Tuesday, April 30, 2013
Thursday, January 10, 2013
Nevada Federal Trademark Defendant Opens Door For Roxanne Grinage To File Criminal Responsibilities Evidence Against Eliot Bernstein and Crystal Cox
01/10/2013.
Mr. Randazza responded to my request for permission to publicly comment or upload his court stamped filed documents in the Nevada District Court Trademark Federal Lawsuit one line, "You are welcome to use anything that is publicly filed."
Today, as I was checking the docket report in the Federal Trademark Lawsuit Randazza et al vs. Crystal Cox and Eliot Bernstein... I realized that Doc 30 is Defendant Crystal Cox's Response to Randazza Legal Group on behalf of 3 Randazza individual plaintiffs 11/28/12 Complaint whose nature is Trademark and whose causes of action are (1) Violation of Individual Cyberpiracy Protections 15 U.S.C. 8131 and (2) Cybersquatting 15 U.S.C. 1125(d) and (3) Right of Publicity NRS 597.810 and (4) Common Law Right of Publicity and (5) Common Law Right of Intrusion Upon Seclusion and (6) Civil Conspiracy.
Even though I was never served with Crystal Cox counter claim, I think the fact that Nevada District Court was duped by Cox's purported broadcast email Certificate of Service and listed my name along with some 30 very respectable and prestigious businesses and media entities as so-called "counter defendant" parties, actually works in favor of those pro se litigants like myself seeking to bring our own charges against the Scam Blogger already adjudged $2.5M civilly liable/guilty in the Oregon Federal Court Kevin Padrick vs. Obsidian Financial for acquiring domain names of business people posting abusive and defamatory content, trying to sell them her reputation management services $2,500.00 per month to not publish defamatory content or in the case of Eliot Bernstein inventor of Iviewit technologies uses the posting of defamatory content on domains named for Apple Executives Steve Dowling and Bruce Sewell in an effort to strong arm Apple Inc into paying him money he thinks he's owed for patent theft.
On November 9, 2012, Roxanne Grinage demanded Eliot Bernstein and Crystal Cox remove her/my name from any cc on any email or anything which suggests I have anything to do with their extortive technique to demand money by withholding domain names named for real people.
It would seem that two administrative challenges are posed by this learning. Inevitably the nature of fair market entry forced by standard access business practice models and progressive minded creative thinkers will always forge community-powered solutions to any market entry challenge. This market I would say is the market of Responsible Fact-based Journalism. Yes Federal Court dockets are a part of the requisite research but do not rule out witness testimony and verifiability of witness credibility. A HireLyrics Standard Access Practice Model Slogan: "Restore Courage To Journalism....Tell the Truth for the Sake of Truth In Public Record....U.S. Citizens Control The Public Docket Database."
"A new type of Extortion Crime Modus Operandi? Domain Name Defamation Schemes?"
"Is The Credentialed Professional Service Obligated To Protect Confidentiality of the Former Client Who Broadcasts Defamation Tantrum?"
ROXANNE GRINAGE'S WILL ENTER EVIDENCE IN THE FEDERAL TRADEMARK LAWSUIT OPENED AGAINST COX AND BERNSTEIN BY RANDAZZA ET AL IN NEVADA DISTRICT ON 11/28/2012 because Crystal Cox saw fit to include Roxanne Grinage in a list of counter defendants which opens the door for Roxanne Grinage to file her evidence against Cox and Bernstein now.
I believe Eliot Bernstein and Crystal Cox criminal responsibilities with regard to their defamation of me personally and as a business owner inflicted only after I said my individual principals and my standards of community responsibility would simply not tolerate Eliot Bernstein giving anyone the impression that I condoned his money demands made to Apple Executives or any of the other 4,000 people and entities he says are in illegal possession of his Iviewit Technologies patents he says were stolen by some people working at law firm over twelve years ago....Eliot Bernstein's methods for crime solving somehow evolved to become are criminal in nature.
See how Crystal Cox posts on ROXANNEGRINAGE.COM that Roxanne Grinage is responsible for thwarting "negotiations" of what Eliot Bernstein told me and testified to New York Senate Hearings on the Judiciary Committee in 2009, was a $1 Trillion Patent Loss overall - suddenly grown according to Crystal Cox defamation website on ROXANNEGRINAGE.COM to $13 Trillion Settlement Negotiations between Eliot Bernstein for Iviewit and just one of the more than 4,000 defendants Eliot Bernstein claims has his stolen technologies, Apple, Inc. How did we get from Eliot Bernstein and Crystal Cox's November 9 2012 email to Apple Legal Counsel and P.R. Executives Steven Dowling and Bruce Sewell essentially warning them that the defamatory content they are posting on Bernstein and Cox owned stevedowling.com and brucesewell.net "will continue unless you pay us some money" to "Reverend Crystal Cox In Love of Light Savvy Broker Search Engine Reputation Management Services Scammer posting on ROXANNEGRINAGE.COM that [Roxanne Grinage is so powerful as to have interfered with $13 Trillion Settlement Negotiations between Apple Inc and Eliot Bernstein - Actually insulting readership intelligence asking anyone to believe the reason Apple Inc decided not to pay Eliot Bernstein $13 Trillion had nothing to do with him and Cox pushing up on Applie like two hoodrat thugs - No.....Eliot Bernstein and Crystal Cox were unable to get Apple to pay them because of something Roxanne Grinage did which is to say on November 9th 2012 "DON'T PUT MY NAME ON ANY OF BERNSTEIN AND COX'S EXTORTION CRAP and NO MORE FREE WORK ELIOT BERNSTEIN and NO ROXANNE GRINAGE WON'T HAVE ANYTHING TO DO WITH WITHHOLDING DOMAINS NAMED FOR REAL PEOPLE." Really?
Crystal Cox is running around the country demanding jury trials, selling her domains to Eliot Bernstein to hide her assets from having to pay the $2.5M Obsidian Financial v Cox Defamation Judgment; gives her webhost $85,000 a day liability for her grabbing ROXANNEGRINAGE.COM as Reverend Crystal Cox on November 13, 2012 after sending Roxanne Grinage an email "Declaring War", wastes the court's time and tries to bog down the community of legitimate responsible bloggers journalists and business leaders in non-applicable debates about free speech as she abuses her internet enabled consumer audience reach to perform one predatory act after the next. Crystal Cox and Eliot Bernstein may be motivated by a different reasoning, Eliot Bernstein the cynical jaded gone over to the dark side with the sense of self righteous nous because in his view he has a right to do unto everyone else what he says a law firm did to him 12 years ago - and Crystal Cox is a sad case of needing to be needed - spurned by responsible bloggers and legitimate business people, doing all the grunt work all the postings all the rushed mistake riddled filings, all the lunatic declaration of war - literally the junk yard dog for Eliot Bernstein who was Defaulted in the Docket because his arrogance wouldn't allow him to answer summons, while Crystal Cox stupidity had her spread thin trying to appeal and duck and dodge the $2.5 Million Defamation Judgment in Oregon while she calls out prestigious accomplished legitimate business leaders and motions to recuse the federal judge demanding everyone sign a conflict of interest which is Eliot Bernstein's little catch 22 tool he uses to stop fair adjudication, abuse courts and waste taxpayer money because he and Crystal Cox figure if you just keep naming defendants, five thousand Business Leaders, Law Firms, Bankers, Insurers, Brokers, Litigators, Prosecutors and Academicians who would pick up the phone and make referral to State and Federal Prosecutors to lock up Crystal Cox and Eliot Bernstein would have to self recuse because they would be bound to have a conflict which in Eliot Bernstein and Crystal Cox Conflict of Interest Disclosures they Demanded Nevada Trademark Federal Judge and court practitioners to sign don't just want to rule out "did you ever represent this person or entity" they want you to not have an opinion about right and wrong and overlook application of state and federal laws if you know the person, went to school with the person, your sister's ex boyfriend's niece ever met them at a fundraiser. You understand.
I'm working on a problem I'm having uploading documents but will have the exhibit evidence I will refer to and enter myself uploaded here soon. Of course I will only post the Court's stamped filed or return correspondence to my requests to enter appearance of Roxanne Grinage, Sworn Affidavit Declaration of Roxanne Grinage in the Nevada District Court Federal Trademark Lawsuit; and hope to file a separate complaint putting Eliot Bernstein name first as defendant so he stops enjoying the shield of his not so bright junk yard dog, Crystal Cox who looks like she is being efficiently dispatched with Orders in favor of Plaintiffs Randazza an accomplished 1st amendment lawyer in his own right.
Wednesday, January 9, 2013
Roxanne Grinage HireLyrics Citizens Public Docket Bring Internet Predators Crystal Cox and Eliot Bernstein Accountable For Nationwide Domain Defamation Schemes
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HireLyrics is standard access to legal assistant claims intake litigation and law enforcement referral for the previously un-accommodated federal crime victim witness created by official corruption fraud civil rights violations. Roxanne Grinage's Standard Access Mechanism Business Model Achieved Claims Intake Assessment of 2,060 Federal Crime Victims created by Official Corruption Fraud Civil Rights Violations. Champions of Patriotism were revealed whose litigation and law enforcement referral data respectfully suggest 11 Proposed Federal Laws to Enrich Innovation of U.S. Economy, Education, Judicial Accountability, Prison and Public Safety Reform. "The answer to missed educational opportunities, unaccountability horror stories, poverty, racism and hate-based ideas festering into terrorism is the responsible developments of entities that standardize access and standardize services." -respectfully, roxanne grinage HireLyrics Schematics 2002 "Restore Courage To Journalism... . |
Roxanne Grinage HireLyrics Administrative Services Website: www.HireLyrics.org Email: roxannegrinage@gmail.com |
January 9, 2012
VIA EMAIL AND FACSIMILE (Published to HireLyrics.org Case Study Pages)
| Marc John Randazza | Ronald D Green, Jr. |
Re: Request Permission to publicly comment and possibly join with Plaintiffs' Marc Randazza et al, similarly situated claims of Roxanne Grinage dba HireLyrics Administrative Services and U.S. Citizens Public Docket Database, Pennsylvania and U.S. Department of Treasury registered sole proprietorships damaged by exactly the same defendants, Eliot Bernstein and Crystal Cox for exactly the same nature of suit and causes of action as opened by Marc Randazza et al docket report through date of last filing 01/08/2013 captioned below.
United States District Court District of Nevada (Las Vegas) CASE No. 2:12-cv-02040-GMN-PAL
Randazza et al v. Cox et al | Date Filed: 11/28/2012 |
Dear Messrs Randazza and Green,
Congratulations on Order granting Plaintiffs' Motion for Preliminary Injunction yesterday. May I please have your permission to upload your court stamped complaint, exhibits and Document 2 Motion Temporary Restraining Order Motion Preliminary Injunction and Exhibits and comment on how your claims against Cox and Bernstein are similar to my own on case study pages at HireLyrics.org and also in videos and blog journals?
I am planning to file my own federal complaint against Bernstein and Cox (diversity) from here in Pennsylvania's Eastern District on or about February 22nd. I don't quite know how but I would like to learn if possible how I could notify the federal court here when I file that my claims against Bernstein and Cox are related to your case and if possible to the Oregon appeal of Kevin Padrick Obsidian Financial attempting to enforce $2.5M defamation judgment against Cox in Oregon.
Your complaint filed 11/28/2012 in U.S. District Court of Nevada, against Bernstein and Cox and my review of the docket report through yesterday, confirm for me that I have first-hand irrefutable evidence against Eliot Bernstein that may assist law enforcement in learning Eliot Bernstein is the sinister coward criminal mind behind a not too smart Crystal Cox who has sold some of her domains to Eliot Bernstein to hide her assets and posts the defamatory content about Apple Executives and now roxannegrinage.com after I told Eliot Bernstein and Crystal Cox on November 9, 2012 to get my name off of email(s) to Apple Executives Bruce Sewell and Steven Dowling that had anything to do with demanding money from anyone based on the threat of posting defamatory content on domains named for real people.
The truth is that Eliot Bernstein is backing Cox because Cox is alienated and ostracized by responsible bloggers, journalists and certainly all professionals transacting any legitimate business. Eliot Bernstein is the criminal mastermind behind what I see now on hind sight and review of two five inch expandable redwells of printed file materials, a 1.5 inch three ring binder and 2 4.7GB DVD Data Discs, document and audio files - Eliot Bernstein is in fact a genius who, like the Joker villain on Batman Dark Comic Series has lost his ability to reason and believes that it's okay to do to others what he perceives was done to him. According to his thinking, Eliot Bernstein believes more than 4,000 people entities and businesses are in receipt of revenues earned as a result of patents stolen from him twelve years ago by the law firm he and his inventor team hired to register the patents as they created the internet technology inventions.
I am not too worried about Crystal Cox because as my husband pointed out she is just running all over the country abusing internet consumer audience reach to pick one fight after the next with anyone who won't succumb to Eliot Bernstein's and her extortion by domain defamation schemes. She is spread way too thin and has not realized that Eliot Bernstein sits back comfortably watching her go on one kamikaze mission after the next: Defamation of Obsidian Financial people, Defamation of Apple Executives; Defamation of People and their families even children are fair game for Cox; offering to not defame people if you pay her $2,500 per month for reputation management services; breaking all kinds of laws like practicing law without a license....Cox speaks in court pleadings in pro se voice for herself but represents Eliot Bernstein Iviewit interests as well. I noticed in the docket report that Eliot Bernstein was served summons and his answer to your complaint was due 01/05/12. I guess Ms. Crystal Cox $2.5M Defamation Judgment Scam Blogger is also Eliot Bernstein's attorney representation as well? [sarcasm].
My ethical and moral motivation is to bring Eliot Bernstein accountable to the community of federal crime victim pro se litigants for Eliot's defamation tantrum which deliberately sabotaged the copyright infringement litigation of our mutual friend who Eliot convinced to file on 12/28/12, a non-compliant objectionable ("sham") opposition to motion for summary judgment and avoid any reference to the meat of his case researched verified and document production performed by me as the pro se litigant's consultant agreement contracted legal assistant: four motions, declarations and 10 court stamped evidentiary compliant exhibits e-filed 11/30/12, 12/01/12 and 12/05/12, I had marked itemized and court stamped without any objections whatsoever by adverse party lawyers to this date. Motions I prepared for pro se litigant were denied in part and granted in part.
Eliot Bernstein used his rage against me because I wouldn't go along with his extortion scheme with Crystal Cox against Apple executives Steven Dowling and Bruce Sewell, to call my copyright infringement pro se litigant client, a person who he referred to me as a client on September 2, 2012, but who he shared a long time friendship with and inflicted a defamation tantrum upon an already stressed pro se litigant who was trying desperately to stay alive in a federal copyright infringement docket while he searched for an attorney to help in time for trial scheduled March 2013. Eliot Bernstein used his friendship with this client of Roxanne Grinage to pressure the copyright infringement plaintiff litigant to not use me as his legal secretary for the opposition filing which the Motion for Extension of Time to Reply prepared by me was Granted by the Federal Judge due 12/28/12.
The federal copyright infringement non-attorney represented plaintiff, a creative musician, entered a heartfelt, honest kind of stream of consciousness reply in opposition to defendants' motion for summary judgment and took Eliot Bernstein's advice not to use or refer to any of my work, the exhibit evidence we had already brought to the attention of the court already in the docket and never objected to.
Eliot Bernstein's malicious self centered defamation tirade (bugging my client to not work with me), caused my pro se client's opposition and declaration to be objectionable with evidentiary evidence of "sham", heightens the chances defense will win summary judgment (dismissal with prejudice) and places terrible stress on the musician plaintiff, his family, undermines the effectiveness of a related personal injury federal lawsuit filed in another district court same day 12/28/12 (exclusively researched verified case initiation documents and exhibits produced by Roxanne Grinage Legal Assistant HireLyrics Administrative Services); and inflicts severe damages to my business' ability to recoup investment of costs, payment for work product advanced and professional reputation; especially inasmuch as I am demonstrating a prototype of an invention of reform business method which I tout to Department of Justice for funding to help crime victims in each state.
Please don't be discouraged if you have problems calling my 267 number. I am in the process of changing my cell phone to landline services during a physical move. Your fax reply 215.405.2939 or email reply and communications are seen immediately at roxannegrinage@gmail.com and roxannegrinage@yahoo.com.
You are welcome and encouraged to use this correspondence in any way you see fit and I have disclosed here that I am publishing this letter request for your permission on my case study pages at HireLyrics.org. Of course, I will wait for your reply before publishing anything else related to your litigation against Cox and Bernstein.
Respectfully,
/s/
Roxanne Grinage
Monday, January 7, 2013
Roxanne Grinage Utilizes State Court Document Production Filing Opporunities In CPS Custody Matters to Prime Class Action People of Alaska vs State of Alaska DHHS OCS OPA DOC
| Career Portfolio: Transportable Skills Credentials and Professional Achievements Roxanne Grinage Legal Assistant Project Manager Administrative Solutions Innovate Reform | ||
| Roxanne Grinage’s Standard Access Mechanism Business Model Achieved Claims Intake Assessment of 2,060 Federal Crime Victims created by Official Corruption Fraud Civil Rights Violations. Champions of Patriotism were revealed whose litigation and law enforcement referral data respectfully suggest 11 Proposed Federal Laws to Enrich Innovation of U.S. Economy, Education, Judicial Accountability, Prison and Public Safety Reform. | HireLyrics is standard access to legal assistant claims intake litigation and law enforcement referral for the previously un-accommodated federal crime victim witness created by official corruption fraud civil rights violations. "The answer to missed educational opportunities, unaccountability horror stories, poverty, racism and hate-based ideas festering into terrorism is the responsible developments of entities that standardize access and standardize services." -respectfully, roxanne grinage HireLyrics Schematics 2002. | |
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By Roxanne Grinage, Legal Assistant Marketing Careers Project Manager | ||
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| "There Is An Administrative Solution for Every Market Entry Challenge...© U.S. economy enriching career contributions are blocked by legal or agency policy malpractice. A business or professional service should serve in community trenches in order to measure by standard access and community powered synergy, market entry challenges; count growing jurisdictional and similarly situated claims, and document specialized interest groups, characteristics, deficiencies and attributes of the American working class student impoverished federal crime victim created by official corruption fraud civil rights violations.
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| Enable Fair Holistic Market Place Entry for previously un-accommodated Worldwide Population of Disadvantaged Creators.© | "Survive and Hold On Is a Business Rationale...© It's Not Welfare or Charity If A Professional Service Advances Costs Necessary to Unlock Economy Enriching Contribution."© The sound business model utilized by contingency agreements which glean percentage share of revenues earned as a result of the professional service's competitively rendered administrative support in addition to recouping costs, should be applied to an internet community presenting population of Americans spanning every profession, race, religion, gender, age... whose day to day struggle to provide basic needs precludes the American entrepreneur or head of household holder of untapped claims and economy enriching career contributions from seeking fair entry into industry buyer markets, litigation or law enforcement. | |
| Administrative Solutions Series Born Developed & Demonstrated | DOCUMENTS EXHIBITS AND NOTICES PREPARED BY ROXANNE GRINAGE COURTS AND LAW ENFORCEMENT STAMPED FILED RECEIVED Proprietary Research, Verifications, Trial Prep, Document and Exhibit Production Performed by Roxanne Grinage, Legal Assistant, Marketing, Careers, Project Manager for Pro Se Litigant Federal Crime Witness Claimants created by Official Corruption Fraud Civil Rights Violations.
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Thursday, December 13, 2012
Roxanne Grinage Case Study Commentary opportunities and challenges for a federal crime victim litigant to "stay alive" in a Federal Court Docket while seeking to retain non-conflicted federally practicing attorney representation in time for Trial
Case Study Commentary by Roxanne Grinage December 13, 2012
Opportunities and Challenges for the Non-Attorney Represented
Federal Crime Victim Litigant to Stay Alive in a Federal Court Docket
While Seeking Non-Conflicted Attorney Representation.
120212 Roxanne Grinage Summary of Credentials. HireLyrics Administrative Services Legal Assistant Marketing Careers Project Manager Federal Rules of Evidence Compliant Expert Witness Services Administrative Solutions for Innovation of U.S. Economy Education Judicial Accountability Prison and Public Safety Reform(updated Resume Curriculum Vitae (CV)available upon request).pdf
Calendaring with Alarms Actions Tasks and Deadlines
Motions Denied In Part Granted In Part & Moot Give Options and Opportunities for Court Controlled Case Management
Roxanne Grinage Sees Opportunities for a Federal Crime Victim Non Attorney Represented Litigant to "Stay Alive" In a Federal Court Docket while he simultaneously shops to attract federally practicing attorney representation who is not only knowledgeable about copyright infringement but who may have attorney law firm associates versed in ethics and legal malpractice law to assist in
Correcting Process of Law Deficiencies and Identify Criminal Responsibilities.
Plaintiff can satisfy deficiencies noted in 11/10/12 Doc 206 Order of Honorable Edward Chen Denying Plaintiff's 11/30/12 Sua Sponte Motion for Injunctive Relief and survive threat of dismissal with prejudice posed by Defendants 11/21/12 Doc 171 Motion for Summary Judgment and 11/10/12 Motion for Leave to File Amended Cross Complaint,
If Federal Crime Victim Litigant can e-file two separate Local Rules for Motion Practice Compliant Documents on or before
December 28, 2012.
(1) Plaintiff's Motion for Reconsideration Clarifying Authorities Why Plaintiff Would Prevail on Merits if Process of Law Deficiencies are Corrected and Criminal Responsibilities are Identified
and
(2) Plaintiff Anthony Fredianelli's Opposition of Defendants' 11/21/12 Motion for Summary Judgment with Proof Dismissal with Prejudice Rests on Conflict of Interest Attorney Misconduct Mutilated Complaint, Obstructed Subpoenaed Records and Expert Witness Reports.
Hearing on Plaintiff's Motion Declaratory Judgment Is Scheduled
Before District Court Judge on January 17, 2013.
Hearings on Defendants' Motions for Summary Judgment and Amended Cross Complaint is Scheduled
Before District Court Judge on January 24, 2013
U.S.D.C. CAND Case No. 3:11-cv-03232-EMC
Anthony Fredianelli v. Stephan Jenkins Third Eye Blind,
David Rawson et. al.
A Roxanne Grinage Legal Assistant Marketing Careers Project Manager Work Product Authorized Posted to HireLyrics Administrative Services
Case Study pages in prototype demonstration of a U.S. Citizens (controlled) Public Docket Database to Assist Innovation of U.S. Economy, Education, Court, Prison, and Public Safety Reform Federal Crime Victims Litigants Can Overcome Official Corruption Fraud and Civil Rights Violations to Stay Alive in Federal Court Dockets where Judiciary and Law Enforcement may see unobstructed evidence; accurately calculate damages and identify criminal responsibilities.
"Federal Crime Victim Litigants are also U.S. Economy Careers Contributors."
"Law Enforcement are Working Class People Too!" - roxanne grinage HireLyrics Practice Model Schematics 2011
| ECF Docket Activity Noticed: HireLyrics Administrative Solutions Series:
| Roxanne Grinage Sees Opportunities for a Federal Crime Victim Non Attorney Represented Litigant to "Stay Alive" In a Federal Court Docket while he simultaneously shops to attract federally practicing attorney representation who is not only knowledgeable about copyright infringement but who may have attorney law firm associates versed in ethics and legal malpractice law to assist in Opportunities and Challenges for the Non-Attorney Represented Hearing on Plaintiff's Motion Declaratory Judgment Is Scheduled | ||||||||||||||||||||||||||||||||
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The following transaction was entered on 11/30/2012 at 4:06 PM PST and filed on 11/30/2012
Docket Text: The following transaction was entered on 12/10/2012 at 4:59 PM PST and filed on 12/10/2012
Docket Text: The following transaction was entered on 12/10/2012 at 4:16 PM PST and filed on 12/10/2012
Docket Text:
| Roxanne Grinage's litigation plan strategy for this case study at 12/13/2012. Roxanne Grinage sees the following opportunities and challenges for a federal crime victim litigant to "stay alive" in a Federal Court Docket while seeking to retain non-conflicted federally practicing attorney representation in time for Trial Scheduled March 2013. 1. There was a rigorous volley of ECF Filing Activity Noticed which included Orders of U.S. District Court Honorable Edward M. Chen, Defendants Stephan Jenkins Third Eye Blind Motion to Leave to Amend Cross Complaint; the Defendants' lawyer, Mitchell S. Greenberg had already filed Opposition Plaintiff Anthony Fredianelli's 12/05/12 Motion For Extension of Time to December 28, 2012 to File Motion in Opposition to Defendants' Stephan Jenkins Third Eye Blind's Motion for Summary Judgment Hearing on Defendants' Motion for Summary Judgment scheduled January 3, 2013. Roxanne Grinage also noted that Clerk of Court alerted all parties that action was needed as to stipulating consent to 12/04/12 "15 Minute Further Settlement Conference presided over by Magistrate Jacqueline Corley" which entered the settlement/dismissal of Defendant and Third Party Plaintiff Eric Godtland Management, case management hearing scheduled for December 14, 2012. Anthony Fredianelli's 11/30/12 Motion with supporting Exhibits A, B and C objected to dismissal of Eric Godtland and clarified that a prior stipulated dismissed defendant, the Third Eye Blind band's lawyer, Thomas Mandelbaum was one done by a prior plaintiff counsel's belligerence when gross conflicts of interest and attorney misconduct were complained about. 2. Roxanne Grinage noted that Honorable Chen specified "Sua Sponte" in the Title of his Doc 206 Order and referred to "oral argument" in the content of the Order Denying Sua Sponte Motion. Rox went back and scrutinized he docket reset and rescheduling and noticed although Honorable Chen's Doc 206 Order Denied Sua Sponte (Third Party) Plaintiff's Motion Injunctive Monetary Relief - the Court's Calendar reflected in the Docket Report showed that Hearing on Plaintiff's Declaratory Motion for Injunctive Relief to Correct Process of Law Deficiencies and To Identify Criminal Responsibilities remained scheduled for personal appearance Hearing on January 17, 2013 in United States District Court Judge's Courtroom 5. Honorable Chen's Order is 3 pages and is based in valid legal rationale. However, the U.S. District Court Judges Order Denying Plaintiff's Motion for Sua Sponte Injunctive Relief" is not without judicial compassion, inasmuch as there are a few opportunities for Plaintiff Federal Crime Victim to "stay alive" in copyright infringement federal docket while seeking non conflicted attorney representation further provide pretrial fact finding and evidence of need Correct Deficiencies in Process of Law and to Identify Criminal Responsibilities: 1. Simultaneously (at the same time), a. Plaintiff should seek a federally practicing lawyer preferably experienced in ethics and legal malpractice who will take him on as a contingency fee paid client. b. Plaintiff should prepare and e-file on or before December 28, 2012 (1) Plaintiff's Motion for Reconsideration Clarifying Authorities Why Plaintiff Would Prevail on Merits if Process of Law Deficiencies are Corrected and Criminal Responsibilities are Identified; and (2) Plaintiff Anthony Fredianelli's Opposition of Defendants' 11/21/12 Motion for Summary Judgment with Proof Dismissal with Prejudice Rests on Conflict of Interest Attorney Misconduct Mutilated Complaint, Obstructed Subpoenaed Records and Expert Witness Reports. which provide supplementation and clarifications for every item Judge Chen's Order states plaintiff did not provide sufficient evidence for or clearly state reasons why. c. Plaintiff pro se should be very careful to exclude objections regarding "in relative part" deletion of 11/30/12 Plaintiff Motion Title which included, "....And To Identify Criminal Responsibilities" when providing any and all deficiencies in evidence or clarifications directed in 12/10/12 Document 206 Order of Judge Chen Denying Sua Sponte Plaintiff's Motion. d. Plaintiff should stress in his MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 OF DECLARATORY JUDGMENT the he will abide by District Court Judge Honorable Chen's 12/10/12 Granting in part Denying in part Plaintiff's Motion to Appear Telephonically at all Hearings due to Hardship Cost and Loss Suffered as Recently as 11/30/12 Settlement Conference Hearing before Magistrate Jacqueline Corley, i.e. Plaintiff will personally appear at all motion hearings and be prepared for oral argument in support of his Motion for Declaratory Judgment To Correct Process of Law Deficiencies and To Identify Criminal Responsibilities. Personal appearance discussion and oral argument on Plaintiff's MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 FOR DECLARATORY JUDGMENT IN SUPPORT OF In San Francisco Federal Courthouse before Honorable Judge Chen per Clerks Notice Setting Motion Hearing for 01/17/13 at 1:30 P.M. in Courtroom 5, 17th Floor, San Francisco before Honorable Edward M. Chen. STRATEGY PLANNING AND PRESENTATION: When drafting MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 Plaintiff should keep in mind that Defendants' were not granted everything Stephan Jenkins Third Eye Blind lawyer Mitchell S Greenberg asked the court for. Defendants' lost their opposition to Plaintiff's Motion for Extension of Time to Oppose Stephan Jenkins Third Eye Blind Motion for Summary Judgment. Defendants' lost their attempt to finalize 12/04/12 "15 minute Further Settlement Conference presided over by Magistrate Jacqueline Corley. Defendants Hearings on 2 of Defendants Motions "Summary Judgment and Leave to Amend Cross Complaint" are now actually moved back to January 24, 2013, a full week AFTER Hearing on Plaintiff's Anthony Fredianeli's Hearing on Declaratory Motion (Correct Process of Law Deficiencies and Identify Criminal Responsibilities.) Plaintiff now has until December 28, 2012 to file more evidence in Opposition to Stephan Jenkins' Mitchell S. Greenberg's Motion for Summary Judgments referring to Plaintiff's 12/05/12 court stamped Exhibits A, B, C, and D and entering even more irrefutable evidence as to how belligerence of exposed for conflict of interest withdrawn plaintiff's counsel caused the amended complaint which Defendant's Motion for Summary Judgment relies upon to be a gross mutilation of Plaintiff Anthony Fredianelli's claims, evidence and witness testimony and a deliberate deprivation of F.R.E. 702, F.R.E 611(a), F.R.C.P. 26 to strip the Third Eye Blind Inc Partner Guitarist from standing before trial scheduled March 2013. Plaintiff should research draft consult finalize and E-file the following Documents While he simultaneously shops for federally practicing non conflict attorney representation who is also associated with ethics and legal malpractice associates, showing the prospective copyright infringement plaintiff's attorney active links to the Docket Entries of U.S. District Court Judge's Orders, U.S. Magistrate Judge's Orders, Plaintiffs 4 Motions and 10 Exhibits Documents 178 through 201 filed between 11/30/12 and December 5, 2010 (in the left column of this case study commentary). Plaintiff should e-file Motion for Reconsideration and Opposition of Third Eye Blind's Motion for Summary Judgment e-filed by December 28, 2012 which communicates to the Federal Court that non attorney represented plaintiff has (1) looked up and understands how the case citations of Judge Chen in 12/10/12 Doc 206 Order of Judge Chen Denying Plaintiff's Sua Sponte Motion for Injunctive Relief, require U.S. District Court Judge "(noting that injunctive relief is appropriate where, inter alia, "remedies available at law, such as monetary damages, are inadequate to compensate for that injury") (emphasis added). a. Plaintiff should refer previously entered Exhibits 12/01/12 Plaintiff's Exhibit A, B, and C; and refer to Plaintiffs Exhibits Entered 11/05/12 Exhibit A, B, C and D but only "incorporated by reference as if fully set forth herein", using the form limitations and requires governed by Local Rules Motion Practice to provide those components Honorable U.S. District Court Edward M. Chen points out in his Order of 12/10/12 Document 206: b. Find and identify authorities which support injunctive release of monies stolen as a result of criminal theft by deception. Clarify that Plaintiff is not asking for injunctive relief advancement of damages. c. Add more evidence of Defendant Stephan's Jenkins Theft of Anthony Fredianelli's royalties and proof that corporate and entities have traded by interstate commerce the stolen revenues of Anthony Fredianelli. Reference again the Landmark Supreme Court Case Decision regarding Federal Court's jurisdiction over interstate commerce and build Authorities for the technology commerce, 42 revenue streams Stephan Jenkins is currently siphoning monies of Anthony Fredianelli without accountability. d. Plaintiff should satisfy Judiciary pointing out a deficiency in Plaintiff's Motion filed 11/30/12, "Finally, even if relief were theoretically available, Mr. Fredianelli has failed to make an adequate showing that he would be likely to prevail on the merits, thus rendering his request for relief inappropriate....(noting that "'[a] plaintiff seeking a preliminary injunction must establish that [inter alia] he is likely to succeed on the merits;'")". Roxanne Grinage believes that Plaintiff Exhibits 11/30/12 A, B, C and 12/05/12 Exhibits A, B, C, and D with Declarations Theresa Fredianelli and Beverley should be represented by reference only and another Declaration of Anthony Fredianelli which clarifies his ownership of Third Eye Blind transacted copyrights, royalties should be entered attached to PLAINTIFF'S MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 OF DECLARATORY JUDGMENT FOR HEARING SCHEDULED JANUARY 17, 2013, AND e. Plaintiff's Motion for Reconsideration Declaratory Judgment Injunctive Relief Scheduled for Hearing on January 17, 2013 and Opposition of Third Eye Blind's Motion for Summary Judgment scheduled for Hearing on January 24, 2012,e-filed by December 28, 2012 should introduce for the first time DECLARATION OF ROXANNE GRINAGE in order to satisfy Federal Judge/Federal Court jurisdiction to "Correct Process of Law Deficiencies and To Identify Criminal Responsibilities. Roxanne Grinage has organized for trial prep binders over 700 pieces of evidence, document, audio, medical records, law enforcement referral, attorney notes, and attorney court stamped filings, orders, witness testimony and case history. Roxanne Grinage's Declaration would attach properly redacted medical records of Children's Rady Hospital Emergency Room, Pediatrician, Chadwick and LaJolla Forensic Trauma Specialists, and court stamped filings in Nevada Eighth District Court, Henderson and Las Vegas Metropolitan Police Report exhibits attached which prove the Attorney Misconduct, Witness Intimidation, Child Abduction and personal injury of Plaintiff Fredianelli's daughter by a long time stalker who was introduced to Kristi Fredianelli by Stephan Jenkins of Third Eye Blind was able to gain access to criminally physically and long term trauma injury Fredianelli's five ear old daughter on September 2, 2012 through September 7, 2012 in retaliation for Anthony Fredianelli complaining about Plaintiff's and Defendant's counsel's Cronin and Greenberg conflict of interest regarding Band's insurer AIG, and a Nevada Judge Ritchie's involvement with President Task Force investigated Las Vegas Home Owner's Association fraud. f. Plaintiff's Opposition of Third Eye Blind's Motion for Summary Judgment scheduled for hearing on January 24, 2013, and/or his Motion for Reconsideration Declaratory Judgment Injunctive Relief scheduled for Hearing on January 17, 2013 e-filed by December 28, 2012, should include the 11 page Declaration by Tim Vawter in Support of Tony Fredianeilli and on Ch. 73 Obstruction Violations. 12/11/11 (Not yet filed into Record of Case 3:11-cv-03232-EMC Anthony Fredianelli vs. Stephan Jenkins et al) Declaration of Tim Vawter Senior Investigator of the Protection Group In Support of Tony Fredianelli and on Ch. 73 Obstruction Violations. (Roxanne Grinage's note: Roxanne Grinage recommended Tim Vawter to Anthony Fredianelli after Tony Fredianelli presented on November 23, 2012 for 1.23 Hour Standard Claims Intake Assessment (transcribe of audio interview would be an exhibit in Roxanne Grinage's Declaration) of verifiable claims of official corruption fraud and civil rights violations. Tim Vawter has contributed to development of criminal justice field now known as "countering internet harassment." Tim Vawter is currently the pro se plaintiff in a trailblazing federal lawsuit which introduces new laws written by Tim Vawter regarding internet harassment and specifically to provide law enforcement safeguards to that Americans do not suffer Phoney Power of Attorney Documents). Tim Vawter's Declaration in Support of Tony Fredianelli and on Ch. 73 Obstruction Violations is 11 pages and includes Third Eye Blind Inc Account David Rawson's forged Power of Attorney document, and Tony Fredianelli's Affidavit renunciation of the POA as submitted by Tim Vawter to FBI in San Diego, California. Also featured in Tim Vawter's Declaration pertinent to Case No. 3:11-cv-03232-EMC are the new laws wrote by Tim Vawter which are being filed within Tim Vawter's lawsuit USDNJ case # 3:11-cv-06878-PGS-LHG VAWTER v. NEWS CORP et al, Honorable Peter G. Sheridan,presiding which is about making certain large internet hosting companies responsible for safeguarding users from internet harassment. Pertinent to Third Eye Blind Accountant David Rawson's fake Power of Attorney Document used to steal so much of Tony Fredianelli copyright royalties is One of Tim Vawter authored proposed new laws requires all parties who sign a Power of Attorney document must sign it in person, and on the same day. And, that a Power of Attorney document only lasts for 30 days. Honorable Chen's Order is 3 pages and is based in valid legal rationale. However, the U.S. District Court Judges Order Denying Plaintiff's Motion for Sua Sponte Injunctive Relief" is not without judicial compassion, inasmuch as there are a few opportunities for Plaintiff Federal Crime Victim to "stay alive" in copyright infringement federal docket while seeking non conflicted attorney representation further provide pretrial fact finding and evidence of need Correct Deficiencies in Process of Law and to Identify Criminal Responsibilities: 1. Simultaneously (at the same time), a. Plaintiff should seek a federally practicing lawyer preferably experienced in ethics and legal malpractice who will take him on as a contingency fee paid client. b. Plaintiff should prepare and file a MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 FOR DECLARATORY JUDGMENT which provides supplementation and clarifications for every item Judge Chen's Order states plaintiff did not provide sufficient evidence for or clearly state reasons why. c. Plaintiff pro se should be very careful to exclude objections regarding "in relative part" deletion of 11/30/12 Plaintiff Motion Title which included, "....And To Identify Criminal Responsibilities" when providing any and all deficiencies in evidence or clarifications directed in 12/10/12 Document 206 Order of Judge Chen Denying Sua Sponte Plaintiff's Motion. d. Plaintiff should stress in his MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 OF DECLARATORY JUDGMENT the he will abide by District Court Judge Honorable Chen's 12/10/12 Granting in part Denying in part Plaintiff's Motion to Appear Telephonically at all Hearings due to Hardship Cost and Loss Suffered as Recently as 11/30/12 Settlement Conference Hearing before Magistrate Jacqueline Corley. i.e. Plaintiff will personally appear at all motion hearings and be prepared for oral argument in support of his Motion for Declaratory Judgment To Correct Process of Law Deficiencies and To Identify Criminal Responsibilities. Personal appearance discussion and oral argument on Plaintiff's MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 FOR DECLARATORY JUDGMENT IN SUPPORT OF In San Francisco Federal Courthouse before Honorable Judge Chen per Clerks Notice Setting Motion Hearing for 01/17/13 at 1:30 P.M. in Courtroom 5, 17th Floor, San Francisco before Honorable Edward M. Chen. STRATEGY PLANNING AND PRESENTATION: When drafting MOTION FOR RECONSIDERATION AND OPPOSITION OF THIRD EYE BLIND'S MOTION FOR SUMMARY JUDGMENT E-FILED BY DECEMBER 28, 2012 Plaintiff should keep in mind that Defendants' were not granted everything Stephan Jenkins Third Eye Blind lawyer Mitchell S Greenberg asked the court for. Defendants' lost their opposition to Plaintiff's Motion for Extension of Time to Oppose Stephan Jenkins Third Eye Blind Motion for Summary Judgment. Defendants' lost their attempt to finalize 12/04/12 "15 minute Further Settlement Conference presided over by Magistrate Jacqueline Corley. Defendants Hearings on 2 of Defendants Motions "Summary Judgment and Leave to Amend Cross Complaint" are now actually moved back to January 24, 2013, a full week AFTER Hearing on Plaintiff's Anthony Fredianelli's Hearing on Declaratory Motion (Correct Process of Law Deficiencies and Identify Criminal Responsibilities.) Plaintiff now has until December 28, 2012 to file more evidence in Opposition to Stephan Jenkins' Mitchell S. Greenberg's Motion for Summary Judgments referring to Plaintiff's 12/05/12 court stamped Exhibits A, B, C, and D and entering even more irrefutable evidence as to how belligerence of exposed for conflict of interest withdrawn plaintiff's counsel caused the amended complaint which Defendant's Motion for Summary Judgment relies upon to be a gross mutilation of Plaintiff Anthony Fredianelli's claims, evidence and witness testimony and a deliberate deprivation of F.R.E. 702, F.R.E 611(a), F.R.C.P. 26 to strip the Third Eye Blind Inc Partner Guitarist from standing before trial scheduled March 2013. |
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