Breaking News:

Probable cause to indict the

USAG has been uncovered.

“All evil deeds eventually come to the light.”

USAG Merrick B. Garland and U.S. Attorney
(SDNY) Damian Williams have been implicated in
a DOJ conspiracy to obstruct justice and suppress
material Brady exculpatory evidence in the Ware
Cases.
IRNewswires Government Investigations
Meredith Kammler, Esq., LLB, LLM, Ph.D., Int’l investigative reporter
London, UK
February 2, 2022

IRN’s lawyers have received and reviewed Ulysses T. Ware’s February 1, 2022, Memorandum
of Law directed to the U.S. Attorney General Merrick B. Garland and his surrogate Damian Williams,

Page 1 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
the U.S. Attorney (SDNY). The evidence is very damning, undenied, and is a tremendous and career-
ending challenge for Messrs. Garland, Williams, and the executive leadership of the U.S. DOJ. Mr.
Garland the purported “chief law enforcement officer” for the United States finds himself in an
untenable and no-win situation. He, Mr. Garland, must come forward, immediately, and publicly
address the very serious allegations that are supported by fact; or he and the DOJ implicitly have
admitted the truth of Mr. Ware’s allegations by its silence.
If, a very big if, Mr. Garland and the DOJ are innocent, have done nothing improper, and
have complied with all of the constitutional requirements and processes required of the DOJ regarding
Mr. Ware’s constitutional rights in a criminal proceeding then now is the time to come forward and
explain to the public the position of the DOJ.
Exactly why Mr. Garland and the DOJ pursued ostensible fake and fabricated charges
against Mr. Ware can only be answered as just another nefarious example of an archetypical American
1800’s slavery era Jim Crow racially-motivated hate crime scam the DOJ and America writ large
historically is known for. America, a purported political (racial) democracy, where it claims “no [black]
man is above the law” has a long and horrible past regarding the racial relations between its citizens.
Black Africans were brought in chains, involuntary, to pre-America, the thirteen colonies, circa 1619,
and the Black people were held in insidious racial chattel slavery, stripped of all political rights,
privileges, and wealth until 1862 with the enactment of the Emancipation Proclamation.
Once the Black people were physically freed, but politically still in slavery, the rebellious
southern states enacted insidious Jim Crow legislation and other institutionalized processes that all but
prohibited the newly freed former slaves from politically and economically advancing. Now fast
forward to 2022, and the exact same pattern of pernicious Jim Crow jurisprudence has repeated
itself in the Ware Cases. Mr. Garland, a former U.S. federal appeals court chief judge and nominee to
the Supreme Court of the United States certainly know and is aware of the history of America and the
DOJ; yet he allowed himself to be maneuvered by illegal and improper political and financial influences and
pressures –that is, what is Mr. Garland’s and New York Senator Charles E. Schumer’s

Page 2 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
relationships with the international Hobbs Act money laundering criminal enterprise, Alpha
Capital, AG 1(Anstalt)?
Mr. Garland and the DOJ now find themselves in, perhaps, the most dubious and perilous
position a U.S. Attorney General and the DOJ have faced since the Watergate era crimes committed
by former President Richard M. Nixon in the 1970s, the ‘Saturday Night Massacre.’
Regarding Mr. Garland’s and New York Senator Charles E. Schumer’s relationships with
Alpha Capital, AG (Anstalt), IRN’s lawyers and investigators searched the records of the U.S. federal
district court in the Manhattan district clerk’s office and uncovered more than 50 fake lawsuits
fraudulent initiated by Alpha Capital, AG, lawyers Kenneth A. Zitter, Esq, convicted felon Edward
M. Grushko, Esq., and other law firms. IRN has obtained a copy of the May 17, 2021, certification by
FINRA that certified that Alpha Capital, AG, its manager LH Financial Services, and its investment
adviser Ari Rabinowitz, FINRA confirmed neither have ever registered according to U.S. law as
lawful broker-dealers or investment advisers. That status prohibited Alpha Capital, AG from using
the American federal courts to enforce, as a plaintiff, its illegal and unenforceable contracts that
extorted billions of dollars from the shareholders of the publicly-traded companies targeted and
swindled by Alpha Capital, AG, and its unindicted co-conspirators, perhaps both Messrs. Garland,
Schumer, and Damian Williams?
Where was the American Securities and Exchange Commission, the SEC, while Alpha Capital, AG was
defrauding investors? Apparently asleep at the switch.
IRN’s investigators and lawyers also are investigating exactly what was the process and political
dynamics that allowed Mr. Garland’s former law clerk at the D.C. Circuit Court of Appeals, Damian
Williams, to be nominated for the position of the United States Attorney (SDNY) while having no
executive law enforcement experience? IRN’s lawyers have uncovered the fact that Damian
Williams was a former associate at the same New York law firm, Paul, Weiss, et al., LLP,
where Senator Charles E. Schumer’s brother is a partner and a member of the Senator
Schumer’s purported “nominating committee.” Certainly, an opaque process ripe with conflicts
of interests and other nefarious political and financial influences.

1
See SEC v. Honig, et al., 18cv08175 (SDNY) (Ramos, J.) (Alpha Capital consented to the entry of final judgment for
securities fraud and marker manipulation charges and fined more than $2.5 million).

Page 3 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 IRN will continue to report on the Ware Cases until justice is received for Mr. Ware and others
who have been wrongfully prosecuted and convicted by Jim Crow racially-motivated jurisprudence and law
enforcement.

Copyright © 2022. All rights reserved. IRNewswires Public Corruption Investigations.

Cleared for international and domestic distribution.

Page 4 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 Offices of Ulysses T. Ware
123 Linden Blvd.
Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
[email protected]

February 1, 2022

Personal and confidential

Via U.S. mail and via email to Jeffrey R. Ragsdale c/o

The Hon. Merrick B. Garland
Attorney General of the United States2
United States Department of Justice
950 Pennsylvania Ave.
Washington, D.C. 20530

Via email to the Government’s local counsel.

Damian Williams
Office of the United States Attorney3
For the Southern District of New York
1 St. Andrews Plaza
New York, NY 10007

RE: Doc. 53A-8.3 follow-up to the January 27, 2022, Doc. 53A-8.2, request for Damian
Williams, the purported United States Attorney (SDNY), (the “USAO”), to file into the District
Courts, as an officer of the court, under a duty of “complete candor,” the litigation position(s) of
the USAO on behalf of the United States and its privies, the real party in interest, in regard to the
matters and issues raised herein, to reduce the burden on the court in the imminent judicial
intervention to resolve all disputed matters of material fact.
I.

2
See 28 USC 519.

3
See 28 USC 547(1).

Page 5 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
A. NOTICE OF THE 18 USC 401(3) CRIMINAL CONTEMPT CRIMES COMMITTED BY MERRICK
B. GARLAND, DAMIAN WILLIAMS, AND OTHER DOJ PROSECUTORS IN THE WARE CASES,
United States v. Ware, 04cr1224 (SDNY), United States v. Ware, 05cr1115 (SDNY), and in
Alpha Capital, AG, et al. v. IVG Corp., a/k/a Group Management Corp., (OTCBB: GPMT), et
al., 02cv2219 (SDNY).

Memorandum of Law: #53A-8.3

Page 6 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
To: The United States Attorney General, the Hon. Merrick B. Garland, et al.

From: Ulysses T. Ware, racketeering victim, and defendant.

Date: February 2, 2022.

Re: 18 USC 401(2), 401(3) criminal contempt offenses: the law and the facts.

I.

1. Mr. Ware writes to inform you, in your personal and individual capacity4, and the DOJ
Prosecutors in their personal and individual capacity of regarding the willful, knowing, deliberate,
and intentional in bad faith Jim Crow racially-motivated resistance and disobedience, 18 USC
401(3) criminal contempt,5 of the unequivocal express, explicit, and implicit commands of the

4
Merrick B. Garland, the DOJ’s prosecutors, and others, jointly and severally, have personal civil monetary
liability to Mr. Ware in the sum certain amount of $2.225 billion because (a) as a matter of law probable
cause was a legal impossibility in 04cr1224 and 05cr1115, (b) neither alleged indictment charged an
“offense” as required by 28 USC 547(1); and (c) the respective district courts lacked an “offense” and
accordingly, lacked 18 USC 3231 subject matter jurisdiction to adjudicate any judicial proceedings. The
proceedings as a matter of law are moot, see Steel Co., 523 U.S. at 93-95 (Scalia, J.) (subject matter
jurisdiction is a “threshold matter” that must be resolved by the court “prior to” reaching the merits of
the claims; and if jurisdiction is found to be lacking, the only function of the court is to notify the parties
and dismiss the cause) (emphasis added).
5
18 USC 401(3): A court of the United States shall have power to punish by fine or imprisonment, or
both, at its discretion, contempt of its authority, and none other, as—
(1) Misbehavior of any person in its presence or so near thereto as to obstruct the administration of
justice;
(2) Misbehavior of any of its officers in their official transactions;
(3) Disobedience or resistance to its lawful writ, process, order, rule, decree, or command.

Page 7 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
Brady Court Orders6, to wit: (1) May 19, 2007, Dkt. 17, Tr. 5-9, Pauley, J. (05cr1115); and (2)
August 10, 2007, Dkt. 32, Sweet, J. (04cr1224); and the final judgments: (3) December 20, 2007,
Dkt. 90, Sand, J. (02cv2219); and (4) August 18, 2009, United States v. Ware, 07-5670-cr (XAP),
Gov.-I, (Kearse, J.) (2d Cir.).

2. Mr. Garland, I draw your attention to the very grave, perilous, and untenable position
that you and the DOJ’s prosecutors are currently in regarding your and their willful continued
resistance to and disobedience of the Brady Court Orders and the Final Judgments, unequivocally
a criminal contempt offense, 18 USC 401(3).

3. I inform you of the binding circuit precedent, the law, and reasoning in United States v.
Petito, 671 F.2d 68, 73 (2d Cir. 1982). In Petito, the court of appeals affirmed the conviction of
Petito for criminal contempt, 18 USC 401(3), for his willful refusal to give testimony to a federal
grand jury after being immunized. Id. at 69-70. The Court noted and explained the functions of
civil and criminal contempt, Id. at 72:

“This view of the law misreads the function of civil and criminal contempt. The one is coercive,
to compel obedience to a lawful court order [the Brady Court Orders]; the other is retributive,
to punish for an offense against the public and to vindicate the power of the court. An
individual [Merrick G. Garland, Damian Williams, Audrey Strauss, John M. McEnany, Melissa
Childs, Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, Maria E. Douvas, Andrew
L. Fish, Steve R. Peikin, Katherine Polk-Failla, Sarah E. Paul, Margaret M. Garnett, Daniel Gitner,
Preet Bharara, Joon Kim, Michael J. Garcia, David N. Kelley, Jeffrey Berman, collectively, (the
“DOJ’s Prosecutors”) and others7 who aided and/or abetted the disobedience or resistance]

6
The Brady Court Orders commanded the United States and its privies to disclose “all” Brady and Giglio
exculpatory and impeachment materials to Mr. Ware (i) before the start of the 05cr1115 trial then set for
September 2006; and (ii) prior to trial in 04cr1224 then set for November 2007; as well as Brady’s implicit
continuing duty and obligation of the DOJ to disclose after trial, the supervisory responsibility of the U.S.
Attorney General Merrick B. Garland, as an officer of the court, to make certain of the compliance of the
U.S. Attorney’s Office (SDNY), (the “USAO”), disclosed to Mr. Ware the Government’s “principal witness”
at trial in 05cr1115 (i) Jeremy Jones’ alleged September 2006, purported Rule 11 perjury contract, (ii)
Jones’ alleged allocution, (iii) Jones’ USSG 5k cooperation agreement, and (iv) the USAO’s 2008 written
USSG 5k letter to the District Court (Pauley, J.) in support of a downward departure in Jones sentencing,
collectively, (the “Suppressed and Concealed Material Jones Brady and Giglio Materials”).
7
See Exhibit 15 attached hereto and made a part hereof.

Page 8 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 who refuses obedience to a valid order is subject to both civil and criminal contempt for the
same acts. Yates v. United States, 355 U.S. 66, 74, 78 S.Ct. 128, 133, 2 L.Ed.2d 95, 102, (1957).”
(emphasis added).

4. As it relates to Mr. Ware’s outstanding, pending, and unfulfilled demand for the DOJ to
disclose “all” Brady and Giglio exculpatory and impeachment materials post-trial the materials
that were willfully and knowingly suppressed and concealed pre-trial and during trial, (cf., 53A-
8, January 11, 2022, (Demand for the DOJ to disclose all Brady and Giglio materials)) the court
also noted, Id. at 73, that the offense of criminal contempt is committed and completed the
moment you and the DOJ’s prosecutors committed the willful disobedience or resistance to the
Brady Court Orders occurred once you and the DOJ’s Prosecutors decided not to disclose the
Brady and Giglio materials to Mr. Ware, or be bound by the implicit commands of the Final
Judgments:

“In our view there is no requirement that preindictment notice need be given an
individual, held in civil contempt for his refusal to testify following a grant of immunity, that he
could also be subject to a charge for criminal contempt. Appellant had committed the act
subjecting him to criminal contempt at the moment he refused to answer questions after
being granted immunity. Any remarks later made by Judge Bramwell, when Petito appeared
before him for the second time, were after the fact of the contemptuous act. Appellant had
already chosen to disregard the law and risk the consequences. To suggest that he is entitled to
notice of those consequences or of the crime he had already committed as a prerequisite to
being prosecuted is tantamount to adopting the doctrine — which we recently rejected as
unsound — that ignorance of the law is an excuse. We have not been convinced that we should
adopt a wholly new procedural right of notice in criminal contempt proceedings.” (emphasis
added), (the “LAW”).

II.

1. Mr. Garland, if you are true to your public statements, which it appears that you are not
when you, your cronies, and your surrogates have personal pecuniary and penal legal jeopardy,
to “impartially,” “without bias,” “apply the law to the facts” and “follow the evidence wherever
it might lead” (quoting Merrick B. Garland), the evidence leads directly to your front door at The

Page 9 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
United States Department of Justice, 950 Pennsylvania Ave., Washington, D.C. 20530, (the “DOJ’s
Front Door”).

It cannot be debated, rationally, in good faith and non-frivolously, by anyone that is

“impartial” and “unbiased” that Merrick B. Garland, the DOJ’s Prosecutors, and the individuals
and entities named in Exhibit 15, attached hereto, have not willfully disobeyed, resisted, and/or
aided or abetted, and facilitated the disobedience or resistance to the Brady Court Orders and
Final Judgments, (the “Facts”); cf., Doc. 53A-8, January 11, 2022, memorandum of Ulysses T.
Ware to USAG Merrick B. Garland (demand for disclosure of all Brady and Giglio materials).

2. Moreover, where the persons named in Exhibit 15 are federal judges, all by willfully or
recklessly in disregard for the facts and law disobeyed and/or resisted, or aided and/or abetted
the same, have already committed 18 USC 401(2) and 401(3) criminal contempt offenses, high
crimes and misdemeanors, impeachable offenses. cf., Petito, 671 F.2d at 73; and if the DOJ
“applies the law to the facts” “impartially without bias,” probable cause currently exists, and all
are required to be immediately indicted, arrested in the district where located, held without
bail, prosecuted, convicted, and sentenced to life imprisonment.8 That is the LAW you are so
fond of in public claiming to uphold. Your favorite trope.

3. Mr. Garland, the 18 USC 401(2) and 401(3) criminal contempt crimes already have been
committed, completed, and are ongoing by you and the DOJ’s Prosecutors’ willful, deliberate,
intentionally, and bad faith disobedience and resistance –that is, your and their continued refusal
to disclose to Mr. Ware material Brady exculpatory and Giglio impeachment evidence9 in the

8
Kidnapping, 18 USC 1201: (c) If two or more persons conspire to violate this section and one or more of
such persons do any overt act to effect the object of the conspiracy, each shall be punished by
imprisonment for any term of years or for life.
(d) Whoever attempts to violate subsection (a) shall be punished by imprisonment for not more than
twenty years.
9
See Mr. Ware’s January 11, 2022, Doc. 53A-8, and others, written demand(s) served on Merrick B.
Garland and Damian Williams for the DOJ to immediately disclose all Brady and Giglio materials in its
possession in compliance with the Brady Court Orders. According to court records, neither Merrick B.

Page 10 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
position of the DOJ that is dispositive to the -- purported convictions and sentences of Mr. Ware,
that were unlawfully entered in 04cr1224 and 05cr1115, criminal proceedings’ credibility,
veracity, and constitutional integrity; and to unequivocally obey and comply with the implicit
commands of the Final Judgments, i.e., the (i) December 20, 2007, Dkt. 90, (Sand, J.) superseding
voluntary Rule 41(a)(2) final judgment; and (ii) the voluntary 07-5670 (2d Cir.) August 18, 2009,
Gov-I superseding final judgment entered against the United States and its privies.10

III.

1. Mr. Garland, it is regrettable that you, the alleged and purported “chief law
enforcement officer of the United States” knowingly and willfully decided, agreed, and have
orchestrated and participated in the commission of criminal offenses, 18 USC 401(2), 401(3),
criminal contempts of the Brady Court Orders, and the Final Judgments; and other crimes
committed by you, the DOJ’s Prosecutors, and the persons and entities named in Exhibit 15,

Garland nor Damian Williams complied in any way, or responded to, Mr. Ware’s Brady disclosure
demands. Accordingly, their resistance and disobedience are willful, knowingly, intentional, deliberate,
and in bad faith. Cf., Mr. Ware’s Doc. 53A-10, January 23, 2022, Demand to the DOJ and its unindicted
co-conspirators to immediately cease, desist, and terminate all civil and criminal contempts of the Brady
Court Orders and Final Judgements.
10
The United States via the DOJ’s Prosecutors on November 7, 2008, notified the Court of Appeals for the
Second Circuit that the United States and its privies had pursuant to Article II, 18 US 3742(b), and Fed. R.
App. P. 42(b), voluntarily abandoned, and dismissed with prejudice its United States v. Ware, 07-5670-cr
(XAP), Gov. -I, cross-appeal of the 05cr1115 (Pauley, J.), October 2007, Rule 29 (c) post-trial acquittal
verdicts in favor of Mr. Ware, to wit: (1) Dkt. 99, S. Tr. 31 L 18-25 (R-1); (2) S. Tr. 35-36 (R-2); and (3) S. Tr.
73-76 (R-3), jointly, (the “Pauley Double Jeopardy Acquittal Verdicts”).

Regarding the Government, it abandoned, terminated, aborted, and dismissed with prejudice 07-5670-cr
(XAP) (2d Cir.), Gov.-I, cross-appeal, the Double Jeopardy Clause was triggered on August 18, 2009, by the
entry of final judgment against the United States and its privies; which conferred prevailing party status
on Mr. Ware to enforce the Gov.-I final judgment by civil or criminal contempt proceedings; ipso facto
by operation of law terminated all federal and state courts, agencies, and employees authority or subject
matter jurisdiction over any and all aspects of the United States v. Ware, 05cr1115 (SDNY) proceedings;
and ipso facto, by operation of law affirmed R-1, R-2, and R-3 in favor of Ulysses T. Ware, the prevailing
party. That is the LAW.

Page 11 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
attached hereto and made a part hereof, high crimes and misdemeanors. Crimes that you and
the unindicted co-conspirators are required to be indicted, arrested, held without bail,
kidnapping is not a bailable offense, prosecuted, convicted, and sentenced to life imprisonment.

2. Mr. Ware, the victim of the RICO crimes committed by you and your unindicted co-
conspirators hereby this 1st day of February 2022, exercises and gives notice of his rights as a
victim under United States law, a racketeering victim, and refuses to accept or consent to any
guilty plea with any sentence less than 360 months or life in federal prison for each person
found guilty, or that enters a plea of guilty to any crimes committed as a direct or indirect
participant in the RICO criminal enterprise, or individually, that orchestrated, aided, abetted,
facilitated, assisted, helped, furthered, obstructed, delayed, frustrated, or in any way
participated in, directly or indirectly, the 02cv2219 (SDNY), 03-0831 (D. NV), 03-93031 (BC NDGA),
04cr1224 (SDNY), 05cr1115 (SDNY) proceedings, and their derivative proceedings.

3. Mr. Garland, the binding legal authorities of the second circuit all, if applied impartially
and without bias to the facts, suggest and hold that probable cause for the 18 USC 401(2) and
401(3) criminal contempt offenses and crimes has already been established in 05cr1115 (May
2006), in 04cr1224 (August 10, 2007), in 02cv2219 (December 20, 2007), and in 07-5670cr (XAP)
(2d Cir.) (August 18, 2009), collectively, (the “Probable Cause Facts”), the very moment the Brady
Court Orders or Final Judgments were willfully or recklessly resisted and/or disobeyed. Petito,
671 F.2d at 73.

4. The crimes 18 USC 401 criminal contempt crimes already have been committed and
are completed. In other words, or put another way, Merrick B. Garland, the DOJ’s Prosecutors,
and the Exhibit 15 persons and entities are putative and imminent defendants in a federal
criminal proceeding that involved matter they have currently before their courts;11 and,

11
Wendy L Hagenau (03-930310-mhm (BC NDGA)); Edgardo Ramos (04cr1224 and 05cr1115); Kent J.
Dawson (03-0831 (D. NV)); Thomas W. Thrash, Jr. (12cv4397 (NDGA)); Timothy C. Batten, Sr., (In re Ware,
(2008) alleged disbarment proceedings); Damian Williams, U.S. Atty (SDNY), 04cr1224 and 05cr1115;
Colleen McMahon (02cv2219 (SDNY)); Laura Taylor-Swain (02cv2219, 04cr1224, and 05cr1115 (SDNY));

Page 12 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
accordingly, all are legally disqualified from continuing to function or perform in any judicial or
prosecutorial capacity as long as and until each is formally indicted, prosecuted, and/or
convicted, and/or sentenced. The law, In re Murchison, 349 U.S. 133 (1955), explained that “ …
no man or woman can be a judge in their own case; else due process of law is violated ….”
(paraphrased) (emphasis added).12

IV.

Conclusion.

Mr. Garland, regrettably, through unprecedented hubris and avarice you have placed
yourself in a dubious and very perilous position. On the one hand, you have already knowingly
and willfully resisted and disobeyed the written, unequivocal commands of the Brady Court
Orders; and the implicit commands of the Final Judgments. The criminal contempt, 18 USC 401(2)
and 401(3), crimes are already completed. That is factual and cannot be disputed, cf., Doc. 53A-
8, January 11, 2022, demand of Mr. Ware for disclosure of all Brady and Giglio material. Petito,
671 F.2d at 73. Yet, on the other hand, you are the sitting USAG. However, given your indisputable
culpability and liability for federal criminal offenses, you are legally precluded from any and all
direct and/or indirect participation in any aspect of any decision-making viz-a-viz the prosecution
of, obviously yourself, In re Murchison, Id., the DOJ’s Prosecutors, or the Exhibit 15 persons and
entities.

Amalya L. Kearse and Robert D. Sack (07-5222 and 07-5670) (2d Cir.); and Merrick B. Garland, et al., (all
of the above cases pursuant to 28 USC 519).

12
Palpably, if any person who is a putative defendant in a federal criminal proceedings continues to have
any involvement in matters that affect, in any small or large manner, the outcome of any aspect of the
underlying and criminal proceedings, they have the untenable temptation and very real threat to arrange
and obstruct matters that will affect, influence, and/or benefit their or unindicted co-conspirators’
personal penal and pecuniary interests. Those risks and threats cannot be allowed to occur if the integrity
and credibility of the courts and the DOJ’s oath to “enforce the law” has any veracity.

Page 13 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 Mr. Garland, you, through your, laziness, sloppiness, inattention to details, and
extreme hubris and arrogance, have allowed this matter to linger and it has now festered into a
gangrenous plague of infestation that likely is going to cause the career-ending and imprisonment
for life for many of the persons named herein, including yourself. Rather than concern yourself,
exclusively, with your sworn duty and obligation to “impartially” and “without bias” enforce the
laws, through weakness of character, and intellectual embedded implicit bias, prejudice, and
racism, you allowed yourself and the DOJ to be used; and you and the DOJ succumbed to illegal,
unethical, improper influences, implicit promises of unlawful and improper gratuitous things of
value, and other criminal influences from legislators and others are the causes of your public
demise.

In essence you, Merrick B. Garland, the USAG, are the Shakespearean character in
Othello, Iago, perhaps the most evil and villainous, it has been said, character in “all of
literature.”13

Thus, the only question remaining is, (1) Where does this dreadful fiasco now go from
here given the USAG and the USAO are legally disqualified from all participation in the matter?

Therefore, Mr. Ware hereby this 1st day of February 2022, notifies the USAG Merrick B.
Garland and the U.S. Attorney (SDNY) Damian Williams, et al., that he will partition the Judicial
Conference of the United States, the Hon. Chief Justice John G. Roberts, Jr. and the Judicial
Conference of the Second Circuit, the Hon. Debra A. Livingston, pursuant to the Courts’ Article III
supervisory authority to immediately intervene in this matter given the ongoing unprecedented
risks and threats to the due administration of the criminal law in the federal courts.

13
“Iago is jealous, dishonest, duplicitous, manipulative, and evil. His jealousy is shown when he is
furious of Cassio becoming [Othello’s] military lieutenant, [or in the case of Merrick B. Garland, a
Supreme Court Justice] instead of him.” Perhaps you not getting the Supreme Court has made
you very bitter, like Iago, and this, like Iago, was also your demise.

Page 14 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 Mr. Ware has, is, and will continue to suffer irreparable harms if the intervention is not
made; as well as the public and the court system will suffer irreparable harm. Mr. Ware will
petition the Court(s) to immediately intervene and appoint a special master pursuant to Fed. R.
Civ. 53(a)(1)(B) and (C) with a mandate to call witnesses, issue subpoenas, make findings of facts,
and conclusions of law, issue a public report, permit the parties to participate in the matter as
adversaries, and any other judicial processes that are needed to reach the truth and resolve the
allegations made by Ulysses T. Ware, a Racketeering Victim, and defendant.

Mr. Garland, if you have anything to add or subtract, oppose, dispute, any
disagreement, challenge, or otherwise, to this Memorandum, please do so in writing not later
than 12:00 noon on Wednesday, February 2, 2022, time of the essence.

Sincerely,

/s/ Ulysses T. Ware

cc: The Judicial Conference of the United States, Supreme Court of the United States.

The Judicial Conference of the Second Circuit Court of Appeals.

Page 15 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 Exhibit 15

1. Merrick B. Garland, Lisa O. Monaco, Vanita Gupta

2. Jeffrey R. Ragsdale;
3. David N. Kelley, Michael J. Garcia, Joon Kim, Preet Bharara, Jeffrey Berman, Audrey Strauss,
Damian Williams;
4. Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, Maria E. Douvas, Sarah E.
Paul, Katherine Polk-Failla, Margaret M. Garnett, Daniel Gitner, Alexander J. Wilson,
Steven R. Peikin, David Makol, Maria E. Font, Andrew L. Fish, Melissa Childs, John M.
McEnany, the U.S. Marshals Service (NDGA) and (SDNY);
5. Edgardo Ramos, Laura Taylor-Swain, William H. Pauley, III, Robert W. Sweet, Michael H.
Dolinger, Andrew J. Peck, Ruby Krajick, Colleen McMahon;
6. Timothy C. Batten, Sr., Thomas W. Thrash, Jr., Orinda D. Evans, Marvin H. Shoob, James N.
Hatten, Julie E. Carnes; Gerrilyn G. Brill, Linda T. Walker, Clayton Scofield,
7. the State Bar of Georgia, Paula Fredrick, Bill NeSmith, Jenny Mittlemen, Adrienne Nash,
William A. Myers, Jonathan Hewitt, Dan O’Sullivan, Carmen Rojas-Rafter, Williams P.
Smith, III (deceased), Dawn Jones, ;
8. Edward T.M. Garland, Manibur S. Arora, Donald F. Samuel, David Levitt, Michael F.
Bachner, Gary G. Becker, Lisa Scolari, James H. Roth, Marlon G. Kirton;
9. Michael Fitzpatrick, Thomas J. McCarthy, David Mulcahy, Cathleen Tyler;
10. Jeffrey B. Norris, Spencer C. Barasch, Kent J. Dawson, Steven Korotash, Steven Webster,
John C. Martin, Robert C. Hannan, Joan E. McKown; SEC’s Comm’r that approved the bogus
03-0831 (D. NV) lawsuit;
11. Amalya L. Kearse, Robert D. Sack, Peter W. Hall, Robert A. Katzmann, Barbara S. Jones;
12. Alpha Capital, AG (Anstalt)14, Stonestreet, L.P., Markham Holdings, Ltd., Amro
International, S.A., Ari Rabinowitz, Ari Kluger, Konrad Ackermann, Edward M. Grushko,
Barbara R. Mittman, LH Financial Services, Kenneth A. Zitter, Kilpatrick, Townsend, &
Stockton, LLP, Dennis S. Meir, John W. Mills, III, J. Henry Walker, IV;
13. Margaret H. Murphy, Joyce Bihary, C. Ray Mullins, Wendy L. Hagenau, Patricia Sinback, M.
Regina Thomas; U.S. Trustee Office (NDGA) James Morawitz;

14The international money laundering criminal enterprise operated and managed in New York
and managed by LH Financial Services and unregistered investment advisor government 04cr1224
(SDNY) trial witness Ari Rabinowitz. See SEC v. Honig, 18cv08175 (SDNY) (Ramos, J.)

Page 16 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project
 14. Jeremy Jones, Myron Williams, Elrico Sadler, Carlton Epps, Charles H. Jackson;
15. Gerald B. Tjoflat, Stanley Marcus, Adelburto Jordan, and Charles R. Wilson;
16. James Olas, John Doe #1, John Doe #2, John Doe #3 (U.S. Marshals NDGA);
17. Kelly Quinn, ComputerShare (GPMT’s transfer agent);
18. Linda T. Walker;
19. Andrews & Kruth, LLP
20. Duke School of Law
21. Gerrilyn G. Brill
22. Clayton Scofield
23. Gail McKenzie (AUSA NDGA, Feb 2005, 04cr1224 arrest)
24. Sally Q. Yates (US Atty (NDGA), 12cv4397 (TWT) habeas corpus fraud and obstruction of
justice; fraud on the court; Darlene Drew
25. The GEO Group, Inc., Halfway house, BOP’s regional director, BOP (MDC Warden)
26. John Horn (former U.S. Atty (NDGA)).
27. Sims W. Gordon, Jr.
28. omitted.
29. 9th Cir. Court of Appeals (Johnnie B. Rawlinson, Steve Rhinehart) appeal from 03-0831 (D.
NV) (lack of SMJ)
30. SEC Commissioners (who authorized the 03-0831 (D. NV lawsuit + McKown + 03-0831
lawyers + Dawson)
31. SEC Freedom of Information Division’s fraud in disclosing fraudulent requested
information regarding Joan E. McKown, Jeffrey B. Norris, and Steve R. Peikin.
32. Supreme Court of Georgia’s Justices in their individual capacity (no jurisdiction or
probable cause established by proper service of process

Page 17 of 17
Wednesday, February 2, 2022
IRN 2022 Ulysses T. Ware Innocence and Exoneration Project