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Dkt. 129 Re Demand On Ramos and Garland Ot Disclose Brady Evidence
Dkt. 129 Re Demand On Ramos and Garland Ot Disclose Brady Evidence
Dkt. 129 Re Demand On Ramos and Garland Ot Disclose Brady Evidence
Brady Court Orders and Fed. R. Crim. P. 5(f) Brady Exculpatory and Impeachment Evidence
Production Demand on Edgardo Ramos (personally) and the District Court (SDNY) Records
Department to Produce all Brady Evidence, (B) Demand for Brady Rule 5(f) and Brady Court
Order Civil Contempt Enforcement Proceeding (personally) against Edgardo Ramos, Andre
Damian Williams, Jr., Merrick B. Garland, Daniel Gitner, Margaret M. Garnett, Lisa Monaco,
Vanita Gupta, the USAO’s Criminal Evidence Coordinator, John M. McEnany, Colleen
McMahon, Wendy L. Hagenau, John A. Horn, FINRA, Jeffrey B. Norris, and the Securities and
Exchange Commission, and (C) Demand to Merrick B. Garland and Andre Damian Williams, Jr.,
(officially on behalf of the United States, as purported and alleged adverse party-plaintiff or
respondent, the real party in interest) to Immediately Disclose the United States Article III
“Concrete Adverseness” and “Justiciable Controversy” apropos Ulysses T. Ware with Respect
to the 02cv2219 (SDNY), 03-0831 (D. NV), 03-93031 (BC NDGA), 04cr1224 (SDNY), 05cr1115
(SDNY), and 22cv3409 (SDNY) Proceedings’ Facts, Issues, and Claims.
_______
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
Wednesday, December 14, 2022
Page 1 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 2 of 32
Table of Contents
I. Demand for Edgardo Ramos to produce all Brady exculpatory and impeachment, and 28 USC
2249 materials in his possession. ................................................................................................................ 4
II. Demand for the United States to disclose its initial and current Article III “concrete adverseness”
with respect to all claims and allegations made by the United States in the 04cr1224 and 05cr1115
(SDNY) proceedings. ..................................................................................................................................... 6
III. Conclusion. ..................................................................................................................................... 10
Exhibits of deliberate and intentional Government suppressed and concealed Brady actual innocent
exculpatory and impeachment evidence currently in the possession of Edgardo Ramos. ..................... 12
Ex. 1-1, Dkt. 17, U.S. v. Ware, 05cr1115, (SDNY) Brady Court Order(1) currently in the possession of
Edgardo Ramos....................................................................................................................................... 13
Ex. 1-2, Dkt. 17, U.S. v. Ware, 05cr1115 (SDNY) Brady Court Order(2) currently in the possession of
Edgardo Ramos....................................................................................................................................... 14
Ex. 2-1, Dkt. 32, U.S. v. Ware, 04cr1224 (SDNY), Brady Order (1) currently in the possession of
Edgardo Ramos....................................................................................................................................... 15
Ex. 2-2, Dkt. 32, U.S. v. Ware, 04cr1224 (SDNY) Brady Order (2) currently in the possession of
Edgardo Ramos....................................................................................................................................... 16
Ex. 3-1, suppressed and concealed Brady actual innocent exculpatory and impeachment evidence--
FINRA’s May 17, 2021, unregistered broker-dealer certification currently in the possession of
Edgardo Ramos....................................................................................................................................... 17
Ex. 4-1, Judge Sand’s 12/20/2007, Dkt. 90, Rule 41(a)(2) superseding final judgment in 02cv2219
(SDNY), that annulled, and vitiated all orders, judgments, and proceedings in 02cv2219, and
conferred preferred prevailing party status on Ulysses T. Ware, GPMT, and the Landers. ................ 18
Ex. 5-1, Jeremy Jones’ alleged September 2006 Rule 11 proceedings of government principal witness
a person purported to be “Jeremy Jones” currently in the possession of Edgardo Ramos. ............... 19
Ex. 5-2, alleged September 2006 Rule 11 proceedings of government principal witness a person
purported to be “Jeremy Jones” currently in the possession of Edgardo Ramos................................ 20
Ex. 5-3, District Clerk (SDNY) fabricated and fraudulent 05cr1115 docket that concealed and
suppressed the alleged September 2006 Rule 11 proceedings of government principal witness a
persons to purported to be “Jeremy Jones” currently in the possession of Edgardo Ramos. ............ 21
Ex. 5-4, alleged September 2006 Rule 11 proceedings of government principal witness a person
purported to be “Jeremy Jones,” currently in the possession of Edgardo Ramos. ............................. 22
Page 2 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 3 of 32
Ex. 6-1, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment evidence
currently in the possession of Edgardo Ramos. .................................................................................... 23
Ex. 6-2, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment evidence
currently in the possession of Edgardo Ramos. .................................................................................... 24
Ex. 6-3, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment evidence
currently in the possession of Edgardo Ramos. .................................................................................... 25
Ex. 7-1: DOJ-SEC concealed and suppressed Norris Brady exculpatory email to Jeremy Jones that
indicted the SEC did not include Jeremy Jones in the DOJ-SEC Las Vegas bootleg grand jury
proceedings because the U.S. SEC, the United States, did not believe that Jones or the government’s
trial witnesses were involved in the fabricated conspiracy with Ulysses T. Ware as alleged in the
05cr1115 fabricated void ab initio and moot indictment currently in the possession of Edgardo
Ramos. .................................................................................................................................................... 26
Ex. 8-1: Marlon G. Kirton’s concealed and suppressed Brady exculpatory evidence regarding Jeremy
Jones, and the SEC currently in the possession of Edgardo Ramos. ..................................................... 27
Ex. 8-2: Marlon G. Kirton’s concealed and suppressed Brady exculpatory evidence regarding Jeremy
Jones, and the SEC: Kirton confirmed that Jones was “never made a defendant” in the DOJ-SEC Las
Vegas (03-0831)(D. NV) illegal bootleg grand jury proceedings, currently in the possession of
Edgardo Ramos....................................................................................................................................... 28
Ex. 9: SEC and DOJ concealed and suppressed exculpatory and impeachment communications
currently in the possession of Edgardo Ramos. .................................................................................... 29
................................................................................................................................................................ 29
Ex. 10, Judge Pauley, SEC and DOJ deliberately and intentionally concealed and suppressed actual
innocent Brady exculpatory evidence that annulled, abrogated, impeached, and vitiated the United
States’ 05cr1115 trial theory of “artificial inflation” of INZS and SVSY’s securities—the U.S. SEC in
July 2003 judicially admitted in the Las Vegas 03-0831 (D. NV) bootleg grand jury proceedings, a
binding judicial admission on the United States and its privies in all subsequent proceedings
(05cr1115 and 04cr1224), there was not “artificial” or any “increase” whatsoever of the “stocks”
“prices.” .................................................................................................................................................. 30
CERTIFICATE OF SERVICE ............................................................................................................................ 31
End of document. ....................................................................................................................................... 32
Page 3 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 4 of 32
Ulysses T. Ware Demands that Edgardo Ramos not later than Thursday, December 15,
2022, 1:00 PM, time of the essence, immediately produce (A) government “principal witness”
Jeremy Jones alleged September 2006 Rule 11 perjury contracts, all related transcripts,
debriefings, benefits received, benefits offered, debt relief, (B) production of the U.S. Bureau of
Prisons 28 USC 2249 certificate of “federal prisoner” status on March 21, 2022, and December
12, 2022,1(C) produce government FRE 404(b) witness Jeffrey B. Norris’ medical records and SEC
disciplinary records, (D) the 02cv2219 plaintiffs’ 15 USC 78o(a)(1) FINRA and SEC broker-dealer
registration documents, (E) all email and other communications between the USAO and the SEC
during the 03-0831 (D. NV) 2003-2005 illegal bootleg grand jury proceedings, (F) all other items
of Brady exculpatory or impeachment material in his current possession, or that have been in his
1 The 22cv3409, (“3409”), 2241 habeas corpus petition was filed on “March 21, 2022,” which the
district court (Ramos, J.) has judicially admitted and found as fact in Dkt. 126 at 1 (“Ware initially
filed his [2241 actual innocent] petition on March 21, 2022.”). (emphasis added). Therefore, for
the district court (EDNY), or the 22cv3409 (SDNY) district court to have 28 USC 2255(a) subject
matter jurisdiction to adjudicate the merits of the claims, the government was required to have
filed into the record the required 28 USC 2249 certified records—the certified certificate of
physical custody by the US BOP that Ulysses T. Ware was in the physical custody of the BOP on
“March 21, 2022,” which the United States has not done, according to the docket, and cannot
do. Accordingly, the 3409 district court lacks Article III and statutory subject matter jurisdiction,
2255(a), to conduct any judicial review of the 3409 petition and related filings, other than to
enter the show cause order, 28 USC 2243.
Page 4 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 5 of 32
possession; and (G) the immediate production of all judicial public records in his possession
regarding the 04cr1224 or 05cr1115 proceedings that have not been publicly docketed or
disclosed.
Page 5 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 6 of 32
II. Demand for the United States to disclose its initial and current
Article III “concrete adverseness” with respect to all claims and allegations
made by the United States in the 04cr1224 and 05cr1115 (SDNY)
proceedings.
Office of Ulysses T. Ware
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Wednesday, December 14, 2022
Re: U.S. v. Ware, 04cr1224 (SDNY), (“1224”), Dkt. 32 (Brady Order), and U.S. v. Ware,
05cr1115 (SDNY), (“1115”), Dkt. 17 (Brady Order), (the “Brady Orders”) disclosure
of the United States and its privies Article III “concrete adverseness” with respect
to all issues and claims in 1224 and 1115 for the purpose of Ware v. USA, et al.,
22cv3409 (SDNY), 28 USC 2241(c)(3) actual innocent habeas corpus petition, (the
“2241 Petition”).
Mr. Garland:
It has come to the attention of Ulysses T. Ware that Merrick B. Garland, Andre Damian
Williams, Jr., Edgardo Ramos, Lisa Monaco, Vanita Gupta, Colleen McMahon, and the USAO
actual and/or constructive possession numerous items of intentionally and in bad faith
Page 6 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 7 of 32
undisclosed, concealed, and suppressed actual innocent Brady exculpatory and/or impeachment
evidence, see Ex. 1-8, infra, (the “Brady Evidence”); which was required to have been produced
and disclosed by Garland “prior to trial” in 2007, but deliberately, intentionally, in bad faith,
suppressed, concealed, and covered-up, in civil and willful criminal contempt, 18 USC 401(3) of
the Brady Court Orders, see Ex. 1, and Ex. 2, infra, as an “unconscionable plan and scheme.”
The fraud on the court had as one of its criminal purposes and objectives to delay,
obstruct, impede, and tamper with “the judicial machinery” in such a way to deny Ulysses T. Ware
due process of law, a fair and impartial trial—a fraud on the court, as an overt act in furtherance
of and to protect, conceal, and suppress from public exposure the racketeering activities—the
unlawful criminal usury debt origination, underwriting, funding, collections, and laundering of
the profits and proceeds of the ongoing international Hobbs Act/RICO criminal usury loan
sharking, money laundering, and private equity Ponzi scam conspiracy being run in the SDNY,
and elsewhere, by Colleen McMahan,2 Frank V. Sica, Tailwind Capital Management LLP, Edgardo
Ramos, Ari Rabinowitz, Charles Ellis Schumer, Laura Taylor-Swain, Debra Ann Livingston, Robert
D. Sack, Amalya L. Kearse, Wendy L. Hagenau, convicted felon Edward M. Grushko, Barbara R.
Mittman, Ari Kluger, Alpha Capital, AG (Anstalt), LH Financial Services, Inc., and others, jointly,
(the “Racketeers”).
2
See 02cv2219 (SDNY) Dkt. 139, Dkt. 139-1, and Dkt. 139-2—District Judge (SDNY) Colleen McMahon, her
spouse Frank V. Sica, their so-called private foundation, and Tailwind Capital Management LLP criminal
usury convertible promissory note loan sharking, money laundering, bank, wire, and mail fraud
conspiracy, and private equity Ponzi scam details.
Page 7 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 8 of 32
Mr. Garland, given that you, personally, and officially have plenary authority over the
United States Department of Justice, (the “US DOJ”), a privy of the United States, the real party-
in-interest in the U.S. v. Ware, 04cr1224 (SDNY), (“1224”), and U.S. v. Ware, 05cr1115 (SDNY),
(“1115”), criminal proceedings, the plaintiff, on behalf of the United State the US DOJ, Garland
i. disclose the required Article III “concrete adverseness” with respect to all issues,
ii. disclose the required Article III “justiciable” “live” controversy with respect to the
United States claims and allegations made in the 1224 and 1115 indictments, (the
3
See 05cr1115, Dkt. 99, S. Tr. 31 L 18-25 (R-1); S. Tr. 35-36 (R-2), and S. Tr. 73-79 (R-3), jointly, (the “Pauley
Rule 29 Rulings”), which the United States filed a cross-appeal, U.S. v. Ware, 07-5670cr (XAP)(2d Cir.),
Gov-I, which challenged the Pauley Rule 29 Rulings. However, the then USAG on 11/07/2008 notified the
Court of Appeals (2d Cir.), pursuant to Article II, 18 USC 3742(b), and Fed. R. App. P. 42(b), the United
States, and its privies, had made a voluntary Article II mooting appellate political decision and determined
to moot, abandon, terminate, and dismiss with prejudice Gov-I—that is, the United States and its privies
had: (i) triggered the Double Jeopardy Clause’s and res judicata absolute finality, see Federated, 452 U.S.
at 398, 401-02, with respect to the Pauley Rule 29 Rulings; (ii) terminated and mooted Article III “concrete
adverseness” between Mr. Ware and the USA with respect to the Pauley Rule 29 Rulings; (iii) terminated
and mooted the 1115 district court and the Court of Appeals Article III subject matter jurisdiction over the
Pauley Rule 29 Rulings, (iv) terminated and mooted Article III “justiciable” controversy with respect to the
Pauley Rule 29 Rulings; (v) determined that the Pauley Rule 29 Rulings were the law of the case in all
subsequent proceedings [22cv3409 2241 Petition] between Mr. Ware and the United States and its privies;
(vi) conferred prevailing party status on Ulysses T. Ware with respect to the Pauley Rule 29 Rulings, and
all issues, facts, and claims that depend, actually or necessary, in whole and/or in part on, or rely on the
Pauley Rule 29 Rulings; and (vii) acquitted on 11/07/2008 Ulysses T. Ware of all charges in U.S. v. Ware,
05cr1115 (SDNY)—that is, the United States and its privies, i.e., the USAO, the U.S. BOP, etc., are strictly
forbidden and prohibited from any and all appearance in 05cr1115 (cf., Dkt. 126, n. 4, n. 5, and n. 6) as
adverse party-plaintiffs, petitioners, or respondents, given the United States, the real party-in-interest in
Page 8 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 9 of 32
iii. and to disclose whether or not the United States and its privies are lawfully
(XAP)(2d Cir.), Gov-I, cross-appeal of District Judge Pauley October 2007, Rule 29
Furthermore, in regard to the moot, bogus, ultra vires, and risible December 12, 2022,
Order, Dkt. 126 (Ramos, J.) entered in 22cv3409 (SDNY), any alleged notice of conversion, Dkt.
126, or conversion to 2255(a) is null and void ab initio, and moot—that is, Mr. Ware’s status as a
“federal prisoner” was terminated by the U.S. BOP on May 24, 2022, see Dkt. 128 (22cv3409)
(Decl. of Ulysses T. Ware). Moreover, only the government, the United States, the purported
adverse party-respondent—it has yet to be definitively determined exactly what claims the
United States is “concretely adverse” to, and thus, lawfully permitted to appear in 3409 whether
Only the United States, the purported “real party in interest,” not the district court, sua sponte,
and only then after affirming “concrete adverseness” to all claims—the United State was the
1115 11/07/2008 voluntary Article II termination of “concrete adverseness” and an Article III “justiciable
controversy” between Mr. Ware and the United States and its privies vis-à-vis the Pauley Rule 29 Rulings—
the United States and its privies, the USAO (SDNY) and the U.S. BOP ipso facto, per se, as a matter of
law are not adverse Article III “interested party-respondents” with respect to the 05cr1115, and
22cv3409 proceedings.
Page 9 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 10 of 32
plaintiff in the sub judice criminal cases, and, additionally, only after production of the 2249
certified US BOP records of physical custody of Ulysses T. Ware on “March 21, 2022”—a legal and
factual impossibility. Accordingly, Dkt. 126 is null and void ab initio, and moot.4
III. Conclusion.
Mr. Garland, currently you (personally), and the persons named herein as Racketeers and
Unindicted Coconspirators are in civil and willful criminal contempt of the Brady Court Orders’
written commands made on the United States by court order. Which I and surely the public think
should cause you as the USAG, the purported “chief law enforcement officer of the United
States,” great concern—how can it be that the USAG (Merrick B. Garland who regularly appears
on television and states, “We at the Department of Justice follow the facts, and apply the law in
an impartial and unbiased manner … no one is above the law ….”) is a criminal and willfully
violates federal law when he and his flunkies and minions are caught violating the law?
Is it because the USAG Merrick B. Garland is actively a willing and knowing participant in
the private equity Ponzi scam and criminal usury loan sharking RICO criminal enterprise of Alpha
Capital, AG (Anstalt) along with his patron Charles Ellis Schumer and his flunkies? Or is it because
4
See United States v. Lavelle, 194 F.2d 202 (2d Cir. 1952) and United States v. Bradford, 194 F.2d 197 (2d
Cir. 1952) (dismissed Section 2255 motions as moot because the petitioners were not incarcerated as a
“federal prisoner”—held the district court [22cv3409 (SDNY) (Ramos, J.), vis-à-vis, Dkt. 126] lacked subject
matter jurisdiction over Section 2255 proceedings if the petitioner [Ulysses T. Ware] is not physically
incarcerated by the US BOP or its agents in “federal prisoner” status). (emphasis added).
Page 10 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 11 of 32
USAG Merrick B. Garland thinks that he is “above the law” and he has special status—the law
However, for whatever reason USAG Merrick B. Garland, et al., is not above the law, and
will be held accountable for egregious, execrably, and criminal Brady Court Order contempts,
soon or later—remember the Nuremberg Trials, the Third Reich was expected “to last for a 1,000
years,” it went down in flames in twelve (12) years, not 1,000. Will USAG Merrick B. Garland, like
the Third Reich, “go down in flames” as all tyrants do as a result of hubris, incongruent duplicity,
The clock is ticking on USAG Merrick B. Garland. Will he last another two (2) years,
certainly not 1,000? Politicians with axes to grind after January 2023 will be out looking to hold
Garland, et al. accountable for numerous grievances they alleged and think he has wronged their
interests.
Sincerely,
Ulysses T. Ware
Page 11 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 12 of 32
Page 12 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 13 of 32
Ex. 1-1, Dkt. 17, U.S. v. Ware, 05cr1115, (SDNY) Brady Court Order(1) currently in the
possession of Edgardo Ramos.
Page 13 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 14 of 32
Ex. 1-2, Dkt. 17, U.S. v. Ware, 05cr1115 (SDNY) Brady Court Order(2) currently in the
possession of Edgardo Ramos.
Page 14 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 15 of 32
Ex. 2-1, Dkt. 32, U.S. v. Ware, 04cr1224 (SDNY), Brady Order (1) currently in the
possession of Edgardo Ramos.
Page 15 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 16 of 32
Ex. 2-2, Dkt. 32, U.S. v. Ware, 04cr1224 (SDNY) Brady Order (2) currently in the
possession of Edgardo Ramos.
Page 16 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 17 of 32
Ex. 3-1, suppressed and concealed Brady actual innocent exculpatory and impeachment
evidence--FINRA’s May 17, 2021, unregistered broker-dealer certification currently in the
possession of Edgardo Ramos.
Page 17 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 18 of 32
Ex. 4-1, Judge Sand’s 12/20/2007, Dkt. 90, Rule 41(a)(2) superseding final judgment in
02cv2219 (SDNY), that annulled, and vitiated all orders, judgments, and proceedings in
02cv2219, and conferred preferred prevailing party status on Ulysses T. Ware, GPMT,
and the Landers.
Page 18 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 19 of 32
Ex. 5-1, Jeremy Jones’ alleged September 2006 Rule 11 proceedings of government
principal witness a person purported to be “Jeremy Jones” currently in the possession of
Edgardo Ramos.
Page 19 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 20 of 32
Ex. 5-2, alleged September 2006 Rule 11 proceedings of government principal witness a
person purported to be “Jeremy Jones” currently in the possession of Edgardo Ramos.
Page 20 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 21 of 32
Ex. 5-3, District Clerk (SDNY) fabricated and fraudulent 05cr1115 docket that concealed
and suppressed the alleged September 2006 Rule 11 proceedings of government principal
witness a persons to purported to be “Jeremy Jones” currently in the possession of
Edgardo Ramos.
Page 21 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 22 of 32
Ex. 5-4, alleged September 2006 Rule 11 proceedings of government principal witness a
person purported to be “Jeremy Jones,” currently in the possession of Edgardo Ramos.
Page 22 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 23 of 32
Ex. 6-1, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment
evidence currently in the possession of Edgardo Ramos.
Page 23 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 24 of 32
Ex. 6-2, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment
evidence currently in the possession of Edgardo Ramos.
Page 24 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 25 of 32
Ex. 6-3, SEC lawyer Jeffrey B. Norris’ concealed and suppressed Brady impeachment
evidence currently in the possession of Edgardo Ramos.
Page 25 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 26 of 32
Ex. 7-1: DOJ-SEC concealed and suppressed Norris Brady exculpatory email to Jeremy Jones
that indicted the SEC did not include Jeremy Jones in the DOJ-SEC Las Vegas bootleg grand
jury proceedings because the U.S. SEC, the United States, did not believe that Jones or the
government’s trial witnesses were involved in the fabricated conspiracy with Ulysses T.
Ware as alleged in the 05cr1115 fabricated void ab initio and moot indictment currently in
the possession of Edgardo Ramos.
Page 26 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 27 of 32
Ex. 8-1: Marlon G. Kirton’s concealed and suppressed Brady exculpatory evidence
regarding Jeremy Jones, and the SEC currently in the possession of Edgardo Ramos.
Page 27 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 28 of 32
Ex. 8-2: Marlon G. Kirton’s concealed and suppressed Brady exculpatory evidence
regarding Jeremy Jones, and the SEC: Kirton confirmed that Jones was “never made a
defendant” in the DOJ-SEC Las Vegas (03-0831)(D. NV) illegal bootleg grand jury
proceedings, currently in the possession of Edgardo Ramos.
Page 28 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 29 of 32
Ex. 9: SEC and DOJ concealed and suppressed exculpatory and impeachment
communications currently in the possession of Edgardo Ramos.
Page 29 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 30 of 32
Ex. 10, Judge Pauley, SEC and DOJ deliberately and intentionally concealed and suppressed
actual innocent Brady exculpatory evidence that annulled, abrogated, impeached, and
vitiated the United States’ 05cr1115 trial theory of “artificial inflation” of INZS and SVSY’s
securities—the U.S. SEC in July 2003 judicially admitted in the Las Vegas 03-0831 (D. NV)
bootleg grand jury proceedings, a binding judicial admission on the United States and its
privies in all subsequent proceedings (05cr1115 and 04cr1224), there was not “artificial”
or any “increase” whatsoever of the “stocks” “prices.”
Page 30 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 31 of 32
CERTIFICATE OF SERVICE
The individuals listed below were served via email with a copy of this pleading on
December 14, 2022.
Page 31 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.
Case 1:22-cv-03409-ER Document 129 Filed 12/14/22 Page 32 of 32
End of document.
Page 32 of 32
Wednesday, December 14, 2022
(86) re: Demand for Merrick B. Garland, Andre Damian Williams, Jr., Edgardo Ramos, et al., and the U.S.
District Court (SDNY) Records Department to produce Jeremy Jones’ alleged Sept. 2006 Rule 11 perjury
contracts, bribes, payoffs, all Brady exculpatory and impeachment materials, Judicial Public Records.