Tuesday, February 12, 2013

District of Nevada Case 2:12-cv-02040-GMN-PAL Pro Se Counter Plaintiff / Defendant Investigative Blogger Crystal L. Cox Filed a Motion to Sanction Randazza Legal Group, Ronald D. Green, and Marc J. Randazza. Blogger Crystal Cox is Fighting for Her Life and Attempting to Protect Her Sources from a Gang of Attorneys with Special Privilege, and Power over the Courts.

Pro Se Counter Plaintiff / Defendant Investigative Blogger Crystal L. Cox District of Nevada Case 2:12-cv-02040-GMN-PAL is fighting for her life, and any quality of life she has left.

This Post, as with ALL my Blog posts, are written upon my Belief and Knowledge.

I, Crystal Cox, want ALL to know as much as possible about this Internet Mobbing, Gang Stalking Group.  I do not expect to WIN this Case, as they have already wiped out my blogs, redirected my Domain Names, removed massive content, and that was in the first month.

I may not live through this case, as I, and my sources get constant threats, intimidation, attacks and constant duress toward them in some way.

However, there will be a transparent record, to the best of my ability, as to what they have done to me, and what they are capable of doing. Hopefully this information will help others at some point in the future.

Below is a Motion to Sanction Randazza Legal Group, Ronald D. Green, and Marc J. Randazza I, Pro Se Counter Plaintiff / Defendant Investigative Blogger Crystal L. Cox Filed Today.

  District of Nevada Case 2:12-cv-02040-GMN-PAL Pro Se Counter Plaintiff Crystal Cox Files Motion to Sanction Randazza Legal Group, Ronald D. Green, and Marc J. Randazza


For More Information on  District of Nevada Case 2:12-cv-02040-GMN-PAL
Nevada Slapp Suit, Free Speech Threat, First Amendment Threat, Chill Speech Threat

http://www.crystalcox.com/2013/02/crystal-l-cox-nevada-lawsuit-crystal.html

 http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/

 http://www.freespeechthreat.com/

My Blogs, Videos, Documents, Websites, eMail Accounts, GoDaddy Domain Names, Documents, and more.. disappear daily in retaliation to SUPPRESS, Silence my First Amendment Rights to report on, blog on the Plaintiff and Alleged Co-Conspirators, so if any document is missing or information is not here and you need it for your case AGAINST these, what seem to be Serial Plaintiffs, Committing RICO Crimes, email me at:

Crystal@CrystalCox.com or 
ReverendCrystalCox@Gmail.com or 
SavvyBroker@Yahoo.com

You Can Leave a Phone Message Here
(406) 624-9510. 
Note all HATEFUL Voicemails Will Be Posted




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Monday, February 11, 2013

Crystal L. Cox Nevada Lawsuit. Crystal Cox Sued by First Amendment Attorney AND Fights Back. District of Nevada Case 2:12-cv-02040-GMN-PAL Case Filings, Documents, Motions and Docket Record for your Research. And to provide Transparency in the Courts.


District of Nevada Case 2:12-cv-02040-GMN-PAL SLAPP Suit by Nevada Attorney to Retaliate against Ex-Client Investigative Blogger Crystal  L.Cox.  

This Post is Written Upon the Knowledge and Belief of Defendant / Counter Plaintiff
Investigative Blogger Crystal L. Cox.

Chill Speech Lawsuit, Free Speech Threat, First Amendment Legal Threat; Retaliation Lawsuit, State of Nevada Case 2:12-cv-02040-GMN-PAL
Docket Entries, Motions, Replies, Objections, Responses.

A Nevada Attorney, who is also licensed in Mass., Arizona, California, and Florida sued me to wipe out massive content and steal Domain Names. 

This Nevada Case is a prime example of a SLAPP Suit, a Defamation Lawsuit, but he Calls it a Copyright Lawsuit, Trademark, yet he has no Trademark and all the power of the courts to delete massive online content. And he claims to be a First Amendment Defender, Yet he has CENSORED mass blogs of mine and my online voice, in selective prosecution reporting on him. And thereby removed my First Amendment Rights Completely.

Learn all you Can about this Case. Whether you like my Independent Writing Style or Not, the facts remain the same. If he has this much power, and so does the alleged co-conspirators, you could be next,  take a look.


Original Complaint 
(Nevada Slapp Lawsuit brought against an Investigative Blogger in Retaliations by an alleged First Amendment Supporter, Attorney.)



Judge Requested to Admit or Deny ANY Conflict of Interest

Pro Se Defendant / Pro Say Counter Plaintiff Crystal Cox Requests Judge Sign a Conflict of Interest Disclosure Admitting or Denying Conflict

Request for Judge to Sign a Disclosure Admitting or Denying Conflict.



Countercomplaint Filed by Counter Plaintiff Crystal COX

Original Counter Claim by Counter Plaintiff Crystal Cox



Plaintiff Files a Motion to Strike Counter Plaintiff Crystal Cox's
Counterclaim and her Complaint Answer


Counter Plaintiff / Defendant Crystal Cox Objection / Response in Opposition to to PLAINTIFFS’ MOTION TO STRIKE DEFENDANT CRYSTAL COX’S COUNTERCLAIMS AND ANSWER.



Judge Removal Request

Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox Files Motion Requesting to Remove Judge in State of Nevada Case 2:12-cv-02040-GMN-PAL


First Request by Pro Se Defendant / Pro Say Counter Plaintiff Crystal Cox to Remove Judge from State of Nevada Case 2:12-cv-02040-GMN-PAL.


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. Cites NO Law that Gives Judge Legal Power to Rule on whether to Remove, Recluse Themselves.

" 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."


Motion to Reconsider Request by Pro Se Defendant / Pro Say Counter Plaintiff Crystal Cox to Remove Judge Gloria M. Navarro (Second Request)









Plaintiff Files for Preliminary Injunction and WINS


EX PARTE MOTION / Proposed Order for 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
http://www.docstoc.com/docs/142406400/Ex-Parte-Motion-for-Temporary-Restraining-Order-and-Motion-for-Preliminary-Injunction


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


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


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


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


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

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




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."


in Forma Pauperis


Defendant / Counter Plaintiff Crystal Cox Files in Forma Pauperis

Ronald D. Green Lies to Court, Abuse of Power
In an Opposition to Crystal Cox Continuing in Forma Paupis

Counter Plaintiff /  Defendant Crystal Cox Replies to Ronald D. Green's Motion to STOP the Courts from serving ALL the Counter Defendants in 
District of Nevada Case 2:12-cv-02040-GMN-PAL.


Notice to Court to Notify State Auditors
http://www.docstoc.com/docs/144851855/Notice-to-Court-to-Notify-State-Auditors



Why WOULD the Plaintiff and Ronald D. Green, the Attorney's Attorney, FIGHT so hard to not NOTIFY Authorities?  

I mean, they have defamed Crystal Cox in mass publications accusing her, me of Extortion which is a Crime, so Why not bring in SPECIAL Investigators into all the matters of District of Nevada Case 2:12-cv-02040-GMN-PAL ? 

WHY would Law Abiding Attorneys and Judges not want this? 
Sure SEEMS Fishy to Me.


Defendant / Counter Plaintiff Crystal Cox Notifies Courts to Notify Authorities
http://www.docstoc.com/docs/144851210/Defendant--Counter-Plaintiff-Crystal-Cox-Notifies-Courts-to-Notify-Authorities

Plaintiff Opposition to Notify Authorities. Ronald D. Green Objects to Authorities Being Notified.
http://www.docstoc.com/docs/144852479/Plaintiff-Opposition-to-Notify-Authorities-Ronald-D-Green-Objects-to-Authorities-Being-Notified


Defendant / Counter Plaintiff Crystal Cox's Reply to Response in Opposition of Notifying Authorities.  See Crystal COX wants Authorities To Investigate.
http://www.docstoc.com/docs/144854142/Defendant-Counter-Plaintiff-Crystal-Cox-Reply-to-Response-in-Opposition-of-Notifying-Authorities




Crystal L. Cox Request Nevada Court Protect Her 
and Her Sources, Plaintiff OBJECTS.

Defendant Crystal Cox Motion for Protective Order




Notice to Nevada Court of Counter Defendants / Alleged Co-Conspirators Attack on Porn Industry Insider AND Second Demand for Protective Order.
http://www.docstoc.com/docs/143477716/Notice-to-Court-Regarding-Danger-to-Defendants-and-Sources

Ari Bass aKa Michael Whiteacre, Sean Tompkins, J. Malcom DeVoy Threats



District of Nevada Case 2:12-cv-02040-GMN-PAL Docket


District of Nevada Case 2:12-cv-02040-GMN-PAL SLAPP Suit by Nevada Attorney to Retaliate against Ex-Client Crystal Cox, Docket Links
(yes Folks, the Docket is a Living Breathing Entity, and the Plaintiff can contact the Court and have it changed at any time, in my Belief) 

Attorneys SHOULD not have Special Privileges and Access to the Courts.
They SUE Me, I Fight Back, and they Claim I am abusing the Electronic Docket Service, all because I am providing Transparency.


Nevada Docket as of January 12th, 2013
http://www.docstoc.com/docs/144855176/Nevada-Docket-as-of-January-12th-2013


Nevada Docket as of January 16th, 2013
http://www.docstoc.com/docs/144855394/Nevada-Docket-as-of-January-16th-2013



Nevada Docket as of January 23rd 2013
http://www.docstoc.com/docs/144854914/Nevada-Docket-as-of-January-3rd-2013


Docket as of Jan. 25th 7:30 PM
http://www.docstoc.com/docs/144852069/District-of-Nevada-Case-212-cv-02040-GMN-PAL-SLAPP-Suit-by-Nevada-Attorney-to-Retaliate-against-Ex-Client-Crystal-Cox-Docket-as-of-Jan-25th-730-PM


Docket as of February 8th 2013
http://www.docstoc.com/docs/144852776/Docket-as-of-February-8th-2013


District of Nevada Case 2:12-cv-02040-GMN-PAL Docket as of February 10th 2013
http://www.docstoc.com/docs/144701344/District-of-Nevada-Case-212-cv-02040-GMN-PAL-Docket-as-of-February-10th-2013


My Blogs, Videos, Documents, Websites, eMail Accounts, GoDaddy Domain Names, Documents, and more.. disappear daily in retaliation to SUPPRESS, Silence my First Amendment Rights to report on, blog on the Plaintiff and Alleged Co-Conspirators, so if any document is missing or information is not here and you need it for your case AGAINST these, what seem to be Serial Plaintiffs, Committing RICO Crimes, email me at:

 Crystal@CrystalCox.com or ReverendCrystalCox@Gmail.com or SavvyBroker@Yahoo.com

You Can Leave a Phone Message Here
(406) 624-9510. 
Note all HATEFUL Voicemails Will Be Posted
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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
a : causing vexation : distressing <vexatious delays>
b : intended to harass <a vexatious lawsuit>
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".

"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)."
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.
http://www.josephrakofsky.com/2013/02/counter-defendants-of-nevada-slapp-case.html
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
Posted by at No comments:

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
http://www.docstoc.com/docs/142406400/Ex-Parte-Motion-for-Temporary-Restraining-Order-and-Motion-for-Preliminary-Injunction

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


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


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



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


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


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


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 Counterclaim


Motion Requesting Plaintiff Seek Outside Counsel and Declaration


Plaintiff Opposition to Defendant Cox's Motion Requesting Plaintiff Seek Outside Counsel and Declaration



Defendant Crystal Cox Motion to Recluse, Remove Disqualify Judge



First Request by Pro Se Defendant / Pro Say Counter Plaintiff Crystal Cox to Remove Judge
Motion Requesting the Reclusal, Removal of Judge Gloria M. Navarro, First Request, filed by District of Nevada Case Number 2:12-cv-02040-GMN-PAL Pro Se Defendant Crystal L. Cox - Pro Se Counter Plaint

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."


Defendant Crystal Cox Motion for Protective Order










Ronald D. Green, Alleged Intellectual Property Attorney, LIES to Nevada Courts Deliberately to Defame, Harass, Intimidate Counter Plaintiff / Defendant Crystal Cox. Why is Randazza Legal Group Above the Law? Why Do Counter Defendants of District of Nevada Case 2:12-cv-02040-GMN-PAL use the courts to intimidate, harass, threaten, and attack who ever they please? Who will Stand up to Ronald D. Green and Randazza Legal Group? No One Can, as they Allegedly have Mafia behind them, which is said to include MASSIVE Porn Industry MONEY. Add that to the BILLIONS that Liberty Media Holdings have Backing them, and fighting to STOP The iViewit Story, and there you have it. Attorney Reign of Terror, Internet Mobbing, Gang Stalking and NO Accountability in SIGHT.

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