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Michael Barnett
From:
Sent:
To:
Cc:

Subject:

FRCHoldContact
Monday, November 03, 2014 1:23 PM
John Frankenheimer
'newhallc@adr.org; naimarkr@adr.org; tuchmanne@adr.org; rossif@adr.org; 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;
pdrucker@loeb.com; Tiffany Dunn; wedmiston@loeb.com; Paul Frimmer; Seth Gelblum;
tguida@loeb.com; 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;
trohlf@loeb.com; Paul Rohrer; Raymond A. Sanseverino; schneider@loeb.com; Paul
Severin; Michael B. Shortnacy; Regan Smith; Rebel Roy Steiner, Jr.; Stuart P. Tobisman;
Nicholas J. Van Brunt; nbrunt@loeb.com; William J. ("Bill") Voller III; Mark E. Waddell;
Susan Zuckerman Williams; Stephen Zager
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:humanrights.areamust@gmail.com]


Sent: Monday, November 3, 2014 12:52 PM
To: ccarbone@loeb.com
Cc: mbeck@loeb.com; mzweig@loeb.com; mbarnett@loeb.com; tdickstein@loeb.com; johnsoni@adr.org;
pkevin_castel@nysd.uscourts.gov; robert_p_patterson@nysd.uscourts.gov; loretta_a_preska@nysd.uscourts.gov
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 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 that
William 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 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 publicly
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.
1

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 3 of 8


I also believe your actions constitute further evidence of the overall pattern of fraud Loeb & Loeb LLP has engaged in for decades
throughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98
Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence 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 status, prejudiced my appeal by stating that my appeal would not be
made in good faith and denied my October 3, 2014 Fed. R. Civ. P. 60 Fraud Upon the Court Motion as being without merit, I
want to give you one last opportunity before I submit my appeal to the Second Circuit, to be honest by either confirming or denying
that you are and/or were married to Sasha Angelique Carbone (Sasha Angelique Smith) at any time during your representation of
William 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:

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 4 of 8

And the second link directed me here:

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 5 of 8

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decide 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 in considerable bad faith and having unclean hands. For
eight months, you have refused to acknowledge or answer 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 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 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 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 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 VII,
NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African descent and antitrust
violations under the Sherman and Donnelly Acts. Since the Constitution guarantees equal protection under the law and justice
4

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 6 of 8


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 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 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,
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

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally
privileged. 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, please
immediately 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:humanrights.areamust@gmail.com]


Sent: Thursday, March 13, 2014 1:13 PM
To: 'AAA Heather Santo'; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com; johnsoni@adr.org; tlewis@schnader.com;
mbeck@loeb.com; carbones@adr.org
Cc: '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: Are
Christian 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, any
adverse 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 may
contain confidential information that is legally privileged. 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, please
immediately 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:heathersanto@adr.org]


Sent: Thursday, March 13, 2014 12:50 PM
5

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 7 of 8


To: M.Washington; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com
Cc: AAA Carol Placella
Subject: 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 the
American 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" <humanrights.areamust@gmail.com<mailto:humanrights.areamust@gmail.com>>
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 of
William Morris, that your wife Sasha Angelique Carbone was the Associate General Counsel at the American Arbitration
Association 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 to
fraud and I already have a final award from Arbitrator Gregory, who found that William Morris Endeavor LLC discriminated
against [me, pro se litigant Marcus Isaiah Washington,] in violation of pertinent federal, state, and local law prohibiting discrimination
in employment on the basis of race and awarded me back pay, front pay, compensatory & punitive damages and reasonable fees and
costs, 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 and
other causes of action, the AAA, and now Sasha A. Carbone, will also be named in my Complaint.
Marcus Washington
www.meagainstiniquity.wordpress.com<http://www.meagainstiniquity.wordpress.com>
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

[cid:image831fb8.png@b866223b.a891457c]
Heather Santo
Director
American Arbitration Association
950 Warren Ave.
East Providence, RI 02914-1414
T:866 293 4053
F:401 435 6529
E:heathersanto@adr.org
6

Case 1:10-cv-09647-PKC-JCF Document 66-4 Filed 11/17/14 Page 8 of 8

The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for the
recipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited except by or on behalf of
the intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy all
copies of the transmittal. Thank you.
From: M.Washington [mailto:humanrights.areamust@gmail.com]
Sent: Monday, March 10, 2014 7:08 PM
To: ccarbone@loeb.com<mailto:ccarbone@loeb.com>; mzweig@loeb.com<mailto:mzweig@loeb.com>;
mbeck@loeb.com<mailto:mbeck@loeb.com>; johnsoni@adr.org<mailto:johnsoni@adr.org>
Cc: heathersanto@adr.org<mailto:heathersanto@adr.org>; AAA Carol Placella; mbarnett@loeb.com<mailto:mbarnett@loeb.com>;
tlewis@schnader.com<mailto:tlewis@schnader.com>
Subject: 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 the
American 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 any
time 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 my
favor.
Best,
Marcus Washington
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 1 of 9

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 2 of 9

From: Marcus Luther X [mailto:humanrights.areamust@gmail.com]


Sent: Friday, November 07, 2014 9:05 AM
To: Klein, Jeffrey; weg@williegary.com; jkessler@winston.com
Cc: george.pyne@imgworld.com; rick.smith@imgworld.com; chip.mccarthy@imgworld.com; heidi.scott@imgworld.com;
mike.dodson@imgworld.com; john.sands@imgworld.com; dan.king@imgworld.com; chris.clements@imgworld.com;
john.murray@imgworld.com; michael.dierks@imgworld.com; amanda.windsor@imgworld.com;
tammy.purves@imgworld.com; kevin.ring@imgworld.com; clarke.jones@imgworld.com;
stephane.schindler@imgworld.com; ratha.harntha@imgworld.com; angela.lavinski@imgworld.com;
bryon.allen@imgworld.com; babette.perry@imgworld.com; daniel.siegel@imgworld.com; ivan.bart@imgworld.com;
jay.kenney@imgworld.com; john.meis@imgworld.com; kirsten.hunt@imgworld.com; mark.dyer@imgworld.com;
michael.brown@imgworld.com
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)
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 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 that
William Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local law
2

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 3 of 9


prohibiting discrimination in employment on the basis of race and indicated that I would be awarded the full 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 publicly
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 for decades
throughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98
Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence 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 status, prejudiced my appeal by stating that my appeal would not be
made in good faith and denied my October 3, 2014 Fed. R. Civ. P. 60 Fraud Upon the Court Motion as being without merit, I
want to give you one last opportunity before I submit my appeal to the Second Circuit, to be honest by either confirming or denying
that you are and/or were married to Sasha Angelique Carbone (Sasha Angelique Smith) at any time during your representation of
William 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:

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 4 of 9

And the second link directed me here:

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 5 of 9

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 6 of 9

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decide 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 in considerable bad faith and having unclean hands. For
eight months, you have refused to acknowledge or answer 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 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 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 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 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 VII,
NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African descent and antitrust
violations under the Sherman and Donnelly Acts. Since the Constitution guarantees equal protection under the law and justice
6

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 7 of 9


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 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 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,
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

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally
privileged. 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, please
immediately 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:humanrights.areamust@gmail.com]


Sent: Thursday, March 13, 2014 1:13 PM
To: 'AAA Heather Santo'; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com; johnsoni@adr.org; tlewis@schnader.com;
mbeck@loeb.com; carbones@adr.org
Cc: '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: Are
Christian 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, any
adverse 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 may
contain confidential information that is legally privileged. 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, please
immediately 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:heathersanto@adr.org]


Sent: Thursday, March 13, 2014 12:50 PM
7

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 8 of 9


To: M.Washington; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com
Cc: AAA Carol Placella
Subject: 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 the
American 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" <humanrights.areamust@gmail.com<mailto:humanrights.areamust@gmail.com>>
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 of
William Morris, that your wife Sasha Angelique Carbone was the Associate General Counsel at the American Arbitration
Association 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 to
fraud and I already have a final award from Arbitrator Gregory, who found that William Morris Endeavor LLC discriminated
against [me, pro se litigant Marcus Isaiah Washington,] in violation of pertinent federal, state, and local law prohibiting discrimination
in employment on the basis of race and awarded me back pay, front pay, compensatory & punitive damages and reasonable fees and
costs, 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 and
other causes of action, the AAA, and now Sasha A. Carbone, will also be named in my Complaint.
Marcus Washington
www.meagainstiniquity.wordpress.com<http://www.meagainstiniquity.wordpress.com>
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

[cid:image831fb8.png@b866223b.a891457c]
Heather Santo
Director
American Arbitration Association
950 Warren Ave.
East Providence, RI 02914-1414
T:866 293 4053
F:401 435 6529
E:heathersanto@adr.org
8

Case 1:10-cv-09647-PKC-JCF Document 66-5 Filed 11/17/14 Page 9 of 9

The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for the
recipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited except by or on behalf of
the intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy all
copies of the transmittal. Thank you.
From: M.Washington [mailto:humanrights.areamust@gmail.com]
Sent: Monday, March 10, 2014 7:08 PM
To: ccarbone@loeb.com<mailto:ccarbone@loeb.com>; mzweig@loeb.com<mailto:mzweig@loeb.com>;
mbeck@loeb.com<mailto:mbeck@loeb.com>; johnsoni@adr.org<mailto:johnsoni@adr.org>
Cc: heathersanto@adr.org<mailto:heathersanto@adr.org>; AAA Carol Placella; mbarnett@loeb.com<mailto:mbarnett@loeb.com>;
tlewis@schnader.com<mailto:tlewis@schnader.com>
Subject: 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 the
American 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 any
time 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 my
favor.
Best,
Marcus Washington
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

The information contained in this email message is intended only for use of the individual or entity named above. If the
reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended
recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly
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Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 1 of 8

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 2 of 8


Michael Barnett
From:
Sent:
To:

Cc:
Subject:
Attachments:

FRCHoldContact
Wednesday, November 12, 2014 7:49 PM
seymourk@sullcrom.com; jglasser@wiggin.com; edavis@cgsh.com; HLevine@woh.com;
pcurnin@stblaw.com; tmc@connors-vilardo.com; gwalpin@earthlink.net;
eblackwood@burlingtonvt.gov; mpatrick@fragomen.com
Christian Carbone; Michael Zweig; Michael Beck; Michael Barnett; John Frankenheimer
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)
Nov 3 2014 Letter to Christian Carbone re Wife.pdf

November 3, 2014

Mr. Christian Dominic Carbone


Loeb & Loeb LLP
345 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)

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 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 that
William 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 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 publicly
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 for decades
throughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William Morris Agency et al. (98
Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the evidence 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
1

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 3 of 8


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 status, prejudiced my appeal by stating that my appeal would not be
made in good faith and denied my October 3, 2014 Fed. R. Civ. P. 60 Fraud Upon the Court Motion as being without merit, I
want to give you one last opportunity before I submit my appeal to the Second Circuit, to be honest by either confirming or denying
that you are and/or were married to Sasha Angelique Carbone (Sasha Angelique Smith) at any time during your representation of
William 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:

And the second link directed me here:

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 4 of 8

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 5 of 8

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decide 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 in considerable bad faith and having unclean hands. For
eight months, you have refused to acknowledge or answer 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 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 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 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 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 VII,
NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African descent and antitrust
violations under the Sherman and Donnelly Acts. Since the Constitution guarantees equal protection under the law and justice
4

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 6 of 8


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 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 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,
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

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally
privileged. 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, please
immediately 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:humanrights.areamust@gmail.com]


Sent: Thursday, March 13, 2014 1:13 PM
To: 'AAA Heather Santo'; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com; johnsoni@adr.org; tlewis@schnader.com;
mbeck@loeb.com; carbones@adr.org
Cc: '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: Are
Christian 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, any
adverse 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 may
contain confidential information that is legally privileged. 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, please
immediately 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:heathersanto@adr.org]


Sent: Thursday, March 13, 2014 12:50 PM
5

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 7 of 8


To: M.Washington; ccarbone@loeb.com; mzweig@loeb.com; mbarnett@loeb.com
Cc: AAA Carol Placella
Subject: 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 the
American 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" <humanrights.areamust@gmail.com<mailto:humanrights.areamust@gmail.com>>
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 of
William Morris, that your wife Sasha Angelique Carbone was the Associate General Counsel at the American Arbitration
Association 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 to
fraud and I already have a final award from Arbitrator Gregory, who found that William Morris Endeavor LLC discriminated
against [me, pro se litigant Marcus Isaiah Washington,] in violation of pertinent federal, state, and local law prohibiting discrimination
in employment on the basis of race and awarded me back pay, front pay, compensatory & punitive damages and reasonable fees and
costs, 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 and
other causes of action, the AAA, and now Sasha A. Carbone, will also be named in my Complaint.
Marcus Washington
www.meagainstiniquity.wordpress.com<http://www.meagainstiniquity.wordpress.com>
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

[cid:image831fb8.png@b866223b.a891457c]
Heather Santo
Director
American Arbitration Association
950 Warren Ave.
East Providence, RI 02914-1414
T:866 293 4053
F:401 435 6529
E:heathersanto@adr.org
6

Case 1:10-cv-09647-PKC-JCF Document 66-6 Filed 11/17/14 Page 8 of 8

The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for the
recipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited except by or on behalf of
the intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy all
copies of the transmittal. Thank you.
From: M.Washington [mailto:humanrights.areamust@gmail.com]
Sent: Monday, March 10, 2014 7:08 PM
To: ccarbone@loeb.com<mailto:ccarbone@loeb.com>; mzweig@loeb.com<mailto:mzweig@loeb.com>;
mbeck@loeb.com<mailto:mbeck@loeb.com>; johnsoni@adr.org<mailto:johnsoni@adr.org>
Cc: heathersanto@adr.org<mailto:heathersanto@adr.org>; AAA Carol Placella; mbarnett@loeb.com<mailto:mbarnett@loeb.com>;
tlewis@schnader.com<mailto:tlewis@schnader.com>
Subject: 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 the
American 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 any
time 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 my
favor.
Best,
Marcus Washington
________________________________
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may
contain confidential information that is legally privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.
Thank you.
________________________________

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally
privileged. 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, please
immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner. Thank you.

Case 1:10-cv-09647-PKC-JCF Document 66-7 Filed 11/17/14 Page 1 of 5

Case 1:10-cv-09647-PKC-JCF Document 66-7 Filed 11/17/14 Page 2 of 5


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

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


those racist and corrupt rats out of there!!
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 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 that
William 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 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 publicly
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 for
decades throughout Americas judicial system on William Morris behalf (e.g. Rowe Entertainment et al. v. William
Morris Agency et al. (98 Civ. 8287 (RPP) (JCF)) and Arbitrator Gregorys decision to admit Exhibit 31 into the
evidence 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 status,
prejudiced my appeal by stating that my appeal would not be made in good faith and denied my October 3, 2014

Case 1:10-cv-09647-PKC-JCF Document 66-7 Filed 11/17/14 Page 3 of 5


Fed. R. Civ. P. 60 Fraud Upon the Court Motion as being without merit, I want to give you one last opportunity before
I submit my appeal to the Second Circuit, to be honest by either confirming or denying that you are and/or were
married to Sasha Angelique Carbone (Sasha Angelique Smith) at any time during your representation of William
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:

And the second link directed me here:

Case 1:10-cv-09647-PKC-JCF Document 66-7 Filed 11/17/14 Page 4 of 5

Had I been married to an executive at the American Arbitration Association or any forum with the jurisdiction to decide
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 in
considerable bad faith and having unclean hands. For eight months, you have refused to acknowledge or answer
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 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 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 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 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 predetermined 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 VII,
NYSHRL and NYCHRL, as well as claims of conspiracy to interfere with the human rights of people of African descent
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 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 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,

Case 1:10-cv-09647-PKC-JCF Document 66-7 Filed 11/17/14 Page 5 of 5


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

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