AMERICAN ARBITRATION ASSOCIATION X MARCUS ISAIAH WASHINGTON, Claimant, CLAI]VL\NT'S R E P L Y M O T I O N F O R -again stW I L L I A M MORRIS ENDEAVOR E N T E R T A I N M E N T , L L C , formerly k n o w n as the W I L L I A M MORRIS

AGENCY, INC., JEFF M E A D E and S A R A H V A N H O V E N , Respondents. X In addition to the reasons expressed in my July 26, 2013 Motion for having Arbitrator L. Gregory's clarify and modify his July 15, 2013 Interim Decision, I submit the most up to date transcript from our July 30, 2013 Conference Call to support this request. See Exhibit A. On numerous occasions throughout the call. Arbitrator Gregory acknowledged many facts over the phone that were not discussed anywhere throughout his deceptively written July 15, 2013 Interim Decision. C L A R I F I C A T I O N AND M O D I F I C A T I O N O F A R B I T R 4 T O R DAVID L . G R E G O R Y ' S J U L Y 15,2013 I I V T E R I M DECISION. A A A Case No. 13 160 01426 12

"There's no doubt you [Mr. Washington] filed enormous amount of paper, much of it, very well presented I thought.'"

"Mr. Washington...[y]ou were quite precise in much of your reading and your commentary and I appreciate that.
When I reread, especially my references to Mr. Rowe and his deposition, and it was an insolicitous use of language on my part when I referred to "another proceeding." What I meant to say was...uh...shall we say uh...I guess I'm still sorta searching for the appropriate word...another, "anotlier avenue" in the current proceeding, so I did not mistake Mr. Rowe as being stranded a decade ago, but I did understand clearly that the document filed in terms of Mr. Rowe's rather e.x'tensive reiteration was and is part of our proceeding. So

dO

appreciate

yOUr

urging of a more precise read."

I will say this, when I first saw the list ["Exhibit 31"], there was very little information on it.

After I saw the Claimant's

In the first Interim Decision, Arbitrator Gregory likened my efforts to that of prominent civil and human rights activists Dr. Martin Luther King, Jr. and Thurgood Marshall, [pg. 9] However, 15 days prior to the conference call, he labeled my arguments regarding the enforceability of the arbitration agreements to be "rhetorically rich" and "conclusory rote" in his July 15, 2015 Interim Decision, [pg. 4.]

papers...there was a great deal more information on that document and it sounds like much of it, if not all of it, but much of it came through the Claimant's endeavors and in some part of the Claimant's papers,
the Claimant Mr. Washington talks about staying several days in the federal courts going through documents to do your best to comply with my requests for more specificity. And HOW, WC

have a document,

thanks to Mr. Washington's

efforts

primarily it seems, that has significantly more information on it than did the original copy
I f the infamous n-word list were to come forward, it seems that from Mr
wasiington s perspective,

almost auy Variation or any version of that document is going to be vulnerable to, at least the possibility, if not probability, of spoliation."'
"As things are situated now, Mr. Rowe's, we'll call it his statement [Affidavit] is centrally situated

as I see your structural, institutional claims ^

"Let's take sexual harassment. Sexism is one of the deeply embedded pathologies in most of human history. You can see thousands of years of that experience portrayed by Camile Pagilia in her book Sexual Personae.

It's not as deeply embedded as racism is in the United States and perhaps even globally, but there's no
question sexism is also a deeply embedded pathology..."^

It is for these reasons that I alleged in my July 26, 2013 submission, before this call took place, that Arbitrator Gregory did a complete "about-face" between his first and second Interim Decision. .Depending on how Arbitrator Gregory's third Interim Decision is written, it should mirror many of these statements above and incorporate the same level of analysis and understanding based on the facts of the case and the pyramid of evidence I've presented to establish every single one of my claims. I would love for the arbitrator to discuss what made him ignore all of the evidence I presented and write a decision which pretended that I did not authenticate "Exhibit 31" already and ' The fact that Arbitrator Gregory has compelled the Respondents to produce the underlying e-mails to "Exhibit 31" after Leonard Rowe's former attorneys stated that "no derogatory terms" ever existed and the Respondents have claimed no racial slur e-mails were produced to them, means that spoliation of evidence occurred in Rowe. By not producing any of the e-mails received from EED, spoliation is occurring again and this is an obstruction of justice. I replied; "Conspiracy, antitrust as well." "The Aj-bitrator cited to his familiarity with the securities industiy's 'boom boom rom' cases and to Camille Paglia's work on sexual harassment - although nothing in this proceeding bears any conceivable relationship to those subjects." [Resp. Motion to Remove, 8.] -2-

explain its relevance to all of my claims. Given your professional experience and achievements, 1 don't think your mistakes were the result of human error, so J believe I am owed some type o f explanation as to why you departed from remaining "neutral" and impartial with your second Interim Decision.

Dated: New York, New York September 13, 2013 Pro Se Claimant 5 4 Boerum St. Apt. 6M Brooklyn, NY 11206 (646) 504-6497 humanrights.areamust@gmail.com