Defendant Cox's Reply to Plaintiff's Opposition to Docket Entry 91 / Opposition to "RICO" Complaint Filing

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Defendant Cox's Reply to Plaintiff's Opposition to Docket Entry 91 / Opposition to "RICO" Complaint Filing Powered By Docstoc

Crystal L. Cox
Pro Se Defendant
Case 2:12-cv-02040-GMN-PAL

                               UNITED STATES DISTRICT COURT
                                    DISTRICT OF NEVADA
                                 Case 2:12-cv-02040-GMN-PAL

Plaintiff, Counter Defendant Marc J. Randazza /

                                                        Reply to Response in Opposition to ECF 91

Defendant Crystal Cox and Defendant Eliot Bernstein

I Crystal Cox have filed a Separate Lawsuit, and if it is not filed properly, I request this court’s
assistance to help me file this claim properly, as I have been denied filing a counterclaim and
cannot afford a filing fee nor to serve defendants and have a legitimate right to due process.

I, Pro Se Litigant Crystal L. Cox, have a right to file a claim against Plaintiff for the actions he
has taken in conspiracy against me that has, in fact, caused me irreparable harm. This court
gave me the remedy of filing a “separate lawsuit”, Docket Entry 91 is this filing, the only way I
had access to file this legal action. If this court finds that my filing is not “proper” then I request
that this court file this complaint in a “proper” fashion and grant me electronic access to the
new claim. I have a legal right and have properly created and filed this claim to the best of my
ability and as respectful of this court as I can.

Plaintiff cannot avoid this legitimate claim against them by striking my every motion or word.
This court should not make me mail in this complaint nor file it in another state, as this court is
the most practical and cost effective way to bring this case about, seeings how there is
already so much under way.

Plaintiff filed a frivolous, costly legal action against Pro Se Litigant Crystal L. Cox, which cost
me business, massive stress and irreparable damage, even though Plaintiff, as a Trademark
Lawyer, knew he did not have a Trademark as the lawsuit suggests and Plaintiff admits to in
the motion for Summary Judgement Against Defendant Crystal Cox. Plaintiff should not be
able to simply ruin someone’s life and in conspiracy with others and not be held accountable in
a court of law. Plaintiff was acting as my attorney at one point, Plaintiff really did intentionally
defame me and ruin my reputation.


And I, Pro Se Litigant Crystal L. Cox, have a right to a remedy of this unjust action by seeking
financial relief from the irreparable damage and undo stress Plaintiff and Alleged
Co-Conspirators has put on me, my business, my reputation and my life. Plaintiff accused me
of Civil Conspiracy, my Counterclaim, now filed as a Separate Lawsuit addresses that it is
indeed Plaintiff himself involved in a Civil Conspiracy. I, Pro Se Litigant Crystal L. Cox, have a
right to due process of law and to seek claims against Plaintiff and Alleged Co-Conspirators.

Defendant Crystal Cox filed a Counterclaim with legitimate concerns, and filed it as proper as
she knew how to as a Pro Se Litigant

I, Pro Se Litigant, Crystal Cox have filed a Separate Lawsuit to address the issues I raised in
the counterclaim, as Judge Gloria Navarro RULED in a Court Order that I Do So.

I, Pro Se Litigant, Crystal Cox have filed this lawsuit properly and request this court to file the
Complaint that, this court, ordered me to file separately, for me, in Forma Pauperis. I am
unsure how to file this separate complaint as requested by this court. I cannot afford to print
and mail this complaint nor the court filing fee or the Summons for each defendant. I, Pro Se
Litigant Crystal Cox have a legitimate claim and wish to file this complaint as this court case
Judge ordered me to, via Docket Entry 89.

Defendant Crystal Cox's request, complaint filing, should not be disregarded. I should not
have to mail in this complaint after having permission to electronically file for over 2 months.
Plaintiff is attempted to BLOCK my constitutional rights at a counterclaim, court order to be
filed as a separate unrelated legal action. There is no way for this to be unrelated, as it
involves this case. Court Order Docket 89 Says, “Defendant's Counter Complaint is
STRICKEN. Defendant may only file her Counter Complaint as a separate lawsuit. Signed by
Judge Gloria M. Navarro on 2/22/13.” I, Pro Se Litigant Crystal Cox Did So and now Plaintiff
wants to Block this as well, even though the Judge in this case filed an "ORDER" that ordered
me to do so.

Judge Gloria Navarro DENIED Pro Se Plaintiff Investigative Blogger Crystal L. Cox to file a
counterclaim in District of Nevada Case 2:12-cv-02040-GMN-PAL. Docket Entry Number 89
(ECF Nos. 48 and 63), Dated February 22nd 2013, Signed by Judge Gloria M. Navarro of
District of Nevada Case 2:12-cv-02040-GMN-PAL states, “Defendant's Counter Complaint
is STRICKEN. Defendant may only file her Counter Complaint as a separate lawsuit. Signed
by Judge Gloria M. Navarro on 2/22/13.” Therefore Pro Se Litigant Crystal Cox has filed a
separate Judicial Ordered / Court Ordered claim. "separate lawsuit" as per instructions and
court ruling.


This Complaint is not "unrelated", the claims are related. Plaintiff was acting in conspiracy to
silence me and defame me, intimidate and harass me. He had no Trademark and he knew it,
then why sue me? Plaintiff sued me and Eliot Bernstein for the issues raised in the New
"separate lawsuit", it is not unrelated and is a serious matter that this court should take
serious. I apologize for the proper procedure and legal ease I do not know, I am doing the
best I can to defend myself and to protect the public at large.

Plaintiff claims this file is "only a waste of Plaintiff's time", however Plaintiff is the one that
sued me, got an unconstitutional Preliminary Injunction in which caused me massive,
irreparable damage, cost me time money, and quality of life and all with no legitimate
Trademark as admitted in motions filed with this court.

Plaintiff attacked Eliot Bernstein, whom received those domain names in receivership, of
which now that Plaintiff has stolen the names, I Crystal Cox have Debt, once again to Eliot
Bernstein. Then Plaintiff wishes to fine Eliot Bernstein $500,000 and $23,000 for Plaintiff's
Attorney, even though Plaintiff is also acting as his own attorney, which in and of itself is a
huge liability and unethical, especially seeings how Plaintiff, was an attorney who negotiated
on behalf of Defendant Crystal Cox in regard to the very same issues brought up in this
lawsuit against Crystal Cox.

Plaintiff files frivolous litigation, ruin lives and then claims that anyone fighting back does not
have the right to, this is unjust, unfair, unlawful, and unconstitutional.

I have not consented to Electronic Filing being Revoked, Plaintiff has not right to make this
request and I have objected in prior motions. This court can revoke my Electronic privileges
and force me further cost and court time and money for me to print and mail all documents,
however that is to the detriment of the taxpayer and the courts time and money, which Plaintiff
claims to have concern over in stating that my "separate lawsuit" is costing the court money.

Plaintiff is a vexatious litigant, a dangerous and unconstitutional litigant and has caused
Defendant Crystal Cox continual harm and put my life and livelihood in danger. This Court
should Sanction Plaintiff as he is an attorney and sanction his attorney Ronald D. Green, and
this court should consider stronger corrective action, as this is a serious matter.

I, Defendant Crystal Cox, have kept a very good record of every docket entry and filing and
intend to file an appeal with the Ninth Circuit in Forma Pauperis, as to every decision made in
this court that has violated my rights.

I am soon filing criminal complaints, bar complaints, judicial complaints and a Notice of Claim
for Unconstitutional Law with the Department of Justice.


This court has taken my rights of Due Process, violated my First Amendment Rights, caused
me irreparable harm and allowed Plaintiff Marc Randazza to flat out lie about me, threaten me,
bully me, steal my property, incite hate and gives me, Pro Se Litigant Crystal Cox no remedies
of law, no constitutional rights and no due process.

Plaintiff Admitted in a Filing for Summary Judgement that he has no Trademark, therefore
admitting that this lawsuit was filed only to seek revenge, cause irreparable damage, defame
me, threaten me and intimidate me. Yet Judge Gloria Navarro FORBID me to file a
counterclaim in this case, as is my lawful, constitutional right.

Judge Gloria Navarro has tied my hands and forced me to only answer to the claims that
Plaintiff has issued against me, this is a violation of my rights. I object to this, however, Judge
Gloria Navarro does not allow me to object, request or have any rights as a Pro Se Litigant,
instead Judge Gloria Navarro favors the Plaintiff. My only remedy is to appeal to a higher
court and hope for equal treatment outside of the District of Nevada.

Plaintiff should not be above the law and have special protection and Privileges simply
because he is an attorney.

I Pro Se Defendant Crystal Cox have raised valid and important claims and I have right to due
process. Judge Gloria Navarro knows that I filed to move forward in Forma Pauperis, she
removed my right to file a counterclaim, which is a further violation of my rights

Judge Gloria Navarro in Docket Entry 89, Ordered me, Defendant Crystal Cox to file a new
answer to the complaint, though I filed my original answer months ago.

Judge Gloria Navarro also ordered me, Defendant Crystal Cox , to file a separate lawsuit
instead of a counterclaim, I did so, and started a new claim within the Electronic System, it
was number 2:13-cv-00297, however I am not allowed to enter a new claim electronically and
must go through the expense of printing hundreds of pages, paying to mail the complaints and
a filing fee of $350. Judge Gloria Navarro did this to me, in order to cause me hardship and
deter me from filing a complaint that exposed her and Plaintiffs.

I have been ordered to file a separate lawsuit, and I have done so, this court should file this
claim as I was ordered to file it separate AFTER I filed to proceed in Forma Pauperis.

If this court strikes yet another form of my due process, then I am forced to mail in this
complaint and to appeal to higher courts, however, still it must be made known how this court
has treated Pro Se Litigant Crystal Cox, it is not lawful nor constitutional, in hopes of
protecting future victims of this court and this Plaintiff.


I, Defendant Crystal Cox, have filed a valid claim, and a RICO Statement. This is an important
matter and yet I am not taken seriously because I am a Pro Se Litigant and Plaintiff is an
attorney, who has an attorney from his own law firm representing him, yet he also contacts
witnesses to threaten and intimidate them, acting as his own attorney.

Judge Gloria Navarro has endangered my life, caused damage to my online media, caused
me undo stress, allowed Plaintiff to Defame me and all with an unconstitutional Preliminary
Injunction. I, Defendant Crystal Cox, was court ordered to file a “separate lawsuit” and so I
have done so.

My only remedy now is to file criminal complaints, judicial complaints and appeal to the Ninth
Circuit. Meanwhile Plaintiff keeps defaming me to this court and violating my constitutional and
lawful rights.

Plaintiff has violated my rights, bullied me, threatened me, stripped me of my constitutional
rights, defamed me, used confidential information to cause me harm and has flat out lied to
this court about me, yet Judge Gloria Navarro continues to protect Plaintiff, do as he wishes
in complete disregard of the laws of the United States and the Constitution of the United
States of America. This is an outrage and the public at large has a right to know how Marc
Randazza is controlling this court.

I, Defendant Crystal Cox, may not use all the right language, but I have rights and legitimate
complaints. Judge Gloria Navarro claims that have said derogatory things in motions and she
has stricken them, meanwhile Plaintiff lies about me, threatens me and my intimidates my
sources, defames me, abuses the courts, commits fraud on the courts and she allows Plaintiff
to file whatever they want and gave Plaintiff an Unconstitutional Preliminary Injunction that
cause me massive irreparable damage

Judge Gloria Navarro has protected this Attorney in the past in the Righthaven case, the Via
View Case, and the Liberty Media Case. I have reason enough to request a new judge and
have been denied this right over and over, meanwhile I have been stripped of my rights of due
process and though I have been severely damaged by this case, and the lies told here, I have
no right to file a counterclaim. This is a violation of law and of the constitution. I have done
nothing wrong, immoral or illegal. I am an investigative blogger exposing corruption and trying
to make the world a better place, and this court continues to punish me, and let the Plaintiff do
as he pleases to my life, my livelihood, my quality of life, my business, my intellectual property,
and my reputation.


Plaintiff lied to this court about a bond, Plaintiff said I sold questionable supplements and now
the only way I have left to make a living at all has been tarnished, Plaintiff has used this court
as his private judge and jury and retaliation process and Judge Gloria Navarro has allowed
Plaintiff to cause me irreparable harm and has DENIED my a remedy by law to file a counter

Judge Gloria Navarro, in a court order told me, Defendant, Counter Plaintiff Crystal Cox to file
a separate lawsuit, knowing full well that this would cause me a hardship to print out these
documents and mail them to the courts, plus pay a filing fee. She did this to BLOCK my way of
due process of law and protect this Plaintiff, who is a Las Vegas Attorney.

I have a right to Due Process of Law and should not have to mail in this complaint, I filed as
per court order, in such a way as to cost me and the court further money and time.

                              CERTIFICATE OF SERVICE

I hereby certify that the foregoing document was filed using this Court’s CM/ECF
system On February 25th, 2013 and a copy emailed to named Defendants.

Respectfully Submitted
Pro Se Plaintiff / Pro Se Litigant Crystal Cox
Crystal L. Cox


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Description: Defendant Cox's Reply to Plaintiff's Opposition to Docket Entry 91 / Opposition to "RICO" Complaint Filing.