Friday, February 7, 2014

Crystal Cox Marc Randazza, Preliminary Injunction Wars; "Injunction against blogger critical of Miami Heat owner is overturned by appeals court" Oh and who was the Bloggers Attorney, Yep Marc Randazza who got an unconstitutional Preliminary Injunction of his own against Blogger Crystal Cox.

First Amendment Attorney Marc Randazza Says that Preliminary Injunctions are Unconstitutional.

Yet Marc Randazza LIED to the Nevada Courts, GOT an unlawful, unconstitutional Preliminary Injunction against Blogger Crystal Cox, then over a year later tries to use it as criminal evidence to convince Ninth Circuit Judges to allege Crystal Cox has a history of extortion.

Marc Randazza Quote from a Motion Defending AGAINST Preliminary Injunctions

“RKA sought extraordinary relief in the form of prior restraint to enjoin .. . This relief is not recognized in this State, nor anywhere else in the Country. In addition to ignoring the First Amendment Rights and almost a century’s worth of common law, the .. court ignored virtually all procedural requirements for the issue of a preliminary injunction.” Page 5 Paragraph ii of Opening Brief Appellate Case No. 3D12-3189, Irina Chevaldina Appellant vs. R.K./FI Management Inc.;et.al., Appellees. Attorney for Appellant Marc J. Randazza Florida Bar No. 325566, Randazza Legal Group Miami Florida."

Source of Above Quote
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf

I wonder If I, Crystal Cox, could Get Marc Randazza to represent me and overturn my Preliminary Injunction and the 2 years of harassment that went with it from Randazza Legal Group, Ronald Green ( ya, clearly Joking on that). But maybe someday I will get an attorney and be able to SUE Marc Randazza for what he has done to me. I have tried, but thus far Corruption Owns the Courts.

Here are a Couple of Lawsuits Against Marc Randazza and Others, Filed by Blogger Crystal Cox

Florida Case 
http://ethicscomplaint.blogspot.com/2014/02/crystal-l-cox-v-randazza-legal-group.html

New Jersey, Where WIPO Panelist, Attorney Peter L. Michaelson Is
https://docs.google.com/file/d/0Bzn2NurXrSkiN3gyM0VlUE5LdXM/edit

Ok back to Marc Randazza and his LOVE / HATE Relsationship with the Preliminary Injunctions

So you see Marc Randazza gets an unconstitutional Preliminary Injunction against Blogger Crystal Cox, steals her domain names, harasses and defames her for years and then wants to WIELD this magical unconstitutional, unlawful Preliminary Injunction as evidence that Crystal Cox is an Extortionist, Why? Because he says so that's why.

Oh and why does this article make Marc Randazza sound so involved in the appeal, and does not seem to mention when he withdrew from the case due to his hypocritical actions against me. Or so Florida Attorney Todd A. Levine of Kluger, Kaplan, Silverman, Katzen & Levine told me anyway. But then again ya'll know these attorneys will use you as collateral damage to get what they want.

Love this Quote from attorney Todd A. Levine Opposition with Marc Randazza

"From: Todd A. Levine <TLEVINE@klugerkaplan.com>
To: "'Crystal L. Cox, in Love and Light'" <savvybroker@yahoo.com>
Sent: Thursday, February 14, 2013 10:19 AM
Subject: RE: from Crystal Cox
 
Hi Crystal,
 
I think there is a misunderstanding.  After we spoke, my clients hired an appellate specialist from a different law firm to handle the appellate brief and oral argument.   My firm and  I are helping him because we are the litigators that won the injunction, but the other attorney is in charge of the appeal.
 
I think Marc may have withdrawn because he realized he was being inconsistent in our case and your case.  Also, he might not have been getting paid by his client, which may have also caused him to withdraw.  I don’t know the specific reasons because he didn’t disclose them.
 
I did read your documents and if Marc was still in my case I would have had the appellate lawyer use his own words against him, and I would use them against him in the trial court.  There is some good stuff in there and I thank you for sending the documents to me.    Even now, the appellate attorney may use some of the arguments that Marc tried to make against you (and attribute them to our adversary’s former counsel), but I am no longer in charge of that issue, and the fact that Marc is no longer on the other side of the case will make the arguments less effective.
 
Marc did not threaten me with sanctions.  I didn’t remove myself from the case or otherwise withdraw.  I am still counsel for my clients.  My partner and I represent them in the trial court, but we are on the sidelines in the appeal as discussed above.  The appeal is “interlocutory,” meaning that it is in the middle of the case.    I would still have a conflict representing you, because my case is still pending and I am still on the opposite side of the issue in the pending cases.
 
I told you about the brief Marc and his co-counsel filed, because you inquired about it and it is a publically filed document. Again, neither Marc, nor any of his co-counsel have ever threatened me.
 
Sorry for the confusion.
 
Todd A. Levine"
See folks because of the Glen Beck Case, I emailed Todd Levine after Marc sued me. Todd asked for a phone call, as if he may represent me, then what he really wanted was documents to use against Marc Randazza and not to represent me. He said he would email me the appeal filing that Marc Randazza filed, and asked if I would email all my documents in the case. Yet above he claims I 'inquired", guess that is to make him not look bad for actually wanting me to have the motion. Naaa I did not "inquire" nor know it existed, but nice cover up there Todd.

Note: More emails and notes from a phone call I had with Todd Levine about a year ago about all of this.

SO odd the opinion comes out and now it seems they both were still in the case, oh those lawyers...
http://www.3dca.flcourts.org/Opinions/3D12-3189.op..pdf
They will make you collateral damage any given moment, Tricky Bastards they are..



Anyway here is the latest news on the VICTORY for the Blogger

Injuction against blogger critical of Miami Heat owner is overturned by appeals court

"A Florida appeals court has overturned an injunction against a blogger whose sole topic is criticizing Miami Heat part-owner Ranaan Katz, saying the lower court wrongly applied the state's exception to First Amendment concerns for invoking prior restraint, reports Popehat.

The lower court merely considered allegations that Irina Chevaldina's blogging was both defamatory and, particularly, a tortious interference with business relationships. There was no proof of such interference, the Third District Court of Appeals said in its opinion (PDF), and thus Florida's exception to the prior restraint rule under the First Amendment does not apply.

"Angry social media postings are now common," wrote Judge Vance Salter for the court. "Jilted lovers, jilted tenants, and attention-seeking bloggers spew their anger into fiber-optic cables and cyberspace. But analytically, and legally, these rants are essentially the electronic successors of the pre-blog, solo complainant holding a poster on a public sidewalk in front of an auto dealer that proclaimed, 'DON'T BUY HERE! ONLY LEMONS FROM THESE CROOKS!'"

A problem would arise, the court said, if the complainant with a poster entered the dealership and harangued customers or threatened violence, but that in that instance there is well-established law which would provide remedy. "The same well-developed body of law allows the complaining blogger to complain, with liability for money damages for defamation if the complaints are untruthful and satisfy the elements of that cause of action. Injunctive relief to prohibit such complaints is another matter altogether."

Katz, a minor owner of the professional basketball team, owns a real estate development company. Chevaldina is a former tenant, and was represented by Marc Randazza of the Randazza Legal Group and Jeffrey Crockett of Coffey Burlington in her appeal of the injunction."

Source
http://www.abajournal.com/news/article/injuction_against_blogger_critical_of_miami_heat_owner_is_overturned_by_app/

I wonder what Crystal Cox will be awarded for the Unlawful Preliminary Injunction Marc Randazza got against Her, and tried to use to set her up for crime and did use to silence speech and steal massive amounts of intellectual property and TOP search engine placement.
http://rkassociatesusa.blogspot.com/2014/02/rk-centers-raanan-katz-were-ordered-to.html



Let's Look at the RULING and Marc Randazza's Big VICTORY

"Irina Chevaldina appeals an order granting a preliminary injunction  to “enjoin tortious interference, stalking, trespass and defamatory blogs” entered in favor of Raanan Katz and the other named appellees, plaintiffs in the circuit court. We vacate the order and injunction. "

Oh, hey, hypothetically, what if the Ruling Judge threw in, ya we overturn the Injunction but the Blogger did rob a bank apparently, just sayin". (well according to Marc Randazza's rule of law, that A ok with him)

" In this appeal, we review a temporary injunction in the circuit court action
which determined that “the Defendants have blogged extensively about the
Plaintiff and many of these blogs are arguably defamatory. Although ultimately a
defamation trial will be held, this Court ORDERS the Defendants not to enter
defamatory blogs in the future.” The court determined that:
Plaintiffs have a substantial likelihood of ultimately prevailing on the
merits of their claims, and there is a substantial threat of irreparable
injury to the Plaintiffs if injunctive relief is not granted, that the
threatened injury to Plaintiffs outweighs whatever damage the
injunction would cause the Defendants, and that the injunction would
not be adverse to the public interest."

Source
http://www.3dca.flcourts.org/Opinions/3D12-3189.op..pdf

Wow just like Marc did to me, his claims and wala he gets a preliminary injunction. I wonder if this precedent can and WILL be used against Marc Randazza.

The Ruling Goes on to say, "A temporary injunction “should be granted only sparingly and only after the
moving party has alleged and proved facts entitling it to relief.” Liberty Fin. Mortg. Corp. v. Clampitt, 667 So. 2d 880, 881 (Fla. 2d DCA 1996)."

WOW, well Marc Randazza proved NO FACTS in Randazza v. Cox and Bernstein, yet he filed gag orders, injunctions, stole blogs, shut down sites, and even redirected my blogs to a post on his blog defaming and lying about me. Oh well that's all fine because Marc Randazza WINS.

More..

"In order to
establish the right to a temporary injunction the moving party must show: the likelihood of irreparable harm; the unavailability of an adequate remedy at law; the substantial likelihood of success on the merits; the threatened injury to the petitioner outweighs the possible harm to the respondent; and the granting of the
temporary injunction will not disserve the public interest. E.g., City of Miami Beach v. Kuoni Destination Mgmt., Inc., 81 So. 3d 530, 532 (Fla. 3d DCA 2012).  We review the temporary injunction for an abuse of the trial court’s discretion. Angelino v. Santa Barbara Enters., 2 So. 3d 1100, 1103 (Fla. 3d DCA

A. Injunction Against Tortious Interference and Defamatory Blogs Injunctive relief is not available to prohibit the making of defamatory or libelous statements. See, e.g., Vrasic v. Leibel, 106 So. 3d 485, 486 (Fla. 4th DCA 2013). A temporary injunction directed to speech is a classic example of prior restraint on speech triggering First Amendment concerns. Id. There is, however, a limited exception to the general rule where the defamatory words are made in the furtherance of the commission of another intentional tort. E.g., Murtagh v. Hurley, 40 So. 3d 62 (Fla. 2d DCA 2010); Zimmerman v. D.C.A. at Welleby, Inc., 505 So. 2d 1371 (Fla. 4th DCA 1987). "

Source of Ruling
http://www.3dca.flcourts.org/Opinions/3D12-3189.op..pdf

See Crystal Cox, for some reason, has no First Amendment Rights. So her SPEECH was shut down, just like that, no rights, no due process, no First Amendment Adjudication and yes massive irreparable damage to Crystal Cox and Marc Randazza and Randazza Legal Group above the law and have no liability for their actions, or so it seems.

A bit more..

"the trial court failed to make specific findings to support the elements required for the entry of an injunction. See Fla. R. Civ. P. 1.610. “A temporary injunction that merely recites legal conclusions is insufficient to support its entry.” Angelino v. Santa Barbara Enters., 2 So. 3d 1100, 1103 (Fla. 3d DCA 2009). The order on appeal fails to set forth factual findings justifying the entry of the temporary injunction and is therefore inconsistent with the requirements of Florida Rule of Civil Procedure 1.610. Nor does the transcript of the hearing on the motion provide any such specific findings.

Conclusion 

 Angry social media postings are now common. Jilted lovers, jilted tenants, and attention-seeking bloggers spew their anger into fiber-optic cables and cyberspace. But analytically, and legally, these rants are essentially the electronic successors of the pre-blog, solo complainant holding a poster on a public sidewalk
in front of an auto dealer that proclaimed, “DON’T BUY HERE! ONLY LEMONS FROM THESE CROOKS!” Existing and prospective customers of the auto dealership considering such a poster made up their minds based on their own experience and research. If and when a hypothetical complainant with the poster walked into the showroom and harangued individual customers, or threatened violence, however, the previously-protected opinion crossed the border into the land of trespass, business interference, and amenability to tailored injunctive relief.

The same well-developed body of law allows the complaining blogger to complain, with liability for money damages for defamation if the complaints are untruthful and satisfy the elements of that cause of action. Injunctive relief to prohibit such complaints is another matter altogether.
 For all these reasons, the non-final “Order on Plaintiffs’ Motion for Preliminary Injunction to Enjoin Tortious Interference, Stalking, Trespass, and Defamatory Blogs,” is reversed and vacated in its entirety. The scope of our review and this opinion are confined to the claims and motions for temporary injunctive relief. We express no opinion regarding the merits of the still-pending claims for money damages by the appellees based on alleged defamation, trespass, invasion of privacy, tortious interference, and conspiracy. "

Guess this means Marc Randazza's Preliminary Injunction against Crystal Cox and Eliot Bernstein is reversed as well. Oh ya, the Law Does NOT apply to Marc Randazza, I keep forgetting.

Oh an Nicholas Bulgin may want to Take Note; Remember the ManwinSucks.com Preliminary Injunction.
http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/2013/01/nicholas-bulgin-fight-back-know-your.html

Oh and take a look at the Run on Preliminary Injunctions in Nevada

"ViaView, Inc. v. Chanson et al"

"Court Description: ORDER Granting 6 EX PARTE MOTION for Temporary Restraining Order filed by ViaView, Inc. IT IS FURTHER ORDERED that Defendants shall have until 12/7/2012 to file Response to 6 Motion for Preliminary Injunction. Plaintiff shall file reply by 12/21/2021. Motion Hearing set for 1/2/2013 02:30 PM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 11/30/12. (Copies have been distributed pursuant to the NEF - EDS)"

Source
http://law.justia.com/cases/federal/district-courts/nevada/nvdce/2:2012cv01657/90093/10

Even Similiar Wording as the Preliminary Injunction Magic in District of Nevada Case 2:12-cv-02040-GMN-PAL

But See in SOME Cases, a Preliminary Injunction is Unconstitutional

Preliminary Injunction are Unconstitutional Depending on Which Side your Attorney is On.
http://www.docstoc.com/docs/141369776/State-of-Nevada-Case-212-cv-02040-GMN-PAL-in-Connection-to-Irina-Chevaldina-Appellant-Appellate-Case-No-3D12-3189


In the District of Nevada, the Most Important thing is the Attorneys Pay Check, and the Law, the Constitutional Rights of Defendants, Due Process.. well that's Just Irrelevant... Judge Gloria Navarro is THIS Nevada Attorneys SuperHERO.. it's all about the ATTORNEY making money and making a mockery of the courts on the Taxpayers Dime.. Suing Whoever they want.. then getting their attorney fees, intellectual property, fines paid to them and what ever they want in the MAGICALLY Land of the District of Nevada.. Wheee.. Living is Good if your the RIGHT Law Firm in the Fairy Prince Land of MONEY and Make Believe Called District of Nevada.

Judge Gloria Navarro Gives Some More Magic.. 

http://www.vegasinc.com/news/2011/jul/09/attorneys-seek-fee-injunction-against-righthaven/

http://www.vegasinc.com/news/2011/jul/06/righthaven-ordered-pay-defendants-legal-fees/

Liberty Media Holdings LLC v. FF Magnat Limited


Research Links Regarding Ronald D. Green, Greenberg Traurig, Judge Navarro and More.

"The Plaintiff has shown a substantial likelihood of success on the merits of its claims sufficient for the Court to issue a limited Temporary Restraining Order. Plaintiff alleges copyright infringement, contributory copyright infringement, vicarious copyright infringement and inducement of copyright infringement. (Compl., ECF No. 1.) To show a substantial likelihood of prevailing on the merits of a copyright infringement claim, Plaintiff must show that: (1) it owns the copyright to which its infringement claims relate; and, (2) Defendants violated one of the Plaintiff's exclusive rights in the works. See Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991); Latimer v. Roaring Toyz, Inc., 601 F.3d 1224, 1232-33 (11th Cir. 2010); Sid & Marty Krofft Television Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1162 (9th Cir 1977); Educational Testing Servs. v. Katzman, 793 F.2d 533, 538 (3d Cir. 1977). These two factors have been clearly established by the Plaintiff."

Source of Above Judge Gloria Navarro RULING Favoring the SAME Plaintiff
http://nv.findacase.com/research/wfrmDocViewer.aspx/xq/fac.20120621_0003126.DNV.htm/qx

So this SAME Plaintiff ALWAYS seems to show "substantial likelihood of success on the merits of its claim"? Really?  Why is no FBI Agent, Dept. Of Justice Agent, the Nevada Attorney General, or the U.S. Attorney General Looking at all this? It sure seems to VIOLATE the Rights of the Targets, the Defendants in some sort of pattern of "shakedown", in my Opinion. Maybe authorities will take a look when I file my Complaints. Who knows, but someday, somehow, the TRUTH will Come Out, I Hope.

Some More Research on the Liberty Media Holdings LLC v. FF Magnat Limited and this Same  Attorney, who sure is GOOD at Showing Alleged "merits" of winning, Before a Defendant has any First Amendment Adjudication or Right to Due Process.

https://www.rfcexpress.com/lawsuits/copyright-lawsuits/nevada-district-court/98475/liberty-media-holdings-llc-v-ff-magnat-limited-et-al/summary/

Love this Part "Emergency MOTION for Temporary Restraining Order by Plaintiff Liberty Media Holdings LLC. Motion ripe 6/20/2012."

I get threats of death, violence and Judge Gloria Navarro IGNORES my Real Emergency, talk about a racket... Las Vegas, the Land of Lawlessness, INDEED..

Frozen Accounts, Preliminary Injunctions, FORCED Attorney Fees? WOW, sure SEEMS like quite a racket to me, IN MY OPINION.
http://www.scribd.com/doc/105188141/Liberty-Media-Holdings-v-FF-Magnat
"Section 505 of the Copyright Act grants district courts discretion to award “
a reasonableattorney's fee to the prevailing party as part of the costs" Don't ya just LOVE IT, they sue their MARK, and the Judge Forces the MARK aKa Defendant to PAY the ATTORNEYS outrageous Fee's.  And if you Don't SHE will Freeze your Accounts. Pattern and History, I THINK SO.. in my NON-Attorney OPINION.

Don't Forget Liberty Media Holdings allegedly is infringing on the iViewit Technology and many companies owned, at least in part by Liberty Media Holdings are named in iViewit Technology


OUTBREAK of Preliminary Injunctions, Sweeping Rapidly, Seemingly Out of Control, through the District of Nevada, yet Granny Goose Alleges these RULINGS are an "extraordinary remedy"
http://stateofnevadacase212-cv-02040-gmn-pal.blogspot.com/2013/03/pro-se-litigant-investigative-blogger.html

Gee and here we all thought Judge Gloria Navarro was not Marc Randazza's Bitch and full of conflicts of interest. What a tangled web we weave over there with Greenberg, Randazza, Navarro and the gang.

The Full Hypocritical Filing of Marc Randazza Regarding the 
Unconstitutional actions of Preliminary Injunctions.

Page 8 of above, "This appeal Seeks to cure an unlawful prior restraint on the Appellant’s First Amendment rights, improperly imposed by the lower court. On November 19, 2012, the circuit court enjoined Appellant from writing, “defamatory” blogs '1n the future, despite expressly making “no findings of facts as to actual ‘violations of law by the [Appellants], except that [Appellants] have blogged extensively about the Appellee] and many of these blogs are arguably defamatory.” (RÃ/14) The circuit court made this decision Without following the mandates of Florida Rule of Civil Procedure 1.610. However, even if it had, the injunction is patently unconstitutional."

WOW, " the injunction is patently unconstitutional" is that because Marc Randazza did not file it?

Page 10

"Months and months of litigation, thousands of dollars, and thousands of pages of documents later, RKA sought a clearly unconstitutional remedy - an injunction against alleged defamation prior to any court determination that the speech at issue was even legally capable of defamatory meaning, much less Whether it was actually defamatory, privileged, or otherwise protected by the First Amendment. (R Vl-6) The
resulting lnjunction Order was so over-broad and subject to abuse, that the RKA even sought an order for contempt based upon the Chevaldina doing no more than reporting the existence of the Order itself."

WOW again, Really? So all that money to seek a "clearly unconstitutional remedy"? But what if the Plaintiff was Marc Randazza and the injunction chilled online speech, stole intellectual property and tormented his former client? Oh well that's ok, see because that's Marc Riddler Randazza making a mockery of the courts and abusing his privilege and power as an attorney of law. 

Oh and you see, his complaint Randazza v. Cox and Bernsteing, turns out, as he just perjured to the Ninth Circuit, the whole case was about Extortion, yet, oops he forgot to include that as a cause of action or file a criminal complaint, oh SNAP.

Full Hypocritical Motion Linked Below
https://docs.google.com/file/d/0Bzn2NurXrSkiT3M2c1FVbHZqX2c/edit


Let's Take a Look at the Free Speech Supressing SLAPP Lawsuit in Nevada, 
Randazza v. Crystal Cox and Eliot Berstein

Here is the Unconstitutional, Extortion Accusing TRO Motion against Crystal Cox and iViewit Technology Inventor, Victim of Corruption Cox was reporting on, Eliot Bernstein

Defendant Crystal Cox's Opposition to Marc Randazza's unconstitutional Preliminary Injunction
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf

Crystal Cox did not even get First Amendment Adjudication for the massive blogs, domains and websites Marc Randazza seized through an illegal, unconstitutional, seriously over reaching TRO temporary restraining order and a preliminary injunction

Crystal Cox Response to TRO Motion


TRO Motion Supplement, accusations of Criminal Activity of Cox and Bernstein


Defendant Crystal Cox Response to TRO Motion Supplement


Randazza TRO Motion Reply to Response

Another Randazza TRO Response, with false accusations

A letter from Ronald Green, Randazza Legal Group. A pending hearing he deems as a ruling and sends to Godaddy and WOW they give the names to Marc Randazza, just like that.

Defamatory, Over Reaching, Unconstitutional Order Ruling Against Cox and throwing in some accusations, and “pot shots” to further harass, defame and discredit Cox.



So who is it that Does not want the Attorney General involved and an Investigation by Authorities?? Well Crystal Cox wants an investigation, Marc Randazza does NOT.

Crystal Cox wanted a Criminal Investigation and asked the Court to Investigate Marc Randazza and his abuse of Crystal Cox and her informants. Cox also asked to enjoin the attorney general. Crystal Cox wanted due process of law for the extortion allegations, what she got was judges and attorneys ganging up on her and flat out stating Crystal Cox’s guilt without Cox being on trial for or under investigation for Extortion and thereby given due process in the criminal justice system.

Motion Requesting to Investigate Marc Randazza

Marc Randazza is afraid of an investigation and “protests”, all the while accusing Cox of extorting him, which is a crime, so why object to enjoining the attorney general and an investigation?

Investigation DENIED by Judge Gloria Navarro

Motion to Enjoin Attorney General

Order Denying to bring in the Attorney General, gee and isn’t Cox involved in Felony Extortion and yet Marc Randazza and Judge Gloria Navarro, though their ethical duty, don’t want authorities or criminal investigations?? Hmmmm



Take a Look at this information. Marc Wants an unconstitutional preliminary injunction he got, to serve as criminal evidence against his target, victim, Crystal Cox, in a Ninth Circuit Civil ruling NOT about extortin.
http://www.crystalcox.com/2014/02/crystal-cox-on-marc-randazzas-ninth.html

A Bit on The Ninth Circuit Rant and What Really Drives Marc Randazza
https://docs.google.com/document/d/1PJLtqD3SQ_twfQdTClEHNgP-Kt3scT0n6EewWWcNF-Y/edit