Re: Complaint 10237302 Rahul D.

Manchanda v New York State Bar Association

Subject: Re: Complaint 10237302 Rahul D. Manchanda v New York State Bar Associa on
From: Manchanda Law Office And Associates PLLC <info@manchanda‐law.com>
Date: 8/6/2024, 5:41 PM
To: "Kirton, Kris n (DHR)" <Kris [email protected]>
CC: [email protected], Law Office Manager Sylwia Manchanda <sylwia.manchanda@manchanda‐
law.com>

Ms Kirton:

My rebu al is as follows, and is also wri en on the le er itself in red:

This "new rule" 8.4 is being used and abused by more powerful, established, and poli cally connected
minori es (especially in NYC) against less powerful, newer, or poli cally connected minori es,
whenever the la er complains about ins tu onal bias, discrimina on, racism, cronyism in the courts.

For example, this is happening in my own life, wherein I complained a er a 22 year career observing
Jews and African‐Americans who dominate the courts crushing and being unfair to other ethnic,
religious and racial minori es including myself, and instead of ge ng assistance, they gaslighted and
retaliated against me and the A orney Grievance Commi ee (made up almost en rely of Jews and
Blacks) charged me with "an ‐semi sm," "racism," and being "offensive."

The NYSBA should amend the Rule as discrimina on is only truly effec ve as a tool of oppression,
when the oppressor has more power, is more established, and maintains poli cal dominance than the
oppressed.

Not to do so, is naive at best, purposeful at worst.

My AGC 1st Dept disciplinary case led by Remi Shea and Rosalyn Richter, 2 female members of the
oppressive class, in case 1336.2021, is the "minimal due diligence" that is enough for the NYSBA and
David Miranda, as it is first hand, direct observa on, and from personal knowledge.

David Miranda and the NYSBA need to look up the difference between "de jure" and "de facto"
discrimina on.

Thanks,

Kind regards,

‐‐
Rahul D. Manchanda, Esq.
Manchanda Law Office And Associates PLLC

Manhattan NYC Office

250 Park Avenue, 7th Floor
New York, NY 10177

Westchester NY Office
173 Huguenot Street
New Rochelle, NY 10801

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 Re: Complaint 10237302 Rahul D. Manchanda v New York State Bar Association

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On 8/6/2024 9:50 AM, Kirton, Kris n (DHR) wrote:

Please find enclosed the response to the above referenced complaint. Please provide a rebu al on/before
Wednesday August 21, 2024.

August 6, 2024

Rahul D. Manchanda
270 Victory Boulevard
New Rochelle, NY 10804

Re: Rahul D. Manchanda v. New York State Bar Associa on

Case No. 10237302

Dear Rahul D. Manchanda:

A ached is a copy of the respondent's wri en response to your recently filed complaint. At this me, we
are asking you to review the a ached and submit a wri en response (known as a “rebu al”), in order to further
the inves ga on of your case. Please include your case number on your submission and submit your wri en
rebu al to us by 08/21/2024. The Division will not extend the me for your rebu al, unless good cause is shown
in a wri en applica on, submi ed at least five (5) calendar days prior to the me the rebu al is due.

You may submit your rebu al by mail, fax or via e‐mail to [email protected]. Email a achments
should be in *.pdf, *.doc, *.docx or *.xlsx formats. Please contact our office to discuss if you have electronic files
you wish to submit in other formats. If you submit by email, do not send addi onal hard copies through the mail
unless you are specifically requested to do so by Division staff.

If we do not hear from you, we will assume you have nothing to add. The case may then be decided on the

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 Re: Complaint 10237302 Rahul D. Manchanda v New York State Bar Association

basis of what is in the file.

Protec on of personal privacy: You may wish to submit documents in support of your complaint. The
Division observes a personal privacy protec on policy consistent with Human Rights Law § 297.8 which governs
what informa on the Division may disclose, and the N.Y. Public Officer's Law § 89 and § 96‐a, which prohibit
disclosure of social security numbers and limit further disclosure of certain informa on subject to personal privacy
protec on. Please redact or remove personal informa on from any documenta on submi ed to the Division,
unless and un l the Division specifically requests any personal informa on needed for the inves ga on. The
following informa on should be redacted: the first five digits of social security numbers; dates of birth; home
addresses and home telephone numbers; any other informa on of a personal nature. The following
documenta on should not be submi ed unless specifically requested by the Division: medical records; credit
histories; resumes and employment histories. The Division may return your documents if they contain personal
informa on that was not specifically requested by the Division. If you believe that inclusion of any such personal
informa on is necessary to support your complaint, please contact me to discuss before submi ng such
informa on.

Please remember that you must no fy us immediately, in wri ng, of any change in your address or
telephone number. Thank you for your coopera on.

Very truly yours,

Joyce Yearwood‐Drury
Interim Regional Director

A achments:

Response 10237302.pdf 427 KB

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 a .
11111 NEW YORK ST A TE BAR ASSOCIATION
NYSBA One Elk Street, Albany, New York 12207 • PH 518.463.3200 • www.nysba.org

David P. Miranda, Esq., General Counsel • 518.487.5524 • [email protected]

------

August 2, 2024

Joyce Yearwood-Drury (via email to [email protected])

Interim Regional Director
NYS Division of Human Rights
Brooklyn Regional Office
55 Hanson Place, Room 304
Brooklyn, NY 11217

RE: Rahul D. Manchanda v. New York State Bar Association

SDHR NO: 10237302

Dear Joyce Yearwood-Drury:

This is in response to the above referenced notice of Complaint dated July 25, 2024. There is no
basis in law or fact for Complamant Rahul D. Manclum.da's (Complainant) discrimination claim
against the New York State Bar Association (NYSBA).

Complainant fails to set forth any facts that would support a claim of discrimination against This "new
rule" is
NYSBA. Complainant's discrimination claim alleges that "Ethics Rules promulgated by the New
being used
York State Bar Association" are "abusive, overly broad and selectively enforced" as related to and abused
Rule 8.4. There is no basis for any such claim as NYSBA does not promulgate or enforce the by more
Rules of Professional Conduct in New York State (The Rules). The Rules, including 8.4(g), are powerful
promulgated and enforced by the "Judicial Departments of the Appellate Division of the New and
York State Supreme Courts." NYS Judiciary Law § 90, 22 NYCRR, Part 1200. politically
connected
NYSBA is not a state agency or branch of state government, but rather is a private 501(c)(6) not minorities
(especially
for profit membership association. NYSBA has no governmental authority to promulgate or in NYC)
enforce The Rules. against less
powerful
Complainant failed to conduct even minimal due diligence as to the legal merit of their claim and or
sets forth no facts supporting discrimination against them. The very article attached to the politically
Complainant's Complaint confirms that NYSBA does not promulgate The Rules, stating: connected
minorities when the latter complains about institutional bias, discrimination, racism, cronyism in the courts. For
example, this is happening in my own life, wjerein I complained after a 22 year career observing Jews and
African-Americans who dominate the courts crushing and being unfair to other ethnic, religious and racial
minorities and instead of getting assistance, they gaslighted and retaliated against me and charged me with
Page 1should
"anti-semitism," "racism," and being "offensive." NYSBA of 2 amend the Rule as discrimination is only
truly effective as a tool of oppression when the oppressor has more power, established, and dominance than the
oppressed. Not to do so is naive at best, purposeful at worst. My disciplinary case 1336.2021 is "minimal due
diligence" enough for them, as it's first hand, direct observation and from personal knowledge.
 "On June 10, 2022, New York's four Appellate Division departments issued a joint
order immediately adopting a variation of ABA Model Rule of Professional Conduct
8.4(g) broadly prohibiting discrimination and harassment in the practice of law. Joint
Order of the Departments of the New York State Supreme Court, Appellate Division,
dated June 10, 2022. New York's new rule substantially departs from the state's prior,
and much more limited, Rule 8.4(g), which focused primarily on unlawful discrimination
in the workplace" (emphasis added).

The Complaint fails to set forth any conduct by NYSBA or any other party that could be
considered discriminatory.
David Miranda
and the
Rule 8.4(g) seeks to prohibit lawyers licensed to practice in New York from engaging in NYSBA need
misconduct, including unlawful discrimination. The Rule on its face does not discriminate to look up the
against any person or class of persons. The Complaint fails to set forth any facts that provide a difference
basis for a finding of probable cause that an act of discrimination has occurred. Other than the between "de
mistaken claim that NYSBA promulgates The Rules, no action of NYSBA has been alleged. jure" and "de
facto"
discrimination.
For the reasons set forth herein, the Complaint against NYSBA must be dismissed in its entirety,
with prejudice.

Respectfully
Respectfully submitted,
submitted,

David P.
T"'I, •
Miranda
-r.. . . . .
1

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