DKT 81 (47.4R) All Writs Act Applciation and Proposed Order

Case 1:22-cv-03409-ER Document 81 Filed 08/17/22 Page 1 of 20
Filed on 8/17/2022 12:35:22 PM

22cv3409 (SDNY) (47.4R)
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
Wednesday, August 17, 2022
Re: (1) Petitioner’s request for urgent judicial assistance from the Court to obtain a
Bankruptcy Rule 5006 certified copy of the 03-93031 (BC NDGA) docket and Dkt. 11, 15, 16, and
28, (the “Unlawful RICO Pleadings”) in In re Group Management Corp., 03-93031 (BC NDGA) in
preparation for imminent show cause and sanctioning proceedings requested in Dkt. 79 for the
week of August 21, 2022; and (2) Proposed 28 USC 1651(a) All Writs Act Order, Exhibit A,
attached hereto.
Certificate of Service
Cc: Chief Bankruptcy Judge (NDGA) the Hon. Wendy L. Hagenau was served via email GANB-
Hagenau@ganb.uscourts.gov at 12:35:22 pm on August 17, 2022.
Page 1 of 20
(17) re GPMT’s declaration in support of 28 USC 1651(a) All Writs Act relief.
Table of Contents
I. .................................................................................................................................................................... 3
A. Application for urgent 28 USC 1651(a) All Writs Act relief. ............................................................ 3
B. Requested relief. .............................................................................................................................. 3
C. Memorandum of law. ...................................................................................................................... 4
1. The legal standard. ....................................................................................................................... 4
2. Discussion and analysis. ............................................................................................................... 5
C. Conclusion. ................................................................................................................................... 8
Distribution List .................................................................................................................................... 8
Exhibit 1: Declaration. .......................................................................................................................... 9
II. Exhibit A: Proposed Order ..................................................................................................................... 14
Final Order .............................................................................................................................................. 14
I. .......................................................................................................................................................... 14
II. ......................................................................................................................................................... 15
III. ........................................................................................................................................................ 16
IV ......................................................................................................................................................... 18
A. Relief granted. .................................................................................................................................... 18
Page 2 of 20
I.
A. Application for urgent 28 USC 1651(a) All Writs Act relief.

The Hon. Edgardo Ramos
U.S. District Court (SDNY)
500 Pearl St.
New York, NY 10007
Judge Ramos:
Petitioner, Ulysses T. Ware, is approaching the Court and requesting urgent 28 USC
1651(a) Al Writs Act judicial assistance from the Court to obtain judicial public records, a Bankr.
Rule 5006 certified copy of the docket, (the “Certified Docket”), and other 11 USC 107 judicial
public records, Dkt. 11, 15, 16, and 28, in In re Group Management Corp., 03-93031-mhm (BC
NDGA), (“93031”).1
B. Requested relief.
Accordingly, Petitioner seeks an Order from the Court pursuant to its 28 USC 1651(a)
authority in the All Writs Act directed to the U.S. Bankruptcy Court (NDGA) to not later than
1 The Atlanta, GA U.S. Bankruptcy Court (NDGA), despite three prior requests, has refused to
supply to Petitioner the requested Rule 5006 Certified Docket. See Dkt 80, attached exhibits of
Petitioner’s prior requests to obtain the Rule 5006 Certified Docket. The criminal delay and
obstruction of an investigation into the Bankruptcy Court and its employees’ criminal RICO
activities conducted before during, and after the fraudulent May 21, 2003, Dkt. 28, dismissal with
prejudice of Group Management’s Chapter 11 case. Done to aid, abet, and enable the further
RICO 18 USC 1961(6)(B) unlawful debt collection activities of unregistered broker-dealers, the
02cv2219 (SDNY) plaintiffs. See Dkt. 79 (22cv3409).
Page 3 of 20
Thursday, August 18, 2022, at 9:00 am, time of the essence, to file into the Court and serve
Petitioner with the same, a Bankr. Rule 5006 certified copy of the below judicial public records:
1. The complete docket in 93031 that contains “all activity” in the 93031
proceedings; and
2. Rule 5006 certified copies of Dkt. 11, Dkt. 15, Dkt. 16, and Dkt. 28.
Petitioner in support of the requested relief submits, (i) a letter brief of the applicable law
and (ii) his August 17, 2022, declaration regarding the events which have led to the requested
urgent relief from the Court, Exhibit 1, infra.
Petitioner is requesting that the Court enter the attached proposed Order, Ex. A, where
time is of the essence, and Petitioner is and will continue to suffer irreparable harm, by 9:00 AM
on Thursday, August 18, 2022.
C. Memorandum of law.
1. The legal standard.
The federal courts are authorized by statute, 28 USC 1651(a), the All Writs Act, to grant
the requested relief: Section (a) grants the federal court authority:
“The Supreme Court and all courts established by Act of Congress may issue all writs
necessary or appropriate in aid of their respective jurisdictions and agreeable to the
usages and principles of law.” (emphasis added).
Page 4 of 20
The Supreme Court in United States v. New York Telephone, 434 U.S. 159 (1977) (rev’d
the Court of Appeals (2d Cir.) and held that the All Writs Act authorized the District Court to issue
an order compelling the assistance of the telephone company was within the scope of the Act).2
The Court further explained the scope of the Act, and noted, Id. at 173: “ Indeed, [u]nless
appropriately confined by Congress, a federal court may avail itself of all auxiliary writs as aids
in the performance of its duties, when the use of such historic aids is calculated in its sound
judgment to achieve the ends of justice entrusted to it." (emphasis added) (internal quote and
citation omitted).
In Harris v. Nelson, 394 U. S. 286 (1969) the Court authorized the use of the Act in a
habeas corpus proceeding. The question in Harris v. Nelson, supra, was whether, despite the
absence of specific statutory authority, the District Court could issue a discovery order in
connection with a habeas corpus proceeding [cf., 22cv3409 (SDNY)] pending before it? The Court
answered in the affirmative and authorized the use of the Act to issue discovery orders not
specifically authorized by statute, but required by the court, in the interest of justice, to exercise
its jurisdiction over the habeas proceedings. Id. at 299.
2. Discussion and analysis.
Accordingly, the law is well-settled, the district court in this 28 USC 2241(a) actual
innocent habeas corpus proceeding is authorized by law and Supreme Court precedent to issue
2Id., at 172: “We conclude, however, that the order issued here against respondent was clearly
authorized by the All Writs Act, and was consistent with the intent of Congress.” (emphasis
added).
Page 5 of 20
an order to the U.S. Bankruptcy Court (NDGA), and order the Bankruptcy Court to immediately
perform its duties required by law, Bankruptcy Rule 5006, and certify the requested judicial public
records. Judicial public records which are necessary and required to adjudicate the merits of the
22cv3409 (SDNY) actual innocent habeas corpus claims.3
Bankruptcy Rule 50064 is not in dispute. The “clerk [M. Regina Thomas]” was required to
have certified the requested judicial public records [Dkt. 10, 15, 16, and 28, and the 93031 docket
containing “all activity” (see Rule 5003(a)) in 93031] requested by Petitioner. The law is not
debatable. That requested act, the performance of an official judicial transaction (see 18 USC
401(2)), was not done by the Bankruptcy Court upon request of Petitioner, see Exhibit 1, infra;
also see Dkt. 80.
Therefore, the record before the Court is not in dispute, the facts regarding this matter,
see Dkt. 1-2, Ex. 16, Dkt. 80 (08.16.22)(Petitioner’s request for urgent judicial relief) and the
attached Declaration, Exhibit 1, infra, are not in rational, non-frivolous dispute by the Bankruptcy
Court; and moreover, provide the undisputed and unposed factual basis for the Court to grant
the requested relief. Relief the Bankruptcy Court has a legal duty, and obligation, and is
required to perform by law, Rule 5006.
3See Dkt 1-2, Ex. 16 (22cv3409) for criminal obstruction of justice and violations of 18 USC 1519
and 18 US 2071 by the Atlanta, GA bankruptcy court’s judges and employees in refusing to
docket, file, and adjudicate Petitioner’s 2012 Rule 9024/60(d)(3) fraud on the court pleadings.
4Rule 5006. Certification of Copies of Papers.

The clerk shall issue a certified copy of the record of any proceeding in a case under the Code
or of any paper filed with the clerk on payment of any prescribed fee.
Page 6 of 20
The Court has jurisdiction over the 22cv3409 (SDNY) habeas corpus proceeding pursuant
to 28 USC 2241(a) and 28 USC 1331, federal question jurisdiction. The 93031 Chapter 11
bankruptcy proceedings are material to the resolution of the requested sanctioning and the show
cause proceedings requested that the Court conduct, see Dkt. 79; and for resolution of the merits
of the habeas claims concerning the 04cr1224 (SDNY) proceeding.5
Currently, there are credible factual and legal disputes with respect to Dkt. 11, 15, 16, and
28, the alleged May 21, 2003, Order (Murphy, J.),6 to wit:
1. Whether or not the alleged Order was actually signed by a U.S. Bankruptcy Court judge?7
2. And whether or not the Bankruptcy Court had Article III subject matter jurisdiction to have
entertained any request, and have granted any judicial relief to 15 USC 77b(a)(12)
unregistered broker-dealers attempting to collect on an illegal 18 USC 1961(6)(B)
unlawful criminal usury debt?8
5See Dkt. 1-2, Appx. 1 (Memorandum to KTS regarding the criminal conspiracy to commit
bankruptcy fraud, 18 USC 157, for its clients, the unregistered broker-dealers, the plaintiffs in
02cv2219 (SDNY) who lacked Article III standing to have appeared, Dkt. 11, in the 93031
bankruptcy court and requested judicial relief, Dkt. 15, 16, and have the Court grant judicial relief,
Dkt. 28, allegedly).
6According to the 93031 docket, which the Bankruptcy Court has refused to certify as required
by Bankr. Rule 5006, see Dkt. 80 (22cv3409), an alleged Order, Dkt. 28, Murphy, J., (03-93031)
was entered on May 21, 2003, that purported to “dismiss [the 93031 Chapter 11] with prejudice”
on motion, Dkt. 15, 16, filed by KTS on behalf of its unregistered broker-dealer clients, attempting
to conduct RICO 18 USC 1961(6)(B) unlawful debt collection activities against GPMT regarding
the null and void ab initio February 2001 criminal usury debt, cf., Adar Bays, Id.
7 See Exhibit 1, infra, Declaration Facts 7 and 8.
8 See Exhibit 1, infra, Declaration of GPMT and Ulysses T. Ware, at Facts 7 and 8.
Page 7 of 20
C. Conclusion.
The immediate acquisition and obtainment of the requested certified judicial public records
from the Bankruptcy Court (NDGA) will enable the Court and Petitioner to assess whether or not
a fraud and other felony criminal offenses were committed on the Bankruptcy Court, GPMT, and
Petitioner by KTS, its clients, and the Bankruptcy Court judges and employees; which materially
affect the resolution of the actual innocent habeas corpus claims in 22cv3409. Thus, a compelling
need and justification exist for the Court to grant the requested relief.
Respectfully submitted by:
Ulysses T. Ware
/s/ Ulysses T. Ware
August 17, 2022.
Distribution List
The individuals listed below were served via email with a copy of this pleading on August
17, 2022.
cc: Office of the United States Attorney (SDNY)

Office of the Chief District Judge (SDNY)
District Judge Edgardo Ramos (SDNY)
Office of the U.S. Attorney General
Office of the Chief Bankruptcy Judge (NDGA)
The State Bar of Georgia
Office of the United States Attorney (EDNY)
U.S. Bureau of Prisons (Warden, MDC, Brooklyn, NY)
The Wall Street Journal
The New York Times
J. Henry Walker, IV
John W. Mills, III
Page 8 of 20
Edward T. M. Garland
The Securities and Exchange Commission
Sims W. Gordon, Jr.
Thomas J. Leghorn
Marlon G. Kirton
Exhibit 1: Declaration.
Declaration of Group Management and Ulysses T. Ware made by and through

Ulysses T. Ware, its legal representative, both 11 USC 1109(b) statutory parties
in interest in In re Group Management Corp., 03-93031-mhm (BC NDGA).
State of New York

Kings County
City of Brooklyn
August 17, 2022
I, Ulysses T. Ware, hereby this 17th day of August 2022, in Brooklyn, NY, being of the age
of majority, under oath, having personal knowledge of the facts, pursuant to the penalty of
perjury, and 28 USC 1746, on behalf of Group Management, the Chapter 11 Debtor in 03-93031,
make this declaration of fact and state the following Facts, to wit:
1. Group Management Corp.,9 (“GPMT”), currently is an unincorporated business entity
managed by Ulysses T. Ware, located in Brooklyn, NY.
2. GPMT is the Chapter 11 Debtor in In re Group Management Corp., 03-93031-mhm (BC
NDGA), (“93031”).
3. On April 10, 2003, Dkt. 11, Dennis S. Meir appeared in the 93031 Chapter 11 case on
behalf of the plaintiffs in 02cv2219 (SDNY), alleged creditors of GPMT regarding a criminal
9Group Management Corp. at the time of the Chapter 11 in 2003 was a publicly-traded company
on the OTC bulletin board under the symbol, (OTCBB-GPMT).
Page 9 of 20
usury loan in the amount of $1.1M which violated N.Y. Penal Law, section 190.40, the
criminal usury law, a class E felony.10
4. On April 11, 2003, Dkt. 15 (motion to dismiss Chapter 11) and Dkt. 16 (brief in support of
the motion to dismiss Chapter 11), were filed by Dennis S. Meir on behalf of his clients in
the 903031 Chapter 11 case.
5. Dennis S. Meir, John W. Mills, III, and Kilpatrick, Townsend, & Stockton, LLP, jointly,
(“KTS”), pleadings, Dkt. 11, 15, and 16, (the “Unlawful RICO Pleadings”), filed in the
93031 Chapter 11 case constituted RICO unlawful debt collection activities which violated
18 USC 1961(6)(B), a RICO felony criminal offense.
6. The Unlawful RICO Pleadings violated Bankr. Rule 9011 (b)(1-4), 28 USC 1927, 18 USC
1961(6)(B) and cost Ulysses T. Ware, GPMT, and its shareholders injuries, harms, and
damages estimated at +$5.225 billion.
7. On May 21, 2003, Dkt. 28, an Order was allegedly entered by the Bankruptcy Court that
dismissed GPMT’s Chapter 11 with “prejudice” and was allegedly actually signed by a
U.S. Bankruptcy Court judge, Margaret H. Murphy.11
8. GPMT has received credible evidence that the May 21, 2003, Dkt. 28, alleged Order, was
not actually signed by a U.S. Bankruptcy Court judge, i.e., Margaret H Murphy; and is
therefore null and void ab initio.
10 See March 15, 2022, opinion in Adar Bays, LLC v. GeneSys ID, Inc., 28 F.4d 379 (2d Cir. 2022)
(held that KTS’s clients’ loan documents, GPMT’s Notes and Subscription Agreement, were illegal,
criminal usurious contracts, unenforceable, and violated N.Y. Penal Law, section 190.40, the
criminal usury law, a class E felony).
11 GPMT’s investigators traveled to Atlanta, GA, and interviewed persons having knowledge of
the 93031 proceedings and were informed that the Bankruptcy Court (NDGA) is refusing to certify
the requested documents because the Order, Dkt. 28, “is counterfeit … they [M. Regina Thomas
and Wendy L. Hagenau] know it is fake … Judge Murphy did not sign that Order. Regina is not
going to certify the docket because she, Pat [Sinback], Judge Murphy, and Judge Mullins
destroyed Mr. Ware’s [2012 Rule 9024/60(d)(3) fraud on the court] documents submitted to the
court as a favor to Kilpatrick [Townsend, & Stockton, LLP] … they and [KTS] are worried that Mr.
Ware has found out the crimes they committed … they are really worried ….” (emphasis added).
Page 10 of 20
9. On August 16, 2022, Dkt. 195 (03-93031), GPMT filed its third request to the Atlanta, GA
U.S. Bankruptcy Court seeking to obtain Bankr. Rule 5006 certified copies of the 93031
docket; GPMT’s two previous requests to obtain Rule 5006 certified documents had been
ignored by the Bankruptcy Court without explanation or reason.
10. On August 16, 2022, at 2:40 pm, GPMT filed a request with the Bankruptcy Court
(Hagenau, C.J.), to obtain Rule 5006 certified copies of Dennis S. Meir’s pleadings, Dkt. 11,
15, and 16. No response was received from the Bankruptcy Court by 5:00 pm on August
16, 2022.
11. GPMT has exhausted all prescribed legal remedies to obtain the requested certified
documents from the Bankruptcy Court (NDGA).
12. The Bankruptcy Court is required by law, Bankruptcy Rule 5006, to certify all judicial court
records upon request by GPMT or Petitioner.
13. GPMT and Ulysses T. Ware are in urgent need of certified copies of the requested
Bankruptcy Court judicial public records, Dkt. 11, 15, 16, 28, and certified copy of the
93031 docket, jointly, (the “Judicial Public Records”), see 11 USC 107, in another pending
judicial proceeding, Ware v. United States, Merrick B. Garland, Edgardo Ramos, and
Laura Taylor-Swain, 22cv3409 (SDNY), 28 USC 2241(a), actual innocent habeas corpus
proceeding, (the “Habeas Proceeding”).12
14. GPMT and Ulysses T. Ware, 11 USC 1109(b) statutory parties in interest in the 93031
Chapter 11 case, are authorized by federal law to “raise” “and be heard” regarding 18 USC
1519 and 207113 criminal violations by M. Regina Thomas, Patricia Sinback, Margaret H.
12Sanctioning and show cause proceedings in the 22cv3409 Habeas Corpus case have been
requested for the week of August 21, 2022, pertaining to the Atlanta, GA Bankruptcy Court, M.
Regina Thomas, Wendy L. Hagenau, KTS, and others involved in the criminal 93031 proceedings.
See Dkt. 79 (22cv3409).
13M. Regina Thomas, the Bankruptcy Clerk, and Wendy L. Hagenau, the Chief Bankruptcy Judge,
pursuant to Bankr Rules 5003(a) and 5006 authenticate and must account for every judicial
record submitted to the Court regarding the 93031 proceedings; and if they cannot, they have
violated 18 USC 1519 and 2071.
Page 11 of 20
Murphy, Joyce Bihary, Wendy L. Hagenau, Dennis S. Meir, John W. Mills, III, J. Henry
Walker, IV, the Atlanta, GA Bankruptcy Court, Kenneth A. Zitter, Ari Rabinowitz, Leonard
B. Sand, Edgardo Ramos, Laura Taylor-Swain, and others involved, directly and/or
indirectly, in the 93031 Chapter 11.
Signed this 17th day of August 2022, in Brooklyn, NY under oath, subject to the penalty of
perjury, 28 USC 1746, having personal knowledge of the facts.
For: Group Management
By: Ulysses T. Ware
/s/ Ulysses T. Ware
August 17, 2022
Brooklyn, NY
END OF DECLARATION
Page 12 of 20
End of
document
Page 13 of 20
II. Exhibit A: Proposed Order
In the United States District Court

For the Southern District of New York
---------------------------------------------------------------- :
Ulysses T. Ware, :
Petitioner :
: FINAL ORDER
: Case No. 22cv3409
v. :
:
United States, Merrick B. Garland, Edgardo :
Ramos, and Laura Taylor-Swain, :
Defendants. :
--------------------------------------------------------------- :
Final Order
I.
The Court on August 16, 2022, received from Petitioner, Dkt. 80 (request for urgent
judicial relief)14 which indicated that Petitioner had sought on “three” prior instances to obtain
Bankruptcy Court Rule 5006 certified documents, to wit, Dkt. 11, 15, 16, [28], and a certified copy
of the docket in In re Group Management Corp., 03-93031-mhm (BC NDGA), (“93031”).
According to Petitioner’s pleading, Dkt. 80, the Bankruptcy Court had refused to certify the
requested “judicial public records” as required by Rule 5006.
14Petitioner sought judicial relief from the Court pursuant to its supervisory authority or its
authority under 28 USC 1651(a), the All Writs Act.
Page 14 of 20
II.
The Court finds that Bankruptcy Court Rule 5006 requires the Bankruptcy Court (NDGA)
to certify, upon request, and payment of the required fee, the documents Petitioner requested
to be certified (Dkt. 11, 15, 16, 28, and the 93031 docket).
The Court further finds that it has 28 USC 2241(a) and 28 USC 1331 subject matter
jurisdiction over the 22cv3409 (SDNY) actual innocent habeas corpus proceeding.
The Court further finds that it is authorized by an Act of Congress, 28 USC 1651(a), the All
Writs Act, and further authorized by Supreme Court precedent, Harris v. Nelson, 394 U. S. 286
(1969) to grant Petitioner’s requested relief if “necessary and proper” for the Court to adjudicate
the merits of the actual innocent habeas corpus claims.
The Court finds as a matter of law and fact, that it is necessary and proper for the Court
to grant Petitioner the requested relief due to the fact the issues raised by Petitioner, an 11 USC
1109(b) statutory party in interest in the 93031 Chapter 11 case, raise matters that affect the
integrity, credibility, public perception, and the fair, impartial, and unbiased administration of
justice in the federal court:
(i) whether or not the 93031 Bankruptcy Court (NDGA) possessed Article III subject
matter jurisdiction on May 21, 2003, Dkt. 28, to have granted the 02cv2219 (SDNY)
plaintiffs any judicial relief?;
Page 15 of 20
(ii) whether or not the 02cv2219 (SDNY) plaintiffs on April 10, 2003, Dkt. 11, and April 11,
2003, Dkt. 15, and 16, possessed Article III standing to have appeared in the 93031
Chapter 11 and requested any judicial relief?;
(iii) whether or not the Bankruptcy Court’s judges and employees in 2012 continuing to
the present committed a conspiracy to obstruct justice, conspiracy to commit a fraud
on the court, and conspiracy to aid, abet, and enable Atlanta, GA law firm and its
partners, Kilpatrick, Townsend, & Stockton, LLP, (“KTS”), conspire with the Bankruptcy
Court (NDGA) to commit a conspiracy to commit bankruptcy fraud, 18 USC 157 and
other crimes?
III.
Furthermore, this Court will take judicial notice of binding circuit precedent entered on
March 15, 2022, in Adar Bays, LLC v. GeneSYS, Inc., 28 F.4d 379 (2d Cir. 2022). The Court finds
that Adar Bays’ substantive holding, and analysis applies to the subject matter of the 02cv2219
(SDNY), 03-93031 (BC NDGA), and 04cr1224 (SDNY) proceedings—that is, GPMT’s Convertible
Notes (GX 1-4) and its Subscription Agreement (GX-5),15 jointly, (the “Illegal Contracts”).
The Court finds that Adar Bays’ holding applied to GX 1-4 and GX-5, the Illegal Contracts,
ipso facto, as a matter of law and fact:
(i) rendered the 02cv2219 (SDNY) proceedings null and void ab initio;
15 “GX” shall refer to the government trial exhibits entered in U.S. v. Ware, 04cr1224 (SDNY).
Page 16 of 20
(ii) rendered the 02cv2219 (SDNY) plaintiffs’ Article III standing to have appeared
in 93031 void ab initio, and
(iii) rendered the 93031 Bankruptcy Court’s May 21, 2003, Dkt. 28, alleged Order
(Murphy, J.), null and void ab initio for lack of Article III subject matter
jurisdiction;
(iv) rendered the U.S. v. Ware, 04cr1224 (SDNY) proceedings, orders, and
judgments null and void ab initio and moot.
The Court further finds as a matter of law and fact, the December 20, 2007, Dkt. 90,
voluntary, Fed. R. Civ. P. Rule 41(a)(2) final judgment entered in 02cv2219 (SDNY) (Sand, J.), after
the statute of limitation had run on all claims, “annulled” and vitiated all orders, judgments, and
proceedings therein 02cv2219 (SDNY), and by necessary implication and extension, rendered all
orders, judgments, and proceedings in 93031, and 04cr1224 (SDNY) that depended in whole
and/or in part on the 02cv2219 (SDNY) orders, judgment, and proceedings also annulled, vitiated,
abrogated, vacated, and void.16
The Court finds as fact that the Atlanta, GA Bankruptcy Court was and is required by
Bankruptcy Rule 5006 to certify all judicial public records in the 93031 proceedings.
The Court finds as fact that Rule 5003(a) required the Bankruptcy Court to keep and
maintain the 93031 docket and docket “all activity” in 93031.
16
See A.B. Dick Co. v Marr, 197 F.2d 498, 501-02 (2d Cir. 1952).
Page 17 of 20
The Court finds as fact Petitioner submitted Rule 9024/60(d)(3) fraud on the court
pleading to the Bankruptcy Court in 2012 that were required to have been docketed pursuant to
Rule 5003(a) but were not docketed or filed into the 93031 record.17
The Court finds as fact the Bankruptcy Court has not certified as requested and required
by Rule 5006, Petitioner’s requested judicial public records.
IV
The Court finds based on its finding in Sections I-III, supra, the Court is authorized in law
and in fact to grant Petitioner the requested relief.
A. Relief granted.
WHEREFORE, IT IS ADJUDGED, DECREED, AND ORDERED the Court shall grant the
following relief:
1. IT IS ORDERED THAT, not later than August 18, 2022, at 9:00 AM, time of the essence,
the Bankruptcy Court (NDGA), through counsel, shall file in this Court and serve a copy
of the same on Petitioner a response and any objections to the findings made herein.
2. IT IS ORDERED THAT, not later than August 18, 2022, at 12:00 noon, time of the
essence, Petitioner shall file in this Court any reply to any responsive filing made by
the Bankruptcy Court and serve a copy of any reply on the Bankruptcy Court.
17See Dkt. 1-2, Ex. 16 (Petitioner’s exhibits of communications from the Atlanta, GA Bankruptcy
Court’s judges and employees refusing to docket his fraud on the court pleadings), cf, Dkt. 1-2,
Appx. 6 (for more factual proof “activity” in 93031 was not properly filed or docketed as required
by Rule 5003(a)).
Page 18 of 20
3. IT IS ORDERED THAT, if the Bankruptcy Court does not file any response in opposition
to the findings made herein by August 18, 2022, at 9:00 AM, time of the essence, the
Court shall GRANT the relief requested in Dkt. 80, and;
4. WHEREFORE, IT IS AND SHALL BE ORDERED that the Bankruptcy Court (NDGA) shall
not later than 9:01 AM on August 18, 2022, time of the essence, file into the Court
and serve the same of Petitioner certified copies of Dkt. 11, Dkt. 15, Dkt. 16, Dkt. 28,
and a certified copy of the 93031 docket, (the “93031 Certified Judicial Public
Records”).
5. IT IS ORDERED THAT if the Bankruptcy Court (NDGA) does not comply with the written
commands in this ORDER, the Court shall ORDER the Bankruptcy Court (NDGA), M.
Regina Thomas, and Wendy L. Hagenau, and counsel, and Petitioner to appear before
the Court on Monday, August 22, 2022, at _______ AM/PM in courtroom _______,
located at ___________________________________________, New York, NY 10007
to show cause why each shall not be held in civil and criminal contempt of this ORDER;
and civilly fined, and/or civilly incarcerated until full compliance is made regarding this
ORDER’s commands.
WHEREFORE, this 17th day of August 2022, the Court GRANTS Petitioner the relief
requested in Dkt. 80, and further relief herein.
SO ORDERED THIS 17th day of August 2022.

_______________________________
District Judge
Page 19 of 20
End of document
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DKT 81 (47.4R) All Writs Act Applciation and Proposed Order

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Case 1:22-cv-03409-ER Document 81 Filed 08/17/22 Page 1 of 20

Filed on 8/17/2022 12:35:22 PM

A. Application for urgent 28 USC 1651(a) All Writs Act relief.

Wednesday, August 17, 2022

urgent relief from the Court, Exhibit 1, infra.

on Thursday, August 18, 2022.

1. The legal standard.

its jurisdiction over the habeas proceedings. Id. at 299.

2. Discussion and analysis.

22cv3409 (SDNY) actual innocent habeas corpus claims.3

also see Dkt. 80.

required to perform by law, Rule 5006.

4Rule 5006. Certification of Copies of Papers.

of the habeas claims concerning the 04cr1224 (SDNY) proceeding.5

unregistered broker-dealers attempting to collect on an illegal 18 USC 1961(6)(B)

unlawful criminal usury debt?8

Respectfully submitted by:

/s/ Ulysses T. Ware

August 17, 2022.

cc: Office of the United States Attorney (SDNY)

Declaration of Group Management and Ulysses T. Ware made by and through

State of New York

For: Group Management

By: Ulysses T. Ware

/s/ Ulysses T. Ware

August 17, 2022

II. Exhibit A: Proposed Order

In the United States District Court

of the docket in In re Group Management Corp., 03-93031-mhm (BC NDGA), (“93031”).

requested “judicial public records” as required by Rule 5006.

the merits of the actual innocent habeas corpus claims.

justice in the federal court:

plaintiffs any judicial relief?;

Chapter 11 and requested any judicial relief?;

the present committed a conspiracy to obstruct justice, conspiracy to commit a fraud

ipso facto, as a matter of law and fact:

in 93031 void ab initio, and

judgments null and void ab initio and moot.

abrogated, vacated, and void.16

maintain the 93031 docket and docket “all activity” in 93031.

by Rule 5006, Petitioner’s requested judicial public records.

and in fact to grant Petitioner the requested relief.

Court shall GRANT the relief requested in Dkt. 80, and;

located at ___________________________________________, New York, NY 10007

requested in Dkt. 80, and further relief herein.

SO ORDERED THIS 17th day of August 2022.

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