Preview
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Exhibit G
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New York State
Division of Human Rights
Case No. 10224523
R (Raj) S. Raghavendra
v.
The Trustees of Columbia University
TABLE OF CONTENTS
OF
SWORN AFFIDAVIT OF COMPLAINANT
(Rebuttal & “NEVER-Allowed-To-Be Litigated” Facts)
Strong Opposition to “Respondent Columbia University’s ( & Proskauer
Rose Attorney’s) Repeated Perjury/Fraud, Baseless Character-
Assassinations of the Racial-Equality-Seeking Complainant as a
So-Called ‘Frivolous Litigant’ & Obstruction of Justice” SCANDAL
To Deprive Basic Constitutional Rights of
Thousands of Black/Colored Employees” Through a
“$650,000 Bribes/Kickbacks, Arbitration Fraud & Judicial Corruption
(Extrajudicial Court Connections)” Scheme
Respondent Columbia University’s Scheme of
Continuing Illegal Retaliation and Systemic Racial Discrimination
in Hiring and Continued Perjury & Fraud on Even the
New York State Human Rights Division
SUMMARY OF FACTS & REQUEST for IN-OFFICE Presentation ……………………1
I. Respondent Columbia University’s/Bollinger’s Inducement
of a FAKE “INCOMPLETE Arbitration” (1-1/2 Page Term Sheet)
Contract to FRAUDULENTLY Misrepresent as a Totally
ILLEGAL, BOGUS, OUTRAGEOUS (ZERO Payment) So-Called
“Settlement Agreement” that Simply NEVER Existed to
I
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Illegally Pay $650,000 in BRIBES/Kickbacks and Illegally
OBSTRUCT a $200 Million Dollars Class Action, OBSTRUCT
Already Scheduled Jury Trial, OBSTRUCT “Minority Employees
Association” and to CONTINUE Systemic Racial Discrimination/
Subjugation & Illegal Retaliation Practices Simply Through
Repeated Perjury/Fraud and Illegal Abuse of Respondent
Columbia University’s Highest Level Extrajudicial Connections
in New York City Courts……………………………………………………..…….....................7
II. Respondent Columbia University’s/Bollinger’s Fraudulent
CONVERSION of the $650,000 Initial Back-Pay Damages
Arbitration Award into Hundreds of Thousands of Dollars
of BRIBES & KICKACKS (In Guise of BOGUS Attorney Fees)
to the 62-Years Old, “Dr. Martin Luther King, Jr. Type”
Racial Equality-Seeking Complainant’s Own Client-Betraying
/1-of-6-Cases/Extrajudicial-Connections/Out-Going/
40-Hours Attorney Louis Stober, Proskauer Rose Attorneys,
and His Co-Conspirators with Direct Aiding & Abetting of
Jurisdiction-Lacking, Extrajudicial-Financial-Interest
(Bribery-Condoning), Non-Recusing (SDNY Judge) Paul A.
Crotty………………………………………………………………………………..…………………18
III. 1-of-6-Cases/Out-Going/40-Hours/Extrajudicial-Connections
Attorney Louis Stober Repeatedly BETRAYED & HIJACKED
His Own Racial-Equality-Seeking Client Raghavendra’s
Multi-Action, Multi-Jurisdiction, Multi-Million Dollars Systemic
Racial Discrimination/Subjugation Litigation by Committing
Repeated Perjury/Fraud with Direct Aiding & Abetting of
Totally UNCONSTITUTIONAL & BOGUS Orders/Sanctions of
Jurisdiction-Lacking SDNY Judge Crotty to SEEK Hundreds of
Thousands of Dollars in Bribes/Kickbacks from Respondent
Bollinger/Columbia University……………………............…………………………….23
II
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IV. Jurisdiction-Lacking, Extrajudicial-Interest, Bribery-Condoning,
(Non-Recusing) SDNY Judge Paul A. Crotty’s UNTHINKABLE
Judicial Misconduct and His “NON-BINDING on New York State
Courts” Totally UNCONSTITUTIONAL, BOGUS, NON-APPEALABLE,
and UNTHINKABLE (So-Called) Orders/Sanctions & Even Threats
of Illegal Imprisonment of the Racial-Equality Seeking Complainant
to COVER-UP the “$650,000 Bribes/Kickbacks, Systemic Racial
Discrimination/Subjugation, Obstruction of Justice, and Judicial
Corruption/Bribery” SCANDAL…….…………………..…………..……………………..26
V. Respondent Bollinger/Columbia FIRED “Constitutional Law
-Abiding” Attorneys Edward Brill & Susan Friedfel to Hire
“$650,000 Bribery-Scandal-Enabling” Corrupt Attorneys
Gregg Mashberg & Evandro Gigante of the Proskauer Rose
Firm to BRIBE Complainant’s Own 1-of-6-Cases Attorney,
Baselessly CHARACTER- ASSASSINATE the “Dr. Martin
Luther King, Jr. Type” Complainant as a So-Called “Frivolous
Litigant”, OBSTRUCT JUSTICE, & DEPRIVE His Basic
Constitutional Rights by Committing Repeated PERJURY/
FRAUD on Multiple New York State Courts, EDNY District Court,
New York State Human Rights Division and the EEOC to
Continue its Systemic Racial Discrimination & Illegal Retaliation
Practices With Impunity……….……………………………………………………..………38
VI. Respondent Columbia’s Own Trustee Ronaldo T. Acosta’s
(Presiding Justice of Manhattan Appeals Court) and
Columbia Law Professor Debra Livingston’s (Chief Judge
of Second Circuit) Repeatedly DENIED Over THIRTY
Different Times Racial-Equality Seeking Complainant’s
Basic Constitutional Right to Even Appeal Any of the
“BOGUS Res Judicata & FRAUD Based” Totally Baseless
& UNCONSTITUTIONAL Federal & State Court Orders
FLOWING from Jurisdiction-Lacking, Non-Recusing,
(Bribery-Condoning) SDNY Judge Paul Crotty’s
(Uninvestigated) Judicial Misconduct & OBSTRUCTION
III
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of JUSTICE After DISREGARDING All U.S. Supreme Court
Judicial Misconduct/Corruption Law & Court Procedures”
TO
Repeatedly COVER-UP Respondent (Prestigious)
Columbia University’s UNTHINKABLE "$650,000 Bribery/
Kickbacks, Systemic Racial Subjugation/Discrimination,
Perjury, Arbitration Fraud, Deprivation of Constitutional
Rights of Black/Minority Employees and Judicial
Corruption SCANDAL...................................................................…………….……………42
A. Respondent Columbia University/Bollinger EXPLOITED Its
Extrajudicial-Connection (Columbia Trustee & Presiding
Justice of the Manhattan Appellate Division Ronaldo T.
Acosta) to OBSTRUCT JUSTICE & OBSTRUCT ALL Litigation
& Appeals to COVER-UP the “$650,000 Bribery/Kickbacks,
Arbitration Fraud, Continuing Systemic Racial Discrimination
& Illegal Retaliation & Judicial Corruption” SCANDAL Related
Claims in New York STATE Courts…………………………………………..…..43
B. Respondent Columbia University/Bollinger EXPLOITED Its
Extrajudicial-Connection (Columbia Law Professor &
Chief Judge of Second Circuit Court of Appeals, Debra
Livingston) to OBSTRUCT JUSTICE, OBSTRUCT ALL Appeals
& Writ of Mandamus Petitions, OBSTIUCT ALL Judicial
Misconduct/Corruption Complaints and Even Section 1983
Litigation in EDNY District Court Against Jurisdiction-
Lacking. Extrajudicial-Financial-Interest (Bribery-Condoning),
Non-Recusing (SDNY Judge) Defendant Paul A. Crotty to
COVER-UP the “$650,000 Bribery/Kickbacks, Arbitration
Fraud, Continuing Systemic Racial Discrimination & Illegal
Retaliation & Judicial Corruption” SCANDAL Related Claims
In New York FEDERAL Courts……………………………………………………..46
CONCLUSION……………………………………………………………………………………………50
IV
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AFFIDAVIT
of
Complainant Rajagopala (Randy) S. Raghavendra
In New York State Division of Human Rights Complaint Against
Respondent Trustees of Columbia University
STATE OF NEW YORK )
) SS:
COUNTY OF NASSAU )
R (Randy) S. Raghavendra being duly sworn, deposes and says that:
SUMMARY OF FACTS AND OR EVIDENCE
THAT WERE NEVER LITIGATED IN ANY COURT OF LAW WHATSOEVER,
AND FOR REQUESTING IN-OFFICE, ORAL PRESENTATION BEFORE THE
NEW YORK STATE DIVISION OF HUMAN RIGHTS
(1) Complainant Raghavendra is respectfully submitting this Affidavit of the
MOST important facts and Controlling New York State & U.S. Supreme
Court Case Law controlling case law as INITIAL REBUTTAL and in
Strong Opposition to “Respondent Columbia University’s ( & Proskauer
Rose Attorney’s) Continuing Repeated Perjury/Fraud on Various Courts,
Baseless Character- Assassinations of the Racial-Equality-Seeking
Complainant as a So-Called “Frivolous Litigant” , Obstruction of Justice
& Deprivation of Basic Constitutional Rights of Thousands of
Black/Colored Employees” Through $650,000 Bribes/Kickbacks and
Illegal Abuse pf Respondent Columbia University’s Highest-Level
Extrajudicial-Connections in New York City Courts
(2) The facts and case law in this Affidavit EXPOSE Respondent Columbia
University’s Scheme of Continuing Illegal Retaliation and Systemic Racial
Discrimination in Hiring and Continued Perjury & Fraud on Even the New
York State Human Rights Division
To Further COVER-UP Recently Discovered
UNTHINKABLE SCANDAL of
(A) “Repeated PERJURY & FRAUDULENT Misrepresentations of an
“INCOMPLETE Arbitration (Binding Mediation)” (1-1/2 Page Term
Sheet) Contract as a Totally ILLEGAL, ABSURD & OUTRAGEOUS (ZERO
Payment) So-Called “Settlement Agreement” that Simply NEVER
1
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Existed and Even WITHOUT Completing the Second Day of Expressly
Agreed Arbitration and ONLY to Offer UNCONSCIONABLE $650,000 in
BRIBES1/Kickbacks (In Guise of BOGUS Attorney Fees) to Complainant
Raghavendra’s Own 1-of-6- Cases/Client-Betraying/ 40-Hours Attorney
Louis Stober (with Extrajudicial Connections), Colluding Proskauer Rose
Attorneys, and Other Co-Conspirators; and
(B) Obstructing Justice by Baseless Character-Assassination of “Dr. Martin
Luther King Jr Type” Racial-Equality-Seeking Complainant as a So-Called
“Frivolous or Serial Litigant” and by Committing Repeated Perjury &
Fraud on the New York State Courts and Federal Courts to Obtain Various
ILLEGAL (Unconstitutional & Non-Appealable) Orders with DIRECT
Aiding & Abetting of Jurisdiction-Lacking, Extrajudicial-Financial-
Interest (Bribery-Condoning2) SDNY District Judge Paul A. Crotty Who
Also facilitated:
(i) $650,000 Bribes/Kickbacks to Complainant’s Own 1-of-6-Cases
/40-Hours/Client-Betraying Attorney Louis D. Stober to Exploit
His Extrajudicial Connections to Jurisdiction-Lacking, Bribery-
Condoning SDNY Judge(s) who would issue totally Baseless, Non-
Appealable, Unconstitutional, & Bribes-Paying, Illegal/Absurd
Orders for Obstructing Justice and Racial Intimidation/Subjugation;
(ii) Fraudulently OBSTRUCT a $200 Million Dollars (Coca Cola &
TEXACO-Style) Class Action3 on behalf of thousands of victims of
1
Respondent Columbia/Out-Going President Bollinger fired his previous law firm in
already ordered/scheduled “Jury Trial for Systemic Racial Discrimination” in New
York State Court and hired the Proskauer Rose firm expressly because it has a
history of Bribing” Plaintiff’s attorneys in major race discrimination cases to betray
and hijack their own clients’ civil rights litigation. For example, Proskauer Rose had
arranged for another one of their clients, Nextel Communications, to pay over
$7 Million Dollars as a “Bribe” (in guise of BOGUS attorney fees) to the Plaintiffs’
attorneys for deceiving their own clients (Class of hundreds of racially discriminated
employees) into totally outrageous (zero payment) and absurd settlement
agreements. One of the partners of that law firm (Steven Morelli) was recently
disbarred and sentenced to prison for stealing from clients. See Johnson, et al
v. Nextel Communications, et. al, 660 F.3d 131 (2d Cir. 2011).
2
Obstruction of Justice, Abuse of Power and or Fraud on the Court by the Court by
Issuing Totally Baseless, Unconstitutional and “BOGUS SANCTIONS” is a strategy
that is commonly used by CORRUPT JUDGES for UNJUST ENRICHMENT of
themselves and or their friends/relatives and to deprive the basic constitutional rights
of the Plaintiff (see, Exhibit 18).
2
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Systemic Racial Discrimination at Columbia during the period of its
WORST Racial Crisis that included Anti-Racism Hunger Strikes,
Racist Nooses, Swastikas, “Black Women Are Only Good for Sex,
Plantation Mentality, and Blacks Were Invented for Cheap
Labor" attitudes, etc (See, Exhibits 4);
(iii) OBSTRUCTION OF COMPLETION of the Already Ordered/
Scheduled “Jury Trial” for Respondent Columbia’s Systemic Racial
Discrimination & Illegal Retaliation Practices by New York State
Court Justices Joan Kelley and Arthur Engoron. The Trial would have
REQUIRED Out-Going President Lee Bollinger to publically testify
regarding his systemic racial discrimination practices; (See Exhibit 3);
(iv) BREACH4 of (Incomplete) Arbitration Contract by Fraudulently
Misrepresenting it as Some Totally BOGUS & ABSURD (So-Called)
“ZERO-Payment Settlement Agreement” that Simply NEVER Existed
and to Deprive the Basic Constitutional Rights of Thousands of
Black/Colored Employees by Fraudulently HIJACKING All of their
Multi-Action, Multi-Jurisdiction, & Multi-Million Dollars Illegal
Discrimination Litigation WITHOUT Paying a Single Penny as
Compensation;
3
Previously, when Ms. Zenobia White-Farrell, a Black woman and former Head of Equal
Opportunity at Columbia herself attempted to initiate a Class Action on behalf of
hundreds of Black employees of Respondent Columbia, Defendant (President)
Bollinger had hired the same, most bribe-arranging attorneys of Proskauer Rose firm to
use most unethical and direct intimidation tactics including counter-suing the Civil
Rights Plaintiff herself to cover-up his institutionalized racial discrimination and
subjugation of Black/minority employees.
In her Court complaint, Ms. White-Farrell provided mind-boggling statistics that showed
“APARTHEID-Style” blatant racial discrimination and fraud at Columbia by using racial
tokens as a cover-up strategy, while using extraordinary intimidation tactics to
suppress rights of Blacks/minorities. She showed that even though nearly three-
quarters (74%) of Columbia’s support (lower grade) staff is minority, only 6% of senior
grade (grade 14 & above) managerial/executive positions are occupied by Blacks.
Further, to add insult to injury, there is at least a $20,000 difference between median
salaries of Whites and Blacks.
4
The U.S. Supreme Court has repeatedly ruled that a fraud in inducement of an arbitration
contract must be resolved only by the Arbitrator and NOT the courts. See, Rent-A-
Center, West, Inc. v. Jackson, 561 U.S. 63, 71, 130 S. Ct. 2772, 177 L. Ed. 2d 403
(2010); Buckeye Check Cash, Inc. v. Cardegna, 546 U.S. 440, 449, 126 S.Ct. 1204,163
L. Ed. 2d 1038 (2006).
3
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(v) CONTINUING Illegal Retaliation & Racial Discrimination in
Hiring of Racial-Equality-Seeking Black/Colored Employees, Including
Highly Accomplished5 Complainant Raghavendra, by Baseless
Character-Assassinations, Perjury/Fraud, and Cover-Up by use of
FAKE Affirmative Action Programs and or FAKE so-called “Equal
Opportunity Policies & Procedures”;
(vi) OBSTRUCTION of the Lawful Organization of the First Equal
Opportunity Promoting “Minority Employees Association” at the
265-Years Old Columbia University by Racial Intimidation & Illegal
Retaliation; and
BY
EXPLOITING the Prestigious Columbia University’s Own Highest-
Level Extrajudicial Connections in New York City Courts Including
Columbia Trustee Ronaldo T. Acosta (Who was Until Recently Presiding
Justice of Appellate Division) and Columbia Law Professor Debra
Livingston (Who is also Chief Judge of Second Circuit Court, to Obstruct
Any Appeals, Obstruct Any Fact-Finding Whatsoever, and Obstruct
Justice Through Sheer Judicial Corruption
(3) To protect all FUTURE victims of this kind of extraordinary bribery/
kickbacks scandal, Complainant is also requesting all New York
State & Federal Legislators to Immediately enact a Much-Needed
“Anti-Bribing of Plaintiff’s Attorney & Corrupt Judges" Act
OR “Anti-Mockery of Justice” Act
(4) On May 25, 2023, the Respondent Columbia University’s attorney, Mr. Evandro
Gigante, of the Proskauer Rose firm has once again attempted to obstruct
justice by committing additional perjury and fraud even on the New York
State Division of Human Rights to cover-up Respondent Columbia
University’s continuing illegal retaliation and racial discrimination in hiring of
the highly accomplished, 62-years old, dark-skinned Black/Indian complainant
and to further cover-up the above “$650,000 Bribery/ Kickbacks, Continuing
Systemic Racial Discrimination & Illegal Retaliation, Obstruction of Justice,
Deprivation of Basic Constitutional Rights and Judicial Corruption” SCANDAL
5
Complainant Raghavendra with TWO Master’s degrees in Engineering and
Finance/Business Administration and over 30-years of professional/executive
accomplishments SACRIFICED his entire professional career and family life (with
THREE minor children) for promoting Equal Opportunity for Black/Colored employees at
the 265-Years old Columbia University.
4
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masterminded by Columbia University’s own out-going President Lee C.
Bollinger.
(5) Because Respondent has once again attempted to obstruct justice, commit
perjury and fraud even the New York State DHR by presenting various “totally
irrelevant, baseless, fraud on the courts, bribery/ kickbacks based,
unconstitutional and non-appealable” orders and other highly deceptive
and bogus “EOAA Policies & Procedures” manual, etc., Complainant is
requesting an in-office and in-person oral presentation of my above
“Continuing Illegal Retaliation, Racial Discrimination in Hiring and Systemic
Racial Subjugation of Thousands of Black/Minority Employees” case of
national importance as soon as possible.
(6) To date, due to the Respondent’s stonewalling, continuing obstruction of
justice, and baseless character-assassination of the “Dr. Martin Luther King
Jr. Type” Racial-Equality-Seeking Complainant as a so-called “frivolous
litigant” even though he not been allowed to litigate at all, there has NOT
been any fact-finding and or discovery whatsoever in any court of law
whatsoever regarding any of the extraordinary facts regarding the
Respondent’s continuing racial discrimination & illegal retaliation, recently
discovered “elaborate fraud, $650,000 bribery, obstruction of justice,
deprivation of Complainant’s basic constitutional rights, and judicial
corruption” scheme.
(7) Because the Complainant’s written rebuttal to the Respondent’s “perjury/
fraud-based” documents includes hundreds of pages of facts, exhibits and
controlling case law, an oral presentation would be absolutely necessary to
“connect the dots” in the otherwise almost impossible to understand the
extraordinary and sophisticated “perjury/fraud, bribery, obstruction of justice
& judicial corruption” scheme and massive COVER-UP.
(8) Also, because the Respondent has fraudulently misrepresented several totally
baseless, UNCONSTITUTIONAL, and NON-APPEALABLE orders (that flow from
the blatantly unconstitutional and non-appealable orders of jurisdiction-
lacking, extrajudicial-financial-interest (bribery-condoning) Defendant
(SDNY Judge) Paul A. Crotty and are also based on the repeated perjury/
fraud on various courts in blatant violation of Judicial Law 487) as its reason
for continuing illegal retaliation and systemic racial discrimination practices,
5
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explanation of the “$650,000 Bribes/ Kickbacks, Breach of Incomplete
Arbitration Contract, Systemic Racial Discrimination/ Subjugation, Obstruction
of Justice, Repeated Perjury, and Judicial Corruption” Scandal requires a
detailed oral presentation. (See 15-page Press Release (Exhibit 1) that
summarizes some of the most important facts of this truly extraordinary and
unconscionable civil rights scandal of recent times and also the related
proposed new “Anti-Bribing of Plaintiff’s Attorney & Corrupt Judges" Act
or “Anti-Mockery of Justice” Act.)
(9) For all intents and purposes, out-going Columbia President Bollinger
(though his bribe-arranging Proskauer Rose6 attorneys) had offered at
least $650,000 in bribes/kickbacks (Quid Pro Quo payments) to the
highly accomplished (Dr. Martin Luther King Type Racial Equality
Seeking) Raghavendra’s own 1-of-6-cases/40-hours attorney Louis
Stober to exploit his extrajudicial–connections to a jurisdiction-lacking,
Bribery-Condoning SDNY Federal Court judge and for obstructing justice
and or for abusing the power of Columbia’s additional highest-level
extrajudicial connections in New York City Courts, including Columbia
Trustee and non-recusing, (Recent) Presiding Justice of the Manhattan
Appeals Court (Hon. Ronaldo Acosta) and Columbia University Law Professor
and non-recusing Chief Judge of the Second Circuit Court of Appeals (Hon.
Debra Livingston).
(10) In a similar presidential misconduct situation, the Board of Trustees of
the University of Michigan (Bollinger's previous employer) had immediately
6
Respondent Columbia’s new attorney Proskauer Rose firm has had a history of “Bribing”
plaintiffs’ attorneys in major race discrimination cases to betray and hijack their own clients’ civil
rights litigation. For example, Proskauer Rose had arranged for another one of their clients,
Nextel Communications, to pay over $7 Million Dollars as a “Bribe” (in guise of BOGUS attorney
fees) to the Plaintiffs’ attorneys for deceiving their own clients (Class of hundreds of racially
discriminated employees) into totally outrageous (almost zero payment) and absurd settlement
agreements. One of the partners of that law firm (Steven Morelli) was recently disbarred and
sentenced to prison for stealing from clients. See Johnson, et al v. Nextel Communications, et.
al, 660 F.3d 131 (2d Cir. 2011).
Proskauer Rose firm and its attorney Gregg Mashberg are named defendants in
OBSTRUCTED 418-2020 (Raghavendra v. Mashberg, Proskauer Rose,Paul A. Crotty) case.
6
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conducted an internal investigation and FIRED their University
President, Mark Schlissel, for his misconduct of a mere improper
relationship with a female colleague.
(11) Also, by recently selecting the first NON-WHITE (Colored Woman),
Dr. Nemat (Minouche) Shafik, to replace out-going President Bollinger,
for all intents and purposes, the Trustees of Columbia University have
CONCEDED that highest-paid, university president Bollinger had been
engaged in an unthinkable "$650,000 Bribery/Kickbacks, Systemic Racial
Subjugation/Discrimination, Perjury, Arbitration Fraud, Obstruction of
Justice, and Judicial Corruption” scandal during his tenure at Columbia
University.
(12) Upon information and belief, Bollinger has been able to COVER-UP this
extraordinary judicial corruption and civil rights scandal WITHOUT any
news coverage whatsoever simply because of Columbia’s improper power
over even the freedom of speech of the journalists. Clearly, no journalist
exposed this extraordinary scandal because he or she does not want to
jeopardize his or her relationship with Bollinger’s “Pulitzer-Prize Awarding
Committee” at Columbia University.
(13) Bollinger’s/Columbia’a bribing of Racial Equality Seeking Raghavendra’s
own 1-of-6-cases7 attorney and or his extrajudicial-connection SDNY federal
court judge(s), obstructing justice, and committing repeated perjury,
arbitration fraud and deception to COVER-UP the judicial corruption
scandal is obvious from the following UNDISPUTED facts.
I. Respondent Columbia University’s/Bollinger’s Inducement of a
FAKE “$650,000 INCOMPLETE Arbitration” (1-1/2 Page
Term Sheet) Contract
FOR
Offering Hundreds of Thousands of Dollars in Bribes/ Kickbacks to
Racial-Equality-Seeking Complainant Raghavendra’s Own 1-of-6-
7
New York State law PROHIBITS one-of-six-cases/out-going attorney Louis D. Stober
from hijacking and or causing any improper dismissal of any of the Plaintiff’s four other
actions Stober was never retained on. See, Hallock v State of New York, 64 NY2d 224
[1984]; Nash v Y & T Distribs., 207 AD2d 779, 780 [2d Dept 1994] [an attorney has no
implied power to settle or compromise a client’s claim by virtue of his or her general
retainer].
7
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Cases/Client-Betraying/40-Hours Attorney Louis Stober (With
Extrajudicial Connections to Jurisdiction-Lacking SDNY Judges) and
TO
HIJACK ALL of His Own Client’s Multi-Action, Multi-Jurisdiction, Multi-
Million Dollars Litigation (for ENDING Columbia’s Systemic Racial
Discrimination/Subjugation Practices) by BETRAYING and Committing
Repeated Perjury and Fraud Against His Own Client
BY
Obstructing Completion of Expressly Agreed Arbitration Under
Jurisdiction of Labor Arbitrator Martin F. Scheinman and Continuing
Fraudulent Misrepresentations of that “INCOMPLETE Arbitration”
Contract as Some Totally BOGUS, FAKE, MEANGINGLESS &
ABSURD So-Called “BRIBES-Payment Settlement Agreement” that
Simply NEVER Existed and WITHOUT Even Paying a Single Penny
of the $650,000 Initial Back-Pay Damages Arbitration Award
(14) Prior to the “Incomplete Arbitration” (Term Sheet) Contract, Civil Rights
Complainant Raghavendra wrote dozens of letters and e-mails to Bollinger,
including a 4-page letter that was titled (Exhibit 2):
“Request for the Lawful Organization of an Anti-Discrimination
‘Minority Employees Association8’ through Immediate
Negotiations.. ...for RESTORING the New York State Rights, U.S.
8
Respondent Columbia/Bollinger ILLEGALLY retaliated against and fired the (Dr. Martin
Luther King type) Racial Equality Seeking Complainant Raghavendra for merely
proposing a minority employee rights promoting“Racial Equality Struggles for
Columbia University Employees” (RESCUE) Association that is similar to the anti-
Discrimination “Black Employee Associations” across America (See Exhibit 4 for copy of
Columbia Memo CONCEDING to a FALSE pretext before an Administrative Judge).
At numerous prestigious organizations across America, Blacks and other minorities have
been allowed to openly organize and form associations to promote Equal Opportunity and
or to oppose any institutionalized racial discrimination and even bringing Multi-Million
dollar Class Actions. Black Employee Associations have been in active existence for
several decades at several universities including University of Pennsylvania, College of
William & Mary, Dartmouth, Clemson, Johns Hopkins, and University of Michigan (while
Bollinger was its President) and other large organizations such as IBM, NASA, etc.
UCAR is University of Michigan’s “United Coalition Against Racism”, a campus anti-
discrimination group that opposed out-of-control racial discrimination and harassment
and publicly announced its intentions to file a civil rights Class Action lawsuit against the
University of Michigan while Lee C. Bollinger was its President and Dean of Law School.
8
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constitutional rights, Civil Rights & NLRA Rights of the Victims of
Racial Discrimination, Anti-Semitism, and or Harassment, Including
Sexual Harassment, at the 250-Years Old Ivy League University”
(15) Previously, Complainant Raghavendra also wrote letters addressed to
Defendant Bollinger from the which were titled (Exhibit 2):
“Blacks, Jews & Other Minorities CANNOT be Denied Re-Hiring
Due to Columbia University’s Prior Illegal Retaliation Firings”
and
“Preventing an Anti-Discrimination “Minority Employees
Association” at Columbia University & Potential Civil Rights
Class Action Through Direct Intimidation & Illegal Retaliation
is Obstruction of Justice.”
(16) Complainant Raghavendra also wrote several other letters to Bollinger
to discuss remedying the problem of systemic racial discrimination
practices at the prestigious 265-years old Columbia University by at least
allowing for lawful organization of First Equal Opportunity Promoting
“Minority Employees Association” while avoiding any immediate $200
Million Dollars (Coca Cola or TEXACO Style) Class Action at the time of
Columbia’s WORST racial crisis. that included Anti-Racism Hunger Strikes,
Racist Nooses, Swastikas, “Black Women Are Only Good for Sex,
Plantation Mentality, and Blacks Were Invented for Cheap Labor"
attitudes, etc (See, Exhibit 5 for copies of over 38 different articles describing
Anti-Racism Hunger-Strikes/Protests, Incidents of Blatant Racism, and Anti-
Discrimination Class Actions that were Viciously Suppressed by Columbia
President Lee Bollinger & See Exhibit 6 for Examples of Lawful Settlements
of Other Similar Multi-Million Dollar Class Actions for Institutionalized Racial
Discrimination at Coca Cola, TEXACO, etc);
(17) Prior to the first day of an “Incomplete Arbitration”, Complainant
Raghavendra had also made extremely clear, through 1-of-6 cases/out-going
attorney Stober that the most he may agree to settle is just one and only the
$650,000 back-pay damages cases in exchange for not initiating the $200
Class Action on behalf of the Black/Colored employees of Columbia but with
the organization of the first anti-discrimination “Minority Employees
Association.” (See, Exhibit 7 for copy of e-mail that makes it clear that the
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primary topic of negotiation involving Arbitrator Martin F. Scheinman would
be the $200 Million Dollar Class Action)
(18) At the end of the first day of “Incomplete Arbitration”, BOTH Bollinger
(through his Proskauer Rose attorneys) and 1-of-6-cases/out-going attorney
Stober themselves conceded and expressly notified Federal Magistrate
Judge Henry Pitman that it was agreed to settle one and only the $650,000
back-pay damages case in which Stober was retained but he had already filed
a motion to withdraw attorney representation based on irreconcilable
differences with his client, Raghavendra. The faxed letter to Judge Pitman
read as follows
Dear Judge Pitman:
This letter is to inform the Court that at a full-day mediation
(incomplete arbitration) session…., the Plaintiff….reached
settlement of the above captioned (back-pay damages,
06-cv-6841) matter with the (Columbia) Defendants.
(See, Exhibit 8 for copy of letter of Stober and Bollinger (Proskauer Rose) to
Federal Magistrate Judge Henry Pitman that ONLY the back-pay damages case
was settled to avoid a $200 Million Dollars Class Action.)
(19) Arbitrator Scheinman had also advised Raghavendra that based on his
repeated letters and emails to assert the equal opportunity rights of the
thousands of minority employees at Columbia, Bollinger had agreed to the
Incomplete Arbitration Contract that would at least allow for lawful
organization of First Equal Opportunity Promoting “Minority Employees
Association” while avoiding any immediate $200 Million Dollars (Coca Cola
or TEXACO Style) Class Action at the time of Columbia’s WORST racial crisis.
that included Anti-Racism Hunger Strikes, Racist Nooses, Swastikas,
“Black Women Are Only Good for Sex, Plantation Mentality, and
Blacks Were Invented for Cheap Labor" attitudes, etc (See,
Exhibit 5 for Columbia University Blatant Racism of President Bollinger );
(20) In the “INCOMPLETE Arbitration” scheduled by Columbia President
Bollinger in collusion/conspiracy with Racial Equality Seeking
Raghavendra’s own 1-of-6-Cases/Out-Going/40-Hours Attorney Louis
Stober, Famed New York Arbitrator, Martin F. Scheinman, already awarded
$650,000 in initial back-pay damages against Columbia University on the
first day of the incomplete arbitration (binding mediation) while
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implementing “Equal Opportunity” policies in exchange for Raghavendra
NOT initiating a potential $200 Million Dollar (Coca Cola & TEXACO Style)
Class Action on behalf of the thousands of victims of systemic Racial
Discrimination in employment at the 265-years old Columbia University;
(21) The 1-1/2 page “$650,000 INCOMPLETE Arbitration” (Term Sheet) Contract
had an expressly Labor Arbitrator had expressly agreed “Arbitration
Clause” giving ONLY Labor Arbitrator Scheinman EXCLUSIVE jurisdiction
over the terms of any kind of (LIMITED) “settlement agreement” and an
expressly agreed “Anti-Bribery Clause” to expressly PREVENT Bollinger/
Columbia from bribing or any giving any kickbacks or even paying a
single penny to “Equal-Opportunity Seeking” Plaintiff ‘s own 1-of-6-
Cases/Out-Going/40-Hours Attorney Stober for BETRAYING his own client
(Plaintiff) in any way, shape or form. (See Exhibit 9 for copy of the
‘INCOMPLETE Arbitration (Binding Mediation)” (1-1/2 Page Term Sheet)
Contract between Respondent Columbia & Complainant Raghavendra).
(22) However, immediately after inducing the “$650,000 INCOMPLETE
Arbitration” (Term Sheet) Contract, Racial-Equality-Seeking Complainant
Raghavendra’s own 1-of-6-Cases/Out-Going/ 40-Hours attorney Stober
started BRAGGING that to exploit his extrajudicial-connections to SDNY
judges including jurisdiction-lacking, bribery-condoning, district court
judges Paul A. Crotty and William Pauley (his neighbor in Garden City, NY),
Bollinger/Columbia had offered him bribes/kickbacks to induce that
“Incomplete Arbitration” Contract.
(23) Late) SDNY Judge William Pauley was a CLOSE friend/associate of SDNY
Judge Paul Crotty and was known to abuse the court system for the direct
benefit of his personal friends/relatives (See Exhibit 17 for copy of news
article showing SDNY Judge Pauley doing extrajudicial favors.)
(24) Obstruction of Justice, Abuse of Power and or Fraud on the Court by the
Court by Issuing Totally Baseless, Unconstitutional and “BOGUS SANCTIONS”
is a strategy that is commonly used by CORRUPT JUDGES for UNJUST
ENRICHMENT of themselves and or their friends/relatives and to deprive the
basic constitutional rights of the Plaintiff (See Exhibit 18).
(25) See Exhibit 18 for 32 different news and other scholarly articles regarding
CORRUPT Judges taking Attorney Bribes, Obstructing Justice, Abusing their
Power, Extorting Bribes and other favors while making a absolute MOCKERY
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of the whole American Justice System. Some of these CORRUPT judges
were prosecuted to the fullest extent of the law and been sentenced to
serve jail time.
(26) 1-of-6-Cases/Out-Going/40-Hours attorney Stober started HARASSING, and
intimidating his own client (Raghavendra) with threats of totally baseless,
absurd, UNCONSTITUTIONAL9, non-appealable, and unthinkable BOGUS
($5,000/Day for LIFE) sanctions and even threats of baseless imprisonment
that would DEPRIEVE him (own client) his basic constitutional rights for
completion, (in blatant violation of every New York State Rules of Attorney
Conduct & Ethics), obstruct completion of the incomplete arbitration,
obstruct completion of already scheduled jury trial, obstruct all other multi-
action pending litigation in multiple jurisdictions, and obstruct equal
opportunity to thousands of Black/Colored employees at Columbia.
(27) See Exhibit 19 for 20 different news articles regarding CORRUPT attorneys
such as Proskauer Rose and Bribe-Seeking/One-of-Six-cases/40-Hours
Attorney Louis Stober who engage in Attorney Fraud, Bribery and other
outrageous acts while making a total MOCKERY of the whole American
justice system. Many of these corrupt attorneys were prosecuted to the
fullest extent of the law and even been sentenced to serve jail time.
(28) On first day of “Incomplete Arbitration/Mediation” it was, therefore, agreed
that Complainant Raghavendra that in EXCHANGE for payment of only first
four years of back-pay damages of $650,000 (A) he would not initiate any
$200 Million Dollar Class Action; and (B) settle ALL “causes of action” in just
one and only “Arbitrator Authorized” NON-Pro Se 06-cv-6841 (“Out-Going
Stober as Attorney on File”) supplementary action even though Complainant
Raghavendra was already in the process of suing him (Defendant Stober) for
9
Jurisdiction-Lacking, Bribery-Condoning White SDNY Judge Crotty’s BOGUS & UNTHINKABLE
“$5,000/day sanctions for LIFE” was totally unconstitutional and illegal because the U.S.
Supreme Court had established law for over 100 years that a district court judge must have
subject matter jurisdiction over the suit before he may issue a valid contempt (sanctions)
order. See, Ex parte Rowland, 104 U.S. (14 Otto.) 604, 612, 26 L. Ed. 861 (1881). Because
extrajudicial-financial-Interest/Defendant judge Crotty repeatedly acted in excess of his
jurisdiction, his orders to extort “Involuntary Releases” from Plaintiff by use of (bogus)
contempt orders are VOID. Id. at 612, 617-18; see also In re Burrus, 136 U.S. 586, 597, 10
S. Ct. 850, 34 L. Ed. 500 (1890);In re Sawyer, 124 U.S. 200, 221-22, 8 S. Ct. 482, 493, 31 L. Ed.
402 (1888); Ex parte Fisk, 113 U.S. 713, 726, 5 S. Ct. 724, 730, 28 L. Ed. 1117 (1885).
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breaching his attorney services contract and or for not litigating the “Back-
Pay Damages (06-cv-6841)” case all the way to a jury trial.
(29) Respondent Columbia University ’s own former attorney Edward Brill
repeatedly argued before the Courts as follows (See, Transcript):
“....the parties intended to be bound by that term sheet as a
contract.......In the term sheet itself, the parties provided that
mediator/arbitrator would resolve that. In effect, it was an
ARBITRATION provision” (emphasis added). (Transcript
Page 11, Lines 7-20)
(30) The “INCOMPLETE Arbitration” Contract also specifically included an
expressly agreed “Anti-BRIBING” clause that acknowledged the Plaintiff’s
already pending “Breach of Attorney Services Contract” and other legal
malpractice claims against 1-of-6-cases/40-hours attorney Stober as follows
(See, Exhibit 9):
“There is an ongoing dispute between the Law Offices of Lo
Preview
FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 Exhibit G FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 New York State Division of Human Rights Case No. 10224523 R (Raj) S. Raghavendra v. The Trustees of Columbia University TABLE OF CONTENTS OF SWORN AFFIDAVIT OF COMPLAINANT (Rebuttal & “NEVER-Allowed-To-Be Litigated” Facts) Strong Opposition to “Respondent Columbia University’s ( & Proskauer Rose Attorney’s) Repeated Perjury/Fraud, Baseless Character- Assassinations of the Racial-Equality-Seeking Complainant as a So-Called ‘Frivolous Litigant’ & Obstruction of Justice” SCANDAL To Deprive Basic Constitutional Rights of Thousands of Black/Colored Employees” Through a “$650,000 Bribes/Kickbacks, Arbitration Fraud & Judicial Corruption (Extrajudicial Court Connections)” Scheme Respondent Columbia University’s Scheme of Continuing Illegal Retaliation and Systemic Racial Discrimination in Hiring and Continued Perjury & Fraud on Even the New York State Human Rights Division SUMMARY OF FACTS & REQUEST for IN-OFFICE Presentation ……………………1 I. Respondent Columbia University’s/Bollinger’s Inducement of a FAKE “INCOMPLETE Arbitration” (1-1/2 Page Term Sheet) Contract to FRAUDULENTLY Misrepresent as a Totally ILLEGAL, BOGUS, OUTRAGEOUS (ZERO Payment) So-Called “Settlement Agreement” that Simply NEVER Existed to I FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 Illegally Pay $650,000 in BRIBES/Kickbacks and Illegally OBSTRUCT a $200 Million Dollars Class Action, OBSTRUCT Already Scheduled Jury Trial, OBSTRUCT “Minority Employees Association” and to CONTINUE Systemic Racial Discrimination/ Subjugation & Illegal Retaliation Practices Simply Through Repeated Perjury/Fraud and Illegal Abuse of Respondent Columbia University’s Highest Level Extrajudicial Connections in New York City Courts……………………………………………………..…….....................7 II. Respondent Columbia University’s/Bollinger’s Fraudulent CONVERSION of the $650,000 Initial Back-Pay Damages Arbitration Award into Hundreds of Thousands of Dollars of BRIBES & KICKACKS (In Guise of BOGUS Attorney Fees) to the 62-Years Old, “Dr. Martin Luther King, Jr. Type” Racial Equality-Seeking Complainant’s Own Client-Betraying /1-of-6-Cases/Extrajudicial-Connections/Out-Going/ 40-Hours Attorney Louis Stober, Proskauer Rose Attorneys, and His Co-Conspirators with Direct Aiding & Abetting of Jurisdiction-Lacking, Extrajudicial-Financial-Interest (Bribery-Condoning), Non-Recusing (SDNY Judge) Paul A. Crotty………………………………………………………………………………..…………………18 III. 1-of-6-Cases/Out-Going/40-Hours/Extrajudicial-Connections Attorney Louis Stober Repeatedly BETRAYED & HIJACKED His Own Racial-Equality-Seeking Client Raghavendra’s Multi-Action, Multi-Jurisdiction, Multi-Million Dollars Systemic Racial Discrimination/Subjugation Litigation by Committing Repeated Perjury/Fraud with Direct Aiding & Abetting of Totally UNCONSTITUTIONAL & BOGUS Orders/Sanctions of Jurisdiction-Lacking SDNY Judge Crotty to SEEK Hundreds of Thousands of Dollars in Bribes/Kickbacks from Respondent Bollinger/Columbia University……………………............…………………………….23 II FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 IV. Jurisdiction-Lacking, Extrajudicial-Interest, Bribery-Condoning, (Non-Recusing) SDNY Judge Paul A. Crotty’s UNTHINKABLE Judicial Misconduct and His “NON-BINDING on New York State Courts” Totally UNCONSTITUTIONAL, BOGUS, NON-APPEALABLE, and UNTHINKABLE (So-Called) Orders/Sanctions & Even Threats of Illegal Imprisonment of the Racial-Equality Seeking Complainant to COVER-UP the “$650,000 Bribes/Kickbacks, Systemic Racial Discrimination/Subjugation, Obstruction of Justice, and Judicial Corruption/Bribery” SCANDAL…….…………………..…………..……………………..26 V. Respondent Bollinger/Columbia FIRED “Constitutional Law -Abiding” Attorneys Edward Brill & Susan Friedfel to Hire “$650,000 Bribery-Scandal-Enabling” Corrupt Attorneys Gregg Mashberg & Evandro Gigante of the Proskauer Rose Firm to BRIBE Complainant’s Own 1-of-6-Cases Attorney, Baselessly CHARACTER- ASSASSINATE the “Dr. Martin Luther King, Jr. Type” Complainant as a So-Called “Frivolous Litigant”, OBSTRUCT JUSTICE, & DEPRIVE His Basic Constitutional Rights by Committing Repeated PERJURY/ FRAUD on Multiple New York State Courts, EDNY District Court, New York State Human Rights Division and the EEOC to Continue its Systemic Racial Discrimination & Illegal Retaliation Practices With Impunity……….……………………………………………………..………38 VI. Respondent Columbia’s Own Trustee Ronaldo T. Acosta’s (Presiding Justice of Manhattan Appeals Court) and Columbia Law Professor Debra Livingston’s (Chief Judge of Second Circuit) Repeatedly DENIED Over THIRTY Different Times Racial-Equality Seeking Complainant’s Basic Constitutional Right to Even Appeal Any of the “BOGUS Res Judicata & FRAUD Based” Totally Baseless & UNCONSTITUTIONAL Federal & State Court Orders FLOWING from Jurisdiction-Lacking, Non-Recusing, (Bribery-Condoning) SDNY Judge Paul Crotty’s (Uninvestigated) Judicial Misconduct & OBSTRUCTION III FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 of JUSTICE After DISREGARDING All U.S. Supreme Court Judicial Misconduct/Corruption Law & Court Procedures” TO Repeatedly COVER-UP Respondent (Prestigious) Columbia University’s UNTHINKABLE "$650,000 Bribery/ Kickbacks, Systemic Racial Subjugation/Discrimination, Perjury, Arbitration Fraud, Deprivation of Constitutional Rights of Black/Minority Employees and Judicial Corruption SCANDAL...................................................................…………….……………42 A. Respondent Columbia University/Bollinger EXPLOITED Its Extrajudicial-Connection (Columbia Trustee & Presiding Justice of the Manhattan Appellate Division Ronaldo T. Acosta) to OBSTRUCT JUSTICE & OBSTRUCT ALL Litigation & Appeals to COVER-UP the “$650,000 Bribery/Kickbacks, Arbitration Fraud, Continuing Systemic Racial Discrimination & Illegal Retaliation & Judicial Corruption” SCANDAL Related Claims in New York STATE Courts…………………………………………..…..43 B. Respondent Columbia University/Bollinger EXPLOITED Its Extrajudicial-Connection (Columbia Law Professor & Chief Judge of Second Circuit Court of Appeals, Debra Livingston) to OBSTRUCT JUSTICE, OBSTRUCT ALL Appeals & Writ of Mandamus Petitions, OBSTIUCT ALL Judicial Misconduct/Corruption Complaints and Even Section 1983 Litigation in EDNY District Court Against Jurisdiction- Lacking. Extrajudicial-Financial-Interest (Bribery-Condoning), Non-Recusing (SDNY Judge) Defendant Paul A. Crotty to COVER-UP the “$650,000 Bribery/Kickbacks, Arbitration Fraud, Continuing Systemic Racial Discrimination & Illegal Retaliation & Judicial Corruption” SCANDAL Related Claims In New York FEDERAL Courts……………………………………………………..46 CONCLUSION……………………………………………………………………………………………50 IV FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 AFFIDAVIT of Complainant Rajagopala (Randy) S. Raghavendra In New York State Division of Human Rights Complaint Against Respondent Trustees of Columbia University STATE OF NEW YORK ) ) SS: COUNTY OF NASSAU ) R (Randy) S. Raghavendra being duly sworn, deposes and says that: SUMMARY OF FACTS AND OR EVIDENCE THAT WERE NEVER LITIGATED IN ANY COURT OF LAW WHATSOEVER, AND FOR REQUESTING IN-OFFICE, ORAL PRESENTATION BEFORE THE NEW YORK STATE DIVISION OF HUMAN RIGHTS (1) Complainant Raghavendra is respectfully submitting this Affidavit of the MOST important facts and Controlling New York State & U.S. Supreme Court Case Law controlling case law as INITIAL REBUTTAL and in Strong Opposition to “Respondent Columbia University’s ( & Proskauer Rose Attorney’s) Continuing Repeated Perjury/Fraud on Various Courts, Baseless Character- Assassinations of the Racial-Equality-Seeking Complainant as a So-Called “Frivolous Litigant” , Obstruction of Justice & Deprivation of Basic Constitutional Rights of Thousands of Black/Colored Employees” Through $650,000 Bribes/Kickbacks and Illegal Abuse pf Respondent Columbia University’s Highest-Level Extrajudicial-Connections in New York City Courts (2) The facts and case law in this Affidavit EXPOSE Respondent Columbia University’s Scheme of Continuing Illegal Retaliation and Systemic Racial Discrimination in Hiring and Continued Perjury & Fraud on Even the New York State Human Rights Division To Further COVER-UP Recently Discovered UNTHINKABLE SCANDAL of (A) “Repeated PERJURY & FRAUDULENT Misrepresentations of an “INCOMPLETE Arbitration (Binding Mediation)” (1-1/2 Page Term Sheet) Contract as a Totally ILLEGAL, ABSURD & OUTRAGEOUS (ZERO Payment) So-Called “Settlement Agreement” that Simply NEVER 1 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 Existed and Even WITHOUT Completing the Second Day of Expressly Agreed Arbitration and ONLY to Offer UNCONSCIONABLE $650,000 in BRIBES1/Kickbacks (In Guise of BOGUS Attorney Fees) to Complainant Raghavendra’s Own 1-of-6- Cases/Client-Betraying/ 40-Hours Attorney Louis Stober (with Extrajudicial Connections), Colluding Proskauer Rose Attorneys, and Other Co-Conspirators; and (B) Obstructing Justice by Baseless Character-Assassination of “Dr. Martin Luther King Jr Type” Racial-Equality-Seeking Complainant as a So-Called “Frivolous or Serial Litigant” and by Committing Repeated Perjury & Fraud on the New York State Courts and Federal Courts to Obtain Various ILLEGAL (Unconstitutional & Non-Appealable) Orders with DIRECT Aiding & Abetting of Jurisdiction-Lacking, Extrajudicial-Financial- Interest (Bribery-Condoning2) SDNY District Judge Paul A. Crotty Who Also facilitated: (i) $650,000 Bribes/Kickbacks to Complainant’s Own 1-of-6-Cases /40-Hours/Client-Betraying Attorney Louis D. Stober to Exploit His Extrajudicial Connections to Jurisdiction-Lacking, Bribery- Condoning SDNY Judge(s) who would issue totally Baseless, Non- Appealable, Unconstitutional, & Bribes-Paying, Illegal/Absurd Orders for Obstructing Justice and Racial Intimidation/Subjugation; (ii) Fraudulently OBSTRUCT a $200 Million Dollars (Coca Cola & TEXACO-Style) Class Action3 on behalf of thousands of victims of 1 Respondent Columbia/Out-Going President Bollinger fired his previous law firm in already ordered/scheduled “Jury Trial for Systemic Racial Discrimination” in New York State Court and hired the Proskauer Rose firm expressly because it has a history of Bribing” Plaintiff’s attorneys in major race discrimination cases to betray and hijack their own clients’ civil rights litigation. For example, Proskauer Rose had arranged for another one of their clients, Nextel Communications, to pay over $7 Million Dollars as a “Bribe” (in guise of BOGUS attorney fees) to the Plaintiffs’ attorneys for deceiving their own clients (Class of hundreds of racially discriminated employees) into totally outrageous (zero payment) and absurd settlement agreements. One of the partners of that law firm (Steven Morelli) was recently disbarred and sentenced to prison for stealing from clients. See Johnson, et al v. Nextel Communications, et. al, 660 F.3d 131 (2d Cir. 2011). 2 Obstruction of Justice, Abuse of Power and or Fraud on the Court by the Court by Issuing Totally Baseless, Unconstitutional and “BOGUS SANCTIONS” is a strategy that is commonly used by CORRUPT JUDGES for UNJUST ENRICHMENT of themselves and or their friends/relatives and to deprive the basic constitutional rights of the Plaintiff (see, Exhibit 18). 2 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 Systemic Racial Discrimination at Columbia during the period of its WORST Racial Crisis that included Anti-Racism Hunger Strikes, Racist Nooses, Swastikas, “Black Women Are Only Good for Sex, Plantation Mentality, and Blacks Were Invented for Cheap Labor" attitudes, etc (See, Exhibits 4); (iii) OBSTRUCTION OF COMPLETION of the Already Ordered/ Scheduled “Jury Trial” for Respondent Columbia’s Systemic Racial Discrimination & Illegal Retaliation Practices by New York State Court Justices Joan Kelley and Arthur Engoron. The Trial would have REQUIRED Out-Going President Lee Bollinger to publically testify regarding his systemic racial discrimination practices; (See Exhibit 3); (iv) BREACH4 of (Incomplete) Arbitration Contract by Fraudulently Misrepresenting it as Some Totally BOGUS & ABSURD (So-Called) “ZERO-Payment Settlement Agreement” that Simply NEVER Existed and to Deprive the Basic Constitutional Rights of Thousands of Black/Colored Employees by Fraudulently HIJACKING All of their Multi-Action, Multi-Jurisdiction, & Multi-Million Dollars Illegal Discrimination Litigation WITHOUT Paying a Single Penny as Compensation; 3 Previously, when Ms. Zenobia White-Farrell, a Black woman and former Head of Equal Opportunity at Columbia herself attempted to initiate a Class Action on behalf of hundreds of Black employees of Respondent Columbia, Defendant (President) Bollinger had hired the same, most bribe-arranging attorneys of Proskauer Rose firm to use most unethical and direct intimidation tactics including counter-suing the Civil Rights Plaintiff herself to cover-up his institutionalized racial discrimination and subjugation of Black/minority employees. In her Court complaint, Ms. White-Farrell provided mind-boggling statistics that showed “APARTHEID-Style” blatant racial discrimination and fraud at Columbia by using racial tokens as a cover-up strategy, while using extraordinary intimidation tactics to suppress rights of Blacks/minorities. She showed that even though nearly three- quarters (74%) of Columbia’s support (lower grade) staff is minority, only 6% of senior grade (grade 14 & above) managerial/executive positions are occupied by Blacks. Further, to add insult to injury, there is at least a $20,000 difference between median salaries of Whites and Blacks. 4 The U.S. Supreme Court has repeatedly ruled that a fraud in inducement of an arbitration contract must be resolved only by the Arbitrator and NOT the courts. See, Rent-A- Center, West, Inc. v. Jackson, 561 U.S. 63, 71, 130 S. Ct. 2772, 177 L. Ed. 2d 403 (2010); Buckeye Check Cash, Inc. v. Cardegna, 546 U.S. 440, 449, 126 S.Ct. 1204,163 L. Ed. 2d 1038 (2006). 3 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 (v) CONTINUING Illegal Retaliation & Racial Discrimination in Hiring of Racial-Equality-Seeking Black/Colored Employees, Including Highly Accomplished5 Complainant Raghavendra, by Baseless Character-Assassinations, Perjury/Fraud, and Cover-Up by use of FAKE Affirmative Action Programs and or FAKE so-called “Equal Opportunity Policies & Procedures”; (vi) OBSTRUCTION of the Lawful Organization of the First Equal Opportunity Promoting “Minority Employees Association” at the 265-Years Old Columbia University by Racial Intimidation & Illegal Retaliation; and BY EXPLOITING the Prestigious Columbia University’s Own Highest- Level Extrajudicial Connections in New York City Courts Including Columbia Trustee Ronaldo T. Acosta (Who was Until Recently Presiding Justice of Appellate Division) and Columbia Law Professor Debra Livingston (Who is also Chief Judge of Second Circuit Court, to Obstruct Any Appeals, Obstruct Any Fact-Finding Whatsoever, and Obstruct Justice Through Sheer Judicial Corruption (3) To protect all FUTURE victims of this kind of extraordinary bribery/ kickbacks scandal, Complainant is also requesting all New York State & Federal Legislators to Immediately enact a Much-Needed “Anti-Bribing of Plaintiff’s Attorney & Corrupt Judges" Act OR “Anti-Mockery of Justice” Act (4) On May 25, 2023, the Respondent Columbia University’s attorney, Mr. Evandro Gigante, of the Proskauer Rose firm has once again attempted to obstruct justice by committing additional perjury and fraud even on the New York State Division of Human Rights to cover-up Respondent Columbia University’s continuing illegal retaliation and racial discrimination in hiring of the highly accomplished, 62-years old, dark-skinned Black/Indian complainant and to further cover-up the above “$650,000 Bribery/ Kickbacks, Continuing Systemic Racial Discrimination & Illegal Retaliation, Obstruction of Justice, Deprivation of Basic Constitutional Rights and Judicial Corruption” SCANDAL 5 Complainant Raghavendra with TWO Master’s degrees in Engineering and Finance/Business Administration and over 30-years of professional/executive accomplishments SACRIFICED his entire professional career and family life (with THREE minor children) for promoting Equal Opportunity for Black/Colored employees at the 265-Years old Columbia University. 4 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 masterminded by Columbia University’s own out-going President Lee C. Bollinger. (5) Because Respondent has once again attempted to obstruct justice, commit perjury and fraud even the New York State DHR by presenting various “totally irrelevant, baseless, fraud on the courts, bribery/ kickbacks based, unconstitutional and non-appealable” orders and other highly deceptive and bogus “EOAA Policies & Procedures” manual, etc., Complainant is requesting an in-office and in-person oral presentation of my above “Continuing Illegal Retaliation, Racial Discrimination in Hiring and Systemic Racial Subjugation of Thousands of Black/Minority Employees” case of national importance as soon as possible. (6) To date, due to the Respondent’s stonewalling, continuing obstruction of justice, and baseless character-assassination of the “Dr. Martin Luther King Jr. Type” Racial-Equality-Seeking Complainant as a so-called “frivolous litigant” even though he not been allowed to litigate at all, there has NOT been any fact-finding and or discovery whatsoever in any court of law whatsoever regarding any of the extraordinary facts regarding the Respondent’s continuing racial discrimination & illegal retaliation, recently discovered “elaborate fraud, $650,000 bribery, obstruction of justice, deprivation of Complainant’s basic constitutional rights, and judicial corruption” scheme. (7) Because the Complainant’s written rebuttal to the Respondent’s “perjury/ fraud-based” documents includes hundreds of pages of facts, exhibits and controlling case law, an oral presentation would be absolutely necessary to “connect the dots” in the otherwise almost impossible to understand the extraordinary and sophisticated “perjury/fraud, bribery, obstruction of justice & judicial corruption” scheme and massive COVER-UP. (8) Also, because the Respondent has fraudulently misrepresented several totally baseless, UNCONSTITUTIONAL, and NON-APPEALABLE orders (that flow from the blatantly unconstitutional and non-appealable orders of jurisdiction- lacking, extrajudicial-financial-interest (bribery-condoning) Defendant (SDNY Judge) Paul A. Crotty and are also based on the repeated perjury/ fraud on various courts in blatant violation of Judicial Law 487) as its reason for continuing illegal retaliation and systemic racial discrimination practices, 5 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 explanation of the “$650,000 Bribes/ Kickbacks, Breach of Incomplete Arbitration Contract, Systemic Racial Discrimination/ Subjugation, Obstruction of Justice, Repeated Perjury, and Judicial Corruption” Scandal requires a detailed oral presentation. (See 15-page Press Release (Exhibit 1) that summarizes some of the most important facts of this truly extraordinary and unconscionable civil rights scandal of recent times and also the related proposed new “Anti-Bribing of Plaintiff’s Attorney & Corrupt Judges" Act or “Anti-Mockery of Justice” Act.) (9) For all intents and purposes, out-going Columbia President Bollinger (though his bribe-arranging Proskauer Rose6 attorneys) had offered at least $650,000 in bribes/kickbacks (Quid Pro Quo payments) to the highly accomplished (Dr. Martin Luther King Type Racial Equality Seeking) Raghavendra’s own 1-of-6-cases/40-hours attorney Louis Stober to exploit his extrajudicial–connections to a jurisdiction-lacking, Bribery-Condoning SDNY Federal Court judge and for obstructing justice and or for abusing the power of Columbia’s additional highest-level extrajudicial connections in New York City Courts, including Columbia Trustee and non-recusing, (Recent) Presiding Justice of the Manhattan Appeals Court (Hon. Ronaldo Acosta) and Columbia University Law Professor and non-recusing Chief Judge of the Second Circuit Court of Appeals (Hon. Debra Livingston). (10) In a similar presidential misconduct situation, the Board of Trustees of the University of Michigan (Bollinger's previous employer) had immediately 6 Respondent Columbia’s new attorney Proskauer Rose firm has had a history of “Bribing” plaintiffs’ attorneys in major race discrimination cases to betray and hijack their own clients’ civil rights litigation. For example, Proskauer Rose had arranged for another one of their clients, Nextel Communications, to pay over $7 Million Dollars as a “Bribe” (in guise of BOGUS attorney fees) to the Plaintiffs’ attorneys for deceiving their own clients (Class of hundreds of racially discriminated employees) into totally outrageous (almost zero payment) and absurd settlement agreements. One of the partners of that law firm (Steven Morelli) was recently disbarred and sentenced to prison for stealing from clients. See Johnson, et al v. Nextel Communications, et. al, 660 F.3d 131 (2d Cir. 2011). Proskauer Rose firm and its attorney Gregg Mashberg are named defendants in OBSTRUCTED 418-2020 (Raghavendra v. Mashberg, Proskauer Rose,Paul A. Crotty) case. 6 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 conducted an internal investigation and FIRED their University President, Mark Schlissel, for his misconduct of a mere improper relationship with a female colleague. (11) Also, by recently selecting the first NON-WHITE (Colored Woman), Dr. Nemat (Minouche) Shafik, to replace out-going President Bollinger, for all intents and purposes, the Trustees of Columbia University have CONCEDED that highest-paid, university president Bollinger had been engaged in an unthinkable "$650,000 Bribery/Kickbacks, Systemic Racial Subjugation/Discrimination, Perjury, Arbitration Fraud, Obstruction of Justice, and Judicial Corruption” scandal during his tenure at Columbia University. (12) Upon information and belief, Bollinger has been able to COVER-UP this extraordinary judicial corruption and civil rights scandal WITHOUT any news coverage whatsoever simply because of Columbia’s improper power over even the freedom of speech of the journalists. Clearly, no journalist exposed this extraordinary scandal because he or she does not want to jeopardize his or her relationship with Bollinger’s “Pulitzer-Prize Awarding Committee” at Columbia University. (13) Bollinger’s/Columbia’a bribing of Racial Equality Seeking Raghavendra’s own 1-of-6-cases7 attorney and or his extrajudicial-connection SDNY federal court judge(s), obstructing justice, and committing repeated perjury, arbitration fraud and deception to COVER-UP the judicial corruption scandal is obvious from the following UNDISPUTED facts. I. Respondent Columbia University’s/Bollinger’s Inducement of a FAKE “$650,000 INCOMPLETE Arbitration” (1-1/2 Page Term Sheet) Contract FOR Offering Hundreds of Thousands of Dollars in Bribes/ Kickbacks to Racial-Equality-Seeking Complainant Raghavendra’s Own 1-of-6- 7 New York State law PROHIBITS one-of-six-cases/out-going attorney Louis D. Stober from hijacking and or causing any improper dismissal of any of the Plaintiff’s four other actions Stober was never retained on. See, Hallock v State of New York, 64 NY2d 224 [1984]; Nash v Y & T Distribs., 207 AD2d 779, 780 [2d Dept 1994] [an attorney has no implied power to settle or compromise a client’s claim by virtue of his or her general retainer]. 7 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 Cases/Client-Betraying/40-Hours Attorney Louis Stober (With Extrajudicial Connections to Jurisdiction-Lacking SDNY Judges) and TO HIJACK ALL of His Own Client’s Multi-Action, Multi-Jurisdiction, Multi- Million Dollars Litigation (for ENDING Columbia’s Systemic Racial Discrimination/Subjugation Practices) by BETRAYING and Committing Repeated Perjury and Fraud Against His Own Client BY Obstructing Completion of Expressly Agreed Arbitration Under Jurisdiction of Labor Arbitrator Martin F. Scheinman and Continuing Fraudulent Misrepresentations of that “INCOMPLETE Arbitration” Contract as Some Totally BOGUS, FAKE, MEANGINGLESS & ABSURD So-Called “BRIBES-Payment Settlement Agreement” that Simply NEVER Existed and WITHOUT Even Paying a Single Penny of the $650,000 Initial Back-Pay Damages Arbitration Award (14) Prior to the “Incomplete Arbitration” (Term Sheet) Contract, Civil Rights Complainant Raghavendra wrote dozens of letters and e-mails to Bollinger, including a 4-page letter that was titled (Exhibit 2): “Request for the Lawful Organization of an Anti-Discrimination ‘Minority Employees Association8’ through Immediate Negotiations.. ...for RESTORING the New York State Rights, U.S. 8 Respondent Columbia/Bollinger ILLEGALLY retaliated against and fired the (Dr. Martin Luther King type) Racial Equality Seeking Complainant Raghavendra for merely proposing a minority employee rights promoting“Racial Equality Struggles for Columbia University Employees” (RESCUE) Association that is similar to the anti- Discrimination “Black Employee Associations” across America (See Exhibit 4 for copy of Columbia Memo CONCEDING to a FALSE pretext before an Administrative Judge). At numerous prestigious organizations across America, Blacks and other minorities have been allowed to openly organize and form associations to promote Equal Opportunity and or to oppose any institutionalized racial discrimination and even bringing Multi-Million dollar Class Actions. Black Employee Associations have been in active existence for several decades at several universities including University of Pennsylvania, College of William & Mary, Dartmouth, Clemson, Johns Hopkins, and University of Michigan (while Bollinger was its President) and other large organizations such as IBM, NASA, etc. UCAR is University of Michigan’s “United Coalition Against Racism”, a campus anti- discrimination group that opposed out-of-control racial discrimination and harassment and publicly announced its intentions to file a civil rights Class Action lawsuit against the University of Michigan while Lee C. Bollinger was its President and Dean of Law School. 8 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 constitutional rights, Civil Rights & NLRA Rights of the Victims of Racial Discrimination, Anti-Semitism, and or Harassment, Including Sexual Harassment, at the 250-Years Old Ivy League University” (15) Previously, Complainant Raghavendra also wrote letters addressed to Defendant Bollinger from the which were titled (Exhibit 2): “Blacks, Jews & Other Minorities CANNOT be Denied Re-Hiring Due to Columbia University’s Prior Illegal Retaliation Firings” and “Preventing an Anti-Discrimination “Minority Employees Association” at Columbia University & Potential Civil Rights Class Action Through Direct Intimidation & Illegal Retaliation is Obstruction of Justice.” (16) Complainant Raghavendra also wrote several other letters to Bollinger to discuss remedying the problem of systemic racial discrimination practices at the prestigious 265-years old Columbia University by at least allowing for lawful organization of First Equal Opportunity Promoting “Minority Employees Association” while avoiding any immediate $200 Million Dollars (Coca Cola or TEXACO Style) Class Action at the time of Columbia’s WORST racial crisis. that included Anti-Racism Hunger Strikes, Racist Nooses, Swastikas, “Black Women Are Only Good for Sex, Plantation Mentality, and Blacks Were Invented for Cheap Labor" attitudes, etc (See, Exhibit 5 for copies of over 38 different articles describing Anti-Racism Hunger-Strikes/Protests, Incidents of Blatant Racism, and Anti- Discrimination Class Actions that were Viciously Suppressed by Columbia President Lee Bollinger & See Exhibit 6 for Examples of Lawful Settlements of Other Similar Multi-Million Dollar Class Actions for Institutionalized Racial Discrimination at Coca Cola, TEXACO, etc); (17) Prior to the first day of an “Incomplete Arbitration”, Complainant Raghavendra had also made extremely clear, through 1-of-6 cases/out-going attorney Stober that the most he may agree to settle is just one and only the $650,000 back-pay damages cases in exchange for not initiating the $200 Class Action on behalf of the Black/Colored employees of Columbia but with the organization of the first anti-discrimination “Minority Employees Association.” (See, Exhibit 7 for copy of e-mail that makes it clear that the 9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 primary topic of negotiation involving Arbitrator Martin F. Scheinman would be the $200 Million Dollar Class Action) (18) At the end of the first day of “Incomplete Arbitration”, BOTH Bollinger (through his Proskauer Rose attorneys) and 1-of-6-cases/out-going attorney Stober themselves conceded and expressly notified Federal Magistrate Judge Henry Pitman that it was agreed to settle one and only the $650,000 back-pay damages case in which Stober was retained but he had already filed a motion to withdraw attorney representation based on irreconcilable differences with his client, Raghavendra. The faxed letter to Judge Pitman read as follows Dear Judge Pitman: This letter is to inform the Court that at a full-day mediation (incomplete arbitration) session…., the Plaintiff….reached settlement of the above captioned (back-pay damages, 06-cv-6841) matter with the (Columbia) Defendants. (See, Exhibit 8 for copy of letter of Stober and Bollinger (Proskauer Rose) to Federal Magistrate Judge Henry Pitman that ONLY the back-pay damages case was settled to avoid a $200 Million Dollars Class Action.) (19) Arbitrator Scheinman had also advised Raghavendra that based on his repeated letters and emails to assert the equal opportunity rights of the thousands of minority employees at Columbia, Bollinger had agreed to the Incomplete Arbitration Contract that would at least allow for lawful organization of First Equal Opportunity Promoting “Minority Employees Association” while avoiding any immediate $200 Million Dollars (Coca Cola or TEXACO Style) Class Action at the time of Columbia’s WORST racial crisis. that included Anti-Racism Hunger Strikes, Racist Nooses, Swastikas, “Black Women Are Only Good for Sex, Plantation Mentality, and Blacks Were Invented for Cheap Labor" attitudes, etc (See, Exhibit 5 for Columbia University Blatant Racism of President Bollinger ); (20) In the “INCOMPLETE Arbitration” scheduled by Columbia President Bollinger in collusion/conspiracy with Racial Equality Seeking Raghavendra’s own 1-of-6-Cases/Out-Going/40-Hours Attorney Louis Stober, Famed New York Arbitrator, Martin F. Scheinman, already awarded $650,000 in initial back-pay damages against Columbia University on the first day of the incomplete arbitration (binding mediation) while 10 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 implementing “Equal Opportunity” policies in exchange for Raghavendra NOT initiating a potential $200 Million Dollar (Coca Cola & TEXACO Style) Class Action on behalf of the thousands of victims of systemic Racial Discrimination in employment at the 265-years old Columbia University; (21) The 1-1/2 page “$650,000 INCOMPLETE Arbitration” (Term Sheet) Contract had an expressly Labor Arbitrator had expressly agreed “Arbitration Clause” giving ONLY Labor Arbitrator Scheinman EXCLUSIVE jurisdiction over the terms of any kind of (LIMITED) “settlement agreement” and an expressly agreed “Anti-Bribery Clause” to expressly PREVENT Bollinger/ Columbia from bribing or any giving any kickbacks or even paying a single penny to “Equal-Opportunity Seeking” Plaintiff ‘s own 1-of-6- Cases/Out-Going/40-Hours Attorney Stober for BETRAYING his own client (Plaintiff) in any way, shape or form. (See Exhibit 9 for copy of the ‘INCOMPLETE Arbitration (Binding Mediation)” (1-1/2 Page Term Sheet) Contract between Respondent Columbia & Complainant Raghavendra). (22) However, immediately after inducing the “$650,000 INCOMPLETE Arbitration” (Term Sheet) Contract, Racial-Equality-Seeking Complainant Raghavendra’s own 1-of-6-Cases/Out-Going/ 40-Hours attorney Stober started BRAGGING that to exploit his extrajudicial-connections to SDNY judges including jurisdiction-lacking, bribery-condoning, district court judges Paul A. Crotty and William Pauley (his neighbor in Garden City, NY), Bollinger/Columbia had offered him bribes/kickbacks to induce that “Incomplete Arbitration” Contract. (23) Late) SDNY Judge William Pauley was a CLOSE friend/associate of SDNY Judge Paul Crotty and was known to abuse the court system for the direct benefit of his personal friends/relatives (See Exhibit 17 for copy of news article showing SDNY Judge Pauley doing extrajudicial favors.) (24) Obstruction of Justice, Abuse of Power and or Fraud on the Court by the Court by Issuing Totally Baseless, Unconstitutional and “BOGUS SANCTIONS” is a strategy that is commonly used by CORRUPT JUDGES for UNJUST ENRICHMENT of themselves and or their friends/relatives and to deprive the basic constitutional rights of the Plaintiff (See Exhibit 18). (25) See Exhibit 18 for 32 different news and other scholarly articles regarding CORRUPT Judges taking Attorney Bribes, Obstructing Justice, Abusing their Power, Extorting Bribes and other favors while making a absolute MOCKERY 11 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 of the whole American Justice System. Some of these CORRUPT judges were prosecuted to the fullest extent of the law and been sentenced to serve jail time. (26) 1-of-6-Cases/Out-Going/40-Hours attorney Stober started HARASSING, and intimidating his own client (Raghavendra) with threats of totally baseless, absurd, UNCONSTITUTIONAL9, non-appealable, and unthinkable BOGUS ($5,000/Day for LIFE) sanctions and even threats of baseless imprisonment that would DEPRIEVE him (own client) his basic constitutional rights for completion, (in blatant violation of every New York State Rules of Attorney Conduct & Ethics), obstruct completion of the incomplete arbitration, obstruct completion of already scheduled jury trial, obstruct all other multi- action pending litigation in multiple jurisdictions, and obstruct equal opportunity to thousands of Black/Colored employees at Columbia. (27) See Exhibit 19 for 20 different news articles regarding CORRUPT attorneys such as Proskauer Rose and Bribe-Seeking/One-of-Six-cases/40-Hours Attorney Louis Stober who engage in Attorney Fraud, Bribery and other outrageous acts while making a total MOCKERY of the whole American justice system. Many of these corrupt attorneys were prosecuted to the fullest extent of the law and even been sentenced to serve jail time. (28) On first day of “Incomplete Arbitration/Mediation” it was, therefore, agreed that Complainant Raghavendra that in EXCHANGE for payment of only first four years of back-pay damages of $650,000 (A) he would not initiate any $200 Million Dollar Class Action; and (B) settle ALL “causes of action” in just one and only “Arbitrator Authorized” NON-Pro Se 06-cv-6841 (“Out-Going Stober as Attorney on File”) supplementary action even though Complainant Raghavendra was already in the process of suing him (Defendant Stober) for 9 Jurisdiction-Lacking, Bribery-Condoning White SDNY Judge Crotty’s BOGUS & UNTHINKABLE “$5,000/day sanctions for LIFE” was totally unconstitutional and illegal because the U.S. Supreme Court had established law for over 100 years that a district court judge must have subject matter jurisdiction over the suit before he may issue a valid contempt (sanctions) order. See, Ex parte Rowland, 104 U.S. (14 Otto.) 604, 612, 26 L. Ed. 861 (1881). Because extrajudicial-financial-Interest/Defendant judge Crotty repeatedly acted in excess of his jurisdiction, his orders to extort “Involuntary Releases” from Plaintiff by use of (bogus) contempt orders are VOID. Id. at 612, 617-18; see also In re Burrus, 136 U.S. 586, 597, 10 S. Ct. 850, 34 L. Ed. 500 (1890);In re Sawyer, 124 U.S. 200, 221-22, 8 S. Ct. 482, 493, 31 L. Ed. 402 (1888); Ex parte Fisk, 113 U.S. 713, 726, 5 S. Ct. 724, 730, 28 L. Ed. 1117 (1885). 12 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 10/11/2023 breaching his attorney services contract and or for not litigating the “Back- Pay Damages (06-cv-6841)” case all the way to a jury trial. (29) Respondent Columbia University ’s own former attorney Edward Brill repeatedly argued before the Courts as follows (See, Transcript): “....the parties intended to be bound by that term sheet as a contract.......In the term sheet itself, the parties provided that mediator/arbitrator would resolve that. In effect, it was an ARBITRATION provision” (emphasis added). (Transcript Page 11, Lines 7-20) (30) The “INCOMPLETE Arbitration” Contract also specifically included an expressly agreed “Anti-BRIBING” clause that acknowledged the Plaintiff’s already pending “Breach of Attorney Services Contract” and other legal malpractice claims against 1-of-6-cases/40-hours attorney Stober as follows (See, Exhibit 9): “There is an ongoing dispute between the Law Offices of Lo