Thursday, May 16, 2013

Marcus Evans, Inc. v. Coenen et al. Marc J. Randazza Attorney, Tracy L. Coenen Defendant accused of Defamation, Libel Slander. Looks like some pattern and history here. Oh and Tracy Coenen and Marc Randazza, hmm, I ALLEGE Civil Conspiracy.

Marcus Evans, Inc. v. Coenen et al

Plaintiff: Marcus Evans, Inc.
Defendants: Tracy Coenen  and Sequence, Inc.

Case Number: 1:2012cv00163
Filed: January 10, 2012

Court: Illinois Northern District Court
Office: Chicago         Office
County: Cook
Presiding Judge: Matthew F. Kennelly

Nature of Suit: Torts - Injury - Assault, Libel, and Slander
Cause: 28:1332
Jurisdiction: Diversity  

Marcus Evans, Inc. v. Coenen et al


Marc J. Randazza (pro hac vice pending)
RANDAZZA LEGAL GROUP



"AFFIRMATIVE DEFENSE VIII STATEMENTS OF OPINION 
 Defendants’ statements concerning Plaintiff, its business and employees are statements of
opinion, rather than fact, and cannot be the proper basis for a defamation claim. As such,
Plaintiff’s claims of defamation fail against the Defendants, as the Defendants have not made
any false statements of fact. "


Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing

So odd, Marc J. Randazza and Tracy L. Coenen sure seem to know what defamation is, yet deliberately falsified FACTS regarding Crystal Cox.

In Comparision, in Coenen v. Cox, stating that someone is guilty of a crime, is NOT "Opinion" but I suppose Tracy Coenen and Marc Randazza will try and use that one again. Plaintiff Crystal Cox sure can prove that she was not convicted of nor on trial for extortion, yet above the law Attorney Marc J. Randazza and Fraud Investigator Tracy Coenen get to flat out state the I, Plaintiff Crystal Cox is an extortionist. The Defendants in Coenen v. Cox sure have made false statements of FACT, yet oddly seem to be above the law.

Coenen v. Cox, Click Below to view that Complaint.
https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing



"AFFIRMATIVE DEFENSE VII THE FIRST AMENDMENT 
" The First Amendment of the United States Constitution immunizes the Defendants from
liability for their statements concerning Plaintiff, its business and its employees, as Defendants’
statements are matters of public concern and entitled to Constitutional protection. By operation
of the First Amendment, the Defendants are inoculated from liability arising from their
statements concerning Plaintiff. "

Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing


Odd, its like Marc J. Randazza gets this First Amendment thing, yet STOLE massive online media criticizing him, without the First Amendment ever coming in to play, See the SLAPP Lawsuit and First Amendment Smackdown,  Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html


In Coenen v. Cox, Defendants are NOT "inoculated from liability arising from their 
statements concerning Plaintiff". As they FLAT OUT stated false and defamatory statements to a third party concerning Plaintiff Crystal Cox and with FULL knowledge they were and are false.



Coenen v. Cox, Click Below to view that Complaint.
https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing


 "AFFIRMATIVE DEFENSE VI COMMON LAW PRIVILEGE
 Defendants’ statements address matters of public concern and thus are afforded the First
Amendment’s strongest protections. Because of the public import of the Defendants’ statements,
their content is privileged and non-actionable. Accordingly, Plaintiff’s claims for defamation
must fail as a matter of law. "

Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing

Blogger Crystal Cox was posting regarding a federal bankruptcy of public concern, Marc Randazza conspired with the attorneys for Obsidian Finance Group, and attempted to entrap me, Crystal Cox. I was also reporting on, reviewing Marc Randazza who had been my attorney, and who is a public figure, yet he SUED me, in the courts where he is reigning king and shut down massive blogs, deleted blogs, changed servers and all without first amendment adjudication nor any concern for what I was posting that was CERTAINLY of public concern. Marc Randazza is a hypocrite here in the above Tracy L. Coenan case, and after this Tracy Coenen and Marc Randazza defame and harass blogger Crystal Cox, me, as you see here:

Coenen v. Cox, Click Below to view that Complaint.
https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing


"AFFIRMATIVE DEFENSE V RHETORICAL HYPERBOLE
 Defendants’ speech is protected as rhetorical hyperbole, as no reasonable reader of the
statements would interpret them as being statements of fact. As such, they are incapable of
constituting defamation, and Plaintiff’s claims must fail on that basis. "

Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing

What a Crock that is, Marc J. Randazza SEIZED domain names, deletes blogs and suppresses free speech and sues for millions all because a blogger, me Crystal Cox was criticizing him, and using " rhetorical hyperbole". Sure seems like Marc J. Randazza, Randazza Legal Group and Tracy Coenen are HYPOCRITES, but that's just my rhetorical opinion.

Coenen v. Cox, Click Below to view that Complaint.
https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing





"AFFIRMATIVE DEFENSE I THE ILLINOIS CITIZEN PARTICIPATION ACT
 Plaintiff’s instant litigation is brought in connection with, or as retaliation for,
Defendants’ acts in furtherance of their rights to speak, petition or participate in government and
seek favorable action; as such, Plaintiff’s claim is subject to dismissal pursuant to the provision
of the Illinois Citizens Participation Act, 735 ILCS 110/1 et seq. with an award of reasonable
attorneys’ fees to the Defendants."

Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing



I wonder if Tracy Coenen will try and use the Illinois Participation act in Cox v. Coenen in Wisconsin where she also has her business?

Marc J. Randazza sure knows all about retaliation. I, Plaintiff Crystal Cox, FIRED Marc Randazza, I criticized him and her got rid of my blogs and cites in pure retaliation and yet is someone above the law. Then he gets his buddy, looks like former client, Tracy L. Coenen to Defame Crystal Cox as well.

Coenen v. Cox, Click Below to view that Complaint.
https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing





"AFFIRMATIVE DEFENSE IVSUBSTANTIAL TRUTH
 Defendants’ statements are substantially true and therefore non-defamatory.  So long as
the gist of the Defendants’ statements is correct, the statements are not defamatory."

Source
https://docs.google.com/file/d/0Bzn2NurXrSkiQVBQV0ZvaDc4Z2s/edit?usp=sharing


What a CROCK, either its true or not. WE shall see if Randazza and Coenen say the same thing in Plaintiff Crystal Cox's case against them. As Cox is not guilty of Extortion yet the two of them think they are above the law and can say whatever they like, POWERFUL above the Law Dua, seemingly in heavy duty civil conspiracy, in my OPINION.

Check out Cox v. Coenen, Randazza and more... Click Below to view that Complaint.

https://docs.google.com/file/d/0Bzn2NurXrSkicWtOSFNYbV85cFk/edit?usp=sharing





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