No.

15A126

IN T H E

Supreme Court of tlje ^nitetr States;

MARCUS ISAIAH WASHINGTON,

Petitioner,
V.

W I L L I A M MORRIS ENDEAVOR E N T E R T A I N M E N T L L C (formerly the W I L L I A M

MORRIS A G E N C Y ) , J E F F M E A D E and SARAH WINIARSKI,
Respondents.

On Petition for Writ of Certiorari to the United States

Court of Appeals for the Second Circuit

A P P L I C A T I O N T O J U S T I C E R U T H BADER GINSBURG T O STAY E X T E N S I O N O F

T I M E T O F I L E A P E T I T I O N F O R A W R I T O F C E R T I O R A R I PENDING T H E
E X P E D I T E D R E S O L U T I O N O F P E T I T I O N E R ' S J U L Y 18, 2015 MOTION T O
D I S Q U A L I F Y L O E B & L O E B L L P , M I C H A E L P. Z W E I G , CHRISTIAN C A R B O N E
AND O T H E R S F O R "FRAUD UPON T H E C O U R T " B Y A L L J U S T I C E S ON T H E
S U P R E M E COURT, OR IN T H E A L T N E R A T I V E , APPLICATION T O E X C E E D
WORD L I M I T S PURUSANT T O SUPREME C O U R T R U L E 33(l)(d).

RECEIVED I
SFP 1 5 2015
o m c E OF THE CLERK
SUPREME COURT. U.S.

Mr. Marcus Isaiah Washington

Pro Se Petitioner
Boerum Street, Apt. 6M
Brooklyn, NY 11206
(646) 504-6497
humanrights.areamust@gmail.eom

T A B L E OF CONTENTS
INTRODUCTION

BRIEF PROCEDURAL HISTORY OF WASHINGTON BEFORE SUPREME COURT

FIVE REASONS WHY THE CLERK OF COURT AND CYNTHIA RAPP'S REFUSAL TO
ACCEPT PETITIONER'S JULY 18, 2015 MOTION TO DISQUALIFY LOEB & LOEB LLP
CONSTITUTE A N OBSTRUCTION OF JUSTICE
6
1. A PETITION FOR WRIT OF CERTIORARI IS NOT THE ONLY PLEADING THAT
CAN BE SUBMITTED TO THE SUPREME COURT TO VACATE THE
DECISIONS OF THE LOWER COURTS
6
2. FEDERAL COURTS ARE INVESTED WITH A N "INHERENT POWER" TO
"CONTROL AND DIRECT THE CONDUCT OF LITIGATION"

3. A L L L A W ARTICLES READ SUPPORT THAT RULE 8 ALLOWS THE SUPREME

COURT TO DISBAR ATTORNEYS FOR ENGAGING I N CONDUCT
"UNBECOMING MEMBERS OF THE BAR"
8
4. TFIE STATE COURT DOES NOT HAVE A N EXCLUSIVE AUTHROITY TO
DISCPLINE ATTORNEYS FOR ENGAGING IN HIGHLY UNETHICAL
CONDUCT, ESPECIALLY IF THE STATE COURTS IN NEW YORK HAVE A
HISTORY OF WHITEWASHING LEGITMATE COMPLAINTS AND FAILED TO
CONDUCT A N INVESTIGATION
9
5. FOUR QUESTIONS THAT FURTHER DEMONSTRATE RAPP'S DISHONESTY 12
PRAYERS FOR RELIEF

14

CONCLUSION

17

T A B L E OF C I T E D AUTHORITIES
Case Law:
Allen F. Moore v. Stanley F. Sievers. 336 111. 316; 168 N.E. 259 (1929)

14

Blakelv v. Washington. 124 S. Ct. 2531 (2004)

16

Chambers v. Nasco. 501 U.S. 32 (1991)

Herring v. United States. 424 E3d 384 (3rd Cir. 2005)

14

In re Roisman. 931 N.Y.S.2d 571 (App. Div. 1st Dep't 2011)

10

In re Village of WiUowbrook. 37 Ill.App.2d 393 (1962)

14

Kenner v. C.LR.. 387 F.3d 689 (1968)

14

Landis v. N . Am. Co.. 299 U.S. 248 (1936)

Rowe Entertainment. Inc. v. William Moms Agency. Inc.. No. 98 CV 8272, 2005 WL 22833
(S.D.N.Y. Jan. 5, 2005), aff d, 167 F. App'x 227 (2d Cir. 2005), cert, denied, 549 U.S. 887, 127
S.Ct. 283, 166 L.Ed.2d 152 (2006)
3, 9, 14
The People of the State of Illinois v. Fred E. Sterling. 357 111. 354; 192 N.E. 229 (1934)

14

Constitutional Provisions:
5th Amendment of U.S. Constitution

5, 9, 15, 18

7th Amendment of U.S. Constitution

16

14th Amendment of U.S. Constitution

5, 9, 15, 18

Statutes:
Civil Rights Act of 1866, 42 U.S.C. 1981

Civil Rights Act o f 1964, 42 U.S.C. 2000e et seq

Deprivation o f Rights, 42 U.S.C. 1983

2, 3, 16
2

ii

Donnelly Act, General Business Law 340 et seq.,

Federal Arbitration Act o f 1925, 9 U.S.C. 1 et seq

16

K u K l u x Klan Act o f 1871,42 U.S.C. 1985(3)

New York City Human Rights Law, New York Administrative Code 8-101 et. seq

New York State Human Rights Law, New York Executive Law 290 et. seq

Obstruction of Justice, 18 U.S.C. 1503

9, 15

Sherman Antitrust Act, 15 U.S.C. 1 et seq

Law Articles:
Leslie W. Abramson. The Judge's Ethical Duty to Report Misconduct by Other Judges and
Lawyers and its Effect on Judicial Independence. Hofstra Law Review: Vol. 25: Iss. 3, Article 4.
(1997)
8
Joseph J. Anclien. Broader Is Better: The Inherent Powers of Federal Courts. 64 N Y U Annual
Survey of American Law 37, 47 (2008)
7-8
Thomas E. Baker. The Inherent Power To Impose Sanctions: How A Federal Judge Is Like A
800-Pound Gorilla, 14 Rev. Litig. 195 (1994)

Stephen Cillers. Lowering The Bar: How Lawyer Discipline In New York Fails To Protect The
Public. New York University Journal of Legislation and Public Policy, Vol. 17, No. 2, (2014) ..8,
10-12
Jules Lobel and Barbara Wolvovitz. The Enforcement of Civil Rights Statutes: The Reagan
Administration's Record. 9 Black L. J. 252 (1986)

12

Judith A. McMorrow. The (F)utility of Rules: Regulating Attorney Conduct In Federal Court
Practice. 58 SMU Law Review 3, 20 (2005)
8, 10
Judith A, McMorrow. Rule 11 and Federalizing Lawyer Ethics. Brigham Young University Law
Review. (1991)
8
Daniel J. Meador, Inherent Judicial Authority in the Conduct of Civil Litigation, 11) Tex. L. Rev.
1805, 1805 (1995)
7-8

iii

Joe L. Selig. The Reagan Justice Department and Civil Rights: Wltat Went Wrong? 1985 U. 111.
L. Rev. 785 (1985)
12
Analysis: Federal Law of Attorney Conduct. "Structure of Federal Rules Governing Attorney
Conduct." Moore's Federal Practice - Civil. (2015)

Additional Secondary Sources:

Dr. Yosef A.A. ben-Jochannan, African Ongms of the Major 'Western Religions' (1970)

17

Elisabeth Bumiller. "Bush Vows To Seek Conservative Judges." New York Times. March 29,
2002
11
Tom Burrell, Brainwashed: Challenging the Myths of Black Inferiority (2010)

17

Andrew Desiderio. "Clinton: Institutional Racism Still Flourishes in U.S." Real Clear PoUtics.
June 24, 2015
17
Cheikh Anta Diop, The African Origin Of Civilization: Myth or Reality (1957)

17

Lisa Michalle Ellman, David Schkade and Cass R. Sustein. "Ideological Voting on Federal
Courts of Appeals: A Preliminary Investigation," University of Chicago. September 2003

12

Will Evans. "Money Trails To The Federal Bench." Center for Investigative Reporting. October
31,2006
12
Jack Gratus, The Great White Lie: Slavery, Emancipation and Changing Racial Altitudes
(1973)

17

A.L. Higgmbotham, "The Case of the Missing Black Judges." New York Times. July 29, 1992 .12
John G. Jackson, Introduction to Aftican Civilization (1970)

18

David Lauter, "Civil Rights Bill Vetoed By Bush." Los Angeles Times. October 23, 1990

12

LLbLibra, "Corruption In Our Federal Courts." CNN December 20, 2011

Ira Katznelson, When Affirmative Action Was WJiite (2005)

18

Michael J. Klarman, Unfinished Business: Racial Equity in American History (2007)

18

Mary Alice Miller, "Ahon Maddox at Hearing on Lawyer Accountability Calls Secret Lawyer
Discipline a Violation of the 14th Amendment." Our Time Press. August 13, 2015
11
iv

T. Owens Moore, Ph.D., The Science of Melanin: Dispelling the Myths. (1995)

18

J.A. Rogers, Nature Knows No Color-Line (1952)

18

J. A Rogers, Sex & Race Vol. 1 (1952)

18

Charlie Savage, "Appeals Courts Pushed By Right By Bush Choices." New York Times. October
28, 2008
11
R. A. Schwaller de Lubicz. Sacred Science. (1961)

18

Ivan Van Sertima, They Came Before Columbus: The African Presence in Ancient America.
(1976)

18

Marisa Warren, "Do The Right Thing: Policing the Profession and the Attorney's Duty to Report
Misconduct." American Bar Association. March 19-23, 2013
8
Dr. Frances Cress Welsmg, The Isis (YSSIS) Papers: The Keys lo the Colors (1991)

Carter G. Woodson, The Mis-Education of the Negro (1933)

18

Malcolm X, The Autobiography of Malcolm X (1964)

18

"Profiles In Military Service Colonel Cynthia J. Rapp, USA." Reveille. Vol. XIV, No. 3. Winter
2014
13
"Sanders Vows To 'End Institutional Racism' After Black Lives Matter Pushes Him Offstage."
Associated Press. August 8, 2015
17

"White supremacy is antithetical to justice. You cannot have white supremacy and have justice at
the same time." - Dr. Frances Cress Welsing'
Introduction
I -pro se petitioner Marcus Isaiah Washington - submit the following Application to Justice Ruth
Bader Ginsburg to Stay Extension of Time To File Petition For A Writ of Certiorari Pending The
Petitioner's July 18, 2015 Motion to Disqualify Loeb & Loeb LLP, Michael P. Zweig, Christian
Carbone and Others For "Fraud Upon the Court" By A l l Justices On the Supreme Court, Or in the
Alternative, Application To Exceed Word Limits Pursuant to Supreme Court Rule 33(l)(d). For
the following reasons discussed below, ask that Justice Ruth Bader Ginsburg and/or all Justices on
the bench grant the extraordinary relief requested.'^
L

Procedural History of Washington Before The Supreme Court

On December 22, 2010,1 filed a detailed 80-page Complamt against the oldest talent agency in
Hollywood with the Southern District of New York. In the Complaint, I alleged that my former
employer William Morris Endeavor Entertainment LLC (formerly known as the William Morris
Agency) was intentionally engaging in a pattern and practice of discriminating against African
Americans spanning 112 years, maintaming employment practices, policies and procedures that
created a glaring disparate impact against qualified African Americans from being hired and/or
promoted to higher-status, higher-paying positions such as Agent and Agent Trainee, pre and-post

^ In the book. The Isis (YSSIS) Papers: The Keys to the Colors {\99\), general and child psychiatrist Dr. Frances Cress
Welsing provides a "functional definition of racism" and describes "global white supremacy" as:
"the local and global power system structured and maintained by persons who classify themselves as
white, whether consciously or subconsciously determined; this system consists of patterns of perception,
logic, symbol formation, thought, speech, action and emotion response, as conducted simultaneously in all
areas of people activity (economics, education, entertainment, labor, law, politics, religion, sex and war).
The ultimate purpose of the system is to prevent white genetic annihilation on Earth - a planet in which
the overwhelming majority of people are classified as non-white (black, brown, red and yellow) by
whiteskinned people. .All of the non-white people are genetically dominant (in terms of skin coloration)
compared to the genetically recessive white-skinned people " (emphasis added)
^ There is a possibility that this Motion will reach you just short of under 15 days. The reason is because I ran out of
ink and had to wait until Office Depot delivered a new cartridge to my apartment on August 9, 2015.

hiring individual disparate treatment, retaliation and aiding & abetting claims against HR
personnel Jeff Meade and Sarah Winiarski (now known as Sarah Van Hoven) 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-17 ("Title VH"), the New York
State Human Rights Law, New York Executive Law 290 et. seq. (the "NYSHRL") and the New
York City Human Rights Law, New York Administrative Code 8-101 et. seq. (the
"NYCHRL").^
Throughout the entirety of this case, the "dishonorable," Republican appointed federal
judge P. Kevin Castel has intentionally violated his Oath of Office, numerous Canons under the
Judicial Code of Conduct, the U.S. Constitution and 42 U.S.C. 1983 in order to deprive me of
my constitutional and statutory rights under the color of law. After flouting our nation's
antidiscrimination laws and refusing to acknowledge my clauns of disparate impact and systemic
disparate treatment, as well as the pyramid of evidence in support thereof, he issued a Stay Order
compelling this landmark human nghts case into arbitration on July 20, 2011 and issued his Final
Order on September 5, 2015. In both decisions, he "omitted pertinent facts and misapplied the
law" in order to prevent an impartial jury from deciding the merits of my claims.
In Castel's Final Order, he confirmed the fraudulently procured June 25,2014 Final Award
of Schnader LLP attorney Timothy K. Lewis that dismissed my case "with prejudice and on the
merits" and confirmed Lewis' judgment that awarded William Morris $43,707.60 for "fees and
costs." To put the nail in the coffin, Castel revoked my in forma pauperis status although my
economic circumstances have only worsened since filing my Complaint with the Southern District

^ 1 formally added claims of antitrust violations under the Sherman Antitrust Act, 15 U.S.C. 1 el seq. and Donnelly
Act, General Business Law 340 etseq., as well as claims of conspiracy to interfere with the human rights of African
Americans in violation of the Ku Klux Klan Act of 1871, 42 U.S.C. 1985(3) when I submitted my Demand for
Arbitration with the American Arbitration Association on June 15, 2012.

of New York in December of 2010 and prejudiced my appeal by stating that it would not be made
in "good faith." He additionally granted William Morris and Loeb & Loeb's July 10, 2014 Motion
for a Filing Injunction which prevents me from taking future legal action in a separate case against
all parties that have committed fraud in order to allow William Morris and other companies
maintaining racially segregated workforces 51 years after the passage of the Civil Rights Act of
1964 the ability to continue violating our nation's antidiscrimination and antitrust laws. On March
11, 2015, Second Circuit appellate judges Dennis Jacobs and Raymond J. Lohier, Jr. and Southern
District of New York district judge Laura Taylor Swain denied my appeal in two sentences,
concluding that it "lack[ed] an arguable basis in either law or in fact."*
Since learning in January of 2011 of Loeb & Loeb LLP's involvement in a conspiracy to
engage in and commit "fraud upon the Court" in a prior racial discrimination case - Rowe
Entertainment Inc. v. William Morris Agency, Inc., No. 98 CV 8272, 2005 WL 22833 (S.D.N. Y.
Jan. 5, 2005), aff d, 167 F. App'x 227 (2d Cir. 2005), cert, denied, 549 U.S. 887, 127 S.Ct. 283,
166 L.Ed.2d 152 (2006)^ - as well as lead attorney Michael P. Zweig's continuation to commit
"fraud upon the Court" in this case, I've filed numerous motions with the lower courts detailing.
Although Castel and the Second Circuit have also ignored these claims, it is clear based on the
"clear and convincing evidence" that has been presented that Loeb & Loeb LLP should have not
been allowed to represent William Morris in this litigation and should have been severely
sanctioned for their highly unethical and criminal conduct by the lower courts. Instead, it has been
concluded by the lower courts that I am the party that has engaged in "bad faith."

" On March 25, 2015,1 filed a Motion for Reconsideration and on June 11, 2015, I filed a Motion to Recall & Stay
the Mandate. Both were denied without the issuance of an ethical judicial opinion.
' LLbLibra. "Corruption In Our Federal Courts." CNN. December 20, 2011. http://ireport.cnn.com/docs/DOC724105.

Although I spent the first sixty days drafting a petition for a writ of certiorari, I submitted
two Motions on July 18, 2015 with the Supreme Court seeking extraordinary relief to correct the
miscarriage of justice that has taken place throughout this nearly five year litigation. The first
pleading was a 40 page Motion to Disqualify Loeb & Loeb LLP Due To "Fraud Upon the Court"
pursuant to Supreme Court Rules 8 and 21 and the second pleading was a 40 page Motion to
Proceed In Forma Pauperis & Application For Extension To Submit Petition For Writ of Certiorari
pursuant to Supreme Court Rules 13(5)^ and 39.
I presented the same legal arguments in my Motion to Proceed In Forma Pauperis that were
raised in the lower courts, explaining why all of P. Kevin Castel's decisions were erroneous as a
matter of law and public policy, and submitted an Affidavit demonstrating my indigent status.
Since a granting of Motion to Disqualify Loeb & Loeb LLP by the Supreme Court would "dispose
of the entire case [and] would affect the final judgment to be entered" pursuant to Supreme Court
Rule 21(2)(b), 1 asked for an extension to submit the petition as a way to cover all bases since there
was a strong likelihood that the Supreme Court would show deference to Castel and the Second
Circuit's erroneous decisions, provide Loeb & Loeb LLP with the presumption that they were
being honest and ethical and deny my claims without providing an ethical judicial opinion.
On July 24, 2015, Zweig submitted a letter addressed to you echoing statements made in
the lower courts: my claims were "frivolous," that 1 had engaged in a well-documented history of
"bad-faith conduct," and that my "application should be denied because among other reasons, [1]
fail[ed] to demonstrate an entitlement to the relief sought or establish why [1] need[ed] additional

Supreme Court Rule 13(5) states: "For good cause, a Justice may extend the time to file a petition for a writ of
certiorari for a period not extending 60 days. An application to extend the time to file shall set out the basis for
jurisdiction in this Court, identify the judgment sought to be reviewed, include a copy of the opinion and any order
respecting rehearing, and set out specific reasons why an extension of time is justified." (emphasis added) I
requested an extension to submit the petition because the lower courts repeatedly refused to acknowledge or resolve
my claims of "fraud upon the Court" and never compelled Loeb & Loeb LLP to provide a response.

time to file [my] petition for a writ of certiorari with this Court." During this time, I constantly
reviewed the Supreme Court's docket for this case, but I noticed that there was no indication that
I submitted a Motion to Proceed In Forma Pauperis or the Motion to Disqualify Loeb & Loeb LLP.
The only thing listed was that I submitted an Application for an Extension.
On August 1, 2015,1 received a letter from the Clerk of Court, Scott S. Harris^ dated July
29, 2015, stating that Justice Ginsburg granted me an extension, allowing me until September 28,
2015 to submit a petition for a writ of certiorari. In addition to the letter signed by Case Analyst
Erik Fossum, the original and a copy of the Motion to Disqualify Loeb & Loeb LLP were returned
to me.
The next day, I spoke with Erik Fossum and after numerous conversations with him and
others employed by the Supreme Court,^ I resubmitted the two Motions to Disqualify Loeb & Loeb
LLP that were returned to me and submitted a 12-page letter to you on August 8, 2015, explaining
why the Clerk of Court's refusal to accept this Motion violated my constitutional right to due
process and equal protection under the law. See Exhibit A. On August 18, 2015 - seven days after
I received confirmation that my package was delivered to the Supreme Court - Fossum informed
me that my package was located. When I asked him when my docket would be updated to reflect
the pleadings that were submitted, he informed me that that would be handled by Cynthia Rapp. I
called Rapp numerous times after speaking with Fossum and she refused to return my calls.

^ According to a press release issued by the Supreme Court on July 1, 2013, Scott S. Harris, Legal Counsel at the
Supreme Court of the United States, was named the Court's new Clerk, effective September 1, 2013. "Harris has
served as the Supreme Court's Legal Counsel for 11 years. In that role, he has managed the Court's Legal Office,
which provides support to the Justices on a variety of case-related issues and legal services for the Court as an
institution. In announcing the appointment, Chief Justice Roberts stated, 'Scott brings pertinent experience and proven
judgment to his new position. I am confident that he will continue the tradition established by our past Clerks o f
professionalism
and
dedicated
service
to
the
Bench
and
Bar.'"
http://www.supremecourt.gov/publicinfo/press/pressreleases/pr_07-01-13.
* Each individual I spoke to was white. During these conversations, I also learned that the other 9 copies of the Motion
to Disqualify Loeb & Loeb LLP were trashed and I was told that I only had to submit three copies which is false since
my Motion to Disqualify Loeb & Loeb LLP was not submitted under Supreme Court Rule 22.

The next day, my letter and the Motion to Disqualify that 1 resubmitted were returned to
me. In a letter dated August 17, 2015, Rapp stated:
The practice of this Court is to rely on the state investigative authorities with respect to alleged
attorney misconduct. Pursuant to Rule 8 of the Supreme Court Rules this Court will take action
when a member of the Bar of this Court has been disbarred or suspended from practice or when
a finding that the member has engaged in conduct unbecoming a member of the Bar has been
made. You might consider contacting the state bar of the state in which the individual is
licensed to see what their complaint procedure is.
See Exhibit B. In an e-mail dated August 18, 2015, Rapp also stated that "this Court does not
entertain motions to disbar attorneys based on individual requests, we act only upon written
notification from a state that an attorney has been disciplined." (emphasis added)
On August 24, 2015, 1 submitted a follow up e-mail to Cynthia Rapp and Jeff Atkins,
requesting that the eleven copies of my Motion to Proceed In Fonna Pauperis be returned to me
since it was never reflected on the docket that this pleading had been submitted to the Court. This
e-mail was also forwarded to all of the Justices on the Supreme Court, including you. See Exhibit
C. To date, 1 have not received a response from Rapp, the Clerk of Court, its staff or any of the
Justices. To date, the docket for this case only reflects that the only document that 1 have submitted
is an Application For An Extension of Time.
n.

Five Reasons Why the Clerk of Court and Cynthia Rapp Have Obstructed Justice
By Refusing to Accept My Motion to Disqualify Loeb & Loeb L L P .

Although Supreme Court Rule 1 states that the Clerk of Court "has the authority to reject any
submitted filing that does not comply with these Rules," there are a number of reasons why my
Motion

to

Disqualify

Loeb

&

Loeb

LLP

should

have

been

accepted

by

the

Clerk of Court and resolved by the Justices who have been appointed to life terms on the bench.
First and foremost, a petition for a writ of certioran is not the only pleading that can be
filed to vacate the decisions of the lower courts. While Supreme Court Rules 10 through 16 deal

specifically with petitions for a writ of certiorari. Supreme Court Rule 21 deals specifically with
"Motions" and states in Supreme Court Rule 21(2)(b) that a party can submit "any motion the
granting of which would dispose of the entire case or would affect the final judgment to be
entered." Since federal and state courts whitewashed my complaints and refused to acknowledge
the pyramid of evidence proving that Zweig, Carbone and others knowingly "engaged in illegal
conduct that adversely reflects on the lawyer's honesty, trustworthiness or fitness as a lawyer;"
"engaged in conduct involving dishonesty, fraud, deceit or misrepresentation," "engaged in
conduct that is prejudicial to the administration of justice," "knowingly assist[ed] a judge or
judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law;"
and/or "engage[d] in any other conduct that adversely reflect[ed] on the lawyer's fitness as a
lawyer" - violations of New York Rules of Professional Conduct Rule 8.4 (b), (c), (d), (f) and (h)
~ the Supreme Court had to resolve this issue first, or else they would never be able to impartially
resolve the legal arguments raised in my petition for a writ of certiorari.
Secondly, federal courts are invested with an "inherent power" "to control and direct the
conduct of... litigation without any express authorization in a constitution, statute, or written rule
of court."^ Inherent powers cases reflect a justice's "suppleness of adaptation to varying
conditions." Landis v. N. Am. Co.. 299 U.S. 248, 256 (1936). "One of the most common and
important roles of inherent powers is to allow courts to craft flexible sticks to sanction
contumacious parties."' "Manifestly, inherent powers are not some esoteric, antiquated doctrine
valuable only to mavens of federal procedure. Rather, inherent powers are a flexible tool that

' Daniel J. Meador, Inherent Judicial Authority in the Conduct of Civil Liligalion, 73 TEX. L. REV. 1805, 1805
(1995).
Joseph J. Anclien. Broader Is Better: The Inherent Powers of Federal Courts. 64 N Y U Annual Survey of American
Law 37, 47. 2008.

enables courts to respond to the changing realities of litigation without requiring a prolix code of
procedure.""
In Chambers v. Nasco. 501 U.S. 32 (1991), the Supreme Court "reinforced the wellestablished idea that a court has the power to control admissions to the bar and to discipline
attorneys who appear before it"'^ and the case "serves as the exclamation point for the idea that
the federal court is in control."'^ "Fraud upon the Court" is "a well-established body of law
founded on inherent powers that permits courts to set aside judgments that were procured by
fraud."'"^ It "serves the salutary purposes of protecting courts from becoming saddled with i l l gotten judgments, acting as a stick to punish parties who defraud the courts, and furthering general
notions of fair play."'^
Third, I have read a number of additional law articles on this issue and they all support that
either Rule 8 or the Court's "inherent powers," the Supreme Court can disbar attorneys for
engaging in conduct "unbecoming a member of the bar."'^ One of the first articles I read after
being told by Rapp that the Supreme Court "act[s] only upon written notification from a state that
an attorney has been disciplined" was a law article titled "Structure of Federal Rules Governing

" Id. at 49.

Judith A. McMorrow. The (F)utiiity of Rules: Regulating Attorney Conduct In Federal Court Practice. 58 SMU
Law Review 3, 20. 2005
" I d . at2T
Anclien, supra note 10 at 4L
''Id.
Over the last 13 days, the various law articles that I have read to help me develop the legal arguments raised in this
pleading include: Analysis: Federal Law of Attorney Conduct. "Structure of Federal Rules Governing Attorney
Conduct." Moore's Federal Practice - Civil. (2015); Stephen Gillers. Lowering The Bar: How Lawyer Discipline In
New York Fails To Protect The Public. New York University Journal of Legislation and Public Policy, Vol 17, No.
2, (2014); Marisa Warren. "Do The Right Thing: Policing the Profession and the Attorney's Duty to Report
Misconduct." American Bar Association. March 19-23, 2013; Thomas E. Baker. The Inherent Power To Impose
Sanctions: How A Federal Judge Is Like A 800-Pound Gorilla, 14 Rev. Litig. 195 (1994); McMorrow, supra note 12;
Judith A. McMorrow. Rule 11 and Federalizing Lawyer Ethics. Brigham Young University Law Review. (1991);
Leslie W. Abramson. The Judge's Ethical Duty to Report Misconduct by Other Judges and Lawyers and its Effect on
Judicial Independence. Hofstra Law Review: Vol. 25: Iss. 3, Article 4. (1997), Meador, supra note 9; Anclien, supra
note 10.

Attorney Conduct in Supreme Court." 804.04 is titled "Supreme Court, On Rare Occasion,
Directly Disbars Attorneys Using 'Conduct Unbecoming' Standard of Rule 8," See Exhibit D,
and this article, as well as all others that 1 have read, support that the Supreme Court can take
action against attorneys who have engaged in "conduct unbecoming a member of the Bar" and that
the Clerk of Court and Rapp's refusal to accept my motion constituted an obstruction of justice in
violation of 18 U.S.C. 1503, as well as a violation of my constitutional rights to due process and
equal protection under the law. Even though this type of pleading is not typically filed with the
Court, the circumstances in which this motion was submitted are unique and it is clear that under
the Supreme Court's "inherent powers," the Court can accept and has the authority to resolve this
issue since the lower courts refused to.
Fourth, Leonard Rowe and 1 filed a joint complaint with the Departmental Disciplinary
Committee, First Department on July 19, 2012 against nine of the attorneys that were engaged in
the on-going conspiracy to conceal "Exhibit 31" and the hundreds of underlying e-mails to this
document in Rowe.'^ Because one of the attorneys complained of - Dentons LLP attorney Martin
R. Gold - serves as "Special Counsel" to the DDC, his complaint was transferred to the 10^''
Department after our complaint was initially dismissed without an investigation or compelling the
attorneys complained of to respond to our claims.

In their letter refusing to take any disciplinary

action against Gold, they stated:

According to the matenal submitted with your July 2012 complaint, you are pursuing you legal
remedies in a federal proceeding pending in the United States District Court, Southern District
''' After learning of Christian Carbone's marriage to AAA executive Sasha Angelique Carbone and his failure to
disclose this information to myself and the Court, I also filed an individual complaint against him with the DDC on
November 13, 2014. I received no response from the DDC and on August 21, 2015, I was told the compliant was
never received. On the same day, I resubmitted the complaint. All of the complaints [including complaints filed with
the federal and state Attorney Generals] and additional correspondence with the DDC can be viewed here:
https://meagainstiniquity.wordpress.com/e-complaints-to-ddc-attorney-general-etc/.
The four perjurious Declarations of Rowe's former Sonnenschein Nath & Rosenthal LLP attorneys (now known as
Dentons LLP) that were submitted in response to Rowe's March 2012 Fed. R. Civ. P. 60 Motion on May 14-15, 2012
were included with our complaint.

of New York, and as the practice of the Committee is to refrain from investigating complaints
which are being addressed in a legal proceedmg, the Committee is unable to be of assistance
at this time.
While Rapp is saying the power to discipline attorneys is vested with the state court, the
state court is saying the power is vested with the federal court. Basically, both courts have been
stringing us along.'''' "States are one important actor in the law governing lawyers. They are not
the only actor, however. In federal litigation, the federal courts inevitably will be the dominant
actor in determining the norms, the remedy and the role that federal courts are willing to assume
in the mosaic of attorney regulation.
I f the "dominant goals of lawyer discipline are protecting the public and the administration
of justice and promoting the public's confidence in the legal system," as well as "specific and general
deterrence," then the fact is, both courts have the power to resolve these issues and should have
done so. What's appalling is that the First Department stated in In re Roisman, 931 N.Y.S.2d 571,
575 (App. Div. 1st Dep't 2011) that an attorney's "failure to comply with the law's basic obligation
to file tax returns is a serious offense warranting public discipline," but saw nothing wrong with
the fact that the attorneys complained of defrauded the class of black concert promoters out of
$200,000.00, conspired to conceal smoking gun evidence and submitted perjurious Declarations.
Since neither the DDC nor any federal court conducted an investigation or compelled the attorneys
complained of to submit a response before dismissing our legitimate complaints, the "Highest
Court in the Land" must nowresolve this issue.^' I f not, Castel's filing injunction should be vacated

Gillers, supra note 16 at 494.

McMorrow, supra note 12 at 49.
^' It's important to note that the DDC's decisions were made before Arbitrator David L. Gregory admitted "Exhibit
31" into the "evidence of record" in my case. This is after I presented a pyramid of evidence showing that despite
federal judge Robert P. Patterson's conclusions that Leonard Rowe's claims were full of "hot air and paranoid
suspicions," this document was authentic and that Rowe's claims were in fact true. We never informed the DDC of
this evidentiary decision because Loeb & Loeb LLP colluded with the A A A to have Arbitrator Gregory disqualified
after issuing his December 17, 2013 Partial Final Award which concluded that "William Morris Endeavor
Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local laws prohibiting

10

by the "court of last resort" and 1 should be allowed to pursue claims of "fraud upon the Court"
and additional causes of action in a separate case against Loeb & Loeb LLP, Zweig, Carbone and
their co-conspirators.
As one can see, racism and corruption are vertically integrated throughout America's
judiciary. The DDC is an embarrassment and should not have the sole authority over deciding
whether an attorney should be disciplined for engaging in unethical conduct since New York lacks
a statewide disciplinary authority." The DDC's mishandling of our complaint is not isolated- it's
part of their "standard operating procedure" to whitewash legitimate complaints against "elite"
lawyers. Thus, it should not be surprising that the DDC has been described by many in the legal
community, including Elena Sassower [Director of the Center for Judicial Accountability, Inc.],
as a "sham."-^ On August 11, 2015, a public hearing was held in New York City where Sassower
and other individuals discussed their experiences trying to get their complaints investigated by the
DDC. 1 am including an article summarizing the testimony of Alton Maddox, a prominent African
American civil rights attorney who was unjustly disbarred for 25 years.^"* See Exhibit E . Our
racially segregated injudicial system is in need of serious reform,-^ especially the disciplinary

discrimination on the basis of race" and indicated that 1 would be awarded the fijll gamut of monetary damages,
including punitive damages and pro-se non attorney's fees. Castel and the Second Circuit's decisions make no mention
of "Exhibit 31" or Arbitrator Gregory's decision which prevents Loeb & Loeb LLP from continuing to make deceptive
and misleading statements about what happened during e-discovery in Rowe under the doctrine of collateral estoppel.
Gillers, supra note 16 at 496.
To see the evidence in support of Sassower's claims, visit http://www.iudgewatch.org/web-pages/searchingnys/2015-commission-on-attomey-discipline/public-testimony-hearings/ers-testimonv.htm.
Sassower's August 11,
2015 testimony can be viewed here: https://www.youtube.com/watch?v=lQV2woYeZ90.
Mary Alice Miller. "Alton Maddox at Hearing on Lawyer Accountability Calls Secret Lawyer Discipline a Violation
of the 14th Amendment." Our Time Press. August 13, 2015. http://ourtimepress.com/?p= 16886. ("So many things
that we have talked about in the Black community seem to transcend the Black community. There are people
throughout this state who are adversely affected despite their background or their color or class. Judicial
gerrymandering and apartheid justice doesn't only relate to Black people. It obviously relates to everybody".)
Maddox's August I I , 2015 testimony can be viewed here: https://wwv,^youtube.com/watch?v=Bm6n7nV3aFs.
See e.g., Elisabeth Bumiller. "Bush Vows To Seek Conservative Judges." New York Times. March 29, 2002.
http://www.nytimes.com/2002/03/29/us/bush-vows-to-seek-conservative-judges.html.
(On March 27, 2002, George
W. Bush stated to a crowd of more than 1,000 at the Hyatt Regency Hotel: "We've got to get good, conservative
judges appointed to the bench and approved by the United States Senate."); Charlie Savage. "Appeals Courts Pushed
By
Right
By
Bush
Choices."
New
York
Times.
October
28,
2008.

11

agencies in New York that are responsible for handling attorney misconduct.

I f the Supreme

Court will not uphold its own laws, then Rowe, myself and others will bnng these cases before
international organizations concerned with human rights issues such as the United Nations.
And last but not least, I want to ask three questions. I f disciplinary action for attorney
misconduct can "only" be taken by the state court, then why do S.D.N. Y. Local Rule 1.5,^^ Fed.
R. Civ. P. 11 & 60, Fed. R. App. P. 46(b) and Supreme Court Rule 8 exist? Why doesn't Supreme

http://www.nytimes.eom/2008/l0/29/us/29judges.html?pagewanted=all (Bush '"packed the courts' with 'extremists'

who share an agenda of hostility to regulations the rights of women, minorities and workers."); Joe L. Selig. The
Reagan Justice Department and Civil Rights: What Went Wrong? 1985 U. III. L. Rev. 785 (1985); Jules Lobel and
Barbara Wolvovitz. The Enforcement of Civil Rights Statutes: The Reagan Administration's Record. 9 Black L. J.
252 (1986); Neil A. Lewis. "The 1992 Campaign; Selection of Conservative Judges Insures a President's Legacy."
New York Times. July 1, 1992.
http://v>ww^n>'times.com/1992/07/01/us/the-1992-campaign-selection-ofconservative-iudges-insures-a-president-s-legacy.html; A. Leon Higginbotham. "The Case of the Missing Black
Judges." New York Times. July 29, 1992. http://www.nytimes.com/1992/07/29/opinion/the-case-of-the-missingblackiudges.html?pagewanted=all&src='pm: Will Evans. "Money Trails To The Federal Bench." Center for
Investigative Reporting. October 31, 2006. (discussing results from a four-month investigation of Bush-appointed
judges which revealed that six appellate court judges and 18 district court judges, including district judge P. Kevin
Castel, contributed a total of more than $44,000 to politicians who were influential in their appointments. Judge Castel
contributed $2,000 to Bush after he was nominated in March 2003. These political contributions further raises ethical
concerns about Castel's impartiality.); Lisa Michalle Ellman, David Schkade and Cass R. Sustein. "Ideological Voting
on Federal Courts of Appeals: A Preliminary Investigation," University of Chicago. September 2003. (examination
of more than 4,480 legal opinions, involving politically divisive issues indicated that there's a relationship between a
judge's political ideology and their judicial opinions since they overwhelmingly decide cases according to the
philosophical position of the party that appointed them.); David Lauter. "Civil Rights Bill Vetoed By Bush." Los
Angeles Times. October 23, 1990. http://articles.latimes.com/1990-10-23/news/mn-2961_l_civil-rights-leaders.
("The measure's supporters accuse the President of playing to white consen-'atives")
Gillers, supra note 16 at 503-504.
...New York lacks even an approximation of consistency. A lawyer's sanction will depend on the location of his
or her office.
All New York lawyers are governed by the same Rules of Professional Conduct. And the First and Second
Departments define "professional misconduct" in substantively identical language. But disciplinary cases and
sanctions are adjudicated separately in the four appellate divisions. No wonder then that reading hundreds of
disciplinary opinions from the four appellate divisions reveals stark differences in the seriousness with which
these courts regard the same misconduct, at least when measured by the sanctions they impose. The courts are
closed universes whose opinions rarely i f ever cite, let alone conform to, the sanctions imposed in the other
departments. Opinions outside the First Department often do not even bother to harmonize a sanction with those
in the same court's own precedent.
In section b titled "Grounds for Discipline or Other Relief" it states that "Discipline or other relief, of other types
set forth in paragraph (c) below, may be imposed, by the Committee on Grievances, after notice and opportunity to
respond as set forth in paragraph (d) below, if any of the following grounds if...": (2) "Any member of the bar of this
Court has been disciplined by any federal court or by a court of any state or territory" or (5) 'Tn connection with
activities in this Court, any attorney is found to have engaged in conduct violative of the New York State Rules of
Professional Conduct..." (emphasis added) See Exhibit F .

12

Court Rule 8 contain any language mirroring the statements Rapp made to me? Also, why does
the Southern District of New York have a Grievance Committee which is supposed to handle
complaints of attorney misconduct if only the state can decide that issue?^^ For more reasons than
one, things are just not adding up.
In conclusion, my Motion to Disqualify Loeb & Loeb LLP should have been accepted by
the Clerk of Court and resolved by the Justices on the Supreme Court. Rapp and her colleagues
have overstepped their authority and Rapp knew that she was lying to me when she stated that the
Supreme Court "only" acts "upon written notification from a state that an attorney has been
disciplined." because part of her job duty includes handling "the Supreme Court bar suspensions
and disbarments."-^ Since the Clerk cannot decide whether or not an attorney has engaged in
"conduct unbecoming a member of the Bar," Rapp nor any other individual working for the
Supreme Court had the authority to prevent the Justices from deciding this issue.
Although the names of my pleadings have changed over time, the legal arguments raised
have remained the same and whether you read the pleadings or not, you granted me an extension
which requires a showing of "good cause"' and is rarely granted by the Court. Thus, you cannot
personally believe that all of my pleadings "Iack[ed] an arguable basis in either law or in fact" and
you and your colleagues should have resolved my Motion to Disqualify. Pursuant to Supreme
Court Rule 8, an order should have been entered suspending Loeb & Loeb LLP and its attorneys
and they should have been given 40 days to show cause as to "why a disbarment order should not
[have been] entered" against them. Since this did not happen and they have continued to engage

P. Kevin Castel currently presides over this Committee, further evidence that this committee is also a "sham."
2^ "Profiles In Military Service Colonel Cynthia J. Rapp, USA." Reveille. Vol. X I V , No. 3. Winter
2014.
http://www.americanbar.orgL/content/dam/aba/publications/reveille/Reveille_Winterl4.authcheckdam.pdf
("Cynthia J. Rapp is currently a Deputy Clerk with the Supreme Court of the United States. As deputy her
responsibilities include managing the Court's Original Case Docket and preparing the Court's Orders List, Journal
and statistics. She also handles the Supreme Court bar suspensions and disbarments.") (emphasis added)

13

in fraud by deny all wrongdoing in their July 24, 2015 letter, extreme disciplinary and monetary
sanctions, including default judgment, disbannent and imprisonment, should be imposed against
Loeb & Loeb LLP and their miscreant attorneys for engaging in a "pattern" of "fraud upon the
Court" and highly unethical and cnminal activity on William Morris' behalf in this case, as well
as in Rowe.''"
in.

Prayers For Relief

Zweig, like his client William Morris, has refused to admit that he has done anything legally,
morally or ethically wrong and he is not remorseful for what he has done. In true psychopathic
fashion, he believes that he is the victim. My claims of "fraud upon the Court," as well as
intentional violations of numerous rules under the New York Rules of Professional Conduct and
New York Judiciary Law 487 against Loeb & Loeb LLP, Michael P. Zweig, Christian Carbone,
Michael Barnett, Jessica Lee and others have never been presented to obtain a "strategic
advantage" in this case because the law has always been on my side. Had the federal judges in the
lower courts remained independent and upheld the U.S. Constitution and prevailing law, it is clear
that no impartial finder of fact would have been able to render a decision in favor of William
Morris and Loeb & Loeb LLP.
While my livelihood has been destroyed, Loeb & Loeb LLP and its attorneys have been
unjustly enriched from their unlawful, unethical, unconscionable

acts of subterfuge

and

^ It is well established that "a decision produced by fraud upon the court is not in essence a decision at all, and never
becomes final." Kenner v. C.I.R., 387 F.3d 689 (1968); see also The People of the State of Illinois v. Fred E. Sterling.
357 111. 354; 192 N.E. 229 (1934) ("The maxim that fraud vitiates every transaction into which it enters applies to
judgments as well as to contracts and other transactions."); .Allen F. Moore v. Stanley F. Sievers. 336 111. 316; 168
N.E. 259 (1929) ("The maxim that fraud vitiates every transaction into which it enters ..."); In re Village of
Willowbrook. 37 111.App.2d 393 (1962) ("It is axiomatic that fraud vitiates everything.") As a result, the concept of
"fi"aud upon the Court" "challenges the very principle upon which our judicial system is based: finality of judgment."
Herring v. United States. 424 F.3d 384 (3rd Cir. 2005).

14

contumacious conduct.-" As a result, five years of my life have already been wasted, so the last
thing 1 will do, is allow Rapp and her predommately white colleagues in the Supreme Court the
ability to K i m Davis me without any repercussions.^- They have taken it upon themselves to
obstruct justice by refusing to accept and transmit my pleadings to the Justices of this Court and
intentionally lied to me about why my motion could not be accepted. As a result, 1 am asking that
Rapp and her colleagues be ordered to pay me the costs associated with printing and submitting
this application, as well as my July 18, 2015 and August 8, 2015 pleadings since none of the
documents I submitted should have been returned to me. For the last few years, 1 have been living
below the poverty level and it cost me more than $418.36 to print and mail these documents to the
Court." I have sacrificed meals just so that I could submit these pleadings in "good faith" and 1
am spending my last $16 to submit this application to the Court. Rapp and her colleagues must be
held accountable for their unlawful and unconstitutional actions. Therefore, 1 am additionally
asking that Rapp and anyone else responsible for conspiring to obstruct justice in this case be
ordered to issue a fonnal apology and immediately be relieved of their duties since their actions
were deliberate and not the result of "human error."
Each level of the federal judiciary in some shape or fashion, has intentionally violated my
constitutional right to due process and equal protection under the law. As a result, 1 am
unnecessarily having to spend a considerable amount of time discussing ancillary issues in my

In response to my Complaint, Zweig submitted a letter to Castel stating that my claims were "without merit, legally
and factually," yet, he has enlisted more than five additional attorneys and three paralegals to "represenf William
Morris in this case. In arbitration, we spent six months in discovery. Loeb & Loeb LLP refused to produce any
documents and refused to comply with any of my good faith discovery requests. They wouldn't even tell me the date
that a litigation hold was placed on William Morris and its employees. They refused to produce these documents
because it would have fijrther proved that their arguments were pretextual.
'^ Kim Davis's attorneys did not file a petition for a writ of certiorari and although her application for a stay was
addressed to Justice Elena Kagan, the full Court decided her application. This application should be handled the same
way.
'^ Throughout the entirety of this case, I have never asked my friends for money, but after my parents stopped giving
me $400/month to live in July of 2015,1 had to in order to file these pleadings with the Supreme Court.

15

petition, when I should be entirely focused on discussing our nation's antidiscrimination laws and
the Federal Arbitration Act, explaining the numerous ways m which William Morris, as well as all
talent agencies in Hollywood, have intentionally raamtained racially discriminatory employment
practices in order to achieve a race-based monopoly over decisionmaking positions to play a
significant role in shaping our worldview and understanding of race, as well as discussing the
numerous reasons why "savy^ legal loopholes" known as mandatory, pre-dispute arbitration
agreements should not be enforced i f employers have a longstanding history of maintaining
racially segregated workforces.
I f the Supreme Court refuses to resolve my July 18, 2015 Motion to Disqualify Loeb &
Loeb LLP pursuant to Rule 8,1 ask that I be allowed an additional 3,000 words to fully explain
the numerous reasons why Loeb & Loeb LLP and its attorneys have engaged in a "pattern" of
fraud upon the Court" on William Morris' behalf, as well as explain why the various federal judges
of the lower courts have engaged in a conspiracy to interfere with the human rights of people of
African descent to keep the American people from learning the truth about who controls
Hollywood and Hollywood's role in maintaining and perpetuating the myth of white/"Jewish"
superiority throughout our society and the world. These dishonorable judges have violated the U.S.
Constitution, their Oaths of Office, as well as the Judicial Conduct in order to prevent an impartial
jury from rendering a decision that would strengthen the Civil Rights Act of 1964's ability to
combat institutionalized, systemic and structural forms of racism ~ a violation of the 7^
Amendment of the U.S. Constitution. See e.g., Blakelv v. Washington. 124 S. Ct. 2531, 2538-39
(2004) ("[T]he right of jury trial... is no mere procedural formality, but a fundamental reservation
of power in our constitutional structure. Just as suffrage ensures the people's ultimate control in

16

the legislative and executive branches, jury trial is meant to ensure their control in the judiciary.")
As a result, they must be unpeached for their "high crimes and misdemeanors."
I f the relief above is not granted, I ask that you and the Justices convert the four pleadings
submitted to the Court since July 18, 2015 into a petition for a writ of certiorari and deny it since,
it is not "mandatory" for Loeb & Loeb LLP to respond, I ' m not allowed an oral hearing due to my
pro se status and Loeb & Loeb LLP attorney Michael P. Zweig has continued to engage in fraud
by denying all wrongdoing in his July 24, 2015 letter to you.
Conclusion
White America has historically had a problem with racism and whether whites like it or not, global
white supremacy (racism) will be eradicated - sooner, rather than later. ^'^ I f all men are created
truly equal, then I - a hue-man being of African descent - will never accept myself and/or any
other person of African descent being classified as "inferior" to whites or having our potential
capped simply because of the God-given melamn our beautiful black bodies possess.It doesn't

^'^ Luckily, all of my legal arguments have been preserx'ed and there is no statute of limitations for "fraud upon the
Court," so there will come a day when I will be able to correct this gross miscarriage of justice. Presidential hopefuls
Bernie Sanders and Hillary Clinton have both discussed institutional racism on their campaign trails, so if they can
talk about it, why can't an educated black man do the same? See e.g., "Sanders Vows To 'End Institutional Racism'
After Black Lives Matter Pushes Him Offstage." Associated Press. August 8, 2015. http://www.breitbart.com/2016presidential-race/2015/08/08/sanders-vows-to-end-institutional-racism-after-black-lives-matter-pushes-himoffstage/. ("No president will fight harder to end institutional racism and reform criminal justice system...Too many
lives have been destroyed by war on drugs, by incarceration; we need to educate people. We need to put people to
work."); Andrew Desiderio. "Clinton: Institutional Racism Still Flourishes in U.S." Real Clear Politics. June 24, 2015.
http://www.realclearpolitics.com/articles/2015/06/24/clinton_institutional__racism_still_flourishes_in_us_127101 .ht
ml. (Hillary Clinton said Tuesday that the shooting deaths of nine Afi-ican-Americans at their church in Charleston,
S.C., last week is fijrther evidence that institutional racism still exists in the U.S. 'The truth is, equality, opportunity,
civil rights in America are still far from where they need to be[.]"...She added that schools are 'more segregated
[today] than they were in the 1960s.'.. . ' I know it's tempting to dismiss this tragedy as an isolated incident, to believe
in today's America that bigotry is largely behind us, that institutional racism no longer exists,' said the former secretary
of state and New York senator. 'But despite our best efforts and highest hopes, America's long struggle with race is
far from finished.')
Before this case, I knew nothing about institutional racism, global white supremacy (racism) or anything about the
history of my African ancestors pre-slavery in the Americas - even though I excelled in school and obtained a
Bachelors in Psychology & Media Management and Masters in Music Business and Entertainment Industries from
the University of Miami by age 23. See e.g., Cheikh Anta Diop, The African Origin Of Civilization: Myth or Reality
(1957); Yosef A.A. ben-Jochannan, African Origins of the Major 'Western Religions' (1970); Tom Burrell,
Brainwashed: Challenging the Myths of Black Inferiority (2010); Jack Gratus, The Great White Lie: Slavery,

17

matter whether we are in the workplace or in the courtroom, our inalienable human rights will be
respected because no man or corporation is above the law and judges are not Gods. Although many
of your racist, predominately whtte colleagues have rendered decisions over the past decades^*^ that
have eviscerated many of the gains made during the black-led civil rights movement, you are one
of the few Justices that have consistently acknowledged the realities of global white supremacy
(racism) in the United States of America. Thus, it was disingenuous of you to grant me extension
while simultaneously refusing to acknowledge the unique circumstances in which I brought my
"fraud upon the Court" claims against Loeb & Loeb LLP and its attorneys to the attention of the
Supreme Court.
Without an independent & impartial judiciary and procedural due process, substantive
justice is merely an illusion. Since all levels of the judiciary have intentionally deprived me of my
constitutional rights to due process and equal protection under the law, there is absolutely no point
for me to continue abiding by the procedural rules i f those who have taken oaths to uphold the
U.S. Constitution and the law refuse to impartially administer justice in this case. My money has
been wasted and depleted, and my case has been hamifully delayed due to colossal levels of "fraud
upon the Court" and "fraud upon the Court by the Court." As a result, I respectfully ask that you
and all Justices on the Supreme Court use your "inherent powers" to correct this extreme
miscarriage of justice and grant the extraordinary relief requested in this application.

Emancipation and Changing Racial Attitudes (1973); Michael J. Klarman, Unfinished Business: Racial Equity in
American History (2007); Ira Katznelson, When Affirmative Action Was White (2005); J.A. Rogers, Nature Knows
No Color-Line (1952); Rogers, Sex & Race Vol. 1 (1952); Carter G. Woodson, The Mis-Education of the Negro
(1933); Malcolm X, The Autobiography of Malcolm X (1964); John G. Jackson, Introduction to African Civilization,
(1970); Ivan Van Sertima, They Came Before Columbus: The African Presence in Ancient America. (1976); T. Owens
Moore, Ph.D., The Science of Melanin: Dispelling the Myths. (1995); R. A. Schwaller de Lubicz. Sacred Science.
(1961).
Since 1790, there have been 112 Justices appointed to the Supreme Court - 108 men and four women. Only two, or
less than two percent, have been African American. This is statistically significant, not "due to chance" and creates an
inference of racial discrimination on its own.

18

Respectfully submitted,

Marcus Isaiah Washington

Pro Se Litigant
54 Boerum St. Apt. 6M
Brooklyn, New York
(646) 504-6497
humanrights. areamust@gmail. com

September 10, 2015

No. 15A126

I N THE

Supreme Court of tlje nitetj States!

OCTOBER TERM,

2015

MARCUS ISAIAH WASHINGTON,

Petitioner,
V.

W I L L I A M MORRIS E N D E A V O R E N T E R T A I N M E N T L L C (formerly the W I L L I A M

MORRIS A G E N C Y ) , J E F F M E A D E and SARAH WINIARSKI,
Respondents.

CERTIFICATE OF SERVICE
I - pro se litigant Marcus Isaiah Washington - certify pursuant to Rule 29 of this Court,
that on September 10, 2015, I ser\'ed the within APPLICATION TO JUSTICE RUTH BADER
GINSBURG TO STAY EXTENSION OF TIME TO FILE A PETITION FOR A WRIT OF
CERTIORARI PENDING THE EXPEDITED RESOLUTION OF PETITIONER'S JULY 18,
2015 MOTION TO DISQUALIFY LOEB & LOEB LLP, MICHAEL P. ZWEIG, CHRISTIAN
CARBONE AND OTHERS FOR "FRAUD UPON THE COURT" BY A L L JUSTICES ON THE
SUPREME COURT, OR IN THE ALTNERATIVE, APPLICATION TO EXCEED WORD
LIMITS PURUSANT TO SUPREME COURT RULE 33(I)(d) on counsel for respondent Michael P. Zweig of Loeb & Loeb LLP, 345 Park Avenue, 18'^ Floor, New York, New York,
I0I54 - through the United States Postal Service by first-class mail and e-mail.

Mr. Washington Isaiah Washington

Pro Se Litigant, Non-Attorney
54 Boerum St. Apt. 6M
Brooklyn, New York 11206
(646) 504-6497
mumanrights.areamust(^gmail.com