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Filed on 5/17/2022 10:21:32 AM

22cv3409 (SDNY) (21)


United States District Court
For the Southern District of New York
Ware v. USA, et al.
___________
Submitted by:
/s/ Ulysses T. Ware
The Office of Ulysses T. Ware
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Tuesday, May 17, 2022
__________________.

Ulysses T. Ware’s 05.17.22, Ex. 20 (May 17, 2022, re Inquiry regarding


Brady Orders Civil and Criminal Contempt Enforcement) to Dkt. 32
(Motion to Disqualify Judge Ramos in U.S. v. Ware, 04cr1224 (SDNY)
and 05cr1115 (SDNY) for: (1) Conspiracy to Commit Flagrant Judicial
and Prosecutorial Misconduct).1

The government was served with this pleading on 05.17.22 via Damian Williams at
damian.williams@usdoj.gov and Jun Xiang was served at jun.xiang@usdoj.gov, and
on USAG Merrick B. Garland to Jeffrey R. Ragsdale at Jeffrey.ragsdale@usdoj.gov.

1
The District Court (Ramos, J.), the UASO, Damian Williams, and USAG Merrick B. Garland have to the
current date, May 17, 2022, deliberately, intentionally, willfully, and in bad faith resisted all demands, 18
USC 401(2), and 401(3) criminal contempt of the Brady Court Orders, to disclose to Ulysses T. Ware the
bogus and fabricated Jeremy Jones’ USSG 5k perjury contracts, fabricated trial testimony, forged Rule 11
plea agreement, and fabricated allocution documents as required by the May 19, 2006, Dkt. 17, Tr. 5-7,
order (Pauley, J.) Brady court order entered in 05cr1115. See Exhibit 1, infra.

Page 1 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Memorandum No. 051722-A

From: Ulysses T. Ware

To: The District Court (SDNY) (Ramos, J.): U.S. v. Ware, 04cr1224 (SDNY) and U.S. v. Ware,
05cr1115 (SDNY), copied to U.S. Attorney General Merrick B. Garland, U.S. Attorney
(SDNY) Damian Williams, Chief District Judge Laura Taylor-Swain, and the Judicial
Conference of the United States, the Honorable John G. Robert, Jr., the Supreme Court of
the United States.

Date: May 17, 2022

Re: Brady Court Orders enforcement, 28 USC 2243 Show Cause Order, 28 USC 455(b)
disqualification, and Rule 41(a)(2) judgment enforcement proceedings; and Second
request for Judge Edgardo Ramos to immediately sua sponte recuse yourself from the
22cv3409 (SDNY) habeas corpus proceedings and all component proceedings related to
22cv3409 to ensure the public of the integrity of adjudication of the proceedings.

Judge Ramos:
Mr. Ware, the petitioner in Ware v. United States, et al., 22cv3409 (SDNY), 28 USC

2241(a) actual innocent, fundamental miscarriage of justice habeas corpus proceedings, (the

“Habeas Proceedings”), is writing to the Court in regard to invoking the Court’s general

supervisory power and Fed. R. Crim. P. 42 to enforce the Brady Court Orders, the Rule 41(a)(2)

final judgment, the adjudication of all outstanding applications filed in the Habeas Proceedings,

the referral of Merrick B. Garland, Lisa A. Monaco, Vanita Gupta, Jeffrey R. Ragsdale, Audrey

Strauss, John M. McEnany, Melissa Childs, Alexander H. Southwell, Steven D. Feldman, Nicholas

Page 2 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
S. Goldin, Maria E. Douvas, Sarah E. Paul, Katherine Polk-Failla, Margaret M. Garnett, Daniel

Gitner, David N. Kelley, Michael J. Garcia, Joon Kim, Preet Bharara, Damian Williams, Breon

Peace, Nina C. Gupta, and Jun Xiang to the DOJ’s Office of the Inspector General and Office of

Professional Responsibility, and the referral of Edgardo Ramos, LaShann DeArcy Hall, Amalya L.

Kearse, Robert D. Sack, Barbara S. Jones, Michael H. Dolinger, Andrew J. Peck, Thomas W.

Thrash, Jr., Kent J. Dawson, Wendy L. Hagenau, and Laura Taylor-Swain to the Judicial

Conference of the United States for egregious criminal judicial misconduct, and aiding and

abetting the DOJ’s conspiracy to suppress and conceal actual innocent Brady exculpatory and

impeachment evidence.2

I.

A. Brady Court Orders and other Court Orders Civil and Criminal Contempt Enforcement
Proceedings.

Judge Ramos Mr. Ware is sure that as a federal judge you are aware, perhaps, of the

Court’s judicial duty and obligation to enforce, vigorously, all outstanding Brady Court Orders

entered in the proceedings sub judice, to wit: (1) the May 19, 2006, Dkt. 17, order (Pauley, J.)

(deceased) (05cr1115) and (2) the August 10, 2007, Dkt. 32, order (Sweet, J.) (deceased)

(04cr1224), jointly, (the “Brady Court Orders”). Moreover, Mr. Ware is somewhat sure that you

are aware of your obligations under the Codes of Conduct for Federal Judges and 28 USC 455(a)

2
See included exhibits attached hereto.

Page 3 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
and 455(b) where you have been named as (1) a material fact witness, (2) an unindicted co-

conspirator, and (3) an adverse party-opponent in the Habeas Proceedings.3

To date the Court (Ramos, J.) has egregiously and maliciously ignored all requests made

by Mr. Ware to enforce the Brady Court Orders, and the Court has deliberately, intentionally, and

with an evil racially-motivated agenda aided and abetted the ongoing and continuous resistance

and disobedience4 of (1) the Brady Court Orders, and (2) the December 20, 2007, Dkt. 90,

superseding final judgment (Sand, J.) (deceased) entered in 02cv2219 (SDNY), 18 USC 401(3)

criminal contempt of the court orders, a felony criminal offense, a high crime and misdemeanor,

an impeachable offense, and a violation of the Code of Conduct for Federal Judges.

Judge Ramos, the 18 USC 401(3) criminal contempt crime(s) has (have) already been

committed by yourself, the DOJ’s employees and officials, Chief District Judge Laura Taylor-

Swain, and others that aided and abetted the willful resistance to the above court orders; thus,

your continuing resistance to the Brady Court Orders constitutes a racketeering conspiracy to

obstruct justice, 18 USC 1962(a-d); and regarding the 02cv2219 (SDNY) and 04cr1224 (SDNY)

3
Edgardo Ramos has been named in his personal, individual, and official capacity as a material fact
witness, an unindicted co-conspirator, and adverse party-opponent in the 22cv3409 (SDNY) habeas
corpus proceedings; accordingly, as a matter of law, Edgardo Ramos is judicially disqualified from all
judicial participation in all aspects of the Habeas Proceedings and their related component proceedings—
that is Alpha Capital, AG, et al. v. IVG Corp, a/k/a Group Management Corp., et al., 02cv2219 (SDNY),
U.S. v. Ware, 04cr 1224 (SDNY) and U.S. v. Ware, 05cr1115 (SDNY). In re Murchison, 349 U.S. 133, 136
(1949) (no man is permitted to be a judge in his own case).

4
See 18 USC 401(2) (officers of the court regarding official transactions) and 401(3) (willful resistance of
court orders).

Page 4 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
illegal contracts, GX 1-4 and GX-5, a conspiracy to violate N.Y. Penal Law, §190.40, the criminal

usury law, a class E felony, and a violation of 18 USC 1961(6)(A), the making and collection of an

illegal debt.5

In other words, you Judge Edgardo Ramos, a purported United States Article III federal

judge (SDNY), have criminally used and abused your official position as a United States federal

judge, the evidence is indisputable that you have aided, abetted, and directly and/or indirectly

knowingly and willfully participated in two or more acts of racketeering activity as defined in

18 USC 1961 et. seqs; and moreover, you, Damian Williams, Merrick B. Garland, Laura Taylor-

Swain, and others both known and unknown knowingly, willfully, with a racially-motivated evil

and malicious purpose formed an illegal association-in-fact, a continuing criminal enterprise, to

cover up, conceal, suppress, hinder, resist, and criminally disobey the written and inherent

commands of the court orders to protect the participants and the illegal profits and proceeds

5
See the March 15, 2022, opinion by the Second Circuit in Adar Bays, LLC v. Genesys ID, Inc., 18-3023cv
(2d Cir.) (held that contracts, [GX 1-4 and GX-5 in 04cr1224 and the subject matter of 02cv2219 (SDNY)
and 03-93031 (BC NDGA)] that charged a criminal usurious rate of interest violated NY Penal Law §190.40,
the criminal usury law, a class E felony, and accordingly the illegal contracts [GX 1-4 and GX-5] are null and
void ab initio, unenforceable, and thus, the illegal debt [cf., 02cv2219 (SDNY) and 03-93031-mhm (BC
NDGA Chapter 11 proceedings, In re Group Management Corp.,] is not legally required to be repaid—that
is, the 04cr1224 indictment is null and void ab initio, the 04cr1224 purported conviction and sentence is
consequently, null and void ab initio, ipso facto, and the 03-93031 (BC NDGA) Chapter 11 order of
dismissal, May 21, 2003, Dkt. 28, is null and void ab initio).

Page 5 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
generated by Alpha Capital, AG (Anstalt),6 the international Hobbs Act extortion, money

laundering, and racketeering criminal enterprise.7

B. Conclusion.

Judge Ramos, this matter has reached its natural limitation regarding you and your crimes

committed to obstruct justice, cover up, and conceal the crimes committed by the DOJ’s officials

and prosecutors.

Accordingly, not later than 12:00 noon on May 18, 2022, time of the essence, please

notify the parties regarding:

1. Whether or not you intend to sua sponte recuse yourself from all aspect of the

Habeas Proceedings?

2. Whether or not you intend to judicially enforce the Brady Court Orders and the

Rule 41(a)(2) superseding final judgment entered in 02cv2219 (SDNY), Dkt.. 90,

6
See government trial exhibits GX 1-4 and GX-5 in U.S. v. Ware, 04cr1224 (SDNY), (the “Illegal Contracts”),
recently ruled null and void ab initio and unenforceable by the Second Circuit’s opinion in Adar Bays, LLC
v. Genesys ID, Inc., 18-3023cv (2d Cir.) March 15, 2022. Which ipso facto annulled and abrogated all
probable cause in 04cr1224 (SDNY), and annulled and voided ab initio, ipso facto, the purported conviction
and sentence entered in 04cr1224; notwithstanding annulled and voided all Article III standing of the
United States in 04cr1224; annulled and voided all 18 USC 3231 subject matter jurisdiction in 04cr1224;
and annulled and voided, ab initio, ipso facto, all Article III standing, subject matter jurisdiction, and 28
USC 1332(a) diversity subject matter jurisdiction in 02cv2219 (SDNY) and 03-93031 (BC NDGA), GPMT’s
Chapter 11 proceedings, which annulled GX 250, GX 251, GX 252, and GX 253 in 04cr1224 (SDNY).
7
Published reports estimate that unregistered broker-dealer and 15 USC 77b(a)(11) statutory
underwriter Alpha Capital, AG (Anstalt) and its affiliates, New York-based unregistered broker-dealer LH
Financial Services, Inc., and Ari Rabinowitz, have collectively stole, extorted, and laundered more than
+$5 billion in illegal profits and proceeds derived from United States publicly traded companies.

Page 6 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
December 20, 2007, via civil and criminal contempt, Fed. R. Crim. P. 42

proceedings?

3. Whether or not you intend to refer Merrick B. Garland, Damian Williams, et al. to

the DOJ’s Office of the Inspector General and to the District Court’s (SDNY)

Committee on Discipline for willful resistance and disobedience of the Brady Court

Orders and other court orders?

4. Whether or not you intend to refer Edgardo Ramos, Laura Taylor-Swain, and the

judges names herein to the Judicial Conference of the United States with a judicial

recommendation of criminal prosecution for 18 USC 401(2), 401(3) and 18 USC 2,

201, 371, 241, 242, 1512, 1956-57, 156-17, and 1962(a-d)?

Judge Ramos, please file a copy of any response that you make to this Memorandum on

the dockets in 22cv3409 (SDNY) , 04cr1224 (SDNY), 05cr1115 (SDNY), and 02cv2219 (SDNY) to

perfect the record in the event other judicial relief is required to enforce the Brady Court Orders

and to seek recusal of Judge Edgardo Ramos.

Sincerely,

/s/ Ulysses T. Ware

May 18, 2022

Page 7 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibits

Page 8 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 1

Page 9 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 2

Page 10 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 3

Page 11 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 4

Page 12 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 5

Page 13 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 6

Page 14 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 7

Page 15 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 8

Page 16 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 10

Page 17 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 11

Page 18 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibit 12

Page 19 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Exhibits 13-18

Page 20 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Page 21 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Page 22 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Page 23 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Page 24 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
Page 25 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
The formation of the illegal association-in-fact: Chief District
Judge Laura Taylor-Swain, USAG Merrick B. Garland, Damian
Williams, and NY Senator Charles Schumer on behalf of
continuing criminal enterprise Alpha Capital, AG (Anstalt), Ari
Rabinowitz, and LH Financial Services, Inc.

Page 26 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.
International Hobbs Act money laundering and extortion
continuing criminal enterprise Alpha Capital, AG (Anstalt)
unindicted co-conspirators.

Page 27 of 27
Tuesday, May 17, 2022
(21) re Letter Memorandum 051722-A to Judge Ramos regarding (1) Brady Orders
Enforcement via civil and 18 USC 401(3), Recusal, and Rule 41(a)(2) judgment enforcement.

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