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S U P R E M E COURT, A P P E L L A T E DIVISION

FIRST JUDICIAL DEPARTMENT


DEPARTMENTAL DISCIPLINARY COMMITTEE
61 B R O A D W A Y , 2""* F L O O R
N E W Y O R K , N E W Y O R K 10006
(212) 4 0 1 - 0 8 0 0
Jorge Dopieo
Chief C o u n s e l
D A T E : November 13, 2014
Complainant(s):
Washington
Last

M r . ( ) Ms.( ) M r s . ( )

Address:

Marcus
First

I.
Initial

54 Boerum Street

Apt. No. 6M

Telephone:

Home: (

646

11206
Zip Code

New York
State

Brooklyn
City

B u s i n e s s : {_

) 504-6497

Attorney Complained of:


Mr.( ) Ms.( ) M r s . ( )

Address:

Carbone
Last

D.
Initial

345 Park Avenue

Apt. No.

New York
City
Telephone:

Ciirislian
First

New York
State
Business: (

Home:

10154
Z i p Code
212

) 407-4852

************************************
Complaints to other agencies:
H a v e y o u filed a complaint concerning this matter w i t h another B a r Association, District Attorney's Office or any
other agency:
I f so, n a m e o f agency:

No.

A c t i o n taken h y agency:

C o u r t action against attorney c o m p l a i n e d of:


H a v e y o u brought a civil o r c r i m i n a l action against this attorney? ^jo
I f so, n a m e o f court: N/A.

Index No.

***##************************

1.
2.

3.

Please s e n d A N O R I G I N A L A N D O N E C O P Y of y o u r complaint w i t h enclosures. Please do not s e n d original


documents i n y o u r enclosures because w e w i l l not r e t u r n them.
Y o u m a y copy the enclosed f o r m as m a n y times as y o u w i s h , o r y o u m a y find it online. O u r website i s :
www.nycourts.gov. Go to the s e a r c h b a r a n d enter "disciplinary committee." Click on the l i n k w h i c h says,
"Departmental D i s c i p l i n a r y Committee."
Y o u m a y also state y o u r allegations i n a letter. W e request separate complaint forms/letters for each
attorney i n question.

PLEASE PRINT L E G I B L Y OR TYPE IN ENGLISH


Start f r o m the beginning a n d be s u r e to tell u s w h y y o u went to the attorney, w h e n y o u h a d contact w i t h the
attorney, what happened each time you contacted the attorney, a n d what it w a s that the attorney did wrong. Please
attach copies o f all papers that y o u received from the attorney, i f any, i n c l u d i n g a copy o f A N Y R E T A I N E R
A G R E E M E N T that y o u may have signed. D O N O T F O R G E T T O S E N D A N O R I G I N A L A N D O N E C O P Y O F T H I S
COMPLAINT.

See Exhibit A. Pursuant to the New York Rules of Professional conduct, Loeb & Loeb LLP attorney Christian Carbone has violated various Rules,
including but not limited to Rulesl.1 (c)(2), 1.2(d) and (Q, 3.1(a) and (b), 3.3(b) and (f), 3.5(a), 4.1, as well as 5.2 (d)(1), (d)(2)(i) and (d)(2)(ii).
In violation of Rule 8 3, Christian Carbone and other attorneys at Loeb & Loeb LLP (e.g. Michael P. Zweig and Michael Barnett) have
(a) violate[d] or attempt[ed] to violate the Rules of Professional Conduct, knowingly assist[ed] or induce[ed] another to do so, or d[id] so
through the acts of another"; (b) "enqageledl in illegal conduct that adversely reflects on the lawyer's honesty, trustworthiness or fitness as a
lawyer"; (c) "engage[d] in conduct involving dishonesty, fraud, deceit or misrepresentation"; (d) "engagefd] in conduct that is prejudicial to the
administration of justice"; (e) "impl[ied] an ability to (1) "influence improperly or upon irrelevant grounds any tribunal, legislative body or
public official; or (2) to achieve results using means that violate these Rules or other law."
Pursuant to Rule 8.3(a), Christian Carbone has committed numerous violations under "the Rules of Professional Conduct that raises
a substantial question as to that lawyer's honesty, trustworthiness or fitness as a lawyer.' Although I am not an attorney, I am a citizen of the
it is in the public's interest that such information be disclosed "to a tribunal or other authority empowered to investigate or act upon such
violation[s]."
Did Christian Carbone have an ethical obligation to disclose to the opposing party or the federal court, at any time during the litigation,
that he was married to an executive that was employed by the American Arbitration Association when he sought to have the federal judge
compel my case under the jurisdiction of the AAA? If you were arbitrating a case, would you want this information to be disclosed to you,
especially if it is later discovered that the arbitrator and attorney's wife worked closely together? If not, would Carbone's actions be considered
unethical if he were African American? If the Departmental Disciplinary Committee denies my complaint without compelling Carbone to
respond or disclose information about his relationship to AAA executive Sasha Angelique Carbone, then I ask that the DDC issue an
expedited decision, explaining why Carbone and Loeb & Loeb LLP's actions are in compliance with the New York Rules of Professional
Conduct and explain why an attorney does not have an ethical obligation to disclose information re: marital status to employees of an
allegedly "neutral" tribunal.

U N S I G N E D COMPLAINTS W I L L NOT B E P R O C E S S E D .

I ain resubmitting this Complaint since I never received any acknowledgment from the ODC that the original Complaint was received. To this day. Christian Carbone was refused to
confirm and/or deny his marriage to A.\A executive and former Ieb & l-oeb l.I-P attorney Sasha .\ngelique Carbone.

S U P R E M E COURT, APPELLATE DIVISION


FIRST JUDICIAL DEPARTMENT
DEPARTMENTAL DISCIPLINARY COMMITTEE
61 B R O A D W A Y , 2 ^ F L O O R
N E W Y O R K , N E W Y O R K 10006
(212) 4 0 1 - 0 8 0 0
Jorge Dopico
Chief C o u n s e l
D A T E : November 13,2014
Complainant(s);
Washington
Last

M r . ( ) Ms.( ) M r s . ( )

Address:

I.
Initial

54 Boerum Street

Apt. No. _6M_

Brooklyn

aty
Telephone:

Marcus
First

Home: (

646

11206
Zip Code

New York
State

) 504-6497

B u s i n e s s : _

Attorney C o m p l a i n e d of;
M r . ( ) Ms.( ) M r s . ( )

Address:

Carbone
Last

D.
Initial

345 Park Avenue

Apt. No.

New York

City
Telephone:

Christian
First

New York
State
Business: (

H o m e : ^

10154
Z i p Code
212

) 407-4852

Complaints to other agencies;


H a v e y o u filed a complaint concerning this matter w i t h another B a r Association, District Attorney's Office or any
other agency:
I f so, n a m e of agency:

No.

A c t i o n taken by agency:

C o u r t action against attorney complained of:


H a v e you brought a civil or c r i m i n a l action against this attorney? NIo
I f so, n a m e of court: N/A.

1.
a.

3.

I n d e x No.

Please s e n d A N O R I G I N A L A N D O N E C O P Y of y o u r complaint w i t h enclosures. Please do not s e n d original


documents i n y o u r enclosures because w e w i l l not r e t u r n them,
Y o u m a y copy the enclosed form a s m a n y times as y o u w i s h , o r y o u may find it online. O u r website i s :
www.nycourts.gov. Go to the s e a r c h b a r a n d enter "disciplinary committee." C l i c k o n the l i n k w h i c h says,
"Departmental D i s c i p l i n a r y Committee."
Y o u m a y also state y o u r allegations i n a letter. W e request separate complaint forms/letters for each
attorney i n question.

PI FASH P R I N t I K G I B I Y O R

PH: I N R N G I I S H

Start from tlie bej^inning and be sure to tell us why you went to tlie attorney, when you had contact with the
attorney, what happened e-ach timeyou contacted the attorney, and what it was that the attorney did wrong. Please
attach copies of all papers tliat you received from the attorney, i f any, including a copy of ANY R E I A I N E R
A G R l - E M E N l that vou may have signed. DO NOT F O R G E T J O S E N D A N O R I G I N A I . AND O N E COrXQl*' T H I S
COMPLAINT.

See Exlubit A. Piii suant to the New York Rulea of fijFessional conduct, loeb & Loeb LLP attoriieyCluistian Carborie has xnolated various Rules,
mchidin-^but t^oi limijed to Rulesl l(c)(/;). 1 :^(d) and (t). 3 Ijii) and (h), a 3(b) and {>']. 3.5(a), 4 1. as well
In Nnolaiion of Rule 8.3, Christiayi C'arboiig and othev attorneys at Iccb

S.2 {d)(1). (d)(2)(i) andjdj|2"|(ii).

& JAXb lA.P (e.g. Micliacl T'. Zweig and Michael Bamctt) have

(a) *\nolalefd] or aKemptfed] lo %nolate the Rule--- of rrotes.sional Ccnduct. knowin^Qy a.->s.i.st[cd| or irducc(cd] another to do .so. or djid) i.o
Ihroti-sh the acts of anothci^; (b) 'cn,'^a.g;lcdi in illcyai conduct Ibat advcrsi-iy rctlccls on flic la\^7Cr-& honesty, tni.shvoi-thincs.s cr fitncj-s a.<; a
lawyer^; (c) 'cn^^c[d\ conduct mvolvui.;^ dishonesty, friiud. deceit or rfuSfcprc;.ci[|alioir, (d) "engageldl in conduct that is prejudicial to the
adininistralion of justice"; (e) 'impl[ied| ar, ahihty to (1) "intliience iniproyicrly or upoii irrelevant s^ou nets any trihunsLl, Icj^islativc bociy or
{Tublic otficiat; or (2) to aciiicvc result.^ ushi'^ incajis that 'rlolalc these Ridea or oilier law.'
Pui suatii 1-0 Rule .S.3(a). Chnstian Cai'bt^ne hxs committed numerous ^notations under "the Rules of Proi'cgiunaiCunduct tiiai rabies
a substantial qneation as to that lawyer's hoticsty. tnistworthin!.-^S or fitrie?.-S as :-i l.qvv~yg<." Ali}iL-)Ugli I am not an attorney. 1 am a citizen of the
it is in the public's interest that such infcnnation be cUscicsctl "to a lnhun:il or tsth&v auJiiority empowered to investi,-^ate or act upxjn sucli
yiolationls)."
Did Christian Carbone have an dluca: obligation to disclose Ic Hie opposifss party or the federal court, ai any lirnc daruia '.lie lilij;alioi>.
that he was married to ar. executive thn? was t-mploycd

the American Arbitration Association wheri he sought to have the federal iudgfi

ccinpic-l my case under (hf juri.sdicnon of the A.\A? [f you were arbih-ating a cLisc. woi.dd you want lliis inl'omiation tc he disclcsed to you.
especially i i it is later discovered thai the arbitralcr lind utturncy's wife wurkcd closely togcthef'.' If not, would Carbone's actions be considered
unethical if he w c r f .African .Xmcrican'? If il-e nepanmamjil riisctp'iinaJ7 Ccnnniltcc denu's my ccmpilaitit without compiclling Ciirbonc to
respond or disclose inJ'ormalion about his rchilionship lo .AA.A cxfculivc Siisf.a Angchc]uc Carbone. then I ask that the DDC issue an
expedited decision, explainin,^, why Carbon." and Loeb

U v h LLP's -sclJnns are in. compliance wiih the New York Rules of Professional

Conduct and explain why an attorney docs iiot have an ctJueal ob.hgatjon to d-.sciosc intbi-maiion rc. mantal status to employees of an
nlle,'^edly "neutral" tribunal

U N S I G N E D C O M P L A I N T S W I L L NOT B E P R O C E S S E D .
Signature

Exhibit A

.Case l:10-cv-09647-PKC-JCF Document 54 Filed 11/06/14 Page 1 of 5

November 3, 2014

Mr Christian Dominic Carbone


Loeb & Loeb L J P
345 Park Avenue
New York, New York 10154

Re: Fitial Request For Loeb & Loeb L L P Attorney Christian Cartione to Disclose Information on
Relationship to Sasha Angdique Carbone | Marcus T. Washington v. William Morris Endeavor
Entertainment (in Civ. 9647) ( P K Q ( J C F )
Christian Dominic Carbone:
On March 10, 2014, I first rieached out to you and asked i f it was true that you were married to Sasha Angelique
Carbone - former employee o f Loeb & Loeb LLP and a current and/or former executive (e.g. "Associate (l^eneral
Counsel") for the American Arbitratioti .Association, wliich just so happens to be the same arbitral ibrum you sought
Republican appointed federal judge P. Kevin Castel o f the Southern District o f New York to have my employment
discrimination and human rights ca.se against William Morris compelled to. The same arbitration association that
aJlowiSj their arbitraiors to erroneously decide the issue o f arbilrabdity without discussing the parlies' j-uments
and/or citing any case law although P Kevin CastcPs .luly 20, 2011 Stay Order directed the arbitrator to decide that
issue. The same arbilraiion association that urilawlully disquaJitied Arbitrator David L Crregory alTei he issued his
Partial Final Award on December 17, 2013, which concluded that 1 proved by a "preponderance of the evidence" that
"William Morris Endeavor Fntertainment L L C discriminated against [me] in violation of pertinent federal, state, and
local law prohibitmg discrimination in employmeiU on the basis o f race" and indicated tliat 1 would be awarded the
tidl gamut o f monetary damages (including punitive damages and pro se noii attorney's fees) during phase 2 o f our
bifurcated proceeding The same arbiUatioD association that allowed A A A board o f director and Sclinader L L P
attorney Timothy K . Lewis - who lias worked closely vvith Sasha Angelique Carbone as a member o f the A A A ' s
Diversity Committee - to vacate Gregory's Partial Final Award in violation o f 10 o f tlie Pederai Arbitnition Act [the
Award was ripe and final for the sake o f judicial review and only Castel had jurisdictiuii to confirm, modift' and/ur
vacate Gregory's Award or disqualify him after issuing the Award]. The same arbitration association that rcfu.sed to
disqualify Lewis atid allowed him to dismiss my case "'svith prejudice and on the merits" because I continued to
publicly object to the clear fraud that was taking place in my case The same arbitration association liiat advertises
itself as being "neuUal."
I believe that as a licensed attorney in the State o f New York, you had an ethical obligation to disclose information
about your marriage to Sasha .Angelique Carbone to both the Southern District o f New York and myself when you
decided to "represent" William Morris alongside Michael P. Zweig in this case Since yoa knew thai this case was
being compelled to die same forum that your wife worked for, you should have opted against representing William
Morris and you should have never been allowed l o profit from this ca.se, I f this information is tixie, I believe that you
highly unethical actions con.stitutc violations under the New York Rules o f Professional Conduct
rw\v\v.nvcouns.gov7'niies.''jomtappellatc/NY-Rtiles-Pr<i)'4^a'iduor.i200 pdfl and New York Judiciary Law g 487. I
also believe your actions constitute further evidence o f the overall "pattern" o f fraud Loeb & Loeb L L P has engaged
in for decades iluoughout Americas judicial system on William ."vloms' tehalf (e.g. Rowe Entertainment et al. v
William Morris Agency et al (98 Civ 8287 (RPP) (JCF)) and Arbitrator Cfregory's decision to admit "Exhibit 3 1 "
into the "evidence of the record" in my case) to ensure that African American litigants seeking to effectuate the public
policy goals o f our nation's civil & human rights laws by challenging Wiliiara Morris' institutionally racist
employment and business practices in the federal court, are deprived o f their full constitutional and statutory rights
under the color o f law and prevented from having the merits o f their case be decided by an impartial jury.
.Since Castel denied my request to have you confirm or deny tllis Information by AlTidavits stated months later in his
September 5, 2014 Final Order tiiai the marriage was "alleged" [despite Heather Santo's response to my inquiry],
issued a filing injunction against me from going against Loeb &. Loeb LLP, its attontCys^Mfl 6|S^r^5SJpp^|^Rr^Est'
fraud and any other claim I deemed necessary to correct this mariifet;t injustice, revoked my in forma pauperis stktua

NOV

PhO

s e

- 6 2014

Li,

O h h i C g

.case l:10-cv-09647-PKC-JCF Document 54 Filed 11/08/14 Page 2 of 5

prejudiced my appeal by stating that my appeal would not be made in "good faith" and denied my October 3, 2014
Fed. R. Civ. P. 60 Fraud Upon the Court .Motion as being "v/itiiou': merit," I want to give you one last opporluiiily
before 1 subriiii my appeal to the Second Circuit, lo be hone.st by either confirmbig or denying that you arc and/or were
married to Sasha Augellque Carbone ("Sasha .Angelique Smith") at any time during your representation o f William
Morris in Washington v William Morris Endeavor Entertainment et al. ( 1 0 Civ 9647) (PKC) (JCF),
I just did a brief search online and the first link directed me here:

<^ PeopleSinart
Search Successful! 1 Public Record Report Found.
S*l*ct kfriOt^ bvlviv t K I ^ M i ltvift;f*~

-.IN,'I

SASHA
SMrri A C*rt)6i>

r.ssf N--jmc:
CARBONE

. caw

A n d the .second link directed me here:

40

W** Yark. NY

, Case l:10-cv-09647-PKC-JCF Document 64 Filed 11/06/14 Page 3 of 5

6j**inlr.f[>

A'lc3r (Wtf^irt-^ivjooiWi

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I

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i wtiKlMr MiTsdw " j w d W o f


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iR* or?*t:*;r, irtwaafeT', foMliitor. r*j(*<ik:n, V W M - * . s i W f f * jnd tNf v<Maf5 g r n e w w ^ , }*XU, rwa ian

Had 1 been married to an executive at the American Arbitration Association or any forum with the jurisdiction to
decide any aspect o f my case, and did not disclose that information to William M o m s . Loeb & Loeb L L P and the
Southern District o f New York, you, Zweig and Loeb & Loeb LLP would have moved for ilie Southern District (.if
New York lo throw out any decision made in my favor and requested that ssenous sanctions be imposed against me
for engaging in considerable "bad faitlf' and liaving "unclean hands"' For eight months, you have refused to
acknowledge or answer ray request for information abrvjl youi rciatioriship to Sasha .Angelique Carbone, but had I
been married to an executive at the American .Arbitration .Association, i would nor be allowed to wait eight months to
answer your question because Castel would have compelled me to disclose this information and had I been an aaual
attorney, there's no question that Caslel would have immediaieiy disbaned me,
.As you are aware fraud vitiates everything and pursuant to New York Judiciary Law ^187(1), an attorney or counselor
"Svho is guilty o f any deceit or collusion, or consents to any deceit or collusion, with intent to deceive the court or any
party.,, is guilty o f a misdemeanor, and in addition to the punishmeni prescribed therefor by the penal law, he forfeits
to the party injured treble damages, to be recovered in a civil aaian " The irreparable barm that I've suffered as a
result o f the overall fraud you, Zi.veig, Loeb & Loeb L I P and William Morris have engaged in is astronomical. Four
years o f my life have essentially been wasted litigating a ca.se whose outcome was largely pre-deterrained no matter
the uiuefiited pyramid o f evidence that 1 presented to prove my claims o f intentional systemic disparate treatment,
disparate impact, pre and post-hiring individual disparate tre,ment under Section 1981, Title VTI, N'YSHR.L and
N Y C H R L , as well asciaims o f conspiracy lo interfere with the human rights o f people o f .African descent and antitrust
violations under the Sherman and Donnelly .Acis Since the Constitution guarantees "ecjual proteaion under the law"
and justice should be blind to race in our allegedly "post-racial" United States o f .'Xjnenca, then the punishments 1
would receive as a result o f my "highly unethical and criminal conduct' should ]yc no ditTereni than the punishments
you, Michael P Zweig, Loeb & Loeb LLP, William Morris and other various parties should receive for intentionally
engaging in fraud and conspiring to ensure that I was deprived o f my full constitutional and statutoi-y rights under tlie
color o f law.
Whether you decide to dignify my last request or not, just know that you will not be able to remain silent about this
information forever, so you might lias well tell the truth now f ask that you reply to this e-mail no later than Friday,

Case l:10-cv-09S47-PKC-JCF Document 54 Filed 11/06/14 Page 4 of 5

November 7,2014, M y FRAP S, 24, 46(b) Motion to the Second Circuit will be submitted on or hefhre November 2
2014.
Beat,

Marcus Washington

cc;

wmmmmmmmmmmmmmmmmimmt^
Federal Judge P. Kevin Castel. Southem District o f New York (U,.S mail)
Federal Judge Robert P. Patterson, Soulhem District of New York (U,S, mail)
ImJia Johnson, President o f the Americati Arbrtration Association (e-maii)
Michael Beck, Chairman o f f-oeb & Loeb LLP (e-mail)
ftiichaeJ P, Zweig, Partner at Loeb & Loeb I I - P (e-maii)
Michsel Bamett, Associate al Loeb & Loeb L L P (e-mail)
Tal Diokstein, Senior Counsel at Loeb & Loeb L L P (e-maii)