told Cox of issues of organized crime, prostitution and more in which Cox was reporting on connected to RLG, the Free Speech Coalition and the Organized Crime in Porn. Including delicate and private information, texts, phone numbers, contacts of those who have been threatened by RLG and connections.

The Subpoena also requested all other numbers on the account thereby unjustly data mining Cox’s family, friend, business partners, and personal relationships.

The Subpoena also allowed Randazza to access who may help Cox pay her bills, or help her to have a phone. As Cox has no money, no home and is penniless due to the relentless actions of Cox. This compromises the private information of those helping Cox to have a lifeline, a phone. This could also give RLG access to where Cox is located at all times and as Cox has stated many times to the courts, my  life is in and had been in danger, under constant duress and threats by those in the porn industry connected to Randazza and this is potentially life or death to Cox and her sources.

Cox claims Randazza issued a false instrument, impersonated a Subpoena and has caused Cox and those connected to her irreparable harm.

Randazza used his role in this case and as an officer of the court to get people in Cox’s life to give him private information in which he used, not to win this case, but to set Cox up for the crime of extortion, and to broadcast what he found such as private church trips, money Cox got in handouts, and used his power to expose Cox’s personal life, home address, phone number, clients, those she ministers to and her sources inside the porn industry.

Randazza got subpoenas to get personal information of Diana Grandmason, certified human trafficking victim and Monica Foster, adult industry insider and investigative blogger, this had nothing to do with the lanham act, trademark or the merits of this case.

On January  31st 2014 Cox Appealed her Ninth Circuit Case Win: ID: 8961401 Docket Entry: 48, Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz had accused Cox of having a history of extortionate behavior in a Ninth Circuit ruling. This was not adjudicated fact nor a part of the Obsidian v. Cox case or appeal.  Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz simply used a Ninth Circuit ruling to paint Cox as a criminal to the world.

This case filing sought a retraction of the words in which were taken from New York Times article, which was hearsay and stated that I had a history of posting online and then seeking a retraction. Of which I had no history whatsoever before this case painted me in that false light, with deliberate,  malicious intention.

This case filing ENRAGED my former attorney Marc Randazza. As his WIPO case, his case in the District of Nevada against me, his interviews with NPR, the New York Times and Forbes and his statements to many legal bloggers and multiple media would all be discredited if the judges retracted this defamatory statement that had NO relevance to the case.

So my former attorney, who legally, morally, constitutionally and ethically was sworn to NOT seek that is which in opposition of my best interest, filed a hateful, rageful, accusatory, defamatory Amicus Brief to the Ninth Circuit AGAINST me.

On February 3rd 2014, Marc Randazza Cox's filed, Obsidian Finance Group, LLC v. Crystal Cox: Brief of Amicus Curiae, Ninth Circuit Case: 12-35238  ID: 8964107 Dkt Entry: 49-3.  

It is unconstitutional and unethical for Randazza to file court motions such as this, in direct opposition to the best interest of his former client. Not only that, he lied under oath regarding me, his former client. Knowing full well it was false, Randazza accused me of extorting him, when clearly the email at Exhibit 17 shows that he knew I was asking for a job. Randazza did this maliciously to influence a higher court ruling and to further ruin and defame Crystal Cox.

Marc Randazza used the Ninth Circuit courts in a fraud on the court actions, whereby he deliberately lied and misled higher court Judges to influence them to accuse me of criminal activity of which I had never been under investigation for or adjudicated for.

On February 26th, 2014, Martin Cain, another person I had previously reported on, filed: BRIEF OF AMICUS CURIAE MARTIN CAIN, Ninth Circuit Case: Case: 12-35238

ID: 8994409 Docket Entry: 55-1. The Attorney who filed this brief was sought out for and paid for by Marc Randazza.

This Amicus Brief was filed by:

Allan B. Gelbard, Esq.

Law Offices of Allan B. Gelbard

15760 Ventura Blvd., Suite 801

Encino, CA 91436

Allan B. Gelbard is a colleague of Randazza and was secured and paid for by Marc Randazza himself. This was in direct violation of my rights as Randazza’s former client.

On or about March 5th 2014, Marc Randazza, my former attorney filed, Randazza et al. v. GoDaddy LLC et al., case number 2014-5636-CA-01, in the Circuit Court for the Eleventh Judicial Circuit of Florida.

Randazza filed this lawsuit in Florida, as he is a Florida attorney as well, and wanted to use Florida laws that would favor his agenda to obtain my personal information, billing information, phone information, and home address.  He also used this legal action to obtain private information, attack and harass Eliot Bernstein (iViewit Inventor), Porn Industry Bloggers and Whistle blowers Diana Grandmason and Alexandra Mayers. Diana Grandmason is also a registered Human Traffic Victim. I often used their blogs as sources of posts on my blogs. Randazza retaliated against them as well for this.

Diana Grandmason and Alexandra Mayers are Whistleblowers and should have Federal and State Protection in this regard. They are constantly harassed by Randazza Legal Group and those connected to Marc Randazza as well as Randazza himself. These 2 women are porn industry insiders and have reported on organized crime in the porn industry for years. I have picked up a few of their stories, and had Randazza do the same thing to me in which he and his associates did to them and other porn industry whistleblowers. They are in constant danger, under constant threats and duress by Randazza and those connected to him.

Randazza et al. v. GoDaddy LLC et al, Florida, was a legal filing for a bill of pure discovery, so he could set us all up for the felony crime of extortion, he claimed to the media it was to ''bring extortion claims against a group of individuals allegedly behind a collection of defamatory websites''.

Marc Randazza also told media ''that a group led by Crystal L. Cox, a blogger at the center of a notable recent defamation case, has conspired to extort money from him by buying website domain names related to his and his family members' names, filling them with false and harmful statements and seeking payment for retractions of the statements''.

My former attorney, did this maliciously and deliberately, knowing full well that it was not true in any way. And that I had been given no due process on these allegations.

This legal action, Randazza et al. v. GoDaddy LLC et al, targeted information from GoDaddy, Web.com Group Inc. and SoftLayer Technologies Inc. that Randazza claimed was relevant to his claims.

Yet, this was really used to get private information on us all to use to attack us further, defame us, harass us, intimidate us, bully us and sue us in other courts. And as he himself has stated over and over, to set us up for the crime of extortion as a group.

At this time Randazza told Law360  ''Cox is a “well-documented extortionist,” Randazza says, also describing her as “by her own claim” homeless and living in a church property''

Randazza also claimed to Law360 that ''Cox enlisted the help of other individuals, including Eliot I. Bernstein of Florida, Alexandera A. Mayers of Las Vegas and Diana Grandmaison of Florida''

AND

“Together, the tortfeasors continue to assist and aid one another in publishing false and harmful statements about plaintiffs in a constantly shifting configuration of straw ownership in order to avoid detection by plaintiffs, legal liability for their unlawful actions and to conceal the true ownership of these websites and domain names,” Randazza says.

My former attorney knew this was false, yet maliciously kept up his life ruining harassment campaign against me.

These two women were targeted in the same way as I was and in their research they came across me, and me them. So Randazza targeted them along with me to stifle free speech, to flat out STOP the flow of information online that painted him in a less than favorable light.

Randazza and his Associates have stalked Alexandra Mayers and Diana Grandmason for years, and due to their connection to higher ups in the Porn Industry, they have had no State or Federal Protection. Randazza has posted the make and model of Alexandra’s car, her home address and wished he Death. I have even been told that he has said that if he thought it would only kill her he would throw a Molotov cocktail into her home.

On or about March of 2014, Marc Randazza contacted people I had worked for, got my pay documents by threatening to sue them. Then posted this in court motions which he leaked to online media and is now accessible to the world.

My former attorney got my information unethically and by intimidating people and then broadcast it to the world via court motions he filed then posted on his and other legal blogs of his conspirators.

Around this same time Randazza, harassed, threatened, bullied and attacked my church. He scared them into giving him my home address, church trips, banking information, phone information and then he posted this information online and in court motions which his co-conspirators then broadcast world wide.

All this put me in danger. And though I could not rent a home due to Randazza’s defamation nor get any more clients to have an income. From that point I could no longer living in the church housing, as I was in fear of my life, I was followed by a Private Investigator hired by Marc Randazza, and under constant bullying and attacks from his associates via phone, text, email, threats to my kneecaps, threats to coming to my home, and constant online hate and extreme defamation.

Since May of 2013 I have been homeless, having been unable to live in church housing or rent a home. I have no way to make a living, and eat via social programs and church handouts.

Also around this time, Randazza contacted and bullied, threaten to sue, and harassed my ex’s, my former church associates, and other people and threatened to sue them if they did not tell him all they knew about me. Randazza used his Nevada SLAPP suit against me as his authority to these folks to make them give him my private information which he used to harm me.

On March 12th 2014 (Document 181-1), District of Nevada Randaza v. Cox,  my former attorney Randazza filed yet another sworn declaration with the court, and flat out lied in this court documents, that Cox had Extorted him and his family.

Exhibit 17 is an Email from Marc Randazza to his former client Crystal Cox that proves he did not think his client's email to him was trying to extort him, but instead merely asking for a job.

On April 10th, 2014 Randazza filed a SLAPP lawsuit against Porn Industry Insider, Whistle Blower and Investigative Blogger Alexandra Melody Mayers in District Court, Clark County, Nevada, Eighth Judicial District, Case A-14-699072-C.

This lawsuit was to suppress her speech, shut down her blogs and remove her parody of him online. It was also to harass her, bankrupt her, intimidate her and teach her a lesson.

My former attorney Marc Randazza had claimed that I owned RandazzaNews.com and that I had created a parody of his daughter 30 years into the future. Yet he then sued Alexandra Mayers, claiming it was her. Randazza sued he to stifle her speech, shut down her blogs speaking critical of him and stop the flow of information online regarding him and his wife Jennifer Randazza.

Randazza v. Mayers A-14-699072-C, District Court, Clark County, Nevada, Eighth Judicial District, Department 32, was filed in order to teach Alexandra Mayers a lesson for supporting me, and helping to keep me visible and safe from those in the porn industry who had threatened me, intimidated me, bullied me and constantly attacked me online.

This case was for Defamation and False Light, and was a SLAPP suit designed to chill the speech of this blogger whom had tried to help me stay safe.

Nevada attorney Marc J. Randazza, has been involved in prostitution, organized crime, and pornography. All who try and report on him are shut down somehow by him and his associates.

On April 8th 2014 , I filed a Supreme Court Appeal regarding Ninth Circuit Case: 12-35238  ID: 8964107 whereby Judges Arthur L. Alarcón, Milan D. Smith, Jr., and Andrew D. Hurwitz, accused me of having a history of posting things online and seeking money for a retraction. This was flat out false and based only on a New York Times article, of which Randazza himself had created the media storm that painted me, his former client out to be a criminal extortionist and he brought in IViewit Video Technology Inventor Eliot Bernstein. This case was Docketed on April 16, 2014, with the Supreme Court of the United States, see Crystal Cox, Petitioner;  v.Obsidian Finance Group, LLC, et al.;   Case (12-35238, 12-35319)

AT this time Randazza v. Cox is still going on in the state of Nevada. I cannot afford an attorney and simply do the best I can to continue to fight for my life and stand up for my rights and the rights of Randazza’s other victims.

Nevada Rules of Professional Conduct Randazza Violated

CLIENT-LAWYER RELATIONSHIP

Randazza did not abide by my decisions concerning representation. He did not consult with me before proposing a deal allegedly on my behalf and in my best interest with the opposition, and he sought EXTREME retaliation when I chose to longer have him represent me as his client. This is a Violation of Rule 1.2.

Randazza did not abide by my wishes of wanting to appeal and pursued a settlement with the opposition of which he did not include me in the details of this negotiation.

Randazza acted in representations of Cox, without informed consent. And therefore violated Rule 1.2

Randazza did not discuss with me any actions that he thought I may have taken that he thought were criminal, of which, as my attorney he is obligated to. Instead he used his power over the courts and his clout with the media to defame me, and abuse me massive stress and irreparable harm.

If he thought I engaged in any criminal activity, it was his lawful and ethical duty to discuss this with me, instead of simply tell the world and the courts I was guilty of a crime with no adjudication or due process.

Rule 1.2.  Scope of Representation and Allocation of Authority Between Client and Lawyer.

     (a) Subject to paragraphs (c) and (d), a lawyer shall abide by a client’s decision concerning the objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. A lawyer shall abide by a client’s decision whether to settle a matter.

     (b) A lawyer’s representation of a client, including representation by appointment, does not constitute an endorsement of the client’s political, economic, social or moral views or activities.

     (c) A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.

     (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.

 Rule 1.5.  Fees.

Randazza violated rule 1.5 as he told me he was representing me for FREE, Pro Bono, then he turned around and wanted money to travel, to file documents, for hotels and more. Knowing full well that I had NO MONEY.

Rule 1.6.  Confidentiality of Information.

  Attorney Marc Randazza revealed ALL of my private information, strategy and secrets, not only to the opposition without informed consent but to the entire world.

He violated Rule 1.5 in revealing my information without informed consent as the chronology above clearly shows.

Randazza also violated Rule 1.5 in putting me in physical harm, inciting hate among his peers and the world. And encouraging threats, harassment and online attacks of me. As well as physical threats of coming to my town, of taking out my knee caps, text threatening of knowing where I live and more.

Randazza published my home address to the world and used court motions to attack me, then gave those to media to defame me and expose my personal information and home address to the world.  All the while claiming I had harmed an infant child, lying about me and inciting world wide HATE.

Also under this rule, if he thought I had committed a crime then he went about handling it, completely unethical and in violation of my due process rights.

Randazza did not make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the representation of a client. Therefore he violated Rule 1.5.

(a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by paragraphs (b) and (d).

  (b) A lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary:

         (1) To prevent reasonably certain death or substantial bodily harm;

         (2) To prevent the client from committing a criminal or fraudulent act in furtherance of which the client has used or is using the lawyer’s services, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take suitable action;

         (3) To prevent, mitigate, or rectify the consequences of a client’s criminal or fraudulent act in the commission of which the lawyer’s services have been or are being used, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take corrective action;

         (4) To secure legal advice about the lawyer’s compliance with these Rules;

         (5) To establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client; or

         (6) To comply with other law or a court order.

         (7) To detect and resolve conflicts of interest arising from the lawyer’s change of employment or from changes in the composition or ownership of a firm, but only if the revealed information would not compromise the attorney-client privilege or otherwise prejudice the client.

  (c) A lawyer shall make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the representation of a client.

  (d) A lawyer shall reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary to prevent a criminal act that the lawyer believes is likely to result in reasonably certain death or substantial bodily harm.

Rule 1.7.  Conflict of Interest: Current Clients.

  I Randazza had a conflict of interest or felt that Cox was a criminal and did not want to represent her, then he should not have done so. Instead of getting her private information, strategy and secrets and then ruining her life, as details above, clearly show.

It is also a conflict of interest for Randazza Legal Group to represent Marc Randazza in suing his former client in the District of Nevada Randazza v. Cox case, as this law firm represented Cox and had a duty and obligation to her before representing another party to sue her, even if that party was one of their partners or own attorneys.

Randazza should not have sued me, nor represented himself doing so with the same law firm that represented me prior.

Rule 1.7 was clearly violated by Randazza

Rule 1.7

(a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest. A concurrent conflict of interest exists if:

         (1) The representation of one client will be directly adverse to another client; or

         (2) There is a significant risk that the representation of one or more clients will be materially limited by the lawyer’s responsibilities to another client, a former client or a third person or by a personal interest of the lawyer.

  (b) Notwithstanding the existence of a concurrent conflict of interest under paragraph (a), a lawyer may represent a client if:

         (1) The lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client;

         (2) The representation is not prohibited by law;

         (3) The representation does not involve the assertion of a claim by one client against another client represented by the lawyer in the same litigation or other proceeding before a tribunal; and

         (4) Each affected client gives informed consent, confirmed in writing

Rule 1.8.  Conflict of Interest: Current Clients: Specific Rules.

Attorney Marc Randazza should not have engaged in any activity adverse to me, his former client and as seen above he engaged in many.

(a) A lawyer shall not enter into a business transaction with a client or knowingly acquire an ownership, possessory, security or other pecuniary interest adverse to a client unless:

         (1) The transaction and terms on which the lawyer acquires the interest are fair and reasonable to the client and are fully disclosed and transmitted in writing in a manner that can be reasonably understood by the client;

         (2) The client is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel on the transaction; and

         (3) The client gives informed consent, in a writing signed by the client, to the essential terms of the transaction and the lawyer’s role in the transaction, including whether the lawyer is representing the client in the transaction.

  (b) A lawyer shall not use information relating to representation of a client to the disadvantage of the client unless the client gives informed consent, except as permitted or required by these Rules.

 

  (d) Prior to the conclusion of representation of a client, a lawyer shall not make or negotiate an agreement giving the lawyer literary or media rights to a portrayal or account based in substantial part on information relating to the representation.

  (e) A lawyer shall not provide financial assistance to a client in connection with pending or contemplated litigation, except that:

         (1) A lawyer may advance court costs and expenses of litigation, the repayment of which may be contingent on the outcome of the matter; and

         (2) A lawyer representing an indigent client may pay court costs and expenses of litigation on behalf of the client.

  (f) A lawyer shall not accept compensation for representing a client from one other than the client unless:

         (1) The client gives informed consent;

         (2) There is no interference with the lawyer’s independence of professional judgment or with the client-lawyer relationship; and

         (3) Information relating to representation of a client is protected as required by Rule 1.6.

  (g) A lawyer who represents two or more clients shall not participate in making an aggregate settlement of the claims of or against the clients, or in a criminal case an aggregated agreement as to guilty or nolo contendere pleas, unless each client gives informed consent, in a writing signed by the client. The lawyer’s disclosure shall include the existence and nature of all the claims or pleas involved and of the participation of each person in the settlement.

  (h) A lawyer shall not:

         (1) Make an agreement prospectively limiting the lawyer’s liability to a client for malpractice unless the client is independently represented in making the agreement; or

         (2) Settle a claim or potential claim for such liability with an unrepresented client or former client unless that person is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel in connection therewith.

  (i) A lawyer shall not acquire a proprietary interest in the cause of action or subject matter of litigation the lawyer is conducting for a client, except that the lawyer may:

         (1) Acquire a lien authorized by law to secure the lawyer’s fee or expenses; and

         (2) Contract with a client for a reasonable contingent fee in a civil case.

 

  (l) A lawyer shall not stand as security for costs or as surety on any appearance, appeal, or other bond or surety in any case in which the lawyer is counsel.

  (m) While lawyers are associated in a firm, a prohibition in the foregoing paragraphs, with the exception of paragraph (j), that applies to any one of them shall apply to all of them.

  [Added; effective May 1, 2006.]

Attorney Marc Randazza stole my intellectual property, defamed me intentionally and maliciously, and caused me serious hardship.

Marc Randazza did not have a contract where he lined out any fees, yet he expected me to pay for things of which I had no real understanding and claimed to be representing me Pro Bono, for FREE.

Marc Randazza used private information, privileged information against me.

Marc Randazza had no right to portray me to the media as  he did.

Marc Randazza also violated the above rule in trying to negotiate deals, settlement and representation matters WITHOUT my consent or knowledge.  I CLEARLY did not give  Marc Randazza informed consent.

Marc Randazza violated Rule 1.8 in massive widespread conflicts of interest.

Rule 1.9.  Duties to Former Clients.

 

Marc Randazza of Randazza Legal Group represented me in pretty much the same issues exactly as RLG then represented  Marc Randazza in claims as a Plaintiff against me. This is a violation of this rule.

Marc Randazza and his law firm acted materially adverse to my interests. And did so with full knowledge and deliberate intent. This violates Rule 1.9

Marc Randazza used inside and privileged information he gained while representing me, against me to sue me. Which violates Rule 1.9.

Marc Randazza used information against me to my disadvantage. Which violates this rule.

Marc Randazza acquired protected information from me then used this to defame me, set me up for a crime, paint me out to the world as a criminal, sue me, take my blogs and intellectual property, interfere with my appeal, violated my due process laws, violated my constitutional rights, suppress my speech, harass, bully and defame me and my sources and to try and STOP my Ninth Circuit appeal against my will and my rights.  This violates Rule 1.6 and 1.9.

Marc Randazza revealed information about me, without my informed consent.

(a) A lawyer who has formerly represented a client in a matter shall not thereafter represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client gives informed consent, confirmed in writing.

  (b) A lawyer shall not knowingly represent a person in the same or a substantially related matter in which a firm with which the lawyer formerly was associated had previously represented a client:

         (1) Whose interests are materially adverse to that person; and

         (2) About whom the lawyer had acquired information protected by Rules 1.6 and 1.9(c) that is material to the matter;

         (3) Unless the former client gives informed consent, confirmed in writing.

  (c) A lawyer who has formerly represented a client in a matter or whose present or former firm has formerly represented a client in a matter shall not thereafter:

         (1) Use information relating to the representation to the disadvantage of the former client except as these Rules would permit or require with respect to a client, or when the information has become generally known; or

         (2) Reveal information relating to the representation except as these Rules would permit or require with respect to a client.

Rule 1.10.  Imputation of Conflicts of Interest.

 

Marc Randazza and his law firm RLG violated 1.10 in representing, Marc Randazza and his wife and child in suing me, their former client.

(a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.9, or 2.2, unless the prohibition is based on a personal interest of the prohibited lawyer and does not present a significant risk of materially limiting the representation of the client by the remaining lawyers in the firm.

  (b) When a lawyer has terminated an association with a firm, the firm is not prohibited from thereafter representing a person with interests materially adverse to those of a client represented by the formerly associated lawyer and not currently represented by the firm unless:

         (1) The matter is the same or substantially related to that in which the formerly associated lawyer represented the client; and

         (2) Any lawyer remaining in the firm has information protected by Rules 1.6 and 1.9(c) that is material to the matter.

  (c) A disqualification prescribed by this Rule may be waived by the affected client under the conditions stated in Rule 1.7.

  (d) Reserved.

  (e) When a lawyer becomes associated with a firm, no lawyer associated in the firm shall knowingly represent a person in a matter in which that lawyer is disqualified under Rule 1.9 unless:

         (1) The personally disqualified lawyer did not have a substantial role in or primary responsibility for the matter that causes the disqualification under Rule 1.9;

         (2) The personally disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

         (3) Written notice is promptly given to any affected former client to enable it to ascertain compliance with the provisions of this Rule.

  [Added; effective May 1, 2006.]

Rule 1.12.  Former Judge, Arbitrator, Mediator or Other Third-Party Neutral.

 

Even if Marc Randazza did not believe he represented me, which he falsely claims, then he was at least acting as an arbitrator, mediator or other third party neutral in his counsleing me via phone and email, his email saying he would represent me, his negotiations with the opposition and his communications acting as my attorney with Eugene Volokh.

Which violates Rule 1.12.

(a) Except as stated in paragraph (d), a lawyer shall not represent anyone in connection with a matter in which the lawyer participated personally and substantially as a judge or other adjudicative officer, or law clerk to such a person or as an arbitrator, mediator or other third-party neutral, unless all parties to the proceeding give informed consent confirmed in writing.

  (b) A lawyer shall not negotiate for employment with any person who is involved as a party or as lawyer for a party in a matter in which the lawyer is participating personally and substantially as a judge or other adjudicative officer, or as an arbitrator, mediator or other third-party neutral. A lawyer serving as a law clerk to a judge or other adjudicative officer may negotiate for employment with a party or lawyer involved in a matter in which the clerk is participating personally and substantially, but only after the lawyer has notified the judge or other adjudicative officer.

  (c) If a lawyer is disqualified by paragraph (a), no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in the matter unless:

         (1) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

         (2) Written notice is promptly given to the parties and any appropriate tribunal to enable them to ascertain compliance with the provisions of this Rule.

  (d) An arbitrator selected as a partisan of a party in a multi-member arbitration panel is not prohibited from subsequently representing that party.

Rule 1.18.  Duties to Prospective Client.

 

Marc Randazza claims in sworn statements that he was not my attorney. Yet he emailed me that he would take representation, he attempted to broker deals, he advised me on the phone and in emails about court transcripts, he told many attorneys he represented me, he discussed filing court motions with attorney Eugene Volokh, and counseled me on my case.

Therefore it is no excuse to have harmed me, defamed me, interfered with my business and personal relationships, only because he thought he was not acting as my attorney prior. Clearly he owed me the same standard of care as a potential client.  And Marc Randazza knew this full well as a seasoned attorney with his own law firm and in multiple states.

Marc Randazza violated Rule 1.18 and did not have my informed consent for his disclosure of my private emails, negotiation tactics, strategy, nor to provide information that caused me harm. And to do so deliberately with malicious intent.

Mr. Randazza claims, under oath, that he was not my attorney. I fully believe he was. However, if he were to convince this board that he was not my attorney, then clearly he was brokering deals allegedly on my behalf, clearly he was working with other attorneys (Eugene Volokh) and with the courts to file a motion for a new trial, as the email evidence shows, and in this was at least a third party neutral, a mediator, or I was a potential client. In that he owed me a duty to not harm me, not post my private emails to him, not paint me out to the world to be a criminal with no adjudicated facts, not offer to testify against me, not file amicus briefs in opposition to my best interest, not lie about me and defame me, protect  my rights and strategy in my case, and act with integrity as to my best interest.

If Randazza was not my attorney, then he was negotiating with the opposition, giving them my secrets, strategy, strengths and weakness without authorization from me.

Rule 1.18

(a) A person who consults with a lawyer about the possibility of forming a client-lawyer relationship with respect to a matter is a prospective client.

  (b) Even when no client-lawyer relationship ensues, a lawyer who has learned information from a prospective client shall not use or reveal that information, except as Rule 1.9 would permit with respect to information of a former client.

  (c) A lawyer subject to paragraph (b) shall not represent a client with interests materially adverse to those of a prospective client in the same or a substantially related matter if the lawyer received information from the prospective client that could be significantly harmful to that person in the matter, except as provided in paragraph (d). If a lawyer is disqualified from representation under this paragraph, no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in such a matter, except as provided in paragraph (d).

  (d) When the lawyer has received disqualifying information as defined in paragraph (c), representation is permissible if:

         (1) Both the affected client and the prospective client have given informed consent, confirmed in writing, or:

         (2) The lawyer who received the information took reasonable measures to avoid exposure to more disqualifying information than was reasonably necessary to determine whether to represent the prospective client; and

               (i) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and

               (ii) Written notice is promptly given to the prospective client.

  (e) A person who communicates information to a lawyer without any reasonable expectation that the lawyer is willing to discuss the possibility of forming a client-lawyer relationship, or for purposes which do not include a good faith intention to retain the lawyer in the subject matter of the consultation, is not a “prospective client” within the meaning of this Rule.

  (f) A lawyer may condition conversations with a prospective client on the person’s informed consent that no information disclosed during the consultation will prohibit the lawyer from representing a different client in the matter. If the agreement expressly so provides, the prospective client may also consent to the lawyer’s subsequent use of information received from the prospective client.

  (g) Whenever a prospective client shall request information regarding a lawyer or law firm for the purpose of making a decision regarding employment of the lawyer or law firm:

         (1) The lawyer or law firm shall promptly furnish (by mail if requested) the written information described in Rule 1.4(c).

         (2) The lawyer or law firm may furnish such additional factual information regarding the lawyer or law firm deemed valuable to assist the client.

         (3) If the information furnished to the client includes a fee contract, the top of each page of the contract shall be marked “SAMPLE” in red ink in a type size one size larger than the largest type used in the contract and the words “DO NOT SIGN” shall appear on the client signature line.

  [Added; effective May 1, 2006; as amended; effective April 4, 2014.]

COUNSELOR

Rule 2.1.  Advisor. 

     Marc Randazza violated Rule 2. Even if Marc Randazza was NOT my attorney as he claims in court, then he was at the very east my counselor. Marc Randazza counseled me on my case, and yet turned around and deliberate caused me malicious, willful, wanton harm.

If not a counselor then at least an Advisor, Third Party Neutral or an Intermediary. And still owed me a duty of care, in which he clearly violated.

Rule 2.1.  Advisor.  In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In rendering advice, a lawyer may refer not only to law but to other considerations such as moral, economic, social and political factors, that may be relevant to the client’s situation.

  [Added; effective May 1, 2006.]

  Rule 2.1 (former Supreme Court Rule 167) is the same as ABA Model Rule 2.1.

     Rule 2.2.  Intermediary.

  (a) A lawyer may act as intermediary between clients if:

         (1) The lawyer consults with each client concerning the implications of the common representation, including the advantages and risks involved, and the effect on the attorney-client privileges, and obtains each client’s consent to the common representation;

         (2) The lawyer reasonably believes that the matter can be resolved on terms compatible with the clients’ best interests, that each client will be able to make adequately informed decisions in the matter and that there is little risk of material prejudice to the interests of any of the clients if the contemplated resolution is unsuccessful; and

         (3) The lawyer reasonably believes that the common representation can be undertaken impartially and without improper effect on other responsibilities the lawyer has to any of the clients.

  (b) While acting as intermediary, the lawyer shall consult with each client concerning the decisions to be made and the considerations relevant in making them, so that each client can make adequately informed decisions.

  (c) A lawyer shall withdraw as intermediary if any of the clients so requests, or if any of the conditions stated in subsection 1 is no longer satisfied. Upon withdrawal, the lawyer shall not continue to represent any of the clients in the matter that was the subject of the intermediation.

  [Added; effective May 1, 2006.]

Model Rule Comparison—2006

  Rule 2.2 (formerly Supreme Court Rule 168) is based on 1983 Model Rule 2.2. The ABA House of Delegates deleted Model Rule 2.2 and incorporated it into the comments to Model Rule 1.7 in 2002. The Rule has been retained in Nevada because Nevada has not adopted comments to the Rules and the Rule provides some guidance in clarifying conflict of interest concerns.

     Rule 2.3.  Evaluation for Use by Third Persons.

  (a) A lawyer may provide an evaluation of a matter affecting a client for the use of someone other than the client if the lawyer reasonably believes that making the evaluation is compatible with other aspects of the lawyer’s relationship with the client.

  (b) When the lawyer knows or reasonably should know that the evaluation is likely to affect the client’s interests materially and adversely, the lawyer shall not provide the evaluation unless the client gives informed consent.

  (c) Except as disclosure is authorized in connection with a report of an evaluation, information relating to the evaluation is otherwise protected by Rule 1.6.

  [Added; effective May 1, 2006.]

Model Rule Comparison—2006

  Rule 2.3 (formerly Supreme Court Rule 169) is the same as ABA Model Rule 2.3.

     Rule 2.4.  Lawyer Serving as Third-Party Neutral.

  (a) A lawyer serves as a third-party neutral when the lawyer assists two or more persons who are not clients of the lawyer to reach a resolution of a dispute or other matter that has arisen between them. Service as a third-party neutral may include service as an arbitrator, a mediator or in such other capacity as will enable the lawyer to assist the parties to resolve the matter.

  (b) A lawyer serving as a third-party neutral shall inform unrepresented parties that the lawyer is not representing them. When the lawyer knows or reasonably should know that a party does not understand the lawyer’s role in the matter, the lawyer shall explain the difference between the lawyer’s role as a third-party neutral and a lawyer’s role as one who represents a client.

ADVOCATE

     

Marc Randazza acted as my advocate. He spoke with other attorneys, my colleagues, and he told me that people like me are important. He was an advocate for me and turned around and acted with contention, revenge and retaliation.  Marc Randazza sued me in a frivolous, life altering oppressive lawsuit. He violated my First Amendment Rights, my rights of due process and acted in extreme against my best interest.

Marc Randazza put me in danger, rendered me homeless and with no way to rent a home nor to get clients and resume my life. as he painted me out as a scammer, and a felony criminal extortionist to the world. Therefore no one would hire me, rent to me and I lost all business and personal connections.

Marc Randazza violated Rule 3.1 in bringing claims against me. And in attempting to set me up for criminal claims.

Rule 3.1.  Meritorious Claims and Contentions.  A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for the defendant in a criminal proceeding, or the respondent in a proceeding that could result in incarceration, may nevertheless so defend the proceeding as to require that every element of the case be established.

Marc Randazza violated rule 3.7 in offering to be deposed for the opposition in my appeal case.

Rule 3.7.  Lawyer as Witness.

  (a) A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary witness unless:

         (1) The testimony relates to an uncontested issue;

         (2) The testimony relates to the nature and value of legal services rendered in the case; or

         (3) Disqualification of the lawyer would work substantial hardship on the client.

  (b) A lawyer may act as advocate in a trial in which another lawyer in the lawyer’s firm is likely to be called as a witness unless precluded from doing so by Rule 1.7 or Rule 1.9.

  [Added; effective May 1, 2006.]

TRANSACTIONS WITH PERSONS OTHER THAN CLIENTS

Marc Randazza violated Rule 4.1 and LIED deliberately to others regarding me.  As the above chronology clearly shows Marc Randazza knowingly made false statements of fact to others, including and not limited to:  WIPO, Forbes, NPR, the New York Times, the Ninth Circuit court, Florida District Court, Nevada State and Federal Court, multiple legal bloggers and law firms, forensic investigators, my friend, my ex’s, my pastor, my church, my phone vendor, my domain registrar, and more Third Parties.

Marc Randazza did this with deliberate intention and deliberate knowledge that the false statements of fact were false.  

Rule 4.1.  Truthfulness in Statements to Others.  

In the course of representing a client a lawyer shall not knowingly:

  (a) Make a false statement of material fact or law to a third person; or

  (b) Fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 1.6.

  [Added; effective May 1, 2006.]

Rule 4.4.  Respect for Rights of Third Persons.

 

Marc Randazza deliberately and with clear intention used every mean he could to embarrass, delay, and burden third parties to get private personal information about me. He did this in regard to and not limited to Diana Grandmason, Alexandra Mayers, Stephanie DeYoung, my church, my Pastor, my church secretary, and more. He pressured and threatened them until they gave information to him.

Rule 4.4

(a) In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.

  (b) A lawyer who receives a document or electronically stored information relating to the representation of the lawyer’s client and knows or reasonably should know that the document or electronically stored information was inadvertently sent shall promptly notify the sender.

Marc Randazza also violated Rule 4.4 in taking my private email to him and sending it to media, to legal bloggers and claiming it was extortion. Knowing full well that the full email thread showed him saying that he knew I was asking for a job.

LAW FIRMS AND ASSOCIATIONS

     Rule 5.1.  Responsibilities of Partners, Managers, and Supervisory Lawyers.

  (a) A partner in a law firm, and a lawyer who individually or together with other lawyers possesses comparable managerial authority in a law firm, shall make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance that all lawyers in the firm conform to the Rules of Professional Conduct.

  (b) A lawyer having direct supervisory authority over another lawyer shall make reasonable efforts to ensure that the other lawyer conforms to the Rules of Professional Conduct.

  (c) A lawyer shall be responsible for another lawyer’s violation of the Rules of Professional Conduct if:

         (1) The lawyer orders or, with knowledge of the specific conduct, ratifies the conduct involved; or

         (2) The lawyer is a partner or has comparable managerial authority in the law firm in which the other lawyer practices, or has direct supervisory authority over the other lawyer, and knows of the conduct at a time when its consequences can be avoided or mitigated but fails to take reasonable remedial action.

  [Added; effective May 1, 2006.]

     Rule 5.2.  Responsibilities of a Subordinate Lawyer.

  (a) A lawyer is bound by the Rules of Professional Conduct notwithstanding that the lawyer acted at the direction of another person.

  (b) A subordinate lawyer does not violate the Rules of Professional Conduct if that lawyer acts in accordance with a supervisory lawyer’s reasonable resolution of an arguable question of professional duty.

Marc Randazza and Randazza Legal Group violated Rule 5.1 and 5.2.

INFORMATION ABOUT LEGAL SERVICES

   Marc Randazza violated Rule 7.1, 7.2 in misleading me that he was an advocate for the free speech of all. He made false statements of being a trademark and first amendment expert then used this law to attack me and as the District of Nevada case, docket entry 200 shows, Marc Randazza did not have a legitimate Trademark claim against me and violated my First Amendment Rights.

Marc Randazza violated my rights in violations of this rule as I was clearly mislead as to what he was an advocate for and what he was an expert in.  Turned out he was not an expert in Trademark, First amendment or domain law.

 Rule 7.1.  Communications Concerning a Lawyer’s Services.  A lawyer shall not make a false or misleading communication about the lawyer or the lawyer’s services. A communication is false or misleading if it:

  (a) Contains a material misrepresentation of fact or law, or omits a fact necessary to make the statement considered as a whole not materially misleading;

  (b) Is likely to create an unjustified or unreasonable expectation about results the lawyer can or has achieved, which shall be considered inherently misleading for the purposes of this Rule, or states or implies that the lawyer can achieve results by means that violate the Rules of Professional Conduct or other law;

  (c) Compares the lawyer’s services with other lawyers’ services, unless the comparison can be factually substantiated; or

  (d) Contains a testimonial or endorsement which violates any portion of this Rule.

  [Added; effective May 1, 2006; as amended; effective September 1, 2007.]

Model Rule Comparison—2007

  Rule 7.1 (formerly Supreme Court Rule 195) is the same as ABA Model Rule 7.1 except that paragraphs (b) through (d) are Nevada specific and have no counterpart in the Model Rule. The 2007 amendments changed language in paragraphs (b) and (d) only.

     Rule 7.2.  Advertising.

  (a) Subject to the requirements of Rule 7.1, a lawyer may advertise services through the public media, such as a telephone directory, legal directory, newspaper or other periodical, billboards and other signs, radio, television and recorded messages the public may access by dialing a telephone number, or through written or electronic communication not involving solicitation as prohibited by Rule 7.3.

  These Rules shall not apply to any advertisement broadcast or disseminated in another jurisdiction in which the advertising lawyer is admitted if such advertisement complies with the rules governing lawyer advertising in that jurisdiction and the advertisement is not intended primarily for broadcast or dissemination within the State of Nevada.

  (b) If the advertisement uses any actors to portray a lawyer, members of the law firm, clients, or utilizes depictions of fictionalized events or scenes, the same must be disclosed. In the event actors are used, the disclosure must be sufficiently specific to identify which persons in the advertisement are actors, and the disclosure must appear for the duration in which the actor(s) appear in the advertisement.

  (c) All advertisements and written communications disseminated pursuant to these Rules shall identify the name of at least one lawyer responsible for their content.

  (d) Every advertisement and written communication that indicates one or more areas of law in which the lawyer or law firm practices shall conform to the requirements of Rule 7.4.

  (e) Every advertisement and written communication indicating that the charging of a fee is contingent on outcome or that the fee will be a percentage of the recovery shall contain the following disclaimer if the client may be liable for the opposing parties’ fees and costs: “You may have to pay the opposing parties’ attorney fees and costs in the event of a loss.”

  (f) A lawyer who advertises a specific fee or range of fees shall include the duration said fees are in effect and any other limiting conditions to the availability of the fees. For advertisements in the yellow pages of telephone directories or other media not published more frequently than annually, the advertised fee or range of fees shall be honored for no less than one year following publication.

  (g) A lawyer may make statements describing or characterizing the quality of the lawyer’s services in advertisements and written communications. However, such statements are subject to proof of verification, to be provided at the request of the state bar or a client or prospective client.

  (h) Any statement or disclaimer required by these rules shall be made in each language used in the advertisement or writing with respect to which such required statement or disclaimer relates; provided, however, the mere statement that a particular language is spoken or understood shall not alone result in the need for a statement or disclaimer in that language.

  (i) Statement regarding past results.  If the advertisement contains any reference to past successes or results obtained, the communicating lawyer or member of the law firm must have served as lead counsel in the matter giving rise to the recovery, or was primarily responsible for the settlement or verdict. The advertisement shall also contain a disclaimer that past results do not guarantee, warrant, or predict future cases.

  If the past successes or results obtained include a monetary sum, the amount involved must have been actually received by the client, and the reference must be accompanied by adequate information regarding the nature of the case or matter and the damages or injuries sustained by the client, and if the gross amount received is stated, the attorney fees and litigation expenses withheld from the amount must be stated as well.

 

 

Randazza has Duties to Cox as a former client

   Marc Randazza and Randazza Legal Group owed me a duty, a standard of care, and had obligations to me as a former client. Marc Randazza and Randazza Legal Group violated Rule 1.9 and seriously acted adversely against me.

Rule 1.9.  Duties to Former Clients.

     (a) A lawyer who has formerly represented a client in a matter shall not thereafter represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client gives informed consent, confirmed in writing.
     (b) A lawyer shall not knowingly represent a person in the same or a substantially related matter in which a firm with which the lawyer formerly was associated had previously represented a client:
            (1) Whose interests are materially adverse to that person; and
            (2) About whom the lawyer had acquired information protected by Rules 1.6 and 1.9(c) that is material to the matter;
            (3) Unless the former client gives informed consent, confirmed in writing.
     (c) A lawyer who has formerly represented a client in a matter or whose present or former firm has formerly represented a client in a matter shall not thereafter:
            (1) Use information relating to the representation to the disadvantage of the former client except as these Rules would permit or require with respect to a client, or when the information has become generally known; or
            (2) Reveal information relating to the representation except as these Rules would permit or require with respect to a client.
     [Added; effective May 1, 2006.]

Rule 1.7.  Conflict of Interest: Current Clients.

     (a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest. A concurrent conflict of interest exists if:
            (1) The representation of one client will be directly adverse to another client; or
            (2) There is a significant risk that the representation of one or more clients will be materially limited by the lawyer’s responsibilities to another client, a former client or a third person or by a personal interest of the lawyer.
     (b) Notwithstanding the existence of a concurrent conflict of interest under paragraph (a), a lawyer may represent a client if:
            (1) The lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client;
            (2) The representation is not prohibited by law;
            (3) The representation does not involve the assertion of a claim by one client against another client represented by the lawyer in the same litigation or other proceeding before a tribunal; and
            (4) Each affected client gives informed consent, confirmed in writing.
     [Added; effective May 1, 2006.]

Marc Randazza and Randazza Legal Group violated Rule 1.7 in representing him and his family in suing me , a former client, and violated this rule with other aspects of this complaint.  It was directly adverse for Randazza Legal Group to represent Marc Randazza, Jennifer Randazza and their daughter in claims against me, their former client.  

Marc Randazza and Randazza Legal Group acted with serious conflicts of interest.

CLIENT-LAWYER RELATIONSHIP

    Marc Randazza and Randazza Legal Group did not provide competent representation to me as the record shows. Marc Randazza violated Rule 1.1 and 1.2.

Rule 1.1.  Competence.  A lawyer shall provide competent representation to a client. Competent representation requires the legal knowledge, skill, thoroughness and preparation reasonably necessary for the representation.
     [Added; effective May 1, 2006.]


     Rule 1.2.  Scope of Representation and Allocation of Authority Between Client and Lawyer.
     (a) Subject to paragraphs (c) and (d), a lawyer shall abide by a client’s decision concerning the objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. A lawyer shall abide by a client’s decision whether to settle a matter. In a criminal case, the lawyer shall abide by the client’s decision, after consultation with the lawyer, as to a plea to be entered, whether to waive jury trial and whether the client will testify.
     (b) A lawyer’s representation of a client, including representation by appointment, does not constitute an endorsement of the client’s political, economic, social or moral views or activities.
     (c) A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.
     (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.
     [Added; effective May 1, 2006.]

Marc Randazza violated Rule 1.3 and was negligent in his diligence in representing me, promptly informing me, communicating with me, respecting me and my wishes, being reasonable on consulting me regarding my objectives, and keeping me informaiton..

Rule 1.3.  Diligence.  A lawyer shall act with reasonable diligence and promptness in representing a client.
 

  Rule 1.3 (formerly Supreme Court Rule 153) is the same as ABA Model Rule 1.3.
     Rule 1.4.  Communication.
     (a) A lawyer shall:
            (1) Promptly inform the client of any decision or circumstance with respect to which the client’s informed consent is required by these Rules;
            (2) Reasonably consult with the client about the means by which the client’s objectives are to be accomplished;
            (3) Keep the client reasonably informed about the status of the matter;
            (4) Promptly comply with reasonable requests for information; and
            (5) Consult with the client about any relevant limitation on the lawyer’s conduct when the lawyer knows that the client expects assistance not permitted by the Rules of Professional Conduct or other law.
     (b) A lawyer shall explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation.

Randazza had a duty to Cox to keep information Confidential

Marc Randazza violated Rule 1.6 in his disclosure of my secrets and strategy to the opposition in my case without my permission and with using private emails and information from me to him and him to me, as a weapon against me in courts and mass media to bully me, harass me, intimidate me and ruin my life and business.

Rule 1.6.  Confidentiality of Information.
     (a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by paragraphs (b) and (c).
     (b) A lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary:
            (1) To prevent reasonably certain death or substantial bodily harm;
            (2) To prevent the client from committing a criminal or fraudulent act in furtherance of which the client has used or is using the lawyer’s services, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take suitable action;
            (3) To prevent, mitigate, or rectify the consequences of a client’s criminal or fraudulent act in the commission of which the lawyer’s services have been or are being used, but the lawyer shall, where practicable, first make reasonable effort to persuade the client to take corrective action;
            (4) To secure legal advice about the lawyer’s compliance with these Rules;
            (5) To establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client; or
            (6) To comply with other law or a court order.
     (c) A lawyer shall reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary to prevent a criminal act that the lawyer believes is likely to result in reasonably certain death or substantial bodily harm.
     [Added; effective May 1, 2006.]

     Rule 1.10.  Imputation of Conflicts of Interest.
    

Marc Randazza violated Rule 1.10 in knowingly representing a client in adverse to me, which in this case was his law firm representing him, his wife and his daughter as clients against me, their former client.

(a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.9, or 2.2, unless the prohibition is based on a personal interest of the prohibited lawyer and does not present a significant risk of materially limiting the representation of the client by the remaining lawyers in the firm.
     (b) When a lawyer has terminated an association with a firm, the firm is not prohibited from thereafter representing a person with interests materially adverse to those of a client represented by the formerly associated lawyer and not currently represented by the firm unless:
            (1) The matter is the same or substantially related to that in which the formerly associated lawyer represented the client; and
            (2) Any lawyer remaining in the firm has information protected by Rules 1.6 and 1.9(c) that is material to the matter.
     (c) A disqualification prescribed by this Rule may be waived by the affected client under the conditions stated in Rule 1.7.
     (d) Reserved.
     (e) When a lawyer becomes associated with a firm, no lawyer associated in the firm shall knowingly represent a person in a matter in which that lawyer is disqualified under Rule 1.9 unless:
            (1) The personally disqualified lawyer did not have a substantial role in or primary responsibility for the matter that causes the disqualification under Rule 1.9;
            (2) The personally disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and
            (3) Written notice is promptly given to any affected former client to enable it to ascertain compliance with the provisions of this Rule.
     [Added; effective May 1, 2006.]

Even if Randazza were to oddly prevail at claiming he was not Coxs attorney, then he was at least a third party neutral.

Rule 1.12.  Former Judge, Arbitrator, Mediator or Other Third-Party Neutral.
     (a) Except as stated in paragraph (d), a lawyer shall not represent anyone in connection with a matter in which the lawyer participated personally and substantially as a judge or other adjudicative officer, or law clerk to such a person or as an arbitrator, mediator or other third-party neutral, unless all parties to the proceeding give informed consent confirmed in writing.
     (b) A lawyer shall not negotiate for employment with any person who is involved as a party or as lawyer for a party in a matter in which the lawyer is participating personally and substantially as a judge or other adjudicative officer, or as an arbitrator, mediator or other third-party neutral. A lawyer serving as a law clerk to a judge or other adjudicative officer may negotiate for employment with a party or lawyer involved in a matter in which the clerk is participating personally and substantially, but only after the lawyer has notified the judge or other adjudicative officer.
     (c) If a lawyer is disqualified by paragraph (a), no lawyer in a firm with which that lawyer is associated may knowingly undertake or continue representation in the matter unless:
            (1) The disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and
            (2) Written notice is promptly given to the parties and any appropriate tribunal to enable them to ascertain compliance with the provisions of this Rule.
     (d) An arbitrator selected as a partisan of a party in a multimember arbitration panel is not prohibited from subsequently representing that party.
     [Added; effective May 1, 2006.]

Randazza ADVISED COX on his very first conference call and even in Exhibit 20 as per what to do with court transcripts.

Marc Randazza has to maintain Professional Liability Insurance and has repeatedly refused to provide me with this information.

All information that I have provide here is to the best of my knowledge

Crystal L. Cox   /s/

_______________

Crystal L. Cox

            (2) Written notice is promptly given to the parties and any appropriate tribunal to enable them to ascertain compliance with the provisions of this Rule.
     (d) An arbitrator selected as a partisan of a party in a multimember arbitration panel is not prohibited from subsequently representing that party.
     [Added; effective May 1, 2006.]

Randazza ADVISED COX on his very first conference call and even in Exhibit 20 as per what to do with court transcripts.

Marc Randazza has to maintain Professional Liability Insurance and has repeatedly refused to provide me with this information.

All information that I have provide here is to the best of my knowledge

Crystal L. Cox   /s/

_______________

Crystal L. Cox