I, Crystal Cox ALLEGE that Marc Randazza had intent to defraud Creditors and that the Bankruptcy Courts should not, as a matter of law discharge debt that is FRAUD.
June 3, 2015 was date of the the now infamous arbitration in which Marc Randazza was accused of Bribery and was ordered to pay hundreds of thousands of dollars.
Marc Randazza hired his bankruptcy attorney in June 11, 2015 just after this we see Marc Randazza and Jennifer Randazza filed for divorce on June 22, 2015. This too shows intent to defraud creditors in my opinion.
Meanwhile he stalled the Randazza v. Cox in multiple ways and now this bankruptcy has "stayed" that case for who knows how long.
I ALLEGE that Marc J. Randazza made fraudulent transfers of money and other assets and set up an array of trusts, mortgage, car buying spree, IRA's, 401k and more simply to defraud Creditors and with specific intent to do so.
I ALLEGE that Marc Randazza began planning his bankruptcy seriously in March of 2015, once he new he would lose to Liberty Media and that the District of Nevada courts was allowing me, Crystal Cox to have 10 million in counter claims against Marc Randazza.
I Allege that Marc Randazza does not believe he will lose in those counterclaims and that he will continue to badger me or out-lawyer me and I will lose. I have clear and convincing claims, however, the point here is that Randazza added my counterclaims and me as a Creditor because of it's size of 10 MILLION Dollars and this put him at a Chapter 11 vs. a Chapter 13 I believe, or in some way made his story seem more plausible with so much burden. Even though he has stalled my case successfully with his appeals and now this, I allege, fraudulent bankruptcy claim.
I allege that Marc Randazza is using the ownership of Randazza Legal Group to hide assets, using IRA's and other financial accounts he started deliberately to defraud creditors with malicious, willful intent.
Creditors such as Liberty Media and myself, Crystal Cox are not just some Creditor, we were clients, and should have had protection under law, under the bar Association, under Randazza's multi-state liability insurance carrier which he refused and the Nevada courts let him, to ever give me information on who that carrier is or was.
The courts, including the bankruptcy courts should protect clients of attorneys such as Marc Randazza and not let them commit fraud against their clients, or engage in unethical, unconstitutional actions that really do harm their clients and then seek some sort of immunity in the bankruptcy courts.
RANDAZZA took a BRIBE, and I allege this is a tiny, TINY legal infraction of which Randazza has committed a massive amount of this type of action, plus other illegal hacking, stalking, privacy violations, endangerment and flat out criminal defamation and harassment against his former clients and against whistleblowers who tell on him.
I allege that Randazza's divorce is to hide money, assets and even a mortgage to his wife's parents to defraud creditors whose lives he has caused irreparable harm to.
I, Crystal Cox Allege that Marc Randazza has violated Section 548 of the Bankruptcy Code and other Codes to due with fraud. I allege that Randazza had intent to defraud Creditors and therefore he cannot discharge this debt. I allege Marc Randazza is guilty of Fraudulent Transference and Fraudulent Transfers.
"A transfer of the debtor’s property to another party in order to deter, hinder or defraud a creditor, or to unfairly place such property out of the reach of a creditor is a fraudulent transfer. In bankruptcy cases, a trustee is given the power to set aside or avoid these transfers under either federal law or state law. Section 548 of the Bankruptcy Code provides for the federal statutory basis to challenge fraudulent transfers. Section 544 of the Bankruptcy Code provides for the basis to challenge fraudulent transfers under applicable state statutory law.
There are two types of fraudulent transfers in bankruptcy. The first is actual fraud, which involves the intent to defraud creditors. The second is referred to as a constructive fraud, which involves a transfer made in exchange for inadequate consideration.
Actual fraud requires proof of intent from the person challenging the transfer. While intent must be determined on a case-by-case basis, a few examples might include the transfer of all the debtor’s assets to a newly formed company or to a family member to avoid the reach of creditors or litigation threatened against the debtor unless the property is transferred. Even involuntary transfers can be made with actual intent."
I, Crystal L. Cox am Creditor Number 13 in the Ol' Marc John Randazza Bankrutpcy Fiasco and I mailed this OBJECTION to the District of Nevada Bankruptcy Courts.
Here is a Part of it, the Whole Filing I mailed is linked below.
"Debt cannot be Discharged due to Fraud
Crystal Cox claims that Marc John Randazza premeditated this bankruptcy to avoid losing assets. Marc Randazza knew he was going to use bankruptcy to stop or get rid of pending cases against him whereby he actually committed fraud against former clients.
Crystal Cox alleges this is fraud and that debt cannot be discharged in fraud.
Marc Randazza stalled Cox’s counterclaims in the District of Nevada case by appealing a Judge’s ruling to the Ninth Circuit regarding Anti-Slapp laws in Nevada which he personally co-wrote.
This stayed the District of Nevada case pending the Ninth Circuit appeal decision. Randazza was to file an opening brief in that case in August of 2015, however he extended the filing deadline, then on August 28th, 2015 he filed bankruptcy. Randazza then filed this Bankruptcy Notice of filing in the Ninth Circuit case and thereby froze those proceedings as well.
Cox claims that Randazza premeditated these actions and planned a bankruptcy all along, and stalled in order to create trusts, spend money, hide money offshore, file for a divorce to hide money with his wife and her family and make it look like he simply, one day, could not pay his creditors nor be liable to the clients he had intentionally harmed.
Randazza continued to harm his clients and all the while knowing he was creating a massive liability. Cox’s claims against Marc Randazza are clear and convincing, they are valid and the case has been going on since Nov of 2012, nearly 3 years now.
As of January 2015 Marc Randazza knew that the Nevada courts was allowing Cox’s counterclaims, so in March of 2015 Marc Randazza begin planning his bankruptcy, he started several family trusts, bought vehicles, and in June he and his wife Jennifer Randazza who also sued Cox but Cox was not allowed to countersue per judicial order, filed for divorce. Cox alleges this too was premeditated in order to defraud creditors and those who have and had legitimate claims against Marc Randazza.
On March 9th, 2015 Marc Randazza set up the Misuraca Family Trust. He also set up Marc J. Randazza P.A as another entity and this 100% owned by the Misuraca Family Trust.
ALL this to attempt to move forward as a lawyer and not pay those he harmed in previous case and or other creditors. This was and is to protect Marc Randazza to maliciously, willfully and intentionally cheat clients, cause client harm, ruin clients business and quality of life and then simply file bankruptcy and move on as an attorney and hid his assets from those folks (creditors and clients who sued him for malpractice).
Magnolia Holdings 19 LLC is owned by Marc Randazza, Jennifer Randazza and Ronald Green, Randazza’s business partner who represents Marc Randazza and Jennifer Randazza in their lawsuit against Crystal Cox.
These trusts and this divorce filing, as well as several trips to other countries such as Canada, the UK and other countries, Cox alleges this travel was to hide money and assets, and was done with full intent to defraud Creditors, which includes Cox who has $10,000,000 in legitimate claims against Marc J. Randazza of Randazza Legal Group. Therefore Cox objects to the discharge of debt.
March 9th, 2015 Marc Randazza buys a $42,000 BMW. Randazza bought a 2013 Sienna for $25,000 and put it in Jennifer Randazza’s name. And Marc Randazza put $26,000 on tuition for private school for his children, even though one of his children was the Plaintiff in the Cox case, which was an immoral, unethical action for Mr. Randazza to have taken.
On August 25th, 2015 Marc Randazza started a 401k account at John Hancock. 3 days later on August 28th, 2015 he filed for bankruptcy. Cox claims this is clearly with intent to commit fraud on the bankruptcy courts and to defraud Creditors who were entitled to be paid.
Marc Randazza started an IRA at LPL Financial for 99,000.
Marc Randazza created a secured debt of $300,000 with his wife’s parents Denise and Cathy Brochey, of which Cox claims was to defraud creditors and hide assets from his victims.
Cox claims that Randazza created all the above specifically with intent to defraud Creditors.
Cox alleges this was all staged to defraud Creditors.
For all this to happen on the same day March 9th, 2015, is suspect and Cox moves this court to take note that it is odd that all these trusts were set up and a 42,000 BMW was purchased this same day, as well as a 25,000 Toyota Sienna for Jennifer Randazza. "
To View Full Filing, Click Below
My CLEAR and Convincing Claims against my former attorney Marc Randazza, with linking Exhibits.
A Bit more on Bankruptcy Fraud, Fraudulent Transfers and ...
Cox alleges that Marc Randazza has INTENT TO DEFRAUD and therefore he cannot discharge his debt in this bankruptcy case. I claim Marc Randazza had ACTUAL INTENT and in my case he even transfered assets to who I claim is a counter defendant in Randazza v. Cox, his wife Jennifer Randazza whom was / is a Plaintiff in that case as is their young daughter.