Damian Williams, the new U.S. Attorney in Manhattan, faces his first major test: “To be or not to be is the question?”
Mr. Damian Williams
Office of the United States Attorney
For the Southern District of New York
1 St. Andrews Plaza
New York, NY 10007
RE: Application for show cause order for civil incarceration.
RE: United States v. Ware, 04cr1224 (SDNY), Dkt. 32, August 10, 2007, Brady court Order (Sweet, J.) and United States v. Ware, 05cr1115 (SDNY), May 19, 2007, Dkt. 17, Tr. 5–9, Brady court order, (Pauley, J.), jointly, (the “Brady Court Orders”).
Mr. Williams:
Mr. Ware writes to you in your official, personal, and individual capacities as an officer of the court, as the announced United States Attorney for the Southern District of New York, (the “USAO”); and in that capacity having the legal and constitutional duty and obligations imposed by the above Brady Court Orders, Local Rules District Court (SDNY) 1.5(b)(5), and DOJ Rules of Professional Conduct.
Mr. Williams, perhaps you have been deliberately misled or misinformed regarding your absolute legal duties as a federal prosecutor with respect to the above Brady Court Orders; or on the other hand, perhaps you are fully aware of your duty but have decided to take your chances with the SDNY federal courts’ impotence and collusion with your office in risibly attempting to cover up and conceal the indisputable facts regarding the extortion and money laundering committed by the international money laundering Hobbs Act criminal enterprise Alpha Capital, AG (Anstalt), LH Financial Services, and Ari Rabinowitz.
Nevertheless, currently, you have legal jeopardy in your personal capacity regarding civil and criminal contempt, willful resistance, and disobedience, of the Brady Court Orders; which as a federal prosecutor put you in a very dubious and perilous position. Either you can come into full compliance with the Brady Orders, or you can, and you will be held in civil contempt of the Brady Orders and incarcerated until you come into full compliance with the law. Mr. Williams, I am sure you are aware that binding circuit precedent compels and obligates the District Court to incarcerate you until you have fully complied with the Brady Court Orders and disclosed to Mr. Ware “all” Brady exculpatory and impeachment evidence.
Therefore, please be advised that on October 18, 2021, Mr. Ware will move the District Court for an emergency show cause order to incarcerate Damian Williams, Audrey Strauss, John M. McEnany, Melissa Childs, et al., unless the USAO files into the District Court by 12:00 noon, on October 15, 2021, time of the essence, an affidavit or declaration of fact signed by Damian Williams, Audrey Strauss, John M. McEnany, Melissa Childs, and Edgardo Ramos that states the USAO has fully complied with the Brady Court Orders and disclosed to Ulysses T. Ware “all” Brady exculpatory and impeachment evidence, all Giglio evidence, and all Rule 16 evidence in the actual and/or constructive possession of the USAO.
Mr. Williams this is a profoundly serious matter that places you in personal legal jeopardy. Presently District Judge Edgardo Ramos has foolishly decided to collude and conspire with the USAO and has entered into a conspiracy with your office to obstruct justice, as the illegal scheme and plan to conceal and suppress material evidence regarding the continuing criminal enterprise Alpha Capital, AG (Anstalt). However, please be advised that Judge Ramos will likely be indicted and prosecuted for his crimes committed given he also has several undisclosed and covert conflicts of interest recently exposed by the Wall Street Journal. Judge Ramos has little to no integrity or credibility, notwithstanding, and even less judicial competence.
Mr. Williams if you or the USAO have any good-faith objections to Mr. Ware’s assertions that the USAO is currently in willful civil and criminal contempt of Exhibits 1 and 2, the Brady Court Orders, and Exhibit 3, the 02cv2219 (SDNY) voluntary December 20, 2007, Dkt. 90, Rule 41(a)(2) superseding final judgment, please advise Mr. Ware in writing not later than October 15, 2021, at 12:00 noon, time of the essence.
Else Mr. Ware will assume and Damian Williams and the USAO will be deemed to agree and stipulate as fact the USAO did not and has not disclosed “all” Brady exculpatory and impeachment evidence required by the Brady Court Orders; and further the USAO stipulates as fact the USAO and Damian Williams will not oppose the entry of an Order of civil incarceration of Damian Williams, Audrey Strauss, John M. McEnany, Melissa Childs, and Edgardo Ramos until such time as the USAO fully complies with the Brady Court Orders.
Sincerely,
/s/ Ulysses T. Ware
________________________________________
Ulysses T. Ware
cc: Chief District Judge (SDNY) the Hon. Laura Taylor-Swain
United States Department of Justice, Division on Public Integrity
United States Department of Justice, Office of Professional Responsibility
Attachments: Exhibit A
