Thursday, November 20, 2014

Marc Randazza of Randazza Legal Group and others named in Southern District of New York RICO

UNITED STATES DISRICT COURT SOUTHERN DISTRICT OF NEW YORK; RICO Naming Marc Randazza of Randazza Legal Group and others in Alleged Conspiracy.


70. That Self Acclaimed “Porn Industry” Attorney at Law, Randazza, files complaints with
this international intellectual property agency in attempts to seize domain names from
Cox that have his name in the URL and have many links to this RICO and suppress her
blogs and at the same time defame her and Plaintiff.

71. That on June 2012 Randazza filed a CZECH Complaint against Cox and Plaintiff. The
Czech Arbitration Court case worker was Tereza Bartoskova. The Czech Arbitration
Court case number was Administrative proceeding No. 100472. This domain name
dispute was filed by Randazza.

It was filed against Cox and again Plaintiff was inserted and then without notice this case was withdrawn as Cox prepared and filed her response.

Czech Arbitration Court case Administrative Proceeding No. 100472 is hereby included
as evidence into this case, in its entirety, including but not limited to, all documents,
emails, filings, answers, phone records and all information in this case.

72. Czech Arbitration Court case Administrative proceeding No. 100472 was cancelled after
months of document and exhibit submissions by Randazza as well as Respondent. Cox’s
answer was filed. Randazza did not notify Respondents, Plaintiff and Cox that he had
withdrawn the complaint.

Randazza then, at some point after this, and with no reason as to why the Czech case was cancelled, filed a WIPO Dispute with the same claims. In July 2012, Randazza filed a WIPO Complaint against Cox and again, Plaintiff is inserted from start to finish.


73. That this complaint was never served on Plaintiff and no response was tendered in his
defense of this matter, which falsely accuses and defames Plaintiff, stating he has
committed “Extortion” and more.

74. That a decision was reached by a one person panelist, this time amazingly by Michaelson,
they very guy Defendant Proskauer tried to have in their WIPO complaints but was
refused, now ignores his conflicts, which precluded his involvement in the Proskauer
WIPO action listed above and jumps right in. Michaelson denies repeated formal written
requests by Cox for disclosure of conflicts and fails to affirm or deny. Michaelson then
makes determinations in the matter that outright accuses Plaintiff and Cox of the criminal
act of “Extortion” and more, which then goes on to be Published in MAJOR NEWS
PUBLICATIONS, defaming and harassing Cox and Plaintiff and accusing them
publically in Official Proceedings and the Press of crimes they had never been accused or
tried for. Sounds eerily similar to the claims of Celani in the ECC articles when
referencing those who were set up intentionally for crimes that were 100% bogus.

75. That Plaintiff had never been charged at that time or any time with extortion in a criminal
or civil matter, nor has he ever been accused, prosecuted or tried for such crime but with
Michaelson’s decision claiming such false and fabricated accusations, a false media 
campaign was bolstered by an illegally rendered decision and word spread purposely and
from a small spark a wild fire of defamatory press has ensued.

76. That Cox has filed a RICO and a Defamation lawsuit and Plaintiff will soon follow
against all those involved.

77. That WIPO has no legal capacity to rule on criminal matters or to allege publically in a
decision that anyone is acting criminally based on their findings, without that person
being found guilty by the proper criminal authorities, yet this is exactly what happened,
again illustrating another abuse of process that defames Plaintiff.

78. That again the WIPO panelist that makes these defamatory claims is conflicted to
Defendants in this RICO Proskauer Rose, Kenneth Rubenstein, MPEG, Judith Kaye and
others, as fully exhibited in Cox’s filings in the action, and whereby all filings of this
WIPO complaint are hereby incorporated in entirety by reference herein.

79. That in the WIPO decision by Michaelson, he quotes from David Carr of The New York
Times in a published article21, "Ms. Cox, who calls herself an ‘investigative blogger,’ has
a broad range of conspiratorial/journalistic interests. She has written that Bruce Sewell,
the general counsel of Apple, ‘aids and abets criminals’; that Jeffrey Bewkes, the Chief
Executive of Time Warner, is ‘a proven technology thief’; and that various Proskauer
Rose lawyers have engaged in a pattern of ‘conspiracy,’” in order to make Cox look not
credible in reporting on Bruce Sewell, General Counsel of Defendant Apple, former
General Counsel of Defendant Intel and on Defendant Time Warner Inc., BOTH who are
directly involved in the iViewit case. Thereby, David Carr of the New York Times is
found using "big media" that is well trusted by the public, in order to discredit the
iViewIt Technology story, this RICO Lawsuit and the “Legally Related” lawsuits and
acts to further defame and slander Plaintiff.

80. That Randazza through the aid of New York Attorney Michaelson acting in conflict and
who upon being repeatedly requested to affirm or deny conflicts by Cox fails to either
confirm or deny his conflicts with Kenneth Rubenstein, MPEG LA, and Ex Supreme
Court Judge Judith Kay.

That Michaelson in essence frames Plaintiff and Cox with charges of “Extortion” through misuse of an international agency and further illegally seizes domains and Intellectual Properties of Plaintiff and Cox.

81. That Michaelson, WIPO sole Panelist in the decision, frames, defames and slanders
Plaintiff and Cox in an internationally published domain name and intellectual property
decision of WIPO"

"82. That Michaelson, WIPO sole Panelist, Marc J. Randazza v. Reverend Crystal Cox, Eliot
Bernstein, Case No. D2012-1525, States, "Fourth, Respondent Cox exhibited bad faith in
transferring ownership of some of the disputed domain names to Respondent Bernstein,
who merely served as a proxy of the former, in an attempt to evade liability (via so-called
“cyberflight”) under the Policy." This is entrapment, as Plaintiff received domain names
in receivership and part of no cyberflight, and Plaintiff was not, nor is not now a “Proxy.”


83. That on information and belief this case is related matter to the Randazza WIPO case


86. That on November 28th, 2012 Randazza of RLG, former Attorney of Cox, now files
District of Nevada Case 2:12-cv-02040-GMN-PAL against his former client Cox and
allegedly against Plaintiff directly.

87. That on November 30th, 2012, the WIPO decision against Cox and Plaintiff obtained
through the conflicts of interest of Michaelson is then used to support the allegations
against Cox and Plaintiff to the Nevada court as evidence of their criminal acts, all the

22 Docket Link

23 Recent Filing Links
Randazza V. Cox



Cox Reply to Opposition to Defendant’s Motion for Insurance Documentation


Cox Response - Opposition to Defendant’s Motion for Case Management Conference

Motion to Reconsider Counter Complaint Dismissal and leave to amend counter complaint to meet court specifications 

while continuing the defamation that Plaintiff and Cox are now guilty of the crime of
extortion and more.

88. That Plaintiff has recently learned that he may also be a defendant in this suit. While
Plaintiff has not been legally served this complaint, it appears from the Pacer listing that
once again Plaintiff has been added to a complaint without proper notice or service and
according to the docket judgments have been entered against him.

89. That once again, Defendants of this RICO & ANTITRUST are involved in this action
against Cox and now apparently Plaintiff directly as a Defendant, including but not
limited to, Defendant Greenberg Traurig who now shows up. 

90. That Judge Gloria Navarro (“Navarro”), in District of Nevada Case 2:12-cv-02040-
GMN-PAL stated, "The Domain Names at issue in this case were registered by
Defendant Crystal Cox some of which were listed under proxy, Defendant Eliot
Bernstein…” The Footnote in regard to this statement refers to Randazza making this 
claim to Judge Navarro as fact. (Docket Entry 14, Page 2 of 12).

91. That Plaintiff was not a "proxy" and therefore Judge Navarro defamed Plaintiff in
claiming this to be a fact and therefore this became part of a ruling to seize Intellectual
Properties of both Cox and Plaintiff, which was exposing those involved in this RICO
and the “Legally Related” lawsuits.

For the Navarro to claim Plaintiff is a "proxy" in this situation is to suggest criminal activity and that Plaintiff was aiding Cox in hiding alleged "assets", yet another criminal allegation and therefore upon my knowledge and belief, this represents alleged entrapment and criminal conspiracy between Judge Navarro and Randazza. 

92. That Navarro, in District of Nevada Case 2:12-cv-02040-GMN-PAL through an
unlawful, unconstitutional TRO, Preliminary injunction, removed online news sites that
contained investigative reporting regarding the Iviewit companies and the unethical
action of Randazza via this abuse of process.

93. That Navarro, in District of Nevada Case 2:12-cv-02040-GMN-PAL, Docket Entry 14
granted Randazza a mass of domain names, with no due process to Plaintiff or Cox and
Navarro also states on page 6 and in the footnotes that "Defendants" (this includes
Plaintiff), is guilty of acquiring domain names, intellectual property in "bad faith" and 
discusses the offering of a domain name that allegedly had adverse content on it 
regarding Randazza, which is false information and is also entrapment to suggest
"Defendants" are in conspiracy in a "bad faith" extortion scheme.

These are criminal allegations by Navarro in a Civil Case, cleverly designed to discredit, defame and harass Plaintiff and Investigative Blogger Cox who is reporting on the Iviewit story, this 
Lawsuit and the “Related Lawsuits.” 

94. That Navarro, in District of Nevada Case 2:12-cv-02040-GMN-PAL, Docket Entry 14,
page 8, accuses Plaintiff of “cyber-extortion,” which is criminal. 

Judge Navarro is not "Immune" from prosecution for these false allegations in judicial rulings based upon materially false information regarding crimes that were never committed, prosecuted or
tried and where there has been no prosecution or charges of such crimes against Plaintiff 72
and Cox. Therefore, these decisions appear intended solely to defame and harass 
Plaintiff and Cox further and discredit the iViewit companies, this RICO lawsuit and the
“Legally Related” cases.

95. That Page 1, Document 41, District of Nevada Case 2:12-cv-02040-GMN-PAL, is a
Ruling, which also accuses Plaintiff of being a "proxy", which is a criminal allegation.
Document 41 also grants Randazza a Preliminary Injunction that violates the First
Amendment Rights of Plaintiff and Cox, as it removes massive online content without
First Amendment adjudication first, going wholly in opposite of long standing

96. That District of Nevada Case 2:12-cv-02040-GMN-PAL, Docket Entry 39 Grants a
Default Judgment against Plaintiff whom has never been legally served in this case or
received any communications from this Nevada court.

97. That it appears that Ronald Green (“Green”) of RLG, who at the time of filing this
complaint against Cox and Bernstein, had just recently jumped from working at
Defendant Greenberg Traurig’s law firm (in the intellectual property group no less) to
RLG, just in time to prepare in undisclosed conflict, the purported service papers served
in this lawsuit to Plaintiff.

98. That Roxanne Grinage (“Grinage”) was hired and retained by Plaintiff to perform legal
services for Plaintiff. Grinage was under retained legal contract with Plaintiff and
Grinage was given proprietary, confidential, privileged information in this process,
regarding the highly complex details of the iViewit companies, including but not limited 73
to, information regarding intellectual properties, highly sensitive and confidential
information related to business negotiations and federal, state and international
investigation information and all legal actions Plaintiff is involved in.

99. That as a prudent standard of practice, Grinage at her request was copied in emails to
executives of technology companies Plaintiff was negotiating with and other important
legal communications, as she was under contract with Plaintiff and performing related
tasks and legal contract work for Plaintiff on these contacts. It was important to keep
Grinage in the communication loop in these matters, as they pertained to past and future
legal work in which Grinage was under contract to perform for Plaintiff.

100. That in one such series of confidential email communication, regarding communications
with Apple executives Steve Dowling and Bruce Sewell, regarding a website owned by
Plaintiff, that contained information regarding Plaintiff’s
complaint to the SEC regarding Sewell and Intel while he was General Counsel at Intel
and notifying Dowling who had released an Apple press release announcing Sewell’s
arrival at Apple of Sewell’s involvement in the Technology Thefts of Plaintiff while at
Defendant Intel and the SEC complaint filed against Intel naming Sewell.

101. That Dowling had contacted Plaintiff to see if he would sell him back the website and where Plaintiff believes that Sewell was behind this call
attempting to entrap Plaintiff into an extortion scheme where Plaintiff would extort
Dowling with some extreme number “or else.” However, none of that happened as
Plaintiff offered no amount and no “or else” but rather Plaintiff used the opportunity 74
instead to give notice to Apple executive Dowling that Apple and Intel were Defendants
in the Amended Complaint and would be sued in all forthcoming legal actions and also
give formal notice that Apple was infringing on Plaintiff’s Patent Suspended/Pending
technologies and that he should immediately notify Apple shareholders of their liabilities
or Plaintiff would be forced to notify the SEC and others of their failure to account
properly for liabilities under FASB and more. Finally, Plaintiff notified Dowling that he
was now absolutely aware of the lingering liabilities over a decade of use of Plaintiff’s
technologies after reviewing the contents of www.stevedowling,com that he was
attempting to purchase from Plaintiff.

102. That Plaintiff than began a series of follow up emails with Dowling and Sewell to
negotiate a possible license deal with Apple that would settle the infringement and
remove them from the civil RICO action and future legal actions and thereby avoid the
necessity of reporting these major liabilities to their shareholders and others.

103. That Plaintiff copied Grinage in these email communications with Apple, as this was a
standard of practice in order to keep Grinage up to speed regarding the ongoing
communications and negotiations as she had requested. Grinage, a copied recipient on
the emails from Plaintiff then suddenly and for unknown reasons began a campaign to
sabotage and defame both Plaintiff and Cox in the ongoing negotiations with APPLE
executives that were crucial to iViewit companies investors and iViewit companies
inventors, derailing possible settlement talks regarding the issues contained in these 75
confidential emails by suddenly interjecting herself into the negotiations fraught with
allegations of criminal acts by Plaintiff and Cox.

104. That Plaintiff also copied in this series of email communications investigative blogger
Cox, who had been reporting on the iViewit story for 3 years and had posted a blog on
the website , notifying Dowling of the liabilities associated with
Sewell and Apple.

105. That Grinage then suddenly and without warning began replying to the copied recipients
in a massive breach of contract and without conference with Plaintiff or Cox prior. These
replies by Grinage to those same Apple executives, attorneys and officials involved in
this confidential legal communication attacked, defamed, and discredited Plaintiff and
Cox, stating that they were running an extortion plot against Apple executives and others
and other defamatory and slanderous accusations. Accusations that suddenly turn up in a
number of the legal process abuse cases cited herein.

106. That after this series of events Plaintiff immediately ceased working with Grinage who
then sought retaliation by conspiring further against Plaintiff and Cox with Defendant
Randazza to further defame and harass Plaintiff and Cox through broadcasted messages
making wild allegations of criminal activity against Plaintiff, again allegations that have
no factual basis.

107. Cox named Grinage in her counter complaint filed in Randazza v. Cox (District of
Nevada Case 2:12-cv-02040-GMN-PAL) that was dismissed by that Court without
proper adjudication, despite Grinage accepting service and preparing to answer the 76
complaint as Grinage had sent notice to Cox and all those involved in Randazza v. Cox,
except of course Plaintiff, of her anticipated response and counter response to Cox’s filed
counter complaint. Grinage also sent certified motions to the District of Nevada Court of
Judge Navarro, to enter into the case and thereby proving her acceptance of service in
that lawsuit.

However and suspiciously, this motion by Grinage and the accompanying
documents she filed were never placed on the Randazza v. Cox docket or entered into the
record, in fact, Grinage was not even entered as Counter Defendant in the docket or case.
Immediately after Grinage’s filings Judge Navarro dismissed Cox's counter complaint all
together, denying her the right to counter sue and denying Grinage’s right to answer.
108. Cox then named Grinage as a defendant in a new suit that Cox was ordered by Navarro to
file in substitute of the denied counter complaint, alleging that Grinage is acting in
conspiracy to defame and harass Plaintiff and Cox with other defendants named in her
RICO and this RICO.

00297‐JCM‐VCF CHANGED TO 2:13‐CV‐00297 JCM (NJK)

109. That on February 24th 2013, Cox filed District of Nevada 2:13-cv-00297-MMD-VCF.
That this lawsuit is related to the lawsuit above in Nevada as it acts as Cox’s counter complaint in that lawsuit, yet Cox was prohibited from filing a counter complaint in that
lawsuit and Ordered by the judge to file as a separate action?

110. That many of the defendants in that case are again the same as those in this RICO
lawsuit, including but not limited to (bolded names are common defendants); AOL Inc.,
APPLE, David S. Aman, Mark Bennett, Sean Boushie , MT, David W. Brown, Brown,
White and Newhouse Law Firm, Martin Cain, John Calkins, David Carr, Bernie Cassidy
MT, Doug Chey, Tracy L. Coenen, Corbin Fisher, Jennifer DeWolf Paine, Steve
Dowling, Diana Duke, Dylan Energy, Royce Engstrom , MT, Allen Fagin, Forbes Inc.,
Free Speech Coalition, Bob Garfield, Godaddy Inc., Ronald D. Green, Greenberg
Traurig Law Firm,

Scott H Greenfield, Jessica Griffin, Roxanne Grinage, Taylor Kai Groenke MT, Francis Gurry, Judge Marco Hernandez, Kashmir Hill, HireLyrics, Intel Corp., Jason Jones, Edward KWAKWA, Stephen P. Lamont [P. Stephen Lamont], Joseph Lecesse, Liberty Capital, Liberty Interactive, Liberty Media Holdings, John C. Malone, Manwin Business Corporation, Greggory Mashberg, Proskauer Rose, NY, Douglas Melamed, Peter L. Michaelson, Carlos Miller, Mobile Streams Inc., Michael
Morgan, Motorola Mobility Inc., Motorola Solutions Inc., Multnomah County Sheriffs
Office, Leo M. Mulvihill, Mulvihill & Rushie LLC, NPR New York Public Radio,

Judge Gloria M. Navarro, New York Times , NY, Obsidian Finance Group, Oregon State Bar
Bulletin, ..., Bob Parsons , AZ, Philly Law Blog,,
Proskauer Rose Law Firm, Marc J. Randazza , NV, Randazza Legal Group, Janine
Robben, Steven Rodgers, Marshall Ross, Kenneth Rubenstein, Jordan Rushie, Bret 78
Sewell, Bruce Sewell, Daniel Staton, Synaptics, Time Warner Cable Inc., Time
Warner Inc., Sean Tompkins, Tonkon Torp Law Firm, Matthew M. Triggs, Eric
Turkewitz, Turkewitz Law Firm, University of Montana, Tim Vawter, Mark Vena,
WIPO, David Wang, Kenneth P. White, Michael Whiteacre, Eric Wilbers, Steven Wilker
and XBIZ"

111. That in effort to suppress Cox’s right to file a counter complaint, knowing of her
impoverished condition, a condition wholly caused from these Abuse of Process Lawsuits
filed to Harass and Defame her and strip her of her sites that expose the Criminal Cartel
and force her to bankruptcy through judgments garnered through Fraud on that Court.
Judge Gloria Navarro even has issued a ruling that Cox had to file a brand new lawsuit
for the counter complaint.

The legal rationale for this Order was that Cox’s counter complaint addressed the ongoing conspiracy against Cox due to her publications in relation to the Anderson lawsuit and this RICO lawsuit. It should be noted here that there are an overabundance of related Defendants in both of Cox’s cases and Cox provides excellent linkage for this Court to determine exactly who and how they have related to conspire against her rights, through almost identical Obstruction of Justice and Abuse of
Process as described in the Anderson lawsuit and the legally related to Anderson
lawsuits. That this lawsuit filed by Cox and all pleadings, orders, exhibits, etc. rendered
are hereby by reference incorporated in entirety herein.


112. That defendant in this lawsuit Kashmir Hill, Forbes, New York Times, WIPO, Peter L.
Michaelson, and all defendants of Northern California Case 4:13-cv-02046-DMR
conspired to suppress information that investigative Blogger Cox had been reporting on. 

113. That the defendants in this lawsuit violated anti-trust laws and are creating a media
monopoly that is violating the lawful and constitutional rights of Plaintiff and Cox.

114. That WIPO Panelist Michaelson posted unprivileged defamatory statements in an
international WIPO complaint in regard to Cox being guilty of the crime of Extortion and
that the man she was reporting on, Plaintiff, was also guilty of the crime of Extortion.
Neither, Plaintiff nor Cox had been under investigation of extortion, on trial for extortion
or convicted of extortion.

115. That defendant in this lawsuit Randazza, Cox's ex-Attorney conspired with others to
harass, defame and discredit Cox and the iViewit Story of which she was reporting on
when Randazza sued her and Plaintiff (without proper notice), and acted in conspiracy 
with Las Vegas Judge Navarro, WIPO and Godaddy to shut down massive blogs / online
media owned by Cox and Plaintiff.

116. That defendants in this lawsuit conspired to STOP the flow of information and violate
Cox's First Amendment Rights in order to suppress information regarding the Inventor
Eliot Bernstein’s iViewit Technology Story.


117. That allegedly Oregon attorney in this lawsuit defendant .. told defendant Forbes
reporter defendant Kashmir Hill that Cox had been under investigation by the Oregon
Attorney General, Forbes published this false and defamatory statement to third parties
concerning Cox and caused Cox Harm.

118. That defendant in this lawsuit ... told defendant Forbes reporter defendant Kashmir
Hill that Cox was guilty of extortion, and had extorted him. COX had not been on trial
for extortion nor under investigation for extortion. Defendant Forbes reporter defendant
Kashmir Hill published this false and defamatory statement to third parties concerning
Cox and caused Cox Harm.

119. That defendant in this lawsuit Randazza widely published that Cox was guilty of
extortion as did other defendants of the District of Arizona CASE #: 2:13-cv-00962-
MEA, and this has caused irreparable damage to COX.

120. That defendant in this lawsuit Randazza filed a WIPO complaint to defendant WIPO,
whereby defendant Michaelson was the SOLE Panelist in this matter. Defendant
Randazza filed this complaint against Cox and Plaintiff. Randazza accused Cox and
Plaintiff of the crime of extortion. Michaelson then constructed this as fact, along with
the false and defamatory statements of Forbes reporter Kashmir Hill.

121. That Michaelson published false and defamatory statements regarding Cox in a WIPO
decision regarding domain names. Michaelson accused COX and Plaintiff of the crime of
extortion in this international publication through WIPO.

122. Michaelson and Randazza have caused Cox and Plaintiff irreparable harm and are liable 
for damages caused to Plaintiff. 

Randazza had told members that he represented Cox in the matter of her appeal, and so they stayed away. Randazza's negotiation was exposed by UCLA professor Eugene Volokh to Cox, and Volokh has become Cox's counsel, retained under contract with Mayer Brown for her appeal.

57. That upon my knowledge, information and belief, in retaliation, early in 2012, Porn
Industry Attorney Marc J. Randazza of Randazza Legal Group, conspired with Attorney
Aman, to set Crystal Cox up for the crime of extortion. Aman initiated this defamatory
campaign with an email out of context to the New York Times that was one email out of
5 in a settlement negotiation with Cox.

... Randazza conspired to discredit and defame Cox and together convinced Judge Hernandez, and from there the world through Big Media and legal bloggers, that Cox had extorted them, though no extortion complaint was ever filed against her or Plaintiff and where once again, Plaintiff is inserted into the decisions accusing him and defaming him in the process now of extortion and more. "

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