(MicHaeL P. ZWEIG Partner 245 Park Avenve birt 2124074090 tow Yor in 21 LOEB& New Yor NY 10154 Fax 212.208.2582 LOEBue meweig@loeb.com Via Federal Express July 24, 2015 The Honorable Justice Ruth Bader Ginsburg ‘Supreme Court of the United States 1 First Street, NE Washington, DC 20543 Re: Washington v. William Morris Endeavor Entertainment, LLC et al Dear Justice Ginsburg: We represent Respondents William Morris Endeavor Entertainment, LLC (‘WMEE"), Jeff Meade, and Sarah Winiarski (collectively, “Respondents’) in the above-referenced case. We respectfully submit this letter in opposition to pro se Petitioner Marcus Washington's June 18, 2015 motion for leave to proceed in forma pauperis and application for an extension of time to file a petition for a writ of certiorari. Mr. Washington’s application should be denied because, among other reasons, he fails to demonstrate an entitlement to the relief sought or establish why he needs additional time to file his petition for a writ of certiorari with this Court. Under Supreme Court Rule 13.5 (which Mr. Washington himself quotes in his brief), Mr. Washington was required to demonstrate “good cause" and “set out specific reasons why an extension of time is justified,” and he has failed to do so. As to Mr. Washington's motion for leave to proceed in forma pauperis, we note that the USS. District Court for the Southern District of New York sua sponte denied Mr. Washington in forma pauperis status in a September 5, 2014 Order directing Judgment against Mr. Washington, holding that any appeal therefrom “would not be taken in good faith.” See Memorandum and Order, Washington v. William Morris Endeavor Entertainment, LLC et al., No. 10-cv-9647 (S.D.N.Y. Sept. 5, 2014). Mr. Washington then moved for leave to proceed in forma pauperis before the U.S. Court of Appeals for the Second Circuit, which denied the motion on March 11, 2015. See Motion Order, Washington v. William Morris Endeavor Entertainment, LLC et al., No. 14-4328 (2d Cir. Mar. 11, 2015). As with Mr. Washington's appeal below, any petition filed with this Court would be frivolous, and the motion should therefore be denied pursuant to Supreme Court Rule 39.8. The Court may find helpful the following background information: Mr. Washington commenced an action in the district court on December 22, 2010 against his former employer, WMEE, and two of its Human Resources employees, Mr. Meade and Ms. Winiarski, asserting claims of discrimination and retaliation under federal and state law. Respondents successfully moved to stay the action pending arbitration. In June 2014, the arbitrator, former U.S. Court of Appeals Judge Timothy K. Lewis, issued an award dismissing Mr. Washington's claims in full and ordering Mr. Washington to pay Respondents $43,707.60 for, among other things, failing to Los Angeles NewYork Chicago Nashuile Washington, DC Bejing Hong Kong_wwwloeb.comi reve ne a By Sa sa prosecute his claims in good faith; repeatedly violating the terms of the arbitrator's confidentiality order; and threatening to file illegal and fraudulent commercial liens against Respondents, their attorneys, numerous federal judges and the arbitrator. On September 5, 2014, the district court confirmed the arbitral award and issued a filing injunction against Mr. Washington prohibiting him from, among other things, commencing future actions arising out of his employment with WMEE and filing commercial liens against the above-listed persons. See Memorandum and Order, Washington, No. 10-cv-9647 (S.D.N.Y. Sept. 5, 2014). Mr. Washington appealed that Order, and the Second Circuit dismissed his appeal on March 11, 2015, holding that it "lacks an arguable basis either in law or in fact.” See Motion Order, Washington, No. 14-4328 (2d Cir. Mar. 11, 2015), In his motion papers before this Court, Mr. Washington raises the same, previously rejected argument that he has raised in other fora: that a “white/'Jewish” conspiracy, of which WMI competitors, its counsel, and members of the federal judiciary are purportedly members, exists to prevent him from finding employment in the entertainment industry. See, e.g., Pet. Mot. at 15 (Tilt cannot be disputed that ‘Jews’ of European descent are overrepresented in positions of power in Hollywood’); id, at 20 (‘no one group should have a monopoly over Hollywood and the marketplace of ideas—especially those who falsely proclaim to be ‘God's chosen people”). Mr. Washington's argument is without basis in law or fact; serves only to harass and impugn the integrity of the lower courts, Respondents, and their counsel; and underscores the frivolous nature of any petition that Mr. Washington would file with this Court We respectfully request that the Court deny Petitioner's motion. Respegtfully submitted, LQ Michael P. Zweig Partner cc: Marcus Washington (via email & regular mail) Christian D. Carbone, Esq. (via email) Ny19502802 (058425-10022