Offices of Ulysses T.

Ware
123 Linden Blvd.
Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
Utware007@gmail.com

January 17, 2022

Via regular mail and via email to Asst. Attorney General Jeffrey R. Ragsdale c/o:
Office of the Attorney General of the United States
The Hon. Merrick B. Garland
United States Department of Justice
950 Pennsylvania Ave
Washington, D.C. 20530

Request to open a racketeering investigation, 18 USC 1968(a), et seqs.

RE: United States v. Ware, 04cr1224 (SDNY), (“1224”) and United States v. Ware, 05cr1115
(SDNY), (“1115”), (the “Ware Cases”). Official notice of material fact witness and
unindicted co-conspirator status.

Attorney General Garland:

1. Please be advised that the undersigned, the defendant in the Ware Cases, hereby this 17th
day of January 2022, pursuant to 18 USC 1961 et seqs. has officially designated the individuals
and entities listed in Exhibit 15, infra, as material fact witnesses and unindicted co-conspirators.
The Unindicted Co-Conspirators have since on or before 2002, continuously without interruption
to the present, January 2022, in the Southern District of New York, Atlanta, GA, Las Vegas, NV,
and elsewhere, have been knowing, willing, deliberate, intentional, and eager participants,
directly and/or indirectly, in an illegal association-in-fact, a continuing criminal enterprise, as

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RE: 53A-9 Notice of material witness and unindicted co-conspirator status.
defined in 18 USC 1961(4);1 and each person or entity has knowing and deliberately with criminal
intent, and with an evil and criminal Jim Crow racially-motivated motive and objective,
implemented, carried out and executed in interstate commerce, by the use of the means and
instrumentalities of interstate commerce, two or more racketeering activities as defined in 18
USC 1961(a), et seqs.;2 and directly and/or indirectly caused massive and extraordinary damages,
injuries, and harms to Ulysses T. Ware, Group Management, Silver Screen Studios, IVG Corp.,
and Global One Investment Group, jointly (the “Victims” or “Racketeering Victims”).
Mr. Garland, the Racketeering Victims are respectfully requesting that the Department of
Justice’s criminal division and Division on Public Integrity open immediately an 18 USC 1968(a)
racketeering investigation concerning the individuals and entities named in Exhibit 15, attached
hereto, and made a part hereof, regarding the racketeering activities committed before, during,
and after the Ware Cases were allegedly adjudicated in the federal courts. Albeit, in the “clear
absence of all jurisdiction” in the personal and individual capacities of the federal judges, court
employees, Securities and Exchange Commission employees and officials, U.S. Probation Office
employees and officers, FBI employees, and DOJ employees and officials involved in the illegal
prosecutions of the Ware Cases.
Mr. Garland, in Mr. Ware’s January 11, 2022, communication and inquiry to you in your
official capacity as the USAG. Mr. Ware requested a response date of January 21, 2022, at 12:00
noon if you or the DOJ had any official objection, disagreement, challenge, or opposition to the
facts and allegations contained in the inquiry.
Accordingly, Mr. Ware hereby this 17th day of January 2022, notifies you and the DOJ that
if there is no official response in opposition, disagreement, objection, or challenge filed in the

118 USC 1961(4): “enterprise” includes any individual, partnership, corporation, association, or
other legal entity, and any union or group of individuals associated in fact although not a legal
entity.

2 Kidnapping, conspiracy, securities fraud, bankruptcy conspiracy, mail and wire fraud,
racketeering, obstruction of justice, perjury, grand jury conspiracy, money laundering, hate
crimes, etc.

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federal courts on the record to the January 11, 2022, inquiry’s allegations and facts by January
21, 2022, then Mr. Ware will file a sworn copy of the January 11, 2022, inquiry into the courts as
the stipulated facts of the parties, (the “Stipulated Facts”), and request emergency judicial relief
based on the Stipulated Facts for the courts to order and conduct evidentiary and sanctioning
proceedings in regard to the flagrant and criminal judicial and prosecutorial misconduct
committed in the Ware Cases.
Furthermore, it will be agreed, accepted, and deemed as the undisputed stipulated
material fact, estoppel by acquiesce, that the Stipulated Facts provides sufficient factual basis
on all necessary factual elements for racketeering claims, Federal Tort Claim Act claims, New York
State, Georgia State, and Bivens civil rights claims relief in favor of the Racketeering Victims in
the sum certain amount of $2.225 billion dollars, liquidated and stipulated damages, plus costs,
expenses, attorney’s fees, and punitive damages for racketeering civil claims.
Mr. Garland, even a cursory and incomplete review of the records3 in the Ware Cases will
confirm there is an immoral, rotten, insidious, pernicious, and illegal criminality involved in the
due administration of justice in the federal courts. One needs to look no further than the crimes
committed by Unindicted Co-Conspirators District Judges Laura Taylor-Swain4, Edgardo Ramos5,

3
Dkt 32, August 10, 2007, (04cr1224) (Sweet, J.) and Dkt. 17, May 19, 2006, (05cr1115)(Pauley, J.), (the
“Brady Court Orders”) existence cannot be rationally debated or opposed, given the USAO consented to
the entry of the Brady Court Orders.

4
The Chief District Judge (SDNY) has knowingly, deliberately, intentionally, in bad faith, and with an evil
and criminal motive has obstructed, delayed, impeded, frustrated, and prevented the due administration
of justice with respect to Marlon G. Kirton, and the DOJ prosecutors being held accountable for obvious
violations of Local Rule District Court (SDNY) 1.5(b)(5); and moreover, Judge Taylor-Swain has impeded
and obstructed all of Mr. Ware’s application for entry of a supervisory writ directed to the USAO (SDNY)
to address the issues regarding its compliance with the Brady Court Orders entered in the Ware Case viz-
a-viz, 18 USC 401(3) criminal and civil contempt of court orders by the DOJ prosecutors, while aided and
abetted by District Judge Edgardo Ramos. Without any doubt Chief Judge Taylor-Swain and Judge Edgardo
Ramos have knowingly and willfully committed high crimes and misdemeanors, impeachable offenses;
and must be impeached and prosecuted for their crimes.

5
Edgardo Ramos, since July 2021, has knowingly, willfully, deliberately, intentionally, in bad faith, acted
with an evil and racially-motivated depravity and criminal intent, and has viciously and with hate and
malice denied Mr. Ware his constitutional rights under due process of law to have his claims adjudicated

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Williams H. Pauley, III, Robert W. Sweet, Thomas W. Thrash, Jr.,6 Timothy C. Batten, Sr.,7 Wendy
L. Hagenau,8 et al. regarding the respective proceedings before their courts. Chronic criminality
and illegality orchestrated and coordinated by the illegal association-in-fact, the continuing
criminal enterprise, which is currently a conspiratorial malignant cancer in the federal courts and
prosecutors’ offices.
Mr. Garland, given the gravity and the seriousness of this matter, it would be a severe
negligent and dereliction of official duty if the DOJ refused to address the issues and allegations
in the federal courts and remained silent regarding the official flagrant prosecutorial conduct of
DOJ prosecutors and the Unindicted Co-conspirators during all phases of the Ware Cases.

on the merits regarding the enforcement of the Brady Court Orders’ commands, and on other issues and
claims. Ramos has conspired and colluded with the USAO and other politicians, which have criminally
influenced Ramos to conceal and cover-up the crimes committed by international Hobbs Act money
laundering criminal enterprise, Alpha Capital, AG (Anstalt), see SEC v. Honig, 18cv08175 (SDNY) (Ramos,
J.).

6
See Exhibit B, infra. Judge Thrash directly participated in Mr. Ware’s September 1, 2004, Atlanta, GA
kidnapping by the U.S. Marshals Service in an attempted armed robbery of Mr. Ware, while acting under
the color of law, for and on behalf of the 02cv2219 (SDNY) “Civil Plaintiffs,” admitted and confessed
unregistered broker-dealers and Section 2(a)(11) statutory underwriters legally ineligible for Rule 144(k)
exemption from Section 5 of the 1933 Securities Act strict-liability registration requirements. See SEC
Release 33-7190 n. 17 (1995).

7
Chief District Judge (NDGA) Batten has deliberately, intentionally, and in bad faith refused Mr. Ware all
First and Fifth Amendment right of access with respect to viewing, inspecting, and copying all judicial
records and documents in the alleged, purported, and unconfirmed 2008 In re Ulysses T. Ware (Evans, J.)
disbarment proceedings. Judge Batten, Judge Orinda D. Evans, former district clerk (NDGA) James N.
Hatten, and former Chief Judge Julie E. Carnes have knowingly and deliberately obstructed justice, and
committed a fraud on the federal courts by manufacturing or fabricating an illegal disbarment proceeding
conducted and orchestrated in criminal violation of due process of law while colluding and conspiring with
the State Bar of Georgia’s lawyers and agents, to wit: Paula Fredrick, Bill NeSmith (“Big Bill”), Jenny
Mittlemen, Jonathan Hewitt, William A. Myers, Adrienne Nash, Dan O’Sullivan, William P. Smith, III,
Carmen Rojas-Rafter, and others.

8
See AOC Federal Tort Claims Act filings in the Administrative Office of the U.S. Courts filed on June 6,
2021, for the crimes and obstruction of justice committed by Chief Bankruptcy Judge (NDGA) Wendy L.
Hagenau in her risible and criminal attempted cover-up and concealment regarding matter in the Chapter
11 bankruptcy case, In re Group Management Corp., 03-93031-mhm (BC NDGA), while knowingly
colluding and conspiring with the Atlanta, GA law firm Kilpatrick, Townsend, & Stockton, LLP and their
partners and former partners.

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Sincerely,

/s/ Ulysses T. Ware

______________________________________
Ulysses T. Ware
January 17, 2022

cc: Edward T.M. Garland

Manny Arora
Wendy L. Hagenau (for service on the District Clerk (NDGA) and the Chief Judge NDGA)
State Bar of Georgia, Office of the General Counsel
Administrative Office of the U.S. Courts c/o The Judicial Conference of the United States
Judicial Conference of the Second Circuit Court of Appeals
Marlon G. Kirton, Esq.
Damian Williams
District Judge Edgardo Ramos
District Judge Laura Taylor-Swain

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 Exhibit 15

1. Jeffrey R. Ragsdale;
2. David N. Kelley, Michael J. Garcia, Joon Kim, Preet Bharara, Jeffrey Berman, Audrey
Strauss, Damian Williams;
3. 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);
4. Edgardo Ramos, Laura Taylor-Swain, William H. Pauley, III, Robert W. Sweet, Michael H.
Dolinger, Andrew J. Peck, Ruby Krajick;
5. Timothy C. Batten, Sr., Thomas W. Thrash, Jr., Orinda D. Evans, Marvin H. Shoob, James
N. Hatten, Julie E. Carnes;
6. the State Bar of Georgia, Paula Fredrick, Bill NeSmith, Jenny Mittlemen, Adrienne Nash,
William A. Myers, Jonathan Hewitt, Dan O’Sullivan;
7. 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;
8. Michael Fitzpatrick, Thomas J. McCarthy, David Mulcahy, Cathleen Tyler;
9. Jeffrey B. Norris, Spencer C. Barasch, Kent J. Dawson, Steven Korotash, Steven Webster,
John C. Martin, Robert C. Hannan, Joan E. McKown, Michael McAuliffe, Lucy Kish;
10. Amalya L. Kearse, Robert D. Sack, Peter W. Hall, Robert A. Katzmann, Barbara S. Jones;

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 11. Alpha Capital, AG (Anstalt)9, Ari Rabinowitz, Edward M. Grushko10, Barbara R. Mittman,
LH Financial Services, Kenneth A. Zitter, Kilpatrick, Townsend, & Stockton, LLP, Dennis S.
Meir, John W. Mills, III, J. Henry Walker, IV;
12. Margaret H. Murphy, Joyce Bihary, C. Ray Mullins, Wendy L. Hagenau, Patricia Sinback,
M. Regina Thomas, (the “Bankruptcy Court Employees”), see the Administrative Office of
the U.S. Courts Federal Tort Claim Act filings submitted by Mr. Ware on June 6, 2021, via
certified mail receipt 70191120000222690451, regarding the crimes and negligence
committed by the Bankruptcy Court Employees, Edgardo Ramos, and others;
13. Jeremy Jones, Myron Williams, Carlton Epps, Elrico Sadler;
14. Kent J. Dawson;
15. James Olas, John Doe #1, John Doe #2, John Doe #311, U.S. Marshals Service (NDGA)

9The international money laundering criminal enterprise located in New York and managed by
LH Financial Services and unregistered investment advisor government 04cr1224 (SDNY) trial
witness Ari Rabinowitz. See Exhibits 3-1, 3-3, and 5, supra.

10
Alpha Capital, AG’s lawyer and convicted felon for conspiracy to commit securities fraud in (D.
NV).

11 James Olas, John Doe #1, John Doe #2, and John Doe #3, employees of the U.S. Marshals Service

(NDGA) on September 1, 2004, without a lawful and valid search warrant, arrest, or court order,
at approximately 2:00 pm, illegally entered the law office of Ulysses T. Ware, located at 101
Marietta St., Suite 1070, Atlanta, GA, 30303, with guns drawn, and threatened to murder Ulysses
T. Ware, terroristic threats of bodily harm, unless Mr. Ware, right then, issued bogus and
fraudulent Rule 144(k) legal opinions to the “Civil Plaintiffs,” unregistered broker-dealers and 15
USC 77b(a)(11) statutory underwriters of the securities of IVG Corp., a/k/a GPMT, named in
paragraph 8 of the United States v. Ware, 04cr1224 (SDNY) bogus, fraudulent, fabricated, and
moot indictment. See Exhibit A, attached hereto.

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 Exhibit A
Report of the USPO re: September 1, 2004, kidnapping of Ulysses T. Ware by U.S. Marshals
(NDGA), cf. Exhibit B, Official DOJ email of AUSA Alexander H. Southwell.

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 Exhibit B

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