AUSA Maria E.

Douvas’ Brady Violations:

Willful Criminal and Civil Contempt of the Brady Orders,
Exhibits 1-7 and 1-8, and violation of L.R. (SDNY) Rule
1.5(b)(5).

Former AUSA Maria E. Douvas

Perjured declaration of AUSA Maria E. Douvas

Douvas knew that she had suppressed and concealed the attached Exhibits
when she fraudulently submitted the Declaration as an officer of the court.

Page 1 of 13
 Exhibit 1-1
Suppressed material Brady exculpatory evidence by Government’s trial
lawyers and their supervisors.
FINRA’s May 17, 2021, certification of unregistered broker-dealer status for
each of the “Civil Plaintiffs” named in paragraph 8 of the U.S. v. Ware,
04cr12224 (SDNY) indictment, Exhibit 1-2. Unregistered broker-dealers
lacked Article III and 18 USC 1332(a) standing to appear in federal court and
enforce illegal contracts, GX 1-4 and GX-5.

Page 2 of 13
 Exhibit 1-2
Para. 8 of the 04cr1224 indictment.
Paragraph 8 named the same entities as named in Exhibit 1-1 certified by
FINRA as unregistered broker-dealers. The indictment is null and void ab
initio and all probable cause and subject matter jurisdiction was lacking.

Page 3 of 13
 Exhibit 1-2.1
04cr1224 (SDNY) indictment

Page 4 of 13
 Exhibit 1-3
Suppressed Brady material exculpatory evidence.
Confession and judicial admission of Government trial witness Ari
Rabinowitz.

Page 5 of 13
 Exhibit 1-3.1
Material Brady exculpatory evidence:
Unregistered investment adviser, government 04cr1224 trial witness Ari
Rabinowitz.

Page 6 of 13
 Exhibit 1-4
Suppressed material Brady impeachment evidence:
Gov’t 04cr1224 FRE 404(b) bad acts trial witness SEC lawyer Jeffrey B.
Norris’ professional bad acts and misconduct.

Page 7 of 13
 Exhibit 1-5
Suppressed and concealed material Brady exculpatory evidence.
Impeached and undermined the Gov’t trial witnesses that knowingly
committed perjury that was suborned by the Government’s trial lawyers and
their supervisors.

Page 8 of 13
 Exhibit 1-6
Concealed and suppressed material Brady evidence. Suppressed by acting
U.S. Attorney Audrey Strauss, AUSA Melissa Childs, and AUSA John M.
McEnany.

Page 9 of 13
 Exhibit 1-7
04cr1224 (SDNY) August 10, 2007, Dkt 32, Brady order (Sweet, J.).

Page 10 of 13
Exhibit 1-7.1

Page 11 of 13
 Exhibit 1-8
05cr1115 (SDNY) May 19, 2006, Dkt. 17, Tr. 5-9, Brady order (Pauley, J.).

Page 12 of 13
Exhibit 1-8.1

Page 13 of 13