Washington v. William Morris Endeavor Ent. Et Al. (11-3576) - Appellant's Reply Exhibits (October 17, 2011)

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
-----------------------------------------------------}(
WASHINGTON,
11-3S76-CV
Appellant,
V"
AFFIRMATION OF APPELLANT'S
REPLY FOR EMERGENCY MOTION
WILliAM MORRIS ENDEAVOR AND oPPOSmON TO APPELLEES'
ENTERTAINMENT, LLC, et 81., MOTION TO DISMISS APPEAL FOR
LACK OF JURISDICTION
Appellees.

I, Marcus L Washington, affirm under penalty of perjury that:
1. I, Marcus 1. Washington, am'the Appellant in the above entitled action, and
affirmation to the motion dated October 17, 2011 made by myself asking that the
following relief: a grant of the proposed expedited scheduling order and expedited appeal
harmfully biased order of Hon. Castel granting the Appellees' request to compel this issue into
arbitration. Also opposing Appellee'S cross-motion to dismiss appeal for lack of jurisdiction.
2. I have personal knowledge of facts which bear on this motion because as a fonner 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 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, address the ineffectiveness of the Civil Rights Act of 1964 in eradicating these
intentional barriers, and additionally address Hollywood's cabal-like practices which plays a pivotal role in
perpetuating racism in America and throughout the world; 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 article from Miami New Times awarding
Ego Miami Magazine ''Best Local Zine - 200S
n
and citing me personally as a "talented writer" written on
during the month ofJune 2005.
Case: 11-3576 Document: 31 Page: 1 10/17/2011 421086 24
5. Attached hereto as Exhibit B is a true and correct copy of email correspondence sent to SVP of
Contemporary Urban Music - Can Lewis - regarding an artist I suggested William Morris sign on or
about March 31, 2010. Additionally attached is a Billboard article titled "J. Cole Debuts at No.1 on
Billboard 200, Blink-182 Snags No.2" from October 5, 2011.
6. Attached hereto as Exhibit C is a true and correct copy of cover sheets to the various FRCP 59(e)
Motion for Reconsideration rough drafts I worked on dated from July 28, 2011 to August 3, 2011.
7. Attached hereto as Exhibit D is a true and correct copy of Notice of Appeal and Fonn D-P
submitted to the District Court and Second Circuit respectively on or about August 10, 2011.
8. Attached hereto as Exhibit E is a true and correct copy of the notice received by the Second Circuit
stating that I was in default of not turning in my Fonn D-P dated September 13,2011.
9. Attached hereto as Exhibit F is a true and correct copy of the docket sheet from the Southern
District of New York submitted by the Appellees as an exhibit to deceive the Court that I was in default
of not turning in my Fonn D-P dated October 7, 2011.
10. Attached hereto as Exhibit G is a true and correct copy of most updated Second Circuit Docket
Sheet dated October 11, 2011.
11. In view of the foregoing, it is respectfully submitted that the motion should be granted.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: New York, New York Respectfully submitted,
October 17, 2011
By: ~ ~ . - < s J ..~
Marcus 1. Washmgton
54 Boerum St. Apt. 6M
Brooklyn, NY 11206
(646) 504-6497
humanrights.areamust@gmail.com
., .
. ExhibitA
...... & Places
Bars S. Clubs Food & Drinks People & Places Shopping & Services
BEST LOCAL ZINE - 2005 Comments CO)
Ego Miami
BEST LOCAL ZINE Ego Miami Since it was revived last year, the magazine
Miami BEST LOCAL ZINE - Ego Miami - Best Of Miami - Miami New Times Page 1 of3
!Search Miami New Times
Slideshows
Closer Look: The River
Seafood & Oyster Bar
Showing- 0 comments
Sort by
Real-time updating is enabled. (Pause)
Madame Monsters with eire X
at Score
Slideshows
Oktoberfest 2011 at Fritz & Franz Bierhaus
Best Of Award
fonnerly known as Ego Trip has grown into a guil1 pleasure for readers who pick up the pocket-size
monthly at reataurants, bookstores, and other locations. Like every other lifestyle glossy in town, Ego
Miami is drenched in decadent fashion layouts, innocuous Q&A interviews with real estate moguls and
socialites, the occasional profile piece about pop celebrities such as Gwen Stefani and the boys in Green
Day, and a phalanx of picture pages capturing the prettiest and most stylish creatures of nightlife. But Ego
Miami is crafbly assembled with more panache than the others. owing to a clever graphic design and
talented writers such as Anna Maria Diaz-Balartand Marcus Washington.
Readers' Choice: Ocean Drive
BEST11{ADE (SPORTS T10\.,\1) BEST NOTSO-CHEAPTflRlLL
Email :AI Priot
t,) Friend .5!J Artide
Take the Best Of MiamI with you on
your IPhone or Andrckf with our free app.
Also InclUded: Best Of award
winn9i"S from more than 30 cities'
DOWNLOAD HERE
Like
Add New Comment
Sign in with an option below
01' if you don't have an IlCf)fllll1t, plellse tmter n (;l)fmnent lind dkk Post ... \5 to conmwnt as a gU0St
Search Best Of Awards
Best Of - Previous Years
for free stuff. concert and dIning
Info & more!
email
http://www.miaminewtimes.comlbestof/2005/awardlbest-Iocal-zine-427601 10/14/2011
" .
Exhibit B
Gmail - J. Cole show Page 10f1
Marcus Washington <marcus92184@gmail.com>
il
J. Cole show
2 messages
Marcus Isaiah Washington <marcus92184@gmail.com> Wed, Mar 31,2010 at 12:18 AM
Reply-To: marcus92184@gmaiLcom
To: Cara Lewis <clewis@wmeentertainment.com>
Line around the block. Sold out. Great show. People knew his records. Great interaction with crowd. Talib and
Hi Tek made an appearance. Previewed a song from new album - dope production and lyrics. Real hip-hop.
You got to sign him. On 'the cover of The Source and XXL right now. Great support act for NERD, Kanye,
Lupe and a lot of acts on your roster.
Marcus I. Washington
Sent via BlackBerry
Marcus Isaiah Washington <marcus92184@gmail.com>
Reply-To: marcus92184@gmail.com
To: Cara Lewis <clewis@wmeentertainment.com>
[Quoted text hidden}
Wed, Mar 31, 2010 at 12:31 AM
https://mail.google.comlmaill?tf=1&ui=2&ik=9d72795a71&view=pt&q=j%20cole&sear... 10114/2011
J. Cole Debuts at No. 1 on Billboard 200, Blink-182 Snags No. 21 Billboard.com Page 1 of2
Bilileotarcd.com
J. Cole Debuts at No.1 on Billboard 200, Blink-182 Snags No.2
by Keith Caulfield, L.A. I October 05, 2011 11 :00 EDT
Just one week after we saw 85-year old Tony Bennett grab his first No.1 album on the Billboard 200 chart with "Duets II," another
artist nets his first No.1 -- but he's a little younger.
Rapper J. Cole, 26, bows in the No.1 slot with "Cole World: the Sideline Story ," selling 218,000 copies according to Nielsen
SoundScan.
It's the Roc Nation/Columbia artisfs first album and marks the first time a solo act's debut effort has entered at No.1 since May 14,
2010. That week, B.o.B started at No.1 with ''The Adventures of Bobby Ray" with 84,000. Cole's launch is the highest sales week
for any act's debut chart effort since Nicki Minaj's "Pink Friday" started with 375,000 at No.2 on Dec. 11,2010.
J. Cole Talks 'Cole World': Video Track-By-Track
Rock trio Blink-182 returns to the Billboard 200 with its first studio album in nearly eight years as "Neighborhoods" bows at No.2
with 151,000. The recent Billboard magazine cover stars were last on the chart with "Greatest Hits" in 2005, which debuted and
peaked at No.6 on Nov. 19 with 72,000. Before that, their last studio release, its self-titled 2003 album, bowed and peaked at No.3
with 313,000 on Dec. 6.
The group's new album's lead single, "Up All Night," peaked at NO.3 on the Alternative Songs chart. This week, it slips a spot to No.
4, after having spent six weeks at NO.3.
Blink-182: The Billboard Cover Story
Adele's "21" holds at No.3 with 118,000 (up 1%) while last week's No.1, Bennett's "Duets II," falls to No.4 with 91,000 (down
49%). Lady Antebellum's former chart-topper, "Own the Night," slips 2-6 with 75,000 (down 40%).
Wilco's new "The Whole Love" takes a bow at No.5 with 82,000, marking the fourth top 10 effort for the band. Its last release,
'Wilco (The Album)," debuted and peaked at No.4 off a 99,000 start in 2009. The act's short North American tour launched on
Sept. 13 in Indianapolis and will jump over to Europe beginning on Oct. 24.
Lil Wayne's ''Tha Carter IV" shifts 5-7 with 68,000 (down 20%) just ahead of Switchfoot, as its eighth studio album, "Vice Verses,"
bows at NO.8 with 45,000. Irs the act's second top 10, fol/owing "Nothing Is Sound," which topped out at No.3 in its opening week
in 2005, shifting 131,000 copies. Their last release, 2009's "Hello Hurricane," debuted and peaked at No. 13 with 39,000.
Rock super group Chickenfoot -- Michael Anthony, Sammy Hagar, Joe Satriani and Chad Smith -- debuts at No.9 with "Chickenfoot
III" (42,000). It's the acfs second album, following its self-titled 2009 set, which debuted and peaked at No.4 with 52,000.
Rock band Mastodon scores its first top 10 album as "The Hunter" bows at No. 10 with 39,000. Their previous high came with
2009's "Crack the Skye," which just missed the top 10 -- opening and peaking at No. 11 with a 41,000 launch. The act's will support
the new album on the road, with a tour launching on Oct. 25 in Austin, Texas.
Just outside the top 10 this week, Pink Floyd's reissue of "Dark Side of the Moon" re-enters at No. 12 with 26,000 sold (up 3,607%).
The act re-released 14 of its albums last week and a box set collecting all of the newly refurbished titles. "Dark Side" got the
glossiest redux treatment, as it was available in expanded versions dubbed "Experience" and "Immersion." Each came equipped
with bonus live tracks and assorted outtakes with the lavish "Immersion" edition carrying a list price of $130.
Another classic No.1 album, but of a slightly more recent vintage, also makes a big gain this week: Nirvana's "Nevermind" bounds
146-13 with 25,000 (up 647%). The jump is owed to the 1991 album's 20th anniversary reissue packages that dropped last week.
One of them, a "super deluxe" 70-track version, charts separately and debuts at No. 131 with 4,000.
Moving over to the Digital Songs chart, Adele's "Someone Uke You" regains the top slot, moving 2-1 with 222,000 (up 10%), likely
owed to the recent premiere of its music video. Last week's No.1, Maroon 5's "Moves Uke Jagger" (featuring Christina Aguilera)
descends to No.2 with 198,000 (down 15%).
Brand new at NO.3 is B.o.B's "Strange Clouds" featuring UI Wayne, debuting with 197,000 downloads sold. B.o.B last charted as a
lead act on the Digital Songs chart with "Magic," which peaked at NO.7 in 2010. "Strange" marks his best debut sales week for a
single, previously held by the 137,000 launch of "Airplanes" on May 1, 2010.
Foster the People's "Pumped Up Kicks" slides 3-4 with 177,000 (down less than 1 %) while LMFAO's "Sexy and I Know It" skips 6-5
with 161,000 (up 16%). LMFAO's previous hit, "Party Rock Anthem," shuffles down 4-9 with 124,000 (down 17%).
Rihanna's 'We Found Love" rises 7-6 with 147,000 and a 25% gain after the song saw its first full week of availability at digital retail.
Her previous single, "Cheers (Drink to That)" holds at No.1 0 with 96,000 (down 16%).
Gym Class Heroes' "Stereo Hearts" (featuring Adam Levine) drops 5-7 with 140,000 (up less than 1%) as David Guetta's 'Without
http://www.hillhoard.com/jsp/tiles/news/print-article.jsp?decorator=print&confinn=true 10/14/2011
. .
Exhibit C
Plaintiff,
Defendants.
---' , -----..~ - - - ' " -','-:-...M-'-..-,..- , - - - - - - - " - ~ - - x
C(3(1,,- "202.,'22&.
77tb
'. .
Exhibit D
\
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
MARCUS ISAIAH WASHINGTON
(In the space abOve enter thi}uU name(s) o} thi plamtijj(s)lpelttzoner(#)
9647
- against-
NOTICE OF APPEAL
WILLIAM MORRIS ENDEAVOR ENTERTAINMENT, llC.; formerly the
IN A CIVIL CASE
WILLIAM MORRIS AGENCY; JEFF MEADE and SARAH WINIARSKI
(In the space abOve enter the/un name(s) o/the de/endU.nt(s}lrespondent(s).)
Notice is hereby given that _______M_a_T_cu_s_'_sa__ ia_h_W_'_as_h_ing......;.....to....;.n _______...,........_..,......,._
(party)
hereby appeals to the United States Court of Appeals for the Second Circuit from the Judgment
erroneously granting Defendants' motion to compel Plaintiff into arbitration. Judge Castel's deliberate refusal to
(describe the judgment)
decide on the unchallenged arguments raised in my opposition, resulted in a glaring omission of pertinent facts
and a manifest error in'the usage and application ofthe prevailing law.
entered in this action on the __2_0__day of ___J_u_ly___, 20_11__
(date) {month} (year)
S4 BoeTum St. Apt. 6M
Address
Brooklyn, New York 11206
City, State & Zip Code
August 10 2011
( 646 ) 504 _ 6497
DATED:
--------- -,-'
Number
NOTE: To take an appeal. this form must be received by the Pro Se Office of the Southern District ofNew York within thirty
(30) days ofthe date on which the judgment was entered. or sixty (60).days if the United States or an officer or agency of the
United States is a party.
Rev. 0511007
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCmT
CIVIL APPEAL TRANSCRJPT INFORMATION (FORM D-P)
FOR PRO SE APPELLANTS
A PRO SE APPELLANT MUST FILE tHE ORIGINAL OF THIS FORM WITH THE CLERK OF THE SECOND CIRCUIT IN ALL
CIVIL APPEALS WITHIN 14 CALENDAR DAYS AFTER FILING A NOTICE OF APPEAL.
THIS SECTION MUST BE COMPLETED BY APPELLANT
CASE TITLE
Washington v. William Morris
Endeavor Entertainment, LLC,
et. al.
DISTRICT
Southern District of New York
DOCKET NUMBER
10 Civ. 9647
JUDGE
P. Kevin Castel
APPELLANT
Marcus Isaiah Washington
COURT REPORTER
NJA
PRO SE APPELLANT
Marcus Isaiah Washington
Check the applicable provision:
o 'am ordering a transcript.
am not ordering a transcript
Reason for not ordering a transcript:
o Copy is already available
below);
No transcribed proceedings
o Other (Specify in the space
PROVIDE A DESCRIPTION, INCLUDING DATES, OF THE PROCEEDINGS
FOR WHICH A TRANSCRIPT IS REQUIRED (i.e., oral argument. order from the
etc.) .. '
.. ,
_..... ;
-
0
.-
..
MEmOD OF PAYMENT o Funds
.. r-.J
D Ci..{,.VouebiltCJA 21)
"i' "
INSTRUCTIONS TO COURT REPORTER:
o PREPARE TRANSCRIPT OF
PRE-TRIAL PROCEEDINGS
o PREPARE TRANSCRIPT OF TRIAL
o PREPARE TRANSCRIPT OF
OTHER POSTTRIAL PROCEEDINGS
o OTHER (Specify in the space below):
DELIVER TRANSCRIPT TO: NAME, ADDRESS, TELEPHONE)
I certify that I have made satisfactory arrangements with the court reporter for payment of the cost of the transcript.
See FRAP lO(b). I undentand that unless I have already ordered the transcript, I shall order its preparation at the time
required by FRAP and the Local Rules.
APPELLANT'S SIGNATURE..

DATE
10, ZoDll
. -
COURT REPORTER ACKNOWLEDGMENT: Tbls section Is to be completed by the court reporter. Return ODe copy to the Clerk oftbe Second Circuit.
DATE ORDER RECEIVED ESTIMATED COMPLETION DATE ESTIMATED NUMBER OF PAGES
SlCNATlJRK OF COURT RJ:PORTKD DATE
'. .
Exhibit E
UNITED STATES COURT OF APPEALS
for the
SECOND CIRCUIT
At a Stated Term ofthe United States Court of AppealsfortheSecondCircuit, held at
the Daniel Patrick Moynihan United States Courthouse" 500 FearlStreet, in the City ofNew
York, on the 13
th
day of September, tw() thousand and eleven,
Marcus Isaiah Washington,
Plaintiff - Appellant, .
ORDER
Docket Ntimber: 11..3576
v.
william Morris Endeavor Entertainment, LLC, AKA
The William Morris Agency, Incorporated, Jeff Meade,
Sarah Winiarski,
Defendants.- Appellees.
A notice of appeal was filed on August 10,2011. Appellant's Fonn D.;.P was due August
24, 201L The . case is deemed in default.
IT IS HEREBY ORDERED that the appeal will be dismissed effective October 04, 2011
ifthef.ormis not filed bythatctate.
For The Court:
Catherine O'Hagail Wolfe,
Clerk ofCourt
. .
Exhibit F
81
Case: 2:10-cv-Oa647-PKC -JCF As of:10/07120tt 10:03 AM .EDT 1 of 3
APPEAL, CASREF
u.s. District Court
Southern District of New York (FC)leySquare -Suspense)
CIVIL DOCKET FOR
W Morris Endeavor Entertainment, LLC et Date Filed: 12/22/2010
Jury Demand: Plaintiff
Assigned to: Judge P .Kevin Castel NatureofSqit:442 Civil Rights: Jobs
Referred to: Magistrate Judge James C.Francis JUrisdiction: Federal Question
Case in other court: US.Courtof Appeals, Second CircUit,
1)-03576
Cause: 42:2000eJob Discrimination (Employment)
Plaintiff
Marcus Isaiah Washington represented by MarcusIsaiah Washington
54BoerumSt
Apt#6M
Brooklyn, NY 11206
PROSE
v.

William Morris Endeavor representedby Christian D Carbone
ElltertllinDlent, LLC . Lbb&Loeb LLP
formerly known as 345 Park Avenue
The William Monis Agency;_ Inc. New Y()rk, NY 10154
. (212) 407-4852
fa.",: (212) 407--49.90
Email: _ccarbone@loeb-com
Michael Philip_Zweig
Loeb &Loeb LLP
345 Park.Avenue
New Yotk;NY 10154
(212) 40].c.4960
Fax: (212) 407-4990
Email:mZwei&@loeb.com
Defendant
Jeff Meade represented byCbristian DCarbC)ne
(See above for address)
MichaelPbiHp Zweig
(See above for address)
Defendant
Sarah Winiarski represented by ChristianU Carbolle
(see above. foraddress )
Michael Philip Zweig
(See aboveforaddress)
.DateFiled # Docket Text
12/22/2010
1
:QECLARATION IN SUPPORT OF REQUEST TO PRQCEED IN FORMA
PAUPERIS. Document filed by Marcus !sahih. Washington.(mro} (Entered:
12/30/2010)
Case: As bf:1 O/07120l110:03AM EDT 2of3
12122/2010
l
. COMPLAlNT against Jeff Meade, WilljamMoms :Endeavor Entertainment, LLq,
Sarah WiJliarski. Documenffiled by Marcus Isaiall Washington. (Attachlllents: #.1
part 2, #.1 part 3, #..l part 4)( mro) (Eiltered: 12(30/Z010)
0110412011
1
ORDER: Leaveto proceed in thisCotli"t without payment of feesis authotized.28
U.S.C.19I5. SO ORDERED. (Signed by Pr.eskaon 1/4/2011)
. (mbe) .(Entered:Ol/04/2()1l)
01/04/2011
!
NOTICEOF CASE ASSIGNMENTto KeyinCastel. Judge Unassigned is
no . longer to the case. (sjo) (Entered: 01/04/20 11)
0110412011 :?y1agistrate Judge lamesC.Francis IV isso designatd... 011(4/2011)
01104/2Q 11 Mailed notice re:,.! Notice of Case AssigntneIit!Reassigrn:tienttothe attomey(s) of
record. (sjo) (Ente.re4: 01104/2011)
o1I10/201 1
1
ORDER: The Clerkof Courtis directed to issueaS1.IJTU1ions in this action, and
Plaintiffisdirected to serve the Summonsang
(Sjgned by JudgeP. Kevin Castel on 01110/2011)
01l23/2011 24 MARSHAL'SPROQESS RECEIPT . AND 'RETURN OFSERVICE EXECUTED
Summons arid CornPlaintseryed. Jeff Meade serve<;iqn 31712011, answer due
3/28/2011. Service byLori Odierno; 1126/11 Sent outfor mail ..
service,norespons; 2/25/11 Set up for Per/Service U.s)
01/25/2011 FRCP 4 (Service Package Givert) to plaintiffat Pro se Service Counter. The service
package included: an original summons, copies of the<sumlTl,ons; ft:certified In
Fol1ila Pauperis Application{IFP), copies complaint, United States
Marshal (U.S.M.-285) fonns,apro sehandbook,changeofaddress postcards,
Judge's individual rules, instructions on how to file. amotion and opposition,
instructioIl$ OIr filing an amended complaint,application fotcoup$el, Ci cQnsehtto
proceed before a Magistrate J,udge, andaffmnation of service forms. (vj)(Entered:
01125/2011)
01/25/2011 SUMMONS ISSUED as to Jeff Meade, William Moms ElldeavorEntertainment,
LLG, Sarah Winiarski. (vj) (Entered:. 03./Q3/20 11)
02/04/2011
a
O:RDER REFERRING CASE TO MAGISTRATE JUDGE. Order ihat case be
.. referred to the Clerk of Court Magistrate Judge Jot Genenll
,Pretrial (includes motions, and .
settlement). Referred.to Magistrate James C:Francis. (Signed by JudgeR
.KevillCiJ$telon 2/3/2011) (tro) {Entered: 02/04/2010
.02/09/2011
2 ENDORSED LETTER addressed to Judge P.Kevin ..Zweig
2/8/2011 re:Counsel request apre-"'motioncgnferem::e.ENDORSEMENT:
Promotion conference motionbe.Feb 25.,.Response due Marc1l21.
Reply due Apri16. So Ordered. (Signed by Judge P . KeyinCastel on 2/9/2011)
Gfe}(Entered:02/0912011)
02114/2011
III :Letter add.tessed to Judge P. Kevin Castel from Marf\ls
'02/14/11 re: 2(A)(1) ofYour Honor's IndividualPractices, lal1l
given three business days to respond to themovingpartis' (91lectively, "WME")
request to a Pre-Motion Conference withtheirttentofcoOlpelling arbitration due
the signed arbitration agreement andlorto xnycomplaint pursuant to .the
Federal Arbitration Act. I ask that their.l'equest'be dismissed by the Court, for
forth briefly below. Document filed by Marcus Isaiah W8$bington.(rmj)
(Entered: 0211612011)
02/17/2011
11
MEMO ENDORSEMENT on re:..lO. Letter,ENDORSEMENT:lhavereyiewed
Mr. Washington's letter and I adhere to my Order ofEebruary 9, 2011. Mr.
Washington will have a full opportunity to oppose.themotiotlo;n its merits.
(SignedbyJudgeP. Kevin Castel on 2/1fj/ll}(pl) (Enteted:.021l7./2011)
,02/25/2011 12 MOTION to Dis111iSS the plain,tiffscomplaintor, in the alterqatiye, a stay ofthis
actiQripending arbitration.
Endeav:or Entertainment, LLC, Sarah WiniarskL(mro) (Entered: 02/28/20}1)
Case:2:tO-cv-09647 -PKC -JCF As of: 10/0712011 10:03 AM .EOT 3()f 3
02/25/2011 13 MEMORANDUM OF LAW in Supportre:12MOTlON t9
filed by Jeff Meade, William Morris Endeavor En.tertainment, LLC, Sarah
Winiarski. (mro) (Entered: 02/28/2011)
0312112011
.l!
MEMORANDUM OF LAW ill Oppositioll re: 12 MO'(ION to Dismiss. Document
filed by Mar:cus Isaiah Washington. (mro) (Entered: 03/23/2011)
03/21/2011
11
AFFIRMATION of MarcusL Washillgton 'in Opposition of Defendant's Motion to
Dismiss Of, in the Alternative, for Stay pending Arbitration. Document filed by
Marcus Isaiah Washington. (mbe) (Enterefi: . 03n3/401 1 )
04/05/2011 16 REPLYMEMORANDUMOF LAW in Support in further support of Motic:mio
Dismiss, or inthealtemative, for Stay pending Arbit1':ation.. Documellt filed by Jeff
Meade, William Morris EndeavorEntertaillffient,LLC, Sarah Winiarski. (mbe)
(Entered: 04/06/2011)
07/20/2011
l.a
MEM.ORANDUM AND ORDER,granting 12 MotioritoDlsllliss.For the reasons
stated.above, defendants'motion(Docket # 12) is GRANTED insofar as they seek
an order staying the litigation. The CletkoftbeCol.lrtis ditectedtotenninatethis
motion. This case is placed on the susperisedocket.CounselfQrdefendants is
directed to provide: plaintiff with copies of any unpu'blished opinions cited in this
Memorandum and Order. (Signed by Judge P. KevinCasteLon 7/20/11) (PI)
(Elltered;07121120 11 )
08/10/2011
II
NOTICE OF INTERLOCUTORY APPEAL fr6m..ia Order on Motion to Dismiss.
DOcument filed by Marcus Isaiah
08/10/2011 Appeal Remark astQ.2.l Appeal filed by MarcusIsaiah
Washington. NO FEE. IFP GRANTED 114/11.
08/1112011 19 MARSHAL'S PROCESS RECEJPTANDRETIJRNOF SERVICE EXECUTED
Surntnons and Complaint served.William.MorrisEndeavQrEntertainment, LtC
served on 31712011,.answer .cllle 3/28/20 ll.$ervice was by Odie.mo,
DocUIIlellt fileg'byMarcus Isaiah Washington. (mrQ) (pntered:
. 08/11/2011 20 MARSHAL'S PROCESS RECEIPT "ANJ)RETURN.oF SERVICE EXECUTED
. Summons and Complaint served. Sarah Winiarski served on 3/7/2011 ,answer due
3/28/2011. Service was accepted by Loti Odiemo. Document filed by Marcus
Isaiah Washm,gton. (mro) (Entered:. 08/] 512011)
08116/2011
21
Acknowledgment Letter Mailed: Appeals aCk:rlowleciglllent letter mailedto the
plaintiff via USPS to the address noted on the Notice of Appeal on 8/16/11. (rmj)
11) ..
081 Hl/20 I I
II
Memorandum to the Specialist for the tJSCAsent. to the District Court
Appeals Clerk. (rmj) (Entered: 08/16/2011)
08/18/20ll Transmission of Notice of Appeal and Certified CQPyofDocket Sh,eetto {]SCourt
ofAppeals re:.2.l Notic .of Interlocutory AppeaL (tp) 08/18/2011)
08/18/2011 rransmission of Notice ofAppeal to tbeI)istrictJudgere:.2lNoticeof
Interlocutory AppeaL (tp) (Eritered:08118/2011)
08/23/2011
21
Appeal Record Sent to USCA (IIldex)..Noticethat the ()riginal index to the record
on Appeal for..ll Notice of Interlocutory Isaiah
W8$hington 3 Copiesoftheinge){, Certified Clerk Certificate and Certified Docket
Sheet were transmitted to the U.S. Court of Appeals. (tp) (nd). (Entered:
08/23/2011 )
08/23/2011 Appeal Record Sent Indexed record on.f\.ppeaIFilesJor.llNotice
of Interlocutory Appeal filed by Marcus Isaial1 Washington were transmitted to the
U.S. Court ofAppeals. (tp) (Entered: 08123/2011)
09/09/2011 USCACa,se NUn1ber 11-3576 from the 1)S Court ofAppeals, Second Circllit
assignedto.ll Notice of Interlocutory Appeal filed by Marcus Jsaiah Washington.
(nd) (Entered: 09/09/2011) . . .
.
Exhibit G .
. 1-3576 Page 1 of4
General Docket
Court ofAppeals, 2nd Circuit
Court of Appeals Docket #: 11,.3576
Nature of Suit: 3442 CNIL RIGHTS-Jobs
Wasrungtonv. William Morris Endeavor Entert
Appeal From: SDNY (NEW YORK CITY)
Fee Status: Not Applicable
Docketed: 08/24/2011
Case Type Information:
1)Civil
2) Private
3)
Originating Court Infor,mation:
District: 0208-1 :
Trial Judge: P. Kevin. Castel, U.S. District Judge
TrialJudge: James C. Francis, IV, U.S. Magistrate Judge
Date Filed: 12/2212010
Date Order/Judgment:
07/20/2011
Date NOAFlled:
08110/2011
Prior Cases:
None
Current Cases:
None
IPanel Assignnient: Not available
. Marcus Isaiah Washington
. Plaintiff - Appellant
William Morris Endeavor Entertainment, LLC,
AKA The William Morris Agency, Incorporated
Defendant .. Appellee
leffMeade
Defendant - Appellee
Sarah Winiarski
Defendant - Appellee
. Marcus Isaiah Washington,
[NTCPro Se]
54 Boerum Street,Apt. 6M
Brooklyn, NY 11206
Christian Carbone,
Direct: 212-407-4000
[COR NTC Retained]
Loeb & Loeb LLP
345 Park Avenue
New York, NY 10154
Christian Carbone,
Direct: 212-407-4000
[COR NTC Retained]
(see above)
Christian Carbone,,. .
Direct: 212,.407-4000
..,.......- ., ..'.',,,...
https:llecf.ca2.circ2.dcnlcmecf/servletlDktRpt?caseNum=11-3576&dateFrom=&dateTo=... 10/1112011
I
II
'1-1-3576 PageZ of4
[COR NTC Retained]
(see above)
Marcus Isaiah Washington,
Plaintiff - Appellant,
v.
WilliamMonis Endeavor Entertainment, LLC, AKA The William. Monis Agency, Incorporated, Jeff
Meade, Sarah Winiarski,
Defendants - Appellees.
08/24/2011 C..L NOTICE OF CIVIL APPEAL, with district court docket, on: behalf of
8pg,308.9KB Appellant Marcus Isaiah Washington, FILED. [384809] [11-3576]
08/24/2011 C .2_ DISTRICf COURT ORDER, dated 07/20/2011, RECEIVED.[384812]
IBpg,87S.37KB [11-3576]
08/24/2011 C.,;t DISTRICf COURT RECORD ON APPEAL, FILED.[384816] [11-3576]
lpg, 39.04 KB
08/24/2011
C' ..
ELECTRONIC INDEX, in lieuofrecord, FILED.[384819] [11-3576]
5pg, 270.04 KB
08/24/2011
JiL
FORM D,.P, on behalfof Appellant Marcus Isaiah Washington, FILED,
1pg,66.S2KB
Service date 09/16/2011 by CMlECF.[393500] [11-3576]
09/08/2011
C..5...
INSTRUCfIONAL FORMS, to Pro Se litigant,SENT.[384821] [11-3576]
2 pg,37.1 KB
09/13/2011 ORDER, dated 09113/2011, dismissing appeal by 10/04/2011, unless
C
-1.
Ipg,39.34 KB
appellant Marcus Isaiah Washington, submits form D-P, copy to pro se
appellant,FILED.[389138] [11-3576] .
09/16/2011
J2
SCHEDULINGNOTIFICATION, on behalf of Appellant Marcus Isaiah
2 pg. 92.44KB
Washington, informing Court of proposed due date 10/17/2011,
RECEIVED. Service date 09/16/2011 by US mail.[393511] [1 h3576]
09/16/2011
r:
.1.3_
ACKNOWLEDGMENT AND NOTICE OF APPEARANCE FORM, on
L.'
2pg,117.87 KB
behalf ofParty' Marcus Isaiah Washington, FILED. Service date
09/16/2011 by hand delivery.[396357] [11-3576]
09/22/2011 C ACKNOWLEDGMENT AND NOTICE OF APPEARANCE, on behalf of
3pg,56.19KB
Appellee Jeff Meade, William. Morris Endeavor Entertainment, LLC and
Sarah Winiarski, FILED. Service date 09/2212011 by USmai1.[398376]
[11-3576]
09128/2011 MOTION, to expedite appeal, on behalf of Appellant Marcus Isaiah
21 pg, 1.32 MB Washington, FILED. Service date 09/28/2011 byemail.[405267J[1l-3576]
https:llecf.ca2.circ2.dcn/cmeclservletIDktRpt?caseNum=11-3576&dateFrom=&dateTo:::::... 10/1112011
. "11-3576
Page30f4
'09128/2'011 0 J 8_ SUPPLEMENTARY PAPERS TO MOTION [11], on behalf ofAppellant
28 pg, 1.36 MB Marcus Isaiah Washington, FILED. Service date '09/28/2'011 by hand
delivery.[4'05382][18] [11-3576]
1'0/'07/2011 C 24 MOTION, to. dismiss, on behalf ofAppellee Jeff Meade, William Morris
l13pg,2.68MB Endeavor Entertainment, LLC and Sarah Winiarski, FILED. Service date
10/0712'011 byUSmail. [412552] [11 ..3576]
1'0/'07/2'011 r li OPPOSITION TO MOTION to ~ p e d i t e appeal [11], on behalfof Appellee
24 pg, 288.13 KB Jeff Meade, William Moms Endeavor Entertainment, LLC and Sarah
Winiarski, FILED. Service date 1'0/'07/2'011 by US mail. [412558][25] [11
3576]
https:llecf.ca2.circ2.dcn/cmecf/servlet!DktRpt?caseNum=11-3576&dareFrom=&dateTo=... 10/1112'011

Washington v. William Morris Endeavor Ent. Et Al. (11-3576) - Appellant's Reply Exhibits (October 17, 2011)

Încărcat de

Informații document

Titlu original

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

Washington v. William Morris Endeavor Ent. Et Al. (11-3576) - Appellant's Reply Exhibits (October 17, 2011)

Încărcat de

Drepturi de autor:

Formate disponibile

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

S-ar putea să vă placă și