Pursuant to Fed. R. Civ. P. 60(b)(3), one of the grounds warranting “relief from a final judgment, order, or proceeding” is “fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by an opposing party,” or pursuant to 60(b)(6), “any other reason that justifies relief.”

In both my March 17, 2014 Fraud Upon the Court Motion and April 11, 2014 Motion for Reconsideration, I argued that Christian Carbone did not disclose to the SDNY or myself at any time since I filed the complaint with the SDNY on December 21, 2010, that he was married to an executive — Sasha Angelique Carbone — at the American Arbitration Association [the same forum William Morris and Loeb & Loeb LLP wanted to have the case moved to so that the merits of my claims of institutionalized racism could never be decided by an impartial jury]. I argued that his failure to disclose was unethical, further demonstration of Loeb & Loeb LLP’s “pattern” of “fraud upon the Court,” their intentional violations of many Rules under the New York Rules of Professional Conduct, as well as violations of the New York Judiciary Law section 487. Based on the fraud that Michael Zweig and Loeb & Loeb LLP engaged in (e.g. “Exhibit 31”) and got away with to obtain a favorable verdict in Rowe, it is clear that they should have never been allowed to represent William Morris in my case. I also argued the Carbone’s marriage further demonstrated that the AAA was NEVER the “neutral” forum that it proclaimed to be [Arbitrator David L. Gregory and the AAA were aware before I found out] and that this gave additional support to my initial arguments that were raised before the SDNY and Second Circuit: based on William Morris’ 110 year history of intentional systemic disparate treatment against African Americans in employment which pre-dated my employment and I alleged occurred during my employment, arbitration was an inappropriate forum for this particular case to be resolved, as both a matter of law and public policy.

The “honorable,” Republican appointed federal judge P. Kevin Castel’s make no real discussion of arguments in his September 5, 2014 Final Order, which confirmed the fraudulently procured Award of the second “arbitrator” [Timothy K. Lewis] who vacated Arbitrator Gregory’s Partial Final Award [which concluded that William Morris discriminated against me because of my race and awarded me back pay, front pay, compensatory & punitive damages, and other fees and costs] after he was improperly disqualified by the AAA and ultimately dismissed my case “with prejudice and on the merits” because I continued to raise objections to the fraud that was occurring throughout my case. Instead, Castel issued a final decision which supported Lewis’ statements that I was engaging in considerable  “bad faith ” and it’s not William Morris, but it is me who is “racist”…and more specifically, I’m actually “anti-Semitic” and then stripped me of my informa pauperis status and prejudiced my appeal by stating that it would not be made in “good faith.”  #global white/”Jewish” supremacy #manifestinjustice #fraudupontheCourt #judicialcorruption

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