A u g u s t s , 2015

The Honorable Justice Ruth Bader Ginsburg

Supreme Court o f the United States
1 First Stieet, N E
Washington, D C 20543
Re: Washington v. William Morris Endeavor Entertainment, L L C et al. Application No. 15A126
and Unacknowledged Motion to Disqualify Loeb & Loeb L L P
Dear Justice Ginsburg:
H o w was your trip to South Korea discussing "human rights" w i t h the Koreans? I hope it went well. During
a time when many o f the gains made during the c i v i l rights movement for American citizens o f African
descent have been eviscerated - thanks to decisions by majority o f the white [and one super black] Justices
on the bench' - and race relations between the blacks and whites are worsening by the day,^ I hope this
trip gave you time to really think about and reflect on this complex, social issue.
As you are aware, I have accused Republican appointed federal judge P. Kevin Castel and other officers o f
the court o f intentionally engaging i n misconduct that continues to deteriorate our judicial system's ability
to impartially administer justice without regard to one's race, including but not limited to: violating the
Judicial Code o f Conduct and Oath o f Office, conspiring to deprive m y constitutionaP and statutory rights
under the color o f law in violation o f 18 U.S.C. 241-242, the K u K l u x Klan A c t o f 1871 (42 U.S.C.
1983, 1985(3)) and committing other "high crimes and misdemeanors" that are worthy o f impeachment.
Since this landmark huinan rights, antitiust and employment discrimination case is one o f a kind both
substantively and procedurally, I submitted two, 40-page Motions to the Supreme Court on July 18, 2015,
seeking extraordinary rehef to conect an extreme "miscarriage o f justice" that has taken place i n m y case
over the last five years. The first motion was titled " M o t i o n to Disqualify Loeb & Loeb L L P and Disqualify
Michael P. Zweig, Christian Carbone, Michael Bamett, Jessica Lee & Others" and the second was titied
"Motion to Proceed In Forma Pauperis & Application To Justice Sonia Sotomayor For Extension To Submit
Petition For W r i t o f Certioraii". See Exhibit A .
On July 24, 2015, Zweig submitted a two-page letter addressed to you. He pro\'ided an exttemely brief
procedural history o f the case, stating in part, that m y claims were "frivolous" and that as a result o f m y
well-documented histoiy o f engaging i n "bad-faith conduct," m y "application should be denied because,

' Marcia Coyle. "Ginsburg On Rulings, Race." The National Law Journal. August 22, 2014.
http://www.nationallawioumal.CO m/id=1202667692557/Ginsburg-On-Rulings-Race?slreturn=20150708122918.
("The high court was 'once a leader in the world in rooting out racial discrimination,' the justice said in a wide-ranging
interview. 'What's amazing is how things have changed.'")
^ See e.g., Scott Clement. " A Year After Ferguson, 6 out of 10 Say Changes Are Needed To Give Blacks and Whites
Equal Rights." The Washington Post. August 5, 2015.
http://www.washingtonpost.com/news/theFix/wp/2015/08/05/what-changed-since-ferguson-americans-are-far-more-worried-about-black-rights/.
^ This is a violation of the 5*, 7"' and 14'*' Amendments of the U.S. Constitution. Tve never had an oral hearing or had
the opportunity to speak under oath in this entire case. As a pro se litigant, I am barred from arguing this case before
the Supreme Court. See e.g., Joe Patrice. "R.I.P. Pro Se Litigants Before The Supreme Court." Above The Law. July
1, 2013. http://abovethelaw.com/2013/07/r-i-p-pro-se-litigants-before-the-supreme-court/.

The Honorable Justice Ruth Bader Ginsburg

August 8, 2015
Page 2
among other reasons, [I] fail[ed] to demonstrate an entitlement to the relief sought or establish why [I] need
additional time to file [my] petition for a w r i t o f certiorari with this Court."
On August 1, 2015,1 received a letter dated July 29, 2015 from the Clerk o f the Court - Scott S. Harris -stating that my "application for an extension o f time within which to file a petition for a writ o f certiorari
in the above-entitled case has been presented to Justice Ginsburg, who on July 29, 2015, extended the time
to and including September 28, 2015."'' I also received the original and a copy o f m y Motion to Disqualify
Loeb & Loeb L L P . For the following reasons below, I respectfully ask that your decision regarding an
extension be stayed pendmg the acknowledgement and resolution o f my Motion to Disqualify Loeb &
Loeb L L P Due to "Fraud U p o n the Court" by all Article I I I Justices in the Supreme Court.
A.

A Perition F o r A W r i t O f Certiorari Is Not T h e Only Pleading T h a t C a n Be Submitted T o The

Supreme C o u r t T o "Dispose O f T h e Entire Case" O r "Affect The Final Judgment T o Be
Entered."

As discussed throughout m y M o t i o n to Disqualify, Loeb & Loeb L L P , Zweig, Carbone and other Loeb
attorneys that have been unjustly enriched from their fraudulent representation o f W i l l i a m Morris i n this
present litigation and are guilty o f violating numerous Rules under the New Y o r k Rules o f Professional
Conduct, as well as the New York Judiciary L a w 487 and additional laws. In Rowe Entertaimrent. Inc.
V. William M o m s Agency. Inc.. No. 98 C V 8272, 2005 W L 22833 (S.D.N.Y. Jan. 5, 2005), afTd, 167 F,
App'x 227 (2d Cir. 2005), cert, denied, 549 U.S. 887, 127 S.Ct. 283, 166 L.Ed.2d 152 (2006), Loeb & Loeb
L L P and others conspired with counsel for the class o f black concert promoters to conceal smoking gun
evidence from being produced during e-discovery. See Exhibit B . Thirteen years later, this evidence has
not seen the light o f day although in September o f 2013, Arbitrator David L . Gregory o f the American
Arbitration Association ( " A A A " ) admitted "Exhibit 31"^ into the evidence o f record in my case butttesses.
This decisions proves that "Exhibit 3 1 " is an authentic document and Loeb & Loeb L L P are collaterally
estopped from deferring to the fraudulently procured decisions o f former federal judge Robert P. Patterson
regarding this issue.
After getting away w i t h their highly unethical and criminal conduct in Rowe, Michael P. Zweig and Loeb
& Loeb L L P made the decision to "represent" W i l l i a m Morris four years later in m y case denying any and
all wrongdoing on W i l l i a m Morris' behalf During discovery, Loeb & Loeb L L P refused to comply with
any o f my good-faith discovery requests and produced zero documents. They wouldn't even tell me the
date the litigation hold was placed. 39 months into the case and after Arbitrator Gregory was fraudulently
disqualified after issuing a final decision on the issue o f arbitrability and liability and indicated that I would
receive the full gamut o f monetary damages during phase two o f our bifurcated proceeding, I learned Loeb
& Loeb L L P and the American Arbitration Association were literally sleeping in bed togetiier^ - a fact that

" The letter is written as i f written by the Clerk of Court, but the letter is signed by Case Analyst Erik Possum
' I included the full document that was filed as "Exhibit 31" in my Motion to Disqualify. I only included the cover
page and first page that was submitted by the Willie Gary Law Firm. The full document be viewed at
www.meagainstiniquity.wordpress.com
or
https://www.scribd.com/doc/93697362/Rowe-Entertainment-Inc-vWilliam-Morris-Agencv-et-al-98-8272-Breakdown-of-Racial-Epithets-Including-Nigger-Used-By-Execs-at-WMAand-CAA.
I learned that Christian Carbone was married to an executive at the American Arbitration Association - Sasha
Angelique Carbone. Christian, Loeb & Loeb LLP and the A A A failed to disclose this information to myself and/or
the Court. This creates a gross conflict of interest since the appointed "arbitrator" - Schnader LLP attorney and A A A

The Honorable Justice Ruth Bader Ginsburg

Augusts, 2015
Page 3
cannot be disputed since Carbone has had ample opportunity to deny this, and he has decided to remain
silent.
Throughout this entire case, Castel and the Second Circuit have acted as counsel for Zweig, Carbone and
Loeb & Loeb L L P - hence the reason why all o f their decisions are erroneous as a matter o f law and public
policy. I've filed more than five separate "fraud upon the Court" motions in both the district and appellate
court and Loeb & Loeb L L P have never had to reply.'' I have also filed complaints with the Departmental
Disciplinary Committee^ and with the Department o f Justice. N o investigation has taken place into m y
claims. Despite W i l l i a m Morris and Loeb & Loeb L L P ' s general denials and silence, the Court has entered
judgments in their favor which make no mention that I have raised claims o f "fraud upon the Court" and
making no mention o f Arbitirator Gregory's decisions regarding "Exhibit 3 1 . "
Ever since the Second Circuit issued an Order on March 11, 2014, denying my November 2 1 , 2014 M o t i o n
to Restore In Fonna Pauperis Status in T W O sentences and confirming the legally erroneous decisions o f
Republican appointed federal judge P. Kevin Castel, I began working on ray Petition for a W r i t o f Certiorari
to the Supreme Court. While writing the petition, I realized i n early July that due complexity o f the case
and intentional procedural errors that resulted i n one-sided decisions in favor o f W i l l i a m Morris and Loeb
& Loeb L L P , 1 decided to write my Motion to Proceed In Forma Pauperis following the guidelines set forth
in the Fed. R. App. P. had to submit a separate Motion to Disqualify Loeb & Loeb L L P since Loeb & Loeb
L L P should have absolutely no involvement in this case due to the fraud that was perpetrated in Rowe. as
well as m y case. Since all o f the lower courts refused to acknowledge or resolve m y claims o f "fraud upon
the Court," "the m o t i o n " that was "filed together" with my M o t i o n to Proceed In Forma Pauperis was m y
M o t i o n to Disqualify Loeb & Loeb L L P .
It cannot be disputed that the "highest couit o f the land" has jurisdiction over this case. Rule 8.1 says
"[wjhenever a member o f the Bar o f this Court has... engaged i n conduct unbecoming a member o f the Bar
o f this Court, the Court w i l l enter an order suspending that member from practice before this Court and
affording the member an opportunity to show cause, within 40 days, why a disbarment order should not be
entered."' Supreme Court Rule 39.2 states: " I f leave to proceed in forma pauperis is sought for the purpose
o f fding a document, the motion, and an affidavit or declaration i f requested, shall be filed together with
that document and shall comply in every respect with Rule 2 1 . " Rule 21.2(b) indicates that "any motion
the granting o f which w o u l d dispose o f the entire case or would affect the fmal judgment to be entered" can
also be filed with the Supreme Court.

board of director Timothy K. Lewis - works closely with Mrs. Carbone as members of the AAA's "Diversity
Committee."
' Leonard Rowe submitted a Fed. R. Civ. P. 60 Fraud Upon the Court Motion on March 2, 2012. Federal judge Robert
P. Patterson never compelled William Morris and Loeb & Loeb LLP to submit a reply.
* Although 1 filed a joint complaint with Leonard Rowe before Arbitrator Gregory admitted "Exhibit 31" into the
evidence of record, I also filed an individual complaint against Christian Carbone after learning about his marriage to
Sasha Carbone on November 13, 2014. See Exhibit C .
' P. Kevin Caste) sits as the head of the Grievance Committee for the Southern District of New York. Rule 8.3(a) of
the New York Rules of Professional Conduct states that any lawyer who knows that another lawyer has "committed
a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer's honesty,
trustworthiness or fitness as a lawyer shall report such knowledge to a tribunal or other authority empowered
to investigate or act upon such yiolation." (emphasis added)

The Honorable Justice Ruth Bader Ginsburg

Augusts, 2015
Page 4
In Zweig's July 24, 2015 letter, he makes absolutely no mention o f the M o t i o n to Disqualify that I submitted
- he only acknowledges m y M o t i o n to Proceed In Forma Pauperis. I n addition to July 29, 2015 letter I
received from the Supreme Court, I also received the original and a copy o f m y M o t i o n to Disqualify.
Shortly thereafter, I checked the Supreme Court's docket for diis case, and discovered that there is no
mention o f two Motions that I submitted - it only indicates that I submitted an Application For A n Extension
o f Time.'" See Exhibit D. On August 3, 2015,1 called and spoke with Case Analyst Eric Fossum on two
sepaiate occasions to understand why m y M o t i o n was returned to me.'' His reasons were insufficient and I
informed h i m that I would bring this issue to the Court's attention since the Court's attempt to whitewash
my M o t i o n from the record constitutes an obstruction o f justice and gross violation o f my constitutional
right to due process.
Had the Rules been properly followed, m y in forma pauperis status should have been restored because o f
my well-documented indigent status and due to the fact that none o f m y legal arguments have been
"frivolous." Although I am thankful that you granted an extension, all o f the Justices on the Supreme Court
should have resolved m y M o t i o n to Disqualify pursuant to Rule 8 since a smgle Justice cannot decide the
M o t i o n to Disqualify on their own and the "granting o f [Motion to Disqualify] would dispose o f the entire
case [and] would affect the fmal judgment to be entered."

' Supreme Court Rule 39.4 states: "When the documents required by paragraphs 1 and 2 of this Rule are presented
to the Clerk, accompanied by proof of service as required by Rue 29, they will be placed on the docket without the
payment of a docket fee or any other fee."
" Daring the initial call, Fossum told me that I could not submit this type of Motion to the Court. I stated that due to
the unique circumstances of the case, this Motion should have been accepted by the Court, even if this type motion is
not typically filed. He then told me that I could resubmit it. He also stated that the Motion to Disqualify could not be
submitted since I had not paid the filing fee. After I thought about what he stated, I called him back a few minutes
later. During the second call, I inquired about the whereabouts of the other 9 Motions to Disqualify that T submitted.
Fossum informed me that all of my Motions to Disqualify were discarded and stated that I only needed to submit three
copies of the Motion to Disqualify. The fact that Fossum told me I can resubmit the Motion to Disqualify means that
my Motion should have never been returned to me by the Court This alone raises doubts about the Court's
competence and ability to remain impartial.

The Honorable Justice Ruth Bader Ginsburg

Augusts, 2015
Page 5
B,

T h e Two Morions Submitted Are a Condensed Version O f A l l The Pleadings T h a t I Have

Submitted to the E E O C , the American Arbitrarion Association,'^ P. Kevin Castel of the Southern
District of New Y o r k and the Second Circuit Over the L a s t Five Years. A l l O f The Lower Courts
Have Denied AU O f M y Claims As "Frivolous," Claimed T h a t I Have Engaged In "Bad Faith"
And Refused To Issue Ethical Judicial Opinions - While Refusing to Uphold O u r Nation's
Antidiscrimination L a w s O r Acknowledge M y Claims O f "Fraud Upon the Court." I f I've Shown
"Good Cause" F o r A n Extension, Then M y Legal Arguments A r e Not "Frivolous," M y In Forma
Pauperis Status Should Not Have Been Revoked By Castel and the Second Circuit Should Have
Issued A n Ethical Judicial Opinion Reversing The Erroneous Decisions of Castel and the
American Arbitration Association Due T o " F r a u d Upon the Court" and "Fraud Upon the C o u r t
B y T h e Court." Since Loeb & Loeb L L P Continues T o Deny A l l Wrongdoing And It's Not
"Mandatory" F o r William Morris T o Reply T o Petition F o r W r i t of Certiorari, It Is Futile F o r
M e T o Submit A Petition F o r A W r i t O f Certiorari.

Supreme Court Rule 13.5 states: "For good cause, a Justice may extend the time to file a petition for a writ
o f certiorari for a period not exceeding 60 days. A n application to extend the time to file shall set out the
basis for jurisdiction in this Court, identify the judgment sought to be reviewed, include a copy o f the
opinion and any order respecting rehearing, and set out specific reasons why an extension o f time is
justified... A n application to extend the time to file a petition for a writ of certiorari is not
favored.'Yemphasis added) In Zweig's July 24, 2015 lett:er, he stated that I "failed to" show "good cause"
or "set out specific reasons why an extension o f time is justified," but your decision granting my application
proves otherwise and demonstrates that my legal arguments are not "fhvolous," I am not engaging in "bad
faith" and my appeal d i d not "lacks an arguable basis either i n law or in fact."'^
Throughout this case, P. Kevin Castel and various appellate judges i n the Second Circuit have intentionally
flouted our nation's antidiscrimination laws. From the beginning, Castel ignored m y claims o f systemic
disparate treatment, disparate impact and pre-hiring individual disparate treatment and all fmders o f fact
subsequently appointed to this case have done the same. There is no discussion o f the C i v i l Rights Act o f
1964, New York City Human Rights Law and other statutes i n their decisions. When 1 sought Castel's
disqualification, he refused and shortly after, he entered a one-sided "fmal decision" that upheld the
fraudulently prociu^ed decision o f the unlawfully appointed "arbitrator" Timothy K . Lewis, upheld L e w i s '
monetary award in the amount o f $47,6060.70 due to my "bad faith" conduct, prejudiced my appeal by
stating that it w o u l d not be submitted i n "good faith," revoked my i n forma pauperis status and granted
W i l l i a m M o n i s and Loeb & Loeb L L P motion to issue a filing injunction against me.
I n Zweig's one and one-half page reply to my July 18, 2015 Motions, he also stated:

Aside from the only lawfijUy appointed arbitrator David L. Gregory, who issued a Partial Final Award on December
17, 2013, concluding that I proved by a "preponderance of evidence" that "William Morris Endeavor Entertainment
LLC discriminated against [me] in violation of pertinent federal, state, and local law prohibiting
'^ None of my legal arguments have changed. I f I've demonstrated "good cause" for an extension, it is clear that my
legal arguments have never been "frivolous" and I ' m not engaging in "bad-faith" conduct for trying to uphold the
public policy goal the Civil Rights Act of 1964: eradicating racial discrimination in the workplace against African
Americans. Castel should not have revoked my in forma pauperis status and prejudiced my appeal by stating that it
would not be made in "good faith." Additionally, the Second Circuit should not have concluded that my appeal lacked
an arguable basis in law or in fact and they also should not have denied my appeal without providing an ethical judicial
opinion.

The Honorable Justice Ruth Bader Ginsburg

August 8, 2015
Page 6

I n his motion papers before this Court, M r . Washington raises the same, previously rejected argument
that he has raised in other fora: that a 'white/'Jewish'" conspiracy, o f which W M E , its competitors, its
coimsel, and members o f the federal judiciary are purportedly members, exists to prevent h i m from
finding employment in the entertainment industry. See, e.g., Pet. M o t . at 15 ("[i]t cannot be disputed
that 'Jews' o f European descent are overrepresented in positions o f power in Hollywood"); id. at 20
("no one group should have a monopoly over H o l l y w o o d and the marketplace o f ideas - especially
those who falsely proclaim to be 'God's chosen people.'") M r . Washington's argument is without
basis in law or in 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 M r .
Washington would file with this Court.'** (emphasis added)
Zweig is fully aware that I have accused W i l l i a m Morris o f intentionally engaging in a pattern and
continuing practice o f excluding qualified African Americans and people o f color fiom Agent, Coordinator
and Agent Trainee positions spanning more than 110 years, maintaining "ostensibly neufral" employment
practices, policies and procedures that create a glaring disparate impact against qualified African Americans
from being hired and/or promoted to Agent and using race, color and/or perceived national origin as a
"motivating factor" in their refusal to hire and/or promote to Agent after submitting m y resume and cover
letter to the company after graduating with m y Masters in Music Business and Entertainment Industries
from the University o f M i a m i in May o f 2008.
One o f the reasons why I was happy about addressing my application to Justice Sotomayor, is due to the
fact that she has always acknowledged the reality o f racism m our society. Although I ended up addressing
my application to the wrong Justice, I am still fortunate because you have spent your entire career also
being vocal about the realities o f global white supremacy (racism) throughout our multicultural society. In
Adarand Constructors, Inc. v. Pena. 515 U.S. 200, 273-274 (1995), you stated in your dissent:
"The persistence of racial inequaUtv...and discrimination's lingering effects...are evident in our
workplaces, markets, and neighborhoods. Job applicants with identical resumes, qualifications, and
interview styles still experience different receptions, depending on their race. White and AfricanAmerican consumers still encounter different deals. People o f color looking for housing still face
discriminatory treatment by landlords, real estate agents, and mortgage lenders. Minority
entrepreneurs sometimes fail to gain contracts though they are the low bidders, and they are
sometimes refused work even after winning contracts. Bias both conscious and unconscious,
reflecting traditional and unexamined habits of thought, keeps up barriers that must come down
if equal opportunity and nondiscrimination are ever genuinely to become this country's law and
practice."'^ (emphasis added)
1 was 10 years old when you wrote this dissent. 13 years later, I was hired into WiUiam M o r r i s '
"competitive" Agent Trainee program, only to discover that I was the only African American employed in
the Agent Trainee program and that African Americans had zero percent chance o f being promoted to

'* Michael P. Zweig and Loeb & Loeb LLP have used this same deceptive tactic in Rowe.
'^ This quote was included on page 36, footnote 92 of my Motion To Proceed In Forma Pauperis.

The Honorable Justice Ruth Bader Ginsburg

A u g u s t s , 2015
Page?
Agent.'* N o matter how hard I tried to excel, it was never good enough although I was considerably more
qualified than all o f m y similarly situated white/"Jewish" counterparts. I was just as qualified as recently
promoted Agents and tiiat fact cannot be disputed. Had W i l l i a m Morris made its music Agent position
available to the public, I or another person o f color would have more than likely been hired as a music
Agent.
After nearly five years o f litigation, the historical, statistical, anecdotal, circumstantial and other forms of
evidence I have presented establishing W i l l i a m Morris' pattern and continuing practice o f intentional
discrimination, disparate impact, pre-luiing individual disparate treatment, violations o f antitrust laws have
never been sufficiently refuted and this evidence cannot be ignored by the fmder o f fact merely because
this is not a class action.'^ W i l l i a m Morris and Loeb & Loeb L L P cannot name two Afiican American
Agent Trainees who were promoted to Agent i n the N e w York office between 2000 and 2010, but they are
accusing me o f being "racist" and "anti-Semitic."
Since you also identify as a "Jew" o f European descent, 1 have to briefly respond to Zweig's
misrepresentations regarding God's allegedly "chosen people" being overrepresented"'^ i n decisionmaking
positions throughout Hollywood and other influential industries throughout the United States since this is
a well-established fact that can no longer be refuted." It cannot be disputed that W i l l i a m Morris was

'^ When I began the William Morris Agency's "Agent Trainee program" in September of 2008, zero out of the 50
Agents were African American - although this company has exploited and made millions of dollars off of African
American entertainers since integrating their roster in the early 1900s. There were also zero Coordinators and Agent
Trainees employed in the New York office. From 2000 to 2010, zero African American Agent Trainees were
promoted to Agent in the New York office. This statistical evidence is "statistically significant" and establishes an
inference of intentional racial discrimination on its own. See Bamer v. City of Harvey. No. 95 C 3316, 1998 WL
664951, at *50 (N.D. III. Sept. 18, 1998) ("Incases, such as this one, the'inexorable zero' speaks volumes and clearly
supports an inference of discrimination."); Ortiz-Del Valle v. National Basketball Ass'n. 42 F. Supp. 2d 33 (S.D.N.Y.
1999) (recognized that evidence of an inexorable zero can support a jury's finding of discrimination against a motion
for judgment as a matter of law); Victory v. Hewlett-Packard Company. 34 F. Supp. 2d 809 (E.D.N.Y. 1999) (read
Teamsters as holding that an inexorable zero standing alone could support a disparate impact claim of sex
discrimination in promotions, asserting that "[t]he Supreme Court has repeated countenanced the use of statistical
evidence, and evidence of the absence of a single minority employee being hired, labeled the 'inexorable zero,' would
in and of itself support an inference of discrimination").
" Although I have no desire to work for this racist institution ever again, I am still entitled to declaratory, injunctive
and affirmative relief in additional to considerable monetary damages.
'^ "Jews" of European descent only account for less than 3 percent of the United States population.
" See e.g., Neal Gabler. An Empire Of Their Own: How the Jews Invented Hollywood. 1989. (This book was the
winner oi the, Los Angeles Times Book Award for history); Gabler, "Jews, Blacks and Trouble in Hollywood," New
York Times, (September 2, 1990) http://www.nytimes.com/1990/09/02/movies/film-view-jews-blacks-and-trouble-inhollywood.html:
John
W. Cones, Esq.
"What's
Really Going On In Hollywood!"
(1997)
http://www.filmreform.org/whats.html: Ray Moseley. "British Article On Hollywood Jews Triggers Row." Chicago
Tribune. December 1, 1994.
http://articles.chicagotribune.com/1994-12-01/news/9412010086J_iewish-cabalsemitic-vanity-fair. ("No one denies that William Cash's article about Hollywood Jews was mde. But was it antiSemitic? The Spectator, a conservative and irreverent British weekly that published an article by Cash in hs Oct. 29
issue on the alleged domination of Hollywood by a "Jewish cabal," is still feeling the reverberations of the controversy
touched off on both sides of the Atlantic."); Dennis Romero. "How Hollywood Keeps Minorities Out." LA Weekly.
February 25, 2015. http://www.laweeklv.com/news/how-hollywood-keeps-minorities-out-5402815; Benjamin
Hooks. "Report Says Blacks Are Underhired In Hollywood." New York Times. September 24, 1991.
http://www.nytimes.com/1991/09/24/arts/report-says-blacks-are-underhired-in-hollvwood.html. (The study, titled
"Out of Focus Out of Sync," says that blacks are unable to make final decisions in the motion picture process and
that only a handful of blacks hold executive positions with film studios and television networks. Although blacks

The Honorable Justice Ruth Bader Ginsburg

Augusts, 2015
Pages
founded by a German "Jewish" immigrant in 1898 and diat the company had an explicit policy o f not hiring
blacks to positions o f Agent and Agent Trainee for its fust 63 years o f business. Although the company no
longer explicitly bars qualified people o f color fi-om meaningfiil positions o f employment, they have uses
"ostensibly neutral" employment practices, policies and procedures (e.g. strong reliance on word o f mouth
and referrals to hire Agents and Agent Trainees, strong reliance on subjective decisionmaking in racially
segregated workplace, etc.) that achieve the same result, hence the modem-day "inexorable zero" and/or a
gross underrepresentation o f blacks and people o f color still exists throughout aU o f the W i l l i a m M o r r i s '
offices located throughout the U.S. and the world. Since all o f the other talent agencies have followed i n
W i l l i a m M o r r i s ' footsteps, all o f the agencies have similar racial makeups.^"
I n the begiruiing o f this case, Zweig initially argued that all o f m y claims were "without merit, legally and
factually." Five years later, his arguments haven't changed, but it doesn't change the fact that W i l l i a m
Morris is "Iimit[ing], segregate[ing], [and] classify[ing] [dieir] employees or applicants for employment i n
any way which would deprive or tend to deprive any individual o f employment opportunities or otherwise
adversely affect his status as an employee, because o f such individual's race, color, religion, sex, or national
origin," 42 U.S.C. 2000e-2(a)(2), and maintaining employment practices, policies and procedures that
prevent equal employment opportunities for African Americans and create a glaring disparate impact
against qualified people o f color, 42 U.S.C. 2000e-2(k)(l)(A)(i), simply due to the amount o f God given
skin melanin our bodies are naturally able to produce. The lower coiuts erred by refusing to uphold our
nation's antidiscrimination statirtes and failing to acknowledge the unrefuted historical and statistical
evidence^' detailing W i l l i a m Morris' history o f intentionally excluding qualified Afiican Americans fi-om
meaningful positions o f employment, such as Agent and Agent Trainee.

I f the public policy goal o f our

nation's antidiscrimination laws is to eradicate racism, then even a blind man can see that an impartial j u r y
should have decided the merits o f Rowe and Washington and that the C i v i l Rights Act o f 1964 and the
purchase 25 percent of domestic movie tickets, black-owned businesses are frequently excluded from the
entertainment industry, the report said."); Ron Walters. "Hollywood's Racism Factory." FinalCcill. March 28, 2006.
http://www.fmalcall.com/artman/publish/Perspectives_l/Hollywood_s_racism_factory_2515.shtml. ("The bottom
line is that since the positioning of racial images is about money, Hollywood thinks it must play to the racial
stereotypes, making it the most powerilil purveyor of global racism that exists. It educates and reinforces the
demeaning racial role that is in the heads of both Americans and foreigners, through the economic power, to
commercialize these images through the distribution network of movies and advertising outlets. We should put more
of a spotlight on the producers and financiers of these movies who keep alive the negative images o f Black people
before the worid."); Jennifer Armstrong and Margeaux Watson. "Diversity in Entertainment: Why Is TV So White?"
Entertainment Weekly. June 13, 2008. http://www.ew.com/ew/article/0..20206185.00.html; Who Controls America?
"Who Controls Hollywood?" https://thezog.wordpress.com/who-controls-hollywood/; Joel Stein. "Is Hollywood Run
by Jews? You Bet." LA Times. December 19, 2008. http://articles.latimes.com/2008/dec/19/opinion/oe-steinl9. ("But
I don't care if Americans think we're running the news media, Hollywood, Wall Street or the government. I just care
that we get to keep running them.").
^ At the time the William Morris Agency merged with Ariel Emanuel's Endeavor Talent Agency in April of 2009,
Endeavor employed zero African American Agetns. When William Morris Endeavor Entertainment merged
^' See e.g., Andrew Kreshner. "Statistics Fall Short of Showing Intent, Circuit Says." Law.com. August 3, 2015.
http://www.law.com/sites/articles/2015/08/01/statistics-fall-short-of-showing-intent-circuit-says/. ("Southern District
Judge Jed Rakoff, sitting by designation, said the case presented a matter of first impression for the circuit "in the
context of a putative class action alleging employment discrimination under [42 U.S.C] 1981 and/or the Equal
Protection Clause." As some of the circuit's employment discrimination cases 'have hinted, in certain
circumstances... statistics alone may be sufficient," Rakoff said. But to make the showing on statistics alone, he said,
the figures "must not only not only be statistically significant in the mathematical sense, but they must also be of a
level that makes other plausible non-discriminatoiy explanations very unlikely.'")
Historical and statistical evidence can be used to establish pretext under the McDonnell Douglas tripartite formua.

The Honorable Justice Ruth Bader Ginsburg

A u g u s t s , 2015
Page 9
other antidiscrimination statutes throughout our nation must be sh-engthened to eradicate institutionalized,
structural, systemic and other pervasive fornis o f racism and discrimination throughout all areas o f our
society.
As discussed in m y Motions, the conservative judicial agenda has been well documented.^^ Five out o f the
nine Justices on the Supreme Court have been appointed by Republican Presidents and over the decades,
many o f their decisions reflect a hostility toward civil rights cases involving litigants o f African descent
and a disconnect from reality - hence the reason many o f the gains made during the civil rights movement
during the 1950s and 1960s have been eviscerated 60 years later as blatant forms o f white racism worsen.
Like Castel and the appellate judges in the Second Circuit, these formalist, ideologically conservative
Justices render decisions that ignore the realities o f racism and/or support the notion that whites are the true
victims o f racial discrimination in our "post-racial" society. See e.g., Ricci v. DeStefano. 129 S. Ct. 265S
(2009). Since m y case has

the ability to reverse these decisions

and sfrengthen

our

nation's

antidiscrimination statutes, it's not in the interests o f the white judicial elite to take such a case when they
are busy chipping away at the substantive sfrength o f laws that were created primarily to protect the hueman rights o f American citizens o f African descent who have been robbed o f their history, culture, heritage
and identity.
Is it possible to show "good cause" for an extension i f a litigant is raising legally frivolous arguments? I f
my legal arguments have never changed and I have shown "good cause," then it is clear that m y legal
arguments are not "frivolous or malicious." I f they were, you would have denied m y application for an
extension since extensions are rarely granted and less than 1 percent o f petitions for a writ o f certiorari are
accepted by the Supreme Court each year. For this reason alone, the appellate court should have fransferred
my appeal to another circuit as requested or issued an ethical judicial opinion^^ after resolving the issues
that P. K e v i n Castel ignored, including m y claims o f "fraud upon the Court."
I submitted a Notarized Affidavit proving that I am living below the poverty level. I have been unemployed
for five years and for the last three years, I have been living o f f o f $400.00/month thanks to m y parents,
who are now no longer fmically able to support me. It cost me more than $200.00 to pay for the costs o f
submitting my motions to the Supreme C o m l . I f you've concluded that I've shown "good cause" for an
extension, then it would make absolutely no sense for me to spend the next 60 days writing a petition that
is later denied by a conservative majority that I have accused o f playing a pivotal role i n maintaining global
white supremacy (racism) throughout our society and the world. Albert Einstein would call that "insanity."
Since no new arguments are being raised and you know that I don't have the money to mail ten copies o f a
petition and possible brief, there is no point m subinitting the pleadings i f the Supreme Court is going to
freat my claims institutionalized racism i n Hollywood and "fraud upon the Court" against Loeb & Loeb
L L P as "frivolous."
Ironically, while writing this letter, I came across an article published by the National Law Journal

on

August 4, 2015 mentioning your recent trip to South Korea and how you "met w i t h Chief Justice Yang
23

Supreme Court Rule 39.8 states: " I f satisfied that a petition for a writ of certiorari.. .or petition for an extraordinary
writ is frivolous or malicious, the Court may deny leave to proceed in forma pauperis"
" Unfortunately, two out of the three judges who dismissed my appeal as "frivolous"- district court judge Laura Swain
Taylor and Canadian bom appellate judge Raymond J. Lohier, Jr. ~ are of African descent. The other judge was Chief
Judge They should both be impeached as well.

The Honorable Justice Ruth Bader Ginsburg

A u g u s t s , 2015
Page 10
Seung-tae this week 'to discuss the promotion o f human rights and minority rights protection.'"-^'' During
your five-day visit, the article also stated that you were expected to "deliver remarks on human rights
and...meet with other top jurists in Korea." I fmd it very hypocritical o f you to engage in such discussions
as a representative o f this country after ignoring the compelling arguments raised i n m y M o t i o n to Proceed
In Forma Pauperis, proving beyond a reasonable doubt that various officers o f the Court have engaged in
an egregious and diabolical conspiracy to deprive me o f m y constitutional and statutory rights under the
color o f law in an effort to maintain global white supremacy (racism) throughout America and the world.
This is a sign from tlie imiverse that although you are tiying to be nice, you are not being fully impartial.
Since you are one o f the four "liberal" Justices, i f you thought m y claims were "frivolous" and made in
extreme "bad-faith" as stated by the Second Circuit, P. Kevin Castel o f the Southern District o f New Y o r k
and Timothy K . Lewis^^ o f the American Arbifration Association, then that would make six Justices who
more likely than not deny m y petition as being "frivolous," and thus, m y Motions should have been denied
since the Supreme Court is not obligated to issue an ethical judicial opinion.
Due to Loeb & Loeb L L P ' s "pattern" o f engaging in "fraud upon the Court," exfreme disciplinary and
monetary sanctions should be imposed against Michael P. Zweig, Christian Carbone, Loeb & Loeb L L P
and all attomeys who have been unjustiy enriched from their highly unethical and criminal acts, including
to default judgment and an amount no less than $1 billion. The monetary sanctions against W i l l i a m Morris
Endeavor Entertainment should be more.^^ I f the Supreme Court refuses to acknowledge and resolve the
claims raised in this Motion, Castel's filing injunction should be vitiated and 1 should be allowed to pursue
independent claims o f "fraud upon the Court," violations o f New Y o r k Judiciary Law 4S7, conspiracy to
interfere with the human rights o f people o f African descent, obstruction o f justice, malicious abuse o f
process and other causes o f action against Michael P. Zweig, Christian Carbone, Loeb & Loeb LLP-^' and
others that have conspired to deprive me o f m y constitutional, statutory and inalienable rights under the
color o f law. I f not, I w i l l have no choice than follow the advice o f M a l c o l m X , and bring this case before
all international institutions and tiibunals such as the United Nations-'" to resolve these historical and on-

Tony Mauro. "Ginsburg, Other Justices Head Overseas During Summer Recess." National Law Journal. August 4,
2015. http://www.law.com/sites/articles/2015/08/04/ginsburg-other-iustices-head-overseas-during-summer-recess/.
^^ Lewis is a former federal judge and current attorney at Schnader Harrison Segal & Lewis LLP.
http://www.schnader.com/professionals/xprProfessionalDetailsSchnader.aspx?xpST=ProfessionalDetail&profession
al=142. He is also a board of director for the AAA, board member of The Constitution Projectand After Lewis was
appointed, I discovered this blog detailing his firm's close relationship with Israel, http://schnaderpittisrael.com/. The
blog has not been updated since March 10, 2014, which is after I confronted them.
See e.g.. Josh Rottenberg. "Wall Street investors to Hollywood Talent Agencies: 'Show Us The Money.'" L . A.
Times. July 10, 2015. http://www.latimes.com/entertainment/envelope/cotown/la-et-ct-talent-agencies-privateequity-20150710-story.html. "In 2012, Silver Lake, best known for its investments in tech firms including Skype and
Alibaba, acquired a 3 1 % stake in WME for $200 million, then followed that up last year with a $500-miIIion
investment that increased its stake to 51%. With Silver Lake's backing, in 2013 WME acquired New York-based
sports and media group I M G Worldwide Inc., a $2.4-billion deal that vaulted the agency over CAA in scale." See
also, William D. Cohan. "The Inside Story of Ari Emanuel's Big, Risky WME-IMG Merger." Vanity Fair. February
11, 2015. http://www.vanityfair.com/news/2015/02/wme-img-merger-ari-emanuel.
I have also contacted the Chairman and Chairman Emeritus of Loeb & Loeb LLP on more than one occasion Michael Beck and John T. Frankenheimer - about the fraud engaged in by Michael P. Zweig, Christian Carbone and
others from their firm on William Morris' behalf Both have ignored my correspondence.
^ The United Nations has declared 2015-2024 to be "The Decade For People of African Descent." Global white
supremacy (racism) must finally be eradicated, http://www.un.org/en/events/africandescentdecade/. On August 28,
2014, the United Nations Committee on the Convention on the Elimination of All Forms of Racial Discrimination
(CERD) "slammed the United States for persistent racial and ethnic discrimination. The watchdog said Washington

The Honorable Justice Ruth Bader Ginsburg

A u g u s t s , 2015
Page 11
going crimes that are being committed against hue-man beings o f African descent since race is a legal and
social construct and white racial superiority is nothing but a myth.^'
CONCLUSION
As you aie aware: Substantive justice cannot be achieved without ( I . ) an independent & impartial judiciaiy
and (2.) procedural due process. The two Motions that were submitted to the Coiut on July 18, 2015
demonstrate that i f I had to submit a petition for certioraii it would be "certworthy" and that all decisions
rendered in favor o f W i l l i a m Morris and Loeb & Loeb L L P throughout this proceeding should be vitiated
due to "fraud upon the Court" and "fraud upon the Court by the Court." for that reason alone, the appellate
couit should have transferred my appeal to another circuit as requested or issued an ethical judicial opinion
after resolving the issues that P. K e v i n Castel ignored, including my claims o f "fraud upon the Court."
Under the Supreme Court's "inherent powers," the Court has the jurisdiction to do whatever is necessary
to conect this extreme "miscarriage o f justice." Since W i l l i a m Morris and Loeb & Loeb L L P have denied
all wrongdoing over the last five yeais and are not obligated to submit reply to my petition for a writ o f
certiorari, it's futile for me to say anything further and there is no need for me to submit a petition for a writ
o f certiorari since the granting o f my Motion to Disqualify Loeb & Loeb L L P and Motion to Proceed I n
Fonna Pauperis would "dispose o f the entire case [and] would affect the final judgment to be entered." Rule
21.2(b). Pursuant to Rule 8, I ask that the Supreme Court suspend Michael P. Zweig, Christian Carbone
and Loeb & Loeb L L P and give them until August 24, 2015 to submit a fonnal reply before disqualifying
Loeb & Loeb L L P and disbarring each attorney that has been unjustly enriched from this case.
I f the Supreme Court refuses to acknowledge and impartially resolve my M o t i o n to Disqualify, I ask that
the two Motions and this letter be converted into my petition for a writ o f certiorari or a petition for a writ

has failed to meet its treaty obligations under the convention, one of only three core human rights accords that the
U.S. has ratified. The 18-person panel of experts based its findings on review of official submissions from the U.S.,
reports from numerous civil society organizations and testimonies by U.S. officials and advocacy groups over several
days of hearings earlier in August." Lauren Carasik. Aljazeera. "United Nations Watchdog Blasts US For Persistent
.Racism."
September
8,
2014.
http://america.aljazeera.co m/opinions/2014/9/united-nationsracismracialandethnicdiscriminationintheus.html.
Before this case, I knew nothing about institutional racism, global white supremacy (racism) or knew anything about
the history of my African ancestors pre-slavery in the Americas - even though I excelled in school and have a
Bachelors in Psychology & Media Management and Masaters in Music Business and Entertainment Industries from
the University of Miami. See e.g., Cheikh Anta Diop, The African Origin Of Civilization: Myth or Realty (1957);
Yosef A.A. ben-Jochannan, African Origins of the Major 'Western Religions' (1970); Tom Burrell, Brainwashed:
Challenging the Myths of Black Inferiority (2010); Jack Gratus, The Great White Lie: Slavery, Emancipation and
Changing Racial Attitudes (1973); OMichael J. Klarman, Unfinished Business: Racial Equity in American History
(2007); Ira Katznelson, When Affirmative Action Was White (2005); J.A. Rogers, Nature Knows No Color-Line
(1952); Rogers, Sex & Race Vol. 1 (1952); Carter G. Woodson, The Mis-Education of the Negro (1933); Malcolm X,
The Autobiography of Malcolm X (1964). Currently reading John G. Jackson's Introduction to African Civilization,
1970; Ivan Van Sertima, They Came Before Columbus: The African Presence in Ancient America. 1976; T. Owens
Moore, Ph.D., The Science ofMelanin: Dispelling the Myths. 1995; R. A. Schwaller deLubicz. Sacred Science. 1961;
John G. Jackson, Introduction to African Civilizations. 1970.

The Honorable Justice Ruth Bader Ginsburg

August 8,2015
Page 12
o f extraordinary rehef pursuant to Rule20.3 to prevent hannful delay, and that the petition be denied to
prevent further harmful del ay.
Respectfully submitted.

Marcus Isaiah Washington,

Pro Se Petitioner
cc;

Michael P. Z w e i g (via U.S. postal and e-mail)

Christian Carbone (via e-mail)
Michael D . Beck, Chairman & Partner o f Loeb & Loeb L L P (via e-mail)
John T. Frankenheimer, Chairman Emeritus o f Loeb & Loeb L L P (via e-mail)
In addition to resubinitting two copies o f the M o t i o n to Disqualify Loeb & Loeb L L P that was
returned to me, 1 have also filed an original and ten (10) copies o f this letter. I n addition to Justice
Ginsburg, each Justice on the Supreme Court o f the United States should be given a copy o f this
letter.

" In addition to an original and ten copies of this letter, I have also enclosed the original and copy of the Motion to
Disqualify that Scott S. Harris and Erik Fossum returned to me in the Supreme Court's attempt to obstmct justice and
violate my constitutional right to due process and equal protection under the law.

Exhibit A

No.

IN T H E

Supreme Court of t\)t Winittt ^tatefli

O C T O B E R T E R M , 2015

MARCUS ISAIAH WASHINGTON,

Petitioner,
V.
W I L L I A M M O R R I S E N D E A V O R E N T E R T A I N M E N T L L C (formerly the W I L L I A M
M O R R I S A G E N C Y ) , J E F F M E A D E and S A R A H W I N L A R S K L
Respondents.

CERTIFICATE OF SERVICE
I - pro se litigant Marcus Isaiah Washington - certify pursuant to Rule 29 o f this Court,
that on July 19, 2015, I served the w i t h i n M O T I O N T O D I S B A R M I C H A E L P. Z W E I G ,
CHRISTIAN CARBONE, M I C H A E L B A R N E T T & OTHERS A N D IMPOSE
DISCIPLINARY A N D M O N E T A R Y SANCTIONS

EXTREME

AGAINST LOEB & LOEB LLP

FOR

E N G A G I N G I N A N I N T E N T I O N A L " P A T T E R N " OF " F R A U D U P O N T H E C O U R T ' A N D

B A D F A I T H L I T I G A T I O N and M O T I O N F O R L E A V E T O P R O C E E D I N F O R M A P A U P E R I S
& A P P L I C A T I O N T O J U S T I C E S O N I A S O T O M A Y O R F O R A N E X T E N S I O N OF T I M E T O
F I L E A P E T I T I O N F O R A W R I T OF C E R T I O R A R I on counsel for respondent - M i c h a e l P.
Z w e i g o f L o e b & L o e b L L P , 345 Park Avenue, 18* Floor, N e w Y o r k , N e w Y o r k , 1 0 1 5 4 - t h r o u g h
the U n i t e d States Postal Service by first-class m a i l .

Pro Se Litigant, N o n - A t t o r n e y
54 B o e r u m St. A p t . 6 M
B r o o k l y n , N e w Y o r k 11206
(646) 504-6497
mumanrights.areamust@gmail.com

Exhibit B

W i J l i e E. Gary, Esquire
W i l l i a m C. C a m p b e l l , Esquire
M a r i a P. Sperando, Esquire

GARY, WILLIAMS, PARENTI, FINNEY,

L E W I S , WATSON & SPERANDO
221 E . Osceola Street
Stuart, F L 34994

T e l : (772)283-8260
Fax: (772)221-2177
A t t o m e y s for Plaintiffs R o w e Entertainment, Inc., et al.

UNITED STATES D I S T R I C T COURT

SOUTHERN DISTRICT O F NEW Y O R K

R O W E E N T E R T A I N M E N T , I N C . et al.,

N O . 98-CV-8272 (RPP)

Plaintiffs,
vs.

T H E Wn J T A M M O R R I S A G E N C Y , I N C .
ETAL.,
Defendants

EXHIBITS TO
PLAINTIFFS' MEMORANDUM O F LAW
IN OPPOSITION TO BOOKING AGENCY DEFENDANTS'
MOTION FOR SUMMARY .TUDGMENT

V O L U M E II

1 4 . 4 5 FROM.SNR.NEW

DGOUDFARB
Spade
DGROVER
colored
DGROVER
monkey
DGROVER
spade
DGROVER
spook
DRA8IEH
monkey
DTENZER
colored
DTENZER
monkey
DTENZER
negro
DTENZER
nigger
DTENZER
spade
DWATTS
colored
DWATTS
monkey
DWATTS
negro
DWATTS
nigger
DWATTS
spade
DWATTS
spook
EGERSON
cokjred
EGERSON
nrtonkey
EGERSON
negro
EGERSON
nigger
EGERSON
spook
EGERSON
uncle torn
FIFVY
cx>lored
ELEVY
spade
FSALINAS
colored
FSALINAS
monkey
FSALINAS
spade
FWHITEHEAD
colored
FWHITEHEAD
monkey
FWHITEHEAD
spade
GGURROLA
colored
GGURROLA
monkey
GGURROLA
negro
GGURROLA
nigger
GMEREDfTH
colored
GMEREDFTH
monkey
GMEREDFTH
negro
GMEREOrTH
spook
GPULIS
cx>loned
GPUUS
spade.
GROTH
colored
GROTH
monkey
GROTH
spade
GWATERS
colored
GWATERS
monkey
HELPDESKTEMP colored
HELPDESKTEMP monkey
HELPDESKTEMP' spade
IPINCUS
colored
IPINCUS
monkey
IPtNCUS
negro

YORK

3
2
2
2
2
2
14
28
1
1
27
55
35
2
1
26
3
14
7
2
1
2
1
1
2
2
7
2
3
6
22
3
7
1
2
3
19
2
1
1
3
1
3
3
2
4
4
3
3
6
25
5

Exhibit C

S U P R E M E COURT, APPELLATE DIVISION

FIRST JUDICLU. DEPARTMENT
DEPARTMENTAL DISCIPLINARY COMMITTEE
61 B R O A D W A Y , 2"" F L O O R
N E W Y O R K , N E W Y O R K 10006
(212) 401-0800
Jorge Dopico
Chief Counsel
D A T E : November 13. 2014
Complainant (s):
Mr.(y(^Ms.( ) M r s . { )

Washington

Last
Address:

Marcus
First

1.
Initial
Apt. No. 6M

54 Boerum Street
Bi>X)idyn

Telephone:

Home: (

646

11206

New York

City

State

Zip Code

Business: ^

) 504-6497

Attorney Complained of:

M r . C ^ M s . ( ) Mrs.( )

Address:

Telephone:

Carbone
Last

Chiistian

D.
Initial

First

Apt. No._

345 Park Avenue

Home: i_

New York

New York

City

State

_ 1 _

Business: (

10154

Zip Code
212

) 407-4852

Complaints to other aRencies:

Have you filed a complaint concerning this matter with another B a r Association, District Attorney's Office or any
other agency:
I f so, name of agency:

No.

Action taken hy agency:

Court atAion against attorney complained of:

Have you brought a civil or criminal action against this attorney? No
I f so, name of court: N/A.

1.
a.

3.

Index No.

Please send A N O R I G I N A L A N D O N E C O P Y of your complaint with enclostu-es. Please do not send original
documents i n your enclosures because we will not return them,
Y o u may copy the enclosed form as many times as you w i s h , or you may find it online. O u r website is:
www.nycourts.Rov. Go to the search bar and enter "disciplinary committee." Click o n the link which says,
"Departmental Disciplinary Committee."
Y o u may also state your allegations i n a letter. W e request separate complaint forms/letters for each
attorney i n question.

P L E A S E PRINT L E G I B L Y OR T Y P E IN ENGLISH
Start from the beginning and be sure to tell us why you went to the attorney, when you had contact with the
attorney, what happened each time you contacted the attorney, and what it was that the attorney did wrong. Please
attach copies of all papers that you received from the attorney, i f any, including a copy of A N Y R E T A I N E R
A G R E E M E N T that you may have signed. DO NOT F O R G E T TO S E N D AN O R I G I N A L AND O N E C O P Y O F T H I S
COMPLAINT.

See Exhibit A. Pursuant to the New York Rules of Pi^ofessional conduct, Loeb & Loeb LLP altorney Chj-istian Carbone has Nnolated various Rules.
including but not limited to Ru)esM (c)(2), 1.2(d) and (f). 3.1(a) and (b), 3.3(b) and ji). 3 5(a). 4 J . ag well as 5,2 (d)(]), (d)(2)(i) and (d)(2)(ii).
In violation of Rule S.3. Christian Cajboiie and otlier aHomeys at Loeb & \jocb LLP (e.g. MichaeJ P. Zweig and Michael Barnett) have
(a) *violale[d| or attempt[edl to violate the Rules of Professional Conduci, kiiowingly assistfedl or induce[edl another to do so, or dfidj so
through the acts of anothet'; (b) "enga^e[ed| in illegal conduct that adversely reflects on the lawyer's honesty, ti-ustwor-tltiness or fitness as a
lawyer; (c) ''ensage[d] in conduct involving dishonest^', fraud, deceit or misrepresentation"; (d) "engagetdj in conduct thai is prejudicial to the
administration of justice"; (e) "impl(ied| an ability to (1) "influence improperly or upon irrelevant grounds any tribunal, legislative body or
public official; or (2) to achieve results using meaiis that violate these Rules or other law."
Pursuant to Rule S.3(a), ChristiaiT Carbone has conrmitted numerous violations under "the Rules of Professional Conduct that rai.ses
a substantial question as to that lawyer's honesty, tnistwoi-thiness or fitness as a lawyer." Althougli I am not an attorney, I am a citizen of the
it is in the public's interest that such infonnation be disclosed "to a tribunal or other authority empowei-ed to investigate or act upon such
violation [s].'
Did Christian Carbone have an ethical obligation to disclose to the opposing paity or the federal court, at any time during the litigation,
that he was marned to an executive that was employed by the .American Arbitration Association when he sought to have the federal judge
compel my case under the jurisdiction of the AAA? If you were ai'bitrating a case, would you want this information to be disclosed to you.
especially if it is later discovered thai the arbitrator and aMomey's wife worked closely together? If not, would Carbone's actions be considered
unethical if he were African American? If the Departmental Disciplmary Committee denies ray complaint without compelling Carbone to
respond or disclose information about his relationship to AAA executive Sasha Angelique Carbone, then I ask that the DDC issue an
expedited decision, explaining wliy Carbone and l ^ b & Loeb LLPs actions are in compliance with the New York Rules of Professional
Conduct and expl;iin why an attorney does not have an ethical obligation to disclose information re. marital status to employees of an
allegedly "neutral" tribunal.

U N S I G N E D C O M P L A I N T S W I L L NOT B E P R O C E S S E D .
Signature

Exhibit D

8/7/2015

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Home I S e a r c h R e s u l t s

No. 15A126
Title:

Marcus Isaiah Washington, Applicant

V.

William Morris Endeavor Entertainment, LLC, et al.

Docketed:

July 29, 2015

Lower Ct:

United States Court of Appeals for the Second Circuit

CaseNos.:
Date
Jul 20 2015

(14-4328)
Proceedings and Orders
Application (15A126) to extend the time to file a petition for a writ of certiorari from July
29, 2015 to September 27, 2015, submitted to Justice Ginsburg.

Jul 24 2015

Response to application from respondent William Morris Endeavor Entertainment, LLC,

et al. filed.

Jul 29 2015

Application (15A126) granted by Justice Ginsburg extending the time to file until
September 28, 2015.

file;///C:/Users/Marcus/Documents/WASHINGTON%20v.%20WME/UNITED%20STATES%20SUPREME%20COURT/Supreme%20Court%2^^