Nov 9, 2017

The tactics of the Gang Stalking attorneys who work with Marc Randazza and I allege some judges in the past are just as evil as what we are hearing about Harvey Weinstein and worse. Many of these targeted whistleblowers are harassed and shamed into suicide. Marc Randazza is NOT above the law nor is ANY attorney, Godaddy insider, Google insider, Court Clerk, or ANYONE else who helped Randazza to silence Victims.

Marc Randazza, Randazza Legal Group and their conspirators are CONSTANTLY active in suppressing Journalism.  They use their power and position as officers of the court to intimidate, threaten, bully, and shut down those who expose the Porn Industry secrets, expose human trafficking, EXPOSE predators, and EXPOSE the attorneys who protect them. 

Marc Randazza, Ron Green and Randazza Legal Group sidesteps the First Amendment and use any intimidation tactic available. Your hearing now of how Harvey Weinstein got a gang of investigators, lawyers, spies and more to silence and intimidate women. Randazza and his co-conspirators, I allege, do the same tactics to SILENCE journalists which is what investigative bloggers are. The BIG difference is they are OFFICERS OF THE COURT.

Randazza succeeds in removing mass content, getting huge judgments, getting bank records and phone records, alienating people by threatening to sue anyone who is connected to them or works with them and drives them into financial ruin, constant never ending fear and stress, and after years of that Randazza Legal Group WILL file in a court of law to make their VICTIM, their TARGET pay for their legal fees for attacking, harassing, tormenting, suing, defaming and ruining the Targets life. 

Just as the Weinstein case, we see large amounts of victims come out and tell the courts what officers of the court Randazza Legal Group and ALL connected attorneys are doing. And the courts have thus far protected these guys.

They actual file lawsuits against each others targets, they blog the conspired narrative in mass among many "credible" officers of the court aKa attorneys. These malicious "opinions" on blogs by officers of the court are not only deemed credible and true but they are used as actual EXHIBITS in a Court of Law as Unadjudicated yet VERY EFFECTIVE evidence against their target.

These Gang stalking Attorneys are believed over and over as their target is NOT believed, ruled against and their life is ruined. 

Check Out Jennifer Randazza and Marc Randazza suing me, Crystal Cox to shut down massive online content, steal domain names and redirect them to their commercial site, bully me, harass and threaten me. Read it all and learn how these attorneys do this.

Also research J. Devoy cases and cases that involve Judge Navarro and many unconstitutional TRO's. There are many cases out there where these guys sue a target, get the precedence they want, shut down content (Chill Speech) and get a Judgment in their favor to pay them HUGE legal fees for their fraud on the court, torturous interference, bullying, lying, threatening, HORRIFIC RETALITION.

Randazza v. Cox Docket
http://ia600304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

THESE GANG STALKING ATTORNEYS threaten, sue, bully, intimidate, stalk, blog hate in mass, drive by victims homes, publish victims home address, and have a constant campaign to keep them quiet WHATEVER IT TAKES.

Alexandra Mayers was sued by Jennifer Randazza, the wife of First Amendment PORN attorney Marc Randazza. Jennifer Randazza claimed Alexandra Mayers Defamed her "per se" and painted her in False Light.  This is SERIOUSLY Laughable, a Parody, a Joke. Oh wait its a REALLY BIG DEAL. As this EVIL woman, Jennifer Randazza seems to have convinced a seemingly rogue and corrupt court to actual rule in her favor. I wonder that that cost??? "per se"

J. Malcom DeVoy and Ronald Green of Randazza Legal Group represented Jennifer Randazza in this malicious UNCONSTITUTIONAL, Unlawful Lawsuit to silence and intimidate a journalist.

Alexandra Mayers / Monica Foster NEVER had an "unhealthy obsession" with Jennifer Randazza. Instead Alexandra Mayers dedicated her life to doing the right thing and reporting on the REAL "bad guys" such as Jennifer Randazza's husband and the thugs at his law firm Randazza Legal Group who were causing real harm to people.

Alexandra Mayers was reporting on them, exposing them and making fun of them as his her First Amendment Protected right. Jennifer Randazza is the one who had the VERY "unhealthy" obsession with Monica Foster / Alexandra Mayers . Why not ignore the name calling? I allege that Jennifer Randazza sued Alexandra Mayers as a PROXY for her husband and his gang stalking co-conspirators to suppress Alexandra Mayers speech, steal blogs and other intellectual property, and to intimidate and bully Alexandra Mayers .

Marc Randazza has a SERIOUS "unhealthy obsession" with any woman who DARES to make fun of him, call his wife a slut, expose his illegal behavior, report on porn industry criminal allegations and unethical behavior and most of all WOMEN WHO DARE TO STAND UP TO HIM.

When Jennifer Randazza Gets BUTTHURT she sues the Women who Stood up to her THUG of a Hubby
Check Out A-14-699072-C | Jennifer Randazza, Plaintiff(s) vs. Alexandra Mayers, Defendant AND see how to SHUT down the TRUTH and use the Judicial Process for REVENGE against someone who called you a slut and made "parody" of your high profile life that has NO RIGHT to Privacy as suggested in their legal cases as a matter of law.  See the link below for Federal Judge SHUT down of these allegations.

Yet somehow the Nevada State court went along with Jennifer Randazza???

Was Jennifer Randazza connected to Organized Crime or Pornography? Ummm geee Duh, all you have to do is look at Marc Randazza's blogs, or pool parties with predators they took their kids to as seen in this Arbitration.
https://drive.google.com/file/d/0Bzn2NurXrSkiMV9xcl9qeVdpSUU/view?usp=sharing

Jennifer Randazza and Marc Randazza I ALLEGE have Committed SERIOUS "INTENTIONAL MISCONDUCT" in Mass and have used the power of our legal system to do it.

A-14-699072-C | Jennifer Randazza, Plaintiff(s) vs. Alexandra Mayers, Clark County Nevada Rob Bare, Bonnie Bulla Case Docket Linked Below
https://drive.google.com/file/d/1MEASOxyMqeDK5KqTF8OhDScygbBi_PUe/view?usp=sharing

How in the World did Clark County Courts let Jennifer Randazza get away with these knowingly false pleadings and I allege perjury? Well who knows? I do know the TRUTH has a tendency to comet out. SO one day that too will surface from the "False Light" to the "True Light".

We all thought that Jennifer Randazza contacted Monica Foster / Alexandra Mayers and set up a meeting to discuss trying to get away from Marc Randazza. I FULLY believed that to be true, so did other followers of Monica's blogs. As someone claiming to be Jennifer Randazza contacted Monica Foster / Alexandra Mayers, that really happened.

Monica posted on her blog about the meeting, and yeah to Divorce Marc Randazza would be to leave #organisedcrime and #prostitution as that is the industry he works in as the RECORD everywhere CLEARLY shows. So to sue Jennifer Randazza contacted Monica Foster / Alexandra Mayers

Jennifer Randazza made false and SERIOUSLY HARMFUL statements about me Crystal Cox and did see in sworn to be true court filings. Flat out LIES, Defamation and False Light to a Federal Court about me, yet that's ok? Why? Because it is my life SHE ruined in suing me?


None of Jennifer Randazza's allegations are "highly offensible" to the "reasonable person" and even if poor baby Jennifer Randazza was offended SO WHAT. The Randazza's are the Face out there on the TV and in other mass media fighting for the right to OFFEND People.

Jennifer Randazza YOU DO NOT GET THE LUXURY OF BEING "OFFENDED" 

Again See The Court Order Below. Jennifer Randazza does not get to claim this shit, as a matter of LAW.  Summary Judgement DENIAL in Randazza c. Cox. Jennifer Randazza is NOT above the Law.
http://ia800304.us.archive.org/9/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf


I allege that Jennifer Randazza perjured herself in this case and I hope to soon file criminal charges myself as Jennifer Randazza is a very dangerous woman, using the power of our judicial system and her officer of the court husband to SHUT DOWN women who call her out, tell the truth about her and her husband and make fun of Jennifer Randazza.

Jennifer Randazza had such an Unhealthy Obsession with me, Crystal Cox, that she sued me for around 30 million and her husband and his law firm took my intellectual property in MASS to shut down my Speech about the RANDAZZAS.

These Free Speech hating Jackasses simply removed my blogs about princess Jennifer Randazza.  So we may never get to the bottom of this Slut thing or allegations of how Marc Randazza and Jennifer Randazza really met? Got a Tip?  ReverendCrystalCox@Gmail.com


We shall examine the Whole Is or Was Jennifer Randazza a Slut thing

Well Marc Randazza sure does describe what I allege is a SLUT, check it out
"we had a particularly spirited drunken tryst that day. Yep, some great scuba diving, some great mojitos with some of my best friends, a little whisper of “lets go take a nap,” in my ear, and a new life begins."
Source and Full Drunken Tryst
https://web.archive.org/web/20110303101527/http://randazza.wordpress.com/2008/03/22/the-most-amazing-news/

Oh and Check out Marc Randazza Defending Rush Limbaugh to call Sandra Fluke a SLUT, but We Dare not call Drunken Tryst get knocked up by a Porn Attorney clearly using no protection Jennifer Brochey Randazza a SLUT, how dare we

Check this out
http://unethicalscumattorney.blogspot.com/2014/12/marc-j-randazza-says-ms-mayers-got-sued.html

Oh and this one, at 1;15 into it is a discussion where going after another guys wife is a First Amendment RIGHT but not for Crystal Cox or Alexandra Mayers, NOPE Sue Them.

Check it out



And don't forget Joseph Rakofsky

Joseph Rakofsky explained in great detail what these guys were doing and that was years ago. Still our Courts let this behavior continued. I mean who is going to disbelieve a bunch of attorneys saying the same thing and even bloggging flat out lies about people that is then used by the other attorneys in court cases as UNADJUDICATED yet effective Evidence against their target.

Joseph Rakofsky AGAIN told the courts exactly what these attorneys were doing and the Courts simply ignored the victims and chose the bad guy attorneys. Meanwhile the litigant/victim is discredited in mass by their gang of attorneys, forensic accountants, journalists and judges.

Open Letter I wrote to Joseph Rakofsky
http://proofofcorruption.blogspot.com/2013/02/open-letter-to-joseph-rakofsky-from.html

JOSEPH RAKOFSKY, and RAKOFSKY LAW FIRM, P.C.,
                                                                                   INDE)( NO.: 105573/11
Plaintiffs,
-against

THE WASHINGTON POST, et aI.,
Defendants.

SUPREME COURT OF THE STATE OF NEW YORK PROTECTING THEM.

THESE GUYS REALLY DID GANG UP ON THIS GUY TO PROTECT THE LIES AND BAD, UNETHICAL BEHAVIOR OF ONE OF THEIR OWN.

A Few Research Links on  Rakofsky v. the Internet.

https://www.techdirt.com/articles/20130510/17292223040/judge-not-impressed-rakofsky-v-internet-dismisses-defamation-claims.shtml

https://www.techdirt.com/articles/20110524/23465814426/recent-law-school-grad-gets-berated-judge-then-sues-nearly-everyone-who-discussed-case.shtml

Joseph Rakofsky reported the Truth and experienced Judicial Retaliation in mass.

And there are many More. The Courts know and thus far have let these guys continue to use this same tactic in State and Federal Courts. I Allege over and over that all Marc Randazza, Ronald Green, J. Devoy and ALL the attorneys named in the cases above really are and have done this stuff and the courts NEED to stop letting them get away with it.

Some more Drunken Tryst Research
http://unethicalscumattorney.blogspot.com/search?q=tryst

Nov 2, 2017

Embattled copyright lawyer uses DMCA to remove article about himself. Marc Randazza has Abused our Justice System OVER and OVER to remove online content that did not "flatter him", exposed him or flat out criticized him.

"Marc Randazza tells Wordpress that the unflattering story "is not fair use.

Well-known copyright lawyer Marc Randazza used the Digital Millennium Copyright Act (DMCA) to delete an online article about a dispute between his former employer and himself.

Click Below to Read the FULL document, So many Lies. Marc Randazza is the world's most hypocritical lawyer and violates First Amendment Rights in mass. 
https://arstechnica.com/tech-policy/2016/02/embattled-copyright-lawyer-uses-dmca-to-remove-article-about-himself/

When I First Spoke to Marc Randazza he said that the Big Media had a Monopoly on Free Speech and there was Not Much I Could Do about it. Guess I Proved First Amendment Attorney Marc Randazza VERY Wrong.


Investigative Blogger Crystal Cox was the FIRST to gain Equal Free Speech Rights for ALL Bloggers to that of Institutional Press Journalists.

It was ruled for the first time that a blogger is entitled to the same free speech protection as a journalist.
On 2014, blogger Crystal Cox accused Obsidian and Kevin D. Padrick of corrupt and fraudulent conduct. Although the court dismissed most of Cox's blog posts as opinion, it found one post to be more factual in its assertions (and, therefore, defamatory).
It was ruled for the first time,[17][18] by the Court of Appeals for the Ninth Circuit,[19] that a blogger is entitled to the same free speech protection as a journalist and cannot be liable for defamation unless the blogger acted negligently.[20] In the decision, journalists and bloggers are equally protected under the First Amendment[17] because the "protections of the First Amendment do not turn on whether the defendant was a trained journalist, formally affiliated with traditional news entities, engaged in conflict-of-interest disclosure, went beyond just assembling others' writings, or tried to get both sides of a story."[19]:11–12[21]


I, Crystal Cox was the FIRST, because I refused Settlements over and over. I wanted a precedent to FREE all Citizen Journalists, Investigative Bloggers and Whistleblowers

#DefamationCase #FreeSpeech #ConstitutionalLaw #CrystalCoxCase #Whistleblower #InvestigativeBlogger #Ant-Slapp #CitizenJournalist #FirstAmendment #Defamation #DefamationLawsuit 


When I First Spoke to Marc Randazza he said that the Big Media had a Monopoly on Free Speech and there was Not Much I Could Do about it. Guess I Proved First Amendment Attorney Marc Randazza VERY Wrong.


Investigative Blogger Crystal Cox was the FIRST to gain Equal Free Speech Rights for ALL Bloggers to that of Institutional Press Journalists.

It was ruled for the first time that a blogger is entitled to the same free speech protection as a journalist.
On 2014, blogger Crystal Cox accused Obsidian and Kevin D. Padrick of corrupt and fraudulent conduct. Although the court dismissed most of Cox's blog posts as opinion, it found one post to be more factual in its assertions (and, therefore, defamatory).
It was ruled for the first time,[17][18] by the Court of Appeals for the Ninth Circuit,[19] that a blogger is entitled to the same free speech protection as a journalist and cannot be liable for defamation unless the blogger acted negligently.[20] In the decision, journalists and bloggers are equally protected under the First Amendment[17] because the "protections of the First Amendment do not turn on whether the defendant was a trained journalist, formally affiliated with traditional news entities, engaged in conflict-of-interest disclosure, went beyond just assembling others' writings, or tried to get both sides of a story."[19]:11–12[21]


I, Crystal Cox was the FIRST, because I refused Settlements over and over. I wanted a precedent to FREE all Citizen Journalists, Investigative Bloggers and Whistleblowers

#DefamationCase #FreeSpeech #ConstitutionalLaw #CrystalCoxCase #Whistleblower #InvestigativeBlogger #Ant-Slapp #CitizenJournalist #FirstAmendment #Defamation #DefamationLawsuit 


Nov 1, 2017

Hypocritcal Attorney Marc Randazza of Randazza Legal Group seems to be a but Slippery Under Oath or perhaps has even purjured himself yet again. Marc Randazza Bankruptcy filing as he relentless attacks blogger Crystal Cox, sure seems to be perjury to me.


In Marc Randazza’s Recent Filing, Motion for Default, Case 16-01111-abl Doc 26 Entered 10/20/17, he claims that ONLY upon Volokh being interested in teaming up with him was he then “willing to accept the case”. Meaning the Crystal Cox Ninth Circuit Appeal. Yet Crystal Cox claims Randazza represented her before this and told others he was her attorney. Randazza states in earlies sworn documents a different version of his story, let’s take a look.

Page 38, Line 26-28 and Page 39 1-4, Case 16-01111-abl Doc 26, (Randazza Decl. ¶ 26) Says:Only upon Mr. Volokh expressing an interest in teaming up on the case with him did Mr. Randazza decide that he was willing to accept the case. (Randazza Decl. ¶ 26).”

In this sworn statement (Randazza Decl. ¶ 26) Randazza claims he was only interested in representing me, Crystal Cox, with Volokh and only offered to represent me after this conversation. Even though, the only reason Volokh was talking to Randazza about me, Crystal Cox was Randazza told Volokh he represented Crystal Cox. And that he was brokering a deal with the Opposition in the Obsidian case, David Aman.

The statement is false, and it is making a false declaration to a Federal Court while knowing full well it is False as Randazza swore to different facts in Case 2:12-cv-02040-JAD-PAL Document 252 Filed 04/06/15,  Exhibit 9, Marc Randazza’s sworn interrogatory answers.

So in Case 16-01111-abl Doc 26, Page 38, Line 26-28 and Page 39 1-4, we see RANDAZZA swearing that he ONLY agreed to Represent Cox after Volokh expressed interest to team up with him.   We see below in a previous Sworn statement of Randazza that he was involved in representation BEFORE speaking with Volokh, talking strategy with Volokh, and only spoke with Volokh after he had already put in time and material into representation.



Interrogatory 21 Exhibit 9:

“Did you have phone conversations with Eugene Volokh and state that you represented Cox and discuss with him your strategy, or a deal you were trying to make with the opposition, Plaintiff’s attorney David Aman?”
Randazza’s Sworn RESPONSE TO INTERROGATORY NO. 21:

"... Counterdefendant responds as follows:

Counterdefendant spoke with Eugene Volokh in December 2011.

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

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

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

What gave Marc Randazza a legal right to negotiate who gets to be my attorney with him, if he was not indeed my attorney, or acting as if he was my attorney?

Randazza and Volokh discussed strategy? About Me? They discussed that a settlement was in my, Crystal Cox’s, best interest?

A couple of guys deciding what was in my best interest and Randazza proceeding with steps to negotiate what was in my best interest when Randazza clearly and plainly knew that I want to appeal. I did NOT want to settle nor did I want some aggressive, asshole man to decide it would be better if I settled and push me to do what I did want to do, negotiate behind my back, and trick and deceive me by letting the deadline run out while he held himself out as my attorney so no one else would represent me, thereby blocking me from appealing. He did not know I had talked to Volokh when he tried to pull off this malicious scheme.
In Conclusion,

Page 38, Number 1-13 of Interrogatory 21 Exhibit 9, Case 2:12-cv-02040-JAD-PAL Document 252 Filed 04/06/15 is Marc J. Randazza’s SWORN statement that the Interrogatory Answers are true to the best of his knowledge, yet we see on Page 38, Line 26-28 and Page 39 1-4, Case 16-01111-abl Doc 26, (Randazza Decl. ¶ 26) that Marc Randazza swears to the a VERY different Answer.


“I declare under penalty of perjury that the foregoing is true and correct.
Dated: October 20, 2017.

/s/ Marc J. Randazza
MARC J. RANDAZZA, ESQ.”

So How Can Both be True under penalty of perjury?

Marc Randazza held himself out as my attorney, he bullied me to STOP me from appealing for his own gain, he ran over my rights and when I FIRED Marc Randazza of Randazza Legal Group, he sued me, threatened me, attacked me, launched a 5 year and counting malicious cyber attack and still seems to by lying about all to Federal Courts. Take a Look


In Marc Randazza’s Recent Filing, Motion for Default, Case 16-01111-abl Doc 26 Entered 10/20/17, he claims that ONLY upon Volokh being interested in teaming up with him was he then “willing to accept the case”. Meaning the Crystal Cox Ninth Circuit Appeal. Yet Crystal Cox claims Randazza represented her before this and told others he was her attorney. Randazza states in earlies sworn documents a different version of his story, let’s take a look.

Page 38, Line 26-28 and Page 39 1-4, Case 16-01111-abl Doc 26, (Randazza Decl. ¶ 26) Says:Only upon Mr. Volokh expressing an interest in teaming up on the case with him did Mr. Randazza decide that he was willing to accept the case. (Randazza Decl. ¶ 26).”

In this sworn statement (Randazza Decl. ¶ 26) Randazza claims he was only interested in representing me, Crystal Cox, with Volokh and only offered to represent me after this conversation. Even though, the only reason Volokh was talking to Randazza about me, Crystal Cox was Randazza told Volokh he represented Crystal Cox. And that he was brokering a deal with the Opposition in the Obsidian case, David Aman.

The statement is false, and it is making a false declaration to a Federal Court while knowing full well it is False as Randazza swore to different facts in Case 2:12-cv-02040-JAD-PAL Document 252 Filed 04/06/15,  Exhibit 9, Marc Randazza’s sworn interrogatory answers.

So in Case 16-01111-abl Doc 26, Page 38, Line 26-28 and Page 39 1-4, we see RANDAZZA swearing that he ONLY agreed to Represent Cox after Volokh expressed interest to team up with him.   We see below in a previous Sworn statement of Randazza that he was involved in representation BEFORE speaking with Volokh, talking strategy with Volokh, and only spoke with Volokh after he had already put in time and material into representation.



Interrogatory 21 Exhibit 9:

“Did you have phone conversations with Eugene Volokh and state that you represented Cox and discuss with him your strategy, or a deal you were trying to make with the opposition, Plaintiff’s attorney David Aman?”
Randazza’s Sworn RESPONSE TO INTERROGATORY NO. 21:

"... Counterdefendant responds as follows:

Counterdefendant spoke with Eugene Volokh in December 2011.

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

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

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

What gave Marc Randazza a legal right to negotiate who gets to be my attorney with him, if he was not indeed my attorney, or acting as if he was my attorney?

Randazza and Volokh discussed strategy? About Me? They discussed that a settlement was in my, Crystal Cox’s, best interest?

A couple of guys deciding what was in my best interest and Randazza proceeding with steps to negotiate what was in my best interest when Randazza clearly and plainly knew that I want to appeal. I did NOT want to settle nor did I want some aggressive, asshole man to decide it would be better if I settled and push me to do what I did want to do, negotiate behind my back, and trick and deceive me by letting the deadline run out while he held himself out as my attorney so no one else would represent me, thereby blocking me from appealing. He did not know I had talked to Volokh when he tried to pull off this malicious scheme.
In Conclusion,

Page 38, Number 1-13 of Interrogatory 21 Exhibit 9, Case 2:12-cv-02040-JAD-PAL Document 252 Filed 04/06/15 is Marc J. Randazza’s SWORN statement that the Interrogatory Answers are true to the best of his knowledge, yet we see on Page 38, Line 26-28 and Page 39 1-4, Case 16-01111-abl Doc 26, (Randazza Decl. ¶ 26) that Marc Randazza swears to the a VERY different Answer.


“I declare under penalty of perjury that the foregoing is true and correct.
Dated: October 20, 2017.

/s/ Marc J. Randazza
MARC J. RANDAZZA, ESQ.”

So How Can Both be True under penalty of perjury?

Oct 29, 2017

In Randazza v. Cox, Nevada Judge Gloria Navarro issued an unconstitutional TRO against Blogger Crystal Cox and Gave Marc Randazza massive online content and intellectual property. Thereby shutting down Cox's speech and flat out stealing blogs, online content and redirecting MY WORK and PROPERTY to Randazza's Legal Blog SLAMMING me and Promoting him and his law firm. In that Case it was OK and seemingly Lawful for a Federal Judge to go ahead and take my Constitutional Rights. Check Out this case below where WORLDS Most Hypocritical Lawyer Marc Randazza Makes the OPPOSITE CASE AGAIN.

"In the motion to dissolve the order, attorney Marc Randazza points out that fashioning a libel lawsuit as a tortious interference lawsuit doesn't change the ultimate goal of the litigation: to silence criticism."


"Judge Decides Free Speech Is Still A Right; 
Dumps Prior Restraint Order Against Mattress Review Site

A couple of weeks ago, a federal judge in Utah decided prior restraint was the best way to handle a recently-filed defamation suit against Honest Mattress Reviews by Purple Innovations, makers of the Purple Mattress.
Purple's lengthy filing contained numerous allegations of harm caused by Honest Mattress Reviews' extended commentary on the white plastic powder covering every mattress Purple ships. It also alleged HMR was just a front for site owner Ryan Monahan's brand management work with Purple's competitor, Ghostbed. Rather than give HMR a chance to respond, the judge decided the review site could publish nothing further about Purple or the lawsuit. It wasn't even allowed to refer to its previous rating of Purple's mattress.
Honest Mattress Review didn't care much for this decision -- one it had been given no chance to contest. It immediately posted an article about the case and offered to comply with the letter of the order, but perhaps not its spirit.
This temporary order commands that we take down all reviews, and even cease rating this company with a rating of “Poor.” Yes, indeed, we are no longer even permitted to rate this company as Poor. I guess we will change its rating to “💩.”
[...]
Do you trust a company that, rather than compete in the marketplace, decides that it will just try and sue negative reviews out of existence?
Purple Innovations immediately returned to court, demanding it find HMR in contempt of its order, in particular pointing to the poo emoji and HMR's claims about the unconstitutionality of the order and Purple's alleged disingenuousness in filing the libel suit.
That review has since been reinstated and given this header image.
And HMR has published a long list of court documents it has filed in this case. This includes a motion to dissolve the restraining order and a preliminary examination of the powdery substance Purple claims is harmless and that HMR claims could be hazardous to purchasers' health.
The action is a quintessential SLAPP suit designed to suppress negative consumer journalism. Plaintiffs have cleverly attempted to disguise this defamation claim as a Lanham Act claim – presumably to ensure the availability of Federal Court jurisdiction and to try to side-step the clear case law that cuts against them in defamation actions. But, no matter how eloquently someone may call a “dog” a “chicken,” it will never lay eggs. And styling a specious defamation claim as a Lanham Act claim does not remove the underlying speech from the protections afforded by the First Amendment.
He also points out that Purple's claims that the plastic packing dust is harmless haven't been supported by anything Purple's willing to let customers and competitors view. Instead, it's only made vague assertions about its safety. And those statements are ultimately meaningless when examined closely.
Plaintiff sells mattresses that are made of a rubber honeycomb, which they then dust with a powder that they claim is made of plastic and has been shown to be polyethylene microspheres. In other words, someone who sleeps on these mattresses would be expected to inhale these microspheres. The Plaintiff claims that it is “non toxic” and “food grade” plastic – but this does not assuage the concerns. After all, a plastic fork is “food grade” and “non toxic” but you most certainly would not want to actually eat it. The same goes for what a person wants to put in their lungs. It was reasonable to be concerned about this “plastic powder” since (a) if the particles that make up this plastic “powder” are of a certain size, they will pass through the alveoli into the bloodstream; or (b) if they are a bit larger, they will simply lodge themselves inside the lungs.
To support its claims, HMR put a Harvard Professor of Pathology to work. Dr. John Godleski's report[PDF] is far from complete at this point, but what's contained in his preliminary examination of the powder doesn't appear to agree with Purple's assertions of harmlessness.
By Fourier Transformed Infrared spectroscopy (FTIR), the white powder particles were shown to be polyethylene, and the purple frame was found to be polyethylene-polypropylene copolymer. The foam portion of the mattress is still understudy, but has characteristics of butadiene, and may be a form of butadiene polymer.
Polyethylene is a common plastic formed into many structures. As inhalable microspheres, these have the potential to cause respiratory irritation especially when inhaled in large numbers as shown in my laboratory (1- 4). In addition, polyethylene has been associated with allergy in the form of either asthma or contact dermatitis in sensitized individuals (5-7). Based on this assessment, it is important for consumers to be aware of the composition of this fine particulate matter in the mattress which may be released into the air and has the potential for the development of respiratory or dermal hypersensitivity in some individuals.
Also included in the filed documents is an affidavit that undercuts Purple's claims about HMR's site owner being a competitor's "brand manager." This is central to Purple's Lanham Act claims -- the claims it's using to sidestep anti-SLAPP motions. The affidavit from the competitor (Ghostbed) notes HMR's site owner has never been directly employed by Ghostbed and that Ghostbed told him to stop referring to himself as its "brand manager" after noticing that statement on his Twitter profile.
The judge presiding over the case appears to have been overwhelmed by the pile of documents landing on his desk. A short order [PDF] issued on the 15th shows what can happen when a normally adversarial process is allowed to be, you know, adversarial.
For the reasons set forth in the parties’ briefing and at oral argument, the court finds a lack of “clear and unequivocal” support for a right to relief that is necessary for the entry of the “extraordinary remedy” of a preliminary injunction. Greater Yellowstone Coal v. Flowers, 321 F.3d 1250, 1256 (10th Cir. 2003). As such, the court hereby grants Defendants’ motions to dissolve the Temporary Restraining Order (Dkt. No. 36), and denies Plaintiff’s oral Motion to convert the Temporary Restraining Order into a Preliminary Injunction. The court similarly denies Plaintiff’s Motion for Leave to Conduct Expedited Discovery (Dkt. No. 39) and Motion for Order to Show Cause Why Defendants Should not be Held in Contempt (Dkt. No. 17). The court further denies Defendants’ request for sanctions, finding that such sanctions are not warranted here.
The restraining order is lifted and HMR's turd-laced post isn't in danger of being found contemptuous. The lawsuit should continue in a more constitutional fashion from this point forward.

Source

"Conclusion and Relief Sought
Because Defendants are likely to succeed on a motion to vacate the TRO, before this Court or on appeal, a stay of the TRO is warranted. Defendants’ fundamental First Amendment rights must not be stymied by the speculations of a Plaintiff who wishes to shut down discussion rather than answer legitimate questions, no matter how hyperbolically raised. Plaintiff has no likelihood of success on its underlying claims and was not entitled to the TRO.

Case 2:17-cv-00138-DB Document 28 Filed 03/09/17 Page 23 of 25
- 24 -
The exigency and urgency of dissolving this temporary restraining order can not be
overstated. Even a temporary suppression of First Amendment rights is itself irreparable harm.
However, given that this is information consumers need to make an informed decision about the health risks inherent in use of the Purple Mattress, even a temporary suppression of this information could be the proximate cause of actual illness or injury."

" Plaintiff is clearly aggressively intent on suppressing this information. At this point, the reporting has been shored up by the expert report of Dr. Godleski. The Purple Mattress, as currently manufactured, appears to be a public health hazard. This Court should abide no further censorship. "

Source of Above and Full Hypocritical Filing

Judge Grants Randazza's Order. To bad I did not have this judge when Randazza got a TRO against me in Randazza v. Cox

"Before the court are Plaintiff’s Motion for Order to Show Cause Why Defendants Should
not be Held in Contempt (Dkt. No. 17), Defendants Ryan Monahan and Honest Reviews, LLC’s
Emergency Motion to Stay and Dissolve Temporary Restraining Order (Amended) (Dkt. No. 28), Defendant Ghostbed Inc.’s Motion to Dissolve the Temporary Restraining Order (Dkt. No. 36),

"For the reasons set forth in the parties’ briefing and at oral argument, the court finds a
lack of “clear and unequivocal” support for a right to relief that is necessary for the entry of the “extraordinary remedy” of a preliminary injunction. Greater Yellowstone Coal v. Flowers, 321 F.3d 1250, 1256 (10th Cir. 2003). As such, the court hereby grants Defendants’ motions to dissolve the Temporary Restraining Order (Dkt. No. 36), and denies Plaintiff’s oral Motion to convert the Temporary Restraining Order into a Preliminary Injunction. "

"For the foregoing reasons, and for those expressed in the parties’ briefing and oral
arguments, Docket Numbers 17 and 39, as well as Plaintiff’s oral Motion to convert the
Temporary Restraining Order into a Preliminary Injunction, are hereby DENIED. Docket
Number 28 and the portion of Docket Number 36 requesting dissolution of the Temporary
Restraining Order are GRANTED. Defendants’ request for sanctions is DENIED."

Source of Above and Full Judicial Order

Check out Randazza v. Cox Docket and See how to REALLY use prior restraint to suppress speech and flat out steal online content AND top search engine placement. 

Lot's More Coming SOON on how to us a TRO effectively to Steal Content, Steal Search Engine Placement, Steal Intellectual Property and More. As inspired by Randazza Legal Group, Marc Randazza, J. DeVoy and Ronald Green. 

Questions or Tips??? eMail me at ReverendCrystalCox@Gmail.com

#MarcRandazza #RandazzaQuotes #RandazzaLegalGroup #FreeSpeech 

Oct 26, 2017

Marc J. Randazza, Randazza Legal Group Tactics Used by Attorneys to Bully and Harass Litigants by Blogger Crystal Cox

#MarcRandazza #RandazzaLegalGroup #JudicialRetaliation #GangStalkingAttorneys

  

Have a Marc Randazza Tip? eMail me at ReverendCrystalCox@Gmail.com 

Oct 25, 2017

Marc Randazza Bankruptcy Challenges by Liberty Media

Marc Randazza Bankruptcy and Liberty Media

"In the meantime, Randazza's old employer, Liberty Media, is challenging his Nevada court filing seeking Chapter 11 bankruptcy protection. In that filing, Randazza claimed assets of up to $10 million, and liabilities of up to $50 million. Randazza included in his liabilities a potential $10 million judgement against him in a lawsuit with a blogger, Crystal Cox of Washington; $1 million to Liberty; as well as another $1 million judgement against him in a lawsuit he's embroiled in with Roca Labs of Largo, Florida."

Source and More
http://1701news.com/node/1183/so-who-klingon-lawyer-marc-randazza.html

Liberty Media Opposition Motion (Doc. 38)
"In an effort to avoid payment of the entire monetary component of the IAA, and before the
IAA could be confirmed by the state court, Debtor, by and through its counsel L&Z, initiated
settlement negotiations with E/L. During these negotiations, Debtor consistently used the threat of
a bankruptcy petition in an attempt to negotiate a sum of payment significantly reduced from that
awarded to E/L in the IAA. Not only did Debtor use the threat of bankruptcy as a cudgel, but he andhis allegedly estranged wife have initiated sealed divorce proceedings, and dissipated assets."

"Debtor attempted delay for two reasons: (1) in a misguided effort to stay the award of attorneys fees by the Arbitrator, as well as the confirmation of the IAA by the state court; and (2) to push the date of petition out more than 90 days, so that Debtor’s fraudulent, improper, and preferential transfers could not be clawed back, including payments to his attorneys L&Z.

According to Debtor’s schedules filed on September 11, 2015, Debtor has deposited with
L&Z sums totaling $94,000. [ECF 15] On September 22, 2015, L&Z filed the instant Application
to Employ and Retain Larson & Zirzow, LLC as Attorneys for the Debtor Nunc Pro Tunc to the
Petition Date."

"According to the retainer agreements and statements made therein, L&Z entered into
representation of Debtor as of June 11, 2015 for “pre-bankruptcy settlement negotiations and to
attend a settlement conference. The Debtor paid L&Z a flat fee of $10,000.00 for this engagement.”

"L&Z also purports to have been retained, via two separate retainer agreements, for representation in both a bankruptcy action, and a potential adversary proceeding."

"the second was for potential nondischargeability litigation. "

"L&Z’s Application is deficient as it relates to exactly what the scope of services are that it
has billed for as of yet. In fact, L&Z only informs as to the fact that it has received a total sum of
$94,000 for legal services in connection with Debtor’s Chapter 11 case. “Of this sum, L&Z billed
and was paid the sum of $26,908.82 prior to the Petition Date, and L&Z currently holds in trust the
remainder sum of $67,091.18 (the “Remaining Retainer”) a portion of which has been allocated
pursuant to the Representation Agreements for potential adversary proceedings.” [ECF 18 at ¶16 (emphasis added)] This Application utterly fails to identify and delineate what services were
provided totaling $26,908.82."

"In any event, all transfers were made within 90 days of the filing of Debtor’s Petition. As
such, the “pre-bankruptcy” retainer fees charged and collected by L&Z constitute an avoidable
preferential transfer, and the funds must be clawed back to the estate. As a result, L&Z will lose
their status as “disinterested parties” and are therefore not qualified to serve as attorneys for the
Debtor.

II. L&Z’S APPLICATION IS INSUFFICIENT TO SATISFY THE TEST FOR
APPROVAL OF HIRING OF PROFESSIONALS.

L&Z’s employment as attorneys for the debtor in possession in a Chapter 11 case is
governed by § 327(a) of the Bankruptcy Code, which requires court approval for the attorney's
employment. The bankruptcy court is charged with “ensur[ing] that attorneys who represent the
debtor do so in the best interests of the bankruptcy estate.” In re Park–Helena Corp., 63 F.3d 877,
880 (9th Cir.1995). Under § 327, an attorney for a debtor cannot “hold or represent an interest
adverse to the estate”; he or she must be a “disinterested person.” 11 U.S.C. § 327(a).

Any creditor of the estate, or anyone with “an interest materially adverse to the interest of the estate ... by reason  of any direct or indirect relationship to, connection with, or interest in, the debtor,” is not a disinterested person. 11 U.S.C. §§ 101(14)(A), (C). A “creditor” includes any “entity that has a
claim against the debtor that arose at the time of or before the order for relief concerning the
debtor.” § 101(10)(A). A “claim” includes any “right to payment.” § 101(5)(A).
To enable the Bankruptcy Court to evaluate an attorney's potential employment, Rule
2014(a) requires that an application for employment of an attorney under § 327 “shall be
accompanied by a verified statement of the person to be employed setting forth the person's
connections with the debtor, creditors, any other party in interest, their respective attorneys and
accountants, the United States trustee, or any person employed in the office of the United States
trustee.” Fed. R. Bankr.P. 2014(a). This disclosure requirement is applied “strictly.” Park–Helena,
63 F.3d at 881.

An attorney approved for employment under § 327 must apply for interim or final
compensation, which is subject to approval of the Bankruptcy Court. 11 U.S.C. §§ 328–31; see also
In re Chapel Gate Apartments, Ltd., 64 B.R. 569, 575 (Bankr.N.D.Tex.1986) (noting that “fees in
bankruptcy cases ... are subject to review, modification, and outright cancellation by the Court”).
Rule 2016(a) requires an attorney seeking compensation and/or reimbursement of expenses to file
an application “setting forth a detailed statement of (1) the services rendered, time expended and
expenses incurred, and (2) the amounts requested.”

The fee application must also include, inter alia, “a statement as to what payments have theretofore been made or promised to the applicant for services rendered or to be rendered in any capacity whatsoever in connection with the case, [and] the source of the compensation so paid or promised.” Id. After notice and a hearing, the court may award “reasonable compensation for actual, necessary services rendered,” as well as “reimbursement for actual, necessary expenses.” §330(a)(1)."

Source and Full Filing
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.38.0.pdf


Liberty Media Move for Order to Modify Stay
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.0.pdf

Doc. 60-2 to above Motion
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.2.pdf

Motion to Confirm Arbitration Award Exhibit - 60-6
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.60.6.pdf

Liberty Media Reply
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.80.0.pdf

COMPLAINT by Liberty Media and Others to Determine Non-Dischargeable Debt
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.83.0.pdf

Doc. 120 filed by Liberty Media, First Amended Complaint, Demand for Jury Trial
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.120.0.pdf

Marc Randazza Bankruptcy Case Docket
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.docket.html


Doc. 148 Settlement
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.148.0.pdf
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.157.0.pdf

EX PARTE APPLICATION FOR ORDER DIRECTING EXAMINATION
PURSUANT TO FED.R.BANKR.P.2004 OF MARC J. RANDAZZA
Doc. 187

"Creditors Excelsior Media Corp. (“Excelsior”) and Liberty Media Holdings, LLC
(“Liberty” and together with Excelsior, “Creditors”), by and through their counsel, James D.
Greene, Esq. of Greene Infuso, LLP pursuant to section 105 of the Bankruptcy Code and Rule
2004 of the Federal Rules of Bankruptcy Procedure and Rule 2004 of the Local Rules of
Bankruptcy Practice and Procedure, hereby apply to the Court for entry of order directing Debtor
Marc J. Randazza (“Debtor”) to appear for and submit to examination under oath before certified court reporter at the office of Greene Infuso, LLP, 3030 South Jones Blvd. Suite 101, Las Vegas, Nevada 89146 on a date and time to be determined, providing that notice of said examination is to be provided no less than 10 judicial days before such examination date. In support of this
application (“Application”), Creditors state as follows:

LEGAL ARGUMENT

An examination pursuant to Bankruptcy Rule 2004 can be ordered [o]n motion of any
party in interest.” In re Stasz, 387 B.R. 271, 273 n.3 (B.A.P. 9th Cir. 2008); see also In re Lifeco
Inv. Grp., Inc., 173 B.R. 478, 480 (Bankr. D. Del 1994), quoting Fed. R. Bankr. P. 2004(a).
Bankruptcy Rule 2004 further provides that the Court may order the examination and the
production of documentary evidence concerning any matter that relates “to the liabilities and
financial condition of the debtor, or to any matter which may affect the administration of the
debtor’s estate, or… any other matter relevant to the case or tot the formulation of a plan.” Fed.
R. Bankr. P. 2004(b); see also In re Dinubilo, 177 B.R. 932, 936 n.6 (E.D. Cal. 1993) (noting that
“[u]nder Rule 2004, a court may order the examination of any person on motion of any party in
interest.”). 

Generally, examinations under Bankruptcy Rule 2004 are for the “purpose of
discovering assets and unearthing frauds.” In re Rafsky, 300 B.R. 152, 153 n.2 (Bankr. D. Conn.
2003) (citation omitted); In re N. Plaza LLC, 395 B.R. 113, 122 n.9 (S.D. Cal. 2008).
The scope of a Bankruptcy Rule 2004 examination is “unfettered and broad,” as the plain
language of the rule indicates. See 9 Collier on Bankruptcy ¶ 2004.02[1] at 2004-6 (15th ed. Rev.
1997); In re Dinublilo, 177 B. R. at 939 quoting In re GHR Energy Corp., 33 B.R. 451, 453
(Bankr. D. Mass. 1983). 

The broad latitude of Bankruptcy Rule 2004 examination furthers the purpose of the rule, which is “to allow the court to gain a clear picture of the condition and the whereabouts of the bankrupt’s estate. In re Int’l Fibercom, Inc., 283 B.R. 290, 292 (Bankr. D. Ariz. 2002) (permitted Bankruptcy Rule 2004 examination aimed at “obtaining information that will … potentially uncover additional claims that may exist for the benefit of the estate”); see also In re W & S Investments, Inc., 985 F.2d 577 (9th Cir. 1993) (“Bankruptcy Rule 2004 is a broadly construed discovery device…”); In re French, 145 B. R 991, 992 (Bankr. D.S.D. 1992) (“Bankruptcy Rule 2004… does not offer the procedural safeguards available under Rule 26 of the Federal Rule Rules of Civil Procedure.”)."

"The information and documents which Creditors seek through this Application relate to
matters that are clearly with the permitted scope of Rule 2004, including: (i) property of the
Debtor’s bankruptcy estate; (ii) transactions and business dealings involving the Debtor and
family members and corporate entities; (iii) potential claims the Creditor may have against third
parties; and (iv) other matters affecting the administration of the Debtor’s estate."

Source and Full Document

Above Order Granted
http://ia800807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.188.0.pdf


Doc. 191 Liberty Media SUPPLEMENTAL BRIEF IN SUPPORT
OF MOTION FOR ORDER CONFIRMING INTERIMARBITRATION AWARD
http://ia600807.us.archive.org/26/items/gov.uscourts.nvb.348854/gov.uscourts.nvb.348854.191.0.pdf


CAN YOU SAY PATTERN AND HISTORY ???