DKT 208 Re DOJ OIG Criminal Misconduct Complaint

Case 1:22-cv-03409-ER Document 208 Filed 03/28/23 Page 1 of 44
Filed on 3/28/2023 10:22:25 AM

22cv3409 (SDNY) (149)
United States District Court
For the Southern District of New York
Ware v. United States, et al.
___________
Exhibit #1 (Office of the DOJ Inspector General Complaint of Criminal
Prosecutorial Misconduct committed by Andre Damian Williams, Jr.,
Merrick B. Garland, et al., and the USAO (SDNY) intentional actual
innocent Brady exculpatory evidence concealment) to Dkt. 207 re
Petitioner Ulysses T. Ware’s Actual Innocent Supplemental Claim
(“AISC”) #20 re: (1) DOJ’s EOUSA’s and U.S. Attorney’s Office’s (SDNY)
willful, bad faith, and reckless concealment and suppression of “over 15
boxes” of materials that “could be” actual innocent Brady exculpatory
and/or impeachment evidence; and (2) Exhibit P: Ulysses T. Ware’s
03.23.23 Emergency request for the DOJ’s Office of Professional
Responsibility, (“OPR”), to open an emergency disciplinary investigation
of the DOJ Prosecutors.1
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, March 28, 2023
1
Exhibit P, infra, was submitted separately to the Office of the District Clerk (SDNY) in a filing on March 23,
2023, Dkt. 206.
Page 1 of 44
(149) re Ex. To Dkt. 207--DOJ’s Office of the Inspector General (OIG) complaint of DOJ Prosecutors’
criminal prosecutorial misconduct in the Ware proceedings.
Table of Contents
APPLICATION to US DOJ’s Office of the Inspector General. ........................................................................ 4

Opening Statement. ..................................................................................................................................... 6
The Purpose of the Complaint. ................................................................................................................ 6
The Identity and Position of the Complainant. ....................................................................................... 6
The identities of the DOJ’s prosecutors that are involved in the criminal prosecutorial misconduct. .. 6
Background and Overview of the Allegations. ........................................................................................ 7
Basis for the Complaint. ........................................................................................................................... 7
Request for an Investigation. ................................................................................................................... 7
Section A: Introduction. ............................................................................................................................... 8
Section B: Background. ................................................................................................................................ 8
Section C: Statement of Facts. ..................................................................................................................... 9
Section C: Purpose of the Complaint. ........................................................................................................ 10
II. Allegations of Misconduct--Specific Allegations of Misconduct. .......................................................... 10
Attachment #1 in Support of Criminal Prosecutorial Misconduct and other Crimes............................... 12
Opening statement. ..................................................................................................................................... 15
Actual Innocent Supplemental Claim #20.................................................................................................... 17
I. .................................................................................................................................................................. 17
A. Introduction..................................................................................................................................... 17
B. Claims and Contentions. .................................................................................................................. 17
Exhibit P....................................................................................................................................................... 20
EMERGENCY APPLICATION to US DOJ Office of Professional Responsibility (Jeffrey R. Ragsdale). .............. 23
Memorandum of Fact and Emergency Petition for Criminal Violation of DOJ Rules of Ethics and
Professional Conduct. .................................................................................................................................. 24
Requested reliefs from OPR. ........................................................................................................................ 24
Declaration of Ulysses T. Ware .................................................................................................................... 25
Introduction:................................................................................................................................................ 31
DOJ ethics and professional standard violations claims and contentions. ................................................... 31
A. March 20, 2023, Executive Office of the United States Attorneys FOIA response. Exhibit A, infra. ..... 33
Section I: The USAO’s Failure to Prepare an Inventory of the Contents of the "15 Boxes." ..................... 34
Page 2 of 44
Section II: DOJ's Implicit Confession of Concealing and Suppressing Brady Material. ............................. 34
Section III: Request for Emergency Civil and Criminal Contempt Proceedings. ....................................... 34
B. Violation of the District Court (SDNY), the DOJ, and ABA Code of Ethics and Professional Obligations.
35
Exhibit A: EOUSA’s March 20, 2023, FOIA response letter. ...................................................................... 39
Exhibit B: U.S. v. Ware, 05cr1115 (SDNY), Dkt. 17, Brady court order--Perjury, lies, and false and
misleading statements of former AUSA Alexander H. Southwell regarding the USAO’s possession of
Brady materials........................................................................................................................................ 40
Exhibit B (con’t) ....................................................................................................................................... 41
Exhibit C: AUSA Southwell’s own official DOJ email to and from disgraced former SEC lawyer Jeffrey B.
Norris that established and confirmed the SEC and DOJ colluded, conspired, and used the Las Vegas 03-
0831 (D. NV) commingled SEC-DOJ illegal and unconstitutional proceedings as a boot leg grand jury
proceedings to gather evidence for the Ware criminal proceedings—clearly favorable Brady exculpatory
and impeachment material in the possession of the SEC, the USAO, and EOUSA’s records and files. ... 42
End of document. ........................................................................................................................................ 43
Certificate of service. ................................................................................................................................... 44
Page 3 of 44
APPLICATION to US DOJ’s Office of the Inspector General.

123 Linden Blvd., Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Via email to USOIG email whistleblower account

Office of the Inspector General
U.S. Department of Justice
Office of the General Counsel
950 Pennsylvania Avenue NW
Washington, D.C. 20530
c/o DOJ Office of the Inspector General, Andre Damian Williams, Jr, the Hon. Laura Taylor-Swain,
and District Judge Edgardo Ramos2
Re: In re Damian Williams and Merrick B. Garland, et al.: Criminal prosecutorial misconduct
and other federal and civil rights crimes committed during and in the Ware proceedings
(SDNY).
Dear Sir.
Please accept this complaint of criminal prosecutorial misconduct committed by the DOJ
Prosecutors named herein, aided, abetted, assisted, and facilitated by Edgardo Ramos, Laura
Taylor-Swain, Debra Ann Livingston, Wendy L. Hagenau, Amalya L. Kearse, Barbara S. Jones,
2
Both District Judges (Ramos and Taylor-Swain) are named in their personal and official capacities on the
face of the 22cv3409 (SDNY) petition as an adverse party-respondent, named as a hostile, adverse,
material fact witness, and also named as an unindicted coconspirator regarding the Proceedings—both
will be subpoenaed and compelled by the Compulsory Process Clause of the Sixth Amendment to appear,
produce records, and give testimony regarding the Proceedings, and therefore, ipso facto, as a matter of
law both District Judge pursuant to the Code of Conduct for Federal Judges, and 28 USC 455(a), 455(b)(1-
5), a judicially disqualified from all “participation” in the Proceedings.
Page 4 of 44
Robert D. Sack, Colleen McMahon, Edward T.M. Garland, Manibur S. Arora, Donald F. Samuel,
David B. Levitt, The State Bar of Georgia, M. Regina Thomas, Margaret M. Murphy, Joyce Bihary,
Coleman Ray Mullins, Patricia Sinback, Michael F. Bachner, Marlon G. Kirton, Gary G. Becker, David
Makol, Maria A. Font, Kilpatrick, Townsend, & Stockton, LLP (Atlanta, GA), J. Henry Walker, IV,
John W. Mills, III, Sims W. Gordan, Jr., Michael H. Dolinger, Andrew J. Peck, Ruby Krajick, David
Mulcahy, Thomas J. McCarthy, Michael Fitzpatrick, Joan E. McKown, Jeffrey B. Norris, Kent J.
Dawson, Thomas W. Thrash, Jr., the U.S. Marshals (SDNY and NDGA), Baker & McKenzie, LLP,
Lawrence B. Mandala, Thomas A. Leghorn, Bernard London, London Fisher, LLP, Robert Abaral,
Jeremy Jones, and others named in the Attachment, infra.
The Complainant, Ulysses T. Ware, is respectfully requesting that the OIG acknowledge
receipt of the whistleblower complaint, assign a file number, assign an investigative team, and
conduct a thorough and complete investigation of the included criminal prosecutorial misconduct
and other crimes committed by the DOJ Prosecutors and their unindicted coconspirators.
If the OIG has any further questions, or requires additional evidence to conduct its
investigation, contact the undersigned and make any request, also please see the Ware v. USA,
et al., 22cv3409 (SDNY), 2241 actual innocent habeas corpus petition, Dkt. 1, for supporting
sworn and undisputed factual predicates; and also see 02cv2219 (SDNY), Dkt. 127, for the RICO
18 USC 1961(6)(B), 18 USC 1956-57 money laundering, loan sharking, frauds, crimes, and
conspiracies of unregistered broker-dealers Colleen McMahon, Edgardo Ramos, Debra Ann
Livingston, Tailwind Capital Management LLP, Laura Taylor-Swain, Frank V. Sica, LH Financial
Services, Alpha Capital, AG (Anstalt), Stonestreet, L.P., Markham Holdings, Ltd., Amro
International, S.A., Ari Rabinowitz, Ari Kluger, convicted felon Edward M. Grushko, Barbara R.
Mittman, and Kenneth A. Zitter.
Submitted on this 28th day of March 2023, under oath, subject to the penalty of perjury, having
personal knowledge of the fact, pursuant to 28 USC 1746, to the DOJ’s Office of the Inspector
General.
/s/ Ulysses T. Ware
Ulysses T. Ware (the Complainant)
March 28, 2023
Brooklyn, NY
Page 5 of 44
Opening Statement.
The Purpose of the Complaint.
This Whistleblower Complaint is being filed with the Office of the Inspector
General (OIG) of the Department of Justice (DOJ) to report serious and alarming criminal
prosecutorial misconduct by the Office of the United States Attorney (SDNY) and Damian
Williams, et al. in the Ware criminal proceedings. The purpose of this Complaint is to bring
to the attention of the OIG the misconduct, violations of the law and DOJ Rules of
Professional and Ethics conduct by the DOJ Prosecutors and the USAO (SDNY), and to
request that an immediate investigation be initiated.3
The Identity and Position of the Complainant.
I, Ulysses T. Ware, this 27th day of March 2023, in Brooklyn, NY, under oath, subject to the
penalty of perjury, having personal knowledge of the facts, pursuant to 28 USC 1746, I am
the complainant in this matter. I am the petitioner in Ware v. USA, et al., 22cv3409
(SDNY), 2241 actual innocent habeas corpus petition, (the “Petition”).
The identities of the DOJ’s prosecutors that are involved in the criminal prosecutorial
misconduct.4
The DOJ prosecutors involved in the criminal prosecutorial misconduct are: Andre Damian
Williams, Jr., Steve R. Peikin, Daniel Gitner, Margaret M. Garnett, Audrey Strauss, John M.
McEnany, Melissa Childs, Jun Xiang, Breon Peace, Nina Gupta, Steven D. Feldman, Maria
E. Douvas, Sarah E. Paul, Katherine Polk-Failla, Andrew L. Fish, David N. Kelley, Michael J.
Garcia, Preet Bharara, Joon Kim, Alexander H. Southwell, John A. Horn, Nicholas S. Goldin,
Neal Katyal, Merrick B. Garland, Lisa Monaco, and Vanita Gupta, jointly, (the “DOJ
Prosecutors”).
3
The Attachment, infra, attached hereto, made a part hereof, in heac verba, fully set forth each of the
claims of criminal prosecutorial misconduct and other federal and state criminal offenses committed by
the DOJ Prosecutors in ad during the Ware proceedings in the U.S. federal courts and agencies.
4
The DOJ Prosecutors are currently, or were employed by the DOJ’s U.S. Attorney’s Office (SDNY), or are
currently employed in the DOJ’s main office in Washington, D.C.
Page 6 of 44
Background and Overview of the Allegations.
The allegations set forth in this Complaint stem from the ongoing attempts to
obtain Brady court orders' enforcement in the Ware criminal proceedings, which have
revealed serious and alarming criminal prosecutorial misconduct by the Office of the
United States Attorney (SDNY) and Damian Williams, et al. As detailed in the following
sections, on March 20, 2023, in response to a FOIA request by the Complainant the
Executive Office of the U.S. Attorneys (the “EOUSA”), implicitly and expressly confessed
and admitted that the USAO (SDNY) currently possessed "over 15 boxes" which apparently
have never been properly inventoried and may contain Brady actual innocent exculpatory
or impeachment materials covered by the Brady court orders entered in the Ware criminal
proceedings. The EOUSA demanded that Mr. Ware pay "$520.00" in advance for the USAO
(SDNY) to allegedly "conduct a search" for the Brady materials, even though the USAO
(SDNY), the United States, and by implication, the DOJ, is currently under and subject to
written Brady court orders, and Rule 5(f) to produce and disclose "all" materials that
"could be" Brady materials. See Brady v. Maryland.
Basis for the Complaint.
Based on my review of the facts and the law in this matter, I have found the
conduct of the USAO and the DOJ Prosecutors to be deeply troubling. The conduct of the
USAO and EOUSA also violated Rules 3.3, 3.4, and 8.4 of the DOJ and ABA Model Rules of
Professional Conduct. Additionally, the DOJ Prosecutors', the USAO's, and EOUSA's
conduct is prejudicial to the administration of justice, which is a clear violation of Rule 8.4.
The Brady court orders were put in place to ensure a fair trial and to prevent the conviction
of innocent individuals. The USAO's, the DOJ Prosecutors', and EOUSA's failure to fully
comply with these court orders undermines the integrity of the criminal justice system
and casts doubt on the legitimacy of any convictions5 that may have been obtained as a
result of this misconduct.
Request for an Investigation.
Given the severity and overt criminal culpability of the allegations and the impact
on the integrity of the criminal justice system, I request that the OIG of the DOJ conduct a
thorough and immediate investigation into the alleged criminal prosecutorial misconduct
willfully, intentionally, and recklessly committed by the DOJ Prosecutors and the USAO
5
See U.S. v. Ware, 04cr1224 (SDNY), and U.S. v. Ware, 05cr1115 (SDNY), the Ware criminal proceedings.
Page 7 of 44
(SDNY) and take appropriate action against those responsible for the misconduct. The
rights of the accused and the integrity of the criminal justice system depend on it.
Section A: Introduction.
1. This is a whistleblower complaint submitted to the Office of the Inspector General (OIG)
of the Department of Justice (DOJ) by Ulysses T. Ware, formerly an attorney licensed to
practice law in the State of Georgia. Mr. Ware brings to the attention of the OIG and the
public serious and alarming criminal prosecutorial misconduct by the Office of the United
States Attorney (SDNY) and Damian Williams, et al., (the “DOJ Prosecutors”), in
connection with ongoing attempts to obtain Brady court orders' enforcement in the Ware
criminal proceedings.
2. The purpose of this complaint is to alert the OIG to the egregious and unprecedented acts
of criminal prosecutorial misconduct by the EOUSA and USAO, which violated federal
criminal contempt statutes and the DOJ and ABA Model Rules of Professional Conduct.
The conduct of the DOJ prosecutors, the USAO, and EOUSA is prejudicial to the
administration of justice, and their failure to fully comply with the court orders
undermines the integrity of the criminal justice system and casts doubt on the legitimacy
of any convictions that may have been obtained as a result of this misconduct.
3. Mr. Ware asserts that the criminal professional prosecutorial misconduct of the DOJ
Prosecutors, the USAO, and EOUSA in this matter has violated not only the Brady court
orders but also federal criminal contempt statutes and the DOJ and ABA Model Rules of
Professional Conduct. He urges the OIG to conduct an immediate and thorough
investigation into these matters and hold Damian Williams, the DOJ Prosecutors, and
others accountable for their criminal prosecutorial misconduct. The integrity of the
criminal justice system and the rights of the accused depend on it.
Section B: Background.
1. Ulysses T. Ware was an attorney licensed to practice law in the State of Georgia. He has
been representing himself pro se in the Ware criminal proceedings, and also in the 2241
actual innocent habeas corpus proceedings, 22cv3409 (SDNY), which were filed under 28
U.S.C. § 2241. The Ware criminal proceedings involve credible allegations of violations of
the Racketeer Influenced and Corrupt Organizations Act (RICO), money laundering, loan
sharking, grand jury conspiracy, bribery, conspiracy, perjury, fabrication of evidence, wire
Page 8 of 44
fraud, and many other offenses committed by the DOJ Prosecutors and their unindicted
coconspirators.6
2. On March 20, 2023, the Executive Office of the U.S. Attorneys (EOUSA) implicitly and
expressly confessed and admitted that the USAO (SDNY) currently possessed "over 15
boxes" which apparently have never been properly inventoried. The EOUSA demanded
that Mr. Ware pay "$520.00" in advance to allegedly "conduct a search" for the Brady
materials, even though the United States, and by implication, the DOJ, is currently under
and subject to written Brady court orders, and Rule 5(f) to produce and disclose "all"
materials that "could be" Brady materials.
3. The failure of the DOJ Prosecutors, the USAO, and EOUSA to fully comply with the Brady
court orders and their attempt to charge Mr. Ware for access to materials covered by a
Brady court order constitute criminal prosecutorial misconduct. This misconduct is a
reckless, willful, and intentional violation of Rule 3.3, 3.4, and 8.4, and 18 USC 401(3)
criminal contempt statutes.
Section C: Statement of Facts.7
1. Mr. Ware contends that the ongoing attempts to obtain Brady court orders' enforcement
in the Ware criminal proceedings have revealed serious and alarming criminal
prosecutorial misconduct by the Office of the United States Attorney (SDNY) and Damian
Williams, et al.
2. The Executive Office of the U.S. Attorneys (EOUSA) implicitly and expressly confessed and
admitted that the USAO (SDNY) currently possessed "15 boxes" which apparently have
never been properly inventoried. The EOUSA demanded that Mr. Ware pay "$520.00" in
advance to allegedly "conduct a search” for the Brady evidence, which expressly violated
the Brady court orders entered in the sub judice criminal proceedings, (1) U.S. v. Ware,
04cr1224 (SDNY), Dkt. 32; and (2) U.S. v. Ware, 05cr1115 (SDNY), Dkt. 17, jointly, (the
“Brady Court Orders”).
3. The Attachment, infra, details the sworn factual predicates on which the claims of criminal
prosecutorial misconduct are based.
6
See the 2241 actual innocent Petition filed on March 21, 2022, claims, statement of facts, and supporting
clear and convincing evidence attached in support of the claims.
7
See the Attachment, infra, for a more complete statement of the relevant facts as the predicates for this
OIG complaint.
Page 9 of 44
Section C: Purpose of the Complaint.
The purpose of this whistleblower complaint is to bring to the attention of the Department
of Justice's Office of Inspector General (DOJ OIG) the potentially illegal conduct by Andre Damian
Williams, Jt., et al. in their role as Assistant United States Attorneys for the Southern District of
New York (USAO-SDNY). The actions described in this complaint constitute a violation of various
ethical and legal obligations imposed on attorneys, particularly those working in a government
capacity.
It is our belief that the conduct described in this complaint is not an isolated incident, but
rather a systemic problem within the USAO-SDNY.8 It is our hope that the DOJ OIG will conduct a
thorough investigation into the matters raised in this complaint and take appropriate action to
ensure that the USAO-SDNY and the DOJ Prosecutors are held accountable for their criminal
wrongdoing.
II. Allegations of Misconduct--Specific Allegations of Misconduct.9
1. Failure to disclose the existence of "15 boxes" of materials that have never been properly
inventoried The EOUSA's demand for payment to conduct a search for Brady materials
despite the existence of a written Brady court order is an egregious and unprecedented
act of criminal prosecutorial misconduct by the EOUSA and USAO. This demand is a
reckless, willful, and intentional violation of Rule 3.3, 3.4, and 8.4, and 18 USC 401(3)
criminal contempt statutes by attempting to charge (extort) Mr. Ware for the production
of materials that are covered by the Brady Court Orders.
2. The USAO and EOUSA are not only recklessly acting in bad faith but also obstructing justice
by preventing the disclosure of Brady materials that may be crucial to the 2241 actual
innocent habeas corpus proceedings, 22cv3409 (SDNY) adjudication. This conduct is
prejudicial to the administration of justice, which is a clear violation of Rule 8.4.
8
Cf., U.S. v. Nejad, 18cr00224 (AJN)(SDNY), Dkt. 375, and Dkt. 399 for Judge Nathan’s harsh assessment
of the USAO’s prosecutorial misconduct committed during the Nejad proceedings.
9
See Attachment #1, infra, for a full and complete rendition of the deliberate, intentional, bad faith, and
reckless acts and omissions of criminal prosecutorial misconduct committed by the DOJ Prosecutors and
their unindicted coconspirators.
Page 10 of 44
Submitted on this 28th day of March 2023, under oath, subject to the penalty of perjury, having
personal knowledge of the fact, pursuant to 28 USC 1746, to the DOJ’s Office of the Inspector
General.
/s/ Ulysses T. Ware
Ulysses T. Ware (the Complainant)
March 28, 2023
Brooklyn, NY
Page 11 of 44
Attachment #1
in Support of
Criminal
Prosecutorial
Misconduct and
other Crimes.
Page 12 of 44
Filed on 3/24/2023 8:52:22 AM

22cv3409 (SDNY) (147)
Ware v. United States, et al.
___________
Submitted by:
/s/ Ulysses T. Ware
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Friday, March 24, 2023
Petitioner Ulysses T. Ware’s Actual Innocent Supplemental Claim

(“AISC”) #20 re: (1) DOJ’s EOUSA’s and U.S. Attorney’s Office’s (SDNY)
willful, bad faith, and reckless concealment and suppression of “over 15
boxes” of materials that “could be” actual innocent Brady exculpatory
and/or impeachment evidence; and (2) Exhibit P: Ulysses T. Ware’s
03.23.23 Emergency request for the DOJ’s Office of Professional
Responsibility, (“OPR”), to open an emergency disciplinary investigation
of the DOJ Prosecutors.10
10
Exhibit P was submitted separately to the Office of the District Clerk (SDNY) in a filing on March 23, 2023, Dkt.
206.
Page 13 of 44

123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Via email to ChambersNYSDRamos@nysd.uscourts.gov

The Hon. Edgardo Ramos
U.S. District Court (SDNY)
500 Pearl St.
New York, NY 10007
Re: Ware v. United States, Merrick Garland,11 Edgardo Ramos,12 and Laura Taylor-
Swain, Case No. 22cv3409 (SDNY), 28 USC 2241(a) actual innocent habeas corpus
proceeding, (the “Petition”).
Government’s U.S. v. Ware, 05cr1115 (SDNY) (“1115”) “principal witness” Jeremy
Jones’ missing and concealed USSG 5k judicial public records subject to 18 USC 2,
241, 242, 371, 401(3), 1519, and 18 USC 2071.
11
See former circuit Judge Merrick B. Garland’s opinion in In re Sealed Case, 185 F.3d 887 (D.C. Cir. 1999)
(Held: Ordered the government to disclose cooperation agreement between trial witness); cf., the irony
and legal contradiction in that gov’t witness Jeremy Jones’ USSG 5k cooperation agreements are
presently being concealed and suppressed by Judge Garland’s former law clerk, U.S. Attorney (SDNY)
Andre Damian Williams, Jr., and by extension (now prosecutor) USAG Merrick B. Garland). Very ironic.
The classic case of incongruent duplicity: Jabberwocky/Orwellian Newspeak judicial and prosecutorial
reasoning and logic is being applied in 04cr1224 (SDNY), 05cr1115 (SDNY), 22cv3409 (SDNY), 02cv2219
(SDNY), 03-93031 (BC NDGA), and 03-0831 (D. NV).
12
Judges Edgardo Ramos and Laura Taylor-Swain have been named in the Petition as an adverse party, a
material witness, and unindicted coconspirator, and pursuant to 28 USC 455(a), 455(b)(1-4), and In re
Murchison, Edgardo Ramos and Laura Taylor-Swain are judicially disqualified from all judicial participation
in the 22cv3409 proceedings (however, see Dkt. 60, risible purported Order); yet Judge Ramos has
adamantly for unexplained and irrational reasons i.e., Orwellian “doublethink” and Newspeak
“blackwhite” revisionist doctrine) applied Jabberwocky logic and reasoning and recklessly refused to
recuse himself and continues to obstruct and impede the proceedings to conceal his crimes committed in
04cr1224 and 05cr1115.
Page 14 of 44

The Hon. Edgardo Ramos
500 Pearl St.
New York, NY 10007
Opening statement.
Judge Ramos, Petitioner Ulysses T. Ware hereby makes the below claims, arguments, and
request the Court to convene and hold an evidentiary hearing, where you, Andre Damian
Williams, Jr., Daniel Gitner, Margaret M. Garnet, Jun Xiang, Breon Peace, Nina Gupta, District
Judges Laura Taylor-Swain, and Colleen McMahon, Frank V. Sica, District Clerk Ruby Krajick,
Merrick B. Garland, Jeffrey R. Ragsdale, and others will be subpoenaed, compelled and called as
hostile, adverse, material fact witnesses, on Monday, March 27, 2023, or such time reasonably
necessary thereafter, to resolve all disputed issues of material fact and other matters.
Please be reminded and advised that the Code of Conduct for Federal Judges and federal
law, 28 USC 455(a), 455(b)(1-5), prohibits any judicial involvement or “participation” by yourself
in any aspect of the 04cr1224, 05cr1115, and 22cv3409 (SDNY) proceedings. 13
13
28 USC 455(a): Any justice, judge [Edgardo Ramos and Laura Taylor-Swain, but see Dkt. 60], or magistrate judge
of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be
questioned.
28 USC 455(b): He shall also disqualify himself in the following circumstances:

(1) Where he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary
facts concerning the proceeding;
(2) Where in private practice he served as lawyer in the matter in controversy, or a lawyer with whom he previously
practiced law served during such association as a lawyer concerning the matter, or the judge or such lawyer has
been a material witness concerning it;
Page 15 of 44
Currently before the Court are motions for Edgardo Ramos’ recusal which have not been
adjudicated and thus, Edgardo Ramos has violated the Code of Conduct for Federal Judges and
obstructed and impeded the timely adjudication of the merits of the actual innocent habeas
corpus claims—that is, the habeas corpus proceedings are deliberately, intentionally, in bad faith,
and criminally being impeded and obstructed by Edgardo Ramos on behalf of the RICO Loan
Sharking, Money Laundering, and Extortion illegal association-in-fact, the continuing criminal
enterprise, (the “CCE”), and the DOJ’s Office of Professional Responsibility (Jeffrey R. Ragsdale,
Esq.).
Respectfully submitted by:
Ulysses T. Ware
/s/ Ulysses T. Ware
(3) Where he has served in governmental employment and in such capacity participated as counsel, adviser or
material witness concerning the proceeding or expressed an opinion concerning the merits of the particular case in
controversy;
(4) He knows that he, individually or as a fiduciary, or his spouse or minor child residing in his household, has a
financial interest in the subject matter in controversy or in a party to the proceeding, or any other interest that
could be substantially affected by the outcome of the proceeding;
(5)He or his spouse, or a person within the third degree of relationship to either of them, or the spouse of such a
person:
(i) Is a party to the proceeding, or an officer, director, or trustee of a party;
(ii) Is acting as a lawyer in the proceeding;
(iii) Is known by the judge to have an interest that could be substantially affected by the outcome of
the proceeding;
(iv) Is to the judge’s knowledge likely to be a material witness in the proceeding.
Page 16 of 44
Actual Innocent Supplemental Claim #20.
I.
A. Introduction.
Petitioner, Ulysses T. Ware, hereby this 24th day of March 2023, files this Actual Innocent
Supplemental Claim (AISC) #20 predicated on Exhibit P, attached hereto, incorporated by
reference herein, and made a part hereof, in heac verba, as the factual and legal basis for AISC
#20.
B. Claims and Contentions.
Petitioners hereby incorporate by reference, and make a part hereof as if set forth herein,
in heac verba, Exhibit P, infra, Petitioner’s March 23, 2023, Declaration, as the factual and legal
basis for the claims, clear and convincing evidence, and contends:
that the respondents, the DOJ Prosecutors named in Exhibit P, have from beginning from, (i)
May 19, 2006, the entry of the U.S. v. Ware, 05cr1115 (SDNY) Brady court order, Dkt. 17; and (ii)
entry of the August 10, 2007, U.S. v. Ware, 04cr1224 (SDNY), jointly, (the “Brady Court Orders”),
1. knowingly, willfully, deliberately, and in bad faith took affirmative steps and omissions
and have resisted the written commands of the Brady Court Orders—that is, the DOJ
Prosecutors individually, and jointly as willing participants in a criminal illegal
association-in-fact as defined in 18 USC 1961(4), a continuing criminal enterprise, (the
Page 17 of 44
“DOJ CCE”), which are willful, bad faith, intentional, and reckless violations of 18 USC 2,
241, 242, 371, 401(3), 1519, 1956-57, 1961(6)(B), 1962(a-d), and 2071, and the DOJ’s and
District Court (SDNY) Rules of Ethics and Professional Conduct by not disclosing and
producing to Petitioner, “prior to trial” the contents of the “over 15 boxes” referenced in
the EOUSA’s March 20, 2023 FOIA response;
2. the DOJ Prosecutors have aided, abetted, assisted, and acted in concert with others14
required to comply with the Brady Court Orders;
3. the DOJ Prosecutors have committed numerous affirmative acts and/or omissions of civil
contempt of the Brady Court Orders by not disclosing and producing the contents of the
“over 15 boxes” “prior to trial;”
4. the DOJ Prosecutors have individually and as a willing participant in the DOJ CCE aided,
abetted, assisted, and facilitated the willful resistance and violation of the commands of
the Brady Court Orders by concealing and suppressing the contents of “over 15 boxes” of
not inventoried materials in the current possession of the USAO (SDNY), the DOJ
Prosecutors, and the DOJ; and
14
Edgardo Ramos, Debra Ann Livingston, Robert D. Sack, Amalya L. Kearse, Laura Taylor-Swain, William H.
Pauley, III (deceased), Robert W. Sweet (deceased), Peter W. Hall (deceased), Leonard B. Sand (deceased),
Robert A. Katzmann (deceased), Ari Rabinowitz, the SEC, Wendy L. Hagenau, John A. Horn, Margaret H.
Murphy, Coleman Ray Mullins, the State Bar of Georgia, LH Financial Services, Kenneth A. Zitter, convicted
felon Edward M. Grushko, Barbara R. Mittman, Jeffrey B. Norris, Steve R. Peikin, Joan E. McKown, Thomas
W. Thrash, Jr., Edward T.M. Garland, Manibur S. Arora, Donald F. Samuel, David B. Levitt, M. Regina Thomas,
Patricia Sinback, J. Henry Walker, IV, Dennis S. Meir, John W. Mills, III, Kilpatrick, Townsend, & Stockton,
LLP, Michael F. Bachner, Marlon G. Kirton, Jeremy Jones, Michael H. Dolinger, David Makol, Maria A. Font,
Andrew J. Peck, the FBI, the OSG, the EOUSA, OPR, Lawrence B. Mandala, Thomas A. Leghorn, Baker &
McKenzie, LLP, Bernard London, London Fisher, LLP,
Page 18 of 44
5. the DOJ Prosecutors have knowingly, willfully, in bad faith, recklessly, with malice, and
intentionally resisted and violated 18 USC 401(2), and 18 USC 401(3), criminal contempt
of the Brady Court Orders and Final Judgments’ the collateral estoppel preclusive effects
by continuing to disregard and disrespect the Brady Court Orders, and continued to
knowingly and intentionally enforce orders, judgments, and proceedings annulled,
vitiated, voided, set aside, and vacated by the Final Judgments’ res judicata preclusive
effects.
Respectfully submitted by:
Ulysses T. Ware
/s/ Ulysses T. Ware
Page 19 of 44
Exhibit P
Page 20 of 44
22cv3409 (SDNY) (146)

Filed on 3/23/2023 10:22:25 AM
Ware v. USA, Merrick B. Garland, Edgardo Ramos, and Laura Taylor-
Swain.
________
Supplement #4.0 to Rule 1.5(b)(5) EMERGENCY APPLICATION,
Dkt. 202—Emergency Petition to U.S. DOJ Office of Professional
Responsibility re Andre Damian Williams, Jr., et al., and the District
Court (SDNY) Committee on Lawyer Discipline.
____________________
Ulysses T. Ware’s Supplement #4.0 to Dkt 202, Emergency Application: (1) March 17, 2023,
Third Request for urgent15 clarification of 06.16.2022, Order, Dkt. 60, Chief District Judge Laura
Taylor-Swain, and (2) the Third Request for Emergency Local Rule District Court (SDNY) Rule
1.5(b)(5) Disciplinary Relief: In re Damian Williams and Merrick B. Garland, et al., 23 misc. ____
(SDNY) for (a) Conspiracy to Obstruct Justice and (b) the Jim Crow Racially-Motivated Hate
Crimes perpetrated against Ulysses T. Ware, Esq., violations of the Rules of Conduct for Lawyers
of the District Court (SDNY).
_________
Submitted by:
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
/s/ Ulysses T. Ware
Thursday, March 23, 2023
15
Petitioner had requested that the Chief Judge respond by 11:00 AM on Monday, March 20, 2023, time
of the essence, and serve the parties with a copy of her clarification and setting of a briefing schedule to
address the issues raised herein regarding the June 16, 2022, Dkt. 60, ultra vires, null and void ab initio
purported “Order.” See Exhibit A, infra. However, the Chief District Judge (Laura Taylor-Swain is judicially
disqualified from any “participation” in any aspect of the 22cv3409 proceedings), and accordingly, Mr.
Ware requests that the Office of the Chief District Judge (SDNY) assign this matter to the most senior
district judge without a conflict of interest present be presented with this request for emergency
disciplinary relief and respond not later than Wednesday, March 23, 2023, by 12:00 noon, time of the
essence.
Page 21 of 44
Exhibit A: EOUSA’s March 20, 2023, FOIA response letter.
Page 22 of 44
EMERGENCY APPLICATION to US DOJ Office of

Professional Responsibility (Jeffrey R. Ragsdale).
123 Linden Blvd., Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
Thursday, March 23, 2023
Emergency Application
Via email to Chambers on March 23, 2023
Office of the Chief District Judge
500 Pearl St.
New York, NY 10007
c/o Jeffrey R. Ragsdale, DOJ Office of Professional Responsibility, Andre Damian Williams, Jr, the
Hon. Laura Taylor-Swain, and District Judge Edgardo Ramos16
Re: In re Damian Williams and Merrick B. Garland, et al., 23 misc. ____ (SDNY).
L.R. 1.5(b)(5) District Court (SDNY) disciplinary supervisory authority.
Supplement #4.0 to Dkt. 202, the Third Request for emergency disciplinary action for 18
USC 401(2), 401(3), criminal contempt of the Brady Court Orders, and Final Judgments
by the Officers of the Court.
16
Both District Judges (Ramos and Taylor-Swain) are named in their personal and official capacities on
the face of the 22cv3409 (SDNY) petition as an adverse party-respondent, named as a hostile, adverse,
material fact witness, and also named as an unindicted coconspirator regarding the Proceedings—both
will be subpoenaed and compelled by the Compulsory Process Clause of the Sixth Amendment to appear,
produce records, and give testimony regarding the Proceedings, and therefore, ipso facto, as a matter of
law both District Judge pursuant to the Code of Conduct for Federal Judges, and 28 USC 455(a), 455(b)(1-
5), a judicially disqualified from all “participation” in the Proceedings.
Page 23 of 44
Memorandum of Fact and Emergency Petition for Criminal Violation of

DOJ Rules of Ethics and Professional Conduct.
From: Ulysses T. Ware
To: U.S. DOJ Office of Professional Responsibility: Jeffrey R. Ragsdale—via email to

Ragsdale.jeffrey@usdoj.gov.
Date: March 23, 2023
Re: Petition to open a DOJ ethics violation investigation regarding Andre Damian Williams, Jr.,
Daniel Gitner, Margaret M. Garnett, Audrey Strauss, John M. McEnany, Melissa Childs, Jun
Xiang, Breon Peach, Nina Gupta, Steven D. Feldman, Maria E. Douvas, Sarah E. Paul,
Katherine Polk-Failla, Andrew L. Fish, David N. Kelley, Michael J. Garcia, Preet Bharara,
Joon Kim, Alexander H. Southwell, John A. Horn, Nicholas S. Goldin, Neal Katyal, Merrick
B. Garland, Lisa Monaco, and Vanita Gupta, (the “DOJ Prosecutors”).
Mr. Jeffrey R. Ragsdale, U.S. DOJ Office of Professional Responsibility (“OPR”).
Requested reliefs from OPR.
I am petitioning to request that the U.S. Department of Justice Office of Professional

Responsibility (“OPR”) immediately on an emergency basis undertake the following action:
1. open an ethics investigation into the criminal prosecutorial misconduct of the DOJ
Prosecutors.17 The basis of this request is the following undisputed factual
predicates.
17
Mr. Ware request that the OPR--given the criminal nature of the egregious and willful ongoing USAO
and DOJ Prosecutors’ continuous criminal violations of the DOJ and District Court (SDNY) Local Rules of
Ethics and Professional Conduct, that the OPR not later than Monday, March 27, 2023, at 10:00 AM, time
of the essence, officially contact the Lawyer Disciplinary Committee of the District Court (SDNY) and
pursuant to L.R. 1.5(b)(5) and 1.5(d)(3) request that the Committee enter an interim emergency
disciplinary order, (“EDO”), and suspend, enjoin, and prohibit the DOJ Prosecutors from appearing in or
Page 24 of 44
2. Refer this matter to the Director of the FBI to open a parallel criminal investigation
regarding the criminal prosecutorial misconduct allegations made herein;
3. Refer this matter to the DOJ’s Division on Public Integrity and request that a
criminal investigation be open regarding the allegations herein; and
4. Refer this matter to the Office of the Chief Justice, Supreme Court of the United
States and request that the Court exercise its Article III supervisory authority and
open an emergency ethics investigation regarding the Office of the Solicitor
General (“OSG”) and the DOJ Prosecutors regarding the Proceedings’ litigation
before the United States courts.
Declaration of Ulysses T. Ware
I Ulysses T. Ware, under oath and pursuant to the penalty of perjury, having
personal knowledge of the facts, hereby this 23rd day of March 2023, in the city of Brooklyn, NY,
Kings County, set my hand and seal, and pursuant to 28 USC 1746, make this Declaration of
Material Facts, (the “Facts”), and state the following.
I.
A. Undisputed factual predicates.
Fact 1.
On June 13, 2022, Dkt. 56, Ulysses T. Ware, (the “Petitioner” or “Complainant”)
filed his first request for L.R. District Court (SDNY), 1.5(b)(5), application for Emergency
Supervisory Disciplinary Relief, (the “First Application”) addressed to the Office of the Chief
District Judge, the Hon. Laura Taylor-Swain, as required by L.R. 1.5(b)(5)18 and L.R. 1.5(d)(3).
before the District Court (SDNY), the Court of Appeals for the Second Circuit, or any other tribunal until
such time as; (1) the DOJ Prosecutors file a sworn declaration into the 22cv3409 (SDNY) district court and
admit or deny the allegations herein, (2) certify that all disclosure and production has been completed as
required by Rule 5(f) and the Brady Court Orders’ commands, and (3) file a certified inventory in 22cv3409
(SDNY) regarding the contents of the “15 boxes” referenced in the March 20, 2023, FOIA response, Ex. A,
infra.
18
“In connection with activities in this Court, any attorney is found to have engaged in conduct violative
of the New York State Rules of Professional Conduct as adopted from time to time by the Appellate
Page 25 of 44
Fact 2.
Having received no response from the Chief Judge to the June 13, 2022, First
Application, Dkt. 56, Mr. Ware on June 16, 2022, at 12.11.38 pm, filed his second application for
Emergency Supervisory Disciplinary Relief pursuant to L.R. 1.5(b)(5), (the “Second Application”),
Dkt. 59.19
Fact 3.
In the Applications, Mr. Ware specifically requested emergency supervisory
disciplinary relief pursuant to Local Rule, (“L.R.”), 1.5(b)(5), District Court (SDNY), (the “Local
Rules”), and addressed the written Application to the Office of the Chief Judge (Laura Taylor-
Swain) as required by the L. R. 1.5(d)(3).20
Fact 4
L.R. 1.5(d)(3) required the Chief Judge to immediately “refer” the Applications to
the Committee on Grievances, (i.e., “Complaints in writing alleging any ground for discipline or
other relief set forth in paragraph (b) above shall be directed to the Chief Judge, who shall refer
such complaints to the Committee on Grievances”). (emphasis added).
Fact 5
The Chief Judge, Laura Taylor-Swain, is not lawfully authorized by the Local Rules
to sua sponte deny the relief requested in the Applications. Only the Committee on Grievance,
(the “Committee”) is authorized to “investigate” the violations of the Code of Conduct for
Lawyers of the District Court (SDNY) allegations made in the Applications against Andre Damian
Divisions of the State of New York. In interpreting the Code, in the absence of binding authority from the
United States Supreme Court or the United States Court of Appeals for the Second Circuit, this Court, in
the interests of comity and predictability, will give due regard to decisions of the New York Court of Appeals
and other New York State courts, absent significant federal interests.” (emphasis added).
19
The First Application and the Second Application, jointly, (the “Applications”).
20
L.R. 1.5(d)(3). “[Disciplinary] [c]omplaints in writing alleging any ground for discipline or other relief set
forth in paragraph (b) above shall be directed to the Chief Judge [see Dkt.56 and 59, 22cv3409 (SDNY)],
who shall refer such complaints to the Committee on Grievances. The Committee on Grievances, by its
chair, may designate an attorney, who may be selected from the panel of attorneys established pursuant
to paragraph (a) above, to investigate the complaint, if it deems investigation necessary or warranted,
and to prepare a statement of charges, if the Committee deems that necessary or warranted. Complaints,
and any files based on them, shall be treated as confidential unless otherwise ordered by the Chief Judge
for good cause shown or in accordance with paragraph (d)(5) below.”
Page 26 of 44
Williams, Jr., Merrick B. Garland, and other lawyers, (i.e., “The Committee on Grievances, by its
chair, may designate an attorney, who may be selected from the panel of attorneys established
pursuant to paragraph (a) above, to investigate the complaint, if it deems investigation necessary
or warranted, and to prepare a statement of charges, if the Committee deems that necessary or
warranted.”). (emphasis added).21
Fact 6
Pursuant to the Local Rules, L.R. 1.5(d)(3), the Chief Judge has no authorized role
in the “investigation” of the written prosecutorial misconduct allegations in the Applications,
other than to “refer” the matter to the Committee, and the Chief Judge is not lawfully authorized
to sua sponte deny Mr. Ware’s requested supervisory disciplinary relief as was purportedly done
in the illegal and obstruction of justice, null and void ab initio, ultra vires Order, Dkt. 60, (06.16.22)
(Taylor-Swain, C.J.), (the “Ultra Vires Order”).22
Fact 7
The Chief Judge (Laura Taylor-Swain) was named on the face of the 22cv3409
(SDNY) habeas corpus petition, see Dkt. 1-2 (22cv3409); furthermore, the Chief Judge has been
designated as (i) an adverse party-opponent, (ii) a material fact witness, and (iii) an unindicted
co-conspirator with respect to the Petitioner’s actual innocent claims pending adjudication on
the merits in the District Court.
Fact 8
The Chief Judge pursuant to 28 USC 455(a), and 455(b)(5) is per se, objectively,
statutorily disqualified—that is, per se actual biased, has an actual overt conflict of interest; and
also pursuant to binding Supreme Court’s authority In re Murchison, 349 U.S. 133, 136 (1955),
the Chief Judge is constitutionally disqualified23 from any and all judicial involvement in the
21
See L.R. 1.5(d)(3).
22
Dkt. 60, Order, “To the extent the Petitioner is requesting that the undersigned [C.J. Laura Taylor-Swain],
make or alter any rulings in the above case [which the Petitioner did not request, cf., Dkt. 56 at 6, for the
requested disciplinary reliefs], the request is [sua sponte without any required investigation by the
Committee] denied. The Chief Judge does not have the authority to take such actions in the cases assigned
to other members of the Court.” (quoting, Taylor-Swain, C.J., 06.16.2022), (emphasis and alterations
added).
23
“A fair trial in a fair tribunal is a basic requirement of due process. Fairness of course requires an absence
of actual bias in the trial of cases. But our system of law has always endeavored to prevent even the
probability of unfairness. To this end no man[or woman] can be a judge in his [or her] own case and no
man [or woman] is permitted to try cases where he [or she] has an interest in the outcome. That interest
cannot be defined with precision. Circumstances and relationships must be considered. This Court has
Page 27 of 44
adjudication or investigation of the allegations in the Applications.24 The Chief Judge was fully
aware of her actual per se bias, prejudice, and conflict of interest regarding the Applications “to
the extent” the Applications involved any facts or issues with respect to the 22cv3409 actual
innocent claims currently before the District Court.
Fact 9
The Chief Judge omitted, deliberately and intentionally, to state in the Ultra Vires
Order whether or not she had followed and complied with the requirements of L.R. 1.5(d)(3) and
referred the Applications to the Committee for investigation of the Petitioner’s allegation of
prosecutorial misconduct involved in the 04cr1224 (SDNY) and 05cr1115 (SDNY) criminal
proceedings.
Fact 10
Currently, there is no written record produced by the Chief Judge that confirms
whether or not the requirements of L.R. 1.5(d)(3) have been complied with in regard to the
emergency processing of the Applications. Rather than comply with the Local Rules, the Chief
Judge, to distract from the substance of the Applications, the prosecutorial misconduct
committed by the DOJ’s prosecutors in 04cr1224 and 05cr1115,25 the Chief Judge deliberately,
intentionally, and as an overt act in furtherance of her criminal obstruction of justice to aid and
abet the continue resistance to and overt disobedience of the written commands of the Brady
Court Orders—that is, 18 USC 401(2) and 401(3) criminal contempt, the Chief Judge created a
trivially frivolous false narrative designed to cover up and conceal the criminal acts and
omissions, criminal prosecutorial misconduct, covered by L.R. 1.5(b)(5), committed by the DOJ’s
prosecutors.
Fact 11
said, however, that "every procedure which would offer a possible temptation to the average man [or
woman] as a judge . . . not to hold the balance nice, clear and true between the State and the accused,
denies the latter due process of law." Tumey v. Ohio, 273 U.S. 510, 532.” (emphasis added).
24
See Dkt. 56 at 4, para. 2: “Judge Taylor-Swain, Mr. Ware reminds you that you have been named in
22cv3409(SDNY) in your personal and individual capacity as an adverse party, a material fact witness,
and as an unindicted co-conspirator regarding your own personal and official criminal judicial misconduct
concerning your adamant illegal refusal in 2021 to exercise the District Court’s supervisory authority and
ensure the full and complete compliance with the Final Judgments by the USAO’s prosecutors and others
that have appeared before the District Court (SDNY) in the DOJ’s Jim Crow Hate Crime Conspiracy Cases.”
25
Mr. Ware, the Petitioner, was explicit regarding the requested relief he sought from the Committee,
see Dkt. 56 at 3-4, on his claims of “prosecutorial misconduct committed by the DOJ’s prosecutors.“
Page 28 of 44
The Chief Judge was fully aware, see Dkt. 56 at 6, that the Petitioner had not
requested any relief in the Applications based on her “judicial misconduct” which she referenced
in the Ultra Vires Order as a ruse to ostensibly justify her egregious violation of L.R. 1.5(d)(3)
requirements, the canonical case of abstract judicial incongruent duplicity.26 Cf., Dkt. 56 at 3-4:
“Mr. Ware, the petitioner in Ware v. USA, et al., 22cv3409 (SDNY), and the defendant in
United States v. Ware, 04cr1224 (SDNY), and United States v. Ware, 05cr1115 (SDNY), jointly,
(the “DOJ’s Jim Crow Hate Crime Conspiracy”), is filing this emergency application for the District
Court (SDNY) pursuant to its inherent supervisory authority to insure the fidelity and full and
complete compliance with all lawful court orders, to wit, (1) the Brady Court Orders, (2) the Rule
41(a)(2) final judgment, and (3) the August 18, 2009, final judgment entered in United States v.
Ware, 07-5670cr (XAP) (2d Cir.), Gov.-I, jointly, (the “Final Judgments”), to enter an emergency
order directed to the Officers of the Court named in the caption to immediately within the next
two (2) days, not later than Wednesday, June 15, 2022, to show cause in writing why each shall
not be disciplined by the District Court’s inherent supervisory authority ordered to show cause
why each shall not be held in civil and willful criminal contempt of the Final Judgments.27
In support of this emergency application, Mr. Ware incorporates by reference, in heac
verba, Dkts. 1-55 in Ware v. USA, et al., 22cv3409 (SDNY), and makes the same a part hereof, in
addition to (1) the deliberate and intentionally unfiled and undocketed pleading 53A-9,
01.17.2022, submitted in 04cr1224 and 05cr1115, Ex. 1, infra; however, Ex. 1 was refused to be
docketed by District Judge Edgardo Ramos as a fraud on the court and an overt act in furtherance
of the conspiracy to aid and abet the civil and criminal contempt of the Final Judgments.”
26
“To the extent Petitioner seeks action based on his allegations of judicial misconduct, Petitioner’s
request is improperly directed to the undersigned in her capacity as Chief Judge because such complaints
are properly directed to the ‘”clerk of the court of appeals for the circuit.’” (citations omitted) (emphasis
added) (quoting the Chief Judge, Dkt. 60, 22cv3409 (SDNY), Order, June 16, 2022).
27
Mr. Ware is the petitioner in the Ware v. USA, et al., 28 USC 2241(a) actual innocent habeas corpus
petition. Mr. Ware filed the petition on March 21, 2022, and no actions whatsoever have been taken by
the District Court, see 28 USC 2243 entry of the required show cause order. Mr. Ware has, is, and will
continue to suffer irreparable harm to his personal and business each day until the 22cv3409 (SDNY)
actual innocence claims are adjudicated on the merits and proceedings are held to address the civil and
criminal contempt of the Officers of the Court and other matters concerning government trial exhibits GX
1-4 and GX-5 (04cr1224), the Illegal Contracts.
United States Attorney (SDNY) Andre Damian Williams, Jr., is the current legal representative for the
government in the DOJ’s Jim Crow Hate Crime Conspiracy cases and is in current malicious civil and
willful criminal contempt, 18 USC 401(2) and 401(3) of the Final Judgments.
Page 29 of 44
Fact 12
To clarify and make absolutely clear and specific, Petitioner did not and is not
requesting any relief from the Chief Judge in the Applications with respect to her criminal judicial
misconduct. That request will be made in an imminent complaint for judicial misconduct filed
with the “clerk of the court of appeals for the circuit.”
Fact 13
To clarify, Petitioner in the Applications sought emergency supervisory disciplinary
relief pursuant to L.R. 1.5(b)(5) and L.R. 1.5(d)(3) in regard to the criminal prosecutorial
misconduct perpetrated as officers of the court, by the DOJ’s prosecutors that participated in the
04cr1224 and 05cr1115 criminal proceedings in the District Court (SDNY); which is exclusively,
within the scope of the jurisdiction and investigative purview of the Committee on Grievances
of the District Court (SDNY).28
Fact 14
Given the Chief Judge was named as an adverse party-respondent in the 22cv3409
actual innocent habeas corpus petition; and according to the docket the petition was allegedly
randomly assigned to District Judge Edgardo Ramos, see 22cv3409 docket; and given Petitioner
presented supervisory relief claims and requested supervisory relief in the petition against both
the Chief Judge and Judge Ramos, the Chief Judge, to obstruct justice, illegally and without any
lawful Article III judicial authority, adjudicated the merits of the supervisory relief claims in her
personal and individual capacity and in her favor in the Ultra Vires Order, Dkt. 60, in the clear
absence of the required 28 USC 2243 show cause order and all Article III subject matter
jurisdiction over issues and facts that are moot, ipso facto, as a matter of law.
I Ulysses T. Ware, have this 23rd day of March 2023, while under oath and pursuant
to the penalty of perjury, having personal knowledge of the facts, pursuant to 28 USC 1746, have
made this Declaration of Undisputed Material Facts in Brooklyn, NY.
/s/ Ulysses T. Ware

________________________
Ulysses T. Ware
March 23, 2023
Brooklyn, NY
28
Local Civil Rule 1.5. Discipline of Attorneys (a) Committee on Grievances. “The Chief Judge shall appoint
a committee of the Board of Judges known as the Committee on Grievances, which under the direction of
the Chief Judge shall have charge of all matters relating to the discipline of attorneys.” (emphasis added).
Page 30 of 44
Introduction:
Ulysses T. Ware, Petitioner, petitions the OPR today March 23, 2023, to bring to your
attention a matter of utmost urgency regarding the United States Attorney's Office (SDNY),
Damian Williams', and the DOJ’s Prosecutors’ criminal prosecutorial misconduct in the criminal
proceedings against Mr. Ware, and during the adjudication of the Ware v. USA, et al., 22cv3409
(SDNY), actual innocent 2241 habeas corpus petition, (the “Proceedings”). The events of March
20, 2023, see Ex. A, infra, have brought to light disturbing revelations that the USAO has concealed
and suppressed Brady material, thereby violating two Brady court orders (04cr1224 (Dkt. 32) and
05cr1115 (Dkt. 17)).
Today, Mr. Ware presents to the OPR clear and convincing evidence of years of DOJ lies,
perjury, obstruction of justice, and criminal contempt of the Brady court orders.29 The Executive
Office of the U.S. Attorneys (EOUSA) implicitly and expressly on March 20, 2023, see Ex. A, infra,
confessed to the current existence of “15 boxes” of concealed and suppressed materials—in the
actual possession of the USAO, that "could be" Brady actual innocent exculpatory or
impeachment materials covered by the Brady court orders entered in the Ware criminal
proceedings. However, in an unprecedented move that violates 18 USC 401(3) criminal contempt
statutes, the EOUSA demanded that Mr. Ware pay “$520.00 “in advance for the USAO to allegedly
"conduct a search" of the “15 boxes” for the Brady materials. The EOUSA further stated that no
search for the Brady materials would be conducted until Mr. Ware paid the $520.00 in extortion
and ramson to gain access to judicial public records, and records covered by court order, and also
covered by Fed. R. Crim. P., Rule 5(f).
DOJ ethics and professional standard violations claims and contentions.
29
See 04cr1224 (SDNY), Dkt. 32, and 05cr1115 (SDNY), Dkt. 17, Tr. 5-10, (the “Brady Court Orders”).
Page 31 of 44
Mr. Ware contends and asserts that the DOJ Prosecutors, the USAO, and the EOUSA
deliberately, intentionally, and in a reckless and irresponsible disregard for the DOJ’s Rules of
Ethics and Professional Conduct recklessly violated Rule 3.3, 3.4, and 8.4 of the DOJ and ABA
Model Rules of Professional Conduct by not previously disclosing that the “15 boxes” of materials
had not been properly inventoried and not having produced to the Court and the defense the
existence of the 15 boxes of materials. The reckless and irresponsible conduct of the USAO and
EOUSA is deeply troubling, violated multiple court orders, and demands immediate attention and
action by OPR.
Mr. Ware further contends the DOJ Prosecutors also recklessly, egregiously, and
deliberately violated the DOJ ethical requirement of “duty of complete candor30 to the [02cv2219
(SDNY), 03-93031 (BC NDGA), 03-0831 (D. NV), 04cr1224 (SDNY), 05cr1115 (SDNY), 22cv3409
(SDNY), and the related appellate proceedings, including perpetration of a fraud on the Supreme
Court of the United States regarding the Ware v. USA, 10-6449 (2010) and other proceedings]
tribunals.”
In this Petition, Mr. Ware will provide a detailed and specific explanation of the events
leading up to March 20, 2023, Ex. A, and why the DOJ Prosecutors’, the USAO, and EOUSA's
reckless and irresponsible prosecutorial misconduct amounts to criminal prosecutorial
misconduct. We will also discuss the legal and ethical violations committed by the DOJ
Prosecutors, the USAO, and EOUSA and their implications for Mr. Ware's case. Finally, we will
request that the OPR take immediate emergency action to hold the DOJ Prosecutors, the USAO,
and EOUSA accountable for their reckless and irresponsible actions and to ensure that Mr. Ware
receives the due process that he is entitled to under the law.
30
The DOJ Prosecutors were required by ethics obligations to notify all “tribunals” regarding the existence
of “15 boxes” of uncatalogued, and un-inventoried materials that “could be” actual innocent Brady
exculpatory and/or impeachment evidence relevant to the Proceedings. The DOJ Prosecutors have not and
did not notify any tribunal or Mr. Ware as required by the duty of candor.
Page 32 of 44
A. March 20, 2023, Executive Office of the United States Attorneys

FOIA response. Exhibit A, infra.
Mr. Ware is writing to bring to your attention a serious matter concerning the Office of
the United States Attorney (SDNY) and Damian Williams' violation of Brady court orders in the
Ware criminal proceedings. I believe it is important to explain to you in detail and with specificity
why the actions of the DOJ Prosecutors, the USAO (SDNY), and Damian Williams have definitively
recklessly and wantonly violated the Brady court orders.
On March 20, 2023, the DOJ's EOUSA in a FOIA response letter, see Ex. A, infra, implicitly
and expressly confessed and admitted that the USAO (SDNY) currently has in its possession
materials that "could be" Brady actual innocent exculpatory or impeachment materials, covered
by the Brady court orders entered in the Ware criminal proceedings. This confession came after
continued pressure was placed on the USAO (SDNY) and Damian Williams to come clean and
admit that they had concealed and suppressed Brady material. However, the DOJ demanded that
Mr. Ware pay “$520.00” in advance for it to allegedly "conduct a search" for the Brady materials
is alarming, especially since the United States is currently under a written Brady court order to
produce and disclose "all" materials that "could be" Brady materials. See Ex. B, infra.
The EOUSA’s letter, Ex. A, infra, to Mr. Ware is clear and convincing evidence of years of
DOJ lies, perjury, obstruction of justice, and civil and 18 USC 401(3) criminal contempt of the
Brady court orders. Mr. Ware respectfully requests that the OPR and the District Court (SDNY) set
this matter (22cv3409, 04cr1224, and 05cr1115) down for an emergency status conference where
the topic of discussion will be sanctioning the EOUSA and the USAO’s prosecutors’ conduct via
civil and criminal contempt sanctioning proceedings on an emergency basis and hold Damian
Williams and others accountable for their criminal prosecutorial misconduct, as alleged in the
March 20, 2023, Dkt. 202, filing by Mr. Ware.
To assist the courts and the OPR in understanding the gravity of the situation, we have
divided this letter into three numbered sections:
Page 33 of 44
Section I: The USAO’s Failure to Prepare an Inventory of the Contents of the "15 Boxes."
In the Ware criminal proceedings, the DOJ Prosecutors, the USAO (SDNY), Damian
Williams, et al. failed to properly prepare an inventory of the contents of the "15 boxes" of
materials that "could be" Brady actual innocent exculpatory or impeachment materials covered
by the Brady court orders. This failure to comply with the court orders is a serious violation of the
defendant's due process rights, and Brady court orders.
Section II: DOJ's Implicit Confession of Concealing and Suppressing Brady Material.
The DOJ's EOUSA implicitly and expressly confessed and admitted that the USAO (SDNY)
does currently have in its possession “15 boxes” of un-inventoried, allegedly, materials that "could
be" Brady actual innocent exculpatory or impeachment materials, covered by the Brady court
orders entered in the Ware criminal proceedings. This implicit and express confession is clear
and convincing admission and confession and evidence of the DOJ's years of lies, perjury,
obstruction of justice, and civil and 18 USC 401(3) criminal contempt of the Brady court orders.
Section III: Request for Emergency Civil and Criminal Contempt Proceedings.
Given the severity, callousness, and bad faith of the violation of the defendant's due
process rights, two Brady court orders, to wit: (1) 04cr1224 (Dkt. 32), and (2) 05cr1115 (Dkt. 17),
Mr. Ware respectfully asserts and contends that the District Court (SDNY) is required, and we
request that the Court on an emergency basis immediately conduct civil and criminal contempt
proceedings and hold Damian Williams, Merrick B. Garland, the USAO, the EOUSA, and others
accountable for their criminal prosecutorial misconduct, as alleged in the March 17, 2023, filing
by Mr. Ware, Dkt. 202.
Moreover, the OPR is a unit of the U.S. DOJ which therefore the OPR and EOUSA are also
covered by a “duty of complete candor to the tribunals” and also covered by the Brady Court
Orders to immediately disclose and produce “all” Brady exculpatory and/or impeachment
Page 34 of 44
evidence in the actual and/or constructive possession of the United States and its privies; and
thus, are subject to the civil and criminal contempt, 18 USC 401(3), sanctioning authority of the
District Court (SDNY) regarding the Brady Court Orders’ enforcement.
B. Violation of the District Court (SDNY), the DOJ, and ABA Code of
Ethics and Professional Obligations.
Mr. Ware contends, asserts, and brings to the attention of the District Court (SDNY)
Lawyer Disciplinary Committee, (the “Committee”), and the OPR the recent developments
regarding the ongoing attempts to obtain Brady court orders’ enforcement in the Ware criminal
proceedings, which have revealed serious and alarming criminal prosecutorial misconduct by the
Office of the United States Attorney (SDNY) and Damian Williams, et al. I have reviewed the facts
and the law in this matter and found them to be deeply troubling.
As you already know, on March 20, 2023, see Ex. A, infra, the Executive Office of the U.S.
Attorneys (EOUSA) implicitly and expressly confessed and admitted that the USAO (SDNY)
currently possessed “15 boxes” which apparently have never been properly inventoried—else
why would the EOUSA have stated, “We estimate that an additional 13 hours will be required to
complete the search for the records you requested” (emphasis added) regarding materials that
"could be" Brady actual innocent exculpatory or impeachment materials covered by the Brady
court orders entered in the Ware criminal proceedings. The EOUSA demanded that Mr. Ware pay
“$520.00” in advance to allegedly "conduct a search" for the Brady materials, even though the
United States, and by implication, the DOJ, is currently under and subject to written Brady court
orders, and Rule 5(f) to produce and disclose "all" materials that "could be" Brady materials.31
31
Ex. A, infra, is indisputable, clear, and convincing evidence the USAO, Damian Williams, et al., have and
currently are in violation of the DOJ’s and District Court’s (SDNY) Code of Conduct for Lawyers—that is,
the willful resistance to the Brady court orders’ written commands, which constitutes a violation of 18
USC 2, 241, 242, 371, 401(3), 1519, 2071, criminal offenses’ which required the 22cv3409, 04cr1224, and
05cr1115 District Courts (SDNY) to sua sponte refer Damian Williams, et al. to the District Court (SDNY)
Page 35 of 44
This egregious and unprecedented act of criminal prosecutorial misconduct by the EOUSA
and USAO—note that Ex. A, infra, specifically noted “In addition, the Southern District of New
York [the USAO, Andre Damian Williams, Jr., et al.] has informed us …” is an express admission
and confession the USAO and the DOJ Prosecutors have known of the existence of the “15 boxes”
of materials, and recklessly refused to comply with its “duty of complete candor to the [04cr1224,
05cr1115, and 22cv3409] tribunals” and make full and complete disclosure regarding the required
Brady production.
Damian Williams’, et al. criminal prosecutorial misconduct regarding Ex. A, Ex. B, and Ex.
C, infra, is a reckless, willful, and intentional violation of Rule 3.3, 3.4, and 8.4, and 18 USC 401(3)
criminal contempt statutes by attempting to charge (extort) Mr. Ware for the production of
materials that are covered by a Brady court order. By attempting to charge Mr. Ware for access to
these materials, the USAO and EOUSA are not only acting in bad faith but also obstructing
justice by preventing the disclosure of Brady materials that may be crucial to the 2241 actual
innocent habeas corpus proceedings, 22cv3409 (SDNY) adjudication.
Moreover, the conduct of the USAO and EOUSA also violated Rules 3.3, 3.4, and 8.4 of the
DOJ and ABA Model Rules of Professional Conduct. Rule 3.3 requires prosecutors to disclose to
the court any legal authority that is directly adverse to the prosecutor's position, including
controlling legal authority in the jurisdiction, and to take remedial measures when necessary.
Rule 3.4 prohibits prosecutors from unlawfully obstructing access to evidence or from knowingly
Committee and request the Committee open Rule 1.5(d) investigation into the matter regarding Ex. A, Ex.
B, and Ex. C, infra.
Page 36 of 44
making false statements to the court.32 Rule 8.4 prohibits lawyers from engaging in conduct that
is prejudicial to the administration of justice.33
In this case, the USAO and EOUSA did not previously disclose that the “15 boxes” of
materials had not been properly inventoried, and they did not produce to the Court and the
defense the existence of the “15 boxes” of materials. This failure to disclose is a clear violation
of Rule 3.3 and 3.4, as it obstructed the defense's access to potentially crucial evidence and
prevented the Court from being fully informed.34
Furthermore, the DOJ Prosecutors’, the USAO's, and EOUSA's conduct is prejudicial to the
administration of justice, which is a clear violation of Rule 8.4. The Brady court orders were put
in place to ensure a fair trial and to prevent the conviction of innocent individuals. The USAO's,
the DOJ Prosecutors’, and EOUSA's failure to fully comply with these court orders undermines the
32
See (A) 15 USC 78o(a)(1), broker-dealer registration requirement regarding the 02cv2219 (SDNY)
plaintiffs concerning the U.S. v. Ware, 04cr1224 (SDNY) prosecution; also see (B) SEC Release 33-7190, n.
17 (1995) (“Section 2(a)(11) statutory underwriting required to register [with the SEC] all distribution of
securities.”). Either A or B vitiated and annulled all probable cause for the DOJ to have sought the
04cr1224 indictment—that is, the DOJ Prosecutors in bad faith intentionally and recklessly concealed the
judicial authority, they lied, committed, perjury, and committed a fraud on the federal grand jury, the
District Court (SDNY), the Court of Appeals, and the Supreme Court of the United States regarding the
bogus and fabricated charges in the null and void ab initio 04cr1224 indictment.
33
See Ex. B, infra, the false and misleading statements made to the District Court on May 19, 2006, by
former AUSA Alexander H. Southwell, regarding the existence of materials that could be considered Brady
materials—Southwell stated in open court he was unaware of any such Brady materials, and again on
January 2, 2007, Dkt. 44, lied, committed perjury, and misled the court and the defense regarding the
existence of Brady material. The EOUSA’s attempt to extort “$520.00” from Mr. Ware to conduct the
required Brady search of the “15 boxes” in the possession of the USAO is ipso facto “prejudicial to the
administration of justice.”
34
The USAO was required by the Brady court orders to have conducted an inventory of the “15 boxes” in
its possession for the possible containment of favorable, exculpatory and/or impeachment evidence
required to have been produced and disclosed according to the Brady court orders’ written commands—
ostensibly, the EOUSA has confessed, and admitted the USAO did not comply with the Brady court orders.
The EOUSA’s confessions and admissions are binding on the USAO and the District Court (SDNY), the U.S.
Court of Appeals for the Second Circuit, and the Supreme Court of the United States; and also binding on
the State Bar of Georgia, and the Supreme Court of Georgia.
Page 37 of 44
integrity of the criminal justice system and casts doubt on the legitimacy of any convictions that
may have been obtained as a result of this misconduct.
In conclusion, the criminal professional prosecutorial misconduct of the DOJ Prosecutors,

the USAO, and EOUSA in this matter has violated not only the Brady court orders but also federal
criminal contempt statutes and the DOJ and ABA Model Rules of Professional Conduct. Mr. Ware
urges the District Court (SDNY) assisted by OPR to conduct an emergency L.R. 1.5(b)(5) lawyer
disciplinary investigation and hold Damian Williams and others accountable for their criminal
prosecutorial misconduct. The integrity of the criminal justice system and the rights of the
accused depend on it.
Submitted by:
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
/s/ Ulysses T. Ware
Page 38 of 44
Exhibit A: EOUSA’s March 20, 2023, FOIA response letter.
Page 39 of 44
Exhibit B: U.S. v. Ware, 05cr1115 (SDNY), Dkt. 17, Brady court order--Perjury, lies, and false
and misleading statements of former AUSA Alexander H. Southwell regarding the USAO’s
possession of Brady materials.
Page 40 of 44
Exhibit B (con’t)
Page 41 of 44
Exhibit C: AUSA Southwell’s own official DOJ email to and from disgraced former SEC lawyer
Jeffrey B. Norris that established and confirmed the SEC and DOJ colluded, conspired, and
used the Las Vegas 03-0831 (D. NV) commingled SEC-DOJ illegal and unconstitutional
proceedings as a boot leg grand jury proceedings to gather evidence for the Ware criminal
proceedings—clearly favorable Brady exculpatory and impeachment material in the
possession of the SEC, the USAO, and EOUSA’s records and files.
Page 42 of 44
End of document.
Page 43 of 44
Certificate of service.
The individuals listed below were served via email with a copy of this pleading on March 24, 2023.
cc: Office of the U.S. Attorney General (Merrick B. Garland)

Office of the Director of the FBI
Executive Director, Administrative Office of the U.S. Courts
The Supreme Court of the United States, Office of the Judicial Congress of the United
States
Office of the United States Attorney (SDNY)
Office of the Chief District Judge (SDNY), Laura Taylor-Swain, personally.
District Judge Edgardo Ramos (SDNY), personally
Office of the U.S. Attorney General
Office of the Chief Bankruptcy Judge (NDGA), Wendy L. Hagenau, personally
The State Bar of Georgia, Office of the General Counsel
Office of the United States Attorney (EDNY)
U.S. Bureau of Prisons (Warden, MDC, Brooklyn, NY)
The Wall Street Journal
The New York Times
J. Henry Walker, IV (representative of the 02cv2219 plaintiffs)
John W. Mills, III
Edward T. M. Garland for Garland, Samuel, & Loeb, P.C., and Michael F. Bachner, Esq.
The Securities and Exchange Commission
Sims W. Gordon, Jr.
Thomas J. Leghorn
Marlon G. Kirton
The Conviction Integrity Committee of the Office of the United States Attorney (SDNY).
Daniel Gitner, and Margaret M. Garnett, personally
Andre Damian Williams, Jr, personally
Colleen McMahon, personally via the Office of the Chief District Judge (SDNY)
Debra Ann Livingston, personally via the Office of the Chief District Judge (SDNY)
Office of the Solicitor General of the United States
Baker & McKenzie, LLP
Lawrence B. Mandala, Esq.
London Fisher, LLP
Judicial Council of the Court of Appeals for the Second Circuit
US DOJ Office of Professional Responsibility (OPR)
/s/ Ulysses T. Ware
Page 44 of 44

DKT 208 Re DOJ OIG Criminal Misconduct Complaint

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DKT 208 Re DOJ OIG Criminal Misconduct Complaint

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Case 1:22-cv-03409-ER Document 208 Filed 03/28/23 Page 1 of 44

Filed on 3/28/2023 10:22:25 AM

APPLICATION to US DOJ’s Office of the Inspector General. ........................................................................ 4

APPLICATION to US DOJ’s Office of the Inspector General.

Tuesday, March 28, 2023

Via email to USOIG email whistleblower account

The Purpose of the Complaint.

The Identity and Position of the Complainant.

Background and Overview of the Allegations.

Basis for the Complaint.

Request for an Investigation.

Section C: Statement of Facts.7

Section C: Purpose of the Complaint.

II. Allegations of Misconduct--Specific Allegations of Misconduct.9

Filed on 3/24/2023 8:52:22 AM

Petitioner Ulysses T. Ware’s Actual Innocent Supplemental Claim

The Office of Ulysses T. Ware

Via email to ChambersNYSDRamos@nysd.uscourts.gov

Friday, March 24, 2023

in any aspect of the 04cr1224, 05cr1115, and 22cv3409 (SDNY) proceedings. 13

28 USC 455(b): He shall also disqualify himself in the following circumstances:

Respectfully submitted by:

/s/ Ulysses T. Ware

Friday, March 24, 2023

Actual Innocent Supplemental Claim #20.

Supplemental Claim (AISC) #20 predicated on Exhibit P, attached hereto, incorporated by

B. Claims and Contentions.

Prosecutors individually, and jointly as willing participants in a criminal illegal

association-in-fact as defined in 18 USC 1961(4), a continuing criminal enterprise, (the

the EOUSA’s March 20, 2023 FOIA response;

required to comply with the Brady Court Orders;

“over 15 boxes” “prior to trial;”

Prosecutors, and the DOJ; and

knowingly and intentionally enforce orders, judgments, and proceedings annulled,

Respectfully submitted by:

/s/ Ulysses T. Ware

Friday, March 24, 2023

22cv3409 (SDNY) (146)

Exhibit A: EOUSA’s March 20, 2023, FOIA response letter.

EMERGENCY APPLICATION to US DOJ Office of

Thursday, March 23, 2023

Memorandum of Fact and Emergency Petition for Criminal Violation of

From: Ulysses T. Ware

To: U.S. DOJ Office of Professional Responsibility: Jeffrey R. Ragsdale—via email to

Date: March 23, 2023

Mr. Jeffrey R. Ragsdale, U.S. DOJ Office of Professional Responsibility (“OPR”).

Requested reliefs from OPR.

I am petitioning to request that the U.S. Department of Justice Office of Professional

Declaration of Ulysses T. Ware

/s/ Ulysses T. Ware

DOJ ethics and professional standard violations claims and contentions.

A. March 20, 2023, Executive Office of the United States Attorneys

In conclusion, the criminal professional prosecutorial misconduct of the DOJ Prosecutors,

Exhibit A: EOUSA’s March 20, 2023, FOIA response letter.

cc: Office of the U.S. Attorney General (Merrick B. Garland)

/s/ Ulysses T. Ware

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