IRNewswires Special Judicial Corruption

Investigation (SDNY) Report

USAG Merrick Garland, U.S. Attorney Damian Williams, Margaret
M. Garnett, District Judges Edgardo Ramos, and Chief District
Judge Laura Taylor-Swain’s Conspiracy to obstruct, delay, frustrate,
impede, and undermine the due administration of justice and the
rule of law.

IRNewswires Media Group

Meredith Kammler, LLB. LLM, Ph.D., Int’l Investigative reporter
Alan Reitman, JD, Ph.D., Esq., summa cum laude, Int’l Investigative Reporter.
December 6, 2021
London, UK

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 Judicial and Prosecutorial Criminal Conspiracy to Obstruct Justice.
IRN’s lawyers and investigators have obtained a copy of Ulysses T. Ware’s latest
submissions to the U.S. District Court (SDNY) in the Ware cases, U.S. v. Ware, 04cr1224
(SDNY) and 05cr1115 (SDNY). The record evidence is overwhelming. Numerous judicial
and prosecutorial crimes have been committed by sitting federal judges and federal
prosecutors, Damian Williams, Margaret M. Garnett, Merrick Garland, and others.
In particular, in what is perhaps the most egregious and pernicious, are the judicial
crimes, high crimes, and misdemeanors, impeachable offenses, committed and currently
being committed by Article III judicial officers, Edgardo Ramos, and Laura Taylor-Swain,
both U.S. federal judges. IRN’s investigators uncovered previously concealed and
suppressed conclusive proof, the December 8, 2012, letter of Mr. Ware to then
Magistrate Judge (SDNY) Michael H. Dolinger. Judge Dolinger played an instrumental and
critical role in the willful and criminal suppression and concealment of the government’s
“principal witness” at trial in Mr. Ware’s 05cr1115 case, Jeremy Jones’ USSG 5k perjury
contracts.
IRN’s investigators have been informed according to officials within the Office of
the District Clerk (SDNY), who fearing vicious retaliation spoke under a condition of
confidentiality that, Jeremy Jones’ secret Rule 11 proceedings occurred, “with the
permission and under the exclusive direction of former District Judge Williams H. Pauley,
III” (deceased). Judge Dolinger allegedly accepted Jones’ purported Rule 11 plea
agreement and USSG 5k perjury contract on or about September 22, 2006, allegedly in
“open court.” However, the Clerk’s Office confirmed that Jones’ alleged Rule 11
proceedings were and have never been officially placed on the public docket in 05cr1115
(SDNY) by “orders of Judge Pauley.” IRN’s lawyers have talked with officials inside the
Office of the Clerk (SDNY) who refused to speak on the records for “fear of retaliation”
who recently informed IRN’s Alan Reitman, Esq.:
“ … Judge Pauley, Judge Dolinger and the Government’s lawyers [AUSA Alexander H.
Southwell and U.S. Atty. Michael J. Garcia] arranged Jones’ Rule 11 plea proceedings
… the matter was not properly docketed by orders of Judge Pauley. Judge Pauley was
in control of everything. He along with the Government’s lawyers. They are the
persons to blame for this fiasco ….”

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 Former District Judge William H. Pauley, III (deceased).

IRN’s lawyers have obtained definitive proof and according to Second Circuit
judicial precedents, Judges Pauley and Robert W. Sweet (deceased), both deliberately and
intentionally violated due process of law by the illegal and fraudulent entry of two illegal
alleged “leave-to-file” sanction orders, Dkt. 222 (Pauley, J.) and Dkt 160 (Sweet, J.),
ostensibly as the illegal means and methods to prevent, obstruct, frustrate, delay, and
impede Mr. Ware from gaining access to Jones’ and other government witnesses’
“cooperation and nonprosecution agreements” required to have been disclosed to Mr.
Ware pursuant to the commands of the Brady Court Orders entered in 05cr1115 (Dkt. 17,
Tr. 5-6) and 04cr1224 (Dkt. 32).
According to court records in July 2021, District Judge Edgardo Ramos was
substituted in both 04cr1224 and 05cr1115 after the deaths of Judges Sweet and Pauley,
respectively; and Judge Ramos, being severely unqualified and apparently ignorant of the
constitutional requirements regarding due process of law, has eagerly and with malice
aforethought, as a willing participant in the conspiracy to obstruct justice, Judge Ramos
has willfully continued the illegal scheme to violate Mr. Ware’s right to due process of law
by the illegal and unconstitutional enforcement of the null and void ab initio alleged and

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purported “leave-to-file” sanction orders: entered in the “absence of all jurisdiction,”
entered in egregious violation of Second Circuit judicial precedents, and due process of
law.
Judges Edgardo Ramos and Chief District Judge Laura Taylor-Swain, both,
functioning as unindicted co-conspirators have knowingly and willfully colluded and
conspired with the Government’s lawyers, Damian Williams, USAG Merrick Garland, and
others to knowingly, willfully, in bad faith, as a fraud on the federal courts, to continue to
conceal and suppress Jones’ fraudulent and void ab initio Rule 11 and USSG 5k perjury
contract, (Brady and Giglio exculpatory and impeachment evidence), by preventing and
criminally impeding Mr. Ware from having his submissions timely adjudicated on the
merits, and the timely enforcement of the Brady Court Orders via the civil and criminal
contempt court processes, cf., with the Federal Tort Claim Act.
The Ware cases are perhaps the most pernicious and insidious occurrences of
criminal prosecutorial and judicial misconduct and corruption that IRNewswires has
reported on in the last 30 years. Cases on par with the corruption of the American
Executive Branch in the Watergate Scandal that brought down an American president,
Richard M. Nixon. Will this festering judicial and prosecutorial Jim Crow racially-motivated
scandal bring down the entire United States Justice Department? “The bell is tolling. It
tolls for thee.”

“Democracy is not equipped for conspiracy between the

Executive and Judicial Branches. That is its Achilles heel.
That is its downfall.”
(Herman Melville).
Copyright © 2021.All rights reserved
IRNewswires Media Group (London, UK).

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 Exhibit A

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 Case Nos. 05cr1115 (SDNY) and 04cr1224 (SDNY) (#53A-5)

Submitted on December 3, 2021, to: Pro_SE_Filing@nysd.uscourts.gov

ChambersNYSDRamos@nysd.uscourts.gov
/s/ Ulysses T. Ware
Ulysses T. Ware
123 Linden Blvd.
Suite 9-L
Brooklyn, NY 11226
(718) 844-1260 phone
utware007@gmail.com

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK
United States of America, et al.,
Respondents, (Unindicted Co-conspirators),

v.

Ulysses T. Ware,
Petitioner (Prevailing Party).

Doc. 53A-5 re: Clear, Plain, and Prejudicial Legal Error, Conspiracy to Obstruct Justice, Fraud on the Court,
Criminal Civil Rights violations, Mail and Wire Frauds, and Civil and Criminal Contempt, 18 USC 401(2)
and 401(3), of: (1) the May 19, 2006, Dkt. 17, Tr. 5-6, Brady Court Order (05cr1115) (Pauley, J.) (deceased)
and (2) the August 10, 2007, Dkt. 32, Brady Court Order (Sweet, J.) (deceased) by Robert W. Sweet,
William H. Pauley, III, Edgardo Ramos, Laura Taylor-Swain, Amalya L. Kearse, Robert D. Sack, Michael
J. Garcia, Preet Bharara, Joon Kim, Damian Williams, Audrey Strauss, Melissa Childs, John M. McEnany,
Margaret M. Garnett, Daniel Gitner, Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin,
Andrew L. Fish, Maria E. Douvas, Merrick B. Garland, and others acting under color of law, acting in
their official, personal and individual capacity “in the clear absence of all jurisdiction,” jointly, (the
“Unindicted Co-Conspirators”).

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 Certificate of Service

I Ulysses T. Ware have this 3rd day of December 2021, served the United States DOJ’s lawyer,

Damian Williams, United States Attorney (SDNY), with a copy of this pleading via email to

Damian.Williams@usdoj.gov, Deputy U.S. Atty (SDNY) Margaret M. Garnett,

Margaret.Garnett@usdoj.gov, USAG Merrick B. Garland via 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, Chief Bankr. Judge (BC NDGA) Wendy L. Hagenau at GANB-

Hagenau@ganb.uscourts.gov, Marlon G. Kirton, Esq. at kirtonlawfirm@gmail.com, and

USAO’s chief of the criminal division Daniel Gitner, Esq., at dgitner@gmail.com and

Daniel.Gitner@usdoj.gov.

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 U.S. Atty (SDNY) Damian Williams Deputy U.S. Atty Margaret M. Garnett

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 Memorandum of Law
I.
A. Dkt. 222 (05cr1115)1 and Dkt. 160 (04cr1224)2, the purported “leave-to-file” sanction orders,
(i.e., illegal and unlawful filing injunctions), were entered in egregious, willful, and bad faith violation of
due process of law and binding circuit precedents; done to deliberately and as an illegal overt act in
furtherance of the DOJ’s conspiracy to obstruct justice and conceal the Government’s “principal witness”
in U.S. v. Ware, 05cr1115 (SDNY) Jeremy Jones’ illegal, unenforceable, and null and void ab initio Rule
11 plea agreement, Rule 11 plea transcript, Dkt 24, and USSG 5k perjury contract,3 Brady and Giglio
exculpatory and impeachment evidence, and perfidiously violate Ulysses T. Ware’s right to due process
of law. CF., 18 USC 241 and 242 (federal hate crime statutes).4

1. Contentions.

The Petitioner contends that any alleged “leave-to-file” sanction order (injunction), Dkt. 222
(05cr1115) and Dkt 160 (04cr1224), that did not strictly adhere to the circuit precedents’ procedural and
substantive due process of law requirements, prior to entry, listed in n.1, 2, and 3, infra, are therefore
as a matter of law null and void ab initio, have no legal preclusive effect, and ipso facto unenforceable.5

1
Exhibit 2, infra.

2
Exhibit 3, infra.
3
Dated September 15, 2006, cf., Dkt. 24 (1115) at page 11, Exhibit 4, cf,. Exhibit 1, infra (CJA court-appointed
lawyer, officer of the court, Marlon G. Kirton, Esq., letter to District Judge Pauley dated April 30, 2008, that
confirmed that government 05cr1115 trial witness Jeremy Jones received a USSG 5k letter from the government’s
prosecutors, Michael J. Garcia, and Alexander H. Southwell, for his known perjured and fabricated testimony).

4
https://www.justice.gov/crt/hate-crimes-prosecutions#hatecrimes.
5
The purported “leave-to-file” sanction orders have no lawful preclusive effect on the District Court (SDNY) in
regard to the adjudication of the merits of Ulysses T. Ware’s submissions: on the one hand a leave-to-file sanction
submission is required to be reviewed by the court on the merits with respect to the submitted claims (i.e., which
requires the reviewing court to have Article III subject matter jurisdiction over the issues, facts, and claims within
the submission); and on the other hand, a leave-to-file sanction requires the reviewing court to enter a written
order detailing the legal reasons for the denial of access to the court. Ramos, J., being completely ignorant in the
law on any subject, is of the erroneous position that he alone is supreme, a judicial king, a puppet, regarding what
is or what is not subject to adjudication in the District Court. He as usual, i.e., “error-prone,” is incorrect.

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 In regard to the null and void ab initio alleged and bogus “leave to file” sanction orders (i.e.,

unenforceable injunctions), Dkt. 222 (05cr1115), Exhibit 2 and Dkt 160 (04cr1224) Exhibit 3, infra, circuit

precedent6 outlawed the sua sponte implementation of any filing injunction or sanction without first (i)

notice served on the party on which the sanction was to be imposed the sanctioning court, i.e., entry

of a show-cause order, and (ii) the litigant provided with a meaningful opportunity to be heard on the

merits of the alleged cause for the sanction.

According to the official dockets in both 04cr1224 and 05cr1115 (SDNY) the required show cause

order or any meaningful opportunity to be heard was not provided to Ulysses T. Ware prior to the entry

of the bogus and void ab initio purported leave-to-file sanction orders Dkt 222 and Dkt 160. Thus, as a

matter of law, the District Court has no lawful sanctioning orders7 (injunctions) that prevent the Court

6
Lei v. Meddaugh, 229 F.3d 121, 123 (2d Cir. 2000) (“However, "[t]he unequivocal rule in this circuit is that the
district court [Pauley, Sweet, Taylor-Swain, and Ramos] may not impose a lawful filing injunction on a
litigant [Ulysses T. Ware] sua sponte without first providing the litigant with notice and an opportunity to be
heard." Moates v. Barkley, 147 F.3d 207, 208 (2d Cir. 1998) (per curiam). The "chance to respond is an empty
opportunity if the party is not given adequate time to prepare his response." Schlesinger Inv. Partnership v. Fluor
Corp., 671 F.2d 739, 742 (2d Cir. 1982) (reversing sua sponte dismissal entered without prior notice). (emphasis
added).

7
Lei, Id. at 123, “Finally, we note that the district court did not memorialize the oral order in a formal
injunction. Federal Rule of Civil Procedure 65(d), which provides the standards for the form and scope of
injunctions, contemplates the issuance of a written order. See Fed. R. Civ.P. 65(d). The provisions of this rule "are
no mere technical requirements." Schmidt v. Lessard, 414 U.S. 473, 476, 94 S.Ct. 713, 38 L.Ed.2d 661 (1974).
Compliance with this rule is essential because, "until a district court issues an injunction, or enters an order
denying one, it is simply not possible to know with any certainty what the court has decided." Gunn v. Univ.
Comm. to End War in Viet Nam, 399 U.S. 383, 388 (1970). Since an injunctive order prohibits conduct under
threat of judicial punishment, fairness requires that the litigants receive explicit notice of precisely what
conduct is outlawed. See Lessard, 414 U.S. at 476. Such notice and specificity foster effective enforcement. See
id. Finally, detailed injunctions are needed to facilitate appellate review. See Fonar Corp. v. Deccaid Services,
Inc., 983 F.2d 427, 429-430 (2d Cir. 1993) (citing Lessard, 414 U.S. at 476-77, 94 S.Ct. 713). "[S]trict adherence to
the Rules is better practice and may avoid serious problems in another case." Clarkson, 544 F.2d at 633
(discussing Fed. R. Civ. P. 65(d) and 52(a)). (emphasis added).

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from adjudicating the merits of the 51H-1 (August 29, 2021) Motion for leave to file civil and 18 USC

401(3) criminal contempt show cause motions and all other pleadings submitted to the District Court

(SDNY) by Ulysses T. Ware.

The record evidence is overwhelming. Edgardo Ramos, a purported U.S. District Court (SDNY)

judge, clearly ignorant in the law, clearly acted in the “clear absence of all jurisdiction” over the 04cr1224

and 05cr1115 proceedings, i.e., acted and functioned not as an Article III judicial officer, but rather in his

personal and individual capacity, and incurred devastating financial and penal liability and jeopardy. 8

There is no “formal [lawful and enforceable filing sanction or] injunction” that requires Mr.

Ware to submit any purported “leave to file” motion prior to the Court adjudicating the merits, assuming

subject matter jurisdiction exists. If such “formal injunction” actually exists, which it does not, please

identify the docket reference where such “formal injunction” was filed in the court; and furthermore,

please identify on the dockets where the required “show cause” orders were entered prior to the

imposition of the fraudulent and null and void ab initio filing injunctions.

8
Ramos having a direct, personal, and substantial financial interest in 04cr1224 and 05cr1115, +$2.225 billion
dollars, and penal interest, 18 USC 401(3) criminal contempt of the Brady Court Orders, high crimes and
misdemeanors, impeachable offenses, in the cases sub judice, pursuant to 28 USC 455(a), and 455(b)(1-4) Ramos
is per se judicially disqualified to have entered any order in 04cr1224 and 05cr1115, cf., Tumey v. Ohio, 273 U.S.
510, 522 (1927) (“To subject a defendant to trial in a criminal case involving his liberty or property before a[n]
[incompetent] judge [Edgardo Ramos and Laura Taylor-Swain] having a direct, personal, substantial interest in
convicting him is a denial of due process of law.”). (emphasis added). Palpably Ramos lacks any knowledge or
competence in constitutional requirements in Article III judicial matters.

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 Accordingly, lacking the required “formal injunction”9 filed into the Court, the District Court

(SDNY) has no lawful authority to not file, docket, and adjudicate the merits of the August 29, 2021,

51H.1 and the Petitioner’s other pleadings and submission on an emergency basis, assuming subject

matter jurisdiction currently exists.

Consequently, Dkt. 222 and Dkt. 160 are null and void ab initio and have no lawful preclusive

effects to prohibit the Court from adjudicating Mr. Ware’s Rule 33 motion for a New Trial predicated on

“Flagrant” Brady violation; Motion to Dismiss the 05cr1115 and 04cr1224 (SDNY) Indictments; Motion

to Enforce the Brady Orders; Motion for Kordel Relief, Motion Challenging the Subject Matter

Jurisdiction of the 1224 and 1115 District Court, and other pending Emergency Motions. Judges Ramos,

Pauley, and Sweet designed and entered the ultra vires purported “leave-to-file” injunctions as the illegal

and fraudulent scheme to cover up, hide, suppress, and conceal their crimes and aided and abetted the

9
See Viola v. United States, 481 Fed. Appx. 30, 31 (2d Cir. 2012) ("[T]he procedure for imposing leave-to-
file sanctions involves three stages: (1) the court [Pauley, Sweet, Taylor-Swain and Ramos first] notifies the litigant
that future frivolous filings might result in sanctions; (2) if the litigant continues this behavior, the court orders
the litigant to show cause as to why a leave-to-file sanction order should not issue; and (3) if the litigant's
response does not show why sanctions are not appropriate, the court issues a sanctions order.") (internal
quotation marks and citation omitted). (emphasis added). No required “show cause” order was ever entered in
1224 and 1115 according to the certified dockets in both proceedings. Nor was Ulysses T. Ware ever given any
opportunity to be heard why any such sanction was not appropriate.

Safir v. U.S. Lines, Inc., 792 F.2d 19, 23 (2d Cir. 1986). In determining whether to exercise that authority, and
impose a leave-to-file sanction, the Court [Sweet, Pauley, Taylor-Swain, and Ramos] is required to consider the
following factors: (1) the litigant's history of litigation and in particular whether it entailed vexatious, harassing or
duplicative lawsuits; (2) the litigant's motive in pursuing the litigation, e.g., does the litigant have an objective
good faith expectation of prevailing?; (3) whether the litigant is represented by counsel; (4) whether the litigant
has caused needless expense to other parties or has posed an unnecessary burden on the courts and their
personnel; and (5) whether other sanctions would be adequate to protect the courts and other parties.

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willful resistance, avoidance, evasion, and disobedience of the Brady and the Court Orders done to

violate the constitutional and legal rights of Ulysses T. Ware intentionally and deliberately, the Prevailing

Party.

Submitted by:

/s/ Ulysses T. Ware

12.03.21

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 Exhibit 1

The gov't "principal witness" Jeremy Jones' lawyer, Marlon G. Kirton, Esq., confirmed that Jones had received a
secret and concealed USSG 5k cooperation letter for his known perjury and false testimony at trial in 05cr1115
before Judge Pauley. Brady and Giglio and exculpatory and impeachment evidence required by the May 19,
2006, Dkt. 17, Tr. 5-6, Brady Court Order to have been disclosed “prior to the start of trial.” Note the required
“show cause” order was not entered before the illegal sanction order was entered in violation of due process
of law according to circuit precedent.

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 Exhibit 2

Judge Pauley was feeling the heat and fearing his and the USAO's exposure for their conspiracy to
suppress and conceal Brady and Giglio evidence bogusly entered Dkt. 222 as the illegal and
fraudulent means and method to obstruct justice and cover up Jones’ USSG 5k perjury contract
knowing that Judge Dolinger, Dkt. 220, had been contacted by Mr. Ware seeking Jones’ Rule 11 plea
documents.

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 Exhibit 3

Null and void ab initio, entered in willful and bad faith violation of due process of law and circuit
precedent by former District Judge Robert W. Sweet, feeling the heat and pressure, see Dkt. 159,
and fearing exposure for his crimes entered Dkt 160 in clear violation of due process of law.

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 Exhibit 4

Dkt 24 was deliberately and willfully concealed and suppressed by the USAO and Judge Pauley from
2006 until 2012 in criminal contempt of the Brady Court Order, Dkt 17, Tr. 5-6.

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 Exhibit 4-1

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 Exhibit 5

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 Exhibit 6

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 Exhibit 6-1

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