Thursday, February 21, 2013
Pro Se Blogger Crystal L. Cox Files Motion to Sanction Attorneys involved in District of Nevada Case 2:12-cv-02040-GMN-PAL. Also a Few Exhibits, and Updated Court Docket in Nevada SLAPP Suit, Free Speech Threat District of Nevada Case 2:12-cv-02040-GMN-PAL.
District of Nevada Case 2:12-cv-02040-GMN-PAL Motion to Sanction
http://www.docstoc.com/docs/146400818/Pro-Se-Blogger-Crystal-L-Cox-Files-Motion-to-Sanction-Attorneys-involved-in-District-of-Nevada-Case-212-cv-02040-GMN-PAL
Reply to Response / Opposition to Motion to Sanction Attorneys filed by Pro Se Litigant Crystal L. Cox in District of Nevada Case 2:12-cv-02040-GMN-PAL
http://www.docstoc.com/docs/146399958/Reply-to-Plaintiffs-Opposition-to-Motion-to-Sanction-Plaintiff
District of Nevada Case 2:12-cv-02040-GMN-PAL Plaintiff eMails Witness Stephanie DeYoung, Acting as his Own Attorney, and Probes into Crystal Cox's Personal and Financial Life, and Accuses Defendant / Counter Plaintiff Cox of "Lying"
http://www.docstoc.com/docs/146399933/Exhibits-Motion-to-Sanction-Plaintiff--Attorney-District-of-Nevada-Case-212-cv-02040-GMN-PAL
Exhibit Plaintiff Marc J. Randazza eMails Witness Stephanie DeYoung to Schedule Deposition, Acting as his Own Attorney, Same Day his Attorney Ronald D. Green Files Summary Judgment Against Pro Se Litigant Crystal L. Cox
http://www.docstoc.com/docs/146399942/Exhibits-Motion-to-Sanction-Plaintiff--Attorney-District-of-Nevada-Case-212-cv-02040-GMN-PAL
District of Nevada Case 2:12-cv-02040-GMN-PAL Exhibit Plaintiff Refuses to Remove Inaccurate information from his Blog, though Author of Information, Stephanie DeYoung Requested a Retraction nearly a Year Ago
http://www.docstoc.com/docs/146399962/Stephanie-Deyoung-Randazza-Emails
Nevada Court Docket as of February 21st 2013
http://www.docstoc.com/docs/146399949/District-of-Nevada-Case-212-cv-02040-GMN-PAL-Court-Docket-as-of-February-21st-2013
Coming Up, Writ of Mandamus to Nevada Supreme Court, Bar Complaints, Criminal Complaints and more, as a Public Service, in hopes this does not happen to any more victims of an unjust, unconstitutional, unlawful, discriminating court process in the District of Nevada Courts.
Monday, February 18, 2013
District of Nevada Case 2:12-cv-02040-GMN-PAL; Nevada SLAPP Lawsuit, Nevada Retaliation Lawsuit, Chilling Effect Lawsuit, First Amendment Threat Lawsuit, Freedom of Expression Suppression Lawsuit. Transparency and Accountability DEMANDED in the Courts. Equality of Law and the First Amended DEMANDED.
Judicial Rulings, Order by Judge Gloria Navarro
District of Nevada Docket Entry 14 Regarding TRO, Preliminary Injunction
http://www.docstoc.com/docs/146014867/District-of-Nevada-Docket-Entry-14-Regarding-TRO-Preliminary-Injunction
Docket Entry 41District of Nevada Case 2:12-cv-02040-GMN-PAL Judge Gloria M. Navarro Ruling Granting Preliminary Injunction to Plaintiff.
District of Nevada Docket Entry 76 Deny Powers to Order Investigation of Plaintiff
http://www.docstoc.com/docs/146014868/District-of-Nevada-Docket-Entry-Deny-Powers-to-Order-Investigation-of-Plaintiff
For More information regarding Nevada SLAPP Suit, Chilling Effect Lawsuit, First Amendment Suppression Lawsuit, Freedom of Expression Suppression Lawsuit, Click Below
District of Nevada Case 2:12-cv-02040-GMN-PAL Docket Entries
Where Judge Gloria Navarro Made a RULING.
Where Judge Gloria Navarro Made a RULING.
Docket Entry 11
ORDER Granting 9 Motion for CM/ECF Access. Ms. Cox must provide certification that she has completed the CM/ECF Tutorial on or before 1/11/13. Signed by Magistrate Judge Peggy A. Leen on 12/11/12. (Copies have been distributed pursuant to the NEF - EDS) (Entered: 12/12/2012)
Docket Entry 14
ORDER Granting 2 Motion for Temporary Restraining Order. Motion Hearing set for 1/7/2013 03:00 PM in LV Courtroom 7D before Judge Gloria M. Navarro re 2 Motion for Preliminary Injunction. Responses due by 12/28/2012. Replies due by 1/4/2013. Signed by Judge Gloria M. Navarro on 12/14/2012. (Copies have been distributed pursuant to the NEF - SLR) (Entered: 12/17/2012)
Docket Entry 27
MINUTE ORDER IN CHAMBERS of the Honorable Judge Gloria M. Navarro, on 1/4/2013. denying 22 Motion to Request This Court Investigate Plaintiff Marc Randazza. (Copies have been distributed pursuant to the NEF - SLR) (Entered: 01/04/2013)
Docket Entry 35
MINUTES OF PROCEEDINGS - Motion Hearing held on 1/7/2013 before Judge Gloria M. Navarro. Crtrm Administrator: Michael Zadina; Pla Counsel: Ronald Green; Def Counsel: None present; Court Reporter/FTR #: Araceli Bareng; Time of Hearing: 3:49-4:09 a.m.; Courtroom: 7D;
(Copies have been distributed pursuant to the NEF - MJZ) (Entered: 01/08/2013)
Docket Entry 36
MINUTE ORDER IN CHAMBERS of the Honorable Judge Gloria M. Navarro, on 1/8/2013. By Deputy Clerk: Michael Zadina.
This case has been assigned to the Honorable Gloria M. Navarro. Judge Navarro's Chambers Practices, which are posted on the U.S. District Court, District of Nevada public website, may also be accessed directly via this hyperlink: www.nvd.uscourts.gov(no image attached) (Copies have been distributed pursuant to the NEF - MJZ) (Entered: 01/08/2013)
Docket Entry 40
ORDER that 16 Plaintiffs' Motion to Strike is DENIED WITHOUT PREJUDICE. Signed by Magistrate Judge Peggy A. Leen on 1/9/13. (Copies have been distributed pursuant to the NEF - MMM) (Entered: 01/11/2013)
Docket Entry 41
ORDER that 2 MOTION for Preliminary Injunction is GRANTED. (See Order for details). FURTHER ORDERED that Plaintiffs shall receive a $600 refund from the Court for the six domain names that were transferred pursuant to the WIPO arbitration decision. The Court shall keep the nominal bond of one hundred dollars ($100) for each of the other twenty-six domain names at issue because the evidence indicates that Defendant will suffer only minimal, if any, damage by the issuance of this preliminary injunction. FURTHER ORDERED that 19 MOTION for Judges and Clerks to Sign a Conflict of Interest Disclosure is DENIED. FURTHER ORDERED that 20 MOTION for Judge Gloria Navarro to Recuse Herself is DENIED. FURTHER ORDERED that 31 Plaintiffs Motion to Strike Defendant Crystal Coxs Fugitive Surreply to Motion for Preliminary Injunction is DENIED. Signed by Judge Gloria M. Navarro on 1/11/13. (Copies have been distributed pursuant to the NEF: cc Finance - MMM) (Entered: 01/11/2013)
Docket Entry 76
MINUTE ORDER IN CHAMBERS Regarding the Requirements of Klingele v. Eikenberry and Rand v. Rowland as to 75 MOTION for Summary Judgment: Opposition due twenty-one (21) days from the date of this Minute Order, and reply due fourteen (14) days after the filing of the opposition. Signed by Judge Gloria M. Navarro. (Copies have been distributed pursuant to the NEF - MAJ) (Entered: 02/12/2013)
Posted here by
Pro Se Defendant / Pro Se Counter Plaintiff
Investigative Blogger Crystal L. Cox
SavvyBroker@Yahoo.com
Crystal@CrystalCox.com
Friday, February 8, 2013
Rabid Hypocritical Lawyer CRIES Sanctions, when he Himself is in Need of being Sanctioned, Disbarred, Investigated and Indicted, Says HIS Defendant / Victim in Nevada SLAPP Suit Case Number 2:12-cv-02040-GMN-PAL, Investigative Blogger Crystal L. Cox.
"I. Introduction
Rakofsky’s vexatious conduct has caused this case to consume more than one year to
even reach a hearing on the defendants’ dispositive motions. At the hearing, the Court
mercifully advised Rakofsky to abandon his course (Exh A at 91:14-20). Defiant, Rakofsky
refused to do so – but not without personally advising the Court why it was wrong, and he was
right (Exh B). This wasteful conduct has gone too far, and must be sanctioned lest it continue,
and other parties, similarly desiring to abuse the legal system, observe this case and determine that virtually no misconduct will result in sanctions.
II. Statement of Facts
In May 2011, Rakofsky filed a lengthy defamation complaint against more than 70
defendants. Days later, Rakofsky filed his first amended complaint, increasing the number of
claims, and bringing the tally of defendants to 81. Rakofsky opposed the defendants’
perfunctory motion for their attorney’s pro hac vice admission, turning a routine motion into a
lengthy endeavor. Rakofsky’s antics responding to that motion delayed the case for months.
After the Court admitted Mr. Randazza pro hac vice, Rakofsky immediately sought to
stay the proceedings.
While the original stay was only to last until December 2011, it ultimately lasted through March of 2012. Despite requesting the stay, Rakofsky then repeatedly tried to file motions in violation of it: First in November 2011 – which Rakofsky ultimately withdrew – and then again in December 2011, which the Court denied as “incomprehensible” (Exh C). In response, Rakofsky applied for emergency relief to the Appellate Division for the First Department. The Appellate Division also summarily denied Rakofsky’s request for emergency relief. Rakofsky v. Wash. Post Co., et al., Case No. M-162 2012 NY Slip Op 64858(U) (1st Dept. Feb. 21, 2012) (denying plaintiffs’ motion for emergency relief).
Rakofsky attempted those filings despite the fact that his lawyer had quit almost immediately after suit was started, and the corporate plaintiff therefore had no attorney. A corporation cannot proceed pro se. CPLR 321(a).
Finally, back at the trial court, Rakofsky obtained new counsel and was ready to proceed with the litigation. With every filing, though, Rakofsky made it very clear that it was he, and not his new counsel, who was steering the litigation. Every submission Rakofsky made to the Court was signed “written by Joseph Rakofsky,” so as to ensure he would take credit – or responsibility – for it. Nevertheless, his counsel continued to maintain responsibility for the case.
Among 3 these submissions, Rakofsky opposed the defendants’ motion to dismiss by misrepresenting the state of the law to this Court, and moved to file a second amended complaint full of previously rejected theories of liability including negligence, injurious falsehood, and a made-up tort of “internet mobbing.”"
Source of Quote Above
http://www.citmedialaw.org/sites/citmedialaw.org/files/2013-01-02-Memo%20in%20support%20of%20defendants'%20motion%20for%20sanctions.pdf
Funny, THEY are GUILTY of Internet Mobbing, but yet CALL my BLOGS, "Spam" and have them removed from Wordpress and Google. Oh and SUE me for the Rest, but somehow get a Preliminary Injunction and remove, steal, delete before I even have a chance to defend myself, and BEFORE First Amendment Adjudication.
You Know Who is Really Guilty of "vexatious conduct" ?
the Hypocritical Plaintiff of District of Nevada Case Number 2:12-cv-02040-GMN-PAL, a Nevada SLAPP Case that is in EXTREME Violation of the First Amendment Rights of Investigative Blogger Crystal Cox and iViewit Inventor Eliot Bernstein.
This Evil Man claiming that Joseph Rakofsky is guilty of "vexatious conduct", well he himself, has caused massive Stress in my life and many others. And odd he was to be my attorney, even attempted to negotiate a BAD DEAL for me, and yet this above the law Evil Doer has the nerve to say that Joseph Rakofsky is guilty of "vexatious conduct"? Are you KIDDING. the KING of "vexatious conduct" claiming that Joseph Rakofsky "vexatious conduct"?
Vexatious "
Definition of VEXATIOUS
1
2
: full of disorder or stress : troubled <a vexatious period in her life>"
http://www.merriam-webster.com/dictionary/vexatious
Yep Should Call his Law Firm Vexatious Law Firm, where RULES the King of "vexatious conduct", aKa Puppet Master Plaintiff.
" This wasteful conduct has gone too far, and must be sanctioned lest it continue, and other parties, similarly desiring to abuse the legal system, observe this case and determine that virtually no misconduct will result in sanctions. "
Says Dipshit Attorney Quoted Above, and WOW, he has wasted MASSIVE money / and the Courts Time in the Nevada Courts Suing me, Investigative Blogger Crystal Cox, even though this same Gang of Thugs accused of Internet Mobbing in Rakofsky V. the INTERNET have done the same thing to Me, and others for personal and financial gain.
"Rakofsky opposed the defendants’ perfunctory motion for their attorney’s pro hac vice admission" You bet he did, WOW, all those Defendants and FORGOT to add the Kingpin to the Original Complaint, or maybe Joseph Rakofsky did not know who the PUPPET MASTER was, well I guess he sure does NOT.
Non-Attorney, Unhinged Blogger Crystal Cox, SURE recommends a "Face Saving Exit" for the ALLEGED Fucktards of District of Nevada Case Number 2:12-cv-02040-GMN-PAL
"Rakofsky rejected all opportunities to escape from this reckless course of action unscathed"
You Know WHO Else Did that? Hmm... Bet Ya Can't Guess.
Love the Bottom of PAGE 3. Hypocritical Gold Medal Should be Given to this ALLEGED Fucktard for this One.
"1. SLAPP is a common acronym for “strategic litigation against public participation.” SLAPP suits are retaliatory lawsuits brought to harass, intimidate, and burden defendants engaged in First Amendment-protected expression that the plaintiff dislikes."
As if this ALLEGED Jackass IDIOT knows what a real SLAPP "retaliatory lawsuit" is. What a Hypocritical, vexatious, cruel, EVIL, unethical, unconstitutional BUNCH Of BULL that is. Have you Seen the Massive SLAPP Down of Investigative Blogger Crystal COX by this Same Asshole in District of Nevada Case Number 2:12-cv-02040-GMN-PAL ? WoW, Guess they KNOW the LAW and the Constitution ONLY applies to who they Say it DOES.
Some More Crap for ya To Digest
"Defendants have shown restraint – waiting nearly six months for Rakofsky to come to his senses. He has not. Sanctions are appropriate."
Yes, IN MY OPINION, as .. well, JUST ME, I Say that the Attorney who WROTE this TRASH talkin' lies, along with Eric Turkewitz and a few more ALLEGED Co-Conspirators, are the ones who SHOULD be Sanctioned. And "Restraint" my Ass..
WHAT a Bunch of Shit this Is...in my Opinion aKa "Legal Commentary".
WHAT a Bunch of Shit this Is...in my Opinion aKa "Legal Commentary".
"Rakofsky’s conduct has been vexatious, frivolous, and improper at every step. "
LOVE that Assnine Hypocritical Comment from a TRUE vexatious LAWYER, who has frivolously SUED Crystal Cox, an investigative Blogger Reporting on him, who was a CLIENT for a few Short Days, and against Eliot Bernstein who Invented a 13 Trillion Dollar Video Technology that this Lawyers client Liberty Media Holdings and others, have been knowingly infringing on for over a decade. (iViewit Technology). Talk about improper and flat out LIES at every step, take a look at District of Nevada Case Number 2:12-cv-02040-GMN-PAL.
"To the extent Rakofsky’s defamation claims rest upon his lack of competence, he has time and time again raised serious questions about his basic legal skills, and validated defendants’ published criticisms of him."
Hey KNOW who Can't Take Criticism and will Flat out DELETE your Blogs, get Unethical Injunctions and redirect servers on massive domain names, and completely violate the constitutional rights of his victims, ALL because he can't Stand to be Criticized in the TOP Ten Of Google Search? Boy he will FIX that, he will get your ASS Deleted..
"Rakofsky disregarded the Court’s merciful warning and the increasingly evident faults in this case; sanctions are therefore appropriate. "
Merciful Warnings, what a Bunch of Mumbo Jumbo. This Attorney NEEDS Sanctions, Disbarred, and Indicted, in my Opinion that I am NOT allowed to HAVE.
"On the merits, Rakofsky’s claims were doomed to fail. New York law requires a defamation plaintiff to allege and prove (1) a false statement of fact; (2) published to a third party without privilege or authorization; (3) with fault amounting to at least negligence, and; (4) that caused special harm or defamation per se, to establish defamation. Dillon v. City of N.Y., 261 A.D.2d 34, 38 (1st Dept. 1999)."
"The defendants’ reporting of the Deaner trial’s proceedings were nearly verbatim reports of the case’s transcripts (Exhs. E and F), and thus protected as a “fair comment” on official proceedings under New York Civil Rights Law § 74. Freihofer v. Hearst Corp., 480 N.E.2d 349, 353-54 (N.Y. 1985). Still other defenses preclude Rakofsky from prevailing on his defamation claims. The non-factual statements by the defendants were opinions, and incapable of forming the basis of defamation. Gertz v. Robert Welch, Inc., 418 U.S. 323, 339-40 (1974)."
"The defendants’ reporting of the Deaner trial’s proceedings were nearly verbatim reports of the case’s transcripts (Exhs. E and F), and thus protected as a “fair comment” on official proceedings under New York Civil Rights Law § 74. Freihofer v. Hearst Corp., 480 N.E.2d 349, 353-54 (N.Y. 1985). Still other defenses preclude Rakofsky from prevailing on his defamation claims. The non-factual statements by the defendants were opinions, and incapable of forming the basis of defamation. Gertz v. Robert Welch, Inc., 418 U.S. 323, 339-40 (1974)."
He you know who Defamed Me, Investigative Blogger Crystal L. Cox with Actual Malice? Well David S. Aman, Tonkon Torp Attorney as well as Kenneth P. White, Tracey Coenen, Eric Turkewitz, Mark Bennet, Bob Garfield NPR, Peter L. Michaelson WIPO Panelist and the whole gang of ALLEGED Co-Conspirators, Counter Defendants of District of Nevada Case Number 2:12-cv-02040-GMN-PAL. And they had ACTUAL MALICE.
This Same Lawyer Defamed me, WITH MALICE, so did the ALLEGED Co-Conspirators, Counter Defendants of District of Nevada Case Number 2:12-cv-02040-GMN-PAL and yet they are trying to hide behind Gertz v. Robert Welch, Inc. They KNOW and KNEW exactly what they were intentionally, with malice doing to ME, Pro Se Defendant / Pro Se Counter Plaintiff Investigative Blogger Crystal Cox. THIS Same ATTORNEY, and he is SO Above the LAW, and here Spouting this Hypocritical BULLSHIT. it is WRONG and HE Needs to be Exposed, Indicted, Investigated, says ME, Pro Se Defendant / Pro Se Counter Plaintiff Investigative Blogger Crystal Cox, Nevada Free Speech Threat / SLAPP Suit District of Nevada Case Number 2:12-cv-02040-GMN-PAL.
More "Legal Commentary" on this Hypocritical Case, from a VICTIMIZED Pro Se Litigant, ME, Coming Soon
These are the Same Lawyers, Reporters, Law Firms involved in Attacking / Internet Mobbing Blogger Crystal Cox in District of Nevada Case 2:12-cv-02040-GMN-PAL. They really are Ganging up, in Internet Mobbing to Defame, Harass, Paint in False Light, and DESTROY the Lives, Career and Business of their Targets. ALLEGES Victim / Defendant / Counter Plaintiff Crystal L. Cox.
"Respectfully submitted by counsel for Defendants
(1) Eric Turkewitz, (2) The Turkewitz Law Firm,
(3) Scott Greenfield, (4) Simple Justice NY, LLC, (5) blog.simplejustice.us,
(6) Kravet & Vogel, LLP, (7) Carolyn Elefant,
(8) MyShingle.com,
(9) Mark Bennett, (10) Bennett And Bennett,
(11) Eric L. Mayer, (12) Eric L. Mayer, Attorney-at-Law,
(13) Nathaniel Burney, (14) The Burney Law Firm, LLC,
(15) Josh King, (16) Avvo, Inc., (17) Jeff Gamso,
(18) George M. Wallace, (19) Wallace, Brown & Schwartz,
(20) “Tarrant84”, (21) Banned Ventures LLC,
(22) BanniNation,
(23) Brian L. Tannebaum, (24) Tannebaum Weiss,
(25) Colin Samuels, (26) Accela, Inc.,
(27) Crime and Federalism, (28) John Doe # 1,
(29) Antonin I. Pribetic, (30) Steinberg Morton,
(31) David C. Wells, (32) David C. Wells P.C.,
(33) Elie Mystal, (34) AboveTheLaw.com, and (35) Breaking Media, LLC."
Source of Post
http://www.citmedialaw.org/sites/citmedialaw.org/files/2013-01-02-Notice%20of%20defendants'%20motion%20for%20sanctions.pdf
Also Check Out Some of the Hypocritical Documentation / Posts / Filings Below
http://www.josephrakofsky.com/
http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/2013/01/pro-se-counter-plaintiff-crystal-l-cox.html
Court Documents and Filings of District of Nevada Case 2:12-cv-02040-GMN-PAL - Chill Speech Case
EX PARTE MOTION / Proposed Orderfor Temporary Restraining Order and MOTION for Preliminary Injunction Filed by Plaintiffs, District of Nevada Case Number 2:12-cv-02040-GMN-PAL, Document Number 2
Document 2-1 Marc J. Randazza Declaration in support of Ex Parte Motion for Temporary Restraining Order and Motion for Preliminary Injunction
http://www.docstoc.com/docs/142406320/Document-2-1-Marc-J-Randazza-Declaration-in-support-of-Ex-Parte-Motion-for-Temporary-Restraining-Order-and-Motion-for-Preliminary-Injunction
http://www.docstoc.com/docs/142406320/Document-2-1-Marc-J-Randazza-Declaration-in-support-of-Ex-Parte-Motion-for-Temporary-Restraining-Order-and-Motion-for-Preliminary-Injunction
SUPPLEMENT TO EX PARTE MOTION FOR TEMPORARY RESTRAINING ORDER AND MOTION FOR PRELIMINARY INJUNCTION, Document #6.
http://www.docstoc.com/docs/142405386/SUPPLEMENT-TO-EX-PARTE-MOTION
http://www.docstoc.com/docs/142405386/SUPPLEMENT-TO-EX-PARTE-MOTION
Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox Response / Objectionto to EX PARTE MOTION for Temporary Restraining Order and MOTION for Preliminary Injunction Filed by Plaintiffs, Document 29
http://www.docstoc.com/docs/142332681/Defendant-Crystal-Cox-Objection-to-TRO-Injunctive-Relief
http://www.docstoc.com/docs/142332681/Defendant-Crystal-Cox-Objection-to-TRO-Injunctive-Relief
Memorandum To Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox Response / Objection to to EX PARTE MOTION for Temporary Restraining Order and MOTION for Preliminary Injunction
http://www.docstoc.com/docs/142332992/Memorandum-to-Objection-to-Injunctive-Relief-and-Temporary-TRO-in-Favor-of-Plaintiff
http://www.docstoc.com/docs/142332992/Memorandum-to-Objection-to-Injunctive-Relief-and-Temporary-TRO-in-Favor-of-Plaintiff
REPLY IN SUPPORT OF PLAINTIFFS’ MOTION FOR TEMPORARY RESTRAINING ORDER AND MOTION PRELIMINARY INJUNCTION, Document 12
http://www.docstoc.com/docs/142405610/REPLY-IN-SUPPORT-OF-PLAINTIFFS%E2%80%99-MOTION-FOR-TEMPORARY-RESTRAINING-ORDER-AND-MOTION-PRELIMINARY-INJUNCTION
http://www.docstoc.com/docs/142405610/REPLY-IN-SUPPORT-OF-PLAINTIFFS%E2%80%99-MOTION-FOR-TEMPORARY-RESTRAINING-ORDER-AND-MOTION-PRELIMINARY-INJUNCTION
ORDER Granting 2 Motion for Temporary Restraining Order. Motion Hearing set for 1/7/2013 03:00 PM in LV Courtroom 7D before Judge Gloria M. Navarro re 2 Motion for Preliminary Injunction. Responses due by 12/28/2012. Replies due by 1/4/2013. Signed by Judge Gloria M. Navarro on 12/14/2012. (Copies have been distributed pursuant to the NEF - SLR) (Entered:12/17/2012), Document Entry 14
http://www.docstoc.com/docs/142332117/Exhibit-TRO-A-Letter-From-Ron-Green-Ltr-to-Cox-encl-TRO-Order
http://www.docstoc.com/docs/142332117/Exhibit-TRO-A-Letter-From-Ron-Green-Ltr-to-Cox-encl-TRO-Order
REPLY to Response to 2 MOTION for Temporary Restraining Order and MOTION for Preliminary Injunction filed by Plaintiffs / REPLY IN SUPPORT OF PLAINTIFFS' Motion for Preliminary Injunction Against Cox and Bernstein, Document 28
http://www.docstoc.com/docs/142405052/REPLY-IN-SUPPORT-OF-PLAINTIFFS-Motion-for-Preliminary-Injunction-Against-Cox-and-Bernstein
REPLY to Response to MOTION for Temporary Restraining Order and
MOTION for Preliminary Injunction filed by Defendant Crystal L Cox Document 30
http://www.docstoc.com/docs/142333607/Opposition-to-Document-28---Google-Drive
http://www.docstoc.com/docs/142405052/REPLY-IN-SUPPORT-OF-PLAINTIFFS-Motion-for-Preliminary-Injunction-Against-Cox-and-Bernstein
REPLY to Response to MOTION for Temporary Restraining Order and
MOTION for Preliminary Injunction filed by Defendant Crystal L Cox Document 30
http://www.docstoc.com/docs/142333607/Opposition-to-Document-28---Google-Drive
District of Nevada Case Number 2:12-cv-02040-GMN-PAL Court Docket Entry 35
Judge Refuses to Sign Conflict of Interest Disclosure and Admit or Deny Conflict, Judge
DENIES Motion to Sign COI Disclsure.
Judge Denies to Recluse, Remove, Disqualify Herself as Judge in District of Nevada Case Number 2:12-cv-02040-GMN-PAL as Requested in a Motion filed by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox.
" MINUTES OF PROCEEDINGS - Motion Hearing held on 1/7/2013 before
Judge Gloria M. Navarro. Crtrm Administrator: Michael Zadina; Pla Counsel:
Ronald Green; Def Counsel: None present; Court Reporter/FTR #: Araceli
Bareng; Time of Hearing: 3:49-4:09 a.m.; Courtroom: 7D;
The Court makes preliminary remarks and hears representations from Mr.
Green regarding the 2 Motion for Preliminary Injunction.
IT IS ORDERED that 19 Motion forJudges and Clerks to Sign a Conflict of Interest Disclosure is DENIED;
20 Motion Requesting the Recusal, Removal of District Judge is DENIED;
31 Motion to Strike Defendant Cox's Reply to Response is DENIED; and
2 Motion for Preliminary Injunction is GRANTED. Mr. Green
shall file a proposed order consistent with the Court's ruling."
Plaintiff Files MOTION to Deny Due Process of Defendant by Striking her Complaint Response and Counter Claim
Unconstitutional Denial of Due Process. NEVADA Case 2:12-cv-02040-GMN-PAL. Plaintiff Motion to Strike Defendant's Complaint Answer and CounterclaimMotion Requesting Plaintiff Seek Outside Counsel and Declaration
Citizen Media Law Project is PART of the LYNCH Mob that really is Internet Mobbing their Targets, Alleges Investigative Blogger Crystal L. Cox. Citizen Media Law Project has a Real Boner for Randazza Legal Group, and Innocent TARGETS aKa Defendants Pay the Price. Citizen Media Law Project claims Rakofsky v. The Internet is a SLAPP, yet Totally IGNORE the Real SLAPP District of Nevada Case 2:12-cv-02040-GMN-PAL.
Come on Josephy Rakofsky in Rakofsky v. The Internet is a SLAPP, a Legal Threat to the Citizen Media Law Project Staff writing these "Legal Commentaries", yet the Citizen Media Law Project IGNORES the Real SLAPP District of Nevada Case 2:12-cv-02040-GMN-PAL, the Real "Legal Threat", the REAL Free Speech Threat, Abuse of Power, Violation of Freedom of Expression, and Complete Violation of Due process and constitutional rights of Investigative Blogger Crystal Cox and iViewit Founder, Inventor Eliot Bernstein? Why? To Protect WHO? Gee Duh, that is NOT to hard to figure out.
Citizen Media Law Project Staff is JADED, and they Paint a False Picture, in FAVOR of Randazza Legal Group, EVERY TIME.
Seriously, don't you Think that the readers of the Citizen Media Law Site, would be interested in how an intellectual property law firm can have massive Domains Names Taken, Blogs Deleted, and huge FINES, just because some Trademark Attorney sought vengeance? And on top of that make you pay their LEGAL fees to do it ???
Or how about the Case of a $2.5 Million Dollar Judgement against a Blogger, ME, and their Buddy at Randazza Legal Group, SEEMING to conspire with, Advise, an Oregon Attorney, David S. Aman of Tonkon Torp, the Opposing Counsel in Obsidian V. Cox, in order to SEIZE a Defendant's Right to Appeal as an Asset to satisfy a $2.5 Million Dollar Judgement?
Is this not a MASSIVE Issue that the PUBLIC should Know About?
I, Crystal Cox have personally communicated with the Citizen Media Law Project Staff on this massively important issue and have been ignored. I even sent them the Motion to Stay and the Memorandum, filed by Constitutional Rights Attorney, UCLA Professor Eugene Volokh, that ALL should have, as a research tool for, if this happens to them, yet the Citizen Media Law Project Staff refuses to discuss it, why? Because they are connected to the Internet Mobbing Gang and they are PROTECTING the "False Light".
For Those Who Want to KNOW about how YOUR Rights to an APPEAL can be STOLEN, Sold at a Sheriff Sale by Unethical ATTORNEY... and ALL should want to KNOW, here is more information on the Attempt to Steal My Appeal Rights and the Court Documents Involved.
http://www.crystalcoxcase.com/2013/01/david-s-aman-tonkon-torp-lawyer.html
http://www.crystalcoxcase.com/2013/01/eugene-volokh-ucla-professor-and.html
http://www.crystalcoxcase.com/2013/01/january-2013-obsidian-finance-group-llc.html
http://www.crystalcoxcase.com/2013/01/motion-to-stay-to-stop-david-aman.html
Citizen Media Law Project is PART of the LYNCH Mob that really is Internet Mobbing their Targets, Alleges Investigative Blogger Crystal L. Cox. Citizen Media Law Project has a Real Boner for Randazza Legal Group, and Innocent TARGETS aKa Defendants Pay the Price. Citizen Media Law Project claims Rakofsky v. The Internet is a SLAPP, yet Totally IGNORE the Real SLAPP District of Nevada Case 2:12-cv-02040-GMN-PAL.
Come on Josephy Rakofsky in Rakofsky v. The Internet is a SLAPP, a Legal Threat to the Citizen Media Law Project Staff writing these "Legal Commentaries", yet the Citizen Media Law Project IGNORES the Real SLAPP District of Nevada Case 2:12-cv-02040-GMN-PAL, the Real "Legal Threat", the REAL Free Speech Threat, Abuse of Power, Violation of Freedom of Expression, and Complete Violation of Due process and constitutional rights of Investigative Blogger Crystal Cox and iViewit Founder, Inventor Eliot Bernstein? Why? To Protect WHO? Gee Duh, that is NOT to hard to figure out.
Citizen Media Law Project Staff is JADED, and they Paint a False Picture, in FAVOR of Randazza Legal Group, EVERY TIME.
Seriously, don't you Think that the readers of the Citizen Media Law Site, would be interested in how an intellectual property law firm can have massive Domains Names Taken, Blogs Deleted, and huge FINES, just because some Trademark Attorney sought vengeance? And on top of that make you pay their LEGAL fees to do it ???
Or how about the Case of a $2.5 Million Dollar Judgement against a Blogger, ME, and their Buddy at Randazza Legal Group, SEEMING to conspire with, Advise, an Oregon Attorney, David S. Aman of Tonkon Torp, the Opposing Counsel in Obsidian V. Cox, in order to SEIZE a Defendant's Right to Appeal as an Asset to satisfy a $2.5 Million Dollar Judgement?
Is this not a MASSIVE Issue that the PUBLIC should Know About?
I, Crystal Cox have personally communicated with the Citizen Media Law Project Staff on this massively important issue and have been ignored. I even sent them the Motion to Stay and the Memorandum, filed by Constitutional Rights Attorney, UCLA Professor Eugene Volokh, that ALL should have, as a research tool for, if this happens to them, yet the Citizen Media Law Project Staff refuses to discuss it, why? Because they are connected to the Internet Mobbing Gang and they are PROTECTING the "False Light".
For Those Who Want to KNOW about how YOUR Rights to an APPEAL can be STOLEN, Sold at a Sheriff Sale by Unethical ATTORNEY... and ALL should want to KNOW, here is more information on the Attempt to Steal My Appeal Rights and the Court Documents Involved.
http://www.crystalcoxcase.com/2013/01/david-s-aman-tonkon-torp-lawyer.html
http://www.crystalcoxcase.com/2013/01/eugene-volokh-ucla-professor-and.html
http://www.crystalcoxcase.com/2013/01/january-2013-obsidian-finance-group-llc.html
http://www.crystalcoxcase.com/2013/01/motion-to-stay-to-stop-david-aman.html
Matthew H. Goldsmith and Joseph Rakofsky Should not Be Sanctioned. Eric Turkewitz, Randazza Legal Group and Alleged Co-Conspirators SHOULD Be Sanctioned and INDICTED for their Massive Fraud on the Courts Says Investigative Blogger Crystal Cox.
"1/2/2013 - After a six month period in which plaintiffs did not withdraw their claims as urged by the court at the June 28, 2012 hearing, the defendants represented by the Turkewitz Law Firm and Randazza Legal Group file a motion for sanctions against plaintiffs and attorney Goldsmith for vexatious conduct and frivolous claims."
Source of Quote
http://www.citmedialaw.org/threats/rakofsky-v-internet#description
Joseph Rakofsky in the Case, Rakofsky v. The Internet, is not making "Frivolous Claims". He is being Lynched, Set Up, Extorted in a Way, Defamed, Painted in False Light, Harassed, Intimidated, Lied About, Threatened, Mistreated and more.. and these Same Defendants in Rakofsky v. The Internet, many of them are Counter Defendants in a Real "SLAPP" Case known as District of Nevada Case 2:12-cv-02040-GMN-PAL.
There seems to be a Pattern and History with these Journalists, Attorneys, Lawyer Bloggers, Law Firms, and they SHOULD not have Free Reign to Gang Up and Ruin Lives, nor to use their power and privilege to Defame, seemingly legally, and to ruin lives based on lies.
Joseph Rakofsky in the Case, Rakofsky v. The Internet, had the backbone to stand up to them all, and they, in turn, GANG UP, some more, to convince judges, courts, other law firms, and the public at large, via their mirage known as "Legal Commentary" of the "Legal Blogsphere", that Joseph Rakofsky is being "frivolous" and that Joseph Rakofsky and Attorney Matthew H. Goldsmith SHOULD be Sanctioned. Why? Because they Stood up to a LYNCH MOB.
These same Defendants in Rakofsky v. The Internet, and many of them are Counter Defendants in a Real "SLAPP" Case known as District of Nevada Case 2:12-cv-02040-GMN-PAL have also attacked insiders, investigative bloggers, whistle blowers in the Porn Industry Exposing them. The Pattern and History is there. Look at their attack on Shelley Lubben, Monica Foster aKa Alexandria Melody and Diana Grandmason aKa Desi Foxx. They have done this with the First Amendment Coalition, the Free Speech Legal Defense Fund (FSLDF), in effort to SILENCE blogs, online media, investigative bloggers, insiders, whistle blower REPORTING on them.
In District of Nevada Case 2:12-cv-02040-GMN-PAL they even named Monica Foster aKa Alexandria Melody and Diana Grandmason aKa Desi Foxx SIMPLY to defame, threaten and harass them when they WERE unrelated to me, investigative Blogger Crystal Cox. They are "related" now, as we are part of a number of individuals ATTACKED by this Internet Mobbing, Gang Stalking Group.
They need to be EXPOSED, Stopped. Instead, for Now, they have Free Reign of the Courts and they Punish whoever they want, in WHATEVER way they want, and have NO Accountability.
http://www.aribass.com/
http://www.josephrakofsky.com/
http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/
http://www.crystalcoxcase.com/
http://rakofskyvtheinternet.blogspot.com/
http://ranaankatz.blogspot.com/
This Gang, Gets my Videos, Blogs, Documents Removed Often, and YET pretend to be Supporters of the First Amendment, which clearly they are Hypocritical on.. so if anything is Missing from My Blogs and you want it, email me at one or all of these eMails, as they block those too, SavvyBroker@Yahoo.com OR ReverendCrystalCox@Gmail.com or at Crystal@CrystalCox.com - the LEGAL Blogsphere Gate Keepers, get my blogs removed ALL the TIME, so who knows that will be here or there when you find this blog post.
Source of Quote
http://www.citmedialaw.org/threats/rakofsky-v-internet#description
Joseph Rakofsky in the Case, Rakofsky v. The Internet, is not making "Frivolous Claims". He is being Lynched, Set Up, Extorted in a Way, Defamed, Painted in False Light, Harassed, Intimidated, Lied About, Threatened, Mistreated and more.. and these Same Defendants in Rakofsky v. The Internet, many of them are Counter Defendants in a Real "SLAPP" Case known as District of Nevada Case 2:12-cv-02040-GMN-PAL.
There seems to be a Pattern and History with these Journalists, Attorneys, Lawyer Bloggers, Law Firms, and they SHOULD not have Free Reign to Gang Up and Ruin Lives, nor to use their power and privilege to Defame, seemingly legally, and to ruin lives based on lies.
Joseph Rakofsky in the Case, Rakofsky v. The Internet, had the backbone to stand up to them all, and they, in turn, GANG UP, some more, to convince judges, courts, other law firms, and the public at large, via their mirage known as "Legal Commentary" of the "Legal Blogsphere", that Joseph Rakofsky is being "frivolous" and that Joseph Rakofsky and Attorney Matthew H. Goldsmith SHOULD be Sanctioned. Why? Because they Stood up to a LYNCH MOB.
Pattern and History among, what Looks to be Common Co-Conspirators, Bloggers, Attorneys, Media Outlets in the Case, Rakofsky v. The Internet of Joseph Rakofsky and the Crystal L. Cox Cases of District of Nevada Case 2:12-cv-02040-GMN-PAL and District of Oregon CIVIL CASE 3:11-cv-00057-HZ, SHOULD not be taken lightly by Special Investigators. As this "Gang" is POWERFUL in the Media and the Courts, and Joseph Rakofsky is FLAT out TELLING the TRUTH.
In District of Nevada Case 2:12-cv-02040-GMN-PAL they even named Monica Foster aKa Alexandria Melody and Diana Grandmason aKa Desi Foxx SIMPLY to defame, threaten and harass them when they WERE unrelated to me, investigative Blogger Crystal Cox. They are "related" now, as we are part of a number of individuals ATTACKED by this Internet Mobbing, Gang Stalking Group.
They need to be EXPOSED, Stopped. Instead, for Now, they have Free Reign of the Courts and they Punish whoever they want, in WHATEVER way they want, and have NO Accountability.
Also Check Out These Blogs for More Information
http://www.aribass.com/
http://www.josephrakofsky.com/
http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/
http://www.crystalcoxcase.com/
http://rakofskyvtheinternet.blogspot.com/
http://ranaankatz.blogspot.com/
This Gang, Gets my Videos, Blogs, Documents Removed Often, and YET pretend to be Supporters of the First Amendment, which clearly they are Hypocritical on.. so if anything is Missing from My Blogs and you want it, email me at one or all of these eMails, as they block those too, SavvyBroker@Yahoo.com OR ReverendCrystalCox@Gmail.com or at Crystal@CrystalCox.com - the LEGAL Blogsphere Gate Keepers, get my blogs removed ALL the TIME, so who knows that will be here or there when you find this blog post.
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