11.16.21 53A-2 Re DKT 24, The USAO's Concealed and Suppressed Rule 11 Transcript of Jeremy Jones

Docket NO: 04cr1224 and 05cr1115 (SDNY) (53A-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 November 16, 2021
In the United States District Court

For the Southern District of New York
____________________________
53A-2 to September 28, 2021, 51J-10, (Taylor-Swain, CJ) re: Request for Supervisory Writ and
October 25, 2021, 52B-1 re: Emergency Motion for Leave to Compel the United States to file all
USSG 5K documents,1 filings, pleadings, memorandums, Brady, Giglio, Rule 16 materials, Rule 11
plea or cooperation agreements,2 and/or promises related to United States v. Ulysses Ware,
05cr1115 (SDNY) and 04cr1224 (SDNY) regarding Government “principal witness” Jeremy Jones,
or any other person, pursuant to the US Attorney’s Manual Sections 9-5.001, the First
Amendment right of access to judicial public records, and New York Bar Assn. Rule 3.8.i
_________________________
1 The Government’s suppressed and willfully concealed September 15, 2006, USSG 5k agreement,
understanding, perjury contract for Jeremy Jones to knowingly, willfully, and in bad faith commit
perjury, and give false, fraudulent, and materially misleading, deceitful, and material
misrepresentations as a government witness at trial in 05cr1115 (SDNY). See Exhibit 2, infra.
2 See Exhibits 2, 3, and 4, infra.
Page 1 of 20
Tuesday, November 16, 2021
53A-2: USAO’s concealed Dkt. 24 re Rule 11 plea transcript of government witness Jeremy
Jones.
DOJ’s Damian Williams, Merrick Garland,3 Marlon G. Kirton, Esq., Edgardo Ramos, Laura Taylor-
Swain, William H. Pauley, III, and others Conspiracy to Suborn Perjury, Obstruct Justice, Commit
a fraud on the District Court (SDNY), the U.S. Court of Appeals for the Second Circuit in U.S. v.
Ware, 07-5222cr, and the Supreme Court of the United States in case no. 10-6449, Ware v.
United States, by the willful, deliberate, and bad faith suppression and concealment of the
illegal, unethical, null and void ab initio September 15, 2006, cooperation agreement4, an illegal
perjury contract, entered into by the United States, the DOJ, the SEC, Jeremy Jones, Marlon G.
Kirton, Michael H. Dolinger, Andrew J. Peck, and William H. Pauley, III, jointly individually, and
severally, (the “Unindicted Co-conspirators”).5
Certificate of Service
I Ulysses T. Ware have this 16th day of November 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,
Chief District Court Judge Laura Taylor-Swain, SwainNYSDCorresp@nysd.uscourts.gov,
Edward T.M. Garland at etg@gsllaw.com, Manny Arora at manny@arora-law.com,
The State Bar of Georgia at Office of the General Counsel, Bill NeSmith at
billn@gabar.org, and Marlon G. Kirton, Esq. at kirtonlawfirm@gmail.com.
3See USAG (then D.C. Circuit Court of Appeals Circuit Judge) Merrick Garland’s opinion in In re
Sealed Case, 185 F.3d 887 (D.C. Cir. 1999) (Garland, J.) (Gov’t Brady obligations in regard to
cooperation agreements).
4 See Exhibit 4, Dkt 24 at Tr. 11 L 2-3:
5 See Exhibit 4, infra, referencing the USAO’s September 15, 2006, illegal perjury contract, the
USSG 5k cooperation agreement, Tr 11 L 2-3, entered into on behalf of the Government by U.S.
Attorney (SDNY) Michael J. Garcia, AUSA Alexander H. Southwell and his supervisor, the chief of
the USAO’s criminal division (as required by the U.S. Attorney’s Manual) with Marlon G. Kirton,
Jeremy Jones, Michael H. Dolinger, and William H. Pauley, III, as material constructive and actual
parties to the illegal Rule 11 plea agreement and the USSG 5K cooperation contract.
Page 2 of 20
Jones.
Memorandum
The Downfall of AUSA Alexander H. Southwell:
An enigma, a conundrum, a fool. 6
I.
New York law firm Gibson, Dunn, & Crutcher, LLP’s partner
former AUSA Alexander H. Southwell.
A. Opening statement.
“Often men try to do good, but fall short and instead do bad. If a man does not
correct his bad deed, a bad deed that he knows is bad, that man is of bad character, of
bad morals, and is a bad person. All the water in the Tiber can never wash away a bad
deed on a man’s character … he is marked for life as a bad man, and nothing can ever
change that ….” Cicero, Opening statement to the Roman Senate.
6 A modern-day Macbeth. Southwell sought power, money, fame, and fortune by any means
necessary. Never stopping to think that Fate was watching his every move, his every lie, his every
fraud, his every illegal plan and scheme. Fate set Southwell up to fail as a warning to others who
would tempt Fate, be irrationally ambitious, and fly too close to the Sun. You will get burned.
Page 3 of 20
Jones.
AUSA Alexander H. Southwell “is marked for life as a bad man, and nothing can ever
change that” his fate is sealed. Southwell, gullible as a child, tempted by the Sirens, thought he
was immortal, flew too high to the Sun, like Icarus,7 foolishly tempted Fate, looked too long into
the abyss, the abyss looked back, and Southwell jumped head-first into the abyss never to be
seen again. CHECKMATE. Poor Alex.8 A fitting end to a sorry career of frauds, lies, conspiracies,
and obstruction of justice in many cases as a federal prosecutor.
Exhibit 1, infra, pages 2-3 of the Government’s lawyers’, AUSA Nicholas S. Goldin and
Andrew F. Fish’s, comical and frivolous appeal brief signed and filed in United States v. Ware, 07-
5222cr (2d Cir.), Ware-I, Ulysses T. Ware’s appeal of the conviction and sentence entered in
United States v. Ware, 05cr1115 (SDNY) (Pauley, J.). Note on page 2 the USAO (SDNY)
prosecutors notified the Court of Appeals (2d Cir.) on November 7, 2008, in regard to the DOJ’s
7 In Greek mythology, Icarus (/ˈɪkərəs/; Ancient Greek: Ἴκαρος, romanized: Íkaros, pronounced [ǐːkaros])
was the son of the master craftsman Daedalus, the creator of the Labyrinth. Icarus and Daedalus attempt
to escape from Crete by means of wings that Daedalus constructed from feathers and wax. Daedalus
warns Icarus first of complacency and then of hubris, instructing him to fly neither too low nor too high,
lest the sea's dampness clog his wings or the sun's heat melt them. Icarus ignores Daedalus’s instructions
not to fly too close to the sun, causing the wax in his wings to melt. He tumbles out of the sky, falls into
the sea, and drowns. The myth would later be coined in the idiom, "don't fly too close to the sun".
8 Southwell’s resume and professional bio in the New York law firm of Gibson, Dunn, and
Crutcher, LLP’s website claims he was graduated magna cum laude from Princeton University
and New York University Law School. However, a private investigator retained by IRNewswires
has interviewed several persons who claimed to have known Southwell at Princeton and on
condition of confidentiality stated, “ … Southwell was a jerk, I am not the least bit surprised that
he would attempt to rig and fix a case … that is who he is, a scumbag … I rather doubt that he
actually graduated magna, likely cheated for his grades … he is total scum he is not to be trusted
under any circumstance ….” (emphasis added).
Page 4 of 20
Jones.
notice of appeal filed in United States v. Ware, 05cr1115 (SDNY) (AUSA Steven D. Feldman), Dkt.
103.9
9 The USAO (AUSAs Nicholas S. Goldin and Andrew F. Fish, deputy chief of appeals) informed the
Court of Appeals (2d Cir.) on behalf of the United States and its privies, the real party in interest,
(i.e., the USAO, the DOJ, the SEC, the FBI, the BOP, the USPO, the Administrative Office of the
U.S. Courts, all United States federal courts and agencies, and their employees) the United States
had decided to waive, forfeit, abandon, abort, terminate, and dismiss with prejudice its Fed. R.
App. P. Rule 28.1 “cross-appeal” filed in United States v. Ware, 07-5670cr (XAP) (2d Cir.), Gov.-I:
a frivolous appeal of the 05cr1115 District Court (Pauley, J.) October 2007 rulings in favor of
Ulysses T. Ware, to wit, Dkt 99, S. Tr. 31 L 18-25 (R-1); S. Tr. 35-36 (R-2); and S. Tr. 73-76 (R-3),
(the “Pauley Double Jeopardy Acquittal Verdicts”).
Ipso facto, as a matter of law, the USAO’s 11/07/2008 Article II appellate political decision, the
voluntary dismissal with prejudice of the USA’s “cross-appeal” Gov.-I, (i) affirmed R-1, R-2, and
R-3 in favor of Ulysses T. Ware, (the “Prevailing Party”); (ii) triggered the Double Jeopardy
Clause’s protections in favor of Mr. Ware regarding all aspects of the 05cr1115 proceedings; (iii)
triggered res judicata and collateral on all issues, facts, and claims actually or necessarily resolved
by R-1 (market inefficiency), R-2 (the government’s risible “fraud on the market” trial theory
confirmed), and R-3 (the government’s insufficient trial evidence on market efficiency); (iv)
terminated the Court of Appeals’ subject matter jurisdiction over Mr. Ware’s Ware-1 direct
appeal, 07-5222cr; (v) established the “law of the case” as resolved by R-1, R-2, and R-3 (i.e., the
markets for INZS and SVSY’s securities were inefficient, and consequently, as a matter of law the
Government’s risible “fraud on the market,” trial theory, see S. Tr. 35-36 (R-2) and S. Tr. 73-76
(R-3) (October 12, 2006 transcript), lacking an efficient market for INZS and SVSY’s securities
failed miserably, and fell flat as a pancake); and (vi) terminated the 05cr1115 district court’s
Article III and 18 USC 3231 subject matter jurisdiction over the moot proceedings. The
Government’s 11/07/2008, Article III appellate political decision to voluntarily dismiss with
prejudice its 07-5670 Gov.-I “cross-appeal” of R-1, R-2, and R-3 had dire, disastrous, and
irreversible fatal consequences on the United States and its privies. The USAO’s prosecutors
checkmated the United States and blew up their own frivolous and risible case. A deserving
ending to a comical case tried by incompetent prosecutors (i.e., AUSAs Alexander H. Southwell,
Steven D. Feldman, Nicholas S. Goldin, Maria E. Douvas, Andrew L. Fish, Michael J. Garcia, Joon
Kim, Preet Bharara, Audrey Strauss, John M. McEnany, Melissa Childs, and Damian Williams); and
a delusional and schizophrenic district judge, William H. Pauley, III (deceased) and now the
“error-prone” criminal Edgardo Ramos.
Page 5 of 20
Jones.
According to magistrate judge Michael H. Dolinger, Dkt. 24, the USAO entered into the
illegal USSG 5K perjury cooperation agreement with its “material witness” Jeremy Jones and his
CJA court-appointed lawyer Marlon G. Kirton, Esq., an officer of the court, on “September 15,
2006.”10
Moreover, the District Judge, Pauley, J. secretly, without docketing the matter, arranged
for Jones to enter the bogus and fraudulent Rule 11 plea, see Exhibits 3 (Tr. 3-4); and furthermore,
on 10/11/06, Dkt. 23,11 Pauley, J. ratified, accepted, Jones’ bogus, bad faith, illegal, and
fraudulent Rule 11 plea, and cooperation agreement “prior to the start of trial”12 in 05cr1115.13
10 See Exhibit 4, Tr. 11 L 2-3.
11 Pauley, J. ratified and officially accepted Jones’ bogus, fraudulent, and illegal contract to
knowingly commit perjury, and to knowing with the consent and approval of the DOJ’s USAO
(SDNY) testify falsely, fraudulently, in a misleading, deceitful, and vindictive manner in exchange
for financial benefits, no prison time, and other illegal gratuities. Cf., Exhibit 2, infra, Kirton’s
letter dated April 30, 2008, acknowledged the USPO recommended that Jones be made
responsible for more than $700k in penalties which were forgiven by the USAO and Pauley, J.
pursuant to the suppressed and concealed USSG 5K cooperation agreement. Material
impeachment evidence to impeach Jones’ credibility and provide a motive for his lies, and false
and misleading trial testimony.
12Cf., Pauley, J., May 19, 2006, Dkt. 17, Tr. 5-6, Brady Court Order, see Exhibit 7 and 7-1, infra,
which ordered the USAO to disclose to Ulysses T. Ware all Brady and Giglio evidence “prior to the
start of trial.” (emphasis added).
13 See Dkt. 23, cf., Exhibit 6, infra. Pauley was clearly aware of his own Brady Court Order, see n.
12, supra, and in general aware of the Government’s duties and obligation to disclose Jones’ Rule
11 plea and cooperation agreement to Ulysses T. Ware. However, rather than protecting Mr.
Ware’s Constitutional rights to a fair trial, Pauley joined force with the USAO and the SEC, and
rigged and fixed the 05cr1115 (SDNY) proceedings to ensure that Mr. Ware was wrongfully
convicted based on knowing false, misleading, and perjured trial testimony obtained from the
Page 6 of 20
Jones.
As of today November 16, 2021, the USAO nor the District Court (SDNY) have made
available Jones’ USSG 5K cooperation agreement, contract, benefits, and other materials14
related to the negotiation and agreement reached to obtain Jones’ known perjured, false,
misleading, and fraudulent testimony knowing suborned and admitted in United States v. Ware,
05cr1115 (SDNY). Moreover, the District Court and the USAO have not publicly filed and docketed
Jones’ and the DOJ’s trial witnesses’ “nonprosecution agreements” and benefits received and the
requirements to receive the nonprosecution and cooperation agreements.15
Government’s bought and paid for trial witnesses. Currently, federal judges (SDNY) Edgardo
Ramos and Chief District (SDNY) Judge Laura Taylor-Swain, have acted and functioned not as
Article III federal impartial, unbiased, and competent judicial officers, but rather as extreme
partisans, biased, prejudiced, and with an evil Jim Crow racially-motivated perfidious and
pernicious motive and agenda, in their personal and individual capacities, in the “clear absence
of all jurisdiction” over the 04cr1224 and 05cr1115 (SDNY) moot proceedings. Egregious judicial
misconduct and violations of the Federal Tort Claim Act.
14Brady exculpatory impeachment, and Giglio impeachment materials the subject matter of the
May 19, 2006, Dkt. 17, (Pauley, J.) Brady Court Order, Exhibits 7 and 7-1; and the subject matter
of Ulysses T. Ware’s motions to hold the Damian Williams, Merrick Garland, Edward T.M.
Garland, USAO, Edgardo Ramos, and Laura Taylor-Swain, et al. in civil and willful criminal
contempt of the Brady Court Order.
15See Exhibit 1, infra, Page 3 of the Government’s United States v. Ware, 07-5222cr (2dCir.)
appeal brief: “The evidence at trial included the testimony of Ware’s former employees, who
[knowingly and while suborned by the USAO] testified [falsely and committed perjury with the
knowledge and consent of the USAO’s prosecutors and their supervisors] pursuant to
cooperation and nonprosecution agreements[.]” Brady and Giglio impeachment evidence
required to have been disclosure to Mr. Ware “prior to the start of trial” pursuant to the written
commands of the Brady Court Order, Dkt. 17, Tr. 5-6 (Pauley, J.), Exhibits 7 and 7-1. (emphasis
added). Indisputable civil and willful criminal contempt, 18 USC 401(3), of the Brady Court
Order.
Page 7 of 20
Jones.
Page 8 of 20
Jones.
Exhibit 1
Page 9 of 20
Jones.
Exhibit 2
Page 10 of 20
Jones.
Exhibit 3
Jones’ concealed and suppressed purported Rule 11 proceedings was arranged and
coordinated by the trial judge William H. Pauley, III, AUSA Alexander H. Southwell,
and Jones’ CJA court-appointed lawyer, Marlon G. Kirton, Esq. as a fraud on the
court, and as a conspiracy to violate Ulysses T. Ware’s Giglio and Brady rights.
Page 11 of 20
Jones.
Exhibit 4
Page 12 of 20
Jones.
Exhibit 5
The illegal and unethical process utilized in violation of Fed. R. Crim. P. Rules 43(a)(1), (2),and
(3)16 and 5517 by the USAO to knowingly and in bad faith suppress and conceal Jones’s illegal
USSG 5K Rule 11 plea and cooperation agreements and proceedings from Ulysses T. Ware and
the public in violation of the First Amendment.
16 Rule 43. Defendant’s Presence.
(a) When Required. Unless this rule, Rule 5, or Rule 10 provides otherwise, the defendant must
be present at:
(1) the initial appearance, the initial arraignment, and the plea;
(2) every trial stage, including jury impanelment and the return of the verdict; and
(3) sentencing.
17
Rule 55. Records.
The clerk of the district court must keep records of criminal proceedings in the form prescribed
by the Director of the Administrative Office of the United States Courts. The clerk must enter in
the records every court order or judgment and the date of entry. (emphasis added).
Page 13 of 20
Jones.
Exhibit 6
Page 14 of 20
Jones.
Exhibit 7
Page 15 of 20
Jones.
Exhibit 7-1
Page 16 of 20
Jones.
i
Brady and Giglio Material Pursuant to Brady v. Maryland, 373 U.S. 83 (1963), and its progeny,
including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976),
United States v. Bagley, 473 U.S. 667 (1985), Kyles v. Whitney, 514 U.S. 419 (1995), and New
York Rule of Professional Conduct 3.8, Ulysses T. Ware requests immediate identification and
disclosure of all documents and information (in whatever form) that are favorable to the defense
or that would tend to exculpate Ulysses T. Ware Jeremy Jones, or mitigate their culpability with
respect to the charges in the United States v. Ware, 04cr1224 (SDNY) and United States v. Ware,
05cr1115 (SDNY) indictments, that would tend to impeach any potential witness against Ulysses
T. Ware, or that are relevant to the issue of sentencing, including but not limited to the following:
1. Any document or information indicating or tending to establish that any of the allegations in
the indictments are not true.
2. Any document or information indicating or tending to establish that any meeting,

conversation, use of words, practice, or conduct that is the subject of the indictment or forms
the basis of the indictment did not violate government laws, regulations, standards or established
business practices.
3. Any document or information indicating or tending to establish that Ulysses T. Ware believed
that any meeting, conversation, use of words, practice, or conduct that is the subject of the
indictment or forms the basis of the indictment did not constitute a crime.
4. Any document or information indicating or tending to establish that any other person
(including but not limited to the alleged co-conspirators) believed that any meeting,
conversation, use of words, practice, or conduct that is the subject of the indictment or forms
the basis of the indictment did not constitute a crime.
5. Any documents or information indicating or tending to establish that Ulysses T. Ware did not
instigate, control, authorize, approve, or acquiesce in the practices that are the subject of the
indictment.
6. Any documents or information indicating or tending to establish that the alleged false or
fraudulent pretenses were not false.
7. Any documents or information indicating or tending to establish that the alleged false or
fraudulent pretenses were not material.
Page 17 of 20
Jones.
8. Any documents or information indicating or tending to establish that a third person was
responsible for the financial transactions or press releases, or Rule 144(k) legal opinions at issue
in any count of the indictment.
9. Any document or information indicating or tending to establish that Ulysses T. Ware engaged
in any conduct that forms the basis of the indictment in reliance upon advice provided by counsel,
accountants, or Securities and Exchange Commission’s rules, regulations, or published policies,
e.g., SEC Release 33-7190 n. 17 (1995); or 15 USC 77b(a)(11).
10. Any document or information (in whatever form) that could be used to impeach any potential
government witness, or any person whose statements will be introduced pursuant to Fed. R. Evid.
801(d)(2)(C), (D), or (E), including but not limited to:
a. Any document or information relating to any conviction, arrest, or criminal record of, and any
criminal charge brought against, any potential government witness;
b. Any document or information relating to promises, consideration, or inducements made to

any potential government witness, whether directly to the witness or indirectly to the witness’
attorney, friends, family, employer, business associates, or other culpable or at risk third-party.
“Consideration” means anything of value or use, including immunity grants, whether formal or
informal, witness fees, transportation or relocation assistance, money, dropped or reduced
charges or suggestions of favorable treatment with respect to any federal, state or local criminal,
civil, or administrative matter, expectations of downward departures or motions for reduction of
sentence, considerations regarding forfeiture of assets, or stays of deportation or other
immigration status considerations;
c. Any document or information tending to show the bias of a potential government witness,
including animosity toward Ulysses T. Ware, animosity toward any group or entity of which
Ulysses T. Ware is a member or with which Ulysses T. Ware is affiliated, a relationship with the
alleged victim, or known but uncharged criminal conduct that may provide an incentive to curry
favor with a prosecutor;
d. Any document or information affecting the reliability of a potential government witness’s

testimony, including known alcohol or abuse, mental health issues or other issues that could
affect the witness’s ability to perceive and recall events (e.g., the SEC’s professional misconduct
discipline imposed on the Government’s 04cr1224 (SDNY) FRE 404(b) bad acts witness former
SEC lawyer Jeffrey B. Norris’ own ‘bad acts’);
e. Any document or information relating to any inconsistency in statements given by any

potential government witness;
Page 18 of 20
Jones.
f. Any document or information relating to any inconsistency between agents’ and/or
prosecutors’ rough notes and FBI 302s or other memoranda of interviews of any potential
government witness;
g. Any document or information bearing adversely on the character or reputation for truthfulness
of any potential government witness; and
h. Each specific instance of conduct from which it could be inferred that any potential
government witness is untruthful.
11. The date of and participants in each and every interview (including not only interviews
conducted by the U.S. Attorney’s Office or the Securities and Exchange Commission, but also
interviews conducted by third parties), debriefing, “queen for a day” session, proffer, deposition,
or other statement or description of the alleged facts made by each potential government
witness (whether directly or indirectly, such as a proffer made by counsel).
In addition, please specify, as to each such witness, the first date on which the witness made any
allegation that Ulysses T. Ware engaged in any allegedly unlawful conduct or any conduct alleged
in the indictment. As you are aware, New York has adopted Rule of Professional Conduct 3.8,
entitled “Special Responsibilities of Prosecutors and Other Government Lawyers,” which
provides that a prosecutor “shall make timely disclosure to [the defense] of evidence or
information known to the prosecutor or other government lawyer that tends to negate the guilt
of the accused, mitigate the degree of the offense, or reduce the sentence . . . .” Rule 3.8(b).
The Supreme Court has recognized that Rule 3.8 imposes a higher standard on prosecutors than
the standards mandating disclosure of exculpatory evidence under Brady. See Kyles, 514 U.S.
at 437 (“[Brady] requires less of the prosecution than the ABA Standards for Criminal Justice,
which call generally for prosecutorial disclosures of any evidence tending to exculpate or
mitigate.”); ABA Standards for Criminal Justice, Prosecution Function and Defense Function 3-
3.11(a) (3d ed. 1993) (“A prosecutor should not intentionally fail to make timely disclosure to the
defense, at the earliest feasible opportunity, of the existence of all evidence or information which
tends to negate the guilt of the accused or mitigate the offense charged or which would tend to
reduce the punishment of the accused”); ABA Model Rule of Professional Conduct 3.8(d) (1984)
(“The prosecutor in a criminal case shall . . . make timely disclosure to the defense of all evidence
or information known to the prosecutor that tends to negate the guilt of the accused or mitigates
the offense”).
We contend that the foregoing categories of information constitute Brady and Rule 3.8(b)
material, and that disclosure should take place immediately. Ulysses T. Ware further requests
Page 19 of 20
Jones.
that the government identify with particularity and provide copies of all materials that qualify as
Brady and Rule 3.8 material, as described above. Please advise us promptly whether the
government will be producing Brady material immediately even if it is contained in what might
otherwise be considered as Jencks material, or whether you take the position that you are not
obligated to produce such material at this time.
We also request the underlying source material for any Brady and Rule 3.8(d) information, as
opposed to any summary letter or paraphrased description of the information. Please advise us
promptly whether the government will not be producing underlying source material. For
purposes of the Brady doctrine, “the format of the information does not determine whether it is
discoverable.” U.S. Attorneys’ Manual § 9-5.002.B.5 (2018). For example, material exculpatory
information that is provided “during a conversation with an agent or a witness is no less
discoverable than if that same information were contained in an email.” Id. We therefore request
that all such information be memorialized and produced to Ulysses T. Ware.
Page 20 of 20
Jones.

11.16.21 53A-2 Re DKT 24, The USAO's Concealed and Suppressed Rule 11 Transcript of Jeremy Jones

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Docket NO: 04cr1224 and 05cr1115 (SDNY) (53A-2)

In the United States District Court

2 See Exhibits 2, 3, and 4, infra.

and obstruction of justice in many cases as a federal prosecutor.

10 See Exhibit 4, Tr. 11 L 2-3.

requirements to receive the nonprosecution and cooperation agreements.15

16 Rule 43. Defendant’s Presence.

2. Any document or information indicating or tending to establish that any meeting,

b. Any document or information relating to promises, consideration, or inducements made to

d. Any document or information affecting the reliability of a potential government witness’s

e. Any document or information relating to any inconsistency in statements given by any

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