Ex. 8 Re 04.30.22 (05) Re Inquiry To Thomas A. Leghorn Regarding Legal Services Provided To Alpha, Et Al

Exhibit 8
April 30, 2022, Demand on Thomas A. Leghorn, Esq., an

officer of the court, and his clients, Lawrence B.
Mandala, Esq. and Baker & McKenzie, LLP.
Page 1 of 11
Saturday, April 30, 2022
(05) Re: Inquiry regarding Legal services provided to Alpha Capital, AG (Anstalt), et al.
22cv3409 (SDNY) (05)
United States District Court
For the Southern District of New York
Ware v. USA, et al.
___________
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
April 30, 2022
________________
Ulysses T. Ware’s and Group Management’s 04.30.22

Last and Final Brady Demand on Thomas A. Leghorn,
Baker & McKenzie, LLP, and Lawrence B. Mandala, Esq.
before an Emergency Judicial Intervention is Sought.
_____________
Counsel for the government, Damian Williams was

served at damian.williams@usdoj.gov on 04.30.22.
Page 2 of 11
The Office of Ulysses T. Ware
123 Linden Blvd.
Ste 9-L
Brooklyn, NY 11226
(718) 844-1260
utware007@gmail.com
URGENT
TIME OF THE ESSENCE
April 30, 2022
4/30/2022 1:42:46 PM
Via email: tleghorn@londonfischer.com
Thomas A. Leghorn, Esq.
London, Fischer, LLP
59 Maiden Lane
New York, NY 10038
Re: Group Management and Ulysses T. Ware

U.S. v. Ware, 04cr1224 (SDNY), Alpha Capital, AG, et al. v. Group Management Corp.,
et al., 02cv2219 (SDNY).
Your file: 810.611
Mr. Leghorn:
I.
Mr. Ware, individually, and as the legal representative of Group Management,
(OTCBB:GPMT), writes to inquire regarding the following issues relevant to your clients Baker &
McKenzie, LLP, and Lawrence B. Mandala, jointly, (“Baker”). As you know GPMT retained Baker
Page 3 of 11
to advise it on the legality of the 2001 $1.1 million criminal usury loan and illegal debt arranged
and facilitated by Alpha Capital, AG, et al.,1 (the “Illegal Transaction”).
You are also aware that the Illegal Transaction was null and void ab initio because the
purported lenders were (i) accordingly to FINRA, see Exhibit 1, unregistered broker-dealers
operating in criminal violation of U.S. securities law, 15 USC 78o(a)(1); charged a criminal usury
rate of interest in the illegal contracts—that is, government trial exhibit in United States v. Ware,
04cr1224 (SDNY), GX 1-4 and GX-5, (the “Illegal Contracts”), that violated N.Y. Penal Law,
§190.40, the criminal usury law,2 a class E felony in New York state; moreover, the Illegal
Contracts and the Illegal Transaction, violated U.S. felony racketeering laws, 18 USC 1961(6)(A).3
II.
We write to inquire: Whether or not Baker since beginning on or about February 1, 2001,
and continuing to the present, April 30, 2022, was ever retained and/or engaged and ever
provided any legal services, whatsoever, to the following individuals or entities listed in Table 1
1
Alpha Capital, AG (Anstalt) and its affiliates, NYC-based unregistered investment advisor, see SEC v.
Honig, 18cv08175 (SDNY) (Ramos, J.), LH Financial Service, are an international Hobbs Act extortion, loan-
sharking, and money laundering continuing criminal enterprise.
https://www.sec.gov/litigation/litreleases/2018/lr24262.htm, cf. Exhibits 2 and 3, attached herein.
2
See Adar Bays, LLC v. Genesys ID, Inc, 18-3023cv (2d Cir.)(March 15, 2022).
3
The null and void ab initio Illegal Transaction constituted loan-sharking, extortion, securities fraud, mail
and wire frauds, conspiracy, money laundering, and racketeering to commit money laundering and
extortion by the collection of an illegal debt that charged a criminal usury rate of interest.
Page 4 of 11
below? And (2) whether or not Baker ever invested in any transaction(s) arranged or facilitated
in any way, whatsoever, by any individual or entity named in the below table?
We further write (3) to inquire whether or not Baker has reported the Illegal Transaction
to (i) the Securities and Exchange Commission, (ii) FINRA, (iii) the New York State Attorney
General, and/or (iv) the U.S. Attorneys (SDNY, EDNY)? If so please provide all records of the
reporting of a crime as required by the ABA and NY State Bar’s Codes of Conduct for Lawyers. If
not, please explain why you and Baker have not reported the criminal conduct of Alpha, et al. to
law enforcement authorities given your duty of complete candor to the courts and duty of loyalty
and trust owed to Baker’s client GPMT.
Mr. Leghorn, given what appear to have been covert acts of collusion and conspiracy
between Baker and Alpha, et al., criminal offenses, there is a very strong inference that you and
London, Fischer, LLP are currently attempting to facilitate and obstruct a criminal investigation
into the crimes committed by Alpha, et al. by your and your clients’ adamant refusal to provide
GPMT with all client records and files that pertained to the Illegal Transaction.
III.
Accordingly, PLEASE BE ADVISED AND TAKE NOTICE:
Ulysses T. Ware and GPMT, the client, hereby this 30th day of April 2022, make this
LAST AND FINAL DEMAND FOR PRODUCTION OF ALL CLIENT RECORDS OF GPMT THAT PERTAIN TO
THE ILLEGAL TRANSACTION IN THE POSSESSION OF BAKER AND/OR THOMAS A. LEGHORN
Page 5 of 11
Mr. Leghorn, GPMT, and Ulysses T. Ware will forthwith bring to use all available and
necessary legal processes to obtain the client records and files in the possession of Baker that
pertains to the Illegal Transaction unless Baker produces the client files not later than 6:00 pm
on April 30, 2022, time of the essence.4
Sincerely,
/s/ Ulysses T. Ware, personally and for Group Management

4/30/2022 1:42:08 PM
4
Any portion of the client files that can be construed or interpreted as Brady exculpatory or impeachment
material is covered by and within the scope of the August 10, 2007, Dkt. 32 (Sweet, J.) (04cr1224) (SDNY)
Brady court order, and the May 19, 2006, Dkt 17, (Pauley, J.) Brady order entered in 05cr1115 (SDNY),
jointly, (the “Brady Court Orders”). Accordingly, Mr. Ware will utilize all enforcement processes and
procedures—that is, civil and Rule 42 criminal contempt show cause processes to secure enforcement
of the Brady Court Orders’ written commands.
Page 6 of 11
Table 1
Alpha Capital, AG (Anstalt), Edward M. Grushko, a Barbara R. Mittman

see Exhibits 2 and 3, attached convicted felon for securities
herein. fraud
Union Atlantic Capital, LLC, Andrew Reckles Ari Rabinowitz, unregistered
unregistered investment broker-dealer, and investment
advisor and unregistered advisor
broker-dealer.
LH Financial Services Stonestreet, L.P. Markham Holdings, Ltd.
Amro International, S.A. Rhino Advisors Thomas Badian
Andreas Badian Leonard B. Sand Edgardo Ramos, Edgardo

Ramos, see Exhibits 2 and 3,
attached hereto
Barbara S. Jones Robert A. Katzmann Peter W. Hall
Celeste Group William H. Pauley, III Robert W. Sweet
LaShann DeArcy Hall Damian Williams Charles E. Schumer
David N. Kelley, see Exhibit 3, Michael J. Garcia Preet Bharara

herein
Audrey Strauss Dechert, LLP, see Exhibit 3 Amalya L. Kearse
herein
Robert D. Sack Gibson, Dunn, & Crutcher, LLP Simpson, Thatcher, &
Bartlett, LLP
Michael F. Bachner Alexander H. Southwell Robert Schumer
Breon Peace Joon Kim Cleary, Gottlieb, Steen, &

Hamilton, LLP
Maria E. Douvas Nicholas S. Goldin RBC
Sarah E. Paul Daniel Gitner Merrick B. Garland
Wendy L. Hagenau Dennis S. Meir John W. Mills, III
Page 7 of 11
J. Henry Walker, IV Kilpatrick, Townsend, & Marlon G. Kirton
Stockton, LLP
Edward T.M. Garland Manibur S. Arora Donald F. Samuel
David Levitt Michael Fitzpatrick David Mulcahy
Thomas J. McCarthy Paul, Weiss, et al., LLP
Page 8 of 11
Exhibit 1
Page 9 of 11
Exhibit 2
Page 10 of 11
Exhibit 3
Former U.S. Attorney (SDNY), David N. Kelley, currently a partner in Dechert, LLP, on November
17, 2004, knowingly and willfully to obstruct justice procured a bogus and fraudulent indictment
in U.S. v. Ware, 04cr1224 (SDNY) on behalf of Alpha Capital, AG, et al. to protect the money
laundering RICO criminal enterprise, and now Kelly is making money from Dechert’s
representation of Alpha Capital in a case before District Judge Edgardo Ramos (SDNY).
Page 11 of 11

Ex. 8 Re 04.30.22 (05) Re Inquiry To Thomas A. Leghorn Regarding Legal Services Provided To Alpha, Et Al

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Ex. 8 Re 04.30.22 (05) Re Inquiry To Thomas A. Leghorn Regarding Legal Services Provided To Alpha, Et Al

Uploaded by

Copyright:

Available Formats

Exhibit 8

April 30, 2022, Demand on Thomas A. Leghorn, Esq., an

Ulysses T. Ware’s and Group Management’s 04.30.22

Counsel for the government, Damian Williams was

Re: Group Management and Ulysses T. Ware

and facilitated by Alpha Capital, AG, et al.,1 (the “Illegal Transaction”).

and trust owed to Baker’s client GPMT.

Accordingly, PLEASE BE ADVISED AND TAKE NOTICE:

on April 30, 2022, time of the essence.4

/s/ Ulysses T. Ware, personally and for Group Management

Alpha Capital, AG (Anstalt), Edward M. Grushko, a Barbara R. Mittman

Amro International, S.A. Rhino Advisors Thomas Badian

Andreas Badian Leonard B. Sand Edgardo Ramos, Edgardo

Celeste Group William H. Pauley, III Robert W. Sweet

LaShann DeArcy Hall Damian Williams Charles E. Schumer

David N. Kelley, see Exhibit 3, Michael J. Garcia Preet Bharara

Breon Peace Joon Kim Cleary, Gottlieb, Steen, &

Sarah E. Paul Daniel Gitner Merrick B. Garland

Wendy L. Hagenau Dennis S. Meir John W. Mills, III

Edward T.M. Garland Manibur S. Arora Donald F. Samuel

David Levitt Michael Fitzpatrick David Mulcahy

Thomas J. McCarthy Paul, Weiss, et al., LLP

You might also like