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

"Randazza first moves to dismiss Cox’s counterclaims under Nevada’s anti-SLAPP law, NRS 41.660"

Marc Randazza filed a SLAPP lawsuit against his former client Crystal Cox to suppress her speech. Yet he tries to claim SLAPP as a defense against her defamation and malpractice claim. And does this wayyyy after she filed those claims.

Court Says,  "I find Randazza’s special motion to dismiss was not filed by NRS 41.660’s 60-day deadline and that the filing delay is not supported by good cause. I therefore deny the special motion to dismiss. I also deny Randazza’s motion to strike Cox’s answer and enter default because claimdispositive sanctions are presently unwarranted. Cox has not been explicitly warned that such sanctions could issue if she continues to disregard court rules and file frivolous motions, and I decline to take such a draconian step without first warning her of this possibility."

THE COURT DENIED RANDAZZA MOTIONS TO DISMISS COX'S COUNTERCLAIM OVER AND OVER. YET HE DESPERATELY KEEPS BEGGING FOR ANOTHER WAY.

COURT SAYS;   "A. Special Motion to Dismiss [Doc. 224] Randazza specially moves for dismissal of Cox’s remaining counterclaims for defamation and malpractice under NRS 41.660, which provides protections for defendants in Strategic Lawsuits Against Public Participation (SLAPP).

Succinctly, “[a] SLAPP suit is a meritless lawsuit that a party initiates primarily to chill a defendant’s exercise of his or her First Amendment free speech rights.” 

A SLAPP claimant typically seeks “to obtain a financial advantage over one’s adversary by increasing litigation costs until the adversary’s case is weakened or abandoned.”5 NRS 41.660 provides a special, expedited procedure for obtaining the dismissal of SLAPP suits.

But to obtain this relief, the special motion to dismiss “must be filed within 60 days after service of the complaint, which period may be extended by the court for good cause shown.”

The 60-day period “runs from the filing of the most recent amended [counterclaim].” Randazza’s special motion is late.

Cox’s last operative iteration of her counterclaims was filed on February 24, 2014, giving Randazza until April 28, 2014, to file a timely special motion under NRS 41.600. But he waited an additional four months—until August 15, 2014—to finally file it. I find Randazza’s excuse for the delay unavailing. Randazza first moved to dismiss Cox’s claims under FRCP 12(b)(6) or strike them in March 2014, and I resolved those motions in May."

CLEARLY Randazza is the one who filed a Strategic Lawsuits Against Public Participation (SLAPP) against his former client Crystal Cox and not the other way around. 

"a] SLAPP suit is a meritless lawsuit that a party initiates primarily to chill a defendant’s exercise of his or her First Amendment free speech rights.” 

.. and that is just what Randazza did to his former Client Crystal Cox, yet begs the court to dismiss her VALID claims as if she filed the SLAPP SUIT.

Randazza filed a SLAPP suit  “to obtain a financial advantage over one’s adversary by increasing litigation costs until the adversary’s case is weakened or abandoned.”

He filed the case against Cox, and harassed her non-stop for nearly 3 years now. She is homeless, penniless and has no attorney, he is the one that took her intellectual property, her livlihood, and pressured her to abandon the case and do what he told her to do.

Then he files yet again to dismiss Crystal Cox's claims, as if SLAPP has anything to do with malpractice really. And the court denies this claim, as seen at the link below.

http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.241.0.pdf

Randazza then, assumedly scared shitless, filed a time stalling frivolous motion to the Ninth Circuit to appeal the above FAIR and JUST ruling as a matter of law.

Here is the Randazza v Cox, and counterclaims docket
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

So after the District of Nevada yet again DENIES his whiny dribble, then Mr. super duper Randazza whines to the Ninth circuit court as if he is the injured party. Hmmm ..

Here is the DOCKET for the Ninth Circuit Randazza whiny dribble appeal of the Judicial Decision above that `DENIED him super powers to squash litigants rights of due process.
http://ia601503.us.archive.org/3/items/gov.uscourts.ca9.15-15610/gov.uscourts.ca9.15-15610.docket.html

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

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

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

THE CASE BELOW RANDAZZA BENEFITS FROM SLAPP LAWS. \

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

District Court State of Nevada, County of Clark Eighth Judicial District A-14-69 8267- C

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

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

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

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

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

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

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

"REQUEST NO. 3:

Anyway phone records, emails, faxes, mail, or records of documentation of any kind between
you and anyone, including and not limited to Judge Marco Hernandez, Michael Spreadbury, ...., Martin Cain, Lara Pearson, Alexandria Mayers, Sean Boushie, Peter L. Michaelson, Eric Turkewitz, Leo Mulville, Jordan Rushie, Kenneth P. White, Ari Bass aKa Michael Whiteacre, Sean Tompkins, Eugene Volokh, Liberty Media Company and all associates, any Porn company what so ever, Stephen Lamont, Pamela Simon, Ted Bernstein, Alan Rose or any other party, in which you made statement to about Crystal Cox in any way and especially whereby you accused Cox of criminal activity.


"RESPONSE TO REQUEST NO. 3:

Counterdefendant objects to Request No. 3 on the grounds that the request is unintelligible,
overly broad, unduly burdensome, vague, ambiguous, lacks specificity, and requests documents
which are neither relevant nor reasonably calculated to lead to the discovery of admissible
evidence.

Counterdefendant further objects as the request seeks documents which are protected by
the attorney/client privilege and/or work product privilege. Furthermore, some of the documents
requested are, or should be, in Cox’s possession – for example, communications with Eugene
Volokh, her attorney. Such discovery requests should be directed at him. "

Source of Marc Randazza Response
https://docs.google.com/file/d/0Bzn2NurXrSkiUHBIcDltaWRKQ28/edit

Odd that Marc Randazza is claiming attorney client protection when he claims he was not my attorney. He STOLE my work product but seems to think his "work product" has value and worth but mine can just be STOLEN ???



INTERROGATORY NO. 21:

Did you have phone conversations with Eugene Volokh and state that you represented Cox and
discuss with him your strategy, or a deal you were trying to make with the opposition, Plaintiff’s
attorney David Aman?

RESPONSE TO INTERROGATORY NO. 21:

"Counterdefendant objects to Interrogatory No. 21 on the grounds that it is vague, ambiguous,
overly broad, not limited in time and scope, and seeks information which is neither relevant nor
reasonably calculated to lead to the discovery of admissible evidence.

Counterdefendant further objects because this interrogatory is in excess of the 25 allowable
interrogatories pursuant to Rule 33(a) of the Federal Rules of Civil Procedure. As a result,
Counterdefendant is not required to respond to the same. Subject to and without waiving the
foregoing objections, Counterdefendant responds as follows:

Counterdefendant spoke with Eugene Volokh in December 2011. 

Randazza informed Volkokh that if he was going to represent Cox, that Randazza would gladly bow out, and defer to Volokh to handle the case.

Volokh, however, said that he would prefer that Randazza co-counsel the case with him due to Volokh’s stated lack of litigation experience. Counterdefendant and Volokh discussed possible strategies that he and Volokh thought might be good ideas during that call.

Counterdefendant and Volokh both discussed the fact that Cox’s interests would be better served
through settlement."

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


Why in the world would you would you "bow out" Mr Randazza if you were NEVER My attorney in the first place? What gives you the right to choose for me, make decision for me and to bow out as my attorney if you are saying that you were not my attorney ??? Hmmm

How in the world does attorney Marc Randazza have the legal right to bow out and to "defer" me, the client to another attorney and then defer to that attorney on the case?

WOW, Marc Randazza world's biggest Hypocrite Attorney.

Randazza Groupie, Kenneth P White of Brown White and Newhouse, MALICIOUSLY attacks Marc Randazza's targets and encourages others to, with TOTAL disregard for the LAW, the Victims rights and the facts. BELOW is a bit about District of Nevada Randazza v. Cox COUNTERCLAIM

Kenneth P. White of Brown, White and Newhouse in California is one of the many attorneys who targets those Marc Randazza sues or wants to shake down, intimidate, coerce in someway, and silence them; ya know suppress their SPEECH and Take away their First Amendment Rights.

BELOW IS A BIT FROM THE RANDAZZA v. COX COUNTERCOMPLAINT

Crystal Cox, Pro Se, sued Marc Randazza, her former attorney, for malpractice and for defamation.

This Post is in regard to Exhibit 22 regarding Ken White's unlawful attack on Blogger Crystal Cox.

The Point of Sharing this is to show what these guys do to people like me, there are many of us out there, and what they say about these attorneys who gang up on targets to affect the outcome of court cases, to intimidate litigants and affect settlements is true.

Click Below for Exhibit 22 of Randazza v. Cox, Clearly Showing that Kenneth White of Popehat.com was working with attorney Marc Randazza to Deliberately Destroy the Life of Crystal Cox. This is in clear violation of law and the rights of former client.

Click Below to See Exhibit Post from Kenneth P. White's defamatory blog Popehat.com
https://docs.google.com/file/d/0Bzn2NurXrSkiU29GUEZTR2ZycnM/edit

Here is a Bit More on Exhibit 22 Above.

Exhibit 22 a blog post from Popehat.com which is a legal blog by First Amendment Attorney Kenneth P. White of the Law Firm, Brown, White and Newhouse out of California.

Kenneth P. White has a reputation of suing on the Painting in False Light statute in California, and seems to get the laws about posting false statements as if they are facts. Yet he deliberated attacked anti-corruption blogger Crystal Cox and came to the odd defense of Porn Attorney Marc Randazza, who clearly, flat out lied to him about Crystal Cox, Investigative Blogger.

Ken White is a friend and close associate of Marc Randazza and works with the Free Speech Coalition alongside Randazza, seems to take Marc Randazza's word as if it were LAW, Flat out Fact and with total disregard for the constitutional rights of Marc Randazza's victims, such as Investigative Blogger Crystal Cox. 

Kenneth White deliberately, willfully, wantonly painted Anti-Corruption blogger Crystal Cox in false light, knowing full well that what he posted was false statements of fact.  

And knowing full well that it was illegal to "gang up" on Randazza Legal Group's former client Crystal Cox. This violates attorney ethics and the law, as well as the constitutional rights of Crystal Cox.  Ken White is an attorney, he KNOWS the law and he is bound to attorney Ethics of which he CLEARLY violated.

Kenneth P. White took the word of Marc J. Randazza and deliberately, knowingly, defamed Crystal Cox MALICIOUSLY and with total disregard for the rights of Blogger Crystal Cox, her side of the story, the truth, or the Law.

Randazza v. Cox, counterclaim (Cox v. Randazza) Exhibit 21 shows an email from Marc Randazza, Crystal Cox's former attorney, offering her help, even if in the background and saying he respected her.

"Subject From To Date Crystal, RE:  from  Pre  Se  Defendant  Crystal  L.  Cox mjr@randazza.com  <mjr@randazza.com> Crystal  L.  Cox  <savvybroker@yahoo.com> 

Fri,  Dec  16,  2011  at  12:55  PM 

"I  want  to  address  a  few things: First  and  foremost,  if  you  feel  that  I  did  not  treat  you  respectfully,  I  humbly  apologize.    

I  do  not  wish  to  leave  that  undiscussed.    

People  like  you  are  important  for  the  future  of  citizen  journalism,  and  I  wish  to  see  you  succeed.   I  also  want  to  correct  a  misperception  here.    

I  did  not  tell  anyone  that  I  represented  you,  for  certain.    I  did  tell  the opposing  counsel  that  I  thought  a  deal  might  be  brokered  -  but  that  I  wanted  to  speak  to  him  first  (to  test  his  waters  with respect  to  a  possible  mutually  agreeable  resolution). 

 Finally,  I  want  to  make  it  clear  that  our  discussion  about  money  was  in  terms  of  "costs."    I  thought  that  I  made  it  clear that  my  bills,  my  fees  (my  income)  would  be  waived.    All  that  I  was  asking  you  about  being  able  to  pay  was  out  of pocket  reimbursement  of  expenses.   

Despite  the  contents  of  this  email,  I  wish  to  let  you  know  that  I  am  sill  willing  to  lend  a  hand  in  any  way  -  even  in  the background.   - Marc"

Exhibt 17 of Cox's Counterclaims against Marc Randazza, suing him for Malpractice and Defamation, is linked below.

https://docs.google.com/file/d/0Bzn2NurXrSkiY00tM3lidGw0M2M/edit

Exhibit 17 was a private email from Blogger Crystal Cox, taking her former attorney at his word of offering help, and asking him for a possible job or job recommendation.

A partial email thread was posted on Ken White's blog, Popehat.com and made to look as if it were the felony crime of extortion, when as Exhibit 17 clearly shows Randazza said flat out that he had no issue with Cox asking for a job and admits to that clearly.  This part of the email thread was initially, maliciously, unethically, unlawfully left out to paint Cox as a CRIMINAL.

Ken White posted this confidential email and painted Cox in false light knowing the laws very well, as he is an attorney.  Ken White got this email from the only person who had it, which was Randazza. And posted the email in a public forum to deliberately defame Blogger Crystal Cox to teach her a lesson for not doing as Marc Randazza DEMANDED of her.

This exhibit proves that Cox's former attorney Marc Randazza deliberately and intentionally defamed Blogger Crystal Cox and is also guilty of malpractice as well as making false and defamatory statements to third parties.

Ken White claimed that Cox had targeted a 3 year old. This was malicious and deliberate defamation against Blogger Crystal Cox, with total disregard of the facts. As Crystal Cox never had a blog about a 3 year old. There is NO basis in fact that Cox attacked a toddler, it NEVER even remotely happened. 

Exhibit 22, Popehat.com blog by California Attorney Kenneth P. White of Brown, White and Newhouse CLEARLY shows yet again that Investigative Blogger Crystal Cox was hailed a "champion", a hero of free speech, and that after the malicious defamation campaign of Marc Randazza and Kenneth White, Cox was the villain, the felon, the extortionist and a monster who attacks a three year old.

Exhibit 22 remarks on Forbes Kashmir Hill and New York Times David Carr turning over rocks to find the truth. Yet Randazza is who told them Cox had extorted him, and had a blog about his child. Randazza made false and defamatory statements to third parties and is guilty of defamation. And Randazza was Cox's attorney and had a duty and obligation to protect COX and not to ruin her life.

Exhibit 22 shows First Amendment Ken White of Brown, White and Newhouse in California, claiming that Litigant Crystal Cox's private email to attorney David Aman, in her pro se capacity after she was sued for 10 million dollars offer a settlement AND her private email to her former attorney Marc Randazza asking for a job was extortionate.

This is CLEARLY a Blog Post of DEFAMATION.  As Kenneth P. White did no fact checking. He simply BELIEVED the Rants of a disgruntled, humiliated, FIRED, former attorney of Investigative Blogger Crystal Cox.

Ken White is GUILTY of Defamation. It is not an EXCUSE that he simply believed his associate, attorney Marc Randazza and posted false statements of fact. 

Kenneth P. White of Brown, White and Newhouse CLEARLY painted Crystal Cox in false light and clearly BROKE the law of Assault, Slander, Defamation. 

And I would say, Ken White is even possibly guilty of Criminal Defamation as Exhibit 22 shows, he did this to target Blogger Crystal Cox in a clear civil conspiracy with other attorneys, including Marc Randazza.

Exhibit 22 shows that Kenneth White of Brown, White and Newhouse posted FALSE Statements of FACT and with clear vile defamatory hatred toward Crystal Cox, wishing her to be cockroach stomped.

Exhibit 22 proves that  Kenneth P. White, California First Amendment Attorney and Nevada attorney Marc Randazza was acting with other attorneys to target Crystal Cox, and deliberately render her powerless.

And these same attorneys DO THIS SAME THING to others they want to Silence, Intimidate, or pressure into a settlement of some kind.

Here is a quote from Exhibit 22:

"First, every time Crystal Cox attacks someone, we can band together — as bloggers did for Marc Randazza when Crystal Cox attacked him — and write fair and factual posts about the target. That substantially blunted Crystal Cox's attempt to destroy Randazza's reputation by spamming numerous nutty blogs about him, pushing her efforts off the first page. 

As a team, we can render Crystal Cox powerless and largely irrelevant. More speech works . (Now you know why I put up that mysterious Popehat Signal.) 

It might be nice to start by offering this gesture to X, her victim in the Oregon case. But if you're out there — if she's gone after you, or threatened to — we can help you, too. We'll throw up the Popehat Signal and gather a more-speech team and flush her off the first pages of your search results."

Crystal Cox is an Investigative Blogger, she did not attack, she reported on and exposed corruption in her unique style. 

Exhibit 22 proves that these attorneys banded together to go after Blogger Crystal Cox. They did this in Civil Conspiracy to render Cox powerless, irrelevant and to stomp her like a cockroach. 

They did this while intentionally, deliberately, wilful and wantonly, knowing that what they posted was not based in adjudicated fact and was malicious defamation.

Kenneth P. White Initiated a Campaign to DESTROY Crystal Cox's Domain name network and intellectual property, she had build over 16 years. 

Exhibit 22 also says: " Third, we can search for other victims. The emails to X's lawyer and to Randazza are two data points — but showing a remarkably similar approach. Has she done this other times? There's a way to find out — we use reverse whois directories , plug in her name and addresses and email addresses and known associates, and find every domain she has ever registered. I've already started. Then we see whether the domains were used to attack someone. If they were, we start contacting the targets and asking questions — like "has Crystal Cox offered you reputation management services?" 

Why would we want to see if Crystal Cox has sent emails to others like the ones she sent to Randazza and X? Well, two reasons, really. 

The first is civil. 

If Volokh succeeds in getting Crystal Cox a new trial on appeal — or if anyone else sues her — a pattern of such communicationswill be very probative of her intent in making false statements about people when she sets up multiple blogs about them. Under Federal Rule of Evidence 404(b) , such "other bad acts" evidence is generally inadmissible — unless it is probative of intent, or knowledge, or motive, or lack of accident, or similar factors. What could be more probative of Crystal Cox's malicious intent than a pattern of such communications — like the pattern we already see in the two described above? And the second reason to investigate further "reputation manager" offers?

Exhibit 22 proves that these attorneys acted together to destroy Cox's intellection property, online reputation, to paint her in false light and deliberately, willfully and wantonly ruin her life, with total disregard for the law and for their duty and obligations to society as attorneys. 

They acted in a pattern of communication, not Crystal Cox.

Exhibit 22 proves that these attorneys were targeting Crystal Cox's domain names, prying into her private information and launching an attack. All based on the third party false and defamatory statements made by Crystal Cox's vengeful former attorney, Marc Randazza.

Exhibit 22 shows that Randazza sued Cox to create a pattern and history to attempt to set up his former client Cox, of which he owed client attorney duties to.  They were creating a false "pattern and history" using privileged emails to attorneys that were not extortion and should not have been posted online, period, as a matter of law.

Exhibit 22 shows the Federal Law they were going for, to sue me in civil court and set me up for a crime.

Click Below to Read Marc J. Randazza attorney emailing his former client Crystal Cox. He emails Blogger Crystal Cox, his former client, after she fired him.  Randazza apologizes and offers help, even if in the background. Yet later, Crystal Cox asks for help and he takes the email out of a thread of emails and deliberately, defames his former client in a malicious worldwide media and legal attack.

Exhibit 17
https://docs.google.com/file/d/0Bzn2NurXrSkiY00tM3lidGw0M2M/edit

A Bit more on What Exhibit 17, in Crystal Cox's counterclaims of Malpractice and Defamaton against Randazza prove;

Exhibit 17 shows that, though Crystal Cox's former attorney Marc Randazza was clearly upset that his former client Blogger Crystal Cox registered the domain name he did not believe she had a reasonable or ethical right to own, Randazza did not tell her he believed it was against the law, or extortion in any way. And in fact CLEARLY, Specifically says that he does not mind that Crystal Cox asked him for a job.

Randazza is well known for defending the rights of individuals to have domain names with other people's names in it, such as the Glenn Beck case he was in. And to gripe about whom ever they please, well protected under the coveted First Amendment

Crystal Cox, assumed that Marc Randaza would have no issue with her owning a domain name that he had decades to purchase if he had wanted, and after she had read his legal arguments in the Glen Beck case and thought, at the time he was a true proponent of Free Speech rights for all.

Crystal Cox, herself, had already won a WIPO claim for the right to own a domain name with 3 different Proskauer Rose attorneys in it. So why in the world would she believe that Randazza's would be different.

Though clearly later shown, WIPO did favor Marc Randazza. Check Out Exhibit 2
WIPO COMPLAINT (clear defamation from attorney Marc Randazza, regarding iViewit 
Inventor Eliot Bernstein and blogger Crystal Cox.

WIPO Complaint Randazza Filed 
https://docs.google.com/file/d/1PqcfV_loGIe_S7Y2oBZTDshtDwq00cRQ_UReJkHsxFsbYAc3g_q23jrEQmqczdCnIiLuGni50YxVmh-H/edit

And Below is the world wide defamation publication by WIPO'S Peter Michaelson, friend of Marc Randazza, in which he accuses Cox and Bernstein of the Felony Crime of Extortion with NO ADJUDICATED

WIPO DEFAMATORY PUBLICATION
http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2012-1525


Motion in Limine for above Exhibit
https://docs.google.com/document/d/11dKxWMPPXsSIQH20o1AL88InEYKBP8fYezVOOumeyjk/edit

It is clear to see from this blog post that Marc Randazza, Crystal Cox's former attorney maliciously lied about her, defamed her and iViewit inventor Eliot Bernstein with full knowledge he was doing it. As it's clear in Randazza's email to Cox that he knew she was merely asking for a job. But flat out LIED in sworn documents to WIPO, with malicious and deliberate intent.

Exhibit 17 CLEARLY shows that counter defendant Marc Randazza did not have an issue with Cox asking him for a Job.

In fact Exhibit 17 shows clearly, without a doubt that Randazza did not believe he was being extorted, but that in fact, he believed Cox was unreasonable and unethical for registering the domain name, but that she was just asking for a job.

This Exhibit proves that Randazza, with full knowledge of it being false, interviewed and flat out lied, made false and defamatory statements to NPR, Forbes, the New York Times, WIPO, the Czech Courts, Tracy Coenen and the Fraud Files, Kenneth White attorney blogger of Popehat.com and numerous other well connected bloggers, and Media around the world.   As well as made these false and defamatory statement in courts and on his own blog. KNOWING full well that it was false.

RANDAZZA gave blogger attorney Kenneth P. White of Popehat.com Cox's personal, privileged, private email to her former attorney who told her to let him know if he could help her in any way, and he used this email to paint Crystal Cox in false light, deliberately not posting the whole email thread which showed that he knew Cox was asking for a job.

Therefore because Cox would not simply turn over a domain name he thought she had no right to own, he went on NPR, interviewed with the New York Times, Forbes, Popehat.com, and he viciously, deliberately, knowing it was false, lied, made false statements to WIPO who used their global clout to ruin the lives of Eliot Bernstein and Crystal Cox and accuse them worldwide and nationwide, in legal blogs, in big and small media, that Crystal Cox and Eliot Bernstein ( who never was even in the email) had extorted him, which is a felony crime.

CLEARLY Crystal Cox is entitled to relief for the damage Randazza has caused her, though Cox has no attorney or way to articulate this evidence on a legal basis. Cox has valid claims and exhibit 17 further proves this.

Exhibit 17 shows that Randazza was "deeply offended" and that he did not think Cox was reasonable or ethical. However, Randazza clearly never claimed Cox was extorting him, nor did he believe this at the time. Yet later, in retaliation, he deliberately defamed Cox in a widespread, malicious, willful and wanton campaign of revenge, harassment, and widespread posting and speaking false and defamatory statements against Cox to third parties. 

This ruined Cox's life, quality of life and business. This also put Crystal Cox in constant danger, duress and up against massive, widespread hate in big and small media around the world.  And simply for registering a domain name and asking for a job.

Randazza has caused Cox irreparable damage.

Exhibit 17 shows Counter Defendant Marc Randazza Say, "Asking me for a job, or a recommendation?  That doesn't bother me in the least."  Yet because Cox did not do as he told her to, he retaliated and ruined her life. And told countless media that he was not only bothered by it but put in terror, stress and extreme duress over it. Which was untrue and Exhibit 17 shows this.

Randazza swore to WIPO that Cox had extorted him and did all the things published worldwide in Exhibit 2. Randazza made false and defamatory statements to third parties, willfully and wanton and with full knowledge that they were not true.

Marc Randazza is friends with Trademark attorney Peter Michaelson (INTA). He has been seen with him at INTA meetings. Peter Michaelson was the Sole WIPO panelist that decided on this decision. He took Marc Randazza at his word, because he knew him and trusted him.

This exhibit proves the damage Randazza deliberately, maliciously caused his former client Crystal Cox, and that he made false statements to WIPO knowing full well they were false.

Randazza got the New York Times, Philly Law Blog, Forbes and others to post defamatory statements about Cox, then he used those articles as exhibits in his WIPO complaint, as some sort of proof.

PAY ATTENTION TO THE ENTIRE RANDAZZA v. COX CASE AND COUNTER CLAIMS AS THIS PROVES WHAT THESE ATTORNEYS DO TO MANY.

MOTION IN LIMINE EXHIBIT 17
https://docs.google.com/document/d/1I159SAmI5r4zRJOwt28a_fG8XsNDu5TTFZMg1q9wSEk/edit


MOTION IN LIMINE EXHIBIT 22
https://docs.google.com/document/d/1Jux23ASWFxziaZRI9JvWmQi1rCxiYBVnJPHRsNnaCkk/edit


MOTION IN LIMINE EXHIBIT 2
https://docs.google.com/document/d/11dKxWMPPXsSIQH20o1AL88InEYKBP8fYezVOOumeyjk/edit

Randazza v. Cox, District of Nevada, 2:12-cv-02040.  Docket Link Below

Case Cause:	15:1125 Trademark Infringement (Lanham Act)
Nature of Suit:	840 Trademark

http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

Nevada Attorney Marc Randazza who filed a SLAPP Lawsuit AGAINST his former client, Blogger Crystal Cox to SUPRESS her Speech and is NOT really a First Amendment Advocate for all. And even illegally and unethically uses Trademark Law to Chill Speech, Well he is accused of Bribes connected to Nevada Slapp Law, Check it Out.

This summary is not available. Please click here to view the post.

DENIAL of Summary Judgement in which SEEMS to Shoot Down ALL of Marc Randazza's Frivolous Claims against Blogger Crystal Cox

http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf

Marc Randazza CLEARLY has NO Case Against Blogger Crystal Cox as seen in the Summary Judgement Below, however, Marc Randazza continues to "pretend" that he does.