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 Castel’s 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 attorney’s 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 AAA’s Diversity Committee – to vacate Gregory’s 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 Gregory’s 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 America’s 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 Gregory’s 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 nation’s 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 Santo’s 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:

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, there’s 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 party…is 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 I’ve 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 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