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Exhibit A

Willie E . Gary, Esquire William C . Campbell, Esquire Maria P. Sperando, Esquire GARY, WILLIAMS, PARENTI, FINNEY, L E W I S , WATSON & SPERANDO 221 E . Osceola Street Stuart, P L 34994 Tel: (772) 283-8260 Fax: (772)221-2177 Attorneys for Plaintiffs Rowe Entertainment, Inc., et al.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

R O W E E N T E R T A I N M E N T , INC. et al., Plaintiffs,


vs.

NO. 98-CV-8272 (RPP)

T H E W I L L I A M MORRIS A G E N C Y , INC. E T AL., Defendants

EXfflBITS TO PLAINTIFFS' MEMORANDUM O F L A W IN OPPOSITION TO BOOKING AGENCY DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

VOLUME I I

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Exhibit B

Decision Proposal Flowchart for Arbitrator Gregory: After compelling William Morris, Loeb & Loeb LLP and Michael Zweig to produce hundreds of fraudulently concealed e-mails in Rowe containing derogatory words such as "nigger," the Arbitrator must determine whether or not the two arbitration agreements I signed as a condition of employment and/or its 'Delegation Provision' are procedurally & substantively unconscionable, tainted with illegality, malum in se and were procured through fraud, in addition to determining whether arbitration is an appropriate fomm for this case to achieve the public policy goals of the Civil Rights Act of 1964 and additional human rights and antitrust laws pursuant to Judge Castel's July 19, 2011 order. [Claimant Rep. to Summary Judgment, 26-29.]

Yes, the arbitration agreement is unconscionable and should not be enforced. Fomm is not appropriate.

Allow case to continue in the S.D.N.Y. Impose

Given the harmful delaj- and irreparable damage caused by Respondents and counsel's ethical and criminal conduct, grant summarj Judgment in favor of Claimant on all claims. Impose monetary sanctions against Respondents and coiuisel no less than $100 million. Request that S.D.N.Y. have oversight in enforcing affirmative relief and request that disciplinary sanctions be imposed against counsel for serious unethical and criminal conduct.

If the agreement is upheld after weighing a pyramid of undisputed evidence demonstrating William Morris' 115 year conspiracy to intentionally discriminate against African Americans, all of Claimants claims should be dismissed because each claim is interrelated and there's no possible way your decision would be fundamentally fair, impartial, unbiased or ethical.

monetary sanctions against Respondents and counsel no less than $10U million. Request an e.vpedited trial so a New York City jur\ can determine whether or not the Respondents violated civil rights and antitrust laws. Additionally request S.D.N.Y. impose disciplinar>' sanctions against counsel for serious unethical and criminal conduct.

Determine Damages

Seek to have the award confirmed by the S.D.N.Y.

Exhibit C

A M E R I C A N A R B I T R A T I O N ASSOCIATION
X MARCUS ISAIAH WASHINGTON, : A A A Case N o . 13 160 01426 12

Claimant, -againstW I L L I A M MORRIS ENDEAVOR E N T E R T A I N M E N T , L L C , foiiTierly known as the W I L L I A M M O R R I S A G E N C Y , INC., JEFF M E A D E and S A R A H V A N H O V E N , Respondents.

: : AFFIDAVIT OFLEONARD ROWE


: :

X STATE OF GEORGIA COUNTY OF FULTON ) ) )

SS.:

LEONARD ROWE, being duly sworn, hereby deposes and states: L L Leonard Rowe, have been a concert promoter for 37 years. I am fully familiar with the matters set forth herein and respectfijlly submit this Affidavit in support of the Claimant's reply to the Arbitrator's Interim Decision which requests more information concerning "Exhibit 3]" and most importantly, compels the Respondents to produce the underlying emails which contain racially inflammatory language in reference to African Americans by executives and other employees at two of Hollywood's biggest and most influential talent agencies in not only Hollywood, but throughout the world - the William Morris Agency (now known as William Mortis Endeavor Entertainment) and Creative Artists Agency ("CAA"). Aside from the corrupt attomeys involved in this conspiracy to interfere with the civil rights of myself and all individuals of African descent, I am probably the most knowledgeable person that can discuss this document and vouch for its authenticity. I personally paid $200,000.00 for this evidence to be retrieved during the electronic discovery phase of my case, but the underlying emails have been concealed from me and the court for nearly eleven years by my former attorneys, Michael Zweig, Loeb & Loeb LLP, and others in a conspiracy that is still on-going. In the interests of justice, these emails must be brought forward and all involved in this sinister conspiracy must finally be held accountable for their egregious and morally reprehensible actions.

G E N E R A L BACKGROUND.
2. I have worked in the entertainment industry for over 30 years and during those years, I have dealt with practically all major talent agencies that represent performing musical entertainers of all kinds. I also sewed as president of the Black Promoters Association (BPA) from 1996 to 2006. I have toured entertainers all over America and abroad, such as Michael Jackson, The Jacksons, Prince, R. Kelly, and many others. During my entire career in the music industry, I have dealt with the William Mortis Agency on an on-going basis and have first-hand knowledge of the racist and discriminatory principles, policies and practices of that agency.

3. In 1998,1 - along with three other African American concert promoters - brought an action against the William Morris Agency and 32 other defendants alleging various causes of action including, but not limited to, anti-trust violations, civil rights violations under 42 U.S.C. 1981 and other claims for relief After incriminating evidence was revealed during discovery, 28 of the defendants decided to settle. Three years after extensive discovery, pre-trial motion practice, and oral argument for summary judgment. Judge Robert P. Patterson of the Southern District of New York granted summary judgment to the remaining five defendants. The court's opinion made only a small footnote mention of the derogatory utilization of the terms "nigger" (which were found in the William Morris Agency and Creative Artist Agency's email records some 349 times), "nigga", "spook," "coon," "monkey," and other blatant evidence contained in "Exhibit 31" which undeniably established that racism in Hollywood is not a myth or a figment of one's imagination. The William Morris Agency and Hollywood collectively have been, and continue to operate with a deep animus directed towards persons of African descent and other historically disadvantaged groups. Additionally, Judge Patterson's opinion did not mention substantial documentary evidence that was presented. This evidence contained over 2,000 contracts which showed systemic disparities in contracting between African Americans, who are members of a protected class, versus white promoters who were given more favorable terms and conditions (e.g. 0 - 10% deposits for whites and 50% deposits for blacks) a clear violation of 42 USC 1981. He also did not mention that the William Morris Agency could not produce one contract showing that they have allowed an African American promoter to engage in a contract with one of the white artists on their roster for a concert in their over one hundred plus year history of doing business. Not one. Judge Patterson also made no mention in his opinion that a hand written note that was discovered where an agent stated, "Do not divulge guarantee to black promoters," and hundreds of other pieces of damaging evidence showing discrimination and violation of the anti-trust laws by W M A and CAA. It is extremely important to note that while Judge Patterson weighed certain evidence during the summary judgment phase of our case, he did not consider "Exhibit 31" or the underlying emails because of the criminal actions and ethical misconduct of my former attomeys, Michael Zweig, Loeb & Loeb LLP, the William Morris Agency and others that were involved in this heinous conspiracy. In short, the underlying emails to "Exhibit 31" were improperly and illegally concealed from me and the court.

E L E C T R O N I C D I S C O V E R Y IN R O W E VS. T H E WTLLIAM M O R R I S A G E N C Y : HOW 1 D I S C O V E R E D " E X H I B I T 31" AND WHY T H E U N D E R L Y I N G E M A I L S W E R E N E V E R P R O D U C E D B Y M Y F O R M E R A T T O R N E Y S A T SNR.


4. As our case proceeded and evidence was being discovered, I was unaware of the depth and extent of corruption and collusion that was developing between my former attorneys at Sonnenschein Nath & Rosenthal LLP ("SNR") (formerly known as RubinBaum and now known as Dentons US LLP) - Martin Gold, Raymond Heslin, Richard Primoff, Christine Lepera and Carl Aaron - and attomeys for the Defendants, including Michael P. Zweig of Loeb & Loeb LLP who served as the lead attorney for the William Morris Agency in my case as well. 5. I asked my attorneys during discovery of our case to file a motion to retrieve the emails of the William Morris Agency and Creative Artist Agency. After our motion was granted by Magistrate Judge James C. Francis, my attorneys at SNR informed me that it would cost approximately $200,000.00 to retrieve the emails from the William Morris Agency and CAA for discovery purposes in our on-going litigation, in which I agreed to pay. We continued to use the services of Electronic Evidence Discovery (now known as Discovery Technology, Inc.) - a company from Seattle, Washington - to perform the duty of retrieving the emails. I was then asked by Mr. Martin Gold and Richard Primoff at SNR to provide the names of agent's emails that we wanted BED to search. For the William Morris Agency, I provided the names of the following music agents; Cara Lewis and Jeff Frasco, as well as the heads of the Music Department, Richard Rosenberg and Peter Grosslight. I also provided the names of agents whose emails were to be searched at CAA. I was then asked by
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my attorneys at SNR to provide derogatory words to be searched for, which I also provided and are found on "Exhibit 31." 6. On the day I was told that the results would be in, I began calling SNR early that morning. I was unable to reach anyone at SNR.. .no one would pick up my call. There were five attorneys working on our case at SNR and I found this to be highly unusual because this had never happened before. At 6pm that afternoon, knowing that it was time for everyone to go home for the day, I decided to make one final attempt to reach attorney Richard Primoff. He was the attorney that was overseeing email discovery in our case. Mr. Primoff finally answered my call. I then asked him about the emails and had the results returned. He informed me that they had returned and nothing of substantiality was found as a result of the email search. He then stated that I had lost my $200,000.00 and that it was wasted. When this was being told to me, 1 could tell that he was not being truthful, but at the time I had no proof of this. I later asked for SNR to send all of the email search results and findings, as well as all documents, to me in Georgia. I received the non-privileged emails about one week later at my home in Atlanta. After careflilly examining each document that my former attomeys at SNR provided to me, I found nothing of use that would help us in proving our claims against the William Morris Agency or CAA. Having worked in that industry for over 25 years at the time and experiencing the racism that I and other African Americans had to endure from the William Morris Agency, 1 found this to be totally impossible to believe. 7. A few weeks later, I was called to the office of SNR in New York for a meeting with another attorney that was working on our case by the name of Raymond Heslin. While waiting outside of Mr. Heslin's office for him to finish a phone conversation he was having, I overheard him on the phone with someone discussing a meeting that they had with opposing counsel in my case, a few days prior. This was very alarming to me because I , nor any of the other Plaintiffs, had been informed of this meeting. After he finished his call, I went into his office and as 1 was sitting down, he received another phone call. He then tumed his back to me for privacy. I happened to glance down on his desk and I saw a small stack of papers. On the cover page of that stack, was the heading 'Rowe Entertainment vs. The William Morris Agency Email Results'. It was then that I observed that the word "nigger" was lined down the entire first page of the report. When Attomey Heslin finished his call, I asked him "What is that?" pointing to the email results report on his desk. Mr. Heslin then turned the report over in my face and told me that I was not supposed to see that. I then asked "Why?" since it pertained to my case. Heslin then got very angry and argumentative with me. I immediately left out of his office and called our co-counsel in Florida, Mr. Willie Gary of the Gary Law Firm, and told him about what I saw on attorney Heslin's desk. Mr. Gary then called SNR and asked that the email report, now known as "Exhibit 31," be faxed to him immediately. This is how and why the report shows the fax ID of SNR at the top of each page of the report. They only sent the email results summary report to the Gary Firm. To my knowledge, the actual emails were never sent to the Gary Firm and remain fraudulently concealed to this very day. This is how the Gary Firm eventually gained possession of "Exhibit 31." I tmly believe God intended for me to see that document. Before "Exhibit 31" was faxed on October 15, 2002, my attomeys at the Willie Gary Firm said that they had no knowledge that this document existed. Therefore, SNR attempted to conceal this smoking-gun evidence from my co-counsel as well. 8. "Exhibit 31" was introduced to the court some fime after I discovered the document on the desk of Mr. Raymond Heslin. Discovery in our case was closed at the time in which I discovered it. My attomeys at the Gary Firm argued to have "Exhibit 31" admitted into the record as evidence. At oral argument on the motion, no one from Loeb & Loeb LLP or any of the other defendants claimed that "Exhibit 31" was unauthentic. They claimed the e-discovery protocol had been violated and suggested that my former counsel "surreptitiously conducted searches of mailbox users without CAA's or WMA's prior knowledge or consent." Therefore, they argued, "Exhibit 31" couldn't be "authenticated" and was "inadmissible." Additionally, they argued that discovery was now closed and this document could represent the lyrics from rap music or movie scripts. During
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that hearing, there was never any mention that this document was fraudulent. The fax I D at the top of each page of the document clearly shows that it was faxed from New York office of SNR. SNR has never disputed this fact. Now, Michael Zweig and Loeb & Loeb LLP continue to quote the erroneous decision of Judge Patterson, saying that "Exhibit 31" is an "unidentified and unauthenticated document," thus insinuating that it could be inauthentic or "bogus." I f anyone would pay close attention to "Exhibit 31," they will find that this document is too detailed to be fraudulent. "Exhibit 31" gives precise information - including user names for more than 190 agents, assistants and departments - that no one would be privileged to have other than the company itself or EED - the company that conducted electronic discovery on the backup tapes provided by the William Morris Agency and CAA. It's mind boggling what these attorneys and judges have done in order to ensure that racism and racial inequality throughout this industry and America persists. The level of fraud that has been perpetrated upon the court in my case is beyond the level of criminal prosecution. 9. When I was in Florida at the Willie Gary Firm helping my attomeys prepare our reply to the Defendants' summary judgment motion in April 2003, I personally saw "Exhibit 31" in its entirety. It contained all pages, including 1 and 17 which are now mysteriously missing. At that time, it contained the word "nigger" 349 times, but now, the document submitted to the court reflects a drastically lower number: 76. Like other situations in my case, fraud has occurred somewhere with this document. It is very difficult for me to believe that a qualified attorney such as Mr. Bill Campbell - who received an undergraduate degree from "Vanderbilt University and a law degree from Duke University, was also a former US prosecutor, as well as the former twoterm mayor of Atlanta, Georgia - could make a mathematical error of this magnitude. His accounting of the word being used was off some 273 times, and I find this very hard to believe knowing Mr. Campbell, and how detailed and thorough he is when engaging in his work. Although the word "nigger" being used once is one time too many, the Respondents should simply come forth with the entire exhibit, including pages 1 and 17. This will put the entire issue of how many times the despicable word "nigger" was used to rest. It will also demonstrate the total amount of times the other racially derogatory terms searched for were found as well. 10. Michael Zweig and his co-conspirators have made many excuses for the email result findings. Their first excuse, when first discussed in open court, on the record, was "this evidence could be the results of rap lyrics or from movie scripts." This excuse is laughable because i f that were true, why are the emails being concealed? There would be no harm in bringing the actual emails forward because that would prove that the contents are from the lyrics of rap artists or the scripts of movies. This would totally extinguish our allegations and claims against their clients concerning "Exhibit 31" and would also put all allegations concerning "nigger" and other despicable words being used in their emails to rest. As of yet, they have not done so and they never will, without being forced to do so, because they know that their excuses are totally false and perjurious. The latest excuse they have used is that this document "may be bogus." I f that was tme, then fraud has been perpetrated against CAA and the William Morris Agency, who is probably one of Loeb & Loeb LLP's biggest clients. This fraud would have had to be perpetrated by not only myself and other black concert promoters, but by the Willie Gary Law Firm as well, because they are the ones who submitted this document to the court. Why wouldn't Loeb and Loeb file criminal charges against us i f they tmly believed that fraud took place against their largest client, especially since they adamantly maintain that their client has never engaged in unlawfijl discrimination? They should have demanded a full investigation take place concerning this document. They also could have subpoenaed the files of EED and the fax phone line records of SNR to find out if this document was fraudulent, but they didn't. The reason they didn't do any of this is very simple: they are lying and i f they called in the US Attorney's office or reported this to the FBI, their unlawful conduct, as well as the numerous crimes they have committed, would be revealed. I have asked Judge Patterson, as well as Chief Judge Loretta Preska of the Southern District of New York, on numerous occasions, by personally writing letter after letter and having other concerned American citizens of all races and color do the same, to please refer this case to the US Attorney's Office of the Southem District of New York, the FBL as well as to all state and bar disciplinary committees where these attorneys are licensed to practice law. They both have refiased these requests and have allowed -4-

these criminally corrupt and morally bankrupt individuals to go unpunished for the millions of lives they have destroyed. 11. As of March 2012, my former attomeys at SNR were still denying that any derogatory words existed in the emails of the William Morris Agency and CAA. In their perjurious declarations which they provided to the court under the "penalty of perjury," Attomey Richard PrimofF stated in his signed declaration that since I did not include "Exhibit 31" in my motion papers, he could not be certain about what I am referring to. He further stated that on the contrary, his recollection was that the emails received from the Defendants yielded nothing of use in proving our case. After "Exhibit 31" was retrieved from my case files at the Southern District of New York in Manhattan, I immediately answered their Declarations with a copy of "Exhibit 31" - which was faxed from SNR to the Willie Gary Lav*' Firm - showing the derogatory words that had been used and found in the emails of executives at W M A and CAA. Neither my former attorneys nor the court responded for weeks. Finally, attomey Raymond Heslin responded with a continuation of false statements to the court. They knew that they had been caught lying under oath. With this damaging evidence presented to Judge Robert P. Patterson, along with their perjurious declarations. Judge Patterson still refijsed to honor my request for an oral hearing on the matter and denied my FRCP 60 Motion. For nearly eleven years, Mr. Martin Gold, Mr. Heslin and others at the law firm of SNR have refijsed to honor my request for the hundreds of email documents that rightfially belong to me. Despite my numerous requests for property in which I paid $200,000.00 to obtain, they still refuse to turn over the actual emails to their rightfial owner.

B R I E F L Y ADDRESSEVG T H E W I L L I E G A R Y FIRM'S I N V O V L E M E N T EN THIS CONSPIRACY.


12. Given that the Willie Gary Firm was not involved in electronic discovery, they cannot be held responsible for violating the protocol of Judge James C. Francis. Since EED and SNR refused to provide them with all of the responsive emails, including the underlying emails to "Exhibit 31" and/or the emails contained on compact discs, it was impossible for them to produce to the Defendants emails in "hard copy form with Bates stamps." However, one question that I have been frequently asked is why didn't Attorney Willie Gary pursue the actual emails after "Exhibit 31" was faxed to him by SNR showing the derogatory words being used. The answer to this question is very simple. After reviewing his actions and reviewing the evidence, 1 tmly believe in retrospect that he was also a part of the conspiracy. I believe that he also was compensated by the defendants to do the bare minimum in having these documents produced and just walk away quietly after judgment was made against us. Mr. Gary could have easily filed a motion alleging fraud against his clients by our former attomeys at SNR, but he didn't. The main reason for my beliefs is that Mr. Gary worked on a contingency basis and allowed this type of fraud to take place against his clients. Not only were we defrauded as Plaintiffs, but i f he were not involved in this conspiracy, he and his firm would have been defrauded as well. However, he allowed this fraud to be perpetrated against us, threw us under the bus, and hasn't said a word about the injustices that have transpired in this case since. His silence speaks volumes.

ADDITIONAL E X A M P L E S O F FRAUD B Y T H E W I L L I A M M O R R I S A G E N C Y AND L O E B & L O E B L L P IN R O W E .


13. Concealing "Exhibit 31" and its underlying emails isn't the only example of fraud that occurred throughout my case. Fraud was also committed by the William Morris Agency and Creative Artist Agency during our on-site inspection of their documents. During our inspection - which I was present and actively involved in - we would label all documents that we believed were material to our case so that they could be copied and sent to our attorneys as evidence. We started noticing that the Defendants began removing highly incriminating documents such as the Spice Girls promoter settlement breakdown showing a $70,000 pay out to

each of the white promoters that were invovied. This demonstrated collusion and supported our claims of antitrust. Also, they concealed a letter from Cara Lewis - a Jewish music agent at the William Morris Agency that deals predominately with African American artists - to a Jewish-white promoter by the name of Dick Kloctzman showing race-based disparate treatment, as well as other evidence that proved our claims against them to ensure that we did not receive those documents. After we noticed this was occurring, one of our attorneys from the Gary Firm - Laura L. Mall - began manually copying the documents that were viewed by us as highly important on her laptop computer before we would send them down to be copied. This is how we finally caught them in the act of removing and concealing evidence. When our attorneys from the Gray Firm confronted them and we were able to give them precise information about the documents that were missing, and threatened to go to the court, they finally decided to send over to us the documents that they had removed and attempted to conceal. 14. Another example of fraud being perpetrated upon the court occurred after discovery ended in my case. In or around March 2003, Loeb & Loeb LLP presented a taped phone conversation to the court allegedly between myself and Cara Lewis. I was asked by my attomeys from the Willie Gary Law Firm to listen to the recorded conversation to verify its authenticity. Immediately it became obvious that a voice that was clearly not mine had been inserted into the conversation. The strange voice made racial and vulgar statements to say the least. When I informed my attorneys at the Gary Firm of the fraud that I felt had been perpetrated, they decided to send the taped conversation to a forensic scientist - Steve Cain - to see i f it had been ahered or changed in any manner. Approximately two weeks later, we received a written report from Mr. Cain, in which he stated that the tape had been altered in numerous places and that insertions had been made to the tape as well. The Gary Firm then filed a motion to the court alleging that the tape that was presented was fraudulent and they also submitted the written report from the tape specialist. My attorneys from the Gary Firm also asked the court to order Loeb and Loeb LLP and the William Morris Agency to produce the original tape recording of the conversation in question. The court refiased our request during oral argument on June 1, 2003, stating that discovery was now closed. Finally, the court decided to not allow the tape into evidence. This was another attempt to perpetrate fraud upon the court in my case by Michael Zweig, Loeb & Loeb LLP, and the William Morris Agency.

CONCLUSION.
15. I believe the agency Defendants financed this entire conspiracy and would have never done so without seeing "Exhibit 31," the actual damaging emails, as well as other devastating evidence that proved our claims against them. My attomeys, as well as the Defendants and their counsel, violated a number of federal lavv^s including, but not limited to, the Racketeer Influenced and Cormpt Organizations Act (RICO) as codified 18 U.S.C. 1961 el seq., conspiracy to interfere with civil rights under 42 U.S.C. 1985, and fraud and illegal tampering of evidence under 18 U.S.C. 1506. They also committed numerous ethical violations as well. The conspiracy that has been perpetrated in my case could not have happened without the participation of all parties on both sides. I f any of my many attomeys from SNR or the Gary Firm had raised an issue with the court about the fraud that had occurred, not only with regards to the concealed emails, but also with other matters, this conspiracy could not have taken place or been successfiil. All were handsomely rewarded to the tune of millions of dollars, and they all quietly walked away with their riches hoping that this case would never surface again. They did not care about the lives and families they have devastated and destroyed. 1 have been continuously meeting with the FBI in Washington D C . and New York demanding that something is done about the awfijl crimes that have been committed in my case. Like all tax paying American citizens, I am entitled to equal protection under the law without regard to my race and I will not stop pursuing that righL nor will I tire from fighting, until all of these immoral and unethical individuals are brought to justice for the suffering they have caused millions of people.

16.

I personalK pray that the Arbitrator will continue to remain impartial and substamiaih reward the

Clainiaju in this case. .Also. 1 pray that sanctions wWl be brought against Loeb & Loeb LLP and Michael Zweig to the point that it w i l l punish and serve as a deterrent to all others in the legal community who take an oath to be ethical, then consider engaging in this type o f evil behavior, The\ must be held accountable for intentionall) using the judicial system to subvert the law in order to deprive .African .Americans o f their human and civil rights under the color o f the law a violation o f i 8 USC 242. They must understand that the repercussions for engaging in this t\pe o f unethical and criminal conduct are severe and they are not above the law. To repeat, the documertt in question. -'Exhibit 31." is an authentic document. ! knov, without a shadovv o f any doubt or reservation that the Respondents and their legal counsel are the orchestrators o f this conspiracy because they ha\ coiitinued to benefit from these despicable and egregious crimes against humanity - hence the reason for Marcus Washington's lawsuit. Their awflil conduct has allowed William Morris and others throughout Hollywood to continue their discriminator} practices by den\g minorities an equal opportunity to advance in the entertainment industry. 17. Whether the masses realize this or not. their unlawful and unethical actions have \iolated the civil and

human rights o f miiiions o f .Americans and it's only a matter o f time before the truth is exposed on a world scale. I have hired a new team o f attorneys that wjii be going after each individual attorney, law firm and Hollywood talent agency involved in this corrupt conspiracy to fi-audulenih conceal smoking gun evidence in my case. In similar fashion to your Interim Decision, we will also demand that William Morris, Loeb & Loeb LLP, .Michael P. Zweig and other Defendants in m\e produce and deliver the actual emails underlying "Exhibit 3 1 " to its rightful owner, whiclt is myself Leonard Rowe.

Leonard Rdwe

I. Leonard Rowe, sign this under the penalty o f perjury this

day o f .lune 2013,

iifetan.'

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