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

Motion for Bench Trial

And Misc. Relief

I, Crystal Cox, hereby submit this motion seeking a bench trial. I, Cox, had requested a
Jury trial in my Claims against Randazza Originally. However, I cannot afford to come to
Las Vegas. I cannot afford an attorney nor to subpoena witnesses.

The Declaration attached to this filing titled DECLARATION OF CRYSTAL COX in

support of Coxs Counterclaims against Randazza And Support of Motion for Bench
Trial. And Declaration of Crystal Cox Declaration, Docket Entry 8, 17-01005 -abl, and all
attached exhibits, as well as 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 Filed 01/03/13, Cox
Counter Complaint and all Exhibits.

All hereby now included in this motion and request in their entirety, are ALL the
Evidence I have to provide to this court for the decision regarding whether I, Crystal Cox
have a claim against Marc Randazza, whether I had an attorney-client relationship and
whether Marc Randazza owed me any duty at all or defamed me.

I request this court to make a ruling without a jury trial and based on evidence and law. I
have no way to do anything further and will not be able to mail filings such as this from
now on as I will be living in a hostel and have no use of a computer for long periods of
time, no way to print and no money to mail. The recent filings were a donation to me of

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which I will no longer have access to. These filings are all the discovery I have and all I
can provide to this court to support my claims.

I request that the entire case is presented directly to the judge in this case and a ruling
is made as a matter of law. I move this court to grant me a JUDGMENT AS A MATTER
OF LAW. As stated, I have nothing else to provide this court and have no attorney.
I have no way to attend a jury trial in Nevada or elsewhere as far as that goes. I have no
way to have an attorney to protect my rights in these matters, as I have been denied in
JAD, Case 2:12-cv-02040-JAD-PAL.

Federal Rules of Civil Procedure Rule 50, Rule 50(a) A motion for judgment as a matter
of law may be made at any time before the case is submitted to the jury.

I seek a judgement in my favor granting relief in the amount this court deems fair and
just.

I have presented this court with all the evidence I have via exhibits and sworn
declarations with exhibits. I request this court make a decision / ruling based on the
evidence presented.

It remains to be decided by this court whether I, Crystal Cox, have rights as a former
client of Marc Randazza and with Randazza defamed me with actual malice and if so
what relief am I entitled to as a matter of law. I seek this court to make this ruling in a
bench trial, an Order and not a jury trial.

It is undisputed by Randazzas own evidence that he defamed me on his blogs and

deemed me having criminal behavior without me having due process in a criminal court.
Randazza repeatedly stated as fact to third parties that I, Crystal Cox am guilty of the
crime of extortion. Documents on both sides of this case clearly, at least, describe that
in detail.

It is undisputed by Randazzas own testimony, sworn statements, motions that I was at

the very least his potential client, that he had been negotiating with others regarding my
case, that he deemed a settlement in best interest and was working out the details of it
with Eugene Volokh and the oppositions attorney David Aman.

It is undisputed that Randazza counseled me on what I should do in the case. Exhibits

show him telling me how and why to get transcripts and talking of discovery and working
out the next step. Randazza put in time and material as Exhibits show and held himself

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out as my attorney to other attorneys. Randazza was at least Coxs advocate,
intermediary, counselor and still owes a duty to Cox.

And that Randazza had a duty to NOT harm Cox or participating with those who were.

Relief Requested

I request all relief allowable by law up to 100 million. I have lost all I knew to be my life
due to the actions of my former attorney Marc Randazza. I have been homeless and
under massive physical duress and stress for 5 years now with no end in site. I allege I
am entitled to relief by way of a financial judgement in my favor.

Randazzas actions rendered me homeless, alienated family and friends and made no
one want to work with me, rent to me or even speak to me as they were afraid of his
legal action against them and or of physical danger as well. Because of Randazza I
have been under massive stress and fear for my life for 5 years non-stop. Randazza
has left my life in ruin and I allege I am entitled to Relief, as a matter of law.

Other Documents of Evidence hereby included:

2:12-cv-02040-GMN-PAL exhibit Doc. entry 45

and 46 Dated 01-13-2013

Case 2:12-cv-02040-GMN-PAL Document 47 Filed 01/17/13 and ALL attached Exhibits,

including 1-13.
Amended Complaint
Case 2:12-cv-02040-GMN-PAL Document 62 Filed 01/27/13
2013-02-2 Doc1 87, including exhibit 1-7

Case 2:12-cv-02040-GMN-PAL Document 130 Filed 06/03/13

Exhibits 1-10

CounterClaim again
Case 2:12-cv-02040-JAD-PAL Document 164 Filed 02/24/14
And Doc. 162

As a matter of Judicial Economy and Law I request a Bench Trial.

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This court has a unique opportunity to set guidelines for attorneys who engage with
clients, or potential clients and do what Marc Randazza, Ron Green and Randazza
Legal Group has done in this case and connected cases.

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.

An Examination of All Relevant Factors Weighs Heavily in Favor of Granting Cox relief.

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 Motion for Bench Trial to:

Judge AUGUST B. LANDIS

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

And Matt@lzlawnv.com