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 Cox’s 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 1

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 Randazza’s 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 Randazza’s 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 2

out as my attorney to other attorneys. Randazza was at least Cox’s 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. Randazza’s 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: [email protected] AND [email protected]

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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 [email protected]

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