U N I T E D STATES D I S T R I C T C O U R T S O U T H E R N D I S T R I C T OF N E W Y O R K

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R O W E E N T E R T A I N M E N T et a l , Plamtiffs, : : 98 Civ.8272 (RPP)(JCF)

against W I L L I A M M O R R I S A G E N C Y , et al. Defendants. :

AFFIDAVIT OF MARCUS ISAIAH

WASHINGTON

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STATE OF NEW YORK COUNTY OF KINGS ) ) )

SS.;

MARCUS ISAIAH WASHINGTON, being duly sworn, hereby deposes and states: 1. I , Marcus Isaiah Washington, am fully familiar with the matters set forth herein and respectfully submit this Affidavit in support of Mr. Leonard Rowe's Opposition to the Defendants' Motion For a Permanent Restraining Order Due To Fraud Upon the Court, which seeks to prevent Mr. Rowe from filing commercial liens against those who have not only violated his constitutional rights, but have also engaged in a heinous, on-going conspiracy that interferes with and violates the human rights of all persons in America and throughout the world, particularly those of African descent. 2. In 1986, the Supreme Court established the "separate, but equal" doctrine in Plessy v. Ferguson. 163 U.S. 537 (1896), ushering in a period of American history known as the Jim Crow era. Two years later, the William Morris Agency ("WMA") (now known as William Morris Endeavor Entertainment) was founded in New York City, New York by a "German Jewish immigrant" by the name of Zelman Moses, later known as William Morris. 3. From 1898 until 1961, the William Morris Agency had an explicit policy of not hiring African Americans, particularly with regards to positions such as Agent Trainees and Agents. As a result of the broader civil rights movement and direct protests against institutionalized racism and employment discrimination in Hollywood by civil rights organizations such as the NAACP, William Morris hired its first African American Agent Trainee Wally Amos - in 1961. By 1963, Amos was promoted and became the company's first African American music Agent, representing entertainers such as Marvin Gaye, The Supremes and Simon & Garflmkel. After six years working as a music Agent, Amos experienced the glass ceiling after asking to be promoted to work as an Agent in the film or television department. He was told that the studios and networks weren't "ready for a black agent." In his autobiography, Amos is quoted as saying, "What a distressing paradox: I was hired because I was black and now I could not advance because 1 was black." 4. Prior to working for the oldest and one of the most prestigious talent agencies throughout the world, I spent four years working various jobs throughout the entertainment industry, including but not limited to: the "Urban Editor" of a popular regional entertainment and fashion publication, publicist for a now GRAMMY award winning producer, GRAMMY U Student Rep. for the Florida Chapter of The Recording Academy and co-

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manager to now 8x GRAMMY nominated singer/songwriter Jazmine Sullivan - while simultaneously obtaining my Bachelors in Psychology & Media Management (2006) and Masters in Music Business and Entertainment Industries (2008) from the University of Miami by age 23. 5. Before moving to New York City and applying to the William Morris Agency's Agent Trainee program, I had a pre-existing relationship with William Morris. I learned from courses taken in grad school and working in artist management that pursuant to the Talent Agencies Act, Cal. Labor Code 1700 el seq. ("TAA") and similar laws in the state of New York and Florida, a manager is required to be "licensed" to procure engagements for their clients. As a law abiding citizen, I took the initial meetings in .December of 2007 with William Morris' Cara Lewis - former Senior Vice President of Urban Contemporary Music - throughout my search for someone "licensed" to represent Sullivan. Shortly after parting ways with Sullivan in a management capacity in April 2008, Sullivan signed with William Morris and was represented by Lewis until Lewis departed from the company in December 2011. As of December 2, 2013, Sullivan is still a client of William Morris. 6. According to the amicus curiae brief filed by the William Morris Agency on December 7, 2007 in support of the Respondent in Arnold M . Preston v. Alex E. Ferrer (06-1463), they stated; "The William Morris Agency endorsed the enactment of rules for theatrical and motion picture agents (as well as artists' managers) through California's Employment Agencies Act in 1937, and supported the TAA when it was adopted in its present form by the California legislature in 1978. W M A continues to support the TAA's operafion - as through the licensure, oversight, and adjudicative decisions of California's Labor Commissioner - to this very day." 7. In or around June 2010,1 applied to William Morris' Agent Trainee program and went through a three-part interview with the expressed goal of ultimately becoming a music Agent. From September 2, 2008 to April 9, 2010,1 was employed as an Agent Trainee at the New York office. 8. Within the first twenty minutes of employment, I along with two other individuals starting that day, were given a number of employment related agreements to review and sign, including an "agreement" to arbitrate "any and all issues which may arise...regarding any aspect of the[ ] employment relationship" without limitation to "disputes involving state and federal discrimination and harassment claims." Ahhough I did not know what arbitration was, I signed the arbitration agreement because I ultimately wanted to advance my career, ft wasn't until after signing these "agreements" as a condition of employment, that I discovered that I was the only African American employed throughout any level of the Agent Trainee program - even though William Morris has represented many notable African American entertainers and has made millions of dollars exploiting them throughout the decades. And while the Civil Rights Act of 1964 clearly states that it is unlawful for an employer "to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such individual's race, color, religion, sex, or national origin," 42 U.S.C. 2000e-2(a)(2), there were zero African Americans or Hispanics employed as Agent Trainees, Coordinators or Agents in the New York City office, although African Americans and Hispanics were overrepresented in Support Staff and Mailroom positions. 9. Although I was not knowledgeable of antidiscrimination law at any time before and/or during my employment at William Morris, it is well-settled that the presence of the "inexorable zero" in the workplace can serve as statistical evidence to support "an inference of discrimination." See 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 discriminafion."); Ewing v. Coca Cola Bottling Co.. No. 00 CIV. 7020(CM), 2001 WL 767070 (S.D.N. Y. June 25, 2001) (the court found a claim noting that the "inexorable zero" was sufficient to defeat a motion to dismiss because a near-zero promotion

rate of minorities into higher-skilled jobs reflected de facto segregation, and therefore supported an inference of intentional discrimination.); Loyd v. Phillip Bros.. 25 F.3d 518, 524 n.4 (7th Cir. 1994) ("100% sex-segregated workforce is highly suspicious and is sometimes alone sufficient to support judgment for the plaintiff."); Barner v. City of .Harvey. No. 95 C 3316, 1998 W L 664951, at *50 (N.D. 111. Sept. 18, 1998) ("In cases, 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); Compare Reynolds v. School Dist. No. 1. Denver. Colo.. 69 F.3d 1523, 1535, 104 Ed. Law Rep. 1004, 72 FairEmpl. Prac. Cas. (BNA) 485, 67 Empl. Prac. Dec. (CCH) ^143828 (10th Cir. 1995) ("Reynolds was the only white employee in the otherwise all-Hispanic Bilingual/ESOL Department, and Hispanic supervisors made most of the employment decisions of which Reynolds complains."). 10. After a few months of employment, I began to realize that I was considerably more qualified than majority, if not all, of the predominately White/"Jewish" Agent Trainees that were being hired. Most of those hired into the program had recently obtained their Bachelor's degree and had no relevant work experience in the entertainment industry, yet they were all being promoted above me to permanent Assistant positions. Over time, I realized that no matter how hard I tried, I was not going to be able to advance above the company's thick, glass ceiling - a direct result of William Morris' intentionally discriminatory organizational structure, institutional practices and work culture defined along racialized lines. 11. Although I openly discussed my work experiences and frustrations with my parents, friends and a few coworkers, I eventually had a meeting on March 17, 2010 with the former Chief Operating Officer of the New York office, Cara Stein, and expressed to her that I felt I was being discriminated against by the company and some of its employees because of my race. Stein's immediate response was that the company would "never" discriminate against African Americans and people of color, although she was able to recollect a time when the company's old white/"Jewish" boy's network discriminated against women from equal employment opportunities. Prior to this meeting, I ' d never had a conversation with Stein, but based on information relayed to her by those responsible for arranging the meeting - either Sarah Winiarski and/or Jeff Meade in Human Resources - she then suggested that I was the reason for why I could not advance in the company, while ignoring the fact that the second African American Agent Trainee that was hired after I moved out of the Mailroom was also never able to advance. Based on her response, I became visibly upset because it indicated to me that no action would be taken by the company to look into the truth of my allegations, and as a result, the myth that I was the lazy, underperforming, black employee who unable to advance due to my own shortcomings could be maintained. In order to "turn a negative into a positive," Stein offered to use the company's resources and her personal contacts to help me find a job outside of the company. 12. A month later, on April 7, 2010, Stein and I had a follow-up meeting. Despite the company's "Open Door Policy" and policies pertaining to "Reporting Harassment, Discrimination or Retaliation" located in the company's employee handbook, no investigation was made into my claims of racial discrimination. Stein told me she did review my evaluations and noted that they weren't "exceptional." We discussed my areas of interest and she stated to me that there would be "no movement" in those areas for the foreseeable fliture. She then informed me that due to new company policy, i f I did not land an Assistant position by "end of summer," I would have to leave the company. 13. The day after my second meeting with Stein, I met with the Head of Human Resources, Carole Katz. Typically based in Beverly Hills, Katz was visiting the New York office to discuss the company's new 401k plans. Prior to this meeting, I contacted Katz on August 6, 2009 to inform her about an incident in which 1 discovered that a "supervisor" - Christopher Walsh, Head of Special Services - lied on me in two e-mails that were sent to NY Human Resources. I expressed to Katz that I didn't feel comfortable going to Human Resources - specifically Pat

Galloway and Jeffrey Meade - about this problem, because I felt they were playing a pivotal role in "setting me up to fail." During our face-to-face meeting eight months later, .1 updated her about my experiences with the company, including my conversations with Cara Stein. I then inquired i f Sarah Winiarski and Meade ever told her about the meeting I requested in January 2010 to discuss my larger concerns with the company and how I was being treated. She replied no. [Stein told me the day after that Katz was informed about my request.] After learning this information, I replied, " I am talking with you about this behind closed doors, but I can make this a much bigger issue." Without hesitation, she offered me two options: either continuing to work or take five months' salary to look for another job. Since the company made no effort to investigate my claims and took no steps to ensure that its employment practices, policies and/or procedures were not discriminatory and unlawful, I was left with no choice but to accept the latter option - especially since I was suffering from stress related gastrointestinal and urinary health problems that were exacerbated by being given a high frequency of dead-end assignments and spending 10 hour work days in William Morris' insidiously discriminatory work environment. 14. My exit from the company on April 9, 2010 immediately went public after my "goodbye e-mail" appeared on a popular Hollywood blog. The article sparked a lot of debate about racism in Hollywood, and led to mentions on the HuffmglonPosi and Billboard.biz. After considerable thought, I made the decision to file a complaint with the Equal Employment Opportunity Commission ("EEOC") on June 3, 2010. While employed at William Morris, I'd never heard of the EEOC. My detailed complaint focused almost entirely on my individual experiences o f disparate treatment. Before filing this complaint, I knew nothing about William Morris' then 112-year pattern and continuing practice of engaging in employment discrimination and institutional racism. 15. Following the merger between the William Morris Agency and Endeavor Talent Agency in April of 2009, the New York office hired zero African American Floaters within its first year under the new leadership of Ariel Emanuel. After filing the complaint with the EEOC, the New York office of WME Entertainment hired five (5) African Americans as Floaters one month later. This is "statistically significanf and not "due to chance," especially since senior management told me the company had and would "never" discriminate against African Americans and people of color. In less than a year, zero out of those five African American hires remained employed at William Morris. 16. EEOC investigator Andrea Hahm failed to conduct an investigation into my complaint, and on September 28, 2010, the EEOC issued a.Dismissal and Notice of Rights letter. After conducting pre-discovery between June and December 2010,1 - as a pro se litigant - filed an 80-page complaint with the Southern District of New York on December 21, 2010 alleging claims of pattern and practice discrimination (systemic disparate treatment), disparate impact, failure to hire, pre and post-hiring individual disparate treatment, failure to promote, and retaliation based on race, color and/or perceived national origin against William Morris, in violation of Section 1981 of the Civil Rights Act of 1866, 42 U.S.C. 1981 ("Section 1981"), Title V I I of the Civil Rights Act of 1964, as codified, 42 U.S.C. 2000e to 2000e-l 7 ("Title W ) , the New York State Human Rights Law, New York Executive Law 290 e/iec/. (the "NYSHRL") and the New York City Human Rights Law, New York Administrative Code 8101 et seq. (the "NYCHRL"). Additional claims of retaliation and aiding & abetting based on race, color and/or perceived national origin were made against Winiarski and Meade. My extremely detailed complaint in and of itself created a prima facie case that my race, color and/or perceived national origin played a motivating factor in preventing me from being hired and/or promoted to Agent. Republican appointed Judge P. Kevin Castel and Magistrate James C. Francis were selected to preside over the case and Michael P. Zweig of Loeb & Loeb LLP served as the lead attorney for William Morris. 17. In a letter written to Judge Castel on February 8, 2011, Michael P. Zweig stated that all of my claims were "wholly without merit, legally and factually" and asked that the Court enforce the two arbitration agreements that I signed as a condition of employment at the William Morris Agency, and later, William Mortis Endeavor Entertainment. On February 25, 2011, Michael P. Zweig filed a Motion to Dismiss, or in the Alternative, Stay -4-

Pending Arbitration on behalf of William Morris. On March 21, 2011,1 raised a unique and narrowed argument in opposition to the arbitration agreement's enforceability: Based on the preexisting historical, statistical and other forms of evidence demonstrating William Morris' 112 year "pattern and practice" of systemic disparate treatment against African Americans and people of color, the "discrimination" and "retaliation" provisions in their arbitration agreement were "unconscionable and [ ] in direct violation of [Section 1981] and [Title V I I ] . " Additional arguments were also raised to support that this landmark civil and human rights case should remain in the federal court and be decided by an impartial jury. In William Mortis' Reply, they argued, "Much like his complaint, Mr. Washington's opposition is filled with outrageous, self-contradictory, and utteriy unsubstantiated allegations about WME and its employees." They also stated that I "raise[d] no credible opposition to the enforcement of his agreement to arbitrate." 18. On July 20, 2011, Judge Castel issued his deceptively written decision staying the case and compelling the case into arbitration. He ignored my entire argument, omitted pertinent facts and misapplied the law in order to conclude that the arbitration agreements should be upheld. Instead of applying antidiscrimination law into the framework of the Federal Arbitration Act, 9 U.S.C. 1 el seq ("FAA") to determine unconscionability, he relied exclusively on the literal language contained within the four corners of the agreement and focused only on the FAA. Castel never decided whether or not the "discrimination" and/or "retaliation" provisions were unconscionable. The 2009 Arbitration Agreement exclusively contained what Castel referred to as the "Delegation Provision." It stated: "The Arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute relating to the interpretation, applicability, enforceability or formation of this Agreement, including but not limited to any claim that all or any part of this Agreement is void or voidable." Based on this language. Castle shifted responsibility to the Arbitrator to determine whether the "discrimination" provision was unconscionable and/or whether or not the arbitration agreement should be enforced. There is no indication from Castel's Stay Order that the legislative history of Title V I I , the NYCFIRL or any of the other antidiscrimination statutes mentioned in paragraph 16 were taken into consideration in writing his decision. 19. From September 28, 2011 to June 6, 2011, I made four "good faith" attempts to appeal the erroneous Stay Order of Judge Castel. In my first appeal attempt (hereinafter "Emergency Motion to Appeal"), I demonstrated that Judge Castel's Stay Order was erroneous as a matter of law, adding that the provisions were also tainted with illegality and malum in se. Secondly, 1 demonstrated that there was a "strong public interest" that this case remain in the federal court due to the (1.) the ineffectiveness of the Civil Rights Act of 1964's ability to combat and eradicate insidious and institutional racism throughout the American workplace and to (2.) address the direct role William Morris' (and Hollywood) "cabal-like practices" play in maintaining racism throughout society and the worid due it's considerable influence over powerful communicative mediums such as television and film. Lastly, I used Judge Castel's Stay Order as a lens to support that both he and Magistrate Judge James C. Francis should be disqualified from my case due to what I believed was an "appearance and/or actual bias, prejudice and/or impropriety" pursuant to 28 U.S.C. 455 and 28 U.S.C. 2106. William Morris never rebutted my arguments that Judge Castel applied the wrong standard of law in their Opposition filed on October 7, 2011. Instead, they argued that the Court did not have jurisdiction to hear the appeal because Judge Castel issued an interlocutory order and that my appeal was "moot." In my Reply submitted on October 17, 2011, I responded by stating that Michael P. Zweig and Loeb & Loeb LLP's "counter arguments [were] moot, substantively insufficient and serve[d] as nothing more than a smoke-screen to deceive the Court into believing that their words are of meaning." I also showed that the request for an expedited appeal was justified and not "moot" by demonstrating an "extraordinary showing o f 'good cause'" pursuant to section 1292(b), as codified 28 U.S.C. 1292(b). On December 13, 2013, the three panel judges - Denny Chin, Peter W. Hall and Gerard E. Lynch - mirrored the arguments of William Morris and Loeb & Loeb LLP with a one paragraph, stating that the appellate court did not have jurisdiction to hear an interlocutory appeal and dismissed my appeal as being "moot."

20. On December 27, 2011,1 filed a Petition for Rehearing, Petition for Rehearing En Banc and/or Petition for a Writ of Mandamus (hereinafter "Motion for Reconsideration"). In it, I demonstrated that based the exceptional arguments raised in my Emergency Motion to Appeal, I met the multi-factored requirements under section 1292(b), the collateral order doctrine and the All Writs Act, as codified as 28 U.S.C. 1651 to allow the appellate court "immediate appellate review" to reverse the harmfully erroneous Stay Order of Judge Castel - even though the Stay Order was a "non-final," interlocutory order. On February 3, 2012, in a two-sentence order, the "panel [determining] the appeal...and the active members of the Court [considering] the request for reconsideration en banc" denied the motion without any explanation. For the second time, no judicial opinion was provided. 21. In January 2012, while writing my third appeal (hereinafter "Motion to Recall Mandate"), I came across an article on CNN's website titled "Corruption in Our Federal Courts," which discussed the Rowe Entertainment et al. V. William Morris Agency et al. case. Although I was aware that a racial discrimination case involving William Morris had been litigated while conducting pre-discovery for my case, I knew very little about the facts of their case or that it had been alleged that attorneys on both sides conspired to conceal smoking gun evidence in which various employees from two of Hollywood's biggest talent agencies - the William Morris Agency and Creative Artists Agency - were caught referring to African Americans as "nigger," "nigga," "coon," "monkey," and other racially derogatory terms hundreds of times throughout their e-mails. I was completely disgusted after reading about how Leonard Rowe discovered "Exhibit 31" - the e-mail search summary results - on the desk of his former attorney after being told by his attorneys that no derogatory terms had been found, how the underlying e-mails were never produced by his attorneys that eventually withdrew from the case and that Judge Patterson "turned a deaf ear, blind eye, held his nose and swept the evidence under the rug as he entered an order dismissing the case, at the summary judgment level, while at the same time, intentionally ignoring the evidence that black people had been referred to as 'nigger' over 232 times, by the White executives of these entertainment industry giants, in their daily business practices." Since "genuine issues of material fact" existed in this case, it should have been decided by an impartial jury. My disgust grew when I found out that Michael P. Zweig, Loeb & Loeb LLP and Magistrate Judge James C. Francis were also involved in the Rowe Litigation. 22. Sometime in April 2012, I discovered that Leonard Rowe filed a Fed. R. Civ. P. 60 Motion on March 2, 2012 to seek to have his case reopened due to "fraud upon the Court." After finding out he was now a pro se litigant, I used the contact information listed on his motion to get in contact with him and ever since, we have been allies in our respective fights to challenge William Morris' discriminatory and anticompetitive practices, policies and procedures, as well as challenge institutional racism throughout Hollywood and corruption throughout America's judicial system (and any other branch of government). 23. When I submitted my Expedited Motion for Review to Recall Mandate, Vacate Improvident Order and Articulate Reasoning in the Form of a Judicial Opinion, Pending the Filing and Disposition of a Petition for a Writ of Certiorari on May 3, 2012 to demonstrate why my appeal was not "moot" as a matter of law, I also included information pertaining to Rowe to buttress my claims that Michael P. Zweig and Loeb & Loeb LLP were engaging in a "pattern" of highly unethical and criminal conduct on behalf of William Morris. I also cited case law to demonstrate that a judicial opinion should have been provided due to the "exceptional importance of this case" and as a result of the Second Circuit's decision to subvert the law, numerous Canons contained within the Judicial Code of Conduct were being violated. I flirther expounded upon my claims that bias existed with the judges assigned to my case by showing the "intersection between racism, politics and the law." By focusing on historical evidence spanning four decades, I demonstrated that our predominately all-White/"Jewish" judiciary was anything but "independent" or "impartial," especially when it comes to claims of institutional racism. Studies indicate that federal judges are largely influenced by the political ideology of those who appointed them to the bench. The cumulative evidence supported my claims that the harmful actions of the Republican appointed judges assigned to both cases reflected "institutionalized racism within America's judicial system and a larger conservative conspiracy

[particularly by Republican appointed judges] to eviscerate many of the gains made during the civil rights movement." 24. On May 14, 2012, three of Leonard Rowe's former attorneys from Sonnenschein Nath & Rosenthal LLP ("SNR") (now known as Dentons LLP) - Christine Lepera, Raymond Heslin and Richard Primoff - submitted Declarations that were ordered by Judge Patterson. Under ''penalty of perjury," each one stated, more or less, that no derogatory words were found during Electronic Evidence Discovery's ("EED") (now known as Documents Technology, Inc.) September 2002 search of William Morris and Creative Artists Agency's 1998-1999 backup tapes. On the following day, the fourth attorney - Martin R. Gold - submitted his Declaration, also denying that any derogatory terms were found. On that same day, I acquired possession of "Exhibit 31" from the Southern District of New York. Prior to this date, Leonard Rowe never had possession of this document. I f he did, it would have been included as an exhibit in his Fed. R. Civ. P. 60 Motion. 25. Before allowing me the opportunity to submit a reply to my Motion to Recall Mandate - which would have included "Exhibit 31" and the perjurious Declarations of Mr. Rowe's former attorneys - the Second Circuit prematurely and erroneously denied my appeal on May 23, 2012 without providing a judicial opinion for the third time. 26. On June 6, 2012, I filed an Emergency Petition for Rehearing to introduce "Exhibit 31" and provide supporting evidence that William Morris and "their amoral and unethical attorneys at Loeb & Loeb LLP, have engaged in a corrupt and sinister conspiracy to racketeer, collude and commit 'fraud upon the court' for more than a decade in two separate racial discrimination and antitrust cases against the Appellees - violations of the Racketeer Influenced and Corrupt Organizations Act ("RICO"), as codified, 18 U.S.C. 1961 el seq., the Organized Crime Control Act ("OCCA"), as codified, N.Y. Penal Law 460.00 el seq., 18 U.S.C. 1506 which addresses tampering with evidence in a federal case, obstruction of justice and other criminal statutes. I also argued: "Since I have presented evidence showing a 'pattern and existing practice' of systemic disparate treatment towards African Americans spanning 114 years and the Appellees have been unable to provide specific evidence to rebut my claims, any other argument raised by the Appellees should have been labeled frivolous, germane and legally insufficient as a matter of law by members of an impartial and unbiased judiciary. However, due to collusion and corruption, the attorneys and judges have been in bed together and the highly subjective decisions not based on law have been largely predetermined in an attempt to maintain the system of white supremacy throughout America." 27. On June 12, 2012, the Clerk of Court - Catherine O'Hagan Wolfe - obstructed the administration of justice by preventing the Court from receiving my fourth appeal containing direct evidence to support my claim that William Morris, Loeb & Loeb LLP and Michael Zweig were engaging in a "pattern" of "fraud upon the Court." In their "non-jurisdiction" letter, it stated that my case was closed and the entire motion was mailed back to me. 28. Instead of having the case harmfully delayed any further by attempting to file a petition for a writ of certiorari and having it rejected by the Supreme Court's conservative. Republican-appointed majority, I decided to comply with Judge Castel's erroneous Stay Order and filed a Demand for Arbitration with the American Arbitration Association on June 15, 2012. After Michael P. Zweig and Loeb & Loeb LLP continued to deny all claims on behalf of William Morris, I moved for summary judgment on August 15, 2012. In their November 6, 2008 Cross Motion to Dismiss, William Morris and their attorneys did not specifically address "Exhibit 31." Instead, they stated: "Washington's repeated reliance on the unsuccessftil claims alleged in Rowe Entm't. Inc. v. William Morris Agencv. Inc.. 98 CIV. 8272, 2005 W L 22833 (S.D.N.Y. Jan. 5, 2005) afPd, 167 F. App'x 227 (2d Cir. 2005) is particularly unavailing, especially in light of the District Court's 175 page summary judgment decision dismissing those claims. In Rowe, Judge Patterson rejected plaintiffs' attempts to rely on an alleged proven history of systemic discrimination to support their claims. The court found that generalized statements, about systemic -7-

racism without supporting facts demonstrating specific incidents of discrimination against plaintiffs failed to establish a prima facie case of discrimination. Id. at *8. As the Second Circuit later affirmed, the plaintiffs put forth no facts upon which a reasonable juror could conclude that racial discrimination took place. Rowe Entm't. Inc. V. William Morris Agency. Inc.. 167 F. App'x 227, 229 (2d Cir. 2005). Similarly, here, without any concrete facts, or any specific evidence whatsoever to support his claims, Washington's allegations o f pattern and practice discrimination, or any other form of discrimination, must be rejected." [pg. 35 ] 29. Two days later, on November 8, 2012, Republican appointed Judge Robert P. Patterson - now 89 years old - denied Leonard Rowe's Fed. R. Civ. P. 60 Motion, claiming that his claims of "fraud upon the Court" were "based on nothing more than hot air and paranoid suspicions." The decision makes no mention of the four perjurious Declarations from Leonard Rowe's former all-White/"Jewish" attorneys which continued to falsely state that no derogatory terms were found - to the benefit of William Morris, Creative Artists Agency, Loeb & Loeb LLP, Weil Gotshal & Manges LLP and others that remained silent to Rowe's Fed. R. Civ. P. 60 Motion - although "Exhibit 31" clearly demonstrates that the document was faxed from "SNR New York" on October 15, 2002. Although they deny any derogatory terms ever being discovered, SNR has never denied the fact that "Exhibit 31" was faxed by someone from their New York office to the Willie Gary Law Firm or claimed that this document is bogus and/or fi-audulent. 30. On January 31, 2013, I submitted the "97 page omnibus" Reply for my Motion for Summary Judgment to the AAA and incorporated a lot of the "newly discovered details" from Patterson's November 8, 2012 decision to demonstrate that my "Exhibit 31" was in fact an authentic document and that I should be allowed discovery to obtain possession of this spoliated, smoking-gun evidence because it demonstrated the "unvarnished racial animus" of William Morris and its employees and proved all of my claims - including those pertaining to the unconscionability of William Morris' arbitration agreements and allegations that Loeb & Loeb LLP and its attorneys were engaging in highly unethical and criminal conduct on behalf of their client William Morris. I asked for the Arbitrator to have William Morris cover the costs of having an e-discovery expert of my choice retrieve the e-mails from the 1998-1999 backup tapes that were originally searched in Rowe or pay for the costs of a contemporary e-mail search including many o f the search terms used in Rowe. In the March 15, 2013 Reply to William Morris' Cross Motion to Dismiss, William Morris and their attorneys addressed "Exhibit 31" and mirrored the statements made in Judge Patterson's January 5, 2005 decision by stating: "Washington acknowledges that Judge Patterson has repeatedly ruled that 'Exhibit 31' is 'irrelevant material,' yet, Washington inexplicably claims, without a whit of substantiation, that there are emails that underlie Exhibit 31 and that those emails are somehow relevant to his claims. Yet he does not deny that Exhibit 31 was dismissed by the Court as 'an unidentified and unauthenticated document.' The author of this document was never identified, nor was the source of the 'information' allegedly contained therein. None of the individuals whose names are listed on this document are named in this suit, nor does Washington allege that those individuals were involved in any way in the facts giving rise to his claims. Exhibit 31 - the basis for Washington's 'emergency motion' - has already been discredited by a Federal court and is wholly irrelevant to Washington's claims." [pg. 16-17.] 31. In the first Interim Decision of Arbitrator David L. Gregory issued on April 18, 2013, he determined - after "carefully read[ing] the parties [submissions filed with the Southern District of New York, Second Circuit and A A A ] and the available relevant authorities cited therein" - that, "Claimant may stand in political solidarity with Mr. Leonard Rowe but Claimant is not foreclosed by judicial decisions regarding Mr. Rowe's past proceedings.. .1 do not find Judge Patterson's decision regarding Exhibit [31] in the Rowe matter to have res judicata or collateral estoppel or other preclusive influence on the status of Exhibit [31] in this arbitration." [pg. 1, 14] ITe stated " I am persuaded that a particular document [Exhibit 31] is critically important and should be produced and truthflilly explained by both parties to the extent that they are realistically able to do so" and did something any impartial judge should have done in Rowe - he compelled William Morris, Loeb & Loeb LLP and/or Michael P. Zweig to produce the underlying e-mails to "Exhibit 31," or in the alternative, produce whatever e-mails obtained from -8-

Electronic Evidence Discovery since SNR, Loeb & Loeb LLP, Michael P. Zweig and others involved with electronic discovery adamantly maintain that no derogatory terms were ever found during EED's search. He stated "T would prefer the production of the original documents constituting Exhibit [31]." [pg. 5, 12] He then gave us an assignment; "In this case before me at this Arbitration, I need to know more about Exhibit [31]. Both parties know that Exhibit [31] exists. Their assessment of Exhibit [31] dramatically vary. I want to know what Exhibit [31] is, and who authored it, is it genuine? Is it relevant? I want to know the context." [pg. 10-11] Both parties were given until June 3, 2013 to submit their responses. 32. During the month of June, I spent countless hours at the Southern District of New York going through the record in Rowe. pulling documents that I felt were relevant to help demonstrate that "Exhibit 31" was an authentic document. 33. In William Morris' Reply to the Arbitrator's April 18, 2013 Interim Decision submitted on June 14, 2013, William Morris, Loeb & Loeb LLP and Michael P. Zweig argued that they had "no independent, first-hand understanding or knowledge concerning Exhibit [31]" and that they "a) never received or saw any such 1998-1999 emails, as allegedly referenced by Exhibit [31]; b) have no reason to believe such emails exist or even existed; and c) notwithstanding Washington's false assertion, never received copies of such emails fiom the Rowe plaintiffs, their attorneys or their e-discovery expert ("EED") during the Rowe Litigation, or at any time thereafter." (emphasis in the original.) [pg. 1, 5 ] William Morris identified 19 usemames from "Exhibit 31" as being former or current employees o f the company, but according them, this document was irrelevant to my claims because ail individuals identified on the 11 year old document were employed in the Beverly Hills office and "had no possible involvement in any of the matters related to Washington's claims for employment discrimination arising from his employment at WME in 2008-10." [pg. 8-9] 34. In my Reply to the Arbitrator's April 18, 2013 Interim Decision submitted on June 14, 2013, I demonstrated, amongst many things, that: (1.) SNR exclusively handled e-discovery on behalf of the black concert promoters; (2.) SNR gave counsel for William Morris and Creative Artists Agency permission to obtain the e-mail results first without informing their clients who paid $200,000.00 for the search - this was an expressed violation of Judge Francis' e-discovery protocol; (3.) In or around September 2002, EED created and searched mirror images of William Morris' computer hard drives; (4.) On the day the results were due, counsel for the class of black concert promoters informed their clients that no derogatory terms were found; (5.) Loeb & Loeb LLP received the e-mail results before SNR and deleted e-mails they felt were "privileged" - a violation of Judge Francis' protocol; (6.) All e-mails, compact discs (CDs) and privilege logs received by SNR pertaining to EED's search on the backup tapes of W M A came from Loeb & Loeb LLP; (7.) Unless SNR fraudulently created "Exhibit 31," SNR could have only received "Exhibit 31" from EED; (8.) The Willie Gary Firm was first informed of "Exhibit 31" after Leonard Rowe discovered the document on the desk of former attorney Raymond Heslin and it was soon after faxed to the Willie Gar>' Firm from "SNR NEW YORK" on October 15, 2002; and (9.) There is reason to believe that none of the music Agents' e-mails from William Morris were actually searched by EED. Although the version of "Exhibit 31" that was submitted in the class of black concert promoters' April 24, 2003 Opposition to Summary Judgment by Willie Gary is missing two pages, this document contains usemames for more than 195 employees and departments from W M A and CAA, although the usemames of the five (5) W M A music Agents - Cara Lewis, Peter Grosslight, Richard Rosenberg, Jeff Frasco and Shelly Schultz - are nowhere to be found. Whether or not the actual e-mails were physically "received" is irrelevant since EED's search indicates that the derogatory words are located on the 1998-1999 backup tapes of W M A and CAA. These facts are mentioned nowhere throughout Patterson's unfavorable decisions in Rowe because they support that Leonard Rowe's claims are not flill o f "hot air" and "paranoid suspicions" and that a conspiracy - "an agreement between two or more persons to commit a crime" - did take place involving various officers of the court, including Michael P. Zweig of Loeb & Loeb LLP, to conceal damaging, smoking-gun evidence showing beyond a reasonable doubt, the "unvarnished racial animus" of William Morris, Creative Artists Agency and its employees. -9-

35. Although I presented a "pyramid of evidence" demonstrating that "Exhibit 31" was authentic and Gregory had more than enough evidence to determine whether or not to enforce William Morris' arbitration agreements, none of this evidence was included in Arbitrator Gregory's second Interim Decision issued on July 15, 2013. Between the first and second Interim Decisions, Gregory did a complete about-face. In the first Interim Decision, he compared my efforts to that of Martin Luther King, Jr. and Thurgood Marshall. Now, he was describing my arguments as being "rhetorically rich" and that my "language ultimately [wa]s merely conclusory rote." [pg. 4.] In order to support his decision to prolong making a "final" decision in the case, he incorrectly applied Rivera v. Rochester and Genesee Regional Transportation Authority. F.3d, No. 11-762 (December 21, 2012) and stated that the Second Circuit "expressed jurisprudential unease with decisions regarding employment law issues rendered solely via Summary Judgment papers." [pg. 3.] He then stated that "the continuing troubling indeterminacy o f potentially very important possible evidence ("Exhibit [31]") may be more thoroughly and, hopefially, finally resolved by sworn testimony in a hearing." [pg. 3-4.] Having ignored the mountain of evidence that was presented, he repeated the same question that both parties endeavored to answer in our June 14, 2013 submissions, stating: " I continue to need to know more about proposed Exhibit [31]. The parties' assessments of Exhibit [31] dramatically vary, to say the least. The author(s) have not been definitively identified. I still want to know who authored it. Is it genuine? Is it relevant?" [pg. 12.] He also stated: "Claimant remains free throughout continuing discovery and at the forthcoming arbitration hearing to continue to try to provide credible information about Exhibit [31]: e.g., after the Rowe/Heslin meeting, who retained the document that Rowe saw on Heslin's desk? Were copies made or distributed? I f so, by and to whom? When?" [pg. 6.] Gregory stated that since I was the "proponent of Exhibit [31] coming into evidence," he expected me to "take the initiative," [pg. 11.], and "expect[ed] Respondents to remain open to facilitating reasonable pertinent discovery requests regarding particular persons named on the current version of Exhibit A." [pg. 8.] In order to accommodate this order, Gregory stated that "discovery requests, and the statutory law against unlawful employment discrimination," were to be "liberally construed" pursuant to New York law. [pg. 13.] A hearing was expected to take place no later than December 16, 2013. 36. On July 26, 2013, 1 filed an Emergency Motion for Clarification and Modification, Expedited Oral Hearing Demanded. This motion specifically addressed more than 19 of the gross factual errors and inaccuracies contained in the second Interim Decision of Arbitrator Gregory. On July 30, 2013, Arbitrator Gregory scheduled a conference call with both parties. During the recorded call, Gregory acknowledged many things that were not stated in second Interim Decision. He stated, "There's no doubt you [Mr. Washington] filed enormous amount of paper, much of it, very well presented I thought." Although he incorrectly stated that the Affidavit submitted by Leonard Rowe in support of my June 14, 2013 submission came from "another proceeding," he acknowledged his error, stated that he "appreciate[d] [my] urging of a more precise read" and expressed that he saw how Rowe's Affidavit was "centrally situated as I see your structural, institutional claims." He noted that "Sexism is one of the deeply embedded pOathologies in most of human history," while adding that "it's not as deeply embedded as racism is in the United States and perhaps even globally." Most importantly, with regards to "Exhibit 31," he stated: " I will say this, when I first saw the list ["Exhibit 31"], there was very little information on it. After I saw the Claimant's papers.. .there was a great deal more information on that document and it sounds like much of it, i f not all o f it, but much of it came through the Claimant's endeavors and in some part of the Claimant's papers, the Claimant Mr. Washington talks about staying several days in the federal courts going through documents to do your best to comply with my requests for more specificity. And now, we have a document, thanks to Mr. Washington's efforts primarily it seems, that has significantly more information on it than did the original copy..." 37. Throughout majority of the July 30, 2013 conference call with Gregory, I maintained that in order to ensure "fijndamental fairness," Gregory's second Interim Decision needed to be cortected and discovery and an oral hearing needed to take place before a decision could be made with regards to any aspect of my case. However, by the end of the nearly hour long call, Gregory stated that he would be able to render a "final" decision by "Labor Day," in which I agreed. Realizing my error, I immediately maintained my earlier position in an e-mail sent to the A A A on August 1, 2013, followed by my Proposed Discovery and Hearing Schedule submitted on August 7, 2013. -10-

38. In response to my Emergency Motion for Modification and my proposed discovery and hearing schedule, Arbitrator Gregory issued his third Interim Decision on September 25, 2013. Although it had already been decided that he could not make any decisions in my case before discovery and an oral hearing was held. Arbitrator Gregory prematurely dismissed both of my conspiracy claims under the Sherman Antitrust Act, 15 U.S.C. 1 et seq. and Ku Klux Klan Act of 1871, now codified as 42 U.S.C. 1985, and stated that the arbitration agreement was "not unconscionable," without any mention of the facts of the case or any citation of the prevailing law. He also refiased to clarify and/or modify his second Interim Decision to reflect that verbal statements made during our July 30, 2013 conference call. In the same decision, he simultaneously admitted "Exhibit 31" into the evidence of record although I presented no new evidence regarding "Exhibit 31" since my June 14, 2013 submission, [pg. 2.] My discovery requests to depose Loeb & Loeb LLP attorneys Michael P. Zweig and Helen Gavaris, as well as WME CEO Ariel Emanuel, were denied without any citation of the law. He did, however, order William Morris to pay the costs associated with having an e-discovery expert of my choice retrieve this decade old, spoliated, smoking gun evidence, [pg. 2.] 39. Between April 18, 2013 and October 16, 2013, absolutely no discovery took place. Throughout this entire time, William Morris, Loeb & Loeb LLP and Michael P. Zweig engaged in contumacious and unethical conduct with extreme bad faith. They refused to meet and confer to discuss "Exhibit 31." They refused to inform me of when a litigation hold was placed on William Morris and its employees. My Interrogatories were never responded to. Also, no e-mails whatsoever have been produced. On September 30, 2013, I was left with no choice but to file an Emergency Motion for Order to Compel Respondents to Comply with Discovery Requests because due to William Morris' refiisal to answer preliminary questions about the 1998-1999 backup tapes, I was unable to comply with Gregor}''s decision and obtain accurate quotes from e-discovery experts. Additionally, William Morris and Loeb & Loeb LLP also refiised to produce the compact discs (CDs) and privilege logs that were mentioned in letters sent from Loeb & Loeb LLP attorney Helen Gavaris to Richard Primoff in late 2002. William Morris and their counsel didn't respond directly to this motion. Instead, they submitted a "letter" on October 11, 2013 to Gregory stating that since they had already addressed my "wholly unsupported and outrageous allegations of spoliation and criminal activity, as well as Claimant's inaccurate descriptions of the Rowe litigation and prior decisions in this Arbitration, [they saw] no useful purpose to be served by repeated denials (which are stated again for the record), no any additional response, unless the Arbitrator identifies an issue as to which fijrther briefing is required," [pg. 1-2.] As a result of their troubles, they requested a second protective order as a result of my "strident, abusive and threatening tactics." [pg. 2.] When I tried to submit my reply on October 15, 2013, I was obstructed from doing so by the A A A and its staff, Carol Placella and Heather Santo. 40. On October 16, 2013, Arbitrator Gregory refijsed to make a decision on the Emergency Motion to Compel. Instead, he "suspended" "all discover^' initiatives" and stated, " I am confident that I have sufficient evidence to write the omnibus final decision." Final position statements were submitted by both parties by November 20, 2013 and Arbitrator Gregory is expected to make his "final" decision no later than December 23, 2013. 41. Regardless of Gregory's "final" decision, Gregory's three Interim Decisions regarding "Exhibit 31" establish that William Morris, Loeb & Loeb LLP, SNR, Mchael P. Zweig and all others involved in this conspiracy should be precluded from arguing any further that "Exhibit 31" is an "unidentified and unauthenticated documenf and that Leonard Rowe's claims are full of "hot air and paranoid suspicions" under the doctrine of res judicata, especially since William Morris refijsed produce any of the e-mails, compact discs (CDs), privilege and responsive logs and additional tangible evidence over the last six months. 42. There is no mention of Arbitrator Gregory's three Interim Decisions regarding "Exhibit 3 1 " in the November 22, 2013 submission of William Morris, Loeb & Loeb LLP, Michael P. Zweig and other affiliated attorneys in their request for a temporary restraining order and request for a permanent injunction against Leonard

Rowe from filing commercial liens against those who have violated his constitutional rights and engaged in this sinister and diabolical conspiracy to interfere with the human rights of people of African descent. 43. After nearly three years of litigation, William Morris and Loeb & Loeb LLP have never been able to refute the pyramid of evidence - including substantial case law, sociological jurisprudence, law literature and current events - which prove that William Morris' 115 year pattern and continuing practice o f race-based employment discrimination or the evidence demonstrating that this company and other similarly situated businesses have conspired to maintain a race-based monopoly throughout Hollywood and the marketplace of ideas. They have never provided a "legitimate, nondiscriminatory reason" for why there are zero African American Agents or Coordinators employed in the New York office or why there is a gross underrepresentation of qualified people of color employed throughout its offices located throughout the world and no judge or arbitrator has asked them to do so. They have never demonstrated a "business necessity" for relying on employment practices, policies and procedures that create a glaring disparate impact against qualified African Americans and people of color from being hired and/or promoted to Agent (e.g. reliance on word-of-mouth hiring, subjective decision-making, etc.) and no judge or arbitrator has asked them to do so. No "procompetitive business justification" has also been provided to refute evidence supporting claims of antitrust violations as well. 44. Although racism is a reality, "race" is a social and legal construct. White and/or "Jewish" superiority is nothing more than a myth. As stated in Int'l Bhd. of Teamsters v. United States, 431 U.S. 339 n.20 (1977), "Statistics showing racial or ethnic imbalance are probative... because such imbalance is often a telltale sign of purposeflil discrimination." I f employment discrimination weren't occurring throughout the workplace, "it is ordinarily to be expected that nondiscriminatoP)' hiring practices will in time result in a work force more or less representative of the racial and ethnic composition of the population in the community from which employees are hired." Id. 45. In the same way William Moms engages in company-wide employment discrimination against African Americans and people of color, this racial animus and/or implicit racial bias harbored by its predominately allWhite/"Jewish" employees negatively impacts people of color in all facets of their business. Given that William Morris' discriminator)' employment practices, policies and/or procedures have resulted in zero and/or a gross underrepresentation of qualified Agents and Coordinators in the workplace, the anticompetitive effects of this exclusion demonstrates why the black concert promoters alleged in 1998: "[bjecause of an all-white concert promotion fraternity, the black concert promoters are systematically excluded from the promotion of concerts given by white performers. No black promoter, including plaintiffs, has been able to contract to promote a contemporary music concert given by a white artist, or even been given the opportunity to bid on such promotion. In addition, plaintiffs are regularly excluded from the promotion of concerts given by top-drawing black performers." To my knowledge, there has not been an African American music Agent employed at William Morris since sometime in the 1990s. Between September and November of 2008, I served as a temporary assistant to Cara Lewis and I saw that concert promoters like AEG and Live Nation were exclusively given the rights to nationally tour majority of the African American artists signed to Lewis' roster. 46. As a result of the highly unethical and criminal actions of William Morris, Loeb & Loeb LLP, Michael P. Zweig and their other co-conspirators, numerous Rules under the New York Code of Professional Conduct have been violated, including, but not limited to: "engag[ing] in illegal conduct that adversely reflects on the lawyer's honesty, trustworthiness or fitness as a lawyer;" "engag[ing] in conduct involving dishonesty, fraud, deceit or misrepresentation;" "engag[ing] in conduct that is prejudicial to the administration of justice;" "knowingly assist[ing] a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law;" and "engag[ing] in any other conduct that adversely reflects on the lawyer's fitness as a lawyer." Rule 8.4 (b), (c), (d), (f) and (h). Based on the unethical and criminal conduct of Loeb & Loeb LLP in Rowe. it is without

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question that Michael P. Zweig should be disbarred and imprisoned. Additionally, Loeb & Loeb LLP should not be currently representing William Morris in my racial discrimination and antitrust case. 47. On July 19, 2012, Leonard Rowe and I filed a joint complaint with the Departmental Disciplinary Committee ("DDC"), First Department, against nine attorneys. Our initial complaint was immediately whitewashed. After bringing the issue to the attention of Chairman Roy L. Reardon and requesting reconsideration, the .DDC pretended that they were going to conduct an investigation into our complaint. No investigation took place by either the First or Tenth Judicial District. Given that Leonard Rowe's former attorney Martin R. Gold is a Policy Committee Member of the DDC, his complaint was eventually transferred to the Tenth Judicial District. On January 10, 2013, we received a letter from Robert A. Green of the Tenth Judicial District stating that the "allegations of your July 2012 complaint mirror the allegations of misconduct contained in the complaint you filed against the same attorneys in April 2010" and because Mr. Rowe was "pursuing [his] legal remedies in a federal proceeding pending in the United States District Court, Southern District of New York...the practice of the Committee is to refrain from investigating complaints which are being addressed in a legal proceeding." In a letter dated February 19, 2013, Jorge Dopico of the First Department stated that the DDC decided "not to proceed fijrther with [our] compliant." 48. On September 28, 2012,1 attempted to file a complaint on behalf of Leonard Rowe and I under the Judicial Conduct and Disability Act of 1980, 28 U.S.C. 351-364. The Clerk of Court, Catherine O'Hagan Wolfe, rejected the complaint and erroneously stated that my "document" did not "conform to the Rules of the Judicial Council of the Second Circuit Governing Complaints Against Judicial Officers Under 28 USC 351" 49. On November 2, 2012, I filed a complaint on behalf of Leonard Rowe and 1 with the New York Police Department. I received a letter from Raymond Spinella, Assistant Chief Commanding Officer of Police Commissioner's Office dated November 30, 2012 referring the matter to Roy L. Reardon, Chairman of the Departmental Disciplinary Committee because the "concerns of the writer appear to fall within the purview" of the DDC. In or around this time, I also tried to file a complaint on behalf of Leonard Rowe and I with the Public Integrity Unit with the New York County District Attorney's Office, but I was told there was nothing they could do. 50. On October 28, 2013,1 filed a complaint on behalf of Leonard Rowe and I with the United States Attorneys Office for the Southern District of New York, Civilian Crimes Report Unit (Criminal Division). 51. On November 10, 2013, I filed a complaint on behalf of Leonard Rowe and I with the FBI and the Department of Justice, Civil Rights Division. 52. As of December 2, 2013, none of the ethics committees or government affiliated agencies mentioned in paragraphs 47 through 51 have taken any action with regards to investigating the allegations made in our complaints. In order to fight this gross injustice, the commercial lien seems to be the only option left for Leonard Rowe to have any chance at having this gross injustice corrected. 53. Not only have I been denied equal employment opportunity by William Morris because of my race, color and/or national origin, but I have been denied due process and equal protection under the law for the same reasons as well as a result of the unethical and criminal actions of Loeb & Loeb LLP and its attorneys. Due to the irreparable harm that I've suffered over the last five years, should I decide to employ the commercial lien process like Leonard Rowe, no judgment made by Judge Patterson can prevent me from filing a lien against William Morris, Loeb & Loeb LLP, Michael P. Zweig, Christian Carbone, Michael Barnett and any other officer that has been unjustly enriched fi'oni violating my human rights and engaging in these iniquitous crimes against humanity.

54. Any reasonable person with egalitarian beliefs and decent moral judgment should be disgusted upon reading this Affidavit. .Although Michael Zweig, Loeb & Loeb LLP and William Morris have tried to discredit my arguments by labeling me as a "racist" or by stating that I am "anti-Semitic," neither one of their defamatory and libelous statements are true. I am not racist for exposing racism. I have always believed in a God that created and loves all of us. Additionally, my parents never raised me to live with hate in my hearts. Instead, they always instilled in me the belief that it was my intelligence, strong work ethic, good character and drive that would set me apart from the rest - not my racial, cultural and/or religious affiliations. 55. When all the facts and circumstances are taken into consideration, it is glaringly obvious that our judicial system, especially the predominately all-White/"Jewish" judges that comprise the Southern District of New York, has absolutely no legitimacy or moral authority to decide cases challenging institutional racism. This is due to the simple fact that America's judicial system is an inherently racist and corrupt institution designed to uphold and protect the interest of Whites by any means necessary. Since the commercial lien has been considered a "lethal weapon in the war against injustice," this appears to be the only process that will allow Leonard Rowe a fair opportunity to hold each wrongdoer accountable for their actions.

Marcus Isaiah Washington

I , Marcus Isaiah Washington, sign this under the penalty of perjury this

day of December 2013

Not iry

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