Tagged: monetary sanction

the VOLUMINOUS Em. Motion to Disqualify P. Kevin Castel & James C. Francis, Or in the Alternative, Disciplinary Sanctions Against William Morris, Loeb & Loeb LLP, Michael P. Zweig, Christian Carbone and Michael Barnett has been SUBMITTED!!!

The last 48 hours were insane, but I thank God for allowing me to complete what I started! I almost thought I wasn’t going to make it to the Southern District of New York in time, but at 11:45 PM, the motion was submitted. This is truly a historical document and proves further why I have always stated that this is a landmark employment discrimination and human rights case.

I won’t upload the full motion right now (it’s more than 500 pages if you includes Exhibits A through ZZ), but here’s the Cover Page and Table of Contents just to get an idea of what my arguments were.

Not sure why the roman numerals appeared as page numbers on the first page of the Table of Contents, but given that I didn’t finish everything until an hour before it was due, I had no choice other than to leave it the way it was.

even if, hypothetically speaking, my decision was reversed, William Morris, Loeb & Loeb LLP, Michael P. Zweig and Christian Carbone are still going to have to cut a nice check as a sanction for their contumacious conduct and abusive discovery tactics. hahahahaha.