U.S.

Bankruptcy Court
District of Nevada Las Vegas
Adversary Proceeding #: 17-01005 -abl

Crystal L. Cox,
Counter-Plaintiff,Defendant, Creditor
v.
Adv. 17-01005 -abl
Marc Randazza,
Counter-Defendant, Plaintiff, Debtor

DECLARATION OF CRYSTAL COX

in support of Coxs Counterclaims against Randazza
And Support of Motion for Bench Trial

Declaration of Crystal Cox, Oct. 30, Docket Entry 8 and all Exhibits are hereby also included
with this declaration in its entirety.

Randazza et al v. Cox et al, 2:12-cv-02040, District of Nevada, Case 2:12-cv-02040-GMN-PAL

Document 24 and 25 with all Exhibits Filed 01/03/13, Cox Counter Complaint is hereby included
in its entirety.

I Crystal Cox hereby declare as follows:

I make this declaration based upon my own personal knowledge, and if called upon testify as to
its contents, could and would do so consistently herewith. I make this declaration in support
the exhibits fairly and accurately reflect what I Perceived and what I truthfully experienced with
my ex-attorney Marc Randazza.

I am currently homeless, have no vehicle or income, and have been under extreme duress for 5
years since Marc Randazza launched his attack against me, threatened me, his friends
threatened me, and he painted me in false light maliciously and with actual malice as he knew
the facts and yet falsified material facts.

Randazza continues to claim that my, Coxs modus operandi as an extortionist is simple:
She approaches individuals offering her reputation management services for thousands of
dollars per month. If they refuse, she then uses these services to Google bomb
her would-be clients. This has NEVER ever happened. Randazza knows the facts yet
promotes the lie. I have approx. 2,000 blogs and hundreds of thousands of blog posts over 17
years. My intentions have never been to extort anyone nor have I. I am an anti-corruption
blogger and I give voice to victims to the best of my ability.

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Randazza continues to provide this court with false material facts maliciously knowing it is false.
I had been reporting on Obsidian and the Summit 1031 Bankruptcy case for years when
Obsidian/Kevin Padrick sued me.

I had dozens of insiders giving me information, I had read thousands of documents, I had a
CPA whistleblower sending me information and talking to me on the phone, I had phone
interviews with many creditors and lots of people involved in the matter, I watched videos of
meetings where Kevin Padrick, the Trustee was speaking and I heard and saw all that and
reported on it to the best of my ability and in my own unique First Amendment protected style.

I did not post anything to extort nor did I ever threaten such. I posted for justice for the real
estate consumers who were victims of the Summit 1031 bankruptcy, as I was and am an
Investigative Blogger dedicated to supporting victims of corruption and I have been a real estate
broker for 17 years. I had been licensed in Oregon and MT by that time and had myself been
very familiar with the Summit 1031 company, having owned my own real estate brokerage. I
never asked for money to remove anything nor did I ever want or intend to remove anything.

The email that my ex attorney Marc Randazza has branded as extortion was sent by me, in my
Pro Se capacity to the attorney representing the opposition, David Aman for Kevin Padrick and
Obsidian. The email was sent after several negotiation emails, it was part of a 5 email thread in
a Private Confidential Settlement negotiation, and the email was sent after I had been served a
Cease and Desist and after a Federal lawsuit was filed against me. Obsidian made me
approximately 15 settlement offers, of which I rejected them all as I wanted to fight for equal
rights of whistleblowers, citizen journalists, and bloggers. Marc Randazza knew my mission and
what I wanted in my appeal from that first call with me professing that it was the appeal verdict I
wanted to go for to help all victims of corruptions and to give equal rights to bloggers to that of
the highest paid journalist in the institutional press.

Randazza emailed me, as seen in Exhibits with Dec. of Cox at Doc. 8 with Exhibits, and he
stated that people like me were needed, and offered to assist me in any way he could. He knew
full well that the Obsidian case had no cause of action connected to extortion and that the email
was a dirty trick they all played as they painted me in false light and provided deliberate false
material facts to Federal Courts, in malicious retaliation for me exposing their fraud, collusion,
corruption, bullying and unethical actions in the Summit Bankruptcy. Of which they all knew I
had blogged about for years and did not ask for money to remove anything.

It is ironic to me, and maliciously hypocritical that a settlement communication between me, pro
se, and the opposition was painted out by Marc Randazza as being the criminal act of extortion,
as well as civil extortion, yet recently, on October 23 2017, on behalf of Marc Randazza,
attorney Matt Zirzow sent me an email entitled Randazza v. Cox: Confidential Settlement Offer
and started the email with this:

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This email is confidential and inadmissible pursuant to Federal Rule of Evidence 408 and NRS
48.105 Randazza knows that he used my Confidential Settlement Offer in the Obsidian Case to
paint me out as a criminal, a bad guy, a monster, an extortionist and other vile and disturbing
names and insinuations. Yet as seen in Exhibit A, Randazza wants me to keep his settlement
communications to me PRIVATE AND CONFIDENTIAL.

My case, Obsidian v. Cox, was a Landmark ruling, and it was the First of its kind to win equal
rights for bloggers. My case stopped the monopoly big media had on free speech and
essentially was a game changer. Instead of a hero however, my own attorney painted me out to
be the villian. Randazza tainted my landmark win by flat out maliciously lying to all sizes of
media,in the courts, in sworn statements, in Amicus Briefs, in WIPO complaints, to NPR and
Forbes, to dozens of legal bloggers and more.

On my first call with Randazza, he told me that Big Media had a monopoly on Free Speech. I
proved that wrong with my, first of its kind landmark WIN. Big Media no longer has a monopoly
on Free Speech. Randazza is still mad he was not my attorney in my appeal.

I, Crystal Cox, claim that Marc Randazza owed me a duty of care, a fiduciary duty and an
ethical duty to not harm me, not threaten me, not gang stalk me online, not provide false
material fact to WIPO and Federal courts and to NOT harm me in any way. Therefore I claim
that Randazza owes 5 years of my life back, my future and monetary relief for the irreparable
harm he has caused to my life and to those I love and do / did business with.

Marc Randazzas campaign of malicious lies ruined chance of seo work or any type of online
marketing, or real estate clients. Not only did Randazza lie about me being an extortionist with
NO adjudicated facts, he branded me as some sort of child abusing monster, flat out lying about
me having a blog about his child, there was no blog, he never provided a blog into evidence and
owes me financial relief as I was unable to get a job or rent a home, lost family and friends, and
was maliciously taunted for years and still am, all because of him going on NPR and lying about
me attacking his toddler, lying to Forbes and other media outlets that I attacked a toddler. He did
so knowing full well there was no material facts to support his claim.

I was never seeking clients via an extortion racket. Back then I made a living at real estate and
marketing a nutritional supplement online. My blogs have always been to make the world a
better place. I have not asked for nor received money EVER to remove anything from blog.

Randazza has lied to this Court and other courts knowingly

Randazza Made many false statements of material facts to WIPO and to the District of Nevada
courts regarding Cox. I move this court to hold Marc Randazza accountable and send a
message to other attorneys like him by awarding me a monetary judgement against Marc
Randazza.

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Here is one such false sworn statement Randazza made:

In Marc Randazzas Recent Filing, Motion for Default, Case 16-01111-abl Doc 26 Entered
10/20/17, he claims that ONLY upon Volokh being interested in teaming up with him was he
then willing to accept the case. Meaning the Crystal Cox Appeal. Yet Crystal Cox claims
Randazza represented her before this and told others he was her attorney. Randazza states in
earlier sworn documents a different sworn fact.

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

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

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

In Case 16-01111-abl Doc 26, Page 38, Line 26-28 and Page 39 1-4, we see RANDAZZA
swearing that he ONLY agreed to Represent Cox after Volokh expressed interest to team up
with him. We see below in a previous Sworn statement of Randazza that he was involved in
representation BEFORE speaking with Volokh, talking strategy with Volokh, and only spoke with
Volokh after he had already put in time and material into representation. (See Exhibit 11)
As seen in Exhibit 1, Marc Randazza held himself out to Volokh as representing me, Crystal
Cox. Marc Randazza was clearly acting as my attorney and holding himself out to other
attorneys as my attorney.

Interrogatory 21 Exhibit 9 (see Doc. Entry 8 declaration and Exhibits)

Did you have phone conversations with Eugene Volokh and state that you represented Cox
and discuss with him your strategy, or a deal you were trying to make with the opposition,
Plaintiffs attorney David Aman?

Randazzas Sworn RESPONSE TO INTERROGATORY NO. 21:

"... Counterdefendant responds as follows:

Counterdefendant spoke with Eugene Volokh in December 2011.

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

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

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

Cox alleges that Randazza had no right to negotiate with out having been Coxs attorney. What
gave Marc Randazza a legal right to negotiate who gets to be my attorney with him, if he was
not indeed my attorney, or acting as if he was my attorney?

Randazza and Volokh discussed strategy about me, Crystal Cox, as Exhibits clearly show. They
discussed that a settlement was in my, Crystal Coxs, best interest. Even though they both knew
what I wanted and what I felt was in my own best interest.

They were talking strategy and negotiating what was in my best interest to them and Randazza
proceeded with steps to negotiate what was in my best interest when Randazza clearly and
plainly knew that I want to appeal. I did NOT want to settle nor did I want to be bullied or
pressured into a settlement that I had already rejected 15 times acting as my own attorney.

Randazza tried to push me to do what I did NOT want to do, and what would benefit his
wealthier clients and Randazzas own personal agenda as a First Amendment attorney.

Randazza was clearly negotiating behind my back, without my consent with at least Volokh and
with oppositions attorney David Aman.

Randazza was attempting to trick and deceive me by letting the deadline run out while he held
himself out as my attorney so no one else would represent me, thereby blocking me from
appealing. He did not know I had talked to Volokh when he tried to pull off this malicious
scheme.

Page 38, Number 1-13 of Interrogatory 21 Exhibit 9, Case 2:12-cv-02040-JAD-PAL

Document 252 Filed 04/06/15 is Marc J. Randazzas SWORN statement that the Interrogatory
Answers are true to the best of his knowledge, yet we see on Page 38, Line 26-28 and Page 39
1-4, Case 16-01111-abl Doc 26, (Randazza Decl. 26) that Marc Randazza swears to the a
VERY different Answer.

See Case 16-01111-abl Doc 28 Entered 10/20/17, DECLARATION OF MARC J. RANDAZZA IN

SUPPORT OF MOTION FOR JUDGMENT BY DEFAULT ENTERED BY THE COURT Page 16,
Line 23-25 says:
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I declare under penalty of perjury that the foregoing is true and correct.
Dated: October 20, 2017.
/s/ Marc J. Randazza
MARC J. RANDAZZA, ESQ.

Both cannot be True under penalty of perjury. Cox is entitled to relief for the damage Randazza
has maliciously, willfully and wantonly caused her.

Recently Randazzas attorney Zirzow emailed me an email titled Randazza v. Cox:

Confidential Settlement Offer See Exhibit A

On October 23, 2017 Randazzas attorney emailed me a Settlement Negotiation, in this I,

Crystal Cox, quickly noticed that my settlement terms in Obsidian v. Cox had been
violated/voided/broken.

See Exhibit A In the Obsidian case, there was to be no disclosure of the terms of the PRIVATE
CONFIDENTIAL settlement agreement that I, Crystal Cox, pro se at the time, made with David
Aman, Tonkon Torp attorney on behalf of Kevin Padrick and Obsidian Finance Group. Yet
Randazza somehow knows those terms, as does his attorney and presumably others he has
told. Which is clear to see in Exhibit A.

That settlement was private and confidential. Yet Exhibit A clearly shows Randazza knows,
presumably from being told by David Aman, then of Tonkon Torp law firm, the attorney to the
Opposition.

I have been able to get Mr. Randazza to agree to offer you terms similar to the settlement
you obtained in the Obsidian case. In other words, Mr. Randazza has authorized me to offer
a complete walkaway settlement, whereby each side drops any and all of their claims
against each other in exchange for mutual general releases, provided that Mr. Randazza may
continue to keep the domain names that have already been awarded to him in the WIPO
proceeding and per the injunction in the Federal Court proceeding. In other words, you each
drop any and all claims against each other, and you each give each other full all-encompassing
releases, and you both go your separate ways with no liability to the other. Additionally, this
settlement agreement would also include a non-disparagement clause, whereby you will both
stop publishing any articles about each other, withdraw any and all existing articles or videos
about each other and the cases, Mr. Randazza will stop any amicus briefs regarding you, and
you both agree to never publish or speak about each other again. In other words, the idea is for
both parties to simply get on with their lives and never talk about each other. This is a
substantial offer from Mr. Randazza because he is essentially agreeing to walk away from
nearly a $500,000+ judgment he will soon be awarded against you, and in exchange for your
claims which have no merit and which you could never prove in any event.

Please let me know if such a walkaway settlement would be acceptable to you in general

6
(subject to being documented in a later writing of course).

Once I received this settlement offer on Oct. 23, 2017, I began drafting a letter to Tonkon Torp to
make them aware of the situation. As seen in Exhibit C, Obsidian Finance Group, LLC v. Cox
Case 3:11-cv-00057-HZ Settlement Agreement from Crystal Cox Pro Se. Exhibit C
Cox alleges that Randazzas attorney Zirzow deliberately misled Cox on Deadlines

Also Seen in Exhibit A, Marc Randazzas attorney Matt Zirzow is deliberately trying to mislead
me. As this email dated Oct 23 at 9:31 PM states that I have until November 10th 2017 as my
opposition deadline to Mr. Randazzas currently pending motion for default judgment

Finally, given that you have an opposition deadline of November 10, 2017 to Mr. Randazzas
currently pending motion for default judgment, Mr. Randazza must receive your acceptance of
this walkaway offer by no later than that date. If you do not accept this offer, then Mr.
Randazza will fully proceed with all claims and remedies against you in Bankruptcy Court, and
otherwise.

I urge you to consider this offer, as I think this is the best all sides will ever get from each other.
Exhibit A

Then Zirzow claims my deadline is Nov. 14th.

The hearing on this Motion for Default Judgment is set for November 28, 2017 at 10:00 a.m.
before the Bankruptcy Court in Las Vegas, and thus any opposition to this Motion from you is
due and must be filed and served by no later than November 14, 2017. You are advised that
your failure to oppose or appear for this hearing may result in a judgment being entered against
you. Exhibit B, email from attorney Matt Zirzow

Cox Claims Randazza owed her Fidicuary and Ethical Duties as

a Matter of Law and Nevada Attorney Ruless, allso see
Declaration of Crystal Cox, Doc. Entry 8 and all Exhibits

District of Nevada Rule 172 Candor Toward the Tribunal states

[1] A lawyer shall not knowingly:
(a) Make a false statement of material fact or law to a tribunal;

I had a 2.5 million dollar judgement against me at the time. Marc Randazza made false
statements in mass that were not material fact and was a knowing false statement. This hurt my
case results as the narrative became about the false narrative of extortion instead of the
IMPORTANT First Amendment issues that were being adjudicated by the Ninth Circuit.

Randazza assisted and advised the oppositions attorney David Aman on how to use a State
court to take my Right to Appeal in exchange of the debt of the 2.5 million.

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See Obsidian Finance Group, LLC et al v. Cox 3:11-cv-00057, 01-07-2013 Doc. 144-152 Motion
for Stay and protective order filed by my then attorney Eugene Volokh, whereby Randazza
advised Aman on now to seize my Right to Appeal, apparently it was used in Florida often and
Marc Randazza was very familiar with the method of STOPPING an appeal by auctioning off the
Defendants right to appeal in order to satisfy the Judgement, in this case 2.5 million. My rights
were being auctioned off in an Oregon State court, I found out and contacted Volokh. If I had not
then the appeal would have been successfully stopped.

Marc Randazza did everything he could to STOP my appeal. He did not want the precedent to
harm him or his wealthy clients, so he attacked me on all sides relentlessly to get me to stop.
His attorney friends emailed me and tried to bully me into stopping, Randazza had a massive
online campaign to paint me in false light, harass and defame. He filed Amicus Against me and
funded others to do the same thing. He aided AMAN in receivership to take my intellectual
property, and then he sued me, among other malicious tactics. Cox, I, allege that Randazza
owed me a duty to protect me or at least to not harm me. As his former client, potential client or
even someone he counseled, advised, or advocated for per law and attorney ethics as an officer
of the court.

Randazza RULES Cox to be behaving Criminal with No Due Process

On page 6, line 6-8 Case 16-01111-abl Doc 26 says, On March 30, 2012, Mr. Randazza went
public to combat Coxs criminal behavior wrote on his law blog, The Legal Satyricon Judge
Rules Again that Blogger Crystal Cox is Not a Journalist. Cox alleges this to be defamatory
and with malice as Randazza knew Cox was not an Extortionist. And if Randazza believed Cox
to be behaving criminally than Randazza as Coxs former attorney or at the very least potential
attorney, owed Cox a duty to at least discuss the matter with her before going public. And as an
Officer of the Court Randazza was obligated to file a criminal complaint with the FBI, Police or
Dept. of Justice and allow Cox due process instead of self proclaim him to be judge and jury
that my, Crystal Coxs behavior was indeed criminal. Why not file a criminal complaint and give
me due process. A way to present my side of the story in a court of law and adjudicate the fact
and face my accuser. Instead he simply deemed my behavior criminal and convicted my on
his legal blog. This is Defamation and I, Crystal Cox am allowed all available relief as a matter of
law.

Receiver Lara Pearson

Marc Randazza advised attorney David Aman to use Lara Pearson as a receiver to come after
domain names as assets to satisfy my 2.5 million debt. Randazza had used Lara Pearson in
prior deals such as the Righthaven cases.

See Lacked Standing to Sue "The litigation campaign stalled this summer and, most recently
this month, after judges in Nevada and Colorado ruled Righthaven lacked standing to sue under
8
its lawsuit contracts with the newspaper owners. The latest ruling against Righthaven in
Colorado will likely end 34 open suits there and extinguish Righthavens investment in them
though Righthaven plans to appeal." Exhibit M
http://www.vegasinc.com/news/2011/oct/01/righthaven-stephens-media-eating-more-legal-costs
-/

Judge: Righthaven lacked standing, abused Copyright Act. Exhibit L

Then we see Marc Randazza gets the money from asset sale by Lara pearson, whom he later
helped Obsidian attorney David Aman use to come after me, Crystal Cox, for my intellectual
properties, domain names, copyrights and such.

"Their purchase of the rights would ensure Righthaven cant sue them again over the same
material in the event Righthavens ability to file lawsuits is reinstated, said Las Vegas attorney
Marc Randazza, who represents Righthaven defendants in multiple cases. Lara Pearson, an
attorney appointed by the court to auction Righthavens assets, has already seized and
auctioned its website." ( See Exhibit J.)
http://www.vegasinc.com/news/2012/mar/14/r-j-copyright-be-auctioned-following-righthavens-c/

Then Randazza says Righthaven had no copyright, yet he got near 200,000 in an auction
""Righthaven is neither the owner nor exclusive holder of any rights in the copyrighted work
underlying this lawsuit. As such, Righthaven has suffered no injury or other cognizable harm
required for it to have standing to sue, said one of the filings by attorneys Marc J. Randazza
and J. Malcolm DeVoy IV.
"Indeed, the agreement makes it abundantly clear that Righthaven actually has no rights in the
copyrights it claims, the filing said."
http://www.vegasinc.com/news/2012/mar/14/r-j-copyright-be-auctioned-following-righthavens-c/

Randazza got paid from the sale of their copyright, and then says they don't have one. Cox
claims that Randazza should be forced to auction of his copyrights to pay Creditors. At the very
least this all proves further negligence in suing and defaming COX as Randazza is an expert.

Marc Randazzas Copyrights, Domain Names and Online Properties are Assets that should be
auctioned off to pay Creditors.

Clearly Randazza maliciously worked with the opposition to deliberately harm me, and
Randazza should have at least been a 3rd party neutral even if he only believed me to be a
potential client or someone he once advocated for or counseled, Exhibits attached to
Declaration, Docket Entry 8, clearly show that at the very least Marc Randazza and Randazza
Legal Group agree I was a potential client, yet they retaliated against me relentlessly. (See Doc.
8 with Exhibits on potential client)

Then in 2012 Randazza Legal Group sued me, Case 2:12-cv-02040-JAD-PAL, to silence me,

9
chill my speech, shut down online sites, unconstitutionally seize domain names, suppress
speech, and remove online content that did not flatter him and gave bad reviews to him and his
law firm, Randazza Legal Group. Randazza used an unconstitutional TRO to take my
Intellectual property, my domain names, my search engine ranking and my online content.

Marc Randazza claimed in that case that Domain Names have value and the case was largely
about Randazza claiming I, Crystal Cox, was seeking to hide assets, those assets he claimed
were blogs, websites, domain names and other intellectual property, even accusing me of hiding
domains with Eliot Bernstein as a Proxy, which is untrue.

However, in this bankruptcy case, BK-S-15-14956-abl, Randazza does not claim web
properties, intellectual properties, domain names or any online content as assets and even
seemed to actually attempt to use Ron Green, Jennifer Randazza, Randazza Legal Group and
many others as Proxy to hide assets with knowing Intention to Defraud Creditors.

MarcRandazza.com, of which Randazza stole from me, is owned by Marc Randazza and is not
an asset he lists yet he accused me of using a proxy to hide the domain name from my debt
collectors when I had a 2.5 million judgement against me in Obsidian v. Cox.

Randazza.com for example is held by proxy at Moniker company, and Randazza does not seem
to claim this as an asset either. MarcRandazza.net, RandazzaLegalGroupSucks.com and lots
more domain names and blogs Marc Randazza took from those criticizing him and Randazza
Legal Group, including RandazzaNews.com he bullied, sued and fought Monica Foster /
Alexandra Mayers for and yet Randazza Legal Group seems to be holding this asset in Proxy
and hiding this Marc Randazza asset.

MarcRandazzaSucks.com stolen from me by Randazza is owned by MARC J. RANDAZZA c.o.

Randazza Legal Group, yet he did not claim it as an asset and RLG is holding it in part as a
seeming proxy. There are many other web properties, blogs, domain names and other online
intellectual properties in which Randazza himself claimed had value in receivership when it
came to my debt but seems to be avoiding claiming those assets in this bankruptcy with
knowing deliberate intent to defraud creditors.

Marc RANDAZZAs lawyer Ronald Green from Marcs Law Firm Randazza Legal Group in their
lawsuit against me, abused the power of the courts to harass whistleblowers, churches, pastors,
those I worked with or for in the past, friends, family and more. Ron Gree Subpoened Diana
Grandamason July 28th 2014 via Richard Mockow of The Solomon Law Group, Exhibit C Ron
Green of Randazza Legal Group admits Godaddy Subpoena is improper. Randazza subpoened
CPA whistleblower Stephanie DeYoung, also Verizon for Coxs phone records, Coxs Bank and
more private information about me and my friends, clients and colleagues.

10
A "properly formatted" subpoena is NOT a COURT Order, yet Randazzas attorney Ron Green
of Randazza Legal Group used them as if they were in order to intimidate people into giving him
private confidential about me.

Marc Randazza filed a legal action in Florida against Godaddy in order to further invade my
privacy. I was not named in the legal action, however my Domain names were and Randazza
again abused the power of the courts to circumvent my civil and constitutional rights and due
process rights. (See Exhibit F) Florida 11th Judicial Circuit Court, Civil Action No.
2014-5636-CA.

Law360, Miami (March 5, 2014, 9:44 PM EST) -- A First Amendment attorney has sued three
Web domain-hosting companies, including GoDaddy LLC, in Florida state court Wednesday for
a bill of pure discovery, so he could bring extortion claims against a group of individuals
allegedly behind a collection of defamatory websites.

Marc Randazza, whose firm has offices in Las Vegas and Nevada, says that a group led by
Crystal L. Cox, a blogger at the center of a notable recent defamation case, has conspired to
extort money from him by buying website domain names related to his and his family members'
names, filling them with false and harmful statements and seeking payment for retractions of the
statements.

Wednesday's filing, which lists Randazza, his law practice, his wife and his 3-year-old daughter
as plaintiffs, targets information in the possession of GoDaddy, Web.com Group Inc. and
SoftLayer Technologies Inc. that Randazza says is relevant to his claims against the tortfeasors.

Cox is a well-documented extortionist, Randazza says, also describing her as by her own
claim homeless and living in a church property in Port Townsend, Wash. (Exhibit F)
https://www.law360.com/articles/515754/atty-seeks-discovery-from-godaddy-others-in-extortion-
suit

Also See Exhibit K

This email is to inform you that we have received a properly formatted Amended Complaint in
Equity for a Bill of Pure Discovery for documents in the following civil action: Marc J. Randazza
et al. v GoDaddy, LLC et al. issued by the Miami-Dade County, Florida 11th Judicial Circuit
Court, Civil Action No. 2014-5636-CA. Our response to this subpoena may require us to
disclose some of your personally identifiable information. Therefore, we are providing this
notice as a courtesy to give you an opportunity to object to the Amended Complaint. The only
way to object to a properly filed Amended Complaint is by filing an objection with the court in
which the matter is pending. If you intend on filing an objection, please let us know within 3
business days. If we do not receive an objection notice indicating that you have filed or will be
filing an objection, we will continue with producing the documents requested and may charge
your account according to our registration agreement. Should you require additional time within
which to file your objection with the court, please let us know. Email from Godaddy, Exhibit K.

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See Exhibit O for Page on Marc Randazzas web property / blog where he directed all my
domain names, blogs, intellectual property. In all other legal actions or disputes with domain
names, the domain name is locked until the court case is done. Another words the server stays
as is, it stays in the account it is in and it is LOCKED. In this case the ownership in the registrar
was changed to Randazza, the servers were changed to point to his COMMERCIAL site, and
the names were moved out of the account they were in and put into Randazzas account.

Cox Claims Randazza owed her Fidicuary and Ethical Duties as

a Matter of Law and Nevada Attorney Rules, also see Declaration
of Crystal Cox, Doc. Entry 8 and all Exhibits

Rule 154 Communication; Nevada Code

[1] A lawyer shall keep a client reasonably informed about the status of a matter and promptly
comply with reasonable requests for information.

[2] A lawyer shall explain a matter to the extent reasonably necessary to permit the client to
make informed decisions regarding the representation.

Marc Randazza did not keep me informed, and in fact attempted to make settlement
agreements, he admitted, See Exhibit 9, Crystal Cox Declaration, Doc. Entry 8, that were NOT
what I wanted but what he decided was in my best interest, meaning his. Randazza violated
Rule 154 and has caused me, Crystal Cox, irreparable harm and owes me all allowable relief.

Rule 153 Diligence

A lawyer shall act with reasonable diligence and promptness in representing a client.

Randazza violated this rule and was not diligent in my regard.

Rule 156 Confidentiality of Information

[1] A lawyer shall not reveal information relating to representation of a client unless the client
consents after consultation, except for disclosures that are impliedly authorized in order to carry
out the representation,

Randazza did reveal information related to his representation of Cox.

Rule 157 Conflict of Interest: General Rule

[1] A lawyer shall not represent a client if the representation of that client will be directly adverse
to another client, unless:

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Randazza Legal Group represented one of their own attorneys, Marc Randazza, to sue a former
client, me, Crystal Cox. Randazza has caused me, Crystal Cox, irreparable harm and owes me
all allowable relief.

(a) The lawyer reasonably believes the representation will not adversely affect the relationship
with the other client; and

(b) Each client consents, preferably in writing, after consultation.

[2] A lawyer shall not represent a client if the representation of that client may be materially
limited by the lawyers responsibilities to another client or to a third person, or by the lawyers
own interests, unless:

(a) The lawyer reasonably believes the representation will not be adversely affected; and

(b) The client consents, preferably in writing, after consultation.

Randazza Legal Group violated this Rule in representing Marc to sue me, Crystal Cox and Marc
violated this rule by suing me a former client, or even a potential client.

Rule 158 Conflict of Interest: Prohibited Transactions

[1] A lawyer shall not enter into a business transaction with a client or knowingly acquire an
ownership, possessory, security or other pecuniary interest adverse to a client unless:

Randazza violated this rule and entered into an agreement with RLG to represent him to sue his
former client. Randazza has caused me, Crystal Cox, irreparable harm and owes me all
allowable relief.
Rule 167 Advisor

In representing a client, a lawyer shall exercise independent professional judgment and render
candid advice. In rendering advice, a lawyer may refer not only to law but to other
considerations such as moral, economic, social and political factors, that may be relevant to the
clients situation.

Randazza was at least Coxs advisor, as seen in Exhibits he advised Cox to order transcripts
and of filing for new trial as seen in Exhibit 11 and in Dec. of Cox Doc 8. Randazza has caused
me, Crystal Cox, irreparable harm and owes me all allowable relief.

Rule 172 Candor Toward the Tribunal

[1] A lawyer shall not knowingly:

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(a) Make a false statement of material fact or law to a tribunal;

Marc Randazza lied under Oath regarding me, Crystal Cox, in multiple venues such as WIPO,
the Ninth Circuit, and the District of Nevada. And as seen throughout this declaration and the
COX declaration at Doc. 8 of this case.

Randazza continues to accuse Cox of a campaign of bad faith harassment against the
Randazza family through cyber-extortion. Yet Randazza knows that Cox was not extorting him,
his family nor engaged in a campaign of bad faith as seen in Dec. and Exhibits at Doc. Entry 8,
Randazza himself engaged in a malicious campaign against COX.

Randazza has caused me, Crystal Cox, irreparable harm and owes me all allowable relief.

Coxs appeal in the Ninth Circuit was happening, Marc Randazza affected that case with his
deliberate retaliation and malicious campaign of bad faith. Yes I won the case, However, I was
painted in false light because of Randazza. Randazza even paid for another attorney to
represent Martin Cain to file an amicus brief against me in my Ninth Circuit case, Randazza
himself malicious filed Amicus Brief , and knowingly stated false material facts to a higher court.
Randazza has caused me, Crystal Cox, irreparable harm and owes me all allowable relief.

Randazza therefore violated Rule 177 Trial Publicity

Marc Randazza offered himself up to be deposed by the Opposition in Obsidian v. Cox. Cox
claims this violated her rights. Randazza and Aman were conspiring to harm Cox. Randazza
violated rule 178 and owes Cox all allowable relief.

Rule 178 Lawyer as Witness

[1] A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary
witness except where:

(a) The testimony relates to an uncontested issue;

(b) The testimony relates to the nature and value of legal services rendered in the case; or

(c) Disqualification of the lawyer would work substantial hardship on the client.

I, Crystal Cox was never open to a settlement. I made it clear at ALL times that in Obsidian v.
Cox I was NOT willing to settle as I felt it my duty to move forward and protect the rights of ALL
investigative bloggers, whistleblowers and citizens.

Rule 181 Truthfulness in Statements to Others

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In the course of representing a client a lawyer shall not knowingly:

[1] Make a false statement of material fact or law to a third person; or

[2] Fail to disclose a material fact to a third person when disclosure is necessary to avoid
assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 156.

Randazza has not been Truthful in his statement of others regarding COX and has thereby
caused irreparable harm. Cox alleges she is allowed all available relief and remedy. As
Randazzas lack of Truthfulness has damaged Cox.

Randazza claims he was not my attorney, yet he enlisted Portland Lawyer Lake Perriguey to
assist in the Oregon law part of the case with him. Why do this if he was not holding himself out
as my attorney, or believed he was representing me, Crystal Cox.

Randazza continues to provide this court with my RICO filings in other courts, as some
evidence that I am bad in some way. I am proud of those filings and I did the best I could to fight
corruption, expose corruption and stand for the greater good and for Justice for All. As I have
been doing for approx. 18 years now.

I, Crystal Cox have absolutely No history or record of any kind of extortion. This was made up
by the attorneys in my case, in order to threaten me, intimidate me, bully me, stop my appeal
and make me look not credible as I was exposing their fraud on the court, their crimes, and
their unethical actions to the best of my knowledge and ability.

On March 30, 2015, Mr. Randazza filed an interlocutory appeal from the District
Courts denial of his Anti-SLAPP Motion on timeliness grounds to United States Court of
Appeals for the Ninth Circuit (the Ninth Circuit), where the matter remains pending as Appeal
No. 15-15610 (the Appeal). (RJN, Exs. 58 and 59; ECF 242).10 (Randazza Decl. 56).

I, Crystal Cox, allege that Randazza is guilty of abuse of process, as he sued me, Crystal Cox,
then he wrote the very Nevada Slapp Law he was testing / using on me, so he would have a
precedent to use with his more wealthy clients.

This is unfair at best, and criminal at worst.

The protections of fair and just reporting privilege does NOT apply to Mr. Randazza in this
case. Any statement by Mr. Randazza calling Cox an extortionist is NOT privileged as a fair
reporting of the judicial proceedings in the Obsidian Case. Randazza new the TRUTH, the full
and absolute Truth and is an expert in law, court cases, appeals and the First Amendment. He
knew full well that he was deliberately violating my rights in order to teach me a lesson as he
had threatened in making him my enemy.

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Even if this court were to believe that The only statements that Ms. Cox identifies as
defamatory were made after substantial media coverage of the Obsidian Case, and were in fact
made to some of the people who initially reported on Ms. Coxs behavior. Still Cox alleges
Randazza knew the truth of any alleged allegations and yet he knowingly chimed him as he
explains and maliciously lied about me in order to seal my fate with false material facts.

Randazzas Statements are NOT Protected by the Reply Privilege. They are and were
maliciously known false statements of fact.

Randazza clearly was Negligence, and had Actual Malice regarding Cox as he knew the truth
and was an expert in the industry at question in the case.

Marc Randazza clearly had actual malice, see Declaration of Crystal Cox and all Exhibits.
Randazza flat out accused Cox of extortion in legal documents, sworn statements, interviews
with lawyers, with NPR, Forbes, WIPO and more.

Knowing he did not mind cox asking for job, as Exhibits show, he still maliciously called the
email extortion in order to retaliate against his former client for firing him in what is now the first
of its kind WIN for First Amendment rights of ALL bloggers.

Cox is a Public Figure and does not doubt that, however this does not give Coxs former
attorney Marc Randazza any legal right to maliciously post false statement and to make false
statements to third parties as well as swear to false material facts to the District of Nevada and
to WIPO, as well as other third parties.

There are no adjudicative bodies that have ruled Cox guilty of extortion. In fact Cox has never
been given due process or adjudicated for the allegations of extortion. Randazza simply stated it
as fact, Knowing it was not.

It is NOT a defense for Randazza that others were defaming Cox so it was ok, as a matter of
law, for Marc Randazza to join them, especially with actual malice, willful and malicious intent as
Exhibits of Cox Declaration Doc. 8 clearly show that Marc Randazza supported Cox,
complemented Cox, advocated for Cox, brokered deals on Coxs behalf, and said people like
here were needed and if he could help in ANY way in the future to let him know, as seen in
Exhibits.

Coxs Defamation Claim is NOT Time Barred by the Statute of Limitations. As the false
statements are still online to this day and still defamation. Also Randazza has stalled Coxs
counterclaims for 5 years. Cox claims the damage is cumulative and that Cox is allowed all
relief allowed by law.

Randazza says, Importantly, the attorney-client relationship is based on the subjective belief of
the client. In re Rossana, 395 B.R. 697, 702 (Bankr. D. Nev. 2008). According to Ms. Coxs own

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statements in her 2040 Counterclaim, [o]n this first call . . . Randazza did not commit to
representation. (ECF 164, p. 3). I, Crystal Cox, did believe Marc to be acting as my attorney
In reviewing my files, negotiating with Aman and strategizing with Volokh. I fully believed that all
I told and emailed Randazza was privileged and confidential.

Randazza did take action as Coxs attorney, See Dec. of Cox and Exhibits, Doc. Entry 8
And thereby did have an attorney-client relationship with Cox and did and does owe Cox a duty
not to harm here. Randazza has clearly caused irreparable harm and Cox is allowed all relief
allowed per law.

Cox alleges Randazza did reveal confidential information.

I fired Randazza, my declining was after he was already acting as my attorney, as clearly
shown in exhibits. I fired him because he was not honoring my wishes and attempting to run
over my rights. I later told Volokh Randazza did not represent me, because of his behavior and
not that he was never representing me.

There was NO attorney General Complaint against Cox in Oregon. The Oregon AG told Cox
there was no complaint whatsoever. That too was a false material fact. See Exhibit D.

Zirzow Defames and Criticizes my Ministry in Recent Motion

For some reason Randazzas attorney Matt Zirzows motion for Default, he seemed to be
slamming my church, my ministry, and questioning whether I have or had the right to use the
name, title Reverend Crystal Cox. (See page 1 21-25, Case 16-01111-abl Doc 26)

I find this discriminating and offensive, as well as using an official court filing to continue to slam
and defame me, discredit me. Marc Randazza filed his WIPO complaint against Domain names
owned by my WA registered DBA Reverend Crystal Cox, which I registered in early 2012.

I Move to Sanction Matt Zirzow for his intimidation and disrespect regarding my ministry and my
non-profit corporation, my Lifes work.

BRINGING BACK GODDESS CHURCH LLC is my church name, WA State UBI 603388411,
EIN 46-5093790, a registered charity and a 501(c) Non-Profit Corporation as of March of 2014.
Before that I ran my ministry under a DBA, first in MT than in WA.

The DBA Reverend Crystal Cox, of which owned the Domain names Marc Randazza took, and
is my business/ministry DBA I registered in WA in 2012, Randazza later sued me, Crystal L.
Cox even though my DBA, Sole Proprietor business owned the domain names. Yet I was unable
to counter sue his business DBA Randazza Legal Group, of which I should be entitled to relief
from that Entity as well, as it was the law firm that represented me in my case, at the VERY
least as a potential client and owed me at least to do no harm.
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Marc Randazza filed a WIPO complaint with false statements and a Czech Complaint (See
Czech Arbitration Court 2012-07-08 Administrative Proceeding No. 100472
UDRP proceeding administered by the CAC Tereza Bartokov. In Both of those Complaints
Randazza clearly knew that my DBA, my Business, Reverend Crystal Cox owned the domain
names, yet he Sued me individually as Crystal L. Cox, as did his wife and toddler. I was not
allowed to include his Business Randazza Legal Group in my countersuit, I ask this court to
reconsider and allow my claims against Randazza Legal Group as well.

I have been in the ministry for my entire life, having been Ordained the first time at 16. My
church is all denominations and my plan for my church was stopped by the damage Marc
Randazza did to my life and my ability to create money and build my church as I had hoped. I
have continued my spiritual work to the best of my ability, even being homeless. I help people
every single day in every way I can. I have and do perform weddings and funerals as well as
give sermons and have an online church and following.

I have studied in depth many religious beliefs, doctrines and followings my entire life. I had clear
vision as a child from what I deemed as God, this is very real for me and a lifetime calling. Marc
Randazza has tormented my ministry and has made fun of my title relentlessly, as recent as his
last filing (See page 1 21-25, Case 16-01111-abl Doc 26).

As of July 2014, I have 4361 IRS Exemption and Federal Status as a Minister.

The Domain Names Randazza took from me in an unconstitutional TRO were owned by my
Business, DBA, Trade name Reverend Crystal Cox (Exhibit R)

I ask this court to Sanction Zirzow for making fun of my ministry, and projecting more
defamatory hate at me in this regard. At the least this shows the pure hate and discriminatory
bias that Randazza and his counsel have me. I ask this court to award me all allowable relief.

I have been many places, church sponsored for my ministry work, until Randazza tormented
and threatened my associate church and they stopped sending me on church mission projects.
Stopped helping me with food and shelter. Randazza even used my private, confidential church
records as a way to attempt to prove I had money of some sort, of which I did not and in fact
lived in hostels and my vehicle for years. Right now I am still without a home or way to get by
because of all of my colleagues Randazza contacted and threatened to sue, harassed and that
added to his malicious media campaign to paint me in false light, as well as deliberate false
statements as material fact in sworn court filings such as the District of Nevada and the Ninth
Circuit Appeals Court.

In April of 2012 Marc Randazza filed for a Protective Order in Las Vegas Courts, in order to stop
me from speaking critical of him online. This was later dismissed for unknown reasons.

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An Examination of All Relevant Facts Weighs Heavily in Favor of Granting Cox all allowable
relief as a matter of law, for the irreparable damage Randazza has done.

Please Also See Declaration, Docket Entry 8 with ALL attached Exhibits for proof of Coxs
claims against Marc Randazza.

I declare that all of the above is true to the best of my knowledge.

November, 6th, 2017

/s/ Crystal L. Cox

Crystal L. Cox, Pro Se Defendant / Counter-Plaintiff / Creditor
Investigative Blogger, Victims Advocate, Reverend

Crystal Cox Contact Information:

Current Temporary Mailing Address

Crystal L. Cox
C/O Eliot Bernstein
2753 Northwest 34th Street,
Boca Raton, FL 33434

Permanent eMail: SavvyBroker@yahoo.com AND ReverendCrystalCox@Gmail.com

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 Certificate of Service

November, 6th, 2017

I certify I sent this Declaration to:

Clerk of Court
U.S. Bankruptcy Court
District of Nevada
Foley Federal Building
300 Las Vegas Boulevard South
Third Floor, Courtroom #1
Las Vegas, NV 89101

/s/ Crystal L. Cox

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