Washington v. William Morris Endeavor Ent. Et Al. (11-3576) - Appellant's Emergency Motion To Expedite Appeal Exhibits (September 28, 2011)

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500
MOTION INFORMATION STATEMENT
Docket Nnmber(s): ___________________ _____
Motion for: Emergency Motion For An Expedited Appeal
Washington v. William Eruieavor
.--" -i.'1 t
Entertainment, bLC,,et al:-:::
Set forth below precise, complete statement ofrelief sought: ;:: :-;'."
'---" -,-....
Granting an expedited appeal to reverse the harmfully
erroneous and biased decision of Hon. Castel compelling
this case - which challenges insidious and institutional
racism in the American workolace - into arbitration.
MOVING PARTY: Mr. Marcus Isaiah Washington OPPOSING PARTY: William Morris Endeavor Ent.. LLC
It] Plaintiff 0 Defendant
It] AppellanUPetitioner 0 Appellee/Respondent
MOVING A TTOR."'IfEY: Mr. Marcus Isaiah Washington (pro se) OPPOSING ATTORNEY: Mr. Michael & Christian Carbone
------=----------
[name of attorney, with firm, address, phone number and e-mail)
54 Boerum St., Apt. 6M Loeb & Loeb. LLC
Brooklyn, NY, 11206 345 Park Avenue, 18th Floor
____ ______________
humanrights.areamust@gmail.com 212-407 -4000
Court-Judge/Agency appealed from: Southern District of New York / Hon. P. Kevin Castel
Please cbeck appropriate boxes: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND
INJUNCTIONS PENDING APPEAL:
Has movant notified opposing counsel (required by Local Rule 27.1): Has request for relief been made below? I?] Yes D No
Dyes EI No (explain): All parties are not represented Has this relief been previously sought in this Court? DYes I?] No
by counseL Requested return date and explanation of emergency: Requested date
Opposing counsel's position on motion:
D Unopposed Dopposed I?]Don't Know would be no later than Oct. 17. 2011 - the original date
Does opposing counsel intend to file a response:
DYes DNo I?]Don'tKnow scheduled for me to submit my brief.
Is oral argument on motion requested? DYes IZl No (requests for oral argument will not necessarily be granted)
Has argument date of appeal been set? DYes I?] No If yes, enter
Date: _____ Has service been effected? I?] Yes D No [Attach proof ofservice)
ORDER
IT IS HEREBY ORDERED THAT the motion is GRANTED DENIED.
FOR THE COURT:
CATHERINE O'HAGAN WOLFE, Clerk of Court
Dare: _______________________________ By: ______________________________________
Form T-l080
Case: 11-3576 Document: 17 Page: 1 09/28/2011 405267 21
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
-----------------------------------------------------J(
WASHINGTON,
11-3576-CV
Appellant,
v. AFFIRMATION OF APPELLANTS
EMERGENCY MOTION FOR AN
WILUAM MORRIS ENnEAVOR E1CPEDITED APPEAL AND REQUEST
ENTERTAINMENT, LLC, etal., FOR THE DISQUAliFICATION OF
HON. P. KEVIN CASTEL AND HON.
JAMES C. FRANCIS PURSUANT TO28
Appellees. U.S.c. 455 AND 2106
-----------------------------------------------------J(
I, Marcus 1. Washington, affirm under penalty of perjury that:
..
f" ;
1. I, Marcus I. Washington, am the Appellant in the above entided action, and respectfully:submit ~ s
affirmation to the motion dated September 28, 2011 made by myself asking that the court of"der the
following relief: grant an expedited appeal due to the deliberately harmful error of Hon. Castel granting
the Appellees' request to compel this important civil rights case into arbitration. Also seeking the
acknowledgement of my request to have Hon. Castel and Hon. Francis disqualified pursuant to 28 US.c.
455 and 2106.
2. I have personal knowledge of facts which bear on this motion because as a former employee of
William Moms Endeavor Entertainment, I am a victim of their discriminatory practices, policies and
procedures.
3. The motion should be granted because: (1) I am likely to succeed on appeal due to Hon. Castel's
decision to ignore arguments raised in defense of the arbitration agreement's unconscionable provisions
resulting in an omission of relevant facts and misapplication of the prevailing law; (2) there is a public
interest that this case stay in the federal court to combat insidious and institutional racism in the
American workplace, in addition to addressing Hollywood's cabal-like practices which continue to
perpetuate racism in America; and (3) further delay will cause irreparable harm due to my economic
hardships, health and other circumstances.
4. Attached hereto as Exhibit A is a true and correct copy of the letter submitted to Hon. Castel
requesting an expedited ruling filed in this action on or about July 10, 2011.
5. Attached hereto as Exhibit B is a true and correct copy of the Final Notices from Sallie Mae recClved
for defaulting on student loans on or about July 15, 2011 and July 18,2011.
6. Attached hereto as Exhibit C is a true and correct copy of the numerous medical records detailing
my visits with pbysicians and specialists concerning my stress related gastrointestinal and urinary ailments
which manifested physically while working in William Moms' discriminatory work environment.
Spanning from January 11, 2009 to Ap:ril30, 2010.
7. Attached hereto as Exhibit D is a true and correct copy of NYU's Thirteenth Annual Workshop
"Employment Law for Federal Judge" panel brochure held on or around March 17-18,2010. Hon. Castel
and Hon. Francis were featured speakers.
8. Attached hereto as Exhibit E is a true and correct copy of the American Conference Institute's
Premier Forum on Defending and Managing Employment Discrimination Litigation brochure held on or
about February 25-26, 2010. Hon. Francis was a featured speaker.
9. In view of the foregoing, it is respectfully submitted that the motion should be denied.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: New York, New York Respectfully submitted.
September 28, 2011
By: $ ~ ~ Q ~ ~ ~ ~
Marcus L Washington
54 Boerum St. Apt. 6M
Brooklyn, NY 11206
(646) 504-6497
humanrights.areamust@gmaiLcom
Exhibit A
By Hand
June 10,2011
Hon.. P. Kevin Castel
Uttited States District Judge
Daniel Patrick Moynilw:t
United States Courthouse
500 Pead Street
New Yod. NY 10007-1312
Re: Wash1ogton v. William Mortis Endeavor Entertainment. u.c et al; 10 Civ 9647 (PKC)
Deu' Judge Castel:
On AprilS, 2011. the Defendants (collec1ivdy, "WMEj in the above referenced matter filed their final
motion in hopes ofcompellingme into ubitr.trioo and/or to dismiss my complaint pw:suant to the Fedeml
A.rbitm.tion Act of 1925. After two months without a ruliog. I am now writing to you to tequest an expedited
tu1ing on this matter so that this case can proceed with the hopes ofreaching a resolution in a timely manner. Due
to my eco.ooolic 3t1d tinanciaI circumstances as a result ofbeing unemployed for more than a Yeu'. time becomes
more ~ because the future ofmy Jivclihood is dependent JargeJy on the outcome of this case.
Aside from the blanket statement that my motion was "filled with out:tageous. seJf-coo.t:mdictoty. and
utterly unsubstantiated allegations about WME and its employees." the Defendants' failed to disprove any of the
pertinent facts presented in my o p p ~ motion including the main argument a pre-emring disparate impact
and systemic dispat'ate treatment towards African Americans and other mino.t:ities existed and could be embli.shed
pnorto me signing the arbitrAtion agreement given the company's 113 year "pattern and practice" of
disctimination. Nor could they counter the case Jaw which statistically establi$hes that a prillJafoci' inference of
discriminatioD can be made based OIl the Court's concept ofthe "inexouble zero". Inti BM. Qfl'mn!!t'f: v.
United States" 431 U.S. 339 (1977) (citations omitted); &mer]:. Ciq offIarve,y. No. 95 C 3316, 1998 WI.. 664951
(N,D. Ill. Sept. 18, 1998); Qrtiz-Del YaDe y. Nihil Basketball &S'g, 42 F. Supp. 2d 33 (SD.N.Y. 1999); ~
v. HewJctt-PmN Companf. 34 F. Supp. 2d 809 (E.D.N.Y. 1999); ~ ama.. Ewiog v;. Cog. COla BoEtting Cg. No.
00 CIV. 702O(CM), 2001 WI.. 767070 (S.D.N.Y. Jnne 25, 2(01). For these reasons and JllOl'.e, I am IUlking in my
oppositiO:Dal motion that the 'disctimis:lation' provision in WME's atbitmtion agreements be declared
unconscionable.
It's been over a year since I filed my ficst complaint 'With the EEOC. To this day, WME hasn't had to
respond to these serious and unlawful claims. This is very petpbinggiven the substantial amount ofhistotiaI.
statistical, anecdotal, cittumstanrial and other types ofevidence presented in my compJamt and oppo3itional
motion.. I can't make these things up, even ifI want to. This demonmates the extent to whicll WME bas fIagtantly
violated the Jawand one could even make the argument that this is a form ofcriminal activity. In the introduction
to Oliver C. Cox's Race: A Stm!J iN SmiAI~ (2000), Adolph Reed wrires that racism "is not an affIiction....Nor
is it II thing that can act on its awn; it exists only as it is reproduced in specific social ~ t s in specific
Hoo. P. Kevin Castel
February 11. 2011
Pqe2
societies under historicaJly specific cond.itioos of law. state, and class power.fl Given the systemic nature oftacism,
the courts can 110 longer enable employers to supersede federal, state and city civil and human rights laws by
compelling future employees into 'manda:tory' atb.ittation. specifically Oil issues of <discrim:i.na:ti'. What :incentive
do these employers have to complf with the civil and bmnan rights laws? As demo:ostrated by WME, there is no
incentive, and until companies are held accou.ntr.Ib1e for their actions. the cycle will only continue.
Within the last year, it has come to my attention tha.t: tna1ly employees, including potential by witnesses.
have exited the company and/or have moved out of the state (mdud1ng 1... Foster [the only ot.her .African
American employed at the time ofmy employment]. Cam Stein [COO of the New York office] and Mike Gorski
[the most integ:cU employee within the IT departmentD. 'Th.is will create additional batrien for me during discovery
and to reduce :furt:b.ec disruption and delay on resolving this matter, I am aslcing for an expedited rul:i.ng Oil this
motion. This is 11 critical time fur our nation and at the heart ofthe problem is the issue of "m.ce." Please
understl.Uld and adtnowledge the of the evidence I'm presenting and allow the case to proceed in the
federal court.
I thank the Court for its consideration of this
Respectfully submitted.
fJ..
Mattus L Washington
54 Boenun 51. Apt 6M
Brooklyn, NY t 1206
(646) 504-6497
bJ:u:namights.isamust@gmaiLcom
cc; Me. Michael P. Zweig (Loeb & Loeb,llP) (Via Hand Delivety)
UNITED STATES DlSTRlCT COURT
SOUTHERN DISTRlCT OF NEW YORK
- against
AFFIRMATION OF SERVICE
Wi\lv,.ttt. M6VV'1s UCj
4' & w; \Ii"""", N\tJVJ'I..$ t .P.ff
"Yl4
t, , declare under penalty of perjury that 1 have
(name)
served a copy of the attached { .fr t;..A ... ,;JI4 ....f,'
(document yo are serving)
upon ---,-;..l.. .... J?t...t= ft!.. whose address is

--.;;N_ew_\lc'''F.....
(tOWr;ctry) (stale)
:t!:t-' CQ.
Sign II
0tH1e.

(month) (day) (year)
ZipCOik
"-1'" -
Rn. OJ/ZOO?
Exhibit B
Hair
220 Lasley Ave.
Wilkes-Barre, PA 18706
1658 July 15,2011
Marcus Washington
54 Boerum St Apt 6M Account Number: 9412785418
Brooklyn, NY 11206-2426
LoanID(s): to; 14; 17; 18
FINAL NOTICE
Dear Marcus Washington:
One or more of your private student loans is now seriously past due and is in jeopardy of being written off
as bad debt.
If your student loan defaults:
You will be required to repay tbe entire balance of your loan rather than just the monthly
payments that you have missed;
Your loan may be assigned to a collection agency for additional collection efforts; and
Your default will be reported to all Consumer Credit Reporting Agencies and will stay on your
credit report for up to seven years.
We'd prefer to work directly with you to resolve yOUI" account. However, we will not hesitate to
consider these and other collection options if acceptable payment arrangements are not made
before July 29, 2011.
The fastest way to make a payment is by phone, so call a Sallie Mae account manager today at
1877926-4502 for assistance. Our hours of operation are 8 a,m. to 9 p,m. ET Monday - Friday and
8 a,m. to 12 p.m. ETon Saturday.
Sincerely.
Sallie Mae Collections
P.S. This is also your last opportunity to request to settle your eligible loans before defaulting. With a
settlement, you pay only a portion of your outstanding balance. Call to discuss at 1-877-926-4502.
220071511
This communication is an att.er:npt to ronect a debt and any information obtained win be used for that purpose.
Preserve your credit
and financial future
with one phone call.
1660
Marcus Washington
54 Boerum St Apt 6m
Brooklyn. NY 1 1 2 0 6 ~ 2 4 2 6
July 18, 2011 Account: 9412785418
Dear Marcus Washington,
The delinquency on one or more of your Sallie Mae private loan(s) has reached a critical point. Your
loan(s) are in jeopardy of default. You can avoid this with one phone call.
You are eligible for payment relief through our forbearance program
Call 1-800-891-5476 by July 29,2011
Forbearance will allow you to avoid default and resolve your past due status without having to pay
your past due balance immediately. This program can give you the time you need to secure stable
employment and income and protect your future.
If you allow the loan to default it may be reported as such to the credit reporting agencies for several
years. This may severely impact your ability to gain employment, obtain credit to purchase an
automobile, home or other items. prevent you from leasing a place to live. impact the rates that you
pay for insurance and cause you to be denied for a cellular plan or utility. Interest will continue to
accrue, collection efforts will continue, and paying later will not remove the default from your credit
file.
We can help you avoid this, but in order to do so we must speak with you to gather some information
and provide you with important details about the terms of your particular forbearance program. You
can help preserve your bright future with one phone call.
Take advantage of this opportunity today
by calling 1-800-891-5476
Sincerely,
Joe Sbriglia
Vice President, Sallie Mae 985071811
Exhibit C
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"1 \'1'1.. 1'\ Y i 00 1(j
!1Z;(,:77f;:'', pholl\
\,'il" -:n, :,',1\1, hI}.
4
t,
frt

Your recenl labs orc within normal iimils. If you H(luld lil:e \(l discu::s them
in detail. please make an appointment to see me.
Saint Vincent Comprehensive Cancer Center
1461057 teo 000441355609.
325 West 15th . New Vork, NY 10011
WASHIIiGTON ,MARCUS 24 M
AMBULATORY SURGERY UNIT
SCIIIMRTZ. AU!lWIDER 09/21'191
EDUCATION FOR SELFooCARE AFTER SURGERY
DATE URGICAL PROCEDURE
~ Locel with IV sedation 0 Local
If you racetved anesthesia you may experfance: dizziness. nausea & vomiting, headache. drowsinesS, muscle aches
and 80re throat.
For 24 hrs after recelYJng anestheala you should not:
.. Engage in activities that require coordination and ability to respond qufckIy (driving motor vehicles, riding a blcycfe)
.. Consume aIcohoIk; beverages .
.. lift heavy objects or perfonn heavy work
.. Operate machinery, powertoofs or handle dangerous Items (hot grease; boRing water, smoking. sharp Items)
Sign any legally binding documents
H you rec8.tved general ~ .... you may experience a sore throat for the first 24 hours following surgery. This is
due to a breathing tube placed during the surgery. Immediately call your doctor if you have ~ breathing.
swaIIow'gR or have swelling atethroat.
DIETARY: ConstIpation Is a common side effacl with many narcotic pain medications, 80 Increase the fluids and fiber
In your diet. A fiber diet inclUdes wheat bread, graham crackers, brown' nee. raw fruit &vegetables and soup.
o Regular I Normal Diet ~ liquids (apple juica, jeIfo. ginger ale) to light foods (soup, bouillion). then
advangtna to regular; diet as tolerated
MEDICATION: Medication reconciliation reviewed with the patient and! or escort.
Use TYlENOL only or your pain presctiption as directed. _h_______________
Time & Dose last pain medication was given: __________________
.. Narcotic prescriptions can cause nausea. It may be best to take with food.
Do not ch'i!'k alcohol or drive while you are taking narcotic pain medication .
.. 00 not take aspirin or 8spirirl by-products for 7 days after surgery .
.. Resume your daily prescr1pt1on medication schedule
.. Consutt xgur doctor when to resuma bloodthinnl,! medications ( MA. Aleve. Motrln, AdvH. CoumadinC!avlx, Vitamin
BATHING &WOUND CARE: It Is normal to experiene& mlnimaf swelling, bteeding and bruising at the surgery area.
Your incisfon may be COvered with a ctear water resistant dressing.
o To aIIevi8te the pain. use ice pact (20 minutes on & 20 minUtes off) for 24 hours only.
l
Ho bath or 5Wimming for a week. 0 No restriction on bath or shower.
Shower 24 hours after surgery. ( No direct water spray at your InCleion slta when showering ).
If you have.a press dressing. remove It in 24 hours and then you y shower.
-.
Specific .Instructions:
or Rash develops after taking pain medication. .. Exceuive bleeding (bright red bleeding saturating
.. You have persistent nausea & vomltfng. the dressing completely). Apply pressure and elevate If pc
.. You have no Nllef from your pain medication. * Redness, awelUng with a foul odor drainage or a fever of
FOLLOW UP APPOINTMENT:
call n'5 office &confirm foIlow..u
IN CASE OF EMERGENCY:
101 degrees 36 - hours after SUIU
mon
room or dial 911.
DATE & TIME: - " - + ' - - - - I - - - : ~ " ' " " r -
Peter M. Distler, M.D. P ..L.L.C
3 East Street
New York, NY le028
(112) 7l4-3444
Discharge
Sedative medications given for procedu.... can slow your reaction time and
coordination for many hours. If you receive mediations, it is Important for your safety
to foRow the Instructions tor the remainder of tile day:
8E TAKEN directly home from the office and rest quietly. DO NOT resume norma.
activities until tomorrow.
DO NOT drive,retums to work" Of' operate any machinery or power toolS.
DO NOT make any Important personal or business dedsions, sign any legal papers, or
perform any activity that depends on your futl concentrating power or mental judgment
DO NOT drink any alcohL or take nerve or .sleeping pJJl drugs. They add to the effects of
the medicine stH1 present in your body
a treatment is performed during the procedure,. there is a slight risk of bleeding. If
you receive treatment, we sU9llest that you follow the instruction below.
DO NOT take aspirin or simiJar anti-inflammatory medicines for 7 days
DO NOT exercise, jog.. or do any heavy lifting or straining for 3 days
., ,A>*'
I For eoaobO!PY: I
Potential common effeds and treatments following the procedure:
Mild abdomina! pain, bloating or excessive gas- ret;t, eat lightly, and use a heating pad
Redness and/or sweUing where the IV was - apply heat and elevate
Symptoms to report to Dr. ____________
severe abdominal pain or bloating
Chills or fever about 101 degrees occumng within 24 hours after the procedure
large amounts of rectal bleeding that does not stop. Small amounts of rectal bleeding is
not serious, especially if hemorrhoids are present
Unable to keep down food or drink
IV site stays red or swollen for more then 2 days
I
Potentia' common effects and treatments following the procedure:
Mild sore throat- treat with throat wzenges and gargle. with warm salt water.
Redness and/or $Welting where IV apply and elevate.
MUd abdominal pain or rest, eat lightly and use a heating pad
to report to Dr ..,; __ _ ________
Severe sore throat or inabiflty to swallow and/or eat usual diet
Severe continuing abdominal pain or bloating
Pain in chest or back
Swelling to the neck: area
ChUls or fever above 101 degrees occurring within 24 hDUrs after the procedure
N site stays red or swollen for more than 2 days
Persistent black bowel movements ( may indicate bidden blood)

I have read and understand the a
Patient or Patient Rep
..
-------------------------------
Peter Distler,M.D.,PLLC
PeterM.Distler, MD
3 East 83rd Street
Joseph A.Nash,MD
New Yolk, NY 10028
(212}134-3444
PATIENT INSTRUcnON FOR COLONOSCOPY
Dear Patient: 7,-f..,
yo"!.t.
onoscopy
is scheduled for 11t.':!i 1 I(P i ;)(j-P;
At SO a.m./p.m. at
St. Luke's Hospital
ROOMVelt Hospital
omu
1111 Amsterdam Ave
1000 Tenth Ave
3 East 83"' St.
At 114111 Street
at West 59'" Street
NY,NY 10028
Ambulatory Surgery
Ambulatory Surgery
Day before the test:
J
You should ingest a clear liquid diet; suggested foods include apple juice.
Cranberry juict; JeUO, chicken broth, any kind ofsoda, tea or coffee without
milk. Drink one cup ofliquid every balf-hour from till midnight
(NO orange juice, dairy products. solid foods)

with 12 ounces of Ginger Ale. Remain close to the toilet facilities.
__d Regimen:
5 p,n'I take 4 Osmoprep tablets every lL.minutes with at least 8 ounces ofclear
liq . til theremaining 12 tablets have 00eii consumed. Take the last dose of .
OSlDoprep with 12 ounces of Ginier Ale. Remain close to the toilet facilities.
Do NOT drink or eat anything after midnight.
Do not take aspirin, iron, vitamin R, or non-steroidal anti-inflammatory pills for .
AiD 1v1( tJhVI ffrtl/Y1.S
Notify your doctor immediately ifyou 4\king any blood thinning
medications or medications that affect blood c . g and medications for
diabetes.
( Make arrangements for someone to escort you home. The sedation will not allow you to )
drive for t 2 hours.
,..
You take your heart and/or blood the morning ofyour test, with a
small sip of water (at least 2 hours are scheduled to arrive for the procedure.)
Ifyou have any questiou, please
Statement 09/01/10 Page: 1
PARK NEST RADIOLOGY PC
Oper: LB
315 " 57TH ST
SUITE LL4
NEW YORK,NY 10019 IRS # 133143253
Tel: 212-684-6605
WASHINGTON, MARCUS Acct: 10008624-1 /BM
54 BaHRUM ST
WASHINGTON. MARCUS
APT 6M ;
BRooKLYN,NY 11206
Ins1: GREAT-WEST HEALTHCARB 101092359
Date Code Description Ot Diag Pry Ref AR Plc Amt Bal
< '"' ,- - " .- -- - , - - ." - ,', - , - <.>,., , - - -.

Balance up to 04/30/10 0.00
04/30/10 70551 MAGNETIC RESONANCE INA 1 340 1 28 HM 0 1050.00 1;'6;",.0
#A10579205
06/04/10 INCK INSURANCE CHECK -599.40
GWHC eK 75978595
06/04/10 COIN APPLIED TO COI1fiSfJ1R.1iNCB 6'6.6fJ 0.00
06/04/10 WONG WRITE OFF MANAGED CARE -384.00
07/27/10 CARD CREDIT CARD CHARGE -50.00
VISA 1928,APPR 100273
04/30/10 74181 MRI ABDOMEN; WITHOUT C 1 789.00 5 28 RM 0 1050.00
#AI0554656
06/04/10 INCK INSURANCE CHECK -412.99
G'WHC eK 75979029
06/04/10 COIN APPLIJiID
1.7"1'. '*'0
0.00
06/04/10 tIONtJ WRITE OFF MANAGED CARE -460.01
Regular Balance $
Previous Total: 193.60 Today's To Date
Charges : 0.00 2100.00
Payments 0.00 -1062.39
Adjustments : 0.00 -844.01
Providers: 1 - LOUIE, WILLIAM lID
5 - KASHANIAN, FARZAM MD
Physicians: 28 - ADLER MD, LAWRENCE A
ADDITXONAli PAYMBNT ON OUTSTANDINGBALANCB ro AVOID lATBPBBS.

E ibit D
THIRTEENTH ANNUAL NYU WORKSHOP
Employment Law for Federal Judges
2010 M
N PARTNERSHIP WITH NYU LAW'S DWIGHT D.
Opperman Institute of Judicial Administration and
the Federal Judicial center, the Center for Labor and
Employment Law gathered judicial speakers and at
tendees, practicing attorneys and several academics in
NYU's Pollack Colloquium for the 13th Annual NYU Workshop
on Employment Law for Federal Judges on March 17-19, 2010.
Among the most highly-rated programs on the FJC's calendar,
the 2010 workshop was extended from a two-day format to
a three-day program. Forty-seven judges from 36 federal
district courts and one federal circuit court attended.
Professor Theodore Eisenberg (Cornell Law) and Professor
Richard A. Nagareda (Vanderbilt Law)
Evidence
Hon. John G. Koeltl (U.S. District Court for the Southern
District of New York); Laura S. Schnell (Eisenberg & Schnell);
Professor Paul Secunda (Marquette University Law);
Robert Whitman (Seyfarth Shaw)
Short I)ri!m,,'1' on Sta.Us1ttcs for Juo!es
Professor Stephen Choi (NYU Law)
Hon. P. Kevin Castel (U.S. District Court for the Southern
District of New York); Laurie Berke*weiss (Berke-Weiss &
Pechman); Jeffrey S. Klein (Weil, Gotshal & Manges)
MematlOlm: Do's Don'ts
Hon. celeste Bremer (Magistrate Judge, u.s. District
Court for the Southern District of Iowa); Hon. Karen Klein
(Magistrate Judge, U.S. District Court for the District of North
Dakota); Marpret Shaw (JAMS); Donna Malin (Johnson &
Johnson)
Class and Actions
Zachary D. Fasman (Paul, Hastings); Adam Klein
(Outten & Golden)
Sex
Hon. Laura Taylor SWain (U.s. District Court for the
Southern District of New York); Terri L. Chase (Jones Day);
Anne VWadeck (Vladeck, Waldman, Elias & Engelhard)
Hon. John Gleeson (U.s. District Court for the Eastern District
of New York); Jonathan Ben-Asher (Ritz Clark & Ben-Asher);
Michael I. Bernstein (Bond. Schoeneck & King)
11:1.<0,1""''''''*'''''' Discovery
Hon. James. C. Francis IV (Magistrate Judge, U.S. District
Court for the Southern District of New York); Theodore O.
Rogers Jr. (Sullivan & cromwell); Pearl Zuchlewski
(Kraus & Zuchlewski)
The Workshop was extended
to a three-day program
and included forty-seven
judges from thirty-six federal
district courts and one
federal circuit court.
Imll3.ct; Affirma.tive Action
Hon. Nancy Gertner (U.s. District (ourt for the District
of Massachusetts); Mindy G. Farber (Farber Legal);
Gary R. Siniscalc:o (Orrick, Herrington & Sutcliffe)
R@ctct:10I1 to
Lee Bantle (Bantle & Levy ); Preston L. Pugh (Pugh, Jones.
Johnson & Quandt, p.e); Professor David sherwyn
(Cornell University)
The highlights of the 2010 Workshop included a well
received mock hearing on the Trade Secrets case, presided
over by Judge Kevin Castel and argued by Laurie Berke
Weiss and Jeffrey Klein, and an introduction to the use
of statistics in employment cases provided by Professor
Stephen (hoi of NYU Law.
Exhibit E
HQI1.Dol'lettaW Ambrose
u.s. Dist.Ct.,.W.D. Jla.
riiI Hon. John C Coughenour
WW. US. Dist. Ct., W:P.Wash.
.. Hon. ErleF. Melgren
. .

U.S. Dist. Ct.,D.Kzt.
.Hon. James L.

. U.S.Dist. Wp.Wash.
aon. Roslyn 0, Silver
U.S. Dist. D. Ariz.
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Washington v. William Morris Endeavor Ent. Et Al. (11-3576) - Appellant's Emergency Motion To Expedite Appeal Exhibits (September 28, 2011)

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UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

U.S; Dist. Ct. S,D.N.Y.

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