Washington v. William Morris Endeavor Entertainment Et Al. (10-9647) - Letter To P. Kevin Castel Re: His Refusal To Disqualify and Refusal To Address Claims of Fraud Upon The Court (March 28, 2014)

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March 28, 2014

Mr. P. Kevin Castel Southern District o f New York 500 Pearl Street New York, New York 10007 Re: Washington v. William Morris Endeavor Entertainment et al. (10 Civ. 9647) ( P K C ) ( J C F ) Dear Castel: Over the last four weeks, I , pro se litigant Marcus Isaiah Washington, have submitted three letters pursuant to the Individual Practices o f P. Kevin Castel 2(A)(1) and 2(C) and on March 17, 2014,' I filed the voluminous "Emergency Motion to Disqualify P. Kevin Castel and James C . Francis Pursuant to 28 U.S.C 455, O r In the Alternative, Emergency Motion to Disqualify Michael P. Zweig, Christian Carbone and Loeb & Loeb L L P Due to Fraud Upon the Court. Request for Disciplinary and Monetary Sanctions. Oral Hearing Demanded." In my motion, I thoroughly explained that when you mtentionally chose to ignore both the Judicial Code o f Conduct and the public policy goals of the Civil Rights Act of 1964 to issue your highly erroneous July 20, 2011 Stay Order compelling this landmark human rights and employment discrimination case into arbitration, you failed to uphold your ethical duties as an unpartial, federal judge and deprived me o f my rights under the color o f law in violation o f 18 U.S.C. 242. On March 24 and 27, Francis and Castel respectively, declined to recuse themselves from the case, despite the p>'ramid of evidence I presented which would make any "reasonable person" question the impartiality of the two, white male federal judges appomted to a case challenging the William M o m s Agency's (now known as William Morris Endeavor Entertainment) century-plus conspiracy to not only maintain its discrimmator>', predommately all-white/"Jewish" workforce, but to also help maintain institutional racism throughout society and the world. As reflected m the title o f the motion, you were also made aware that I alleged that William M o m s Endeavor Entertainment, Loeb & Loeb LLP, Michael P. Zweig and others were engagmg in an unconscionable level o f fraud and that I sought disciplmary and monetaiy sanctions against WiUiam Morris, Loeb & Loeb LLP and others for engaging in a "pattern" of highly unethical and criminal conduct. On March 13, 2014, I officially put you on notice as to tlie marriage between Loeb & Loeb LLP attorney Christian Carbone and Sasha Angehque Carbone, General Associate Counsel for the ^American Arbitration Association. I n that letter, I asked for the court to compel Christian Carbone to disclose this information via Affidavit since this information was never disclosed when he and Michael P. Zweig sought to compel this case into arbitration on William Morris' behalf. O f course, your March 27, 2014 Order makes absolutely no mention o f the evidence I have presented to support these facts, and instead states that by submitting this motion, I "violated the stay ordered m the July 20 Memorandum and Order, as well as an explicit Order o f March 10, 2014." (emphasis added) Although Christian Carbone has submitted various pleadings on behalf o f William Morris since March 13, 2014, he and Sasha A. Carbone have chosen to remam silent to a question that must be answered. Mrs. Carbone is one of the vice presidents for the A A A and formerly worked for Loeb & Loeb LLP. In addition, Mrs. Carbone chairs the Diversity Committee - a committee in which Arbitrator Lewis formerly chaired and may currently still sit as a member. Furthermore, Arbitrator Lewis is a board member of the American Arbitration Association. None o f this information was disclosed to me. In fact, this information was concealed from me. Is it appropriate to move forward with my case under the jurisdiction of the American Arbitration Association? And is it appropriate to My motion was submitted 90 days after Arbitrator David L. Gregory issued his Partial Final Award, because I additionally sought to confirm, modify and/or vacate Gregory's Award pursuant to 12 o f the Federal Arbitration Act, m further support that P. Kevin Castel's July 20, 2011 Stay Order should be vacated because it was erroneous both as a matter o f law and public policy.

Mr. P. Kevin Castel March 28, 2014 Page 2 move forward with the substantive issues in federal court, before these ethical issues are resolved? 1 am fully aware o f the ethical responsibilities o f lawyers and judges and I know tliat these various conflicts o f interest, strikes at the heart o f an officer's ability to dispense justice both equally and impartially. I cannot be expected to contmue litigating this case m "good faith" when opposmg counsel have made millions from acting m "bad faith" and have never been required to abide by the New York Rules o f Professional Conduct. Due to the on-going fraud that has occurred smce the inception of this case,

I cannot and will not continue litigating this case any further under the jurisdiction and supervision of the American Arbitration Association until these issues are acknowledged by the federal court and resolved.

Smce I've never had an oral hearing m this case and have repeated requested one, I ask that an expedited oral hearmg take place at the Southern District o f New York, 500 Pearl Street, New York, New York 10007 on or before Friday, April 18, 2014. . ^ i d to ensure that my constitutional and God-given rights are fully protected, I am asking for the fourth time, that this matter be referred to the U.S. Attorney General, Mr. Eric Holder, and President of the United States o f America, Mr. Barack H. Obama. Best,

Marcus I . Washington

Enclosure: cc: Mr. Michael P. Zweig o f Loeb & Loeb LLP (delivered via e-mail)

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