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Plaintiff Files Opposition to Defendant Crystal Cox's Motion for a Protect Order

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					      Case 2:12-cv-02040-GMN-PAL Document 51                  Filed 01/17/13 Page 1 of 3



 1 Ronald D. Green, NV Bar #7360
     Randazza Legal Group
 2 6525 W. Warm Springs Road, Suite 100
     Las Vegas, NV 89118
 3 888-667-1113
 4 305-437-7662 fax
     ecf@randazza.com
 5
     Attorney for Plaintiffs
 6 MARC J. RANDAZZA, JENNIFER RANDAZZA, and NATALIA RANDAZZA
 7
 8                                UNITED STATES DISTRICT COURT

 9                                        DISTRICT OF NEVADA

10                                                      )
   MARC J. RANDAZZA, an individual,                     )   Case No. 2:12-cv-02040
11 JENNIFER RANDAZZA, an individual, and                )
   NATALIA RANDAZZA, a minor,                           )   PLAINTIFFS’ OPPOSITION TO
12                                                      )   DEFENDANT CRYSTAL COX’S
                    Plaintiffs,                         )   MOTION REQUESTING PROTECTIVE
13                                                          ORDER
                                                        )
14          vs.                                         )
                                                        )
15 CRYSTAL COX, an individual, and ELIOT                )
     BERNSTEIN, an individual,                          )
16                                                      )
17                  Defendants.                         )

18
            Plaintiffs Marc J. Randazza, Jennifer Randazza, and Natalia Randazza, through counsel,
19
     hereby submit this response in opposition to Defendant Crystal Cox’s Motion Requesting
20
     Protective Order.
21
            As if it were not abundantly clear on its face, Defendant Cox’s claims that she is in fear for
22
     her life and requires a protective order against Marc Randazza and his counsel are unfounded.
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     Plaintiffs believe that Cox’s arguments are so unmeritorious that Plaintiffs decline to specifically
24
     address them in this Opposition. If the Court believes that Cox’s specific allegations should be
25
     addressed, Plaintiffs will do so upon the Court’s request.
26
27
28
                                                       1
      Case 2:12-cv-02040-GMN-PAL Document 51                           Filed 01/17/13 Page 2 of 3



 1          Plaintiffs’ counsel Ronald D. Green has attempted to contact pro se Defendant Cox twice to

 2 schedule a phone call to confer about a discovery plan, as is required within thirty days of the filing
 3 of an answer pursuant to Local Rule 26-1:
 4          The parties shall meet and/or confer as required by Fed. R. Civ. P. 26(f) within
            thirty (30) days after the first defendant answers or otherwise appears. Fourteen
 5          (14) days after the mandatory Fed. R. Civ. P. 26(f) conference, the parties shall
            submit a stipulated discovery plan and scheduling order.
 6
 7 LR 26-1(d). A copy of both emails Plaintiffs’ counsel sent to Cox are attached as Exhibit A.
 8 Given that Cox has represented herself previously in the Obsidian Finance, LLC v. Cox case, Cox
 9 likely is already familiar with the discovery process. Defendant Cox’s assertion that Plaintiffs’
10 attempt to comply with discovery rules is somehow a veiled threat to her safety is unfounded and
11 offensive.
12          Plaintiffs respectfully request this Court deny Cox’s Motion Requesting Protective Order,

13 and that the Court issue an order not only denying the motion, but admonishing Cox that further
14 frivolous notices will be met with sanctions.
15
16 Dated: January 17, 2013                            Respectfully submitted,

17                                                    /s/Ronald D. Green
                                                      Ronald D. Green, NV Bar #7360
18                                                    Randazza Legal Group
                                                      6525 W. Warm Springs Road, Suite 100
19                                                    Las Vegas, NV 89118
                                                      888-667-1113; 305-437-7662 fax
20                                                    ecf@randazza.com
21
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                                                            2
                                        Plaintiffs’ Opposition to Protective Order
Case 2:12-cv-02040-GMN-PAL Document 51   Filed 01/17/13 Page 3 of 3
Case 2:12-cv-02040-GMN-PAL Document 51-1   Filed 01/17/13 Page 1 of 3




             EXHIBIT A
                   Case 2:12-cv-02040-GMN-PAL Document 51-1            Filed 01/17/13 Page 2 of 3



                                                                                            Correspondence from:
                                                                                            Ronald D. Green, Esq.
                                                                                            rdg@randazza.com

                                                                                            Reply to Las Vegas Office
MARC J. RANDAZZA                                                                            via Email or Fax
Licensed to practice in
Massachusetts
California
Nevada
Arizona
Florida                                                                                       January 11, 2013
RONALD D. GREEN
Licensed to practice in      Via Email Only
Nevada
                             <crystal@crystalcox.com>
JASON A. FISCHER             <savvybroker@yahoo.com>
Licensed to practice in
Florida
California
U.S. Patent Office           Crystal L. Cox
                             PO Box 2027
J. MALCOLM DEVOY
Licensed to practice in      Port Townsend, WA 98368
Wisconsin
Nevada

BETH A. HUTCHENS
                                    Re: L.R. 26-1, Randazza v. Cox, 2:12-cv-02040 (D. Nev.)
Licensed to practice in
Arizona
U.S. Patent Office           Dear Ms. Cox:

                             Pursuant to Local Rule 26-1, parties in an action must meet and/or confer
                             regarding a discovery plan within 30 days of the filing of an answer by a
                             defendant. In relevant part, the Rule states:

                                    The parties shall meet and/or confer as required by Fed. R. Civ. P.
                                    26(f) within thirty (30) days after the first defendant answers or
                                    otherwise appears. Fourteen (14) days after the mandatory Fed. R.
                                    Civ. P. 26(f) conference, the parties shall submit a stipulated
                                    discovery plan and scheduling order.

www.randazza.com             LR 26-1(d). According to the Local Rules, this means we must set up a
                             telephonic conference in the next few weeks. If the timing is convenient for you,
Las Vegas
6525 W. Warm Springs Rd      I would like to schedule a telephone conference with you to discuss a stipulated
Suite 100                    discovery plan the week of January 21-25. Please let me know what date would
Las Vegas, NV 89118
Tel: 888.667.1113
                             be best to schedule the meeting.
Fax: 305.437.7662

Miami
2 S. Biscayne Boulevard                                   Best regards,
Suite 2600
Miami, FL 33131
Tel: 888.667.1113
Fax: 305.397.2772

Phoenix
Two Renaissance Square
40 North Central                                          Ronald D. Green
Suite 1400
Phoenix, AZ 85004
Tel: 888.667.1113
Fax: 305.437.7662
                   Case 2:12-cv-02040-GMN-PAL Document 51-1            Filed 01/17/13 Page 3 of 3



                                                                                             Correspondence from:
                                                                                             Ronald D. Green, Esq.
                                                                                             rdg@randazza.com

                                                                                             Reply to Las Vegas Office
MARC J. RANDAZZA                                                                             via Email or Fax
Licensed to practice in
Massachusetts
California
Nevada
Arizona
Florida                                                                                       January 15, 2013
RONALD D. GREEN
Licensed to practice in      Via Email Only
Nevada
                             <crystal@crystalcox.com>
JASON A. FISCHER             <savvybroker@yahoo.com>
Licensed to practice in
Florida
California
U.S. Patent Office           Crystal L. Cox
                             PO Box 2027
J. MALCOLM DEVOY
Licensed to practice in      Port Townsend, WA 98368
Wisconsin
Nevada

BETH A. HUTCHENS
                             Re: L.R. 26-1, Randazza v. Cox, 2:12-cv-02040 (D. Nev.)
Licensed to practice in
Arizona
U.S. Patent Office           Dear Ms. Cox:

                             On January 11, 2013, I sent you correspondence requesting that you provide your
                             availability to participate in the court-required telephonic conference to discuss
                             the discovery plan for the case. Thus far, we have not heard from you. As stated,
                             we are hoping to have the conference during the week of January 21, 2013. While
                             the concerns that you have expressed regarding your safety are unfounded, as a
                             concession, I would consent to you recording the conversation. If you choose to
                             do so, please be aware that I would do so also.

                             Your prompt response is appreciated.

www.randazza.com
                                                          Best regards,
Las Vegas
6525 W. Warm Springs Rd
Suite 100
Las Vegas, NV 89118
Tel: 888.667.1113
Fax: 305.437.7662

Miami
2 S. Biscayne Boulevard
                                                          Ronald D. Green
Suite 2600
Miami, FL 33131
Tel: 888.667.1113
Fax: 305.397.2772

Phoenix
Two Renaissance Square
40 North Central
Suite 1400
Phoenix, AZ 85004
Tel: 888.667.1113
Fax: 305.437.7662

				
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