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Patricia K. Bucklin, Esq. Executive Director New York State Bar One Elk Street Albany, NY 12207

LEONARD ROWE 1006BAYTREE

Duluth, Georgia 30097 404-374-1370 April6, 2010

Departmental Disciplinary Committee For the First District 61 Broadway, 2nd Floor New York, NY 1 0006

Dear Executive Director Bucklin and State Bar Disciplinary Officials:

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I write to file a formal grievance against Attorneys Martin Roth Gold (Bar No. 1 023639) and Attorney Raymond James Heslin (Bar No. 1131754) who previously represented the undersigned during some exceptionally complex and politically sensitive litigation against The William Morris Agency, Creative Artist Agency (CAA) and other defendants regarding race based discrimination in the entertainment industry that has, and continues to plague the African­American Promoters since the industry's inception. It is my understanding that both of these attorneys are now employed by and/or practicing law with the law firm of Sonnenschein, Nath & Rosenthal at 1221 Avenue ofthe Americas, New York, New York 10020-1001.

The attorneys referenced herein above, actually sought me and my company out as party plaintiffs, along with other African-American Promoters, inducing us to retain their firm for the rendition of professional services in part, because they asserted that we had a "great case". The evidence was overwhelming in support of the allegations contained in the Complaint and what we had acquired in discovery. To say that this information was "damning" would be a gross understatement.

The attorneys referenced above, however, upon seeing what was at stake, undertook a conscious effort to undermine the case of their primary clients in favor of maintaining the status quo in the entertainment industry by breaching their fiduciary duty of loyalty to us, their clients. This breach of fiduciary duty took the form of intentional failures to disclose to us the discovery information that had been received which literally revealed that the defendants in the case had used the derogatory term "niggers" or variants thereof, over 230 times in official documentation, e-mails and related items between the defendants in their ongoing efforts to keep African­American Promoters from a fair chance to compete in the business.

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Executive Director Bucklin & Disciplinary Committee: pg. 2:

Instead of doing what they were properly retained to do, Attorneys Gold and Heslin, began a campaign to injury, damage and sabotage our case by working with opposing counsel and, it appears that they may have compromised the judge assigned to our case, to crush our efforts and destroy any chance for us to prove our case by keeping the discovery fruits and documentation from us and then, without warning, withdrawing from our case on the eve of the summary judgment hearing in federal court which caused irreparable damage to our cause. Additionally, these attorneys also threatened me, directly, that if I opposed their withdrawal, they would go to the judge and take action, ex parte, to create more problems for me and the case. I cannot begin to explain to you the egregious and atrocious loss that we sustained as a direct result of the knowingly wrongful and despicable tactics deployed by these attorneys in our case.

These types of shenanigans are precisely what undermines the public's confidence in the judicial system in general and lawyers in particular. The thought that your lawyer will "sell you out", "push you over the cliff' or "make you walk the plank or push you out of the boat in the middle of the ocean" finds substantial support in the actions of Marty Gold and Ray Heslin.

Understanding that your Committee cannot represent the undersigned or offer legal advice, I do, however, request that a full, fonnal investigation into the impropriety of the attorneys referenced herein for ethical violations and infractions of the Code of Professional Responsibility be undertaken and appropriate disciplinary action be imposed to deter future misconduct by these attorneys against their clients.

Please take all steps necessary to bring these concerns to the attorneys that this grievance concerns and acquire their responses thereto and apprise me of same. If there is anything else that I can do to assist your organization in this process please do not hesitate to let me know as I have retained copies of pertinent documents and related items that will serve as evidence of all that I have asserted herein above.

Thanking you in advance for your anticipated interest and assistance in this matter. I remain;