Docket NO: 22cv1531 (LDH)(LB)

Submitted by:
/s/ Ulysses T. Ware
_____________________________
Ulysses T. Ware, (the “Petitioner” or “Racketeering Victim”)
123 Linden Blvd., Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
April 13, 2022

In the United States District Court

For the Eastern District of New York
___________________________________
Ulysses T. Ware,
Petitioner,

v.
The United States of America (habeas corpus respondent) by and through Merrick B. Garland,
Lisa O. Monaco, Vanita Gupta, Damian Williams, Margaret M. Garnett, Daniel Gitner, and Audrey
Strauss, jointly, (the “DOJ Respondents” or “Government Lawyers”), in their official, individual,
and personal capacities; Edgardo Ramos, individually and personally; and Laura Taylor-Swain,
individually and personally, jointly (the “Federal Judges”), collectively with the DOJ Respondents,
Respondents.
____________________________________
Actual Innocent Supplemental Claim #15, Supplemental Exhibit # 7
Confirmation of LaShann DeArcy Hall undisclosed connection and relationship to
former AUSA Alexander H. Southwell’s and Gibson, Dunn, & Crutcher, LLP (her
former employer). Evidence of actual bias, prejudice, and a conflict of interest.

Breon Peace was served at Breon.peace@doj.gov and Nina C. Gupta

was served at nina.gupta@doj.gov with a copy of this pleading.
Page 1 of 4
Wednesday, April 13, 2022
Re: Supplemental Exhibit #7 to AIS Claim 15 (Conspiracy to obstruct justice of LaShann DeArcy
Hall, et al.)
Page 2 of 4
Wednesday, April 13, 2022
Re: Supplemental Exhibit #7 to AIS Claim 15 (Conspiracy to obstruct justice of LaShann DeArcy
Hall, et al.)
Former AUSA Alexander H. Hall is currently employed at
Gibson, Dunn, & Crutcher, LLP started in June 2007.
Southwell and Hall both are currently in civil and 18 USC 410(3)

criminal contempt of the Brady Court Orders, Dkt. 1, Exhibits 2 and 3.

Southwell and Judge Hall both are charged in the habeas petition with civil and 18 USC
401(3) criminal contempt of Brady Court Orders, Dkt. 1, Exhibits 2 and 3, felony criminal offenses;
high crimes and misdemeanors, impeachable offenses for Judge Hall, and violations of the Codes
of Conduct for Federal Judges, i.e., criminal judicial misconduct.

Page 3 of 4
Wednesday, April 13, 2022
Re: Supplemental Exhibit #7 to AIS Claim 15 (Conspiracy to obstruct justice of LaShann DeArcy
Hall, et al.)
 LaShann DeArcy Hall’s Employment History
LaShann DeArcy Hall’s employment history was taken from her sworn
Senate Judiciary Committee disclosures.

Hall concealed, covered up, and hide the fact she is personally and professionally affiliated
with Southwell and Gibson, Dunn; which affiliation required her to recuse herself from the
22cv1531(EDNY) habeas corpus proceedings required by federal law, 28 USC 455(a) and 455(b),
and the Constitution.

Page 4 of 4
Wednesday, April 13, 2022
Re: Supplemental Exhibit #7 to AIS Claim 15 (Conspiracy to obstruct justice of LaShann DeArcy
Hall, et al.)