9 10 ul 15 16 7 Electronically Filed 08/16/2016 03:42:45 PM Alen tem STAT CLERK OF THE COURT ‘Alexandra Mayers 623 NW 47" Terr Deerfield Beach, FL 33442 702-937-2123 alexandramayers @ yahoo.com Defendant, In Proper Person EIGHTH JUDICIAL DISTRICT COURT CLARK COU TY, NEVADA Jennifer Lynne Randazza Case No.:A-14-699072-C Plaintiti(s), Dept. No 32 vs. Statement: Michael Strother states who posed as Jennifer Randazza Alexandra Mayers requesting my help, after Randazza Legal Group offered their services to Defendant(s), Strother to file a lawsuit against me On August 16, 2016 porn industry blogger Michael Strother aka Mike South of www. MikeSouth,com wrote a post (exhibit A) stating that Sean Matthew Tompkins and Ari Scott Bass posed online (trolled me) as Jennifer Randazza — which is what led me to post the tweets in question (exhibit B) that this lawsuit is based on, Thave been told by another porn industry blogger known as Kelli Roberts, that Randazza Legal Group was involved in Sean Matthew Tompkins’ acquisition of a website called Ari Scott Bass aka Michael Whiteacre was on the initial witness list sent to me from Jennifer Randazza’s legal council (exhibit C). The domestic and international organization, the Aids Healthcare Foundation, re ntly released a press released which states that Michael Strother aka Mike South is a credible blogger / journalist (exhibit D). Page 1 of 49 10 ul 15 16 7 18 24 25 Michael Strother told me on Twitter August 13, 2016 that he would take up Mr. Randazza (Mare Randazza’s) offer to sue me if I did not delete the claims I posted online about him being a pimp and being involved in sex trafficking (exhibit E). Michael Strother aka Mike South has also stated that to me via email (exhibit F) as of August 15, 2016 that if I don’t apologize to him for stating that he is a pimp (even though he labeled himself a pimp as of December 4, 2002 and November 26, 2002: exhibits G - H) and involved in sex and human trafficking, that he will sue me, Michael Strother aka Mike South has a multitude of posts (some in which he recruited civilians for his Bukakke pornographic adult movies which are filmed in Atlanta, Georgia), on a website called www.USAsexGuide.info (a website that labels itself as a sex travel / sex tourism guide, Sex Tourism is a form of human and sex trafficking). Strother vouched for illegal prostitute’s sexual performances on the website's forum and offered recommendations to other posters of the website who were secking to illegally purchase sex (exhibit D. In addition from 2002 to 2011 Mich: || Strother operated a website called www. StueetsOfAtlant om (exhibit J) which showeased photographs and stated the exact streets in Atlanta where illegal prostitutes could be located, Strother stated on his own blog MikeSouth.com (exhibit K) that he gained financially from the sexual exploitation of illegal prostitutes, being that the photographs he took of them drew online traflic to his website, which converted into sales of his pornography on his “pay sites”. Michael Stother aka Mike South emailed me September 5, 2014 (exhibit 1) stating that Mare Randazza was receptive to the idea that someone was impersonating Jennifer Randazza wgainst me if 1 and that he felt he could arrange for Mare Randazza to drop this lawsuit apologized, Lastly, August 16, 2016 at 2:20pm (PST) Michael Strother aka Mike South sent me an email stating that “several people” are offering him money to get a judgment in Georgia against me to take all of my websites (exhibit M). Considering Mare Randazza’s offer to Michael Strother to file a lawsuit against me, I believe that Mare Randazza’s and that of Randazza Le} 11 Group’s actions are that criminal conspiracy & illustrate the abuse the United States judicial system to intimidate me, silence my work on the truth of pornography and organized crime (namely sex and human trafficking), harass me and extort money from me via a legal judgment. Page 2 of 49 10 ul 15 16 7 18 24 25 DATED this 16th day of August, 2016. Pursuant to NRS 53.045, I declare under penalty of perjury that the foregoing is true and correct, Alexandra Mayers sf Alexandra Mayers Defendant, In Proper Person Page 3 of 49 10 ul 15 16 7 18 24 25 CERTIFICATE OF SERVICE Thereby certify that a correct and true copy of this foregoing document was served on this 16th day of August 2016 and served via email: Alex J. Shepard of Randazza Legal Group LLC 4035 S. El Capitan Way Las Vegas, NV 89147 ajs@randazza.com Page 4 of 4Exhibit ABio ses wave Aner _— Ree - 3c uth - South af he pen 5 whichis Dio, Ba sida is urge, eng agent he mau. ree stars Shioniy 6h ESB chaos Monica Foster Gone Too Far? [Phase been facing some trigh eeceons ofa Inne Thave Monies Foster makong & stateman hat am dcecty in hacged,miochfss camactad amounts to per sie As fre jvedin naman trafickng, Sorumhing sbharcent tm ms. and ance F Nave newer bee jas lng at statute peraining te etamaen can serve ber ak hake het answer T gave har he option to retract apologize an move on she refused ste Monica hae substance abuse ane other marta ssies [have been very lalent rhe vin, bot evetualy [have te era iw the sand an say enn is enough Thing sThve been atting bi ice te Monica, eve back when she defarned Marc Ranaczas wif, [told her that she had been oles, that he soc media sccbure that se thought ae Ranaazzas fe a Teall eet ap by Michael Whteacrs and Sean Tompkins snd sat thay Belled hee to mabe seater about Fandaceas vte that they kien fe woul ot i fer, ba tones cowie’ aa that ae was wrong she ching to the Wo hat At coat hae tare tan 56,990 ‘3 Mdgereot hat has, ar aly wont be saised, unless she wins the fttery. ae ts dum ow betes Be Som einnaatExhibit BMonica Foster ~ Feb t it's amazing how many #atte: . their wives & girlfriends into + Monica Foster Tonight | met a woman named Jennifer Randazza who finally is leaving the world of Sorganizedcrime & prostitution. Sperm #nev Fel xpand Monica Foste: _ if you have a # iBett to get her this “book by pic twitter comval OBY ydExhibit COw wm we te NRCPD Ronald D. Green (Nev. Bar No. 7360) Alex J. Shepard (Nev. Bar No. 13582} RANDAZZA LEGAL GROUP, PLLC 3625 S. Town Center Drive, Suite 150 Los Vegas, NV_ 69135 Telephone: 702-420-2001 Facsimile: 702-420-2003 ect@randazza.com DISTRICT COURT CLARK COUNTY, NEVADA Case No.: A-14-699072-C JENNIFER RANDAZZA, an individual, Dept. No. 32 PLAINTIFF'S NRCP 16.7 INITIAL DICLOSURES Plaintiff vs. ALEXANDRA MELODY MAYERS, afkia MONICA FOSTER, an. individual, JANE DOE, and JOHN J } } } } } } J } } DOE, } } } Defendants. Pursuant fo Nev. R. Civ. P_ 16.1{a}{1} Plaintiff JENNIFER RANDAZZA hereby produces the following documenis and witness list. 1.0 INDIVIDUALS LIKELY TO HAVE INFORMATION DISCOVERABLE UNDER NRCP 26{b). Based on information known to Plainfiff at this time, the following individuals are likely to have discoverable informatian: 11 Jennifer Randeza c/o Randazza Legal Group, PLLC 3625 S. Town Center Drive, Suite 150 Las Vegas, NV 89135 702-420-2001ee ary ee} 12 13 Jennifer Randazza is the Plaintiff in this action and is expected to have knowledge and information regarding the facts and circumstances of this case, the allegations against Defendant, and the accuracy of the defamatory statements made by Defendant, Alexandra Mayers: 480 W. Bonanze Rood Las Vegas, NV 89106 Alexandra Mayers is the Defendant in this action and is expected fo have knowledge and information regarding the facts and circumstance and the allegotions against Defendant in this litigation. Ari Scott Bass Las Vegas, NV Mr. Bass is expected fo have knowledge and information regarding the facts ond circumstances related to the numerous claims of iliegal activity made by Mayers in her Answer and Motion fo Dismiss. Plaintiff additionally designates as a witness ony witnesses designated by any party, as well as any person whose identity becomes known during the coune of discovery. DOCUMENTS DISCOVERABLE UNDER NRCP 2é{b}. 20 21 22 23 Documents containing Twitter postings fram Defendant Mayers. Documents containing Defendant Mayers’ and related posts on the website Gewishdit.com>. Whois records for the domain name .Exhibit Dwww businesswire.com/n: 3305005 oN Business Wire’ A Bextshes Htiawnny Company HOME Search Mike South, Respected Porn Industry Blogger, Endorses Prop. 60, California Condom Ballot Measure LOS ANGELES. ainment industry today, ike d industry blogger, has endorsed Proposition suy Aci, the November 2016 Calfornia ballot measure that wil clanily.and strengthen existing state and tederal taw Fequire condom use by adult industry performers working in Castornia, nthe Adu hat aymous website, That Su of out in guppe out in Suppor ww makes @ South, a longtime and | Here ss Wty,” South wrote: sport Prop. 60, cote out in support of Prop €0. There is an AWFUL LOT of WP Tweot th mistoformetion about this measure. Dut when you read it and consider it an consider what does and fust as imporanty does NOT de sense es cone n seovle NUS fs just plaio wong falter South ated wessorsibie Bena: industry}. 38 any wonder that ve are fghting Bus t are dou igen ming?” 7 of producers and certam pertormers ia the aed Bie singe treth 38, Can you look at this industry and say what wewww. businesswire.com nev € ON A [ee Badin Hathawey Company ‘Come on people this is just plain wrong fatter South ofed responsible behavior of producers and certain performers in the industry}, is ¢ any wonder inat we are fighting this fight and ine simple trita ts, can you look at tis industry and say that we are doing the sight thing?” J Ris post, South afso torcefurly debunks the “sue a porn pettormer mythology that the Free Speech Coalition (SC), the porn producers’ sade group leading the oppostion to Prop. 69, has Deen promoting to inekte fear and misunderstanding among performers. “We are glad to fet Mike South’s own words—a bistering indictment of the Indust. ever there was one—speak for 'S and mssinformation continually promulgated by the porn industry regarding portant ballot measure,” said Rick Taylor, Campaign Director ‘themselves in exposing the hypocrisy, i Proposition 89 and thank him for his bold endorsement of this im for the Yes on Propostien 60° campaign, FAIRACA advocates noie that Inial and recent siatewkle poling # conducted suggests over 70% of voters agree wih the baliot measute—far more than the 87% of LA volers® who passed Measure 8, a similar ballot measure In Los Angeles County in 212 * Measure 8 passed in November 2012 with 1,617.006 votes in favor (87%) vs 1,222,864 votes agaist (42 Contacts Dakots Communications Rick Taylor, 310.816.8444Exhibit E@alexandramayers or | am going to take Mr Randazza up on his offer 2 sue you. U know full well what per se libel is ithas already cost you oSeas 28 - 22h @ealexandramayers claiming that! am involved in sex trafficking is crossing the line, remove it and apologize feExhibit Fhuman trafficking Iaite South GS rennusegudeinieoGnypatenaciapt Cuebal 0 ae Sen LOE eee [quotencncerh.jaeait hime ott og dg hac Sht fy Souraabuoke eis aly aye ae Hs te wee tcl ua aye oe yr mary epee P| SiarFleet costs Tate ne et phobia sak. hath ay saben se Sh atu abc ane ae a CE She et he a Se : Poca sig Pca i ee ope a pee ce eo Coyotes oe, [erecta ay pe bt ptt tare wan sa iy wean "HD cles hr af se ng reo Sr ah eas goes deans ke Peppa eas, {etesennah sn hgh ea ana eh ans et ps a he se ae CUTE ie et 2oxKsouth tsorEemigpeasseaihon ime neste SMU QOTER pace a ag Tae cst gh rang! ahab are wi wu ote id cat a, YoU BOR te aR HE, igh 8A Ase Be ee, sa et so saanbisa shout nt wi nana Wo gs soay wan, cpu, esd gues fea wou Be Some Lb os wa eas oye oun Cont Besos ny secu aun te gop sine noe ope! as thence! Se are wa be Speen os ga he dhanbe mn, meete “eoreat orto bsExhibit JStreets of Atlanta ‘Real Hokers plying thels trade on the stteets of Atlanta? ilery 1 Peachtree Street between Toth and 14th Gallery 2 Peachtree between 10th and 14th Guilery 3 *New* Ponce DeLeon at Argonne 4 "New Ponce DeLeon j oer REE Goce ee |Exhibit Kveove mikescuth.com: {PPE JOTES omits Some en Te so ~ Somecite Is Playing Gases Cruising For Street Walkers 8y Mikesoutlt ay th, 2014 ‘Somesme askee me today I was cealy cng for streetialers back in 20/2. as the what the fac are you ting out and they tld me sats what uncle Peg (aka Ar Bas, Michael Whitacre, pornwara and eters} had written en that loser ite he ana Tompins run Laughed my a8 off, yep Tina a posting nce to te atlanta hear on USGeeayuise because they actualy tod me wher= took You see back those cays sha avery poplar se calee StreetsOFAtlanta.com That inks tthe vaybacs feeder ste, featratc tomy pastes. | auld go cut with a fend and snap pls {ar eo} ofthe local youcan ete ‘The ste oot very popular specially hee in dtianta and he cy of tlanea Police contacted me and asked [Ff woul tate & down at at east sep peng i hey Felethat cas beng use te pabliize here i got find seetiabers, Not wanting ay I nih aoed an eventual jst Cnt even ene este you coming tamorty,Inciag an eral ‘So thare ya go Unde Fag..jou chickenshit envard, ut ane good tora desarwes aaater eo have 3 whole po folks you threatened who ous addtess fo udge Mark stevens. that'd be Ue jucge in your domestic uatence case mn Kendersue NY. 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