Monday, December 29, 2014
District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights. Crystal Cox Objection to Summary Judgement.
Document 80, District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights.
Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT
Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT
"Notice To Court: This Court has DENIED requests to sign a conflict of Interest
Disclosure, though requested several times by Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox. Any action forward by Judge Gloria M. Navarro or Judge Peggy A. Leen, who
refuses to admit/deny conflicts and rules forward will be charged with Obstruction of Justice
through conflicts of interest, violations of attorney and judicial cannons in order to Deny Due
Process via aiding and abetting the alleged civil and criminal conspiracy through Fraud on the
Court.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox intend to file criminal complaints
against any officer of the court, including opposing counsel, who violates any law or ethical
statues in order to perpetrate the fraud through obstruction via conflicts, or has violated any law
already in previous rulings affecting me, Pro Se Defendant, Pro Se Counter Defendant Crystal
Cox.
Therefore every ruling of this court on a motion without conflict disclosure will be charged for
each and every act a in a criminal complaint, forthcoming.
Judge Gloria Navarro is alleged by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox to be
acting in criminal and civil conspiracy with Plaintiff / Counter Defendant Marc J. Randazza and
ALL Connected Co-Conspirators and Counter Defendants of District of Nevada Case
2:12-cv-02040-GMN-PAL and therefore this court has a duty to notify all applicable authorities,
bond carriers, insurance carriers, AND State and Federal Auditors of the liability of this allegation
in a Federal Court Proceeding.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox object to Plaintiff’s MOTION
FOR SUMMARY JUDGMENT.
Plaintiff Claims I have not disputed facts, when I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox have disputed Plaintiff’s Allegations over and over to the absolute best of my
ability. Plaintiffs / Counter Defendants have not Disputed ONE Allegation I have Claimed against
them in my Counter Complaint, however.
Plaintiff has not made one valid point of law in which entitles them to a Summary Judgement,
instead Plaintiff has used this MOTION FOR SUMMARY JUDGMENT as further harassment,
intimidation, defamation to Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox, “genuinely” dispute ALL claims in
Plaintiff’s claims against me and have repeatedly.
Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has not had a “campaign” in bad faith to
harass Plaintiff. Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has fought back against
Plaintiff and Counter Defendants attack on her. This court should not grant summary judgement
to Plaintiff, as Plaintiff has simply used the courts in bad faith to ATTACK a blogger he does not
like, or approve of her blog content and to wipe out his competition in the search engines by
using the courts.
Plaintiff and Co-Conspirators have taunted me, harassed, me, defamed me, attacked me
constantly and the only way I have to fight back is to post my proof online. It is a violation of my
Freedom of Expression and my First Amendment Rights to stop the flow of information on my
blogs, to delete my blogs, redirect my domain names and harass me.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Plaintiff continues to LIES to this court and to publicly defame me in court documents, as I did
NOT extort Plaintiff. I asked Plaintiff for a Job, and he was upset at a Domain Name I owned and
then contacted the Plaintiff in Obsidian V. Cox and conspired to set me up for extortion in
revenge for me owning a domain name he did not approve of. If he thought he had a Trademark
then why not just take the name from me, Pro Se Defendant / Pro Se Counter Plaintiff Crystal
Cox or from Monica Foster when she owned it.
Plaintiff offered Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox and Monica Foster for
the domain name and we both turned him down.
There was no Cyber Extortion and if Plaintiff really believes this and has evidence of this then
Plaintiff should file a criminal complaint so that I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal Cox, am entitled to due process of law. Instead Plaintiff is abusing his power over the
courts and simply stating I am guilty of extortion with no proof, no evidence of Extortion.
I did not offer Reputation Services and then attack Plaintiff in the search engines to retaliate. I
asked for a job, he said no and then demanded I turn over domain names. I stood up for myself
and he conspired with others to ruin me and to make it look like I was guilty of the crime of
extortion.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, was not on trial for extortion, never
had due process of law for this accusation, never had a criminal investigation, yet Counter
Defendant / Plaintiff Marc Randazza and Co-Conspirators continue to publicly state that I am
guilty of extortion. Why not file criminal charges, and then if a court of law convicts me of
extortion, then publish Crystal Cox is an Extortionist. Defendant / Plaintiff Marc Randazza and
Co-Conspirators did not do this, they simply attacked me, painted me in false light and made me
look to be an extortionist when that is not true.
I have made a living from Real Estate and from Online Supplements, My Anti-Corruption Blogs
have been to give victims of corruption a voice. The search engine management offer in the
Obsidian V. Cox case was part of a Settlement Negotiation, a month after a legal threat, and a
week after a 10 Million Dollar Lawsuit was filed against me. There were approx. 10 Settlement
Offers in that case. Those emails were between two attorneys negotiating a settlement, I was
Pro Se and acting in my Pro Se Capacity, and this ONE email out of 5 was used out of context
to defame and harass, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, and to retaliate
against me, AFTER David Aman, Tonkon Torp, Opposing Counsel had already won a 2.5 Million
Dollar Judgement.
Counter Defendant / Plaintiff Marc Randazza saw those eMails, he had ALL my files, and he
negotiated with David Aman, Tonkon Torp on my behalf in the Obsidian Case. As per those he
told in the First Amendment Bar that he represented me and was negotiating a deal.
Counter Defendant / Plaintiff Marc Randazza acted with intentional harm against Pro Se
Defendant / Pro Se Counter Plaintiff Crystal Cox,, when he broadcast that I am an Extortionist
and continues to accuse me, using the courts to further harass and defame me and State that I
am guilty of a crime that I am NOT guilty of nor have been charged with, little own prosecuted for.
Counter Defendant / Plaintiff Marc Randazza does not have the legal or constitutional right to, in
retaliation, hate or whatever reason to simply accuse who ever he please of a crime and then
broadcast that accusation as fact, BEFORE an innocent victims, such as Pro Se Defendant /
Pro Se Counter Plaintiff Crystal Cox is permanently harmed and defamed.
Counter Defendant / Plaintiff Marc Randazza had my personal information, confidential details of
my life and my strategy, and Defendant / Plaintiff Marc Randazza knew that I had not been on
trial for extortion nor charged with extortion, he had seen ALL my files. Counter Defendant /
Plaintiff Marc Randazza had requested all these files as email records show, BEFORE he
negotiated with David S. Aman, Opposing Counsel in the Obsidian V. Cox case.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox am one woman. Counter Defendant /
Plaintiff Marc Randazza has a strong blog, several online sites that are very strong, and lots of
connections with other attorneys and big media. When he posted that I was an Extortionist, the
only way I had to post the facts, and to save my reputation was to start multiple blogs. The more
I started, the more he got deleted.
This is not a “Google Bomb”, it is an internet marketing tactic to get my story found in the search engines. Instead of using co-conspirators as the Plaintiff does in this case and in Rakofsky V. the Internet, I am simply use my own sites and post in my own name.
This is not a Google Bomb nor cybersquatting, it is online competition in the search engines, in which Plaintiff Marc Randazza used this court to simply wipe out all my work, and without any due process or First Amendment Adjudication.
Counter Defendant / Plaintiff Marc Randazza states that “"Defendants Crystal L. Cox (“Cox”) and
Eliot Bernstein (“Bernstein”) registered the Infringing Domain Names (as defined in ECF #1 at
6-7) in an attempt to extort Plaintiffs and in violation of the Anti-cybersquatting Consumer
Protection Act (the “ACPA”) (15 U.S.C. § 1125(d)), individual cyberpiracy protections (15 U.S.C.
§ 8131), and rights of publicity under the laws of the State of Nevada Plaintiffs, as well raised
common law claims of intrusion upon seclusion and publicity and civil conspiracy. Plaintiffs’
claims arise from Defendants’ registration and use of Plaintiffs’ personal names as Internet
domain names."
Plaintiff flat out lies to this court, as Plaintiff knows full well that Eliot Bernstein never registered
those domain names. Plaintiff deliberately lies in court documents to defame and harass
Defendants Crystal L. Cox and Defendant Eliot Bernstein. Counter Defendant / Plaintiff Marc
Randazza is very familiar with Obsidian V. Cox, and Plaintiff knows that there are documents
filed as to how and why Defendant Eliot Bernstein got those domain names. Yet, Counter
Defendant / Plaintiff Marc Randazza deliberately lies to this court in retaliation. Counter
Defendant / Plaintiff Marc Randazza represents clients who LITERALLY owe Eliot Bernstein
billions of dollars. This lawsuit naming iViewit Founder Eliot Bernstein is simply to attempt to
discredit, harass, defame and intimidate Eliot Bernstein and to remove blogs that expose the
iViewit Technology theft, with is the biggest technology crime in the world, EVER.
Counter Defendant / Plaintiff Marc Randazza knowingly lies about domain names being
registered to Extort him somehow, that has no TRUTH what so ever to it. Neither Defendant
EVER asked Marc Randazza for money and said they would post “bad faith” or anything at all if
he did not pay, there WAS not Extortion. Counter Defendant / Plaintiff Marc Randazza continues
to use court documents, Big Media, blogs and more to defame, taunt, harass, retaliate, bully and
paint in false light, Defendant / Counter Plaintiff Crystal L. Cox and Defendant Eliot Bernstein.
There is not VIOLATION of the Anti-cybersquatting Consumer Protection Act (the “ACPA”) (15
U.S.C. § 1125(d)), there was NO bad Faith. There was and is not rights of publicity under the
laws of the State of Nevada Plaintiffs and even if the Nevada courts found this to be so, then the
blogs could be banned ONLY In Nevada.
Counter Defendant / Plaintiff Marc Randazza is an expert in this industry, Plaintiff knows that he
is lying to this court deliberately to defame, attack and paint Defendants in false light.
Counter Defendant / Plaintiff Marc Randazza is NOT a household name and does not have an
automatic, exclusive right over the the name “Randazza” or “Marc Randazza” and Plaintiff Does
not have a Right to exclude ONE investigative Blogger from reporting on, publishing, using the
name Randazza” or “Marc Randazza”.
Counter Defendant / Plaintiff Marc Randazza, as in the Domain Name
GlenBeckRapedAndMurderedAYoungGirlIN1990.com and other Domain Name Cases, has
himself represented the domain name owner and argued in favor of the constitutional and lawful
right of the domain owner to own that domain name.
Yet, in a complete opposite, hypocritical defense in this case, Counter Defendant / Plaintiff Marc Randazza claims that CCC has no right to own such a name with the name Randazza in it, as that name is his and his alone to use.
As if to say no reporter, no news, no blog, no media can utter the word “Randazza” or “Marc Randazza” without his exclusive permission and that simply is not true.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza Says "Specifically, Cox registered Plaintiff
Randazza’s personal name, under which he has conducted business at his well-known law firm,
in multiple domain names and attempted to extort Plaintiff, as is her demonstrated modus
operandi (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by
Blogger, attached as Exhibit B) by offering her “reputation management services” in order to “fix”
Randazza’s business reputation that she, herself, harmed."
Counter Defendant / Plaintiff Marc Randazza disturbingly continues to involve his young
daughter, as if to get sympathy from the courts and public at large. Counter Defendant / Plaintiff
Marc Randazza knows full well that CCC never had a blog regarding his daughter, never posted
ONE WORD regarding her, and yet Counter Defendant / Plaintiff Marc Randazza used his own
daughter to paint ccc in false light and defame me, make me look like a monster to the public
and use her to STEAL blogs he has no right to.
Counter Defendant / Plaintiff Marc Randazza gave picture of his young daughter to big media and flat out lied that I had blogged about her when I did not EVER publish anything in regard to his daughter.
Counter Defendant / Plaintiff Marc Randazza even added his daughter to this lawsuit as a
Plaintiff, that is SICK. I, Defendant / Counter Plaintiff Crystal L. Cox have not mentioned her
name and I have not counter sued Plaintiff’s Daughter and Wife, deliberately, as neither had
anything to do with Counter Defendant / Plaintiff Marc Randazza’s hate, rage and retaliation
tactics against Defendant / Counter Plaintiff Crystal L. Cox . Counter Defendant / Plaintiff Marc
Randazza continues to use court dockets to lie about and defame Defendant / Counter Plaintiff
Crystal L. Cox. And he continues to use his young child as a weapon in the courts, SICK.
Counter Defendant / Plaintiff Marc Randazza claims that owning a person’s name in a domain
name is fine if it’s his client, yet wages a retaliation legal war against Defendant / Counter Plaintiff
Crystal L. Cox for owning such a Name. Counter Defendant / Plaintiff Marc Randazza LIES to
this court in AGAIN stating that I tried to extort his well known law firm. First of all he is NOT well
known, not a common household name. Secondly, I, Defendant / Counter Plaintiff Crystal L.
Cox, NEVER ever attempted to use a domain name to Extort Marc Randazza, as email records
show I told him I would not SELL the domain name at ANY price and in FACT gave it to
Investigative Blogger Monica Foster to help expose human trafficking, bad things happening to
kids in porn, prostitution rings, whistleblower retaliation and all that she exposes on
PornNewsToday.com.
Monica Foster aKa Alexandria Melody, was threatened by Marc Randazza and Co-Conspirators /
Counter Defendants, she was in fear of her life and therefore I told her I would take the domain
name back. Shortly after that, Counter Defendant / Plaintiff Marc Randazza filed a fraudulent
WIPO Claim, and then filed this Lawsuit in retaliation.
Counter Defendant / Plaintiff Marc Randazza claims this “by offering her “reputation
management services” in order to “fix” Randazza’s business reputation that she, herself,
harmed.” This is FALSE. I never EVER offered to “FIX” Randazza’s business reputation, email
records show that I, Defendant / Counter Plaintiff Crystal L. Cox, never said that. Counter
Defendant / Plaintiff Marc Randazza continues to use his power in the courts to defame and flat
out lies about Cox.
I, Defendant / Counter Plaintiff Crystal L. Cox, never wrote ONE word about Marc Randazza
when I sent the email asking for a Job. I posted blogs regarding Counter Defendant / Plaintiff
Marc Randazza AFTER he contacted the Plaintiff and the Judge in my Obsidian V. Cox case
and conspired to set me up for a Crime, I started the blogs AFTER that to Defend Myself from
his RAGE and retaliation.
Counter Defendant / Plaintiff Marc Randazza should not be able to simply LIE to a court and
because he is an attorney, it is taken as fact. Counter Defendant / Plaintiff Marc Randazza
should not be able to submit blogs to the courts of his co-conspirators and have those blog
posts used as evidence to harm his intended target, defendant.
Counter Defendant / Plaintiff Marc Randazza is flat out lying about Defendant / Counter Plaintiff
Crystal L. Cox Extorting him. Email records and communications PROVE there was no
Extortion. YET, Counter Defendant / Plaintiff Marc Randazza continues to use motions in the
courts to attack, defame, taunt, harass, bully and paint Defendant / Counter Plaintiff Crystal L.
Cox in false light INTENTIONALLY.
Counter Defendant / Plaintiff Marc Randazza continues to use Kashmir Hill’s post about CC to
defame CC.” (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by
Blogger, attached as Exhibit B) “
Kashmir Hill of Forbes is from AboveTheLaw.com, and Counter Defendant / Plaintiff Marc
Randazza is their attorney. Kashmir Hill of Forbes is a co-conspirator and that article is
DEFAMATION with actual malice. Kashmir Hill of Forbes is liable for the defamation in that post.
Counter Defendant / Plaintiff Marc Randazza knows the information is false, yet uses Kashmir
Hill’s post as some sort of evidence that Defendant / Counter Plaintiff Crystal L. Cox did
something unlawful or prove that Defendant / Counter Plaintiff Crystal L. Cox extorted him, or did
something that would warrant deletion of massive online content, stealing domain names,
removing blogs, redirecting servers and constantly attacking and harassing Defendant / Counter
Plaintiff Crystal L. Cox .
Counter Defendant / Plaintiff Marc Randazza told me Defendant / Counter Plaintiff Crystal L.
Cox, that if I did not GIVE him the Domain Name he wanted, he would make me an ENEMY. Now
that’s Extortion and he sure did follow through. Counter Defendant / Plaintiff Marc Randazza has
RUINED my life, with ACTUAL MALICE, actual knowing of the Facts of the Matter.
Counter Defendant / Plaintiff Marc Randazza Constantly Accuses Defendant / Counter Plaintiff
Crystal L. Cox of being involved in a conspiracy that does not exist, meanwhile he daily
conspires to harm Defendant / Counter Plaintiff Crystal L. Cox, retaliate, defame, intimidate and
ruin Defendant / Counter Plaintiff Crystal L. Cox Facts, Documented Facts and Evidence SHOULD be at Issue in this Case. Instead Plaintiff simply supplies this court with blog posts and words of co-conspirators, in which are NOT documented FACT.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza blogs about Defendant / Counter Plaintiff Crystal L.
Cox and constantly discusses his opinion of me on twitter, facebook, and encourages others to
publish online about me, make videos lying about me and defaming me.
Plaintiff Stating this “Another District Judge, Marco Hernandez of the District of Oregon,
euphemistically described Cox’s scheme as repairing the damage she had caused for a
“tasteful” fee. Obsidian Finance Group LLC v. Cox, 2012 WL 1065484 (D. Ore. 2012).” Is
defamatory. I was not on trial for extortion, this was in regard to a settlement negotiation
communication, and has nothing to do with the material facts of Randazza V. Cox. This is
placed in a Motion for a Summary Judgement, with Malice, to further paint Counter Plaintiff /
Defendant Crystal Cox in false light, defame her, harass and intimidate her.
Counter Plaintiff / Defendant Crystal Cox posted remarks and poked fun at what Plaintiff Marc
Randazza had said about his own wife, in a drunken tryst post on his own blog. Counter Plaintiff
/ Defendant Crystal Cox never EVER posted anything online regarding Marc Randazza’s child,
he himself did that.
Again Counter Defendant / Plaintiff Marc Randazza uses the court docket, abuses his power,
and defames, harasses Counter Plaintiff / Defendant Crystal Cox.
Counter Defendant / Plaintiff Marc Randazza Says, “Plaintiffs are not the only victims of the Cox
scheme. Ms. Cox has targeted several dozen other victims, registering their full names as
domain names and falsely accusing them of any manner of wrongdoings.” This is false and
defamatory and has nothing to do with the material facts of Randazza V. Cox. I am a reporter,
an investigative blogger, what Plaintiff refers to as victims, are subjects of my stories, and yes, of
course I get the best keyword rich domain name I can to get strong in the search engines, that is
taught in EVERY book and class regarding SEO and Internet Marketing. I have never asked for
MONEY to remove any information, no have I ever written a story with the intention to ask for
money to remove it. Nor has I ever stated that if you don’t pay me, I will post bad stuff. That is
simply further defamatory fraud on the courts. I am an investigative blogger exposing corruption
in New Media, with the best possible marketing techniques I know of. I have not extorted anyone
nor received payment from anyone to remove information I have written.
Counter Defendant / Plaintiff Marc Randazza is discriminating against Citizen Journalists and
Bloggers not affiliated with Big Media. The New York Times, Forbes and other Big Media posts
stories daily on companies, individuals and they are not called victims. Often times the The New
York Times, Forbes and other Big Media are asked to remove information or even sued for
inaccurate information, this is not deemed Extortion. Why are my Investigative Blogs called
Extortion?
The reason is because those I expose for alleged corruption and the tips I get on them
in which I post, they don’t like this information out there, so they claim me an Extortionist, when I
have Extorted NO ONE, and received no money for such, nor been under investigation for the
crime of Extortion, yet Counter Defendant / Plaintiff Marc Randazza and Counter Defendant
Ronald Green continue to use this court docket to defame me and flat out state as fact that I
have committed Extortion when I have not had due process, nor a criminal investigation or trial
regarding this allegation. Yet Counter Defendant / Plaintiff Marc Randazza State it as fact.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza State “Just as she has done with Plaintiff Marc
Randazza, Cox then offers her “reputation services” to the people whose names she has
registered. See Obsidian Finance Group, LLC v. Cox, 2012 WL 1065484 (D. Ore 2012)
(“[D]efendant offered ‘PR,’ ‘search engine management,’ and online reputation repair services to
Obsidian Finance, for a price of $2,500 per month ...
The suggestion was that defendant offered to repair the very damage she caused for a small but tasteful monthly fee”);” I object to this statement, Obsidian V. Cox was a CIVIL trial regarding defamation, it had NOTHING to do with Extortion, which would be a Criminal Trial. This $2500, was one sentence pulled from 5 emails between Pro Se Defendant Crystal Cox, acting in her Pro Se Capacity and David S. Aman, Tonkon Torp Opposing Counsel. These 5 emails were a Settlement Negotiation in response to a Cease and Desist Legal Threat and sent after a 10 Million Dollar Defamation Lawsuit had been filed by David S. Aman, Tonkon Torp on behalf of Federal Bankruptcy Trustee Kevin Padrick and his Company Obsidian Finance Group.
This one sentence, has been used out of context to retaliate on a Reporter exposing the clients
of Counter Defendant / Plaintiff Marc Randazza and Counter Defendant David. S. Aman. The
facts of the case are all of record, and Extortion was not a material fact. Also I, Counter Plaintiff /
Defendant Crystal Cox object to speculation stating that “The suggestion was that defendant
offered to repair the very damage she caused for a small but tasteful monthly fee” this is false, I
only offered any negotiation, AFTER I had been threatened with a 10 Million Dollar Legal Action.
This was a negotiation settlement communication to try and STOP the next several years of my
life from being in legal action. The Plaintiff made 8 Settlement Offers to me, and they are not
deemed Extortion yet the Plaintiff offered I pay them $5000 every time I mention their name and
that I blame my whistleblower and her father for my posts, which is illegal. This is all a matter of
record.
Regarding this, “Randazza’s name functions as a trademark. Randazza is an individual, an
attorney, a legal author, and a resident of Clark County, Nevada. (ECF #1 ¶23;Randazza Decl. ¶
1). Plaintiff is the owner and managing partner of RLG, with offices located in Nevada, Florida,
and Arizona. (ECF #1 ¶ 23; Id.). Since 2008, RLG has done business using Marc Randazza’s
personal name as a source identifier for its services. (ECF #1 ¶ 23).”
Counter Defendant / Plaintiff Marc Randazza has NO Trademark or exclusive right to use the
word “Randazza” or Marc Randazza. “Randazza’s name” does NOT function as a Trademark
anymore then I can say no one can use the name Crystal Cox in the reporting of my case or
their opinion of my case. It is not a Trademark violation to report on Marc Randazza.
Counter Defendant / Plaintiff Marc Randazza says, “Cox registered the Infringing Domain Names
with the intent to capitalize on the use of Plaintiff Randazza’s personal name, extort money from
Plaintiffs, and engage witness intimidation. (Exhibit H; Blog post asking for $5 million for sale of
<marcrandazza.me>, attached as Exhibit M; ECF #12-4 video from Cox admitting witness
intimidation, a relevant transcript of which is attached as Exhibit N). In fact, the profit in Ms. Cox’s
endeavor flows directly from her extortion scheme.”
I Counter Plaintiff / Defendant Crystal Cox, Object to that statement. I joked about $5 Million just
after I bought MarcRandazza.me, I titled the post here Kittty Kitty, it was a Parody. I had just
bought it for 10 Dollars, there was no blog on it or value in it. Counter Defendant / Plaintiff Marc
Randazza is trying to make it look like I offered the name for that real price, and that is not True.
However, people buy and sell domain names every day, and can buy and sell LEGALLY for
whatever price they want. Even if their is a possible Trademark. Godaddy has thousands of
domain names on auction sites that have other peoples names or possible trademark names in
them, they sell them all the time. It is not illegal nor has it cause and harm to the Plaintiff.
No Domain Names were EVER bought to tamper with a witness, they were purchased to
report on a story, period.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I Counter Plaintiff / Defendant Crystal Cox, have never had an Extortion scheme nor have I ever
taken in ANY money they could possible be mistook as Extortion. If Counter Defendant / Plaintiff
Marc Randazza really believes this and has convinced this court I am guilty of Extortion then why
not file Criminal Charges, give me an Criminal Attorney and due process under law, BEFORE
publishing widely that I, Counter Plaintiff / Defendant Crystal Cox and Eliot Bernstein are Guilt of
Extortion, as if already convicted. And then Using this Court to further that false defamatory
statement as fact, when it is not fact.
“On December 10, 2011, Crystal Cox registered <marcrandazza.com> in the publicly
available Whois information. (See Exhibit K). On January 16, 2012, Cox sent an email to Plaintiff
stating that she had purchased his personal name as a domain name. (See Exhibit H). She then
asked Plaintiff to purchase her “reputation management services” in an attempt to extort money
from Plaintiff. (See Exhibit H). This is her modus operandi. See Obsidian Finance Group, LLC v.
Cox, 2012 WL 1065484 (D. Ore)
This statement is not true. The New York Times was already defaming me, and there was no
way I would have sent anything that would have even remotely have suggested extortion. I asked
Marc Randazza for a Job, plain and simply. I had the dotcom at issue when he was my attorney,
to report on my own story. He said he did not want to hire me then he proceeded to act and
defame me so I used the name to report on him, expose him and warn the public at large, as a
Public Service.
Counter Defendant / Plaintiff Marc Randazza offered to buy the domain name from me and from
Monica Foster, we both said no. I told him I would not sell for any price, this is NOT extortion.
Plaint then launched into a year long and continued retaliation. Counter Defendant / Plaintiff Marc
Randazza also asked me what I wanted from him, email records prove that. Plaintiff said that I
made my point, if I was an extortionist I would have demanded money, I rejected his offers,
Plaintiff Retaliated over and over.
Counter Defendant / Plaintiff Marc Randazza says, “Defendant Cox will not stop until she is
satisfied that she has successfully intimidated Plaintiff or until he pays the requested ransom.”.
I, Counter Plaintiff / Defendant Crystal Cox, OBJECT to this, I never offered an ransom request,
this is fraud on the courts. Also why would I, over any other reporter, have to be singled out to
stop reporting on, having an opinion on, or making fun of Marc Randazza?
This violated my constitutional and civil rights.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Plaintiff / Defendant Crystal Cox NEVER had “bad faith” intend. My Intent is to report on
and expose corruption in the United States Judicial System. I have been dedicated to this for
over 7 years, at great personal cost. I have been fighting and exposing corruption and Counter
Defendant / Plaintiff Marc Randazza has painted me to look like the criminal, when the truth is I
am reporting on, exposing the crimes.
Regardless of the Defamatory Lies in publications by Counter Defendant / Plaintiff Marc
Randazza and Counter Defendants, Investigative Blogger Counter Plaintiff / Defendant Crystal’s
purpose was ALWAYS, SOLELY to expose corruption, parody corruption, provide “speech
critical” of those I alleged participated in these corrupt activities and to try and make the world a
better place doing what I could to help give justice to victims of corruption.
Counter Defendant / Plaintiff Marc Randazza has no trademark on the name Marc Randazza
and has no right to MarcRandazza.com or any of the Domain Names he stole from Counter
Plaintiff / Defendant Crystal Cox Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as his allegations are all FALSE and Defamatory.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Marco Randazza is the Plaintiffs “Handle”, “Persona” Online, NOT Marc Randazza.
It is unlawful and unconstitutional to ban an investigative blogger, a journalist from writing a last
name on her online media. Marc Randazza, is not the only Marc Randazza in the world, nor
does he have an exclusive right on the use of “Randazza”
There are many people with that last name. Plaintiff has no right to exclude ANY blogger,
journalist, to not use his name or last name. That would be like me saying no one can utter can’t
the last name Cox on anything ever. It is ridiculous, and unconstitutional, as well as selective
prosecution.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Plaintiff Marc Randazza has no Trademark on the name “Marc Randazza”.
Plaintiff Marc Randazza uses the Trade Name, Marco Randazza as his Twitter and
YouTube User Name, as well as his username on his own blog, and many other forums,
blogs, news sites and social networks, NOT Marc but MARCO, .
Plaintiff Marc Randazza uses the Trade Name, Marco Randazza on Best Tweets, in Penn.
News Articles, on Flickr, in Gloucester Times, on multiple YouTube accounts, on the Legal
Satyricon as his username on his own blog, on the DNF forum, on yFrog, and many other
sites and sources.
Plaintiff Marc Randazza had / has no ™ posted at his blog regarding the name Marc
Randazza as being trademarked and Plaintiff Attorney Marc Randazza had no Trademark
when Defendant Crystal L. Cox purchased MarcRandazza.com to use as PR for Defendant
Crystal Cox’s highly public First Amendment Case, that will set a precendence that is a
“Game Changer” for ALL New Media, Bloggers, and Citizen Journalist.
Defendant Crystal L. Cox “actions” as Plaintiff calls it, were a “legitimate purpose” and that
purpose was originally to provide PR for her own court case of which Plaintiff Marc
Randazza was, at that time to be her attorney and acted on her behalf in negotiations with
Opposing Counsel, David S. Aman of Tonkon Torp Law Firm. Obsidian Finance Group vs.
Crystal Cox is the biggest Free Speech case any one, independent blogger has ever seen,
Obsidian V. Cox. Which is the only case of it’s kind to distinguish the rights of bloggers vs.
the rights of traditional media. Obsidian V. Cox will hopefully end the “Monopoly on Free
Speech” in which according to Plaintiff Marc Randazza to Defendant Crystal Cox that “Big
Media” told him, they make more money with a Monopoly on Free Speech.
Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as
his allegations are all FALSE and Defamatory.
There never was an Extortion Scheme. Counter Defendant / Plaintiff Marc Randazza has simply
used his money, power and influence to ruin the life of and bankrupt a female blogger who he did
not agree with.
I, Counter Plaintiff / Defendant Crystal Cox OBJECT to Plaintiff’s Motion for Summary
Judgement in it’s Entirety.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Source and Full Court Filing
District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights. Crystal Cox Objection to Summary Judgement.
Document 80, District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights.
Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT
Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT
"Notice To Court: This Court has DENIED requests to sign a conflict of Interest
Disclosure, though requested several times by Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox. Any action forward by Judge Gloria M. Navarro or Judge Peggy A. Leen, who
refuses to admit/deny conflicts and rules forward will be charged with Obstruction of Justice
through conflicts of interest, violations of attorney and judicial cannons in order to Deny Due
Process via aiding and abetting the alleged civil and criminal conspiracy through Fraud on the
Court.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox intend to file criminal complaints
against any officer of the court, including opposing counsel, who violates any law or ethical
statues in order to perpetrate the fraud through obstruction via conflicts, or has violated any law
already in previous rulings affecting me, Pro Se Defendant, Pro Se Counter Defendant Crystal
Cox.
Therefore every ruling of this court on a motion without conflict disclosure will be charged for
each and every act a in a criminal complaint, forthcoming.
Judge Gloria Navarro is alleged by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox to be
acting in criminal and civil conspiracy with Plaintiff / Counter Defendant Marc J. Randazza and
ALL Connected Co-Conspirators and Counter Defendants of District of Nevada Case
2:12-cv-02040-GMN-PAL and therefore this court has a duty to notify all applicable authorities,
bond carriers, insurance carriers, AND State and Federal Auditors of the liability of this allegation
in a Federal Court Proceeding.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox object to Plaintiff’s MOTION
FOR SUMMARY JUDGMENT.
Plaintiff Claims I have not disputed facts, when I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox have disputed Plaintiff’s Allegations over and over to the absolute best of my
ability. Plaintiffs / Counter Defendants have not Disputed ONE Allegation I have Claimed against
them in my Counter Complaint, however.
Plaintiff has not made one valid point of law in which entitles them to a Summary Judgement,
instead Plaintiff has used this MOTION FOR SUMMARY JUDGMENT as further harassment,
intimidation, defamation to Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox, “genuinely” dispute ALL claims in
Plaintiff’s claims against me and have repeatedly.
Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has not had a “campaign” in bad faith to
harass Plaintiff. Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has fought back against
Plaintiff and Counter Defendants attack on her. This court should not grant summary judgement
to Plaintiff, as Plaintiff has simply used the courts in bad faith to ATTACK a blogger he does not
like, or approve of her blog content and to wipe out his competition in the search engines by
using the courts.
Plaintiff and Co-Conspirators have taunted me, harassed, me, defamed me, attacked me
constantly and the only way I have to fight back is to post my proof online. It is a violation of my
Freedom of Expression and my First Amendment Rights to stop the flow of information on my
blogs, to delete my blogs, redirect my domain names and harass me.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Plaintiff continues to LIES to this court and to publicly defame me in court documents, as I did
NOT extort Plaintiff. I asked Plaintiff for a Job, and he was upset at a Domain Name I owned and
then contacted the Plaintiff in Obsidian V. Cox and conspired to set me up for extortion in
revenge for me owning a domain name he did not approve of. If he thought he had a Trademark
then why not just take the name from me, Pro Se Defendant / Pro Se Counter Plaintiff Crystal
Cox or from Monica Foster when she owned it.
Plaintiff offered Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox and Monica Foster for
the domain name and we both turned him down.
There was no Cyber Extortion and if Plaintiff really believes this and has evidence of this then
Plaintiff should file a criminal complaint so that I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal Cox, am entitled to due process of law. Instead Plaintiff is abusing his power over the
courts and simply stating I am guilty of extortion with no proof, no evidence of Extortion.
I did not offer Reputation Services and then attack Plaintiff in the search engines to retaliate. I
asked for a job, he said no and then demanded I turn over domain names. I stood up for myself
and he conspired with others to ruin me and to make it look like I was guilty of the crime of
extortion.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, was not on trial for extortion, never
had due process of law for this accusation, never had a criminal investigation, yet Counter
Defendant / Plaintiff Marc Randazza and Co-Conspirators continue to publicly state that I am
guilty of extortion. Why not file criminal charges, and then if a court of law convicts me of
extortion, then publish Crystal Cox is an Extortionist. Defendant / Plaintiff Marc Randazza and
Co-Conspirators did not do this, they simply attacked me, painted me in false light and made me
look to be an extortionist when that is not true.
I have made a living from Real Estate and from Online Supplements, My Anti-Corruption Blogs
have been to give victims of corruption a voice. The search engine management offer in the
Obsidian V. Cox case was part of a Settlement Negotiation, a month after a legal threat, and a
week after a 10 Million Dollar Lawsuit was filed against me. There were approx. 10 Settlement
Offers in that case. Those emails were between two attorneys negotiating a settlement, I was
Pro Se and acting in my Pro Se Capacity, and this ONE email out of 5 was used out of context
to defame and harass, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, and to retaliate
against me, AFTER David Aman, Tonkon Torp, Opposing Counsel had already won a 2.5 Million
Dollar Judgement.
Counter Defendant / Plaintiff Marc Randazza saw those eMails, he had ALL my files, and he
negotiated with David Aman, Tonkon Torp on my behalf in the Obsidian Case. As per those he
told in the First Amendment Bar that he represented me and was negotiating a deal.
Counter Defendant / Plaintiff Marc Randazza acted with intentional harm against Pro Se
Defendant / Pro Se Counter Plaintiff Crystal Cox,, when he broadcast that I am an Extortionist
and continues to accuse me, using the courts to further harass and defame me and State that I
am guilty of a crime that I am NOT guilty of nor have been charged with, little own prosecuted for.
Counter Defendant / Plaintiff Marc Randazza does not have the legal or constitutional right to, in
retaliation, hate or whatever reason to simply accuse who ever he please of a crime and then
broadcast that accusation as fact, BEFORE an innocent victims, such as Pro Se Defendant /
Pro Se Counter Plaintiff Crystal Cox is permanently harmed and defamed.
Counter Defendant / Plaintiff Marc Randazza had my personal information, confidential details of
my life and my strategy, and Defendant / Plaintiff Marc Randazza knew that I had not been on
trial for extortion nor charged with extortion, he had seen ALL my files. Counter Defendant /
Plaintiff Marc Randazza had requested all these files as email records show, BEFORE he
negotiated with David S. Aman, Opposing Counsel in the Obsidian V. Cox case.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox am one woman. Counter Defendant /
Plaintiff Marc Randazza has a strong blog, several online sites that are very strong, and lots of
connections with other attorneys and big media. When he posted that I was an Extortionist, the
only way I had to post the facts, and to save my reputation was to start multiple blogs. The more
I started, the more he got deleted.
This is not a “Google Bomb”, it is an internet marketing tactic to get my story found in the search engines. Instead of using co-conspirators as the Plaintiff does in this case and in Rakofsky V. the Internet, I am simply use my own sites and post in my own name.
This is not a Google Bomb nor cybersquatting, it is online competition in the search engines, in which Plaintiff Marc Randazza used this court to simply wipe out all my work, and without any due process or First Amendment Adjudication.
Counter Defendant / Plaintiff Marc Randazza states that “"Defendants Crystal L. Cox (“Cox”) and
Eliot Bernstein (“Bernstein”) registered the Infringing Domain Names (as defined in ECF #1 at
6-7) in an attempt to extort Plaintiffs and in violation of the Anti-cybersquatting Consumer
Protection Act (the “ACPA”) (15 U.S.C. § 1125(d)), individual cyberpiracy protections (15 U.S.C.
§ 8131), and rights of publicity under the laws of the State of Nevada Plaintiffs, as well raised
common law claims of intrusion upon seclusion and publicity and civil conspiracy. Plaintiffs’
claims arise from Defendants’ registration and use of Plaintiffs’ personal names as Internet
domain names."
Plaintiff flat out lies to this court, as Plaintiff knows full well that Eliot Bernstein never registered
those domain names. Plaintiff deliberately lies in court documents to defame and harass
Defendants Crystal L. Cox and Defendant Eliot Bernstein. Counter Defendant / Plaintiff Marc
Randazza is very familiar with Obsidian V. Cox, and Plaintiff knows that there are documents
filed as to how and why Defendant Eliot Bernstein got those domain names. Yet, Counter
Defendant / Plaintiff Marc Randazza deliberately lies to this court in retaliation. Counter
Defendant / Plaintiff Marc Randazza represents clients who LITERALLY owe Eliot Bernstein
billions of dollars. This lawsuit naming iViewit Founder Eliot Bernstein is simply to attempt to
discredit, harass, defame and intimidate Eliot Bernstein and to remove blogs that expose the
iViewit Technology theft, with is the biggest technology crime in the world, EVER.
Counter Defendant / Plaintiff Marc Randazza knowingly lies about domain names being
registered to Extort him somehow, that has no TRUTH what so ever to it. Neither Defendant
EVER asked Marc Randazza for money and said they would post “bad faith” or anything at all if
he did not pay, there WAS not Extortion. Counter Defendant / Plaintiff Marc Randazza continues
to use court documents, Big Media, blogs and more to defame, taunt, harass, retaliate, bully and
paint in false light, Defendant / Counter Plaintiff Crystal L. Cox and Defendant Eliot Bernstein.
There is not VIOLATION of the Anti-cybersquatting Consumer Protection Act (the “ACPA”) (15
U.S.C. § 1125(d)), there was NO bad Faith. There was and is not rights of publicity under the
laws of the State of Nevada Plaintiffs and even if the Nevada courts found this to be so, then the
blogs could be banned ONLY In Nevada.
Counter Defendant / Plaintiff Marc Randazza is an expert in this industry, Plaintiff knows that he
is lying to this court deliberately to defame, attack and paint Defendants in false light.
Counter Defendant / Plaintiff Marc Randazza is NOT a household name and does not have an
automatic, exclusive right over the the name “Randazza” or “Marc Randazza” and Plaintiff Does
not have a Right to exclude ONE investigative Blogger from reporting on, publishing, using the
name Randazza” or “Marc Randazza”.
Counter Defendant / Plaintiff Marc Randazza, as in the Domain Name
GlenBeckRapedAndMurderedAYoungGirlIN1990.com and other Domain Name Cases, has
himself represented the domain name owner and argued in favor of the constitutional and lawful
right of the domain owner to own that domain name.
Yet, in a complete opposite, hypocritical defense in this case, Counter Defendant / Plaintiff Marc Randazza claims that CCC has no right to own such a name with the name Randazza in it, as that name is his and his alone to use.
As if to say no reporter, no news, no blog, no media can utter the word “Randazza” or “Marc Randazza” without his exclusive permission and that simply is not true.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza Says "Specifically, Cox registered Plaintiff
Randazza’s personal name, under which he has conducted business at his well-known law firm,
in multiple domain names and attempted to extort Plaintiff, as is her demonstrated modus
operandi (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by
Blogger, attached as Exhibit B) by offering her “reputation management services” in order to “fix”
Randazza’s business reputation that she, herself, harmed."
Counter Defendant / Plaintiff Marc Randazza disturbingly continues to involve his young
daughter, as if to get sympathy from the courts and public at large. Counter Defendant / Plaintiff
Marc Randazza knows full well that CCC never had a blog regarding his daughter, never posted
ONE WORD regarding her, and yet Counter Defendant / Plaintiff Marc Randazza used his own
daughter to paint ccc in false light and defame me, make me look like a monster to the public
and use her to STEAL blogs he has no right to.
Counter Defendant / Plaintiff Marc Randazza gave picture of his young daughter to big media and flat out lied that I had blogged about her when I did not EVER publish anything in regard to his daughter.
Counter Defendant / Plaintiff Marc Randazza even added his daughter to this lawsuit as a
Plaintiff, that is SICK. I, Defendant / Counter Plaintiff Crystal L. Cox have not mentioned her
name and I have not counter sued Plaintiff’s Daughter and Wife, deliberately, as neither had
anything to do with Counter Defendant / Plaintiff Marc Randazza’s hate, rage and retaliation
tactics against Defendant / Counter Plaintiff Crystal L. Cox . Counter Defendant / Plaintiff Marc
Randazza continues to use court dockets to lie about and defame Defendant / Counter Plaintiff
Crystal L. Cox. And he continues to use his young child as a weapon in the courts, SICK.
Counter Defendant / Plaintiff Marc Randazza claims that owning a person’s name in a domain
name is fine if it’s his client, yet wages a retaliation legal war against Defendant / Counter Plaintiff
Crystal L. Cox for owning such a Name. Counter Defendant / Plaintiff Marc Randazza LIES to
this court in AGAIN stating that I tried to extort his well known law firm. First of all he is NOT well
known, not a common household name. Secondly, I, Defendant / Counter Plaintiff Crystal L.
Cox, NEVER ever attempted to use a domain name to Extort Marc Randazza, as email records
show I told him I would not SELL the domain name at ANY price and in FACT gave it to
Investigative Blogger Monica Foster to help expose human trafficking, bad things happening to
kids in porn, prostitution rings, whistleblower retaliation and all that she exposes on
PornNewsToday.com.
Monica Foster aKa Alexandria Melody, was threatened by Marc Randazza and Co-Conspirators /
Counter Defendants, she was in fear of her life and therefore I told her I would take the domain
name back. Shortly after that, Counter Defendant / Plaintiff Marc Randazza filed a fraudulent
WIPO Claim, and then filed this Lawsuit in retaliation.
Counter Defendant / Plaintiff Marc Randazza claims this “by offering her “reputation
management services” in order to “fix” Randazza’s business reputation that she, herself,
harmed.” This is FALSE. I never EVER offered to “FIX” Randazza’s business reputation, email
records show that I, Defendant / Counter Plaintiff Crystal L. Cox, never said that. Counter
Defendant / Plaintiff Marc Randazza continues to use his power in the courts to defame and flat
out lies about Cox.
I, Defendant / Counter Plaintiff Crystal L. Cox, never wrote ONE word about Marc Randazza
when I sent the email asking for a Job. I posted blogs regarding Counter Defendant / Plaintiff
Marc Randazza AFTER he contacted the Plaintiff and the Judge in my Obsidian V. Cox case
and conspired to set me up for a Crime, I started the blogs AFTER that to Defend Myself from
his RAGE and retaliation.
Counter Defendant / Plaintiff Marc Randazza should not be able to simply LIE to a court and
because he is an attorney, it is taken as fact. Counter Defendant / Plaintiff Marc Randazza
should not be able to submit blogs to the courts of his co-conspirators and have those blog
posts used as evidence to harm his intended target, defendant.
Counter Defendant / Plaintiff Marc Randazza is flat out lying about Defendant / Counter Plaintiff
Crystal L. Cox Extorting him. Email records and communications PROVE there was no
Extortion. YET, Counter Defendant / Plaintiff Marc Randazza continues to use motions in the
courts to attack, defame, taunt, harass, bully and paint Defendant / Counter Plaintiff Crystal L.
Cox in false light INTENTIONALLY.
Counter Defendant / Plaintiff Marc Randazza continues to use Kashmir Hill’s post about CC to
defame CC.” (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by
Blogger, attached as Exhibit B) “
Kashmir Hill of Forbes is from AboveTheLaw.com, and Counter Defendant / Plaintiff Marc
Randazza is their attorney. Kashmir Hill of Forbes is a co-conspirator and that article is
DEFAMATION with actual malice. Kashmir Hill of Forbes is liable for the defamation in that post.
Counter Defendant / Plaintiff Marc Randazza knows the information is false, yet uses Kashmir
Hill’s post as some sort of evidence that Defendant / Counter Plaintiff Crystal L. Cox did
something unlawful or prove that Defendant / Counter Plaintiff Crystal L. Cox extorted him, or did
something that would warrant deletion of massive online content, stealing domain names,
removing blogs, redirecting servers and constantly attacking and harassing Defendant / Counter
Plaintiff Crystal L. Cox .
Counter Defendant / Plaintiff Marc Randazza told me Defendant / Counter Plaintiff Crystal L.
Cox, that if I did not GIVE him the Domain Name he wanted, he would make me an ENEMY. Now
that’s Extortion and he sure did follow through. Counter Defendant / Plaintiff Marc Randazza has
RUINED my life, with ACTUAL MALICE, actual knowing of the Facts of the Matter.
Counter Defendant / Plaintiff Marc Randazza Constantly Accuses Defendant / Counter Plaintiff
Crystal L. Cox of being involved in a conspiracy that does not exist, meanwhile he daily
conspires to harm Defendant / Counter Plaintiff Crystal L. Cox, retaliate, defame, intimidate and
ruin Defendant / Counter Plaintiff Crystal L. Cox Facts, Documented Facts and Evidence SHOULD be at Issue in this Case. Instead Plaintiff simply supplies this court with blog posts and words of co-conspirators, in which are NOT documented FACT.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza blogs about Defendant / Counter Plaintiff Crystal L.
Cox and constantly discusses his opinion of me on twitter, facebook, and encourages others to
publish online about me, make videos lying about me and defaming me.
Plaintiff Stating this “Another District Judge, Marco Hernandez of the District of Oregon,
euphemistically described Cox’s scheme as repairing the damage she had caused for a
“tasteful” fee. Obsidian Finance Group LLC v. Cox, 2012 WL 1065484 (D. Ore. 2012).” Is
defamatory. I was not on trial for extortion, this was in regard to a settlement negotiation
communication, and has nothing to do with the material facts of Randazza V. Cox. This is
placed in a Motion for a Summary Judgement, with Malice, to further paint Counter Plaintiff /
Defendant Crystal Cox in false light, defame her, harass and intimidate her.
Counter Plaintiff / Defendant Crystal Cox posted remarks and poked fun at what Plaintiff Marc
Randazza had said about his own wife, in a drunken tryst post on his own blog. Counter Plaintiff
/ Defendant Crystal Cox never EVER posted anything online regarding Marc Randazza’s child,
he himself did that.
Again Counter Defendant / Plaintiff Marc Randazza uses the court docket, abuses his power,
and defames, harasses Counter Plaintiff / Defendant Crystal Cox.
Counter Defendant / Plaintiff Marc Randazza Says, “Plaintiffs are not the only victims of the Cox
scheme. Ms. Cox has targeted several dozen other victims, registering their full names as
domain names and falsely accusing them of any manner of wrongdoings.” This is false and
defamatory and has nothing to do with the material facts of Randazza V. Cox. I am a reporter,
an investigative blogger, what Plaintiff refers to as victims, are subjects of my stories, and yes, of
course I get the best keyword rich domain name I can to get strong in the search engines, that is
taught in EVERY book and class regarding SEO and Internet Marketing. I have never asked for
MONEY to remove any information, no have I ever written a story with the intention to ask for
money to remove it. Nor has I ever stated that if you don’t pay me, I will post bad stuff. That is
simply further defamatory fraud on the courts. I am an investigative blogger exposing corruption
in New Media, with the best possible marketing techniques I know of. I have not extorted anyone
nor received payment from anyone to remove information I have written.
Counter Defendant / Plaintiff Marc Randazza is discriminating against Citizen Journalists and
Bloggers not affiliated with Big Media. The New York Times, Forbes and other Big Media posts
stories daily on companies, individuals and they are not called victims. Often times the The New
York Times, Forbes and other Big Media are asked to remove information or even sued for
inaccurate information, this is not deemed Extortion. Why are my Investigative Blogs called
Extortion?
The reason is because those I expose for alleged corruption and the tips I get on them
in which I post, they don’t like this information out there, so they claim me an Extortionist, when I
have Extorted NO ONE, and received no money for such, nor been under investigation for the
crime of Extortion, yet Counter Defendant / Plaintiff Marc Randazza and Counter Defendant
Ronald Green continue to use this court docket to defame me and flat out state as fact that I
have committed Extortion when I have not had due process, nor a criminal investigation or trial
regarding this allegation. Yet Counter Defendant / Plaintiff Marc Randazza State it as fact.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Defendant / Plaintiff Marc Randazza State “Just as she has done with Plaintiff Marc
Randazza, Cox then offers her “reputation services” to the people whose names she has
registered. See Obsidian Finance Group, LLC v. Cox, 2012 WL 1065484 (D. Ore 2012)
(“[D]efendant offered ‘PR,’ ‘search engine management,’ and online reputation repair services to
Obsidian Finance, for a price of $2,500 per month ...
The suggestion was that defendant offered to repair the very damage she caused for a small but tasteful monthly fee”);” I object to this statement, Obsidian V. Cox was a CIVIL trial regarding defamation, it had NOTHING to do with Extortion, which would be a Criminal Trial. This $2500, was one sentence pulled from 5 emails between Pro Se Defendant Crystal Cox, acting in her Pro Se Capacity and David S. Aman, Tonkon Torp Opposing Counsel. These 5 emails were a Settlement Negotiation in response to a Cease and Desist Legal Threat and sent after a 10 Million Dollar Defamation Lawsuit had been filed by David S. Aman, Tonkon Torp on behalf of Federal Bankruptcy Trustee Kevin Padrick and his Company Obsidian Finance Group.
This one sentence, has been used out of context to retaliate on a Reporter exposing the clients
of Counter Defendant / Plaintiff Marc Randazza and Counter Defendant David. S. Aman. The
facts of the case are all of record, and Extortion was not a material fact. Also I, Counter Plaintiff /
Defendant Crystal Cox object to speculation stating that “The suggestion was that defendant
offered to repair the very damage she caused for a small but tasteful monthly fee” this is false, I
only offered any negotiation, AFTER I had been threatened with a 10 Million Dollar Legal Action.
This was a negotiation settlement communication to try and STOP the next several years of my
life from being in legal action. The Plaintiff made 8 Settlement Offers to me, and they are not
deemed Extortion yet the Plaintiff offered I pay them $5000 every time I mention their name and
that I blame my whistleblower and her father for my posts, which is illegal. This is all a matter of
record.
Regarding this, “Randazza’s name functions as a trademark. Randazza is an individual, an
attorney, a legal author, and a resident of Clark County, Nevada. (ECF #1 ¶23;Randazza Decl. ¶
1). Plaintiff is the owner and managing partner of RLG, with offices located in Nevada, Florida,
and Arizona. (ECF #1 ¶ 23; Id.). Since 2008, RLG has done business using Marc Randazza’s
personal name as a source identifier for its services. (ECF #1 ¶ 23).”
Counter Defendant / Plaintiff Marc Randazza has NO Trademark or exclusive right to use the
word “Randazza” or Marc Randazza. “Randazza’s name” does NOT function as a Trademark
anymore then I can say no one can use the name Crystal Cox in the reporting of my case or
their opinion of my case. It is not a Trademark violation to report on Marc Randazza.
Counter Defendant / Plaintiff Marc Randazza says, “Cox registered the Infringing Domain Names
with the intent to capitalize on the use of Plaintiff Randazza’s personal name, extort money from
Plaintiffs, and engage witness intimidation. (Exhibit H; Blog post asking for $5 million for sale of
<marcrandazza.me>, attached as Exhibit M; ECF #12-4 video from Cox admitting witness
intimidation, a relevant transcript of which is attached as Exhibit N). In fact, the profit in Ms. Cox’s
endeavor flows directly from her extortion scheme.”
I Counter Plaintiff / Defendant Crystal Cox, Object to that statement. I joked about $5 Million just
after I bought MarcRandazza.me, I titled the post here Kittty Kitty, it was a Parody. I had just
bought it for 10 Dollars, there was no blog on it or value in it. Counter Defendant / Plaintiff Marc
Randazza is trying to make it look like I offered the name for that real price, and that is not True.
However, people buy and sell domain names every day, and can buy and sell LEGALLY for
whatever price they want. Even if their is a possible Trademark. Godaddy has thousands of
domain names on auction sites that have other peoples names or possible trademark names in
them, they sell them all the time. It is not illegal nor has it cause and harm to the Plaintiff.
No Domain Names were EVER bought to tamper with a witness, they were purchased to
report on a story, period.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
I Counter Plaintiff / Defendant Crystal Cox, have never had an Extortion scheme nor have I ever
taken in ANY money they could possible be mistook as Extortion. If Counter Defendant / Plaintiff
Marc Randazza really believes this and has convinced this court I am guilty of Extortion then why
not file Criminal Charges, give me an Criminal Attorney and due process under law, BEFORE
publishing widely that I, Counter Plaintiff / Defendant Crystal Cox and Eliot Bernstein are Guilt of
Extortion, as if already convicted. And then Using this Court to further that false defamatory
statement as fact, when it is not fact.
“On December 10, 2011, Crystal Cox registered <marcrandazza.com> in the publicly
available Whois information. (See Exhibit K). On January 16, 2012, Cox sent an email to Plaintiff
stating that she had purchased his personal name as a domain name. (See Exhibit H). She then
asked Plaintiff to purchase her “reputation management services” in an attempt to extort money
from Plaintiff. (See Exhibit H). This is her modus operandi. See Obsidian Finance Group, LLC v.
Cox, 2012 WL 1065484 (D. Ore)
This statement is not true. The New York Times was already defaming me, and there was no
way I would have sent anything that would have even remotely have suggested extortion. I asked
Marc Randazza for a Job, plain and simply. I had the dotcom at issue when he was my attorney,
to report on my own story. He said he did not want to hire me then he proceeded to act and
defame me so I used the name to report on him, expose him and warn the public at large, as a
Public Service.
Counter Defendant / Plaintiff Marc Randazza offered to buy the domain name from me and from
Monica Foster, we both said no. I told him I would not sell for any price, this is NOT extortion.
Plaint then launched into a year long and continued retaliation. Counter Defendant / Plaintiff Marc
Randazza also asked me what I wanted from him, email records prove that. Plaintiff said that I
made my point, if I was an extortionist I would have demanded money, I rejected his offers,
Plaintiff Retaliated over and over.
Counter Defendant / Plaintiff Marc Randazza says, “Defendant Cox will not stop until she is
satisfied that she has successfully intimidated Plaintiff or until he pays the requested ransom.”.
I, Counter Plaintiff / Defendant Crystal Cox, OBJECT to this, I never offered an ransom request,
this is fraud on the courts. Also why would I, over any other reporter, have to be singled out to
stop reporting on, having an opinion on, or making fun of Marc Randazza?
This violated my constitutional and civil rights.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Counter Plaintiff / Defendant Crystal Cox NEVER had “bad faith” intend. My Intent is to report on
and expose corruption in the United States Judicial System. I have been dedicated to this for
over 7 years, at great personal cost. I have been fighting and exposing corruption and Counter
Defendant / Plaintiff Marc Randazza has painted me to look like the criminal, when the truth is I
am reporting on, exposing the crimes.
Regardless of the Defamatory Lies in publications by Counter Defendant / Plaintiff Marc
Randazza and Counter Defendants, Investigative Blogger Counter Plaintiff / Defendant Crystal’s
purpose was ALWAYS, SOLELY to expose corruption, parody corruption, provide “speech
critical” of those I alleged participated in these corrupt activities and to try and make the world a
better place doing what I could to help give justice to victims of corruption.
Counter Defendant / Plaintiff Marc Randazza has no trademark on the name Marc Randazza
and has no right to MarcRandazza.com or any of the Domain Names he stole from Counter
Plaintiff / Defendant Crystal Cox Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as his allegations are all FALSE and Defamatory.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Marco Randazza is the Plaintiffs “Handle”, “Persona” Online, NOT Marc Randazza.
It is unlawful and unconstitutional to ban an investigative blogger, a journalist from writing a last
name on her online media. Marc Randazza, is not the only Marc Randazza in the world, nor
does he have an exclusive right on the use of “Randazza”
There are many people with that last name. Plaintiff has no right to exclude ANY blogger,
journalist, to not use his name or last name. That would be like me saying no one can utter can’t
the last name Cox on anything ever. It is ridiculous, and unconstitutional, as well as selective
prosecution.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Plaintiff Marc Randazza has no Trademark on the name “Marc Randazza”.
Plaintiff Marc Randazza uses the Trade Name, Marco Randazza as his Twitter and
YouTube User Name, as well as his username on his own blog, and many other forums,
blogs, news sites and social networks, NOT Marc but MARCO, .
Plaintiff Marc Randazza uses the Trade Name, Marco Randazza on Best Tweets, in Penn.
News Articles, on Flickr, in Gloucester Times, on multiple YouTube accounts, on the Legal
Satyricon as his username on his own blog, on the DNF forum, on yFrog, and many other
sites and sources.
Plaintiff Marc Randazza had / has no ™ posted at his blog regarding the name Marc
Randazza as being trademarked and Plaintiff Attorney Marc Randazza had no Trademark
when Defendant Crystal L. Cox purchased MarcRandazza.com to use as PR for Defendant
Crystal Cox’s highly public First Amendment Case, that will set a precendence that is a
“Game Changer” for ALL New Media, Bloggers, and Citizen Journalist.
Defendant Crystal L. Cox “actions” as Plaintiff calls it, were a “legitimate purpose” and that
purpose was originally to provide PR for her own court case of which Plaintiff Marc
Randazza was, at that time to be her attorney and acted on her behalf in negotiations with
Opposing Counsel, David S. Aman of Tonkon Torp Law Firm. Obsidian Finance Group vs.
Crystal Cox is the biggest Free Speech case any one, independent blogger has ever seen,
Obsidian V. Cox. Which is the only case of it’s kind to distinguish the rights of bloggers vs.
the rights of traditional media. Obsidian V. Cox will hopefully end the “Monopoly on Free
Speech” in which according to Plaintiff Marc Randazza to Defendant Crystal Cox that “Big
Media” told him, they make more money with a Monopoly on Free Speech.
Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as
his allegations are all FALSE and Defamatory.
There never was an Extortion Scheme. Counter Defendant / Plaintiff Marc Randazza has simply
used his money, power and influence to ruin the life of and bankrupt a female blogger who he did
not agree with.
I, Counter Plaintiff / Defendant Crystal Cox OBJECT to Plaintiff’s Motion for Summary
Judgement in it’s Entirety.
For More Detailed Information on these Objections, and Reasons why Please See Memorandum
to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,
submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.
Source and Full Court Filing
Motion for Judicial Disqualification of Judge Gloria M. Navarro / Motion to Disqualify Judge Gloria Navarro; YOU have a Legal Right to a Fair and Impartial Judge.
Document 81, District of Nevada Trademark Lanham Court Case
"I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox move this court to Disqualify Judge
Gloria M. Navarro from any RULINGS, Opinions, Official Judgement Regarding DISTRICT OF
NEVADA Case 2:12-cv-02040-GMN-PAL.
With This Motion for Judicial Disqualification, I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox move this court to remove, recluse, disqualify Judge Gloria M. Navarro and to
remove, null, void all Opinions, Orders, Rulings previously opined, ruled on, entered on the
official docket or made in any way, as they were made in conflict and outside of the law and the
constitutional rights of Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.
Judge Gloria M. Navarro is also a named Defendant in DISTRICT OF NEVADA Case
2:12-cv-02040-GMN-PAL, and has yet another conflict of interest in ruling in this case.
With This Motion for Judicial Disqualification, I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox move this court to compensate Defendant for damages of RULINGS, Opinions,
Official Judgement Regarding DISTRICT OF NEVADA Case 2:12-cv-02040-GMN-PAL, in which
cannot be undone, in regard to rulings made in conflict that have caused irreparable harm,
deleted massive, valuable online media, wiped out database, removed thousands of links, and
permanently damaged Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox Defendants.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox have previously filed a motion to
"I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox move this court to Disqualify Judge
Gloria M. Navarro from any RULINGS, Opinions, Official Judgement Regarding DISTRICT OF
NEVADA Case 2:12-cv-02040-GMN-PAL.
With This Motion for Judicial Disqualification, I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox move this court to remove, recluse, disqualify Judge Gloria M. Navarro and to
remove, null, void all Opinions, Orders, Rulings previously opined, ruled on, entered on the
official docket or made in any way, as they were made in conflict and outside of the law and the
constitutional rights of Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.
Judge Gloria M. Navarro is also a named Defendant in DISTRICT OF NEVADA Case
2:12-cv-02040-GMN-PAL, and has yet another conflict of interest in ruling in this case.
With This Motion for Judicial Disqualification, I, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox move this court to compensate Defendant for damages of RULINGS, Opinions,
Official Judgement Regarding DISTRICT OF NEVADA Case 2:12-cv-02040-GMN-PAL, in which
cannot be undone, in regard to rulings made in conflict that have caused irreparable harm,
deleted massive, valuable online media, wiped out database, removed thousands of links, and
permanently damaged Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox Defendants.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox have previously filed a motion to
remove Judge Gloria Navarro, and another Motion to Recluse Judge Gloria Navarro. I have been
denied this right, thus far, and in my research of how a Federal Judge can rule on matters of
Reclusal or Removal of herself, I realize that in common parlance, some use “disqualification”
and “recusal” interchangeably, while others distinguish between the two, using “recusal” to mean
withdrawal on the judge’s own initiative, and “disqualification” to mean withdrawal on the motion
of a party.
Therefore I am now filing a Motion to Disqualify Judge Gloria Navarro from all rulings, matters,
opinions and orders in regard to DISTRICT OF NEVADA Case 2:12-cv-02040-GMN-PAL, and
that this include the dismissal of all previous rulings, and that this court make the matters of
those issues right with the harmed parties.
DISTRICT OF NEVADA Case 2:12-cv-02040-GMN-PAL is a very important legal case in which
involves massively important issues to the public at large. I, Pro Se Defendant / Pro Se Counter
Plaintiff Crystal L. Cox have every legal right and constitutional right to a non-conflicted,
unbiased, Judge ruling as a matter of law, instead of based on conflicts of interest.
According to, Judicial Disqualification: An Analysis of Federal Law, Second Edition,
Charles Gardner Geyh, Associate Dean of Research, John F. Kimberling Professor of
Law, Indiana University Maurer School of Law, a Federal Judicial Center Publication;
"For centuries, impartiality has been a defining feature of the Anglo-American judge’s role in the
administration of justice.
The reason is clear: in a constitutional order grounded in the rule of law,
it is imperative that judges make decisions according to law, unclouded by personal bias or
conflicts of interest. Accordingly, upon ascending the bench, every federal judge takes an oath to
“faithfully and impartially discharge and perform all the duties” of judicial office; and the Due
Process Clause of the Fourteenth Amendment to the United States Constitution has been
construed to guarantee litigants the right to a “neutral and detached,” or impartial, judge.
Moreover, in a democratic republic in which the legitimacy of government depends on the
consent and approval of the governed, public confidence in the administration of justice is
indispensable.
It is not enough that judges be impartial; the public must perceive them to be so.
The Code of Conduct for United States Judges therefore admonishes judges to “act at all
times in a manner that promotes public confidence in the integrity and impartiality of the judiciary” and to “avoid impropriety and the appearance of impropriety in all activities.”
When the impartiality of a judge is in doubt, the appropriate remedy is to disqualify that judge
from hearing further proceedings in the matter. In Caperton v. A.T. Massey Coal Co., a case
concerning disqualification of a state supreme court justice, the U.S. Supreme Court
reaffirmed that litigants have a due process right to an impartial judge, and that under
circumstances in which judicial bias was probable, due process required disqualification. The
Court noted, however, that disqualification rules may be and often are more rigorous than the
Due Process Clause requires. So it is with disqualification requirements for federal judges,
which require disqualification when a judge’s impartiality “might reasonably be questioned."
Disqualification Under 28 U.S.C. § 455
A. Overview
1. The text of § 455 The primary source of disqualification law in the federal judicial system is 28
U.S.C. § 455. It provides, in its entirety, as follows:
§ 455. Disqualification of justice, judge or magistrate judge
(a) Any justice, judge, or magistrate judge of the United States shall disqualify himself in any
proceeding in which his impartiality might reasonably be questioned.
(b) He shall also disqualify himself in the following circumstances:
(1) Where he has a personal bias or prejudice concerning a party, or
personal knowledge of disputed evidentiary facts concerning the proceeding;
(2) Where in private practice he served as lawyer in the matter in
controversy, or a lawyer with whom he previously practiced law served
during such association as a lawyer concerning the matter, or the judge or
such lawyer has been a material witness concerning it;
(3) Where he has served in governmental employment and in such
capacity participated as counsel, adviser or material witness concerning
the proceeding or expressed an opinion concerning the merits of the particular case in
controversy;
(4) He knows that he, individually or as a fiduciary, or his spouse or minor child residing in his
household, has a financial interest in the subject matter in controversy or in a party to the
proceeding, or any other interest that could be substantially affected by the outcome of the
proceeding;
(5) He or his spouse, or a person within the third degree of relationship to either of them, or the
spouse of such a person:
(i) Is a party to the proceeding, or an officer, director, or trustee
of a party;
(ii) Is acting as a lawyer in the proceeding;
(iii) Is known by the judge to have an interest that could be substantially affected by the outcome
of the proceeding;
(iv) Is to the judge’s knowledge likely to be a material witness in
the proceeding.
(c) A judge should inform himself about his personal and fiduciary financial interests, and make a
reasonable effort to inform himself about the personal financial interests of his spouse and minor children residing in his household.
10 Judicial Disqualification: An Analysis of Federal Law
(d) For the purposes of this section the following words or phrases
shall have the meaning indicated:
(1) “proceeding” includes pretrial, trial, appellate review, or other
stages of litigation;
(2) the degree of relationship is calculated according to the civil law
system;
(3) “fiduciary” includes such relationships as executor, administrator, trustee, and guardian;
(4) “financial interest” means ownership of a legal or equitable interest, however small, or a
relationship as director, adviser, or other active participant in the affairs of a party, except that:
(i) Ownership in a mutual or common investment fund that
holds securities is not a “financial interest” in such securities unless the
judge participates in the management of the fund;
(ii) An office in an educational, religious, charitable, fraternal, or civic organization is not a
“financial interest” in securities held by the organization;
(iii) The proprietary interest of a policyholder in a mutual insurance company, of a depositor in a
mutual savings association, or a similar proprietary interest, is a “financial interest” in the
organization only if the outcome of the proceeding could substantially affect the value of the
interest;
"“When Congress amended § 455(a), it made clear that judges should apply an objective
standard in determining whether to disqualify. A judge contemplating disqualification under §
455(a), then, should not ask whether he or she believes he or she is capable of impartially
presiding over the case. Rather, the question is whether a judge’s impartiality might be
questioned from the perspective of a reasonable person, and every circuit has adopted some
version of the “reasonable person” standard to answer this question.
In the context of denying a motion for his disqualification from Cheney v. United States District
Court for the District of Columbia, Justice Scalia noted that this reasonable person is aware “of
all the surrounding facts and circumstances.” The Second Circuit has characterized the
reasonable person as an “objective, disinterested observer” who is privy to full knowledge of the
surrounding circumstances.”
...
“The question has sometimes arisen as to whether the standard for disqualification differs in a
bench trial where the judge’s role is even more pivotal than in a jury trial. In Alexander v.
Primerica Holdings, Inc., the court of appeals said: “We cannot overlook the fact that this is a
non-jury case, and that [the judge] will be deciding each and every substantive issue at trial . . . .
When the judge is the actual trier of fact, the need to presserve the appearance of impartiality is
especially pronounced”
Plaintiff filed this legal action with no Jury Demand, Judge Gloria M. Navarro is the deciding the
issues of this case, this is, even more reason that Judge Gloria M. Navarro ensure I, Pro Se
Defendant / Pro Se Counter Plaintiff Crystal L. Cox of her non-bias, or conflict. Judge Gloria M.
Navarro has denied Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox this right and
should therefore be immediately Disqualified and all prior ruling disregarded, removed, null, void,
disqualified.
Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox intends to file a lien against Judge
Gloria M. Navarro’ bond, Per Nevada Statutes, Chapter 282, Official Bonds and Oaths, within the
next week, and to file a Writ of Mandamus with the Superior Court, the Nevada Supreme Court
and the Ninth District Court.
Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox intends to file also intend to file
complaints with the Attorney General, Department of Justice and the Judicial Council of the Ninth
Circuit COMPLAINT OF JUDICIAL MISCONDUCT"
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox believe Judge Gloria M. Navarro has
had private chamber meetings, phone calls, emails and communications with Plaintiff Attorney
Marc J. Randazza and his Acting attorney from his own Law Firm, Counter Defendant Ronald D.
Green, in which were not made known to opposing counsel, Pro Se Defendant / Pro Se Counter
Plaintiff Crystal L. Cox. Thereby directly discriminating against a Pro Se Litigant.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox believe that Plaintiff Attorney Marc J.
Randazza having his own law firm represent him in suing me, is a violation of my rights, and of
law, as Plaintiff Attorney Marc J. Randazza once represented me in a similar matter.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox believe that Plaintiff / Counter
Defendant Attorney Marc J. Randazza having designated Randazza Legal Group’s Ronald D.
Green as his acting attorney, to then contact witnesses directly and without notifying me,
opposing counsel, is a violation of law, ethics and due process.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox believe Judge Gloria M. Navarro
FAVORS Plaintiff / Counter Defendant Attorney Marc J. Randazza over Pro Se Defendant / Pro
Se Counter Plaintiff Crystal L. Cox because he is an attorney, and I, Pro Se Defendant / Pro Se
Counter Plaintiff Crystal L. Cox believe they have possible financial connections and conflicts
regarding other cases they have been involved with.
Plaintiff / Counter Defendant Attorney Marc J. Randazza has special privilege over Pro Se
Defendant / Pro Se Counter Plaintiff Crystal L. Cox under the law and the constitution, in this
court, with this Judge. And this is a violation of due process laws and of my constitutional rights.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox move this court to Disqualify Judge
Gloria M. Navarro from any RULINGS, Opinions, Official Judgement Regarding DISTRICT OF
NEVADA Case 2:12-cv-02040-GMN-PAL.
Ronald D. Green left a large law firm, Greenberg Traurig LLP around July of 2012. Greenberg
Traurig LLP is named in the iViewit SEC Complaint, iViewit RICO Complaint and massive legal
action relating to the iViewit Technology Theft.
Ronald D. Green was at Greenberg Traurig LLP and knows full well of the massive, undisclosed liability that Greenberg Traurig LLP has in regard to Eliot Bernstein and the iViewit Technology Company. This is a massive Conflict and Randazza Legal Group, Ronald D. Green should NOT be representing his boss, Plaintiff Marc Randazza in this matter.
Ronald D. Green, left Greenberg Traurig LLP for Randazza Legal Group, to intentionally,
deliberately be in a position to sabotage Eliot Bernstein and the Investigative Blogger reporting on
the iViewit Technology Story, Crystal L. Cox.
Upon my Knowledge and Belief, Ronald D. Green, formerly with Greenberg Traurig LLP was
sent to work at Randazza Legal Group by Greenberg Traurig LLP in order to sabotage Eliot
Bernstein. Greenberg Traurig LLP filed legal action against the estate of Eliot Bernsteins father in
September of 2012, just after Ronald D. Green left Greenberg Traurig LLP to work with
Randazza Legal Group, and a few months before Ronald D. Green sued Eliot Bernstein and
Crystal Cox. Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox has made this court,
Judge Gloria M. Navarro aware, and without admitting or denying conflict, Judge Gloria M.
Navarro violated the constitutional and lawful rights of Pro Se Defendant / Pro Se Counter
Plaintiff Crystal L. Cox.
Judge Gloria M. Navarro ruled on a Preliminary Injunction which allowed Plaintiff to wipe out
massive content, blogs, blog posts and links of Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox online media network.
Judge Gloria M. Navarro made this unlawful, unconstitutional ruling outside of due process and without First Amendment Adjudication.
Judge Gloria M. Navarro was preceded by Judge Brian Sandoval, who is now the Nevada
Governor. Brian Sandoval prior to being a federal judge, served as the Nevada Attorney General,
the youngest chairman of the Nevada Gaming Commission and was a state legislator.
This is an added conflict of interest in which Pro Se Defendant / Pro Se Counter Plaintiff Crystal
L. Cox believes created conflict in regarding to this case.
District of Nevada Case Case 2:12-cv-02040-GMN-PAL. involves massive conspirators, Trillions
of dollars of liability and thousands of victims, as connected to Eliot Bernstein. It is crucial to the
public at large that this case be ruled upon in an unpartial, unbiased, constitutional manner.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox belief that mafia ties, organized
crime are controlling factors in this case, and it is CRUCIAL to have an impartial judge.
The Eliot Bernstein iViewit case brings in over 5000 defendants, over a decade of conflict and brings
massive danger and financial liability. Plaintiff sued Eliot Bernstein iViewit founder and one of the
iViewit Inventors whom the Plaintiff’s clients owe 100’s of Billions of dollars to over a decade long
video technology infringement. Greenberg Traurig law firm is well aware of this as is Ronald D.
Green, formerly with Greenberg Traurig LLP, who came to Randazza Legal Group a few months
prior to suing Eliot Bernstein and the Investigative Journalists who is reporting on the iViewit
Technology story and has for over 3 years, me, Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox.
I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox move this court to
appoint a special investigator, a Federal Monitor to investigate the possible
corruption in this court.
Ronald D. Green, formerly of Greenberg Traurig should have admitted his conflict of interest in
suing Eliot Bernstein, in regard to Greenberg Traurig being named in Eliot Bernstein’s Federal
RICO Complaint, SEC Complaint and more.
Ronald D. Green, formerly of Greenberg Traurig worked as an IP attorney, and Eliot Bernstein
had once hired Greenberg Traurig as IP Counsel, Ronald D. Green should have, by law
disclosed this information.
Ronald D. Green, formerly of Greenberg Traurig should have notified this court that Greenberg
Traurig Law Firm is under investigation for Federal RICO Complaints, USPTO Complaints, and State, Federal and International Tribunals as one of the original conspirators in the iViewit
Technology theft.
As an IP Attorney at Greenberg Traurig, Ronald D. Green had no way NOT to know about the
iViewit Technology case.
Ronald D. Green, formerly of Greenberg Traurig should have notified this court that Greenberg
Traurig Law Firm is also representing the Florida Bar in the Eliot Bernstein RICO. Ronald D.
Green, should have disclosed this to the court. To conceal this from the court, seems to be in
conspiracy with Judge Gloria M. Navarro, as Pro Se Defendant / Pro Se Counter Plaintiff Crystal
L. Cox has made this court aware of the situation, and the material facts of this case and has
been denied equal protection under the law and the constitution, denied due process, and denied
protection from physical harm and massive duress.
Upon my knowledge and belief, Judge Gloria M. Navarro has massive conflicts of interest with
Randazza Legal Group and special interest in protecting the interests of Ronald D. Green, and
thereby Greenberg Traurig, and in protecting the interest of Marc J. Randazza, owner of
Randazza Legal Group and Plaintiff in District of Nevada Case Case 2:12-cv-02040-GMN-PAL.
Upon my knowledge and belief, Judge Gloria M. Navarro has enabled the Plaintiff, Counter
Defendants and Co-Conspirators to put me, Pro Se Defendant / Pro Se Counter Plaintiff Crystal
L. Cox in further harm and danger and to allow the continuing of Criminal Endangerment,
Criminal Defamation, Threats, Online Attacks, and violations of my constitutional and civil rights.
Judge Gloria M. Navarro was preceded by Judge Brian Sandoval, who is now the Nevada
Governor.
Prior to his service as a federal judge, he served as the Nevada Attorney General, the
youngest chairman of the Nevada Gaming Commission and a state legislator. I, Pro Se
Defendant / Counter Plaintiff Crystal L. Cox believe this causes further conflict.
District of Nevada Case Case 2:12-cv-02040-GMN-PAL involves massive conspirators, Trillions
of dollars of liability and I, Pro Se Defendant / Counter Plaintiff Crystal L. Cox have a right to an
unbiased, non-conflicted Judge to Rule in this matter
I, Pro Se Defendant / Counter Plaintiff Crystal L. Cox have a right to be treated equal under the
law and the constitution of the United States, regardless of my Pro Se Litigant Status in this
case.
I, Pro Se Defendant Crystal L. Cox request this State of Nevada Court Remove / Disqualify
Judge Gloria M. Navarro from Case 2:12-cv-02040-GMN-PAL . Judge Gloria M. Navarro has
undisclosed conflicts of Interest with Plaintiff Marc Randazza and with Counter Defendants and
Co-Conspirators.
I, Pro Se Defendant / Counter Plaintiff Crystal L. Cox request this State of Nevada Court
FORBID Judge Gloria M. Navarro from the DECISION making Process / Ruling on the matter of
Reclusing / Disqualifying herself from Case 2:12-cv-02040-GMN-PAL.
It is not Lawful for Judge Gloria M. Navarro to rule on whether or not to remove herself, and if this District of Nevada Court RULES that it is Lawful for Judge Gloria M. Navarro to rule on whether or not to remove herself from State of Nevada Case 2:12-cv-02040-GMN-PAL, then I, Pro Se Defendant Crystal L. Cox request the laws be stated to me that allow for this to be ruled upon.
Judge Gloria M. Navarro, is believed to have undisclosed, massive conflicts of interest and
criminal and civil conspiracy with Plaintiff Marc Randazza.
Judge Gloria M. Navarro has endangered the life of Defendant Crystal Cox and many of her “Sources”.
Judge Gloria M. Navarro has aided and abetted Plaintiff to ruin the business, online media, blog network, intellectual property and content of Defendant Crystal Cox and Defendant Eliot Bernstein.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc Randazza.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with
Plaintiff Marc Randazza to remove mass information from the Internet Search Engines regarding
the iVieiwt Technology story.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Godaddy,
Liberty Media Holdings Inc., Bob Garfield NPR, Kashmir Hill Forbes, Jordan Rushie Philly Law
Blog, David Carr New York Times, Kenneth P. White Popehate.com, Jason Jones
SaltyDroid.info, SiouxsieLaw.com, SequenceInc.com Tracy Coenen, and other John and Jane
Doe’s in an Online Hate, Defaming, Criminal Endangerment, Information Suppressing,
Whistleblower Retalitation Harassment Campaign.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc
Randazza to protect Viacom, Time Warner Inc., Encore, Stars, ATT, APPLE, Liberty Media
Holdings, Corbin Fisher, Manwin, MPEG LA, TCI Ventures Group LLC, ATT, Liberty Digital Inc.,
TCI Satellite Entertainment Inc, Discovery Channel, News Corporation, Netflix, QVC, MediaOne
Group, CBS, The Weinstein Company, Liberty Capital, Corbin Fisher, Liberty Global, Belgium's
Telenet Group Holding, Sirius Radio, Barnes and Noble, Discover Communications, Malone
Family Foundation, and other John and Jane Doe’s to supress, remove information from the
Internet, Public View regarding the stolen 13 Trillion Dollar iViewit Technology, Defendant Eliot Bernstein is the Founder of iViewit Technology and is one of the inventors of iViewit Technology.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc
Randazza, Randazza Legal Group, Ronald Green, Laura Tucker and Godaddy to steal
intellectual property of Defendant Crystal Cox and Eliot Bernstein with no due process.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc Randazza, Randazza Legal Group, Ron Green, Laura Tucker to remove thousands of blog
posts forever from the Internet Search Engines Regarding Whistle Blower about Plaintiff Marc
Randazza and Randazza Legal Group and the iViewit Technology Story.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc
Randazza to permanently alter the search engines and protect, aid and abet those involved in
the iViewit Technology theft and Technology Infringement.
Judge Gloria M. Navarro is believed to be acting in criminal and civil conspiracy with Plaintiff Marc
Randazza and with Rimon Law Group’s Lara Pearson who Plaintiff Marc Randazza had used in
Receivership issues regarding Righthaven, in which Judge Gloria M. Navarro ruled on and
enforce."
Source and Full Court Motion
Subscribe to:
Posts (Atom)