10.28.21 IRN 52B-2 Supp 1.0 Re Clear and Convincing Evidence of Willful Criminal Contempt of The Brady Court Orders

IRNewswires Breaking News:
New U.S. Attorney (SDNY) Damian Williams and

USAG Merrick Garland will likely resign from
office in disgrace and be criminally prosecuted.
“For whom does the bell toll? It tolls for thee.”
U.S. Attorney Damian Williams (SDNY)
IRNewswires Public Corruption Investigations Group

Meredith Kammler, LLB, LLM, Ph.D., Int’l Investigative Reporter
October 28, 2021
London, UK
Page 1 of 23
Thursday, October 28, 2021
IRN’s 2021 Ulysses T. Ware’s Innocence Project
Is the USAO doomed to the abyss? Is the camel’s
back already broken? Regrettably, Yes.
The new U.S. Attorney in Manhattan, Damian Williams, tonight is facing a most
serious and profound threat to his continued position as the U.S. Attorney (SDNY);
as well as his boss U.S. Attorney General Merrick Garland. Mr. Garland, a former
federal appeals court judge, supervised Mr. Williams as his law clerk on the District of
Columbia’s federal court of appeals. However, it appears that Mr. Garland and Mr.
Williams both took their eyes off the ball; and for unexplainable reasons have allowed
the criminal and civil contempt allegations -- lodged by Atlanta, GA lawyer Ulysses T.
Ware -- of the Brady Court Orders to fester leaving the District Court no choice but to
hold each and others in civil1 (civil incarceration) and criminal contempt (criminal
prosecution) of the Brady Court Orders if the rule of law has any meaning and no man
is above the law.
The current fiasco within the DOJ is exactly what occurs when you have weak
executive leadership that obtained their respective positions due to cronyism, political
favors, and outright kick-backs and pay-offs, rather than merit, actual competence, and
in reliance on paper titles and questionable academic degrees. But in any event “the die
has been cast” and Mr. Williams and Mr. Garland have no place to run and hide. As
they say in America, “the horse has left the barn.”
Will Mr. Garland, the chief law enforcement officer in the United States, steel
himself for the job, be “bold as a lion” and once and for all accept the challenge of
enlightened leadership and confront and dismantle the centuries-old palpable
institutional and structural racism doctrines, flagrant cronyism, blatant nepotism,
excessive fraud and corruption within the District Court (SDNY) and the U.S.
Attorney’s Office (SDNY)? Or will it be business as usual? Mr. Williams has already
announced that he has hired back to the USAO previous prosecutors, Margaret Garnett
and Daniel Gitner as part of his executive management team. It appears that Mr.
Williams is pouring old wine into new wineskins. Nothing will change within the USAO
until change itself appears. Mr. Williams, albeit an African American with stellar
1Mr. Williams, Mr. Garland, and others likely will be civilly detained until full compliance with the Brady
Court Orders, and fined and assessed monetary damages in the sum certain amount of $2.225 billion dollars.
Page 2 of 23
credentials, is about as institutionalized and normalized as one can be coming from the
same vineyard that produced the old wine that has been drunk for centuries.
Mr. Williams is not the person for revolutionary, dynamic structural change. That
type of management style is not in his or Mr. Garland’s leadership DNA.
As Cicero stated in his opening statement to a session of the Roman Senate

hearing a criminal trial:
“Conscript fathers nothing is more sure, nothing is more certain than that these
honorable and noble men here today will accept a bribe and be bought than the course
of the Tiber. That will never change … all we can hope for is that they have the honor
and restraint to only accept a little bribe and once bought to stay bought … that is all
we can hope for ….”
“And Brutus and Cassius were honorable men.”
Page 3 of 23
Docket NO: 04cr1224 and 05cr1115 (SDNY) (52B-2)
Submitted by:
/s/ Ulysses T. Ware
_____________________________
Ulysses T. Ware, (the “Prevailing Party”), Petitioner
123 Linden Blvd.
Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
Utware007@gmail.com
Submitted on October 28, 2021
In the United States District Court

For the Southern District of New York
____________________________
Supplement #1.0 to October 25, 2021, Emergency Motion for Leave to
Compel the United States to file all Rule 5K documents, filings, pleadings,
memorandums, Brady, Giglio, and Rule 16 materials related to United
States v. Ulysses Ware, 05cr1115 (SDNY) regarding Government
“principal witness” Jeremy Jones, or any other person pursuant to the US
Attorney’s Manual Sections 9-24.400 to 410, Exhibit 2, infra.
_________________________
Certificate of Service
I Ulysses T. Ware have this 28th day of October 2021, served the United States DOJ’s
lawyer, Damian Williams (SDNY), with a copy of this pleading via email to
Damian.Williams@usdoj.gov, Jeffrey R. Ragsdale at Jeffrey.Ragsdale@usdoj.gov,
and Marlon G. Kirton, Esq. at kirtonlawfirm@gmail.com.
Page 4 of 23
Overwhelming “Clear and Convincing”
evidence of the repeated willful
violations of 18 USC 401(3), criminal
contempt by DOJ prosecutors and
federal judges; and US Attorney Manual
Ethical Standards within the purview of
Local Rule District Court (SDNY) 1.5(b)(5)
sanctions.
Page 5 of 23
DOJ Executive Leadership in Civil and willful
Criminal Contempt of the Brady Court Orders,
Exhibits 3 and 4, infra, and Court Judgments.
U.S. Attorney Damian Williams (SDNY)
Page 6 of 23
Page 7 of 23
Exhibit 1
Page 8 of 23
Exhibit 2
U.S. Attorney’s Manual
9-27.400 to 410 - PLEA AGREEMENTS GENERALLY
The Commission has recognized those bases for departure that are commonly
justified. Accordingly, before the government may seek a departure based on
a factor other than one set forth in Chapter 5, Part X, approval of the United
States Attorney, appropriate Assistant Attorney General, or designated
supervisory official is required. This approval is required whether or not a case
is resolved through a negotiated plea.
Section 5K1.1 of the Sentencing Guidelines allows the United States to file a
pleading2 with the sentencing court3 which permits the court to depart
below the indicated guideline, on the basis that the defendant provided
substantial assistance in the investigation or prosecution of another.
Authority to approve such pleadings is limited to the United States
Attorney, the Chief Assistant United States Attorney, and supervisory
criminal Assistant United States Attorneys, or a committee including
at least one of these individuals. Similarly, for Department of Justice
attorneys, approval authority should be vested in a Section Chief or Office
Director, or such official's deputy, or in a committee which includes at least
one of these individuals.
Every United States Attorney or Department of Justice Section Chief (or
Assistant Chief) or Office Director shall maintain documentation of the
facts behind and justification for each substantial assistance pleading.
The repository or repositories of this documentation need not be the case file
2 The Government is required to “file a pleading” with the District Court which is required to be
docketed and publicly filed into the record of the court pursuant to Fed. R. Crim. P. 55. Which
was not done by the Government with respect to “principal witness” Jeremy Jones’ USSG 5k1.1
downward departure. No 5K1.1 “pleading” was filed on the docket with the District Court, and
therefore, as a matter of law, Jones’ illegal downward departure is null and void ab initio. Jones
illegal sentence is required to be vacated and Jones resentenced.
3
District Judge William H. Pauley, III (deceased) in U.S. v. Ware, 05cr1115 (SDNY).
Page 9 of 23
itself. Freedom of Information Act or other considerations may suggest that a
separate form showing the final decision be maintained.
The procedures described above shall also apply to Motions filed pursuant to
Rule 35(b) of the Federal Rules of Criminal Procedure, where the sentence of
a cooperating defendant is reduced after sentencing on motion of the United
States. Such a filing is deemed for sentencing purposes to be the equivalent
of a substantial assistance pleading.
The concession required by the government as part of a plea agreement,
whether it be a "charge agreement," a "sentence agreement," or a "mixed
agreement," should be weighed by the responsible government attorney in
the light of the probable advantages and disadvantages of the plea disposition
proposed in the particular case. Particular care should be exercised in
considering whether to enter into a plea agreement pursuant to which the
defendant will enter a nolo contendere plea. As discussed in JM 9-
27.500 and JM 9-16.000, there are serious objections to such pleas and they
should be opposed unless the appropriate Assistant Attorney General
concludes that the circumstances are so unusual that acceptance of such a
plea would be in the public interest.
[updated February 2018] [cited in JM 9-16.300; JM 9-16.320; JM 9-
27.300; JM 9-28.1300]
Page 10 of 23
Exhibit 3
May 19, 2006, Dkt. 17, Brady Court Order entered in
U.S. v. Ware, 05cr1115 (SDNY) (Pauley, J.)
Page 11 of 23
Exhibit 3-1
Exhibit 4
Page 12 of 23
August 10, 2007, Dkt. 32, Brady Court Order entered in
U.S. v. Ware, 04cr1224 (SDNY) (Sweet, J.) (deceased).
Page 13 of 23
Exhibit 4-1
Page 14 of 23
Exhibit 5
Concealed and suppressed Brady exculpatory evidence
Page 15 of 23
Exhibit 6
FINRA May 17, 2021, confirmed the unregistered
broker-dealer status of the “Civil Plaintiffs” named in
para. 8 of the U.S. v. Ware, 04cr1224 (SDNY) indictment.
Page 16 of 23
Exhibit 7
Concealed and suppressed Brady exculpatory evidence:
Conspiracy to obstruct justice by federal judge Robert W.
Sweet and the USAO. “Lawful” was a factual element of
proof by the Government.
Page 17 of 23
Exhibit 8
Concealed and suppressed Brady exculpatory evidence.
SEC Brady Exculpatory Official Email confirmed by Exhibit
8.1, infra.
Page 18 of 23
Exhibit 8-1.1
Exhibit 8-1.2
Page 19 of 23
Exhibit 9
Willful and known perjury of FBI analyst Maria Font at trial in U.S.
v. Ware, 05cr1115 (SDNY), suborned by AUSAs Alexander H.
Southwell and Steven D. Feldman.
Exhibit 10
Page 20 of 23
Exhibit 11
Page 21 of 23
Para. 33 of the SEC’s 03-0831 (D. NV) unsigned
complaint. A binding judicial admission by the USA there
was no “artificial inflation” of INZS and SVSY’s stock
“price.”
Page 22 of 23
Exhibit 12
Concealed and suppressed Brady impeachment evidence regarding
04cr1224 Government FRE 404(b) witness SEC lawyer “Jeff Norris”
concealed and suppressed by AUSAs Maria E. Douvas, Nicholas S.
Goldin, Sarah E. Paul, Katherine Polk-Failla, Margaret Garnett,
Alexander J. Wilson, Sarah K. Eddy, Melissa Childs, John M.
McEnany, U.S. Attorneys Michael J. Garcia, Joon Kim, Preet
Bharara, Audrey Strauss, Damian Williams, the SEC, and Judge
Robert W. Sweet (deceased).
Page 23 of 23

10.28.21 IRN 52B-2 Supp 1.0 Re Clear and Convincing Evidence of Willful Criminal Contempt of The Brady Court Orders

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IRNewswires Breaking News:

New U.S. Attorney (SDNY) Damian Williams and

U.S. Attorney Damian Williams (SDNY)

IRNewswires Public Corruption Investigations Group

As Cicero stated in his opening statement to a session of the Roman Senate

“And Brutus and Cassius were honorable men.”

In the United States District Court

U.S. Attorney Damian Williams (SDNY)

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