Washington v. William Morris Endeavor Entertainment et al. (10 Civ. 9647) (PKC) (JCF) -- Defendants' Letter to Judge Castel to Submit Motion for a Protective Order Against Mr. Washington

8/10/2019 Washington v. William Morris Endeavor Entertainment et al. (10 Civ. 9647) (PKC) (JCF) -- Defendants' Letter to Jud

1/54

Case 1:10-cv-09647-PKC-JCF Document 66 Filed 11/17/14 Page 1 of 3


2/54



3/54



4/54

Case 1:10-cv-09647-PKC-JCF Document 66-1 Filed 11/17/14 Page 1 of 4


5/54



6/54



7/54



8/54



9/54



10/54



11/54



12/54



13/54



14/54



15/54



16/54



17/54



18/54



19/54



20/54



21/54



22/54



23/54



24/54



25/54



26/54

1

Michael Barnett

From: FRCHoldContact

Sent: Monday, November 03, 2014 1:23 PM

To: John Frankenheimer

Cc: '[email protected]; [email protected]; [email protected]; [email protected]; Nathan J.

Hole; Richard Lorenzo; Tamara Carmichael; Timothy Cummins; Seth A. Rose; Roger Arar;

Ryan Austin; Sunny Brenner; Nichole Cortese; Terence Cuff; Walter H. Curchack;[email protected]; Tiffany Dunn; [email protected]; Paul Frimmer; Seth Gelblum;

[email protected]; Wook Hwang; Steven Kornblau; Thomas Lawson; Scott Liebman;

Nerissa Coyle McGinn; Robert Meyer; Nate Muyskens; Richard A. Nardi; Mitchell

Nussbaum; Sara O'Toole; Ronald Pearson; Martin Pollner; Rachel Straus;

[email protected]; Paul Rohrer; Raymond A. Sanseverino; [email protected]; Paul

Severin; Michael B. Shortnacy; Regan Smith; Rebel Roy Steiner, Jr.; Stuart P. Tobisman;

Nicholas J. Van Brunt; [email protected]; William J. ("Bill") Voller III; Mark E. Waddell;

Susan Zuckerman Williams; Stephen Zager

Subject: FW: Final Request For Loeb & Loeb LLP Attorney Christian Carbone to Disclose

Information on Relationship to Sasha Angelique Carbone | Marcus I. Washington v.

William Morris Endeavor Entertainment (10 Civ. 9647) (PKC) (JCF)

From:Marcus Luther X [mailto:[email protected]]

Sent:Monday, November 3, 2014 12:52 PM

To:[email protected]

Cc:[email protected]; [email protected]; [email protected]; [email protected]; [email protected];

[email protected]; [email protected]; [email protected]

Subject:Final Request For Loeb & Loeb LLP Attorney Christian Carbone to Disclose Information on Relationship to Sasha

Angelique Carbone | Marcus I. Washington v. William Morris Endeavor Entertainment (10 Civ. 9647) (PKC) (JCF)

Christian Dominic Carbone:

On March 10, 2014, I first reached out to you and asked if it was true that you were married to Sasha Angelique Carbone formeremployee of Loeb & Loeb LLP and a current and/or former executive (e.g. Associate General Counsel) for the AmericanArbitration Association, which just so happens to be the same arbitral forum you sought Republican appointed federal judge P. KevinCastel of the Southern District of New York to have my employment discrimination and human rights case against William Morriscompelled to. The same arbitration association that allowed their arbitrators to erroneously decide the issue of arbitrability withoutdiscussing the parties arguments and/or citing any case law although P. Kevin Castels July 20, 2011 Stay Order directed thearbitrator to decide that issue. The same arbitration association that unlawfully disqualified Arbitrator David L. Gregory after heissued his Partial Final Award on December 17, 2013, which concluded that I proved by a preponderance of the evidence thatWilliam Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local law

prohibiting discrimination in employment on the basis of race and indicated that I would be awarded the full gamut of monetarydamages (including punitive damages and pro se non attorneys fees) during phase 2 of our bifurcated proceeding. The samearbitration association that allowed AAA board of director and Schnader LLP attorney Timothy K. Lewis who has worked closelywith Sasha Angelique Carbone as a member of the AAAs Diversity Committee to vacate Gregorys Partial Final Award in violation

of 10 of the Federal Arbitration Act [the Award was ripe and final for the sake of judicial review and only Castel had jurisdiction toconfirm, modify and/or vacate Gregorys Award or disqualify him after issuing the Award]. The same arbitration association thatrefused to disqualify Lewis and allowed him to dismiss my case with prejudice and on the merits because I continued to publiclyobject to the clear fraud that was taking place in my case. The same arbitration association that advertises itself as being neutral.

I believe that as a licensed attorney in the State of New York, you had an ethical obligation to disclose information about yourmarriage to Sasha Angelique Carbone to both the Southern District of New York and myself when you decided to represent WilliamMorris alongside Michael P. Zweig in this case. Since you knew that this case was being compelled to the same forum that your wifeworked for, you should have opted against representing William Morris and you should have never been allowed to profit from thiscase. If this information is true, I believe that you highly unethical actions constitute violations under the New York Rules ofProfessional Conduct [www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdf] and New York Judiciary Law 487.



27/54

2

I also believe your actions constitute further evidence of the overall pattern of fraud Loeb & Loeb LLP has engaged in for decadesthroughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence of the record in my case) toensure that African American litigants seeking to effectuate the public policy goals of our nations civil & human rights laws bychallenging William Morris institutionally racist employment and business practices in the federal court, are deprived of their fullconstitutional and statutory rights under the color of law and prevented from having the merits of their case be decided by an impartial

jury.

Since Castel denied my request to have you confirm or deny this information by Affidavit, stated months later in his September 5,2014 Final Order that the marriage was alleged [despite Heather Santos response to my inquiry], issued a filing injunction againstme from going against Loeb & Loeb LLP, its attorneys and other co-conspirators for fraud and any other claim I deemed necessary tocorrect this manifest injustice, revoked my in forma pauperis status, prejudiced my appeal by stating that my appeal would not bemade in good faith and denied my October 3, 2014 Fed. R. Civ. P. 60 Fraud Upon the Court Motion as being without merit, Iwant to give you one last opportunity before I submit my appeal to the Second Circuit, to be honest by either confirming or denyingthat you are and/or were married to Sasha Angelique Carbone (Sasha Angelique Smith) at any time during your representation ofWilliam Morris in Washington v. William Morris Endeavor Entertainment et al. (10 Civ. 9647) (PKC) (JCF).

I just did a brief search online and the first link directed me here:



28/54

3

And the second link directed me here:



29/54

4

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decide any aspect ofmy case, and did not disclose that information to William Morris, Loeb & Loeb LLP and the Southern District of New York, you,Zweig and Loeb & Loeb LLP would have moved for the Southern District of New York to throw out any decision made in my favorand requested that serious sanctions be imposed against me for engaging in considerable bad faith and having unclean hands. Foreight months, you have refused to acknowledge or answer my request for information about your relationship to Sasha AngeliqueCarbone, but had I been married to an executive at the American Arbitration Association, I would not be allowed to wait eight months

to answer your question because Castel would have compelled me to disclose this information and had I been an actual attorney,theres no question that Castel would have immediately disbarred me.

As you are aware: fraud vitiates everything and pursuant to New York Judiciary Law 487(1), an attorney or counselor who is guiltyof any deceit or collusion, or consents to any deceit or collusion, with intent to deceive the court or any partyis guilty of amisdemeanor, and in addition to the punishment prescribed therefor by the penal law, he forfeits to the party injured treble damages, to

be recovered in a civil action. The irreparable harm that Ive suffered as a result of the overall fraud you, Zweig, Loeb & Loeb LLPand William Morris have engaged in is astronomical. Four years of my life have essentially been wasted litigating a case whoseoutcome was largely pre-determined no matter the unrefuted pyramid of evidence that I presented to prove my claims of intentionalsystemic disparate treatment, disparate impact, pre and post-hiring individual disparate treatment under Section 1981, Title VII,

NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African descent and antitrustviolations under the Sherman and Donnelly Acts. Since the Constitution guarantees equal protection under the law and justice



30/54

5

should be blind to race in our allegedly post-racial United States of America, then the punishments I would receive as a result of myhighly unethical and criminal conduct should be no different than the punishments you, Michael P. Zweig, Loeb & Loeb LLP,William Morris and other various parties should receive for intentionally engaging in fraud and conspiring to ensure that I wasdeprived of my full constitutional and statutory rights under the color of law.

Whether you decide to dignify my last request or not, just know that you will not be able to remain silent about this informationforever, so you might has well tell the truth now. I ask that you reply to this e-mail no later than Friday, November 7, 2014. My FRAP8, 24, 46(b) Motion to the Second Circuit will be submitted on or before November 21, 2014.

Best,

Marcus Washington

CC: Chief Judge Loretta A. Preska, Southern District of New YorkFederal Judge P. Kevin Castel, Southern District of New YorkFederal Judge Robert P. Patterson, Southern District of New YorkIndia Johnson, President of the American Arbitration Association

Michael Beck, Chairman of Loeb & Loeb LLPMichael P. Zweig, Partner at Loeb & Loeb LLPMichael Barnett, Associate at Loeb & Loeb LLPTal Dickstein, Senior Counsel at Loeb & Loeb LLP

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legallyprivileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any review, disclosure, copying,distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, pleaseimmediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner. Thank you.

-----Original Message-----From: M.Washington [mailto:[email protected]]Sent: Thursday, March 13, 2014 1:13 PMTo: 'AAA Heather Santo';[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected]: 'AAA Carol Placella'Subject: RE: Sasha Carbone

Heather,

You cannot speak as to what Sasha's "prior knowledge" was or is, only she can. The question that needs to be answered is: AreChristian and Sasha married? And did the AAA know that Christian and Sasha were married at any time during this arbitration

proceeding?

I am not proceeding any further with the AAA and Lewis can do whatever he wants to do because when it's all said and done, anyadverse decision he makes against me will be vitiated due to fraud.

I will be filing my Motion for Disqualification with the Southern District of New York on March 17, 2014.

Marcus Washington

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it maycontain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering itto the intended recipient, you are hereby notified that any review, disclosure, copying, distribution or use of any of the informationcontained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, pleaseimmediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.Thank you.

-----Original Message-----From: AAA Heather Santo [mailto:[email protected]]Sent: Thursday, March 13, 2014 12:50 PM



31/54

6

To: M.Washington; [email protected]; [email protected]; [email protected]: AAA Carol PlacellaSubject: Re: Sasha Carbone

Dear Parties,

In response to Mr. Washingtons email of March 10th, this will confirm that Sasha Carbone is the Associate General Counsel for theAmerican Arbitration Association. This will also confirm she did not have any prior knowledge, nor is she involved in any manner,with respect to this arbitration.

Sincerely,Heather Santo

On Mar 13, 2014, at 12:17 PM, "M.Washington" wrote:

Im aware that everyone received my first e-mail on Monday, yet, I have not received a response from anyone at the AAA or Loeb &Loeb LLP regarding the relationship between Christian & Sasha Carbone.

Christian, why didnt you explain to P. Kevin Castel when Loeb & Loeb LLP sought to compel this case into arbitration on behalf ofWilliam Morris, that your wife Sasha Angelique Carbone was the Associate General Counsel at the American ArbitrationAssociation and had been employed with the company for seven years?

http://www.linkedin.com/pub/sasha-carbone/51/b95/a23.

Why didnt anyone from the allegedly neutral AAA disclose that pertinent information to me?

The AAA has some serious decisions to make and they need to make them quickly since this case has been harmfully delayed due tofraud and I already have a final award from Arbitrator Gregory, who found that William Morris Endeavor LLC discriminatedagainst [me, pro se litigant Marcus Isaiah Washington,] in violation of pertinent federal, state, and local law prohibiting discriminationin employment on the basis of race and awarded me back pay, front pay, compensatory & punitive damages and reasonable fees andcosts, as a pro se non-attorney prevailing party on statutory claims in a case of considerable procedural and substantive complexity.

As stated, when I take legal action against William Morris, Loeb & Loeb LLP, Michael Zweig and Christian Carbone for fraud andother causes of action, the AAA, and now Sasha A. Carbone, will also be named in my Complaint.

Marcus Washingtonwww.meagainstiniquity.wordpress.com

________________________________CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it maycontain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering itto the intended recipient, you are hereby notified that any review, disclosure, copying, distribution or use of any of the informationcontained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, pleaseimmediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.Thank you.

________________________________

[cid:[email protected]]

Heather SantoDirectorAmerican Arbitration Association950 Warren Ave.East Providence, RI 02914-1414T:866 293 4053F:401 435 6529E:[email protected]



32/54

7

The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for therecipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited except by or on behalf ofthe intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy allcopies of the transmittal. Thank you.From: M.Washington [mailto:[email protected]]Sent: Monday, March 10, 2014 7:08 PMTo: [email protected]; [email protected];[email protected]; [email protected]: [email protected]; AAA Carol Placella; [email protected];[email protected]: Sasha Carbone

Hi Christian & the AAA,

Can you please confirm whether or not your wifes name is Sasha Carbone? Also, can you confirm if your wife is an executive at theAmerican Arbitration Association [please see attachment]?

If the answer to both of these questions is yes, I need to know if India Johnson and the AAA were aware of this information at anytime during this arbitration proceeding.

I also ask that due to this overall fraud perpetrated by William Morris, Loeb & Loeb LLP, Michael P. Zweig, Christian Carbone and

others, default judgment be immediately granted on all claims pled against William Morris and $250,000,000.00 be awarded in myfavor.

Best,

Marcus Washington

________________________________CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it maycontain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering itto the intended recipient, you are hereby notified that any review, disclosure, copying, distribution or use of any of the informationcontained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, pleaseimmediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.

Thank you.________________________________



33/54



34/54

2

From: Marcus Luther X [mailto:[email protected]]

Sent:Friday, November 07, 2014 9:05 AMTo: Klein, Jeffrey;[email protected];[email protected]:[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];

[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected]:FW: Final Request For Loeb & Loeb LLP Attorney Christian Carbone to Disclose Information on Relationship toSasha Angelique Carbone | Marcus I. Washington v. William Morris Endeavor Entertainment (10 Civ. 9647) (PKC) (JCF)


On March 10, 2014, I first reached out to you and asked if it was true that you were married to Sasha Angelique Carbone formeremployee of Loeb & Loeb LLP and a current and/or former executive (e.g. Associate General Counsel) for the AmericanArbitration Association, which just so happens to be the same arbitral forum you sought Republican appointed federal judge P. KevinCastel of the Southern District of New York to have my employment discrimination and human rights case against William Morriscompelled to. The same arbitration association that allowed their arbitrators to erroneously decide the issue of arbitrability withoutdiscussing the parties arguments and/or citing any case law although P. Kevin Castels July 20, 2011 Stay Order directed thearbitrator to decide that issue. The same arbitration association that unlawfully disqualified Arbitrator David L. Gregory after heissued his Partial Final Award on December 17, 2013, which concluded that I proved by a preponderance of the evidence thatWilliam Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local law



35/54

3

prohibiting discrimination in employment on the basis of race and indicated that I would be awarded the full gamut of monetarydamages (including punitive damages and pro se non attorneys fees) during phase 2 of our bifurcated proceeding. The samearbitration association that allowed AAA board of director and Schnader LLP attorney Timothy K. Lewis who has worked closelywith Sasha Angelique Carbone as a member of the AAAs Diversity Committee to vacate Gregorys Partial Final Award in violationof 10 of the Federal Arbitration Act [the Award was ripe and final for the sake of judicial review and only Castel had jurisdiction toconfirm, modify and/or vacate Gregorys Award or disqualify him after issuing the Award]. The same arbitration association thatrefused to disqualify Lewis and allowed him to dismiss my case with prejudice and on the merits because I continued to publiclyobject to the clear fraud that was taking place in my case. The same arbitration association that advertises itself as being neutral.

I believe that as a licensed attorney in the State of New York, you had an ethical obligation to disclose information about yourmarriage to Sasha Angelique Carbone to both the Southern District of New York and myself when you decided to represent WilliamMorris alongside Michael P. Zweig in this case. Since you knew that this case was being compelled to the same forum that your wifeworked for, you should have opted against representing William Morris and you should have never been allowed to profit from thiscase. If this information is true, I believe that you highly unethical actions constitute violations under the New York Rules ofProfessional Conduct [www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdf] and New York Judiciary Law 487.I also believe your actions constitute further evidence of the overall pattern of fraud Loeb & Loeb LLP has engaged in for decadesthroughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence of the record in my case) toensure that African American litigants seeking to effectuate the public policy goals of our nations civil & human rights laws bychallenging William Morris institutionally racist employment and business practices in the federal court, are deprived of their fullconstitutional and statutory rights under the color of law and prevented from having the merits of their case be decided by an impartial

jury.





36/54

4




37/54

5



38/54

6








39/54

7



Best,

Marcus Washington





Heather,


proceeding?



Marcus Washington





40/54

8


Dear Parties,












________________________________





41/54

9







Best,

Marcus Washington


Thank you.________________________________

The information contained in this email message is intended only for use of the individual or entity named above. If thereader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intendedrecipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictlyprohibited. If you have received this communication in error, please immediately notify us by email, [email protected]

and destroy the original message. Thank you.



42/54



43/54

1

Michael Barnett

From: FRCHoldContact

Sent: Wednesday, November 12, 2014 7:49 PM

To: [email protected]; [email protected]; [email protected]; [email protected];

[email protected]; [email protected]; [email protected];

[email protected]; [email protected]

Cc: Christian Carbone; Michael Zweig; Michael Beck; Michael Barnett; John FrankenheimerSubject: Complaint re: Unethical Conduct of Loeb & Loeb LLP Attorney Christian Carbone

Pursuant to Local Rule of the Court of Appeals to the Second Circuit 46.2(b)(3)(A)

Attachments: Nov 3 2014 Letter to Christian Carbone re Wife.pdf

November 3, 2014

Mr. Christian Dominic CarboneLoeb & Loeb LLP345 Park Avenue

New York, New York 10154

Re: Final Request For Loeb & Loeb LLP Attorney Christian Carbone to Disclose Information on Relationship to Sasha

Angelique Carbone | Marcus I. Washington v. William Morris Endeavor Entertainment (10 Civ. 9647) (PKC) (JCF)


On March 10, 2014, I first reached out to you and asked if it was true that you were married to Sasha Angelique Carbone formeremployee of Loeb & Loeb LLP and a current and/or former executive (e.g. Associate General Counsel) for the AmericanArbitration Association, which just so happens to be the same arbitral forum you sought Republican appointed federal judge P. KevinCastel of the Southern District of New York to have my employment discrimination and human rights case against William Morris

compelled to. The same arbitration association that allowed their arbitrators to erroneously decide the issue of arbitrability withoutdiscussing the parties arguments and/or citing any case law although P. Kevin Castels July 20, 2011 Stay Order directed thearbitrator to decide that issue. The same arbitration association that unlawfully disqualified Arbitrator David L. Gregory after heissued his Partial Final Award on December 17, 2013, which concluded that I proved by a preponderance of the evidence thatWilliam Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local law

prohibiting discrimination in employment on the basis of race and indicated that I would be awarded the full gamut of monetarydamages (including punitive damages and pro se non attorneys fees) during phase 2 of our bifurcated proceeding. The samearbitration association that allowed AAA board of director and Schnader LLP attorney Timothy K. Lewis who has worked closelywith Sasha Angelique Carbone as a member of the AAAs Diversity Committee to vacate Gregorys Partial Final Award in violationof 10 of the Federal Arbitration Act [the Award was ripe and final for the sake of judicial review and only Castel had jurisdiction toconfirm, modify and/or vacate Gregorys Award or disqualify him after issuing the Award]. The same arbitration association thatrefused to disqualify Lewis and allowed him to dismiss my case with prejudice and on the merits because I continued to publiclyobject to the clear fraud that was taking place in my case. The same arbitration association that advertises itself as being neutral.

I believe that as a licensed attorney in the State of New York, you had an ethical obligation to disclose information about yourmarriage to Sasha Angelique Carbone to both the Southern District of New York and myself when you decided to represent WilliamMorris alongside Michael P. Zweig in this case. Since you knew that this case was being compelled to the same forum that your wifeworked for, you should have opted against representing William Morris and you should have never been allowed to profit from thiscase. If this information is true, I believe that you highly unethical actions constitute violations under the New York Rules ofProfessional Conduct [www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdf] and New York Judiciary Law 487.I also believe your actions constitute further evidence of the overall pattern of fraud Loeb & Loeb LLP has engaged in for decadesthroughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence of the record in my case) toensure that African American litigants seeking to effectuate the public policy goals of our nations civil & human rights laws bychallenging William Morris institutionally racist employment and business practices in the federal court, are deprived of their full



44/54

2

constitutional and statutory rights under the color of law and prevented from having the merits of their case be decided by an impartialjury.






45/54

3



46/54

4








47/54

5



Best,

Marcus Washington





Heather,


proceeding?



Marcus Washington





48/54

6


Dear Parties,












________________________________





49/54

7







Best,

Marcus Washington


Thank you.________________________________




50/54



51/54

meagainstiniquity.wordpress.com

https://meagainstiniquity.wordpress.com/2014/11/03/the-southern-district-ofnew-york-needs-to-be-fumigate

the southern district of new york needs to be FUMIGATED!!! get

those racist and corrupt rats out of there!!


On March 10, 2014, I first reached out to you and asked if it was true that you were married to Sasha Angelique

Carbone former employee of Loeb & Loeb LLP and a current and/or former executive (e.g. Associate General

Counsel) for the American Arbitration Association, which just so happens to be the same arbitral forum you sought

Republican appointed federal judge P. Kevin Castel of the Southern District of New York to have my employment

discrimination and human rights case against William Morris compelled to. The same arbitration association that

allowed their arbitrators to erroneously decide the issue of arbitrability without discussing the parties arguments

and/or citing any case law although P. Kevin Castels July 20, 2011 Stay Order directed the arbitrator to decide that

issue. The same arbitration association that unlawfully disqualified Arbitrator David L. Gregory after he issued his

Partial Final Award on December 17, 2013, which concluded that I proved by a preponderance of the evidence tha

William Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, andlocal law prohibiting discrimination in employment on the basis of race and indicated that I would be awarded the fu

gamut of monetary damages (including punitive damages and pro se non attorneys fees) during phase 2 of our

bifurcated proceeding. The same arbitration association that allowed AAA board of director and Schnader LLP

attorney Timothy K. Lewis who has worked closely with Sasha Angelique Carbone as a member of the AAAs

Diversity Committee to vacate Gregorys Partial Final Award in violation of 10 of the Federal Arbitration Act [the

Award was ripe and final for the sake of judicial review and only Castel had jurisdiction to confirm, modify and/or

vacate Gregorys Award or disqualify him after issuing the Award]. The same arbitration association that refused to

disqualify Lewis and allowed him to dismiss my case with prejudice and on the merits because I continued to publi

object to the clear fraud that was taking place in my case. The same arbitration association that advertises itself as

being neutral.

I believe that as a licensed attorney in the State of New York, you had an ethical obligation to disclose information

about your marriage to Sasha Angelique Carbone to both the Southern District of New York and myself when you

decided to represent William Morris alongside Michael P. Zweig in this case. Since you knew that this case was

being compelled to the same forum that your wife worked for, you should have opted against representing William

Morris and you should have never been allowed to profit from this case. If this information is true, I believe that you

highly unethical actions constitute violations under the New York Rules of Professional Conduct

[www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdf] and New York Judiciary Law 487. I also

believe your actions constitute further evidence of the overall pattern of fraud Loeb & Loeb LLP has engaged in fo

decades throughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William

MorrisAgency et al. (98 Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into theevidence of the record in my case) to ensure that African American litigants seeking to effectuate the public policy

goals of our nations civil & human rights laws by challenging William Morris institutionally racist employment and

business practices in the federal court, are deprived of their full constitutional and statutory rights under the color of

law and prevented from having the merits of their case be decided by an impartial jury.

Since Castel denied my request to have you confirm or deny this information by Affidavit, stated months later in his

September 5, 2014 Final Order that the marriage was alleged [despite Heather Santos response to my inquiry],

issued a filing injunction against me from going against Loeb & Loeb LLP, its attorneys and other co-conspirators for

fraud and any other claim I deemed necessary to correct this manifest injustice, revoked my in forma pauperis statu

prejudiced my appeal by stating that my appeal would not be made in good faith and denied my October 3, 2014

http://www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdfhttps://meagainstiniquity.wordpress.com/2014/11/03/the-southern-district-ofnew-york-needs-to-be-fumigated/https://meagainstiniquity.wordpress.com/http://www.nycourts.gov/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdfhttps://meagainstiniquity.wordpress.com/2014/11/03/the-southern-district-ofnew-york-needs-to-be-fumigated/https://meagainstiniquity.wordpress.com/


52/54


53/54

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decid

any aspect of my case, and did not disclose that information to William Morris, Loeb & Loeb LLP and the Southern

District of New York, you, Zweig and Loeb & Loeb LLP would have moved for the Southern District of New York to

throw out any decision made in my favor and requested that serious sanctions be imposed against me for engaging

considerable bad faith and having unclean hands. For eight months, you have refused to acknowledge or answe

my request for information about your relationship to Sasha Angelique Carbone, but had I been married to an

executive at the American Arbitration Association, I would not be allowed to wait eight months to answer your questi

because Castel would have compelled me to disclose this information and had I been an actual attorney, theres no

question that Castel would have immediately disbarred me.

As you are aware: fraud vitiates everything and pursuant to New York Judiciary Law 487(1), an attorney or

counselor who is guilty of any deceit or collusion, or consents to any deceit or collusion, with intent to deceive the

court or any partyis guilty of a misdemeanor, and in addition to the punishment prescribed therefor by the penal la

he forfeits to the party injured treble damages, to be recovered in a civil action. The irreparable harm that Ive

suffered as a result of the overall fraud you, Zweig, Loeb & Loeb LLP and William Morris have engaged in is

astronomical. Four years of my life have essentially been wasted litigating a case whose outcome was largely pre-

determined no matter the unrefuted pyramid of evidence that I presented to prove my claims of intentional systemic

disparate treatment, disparate impact, pre and post-hiring individual disparate treatment under Section 1981, Title V

NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African desce

and antitrust violations under the Sherman and Donnelly Acts. Since the Constitution guarantees equal protection

under the law and justice should be blind to race in our allegedly post-racial United States of America, then the

punishments I would receive as a result of my highly unethical and criminal conduct should be no different than thepunishments you, Michael P. Zweig, Loeb & Loeb LLP, William Morris and other various parties should receive for

intentionally engaging in fraud and conspiring to ensure that I was deprived of my full constitutional and statutory

rights under the color of law.

Whether you decide to dignify my last request or not, just know that you will not be able to remain silent about this

information forever, so you might has well tell the truth now. I ask that you reply to this e-mail no later than Friday,

November 7, 2014. My FRAP 8, 24, 46(b) Motion to the Second Circuit will be submitted on or before November 21

2014.

Best,



54/54

Marcus Washington

CC: Chief Judge Loretta A. Preska, Southern District of New York

Federal Judge P. Kevin Castel, Southern District of New York

Federal Judge Robert P. Patterson, Southern District of New York

India Johnson, President of the American Arbitration Association

Michael Beck, Chairman of Loeb & Loeb LLP

Michael P. Zweig, Partner at Loeb & Loeb LLP

Michael Barnett, Associate at Loeb & Loeb LLP

Tal Dickstein, Senior Counsel at Loeb & Loeb LLP

About these ads

Related

http://wordpress.com/about-these-ads/

Documents

Washington v. William Morris Endeavor Entertainment et al. (10 Civ. 9647) (PKC) (JCF) -- Defendants' Letter to Judge Castel to Submit Motion for a Protective Order Against Mr. Washington