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(14.EX GX 92, GX 93) (07-5222cr) Re Fabricated Gov't 05cr1115 (SDNY) Trial Exhibits GX 92 and 93
(14.EX GX 92, GX 93) (07-5222cr) Re Fabricated Gov't 05cr1115 (SDNY) Trial Exhibits GX 92 and 93
Page 1 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Table of Contents
Memorandum for Attachment (Ex 14: GX 92, GX 93) ................................................................................. 4
Exhibits .......................................................................................................................................................... 8
Exhibit 2A—Alleged Sept. 22, 2006, Rule 11 proceedings involving a person claimed to be without any
record proof to be the government’s “principal witness” in 05cr1115 (SDNY) according to Judge Kearse
to be “Jeremy Jones.” See U.S. v. Ware, 577 F.3d 442, 444 (2d Cir. 2009). (Kearse, J.). Note that Doc.
#24 does not appear on the 05cr1115 docket during the trial or appeal of the proceedings, cf., Ex. 2C,
infra. .......................................................................................................................................................... 9
Exhibit 2B—Alleged Rule 11 transcript, Sept. 22, 2006, Rule 11 plea proceedings of a person alleged to
be Jeremy Jones of which there is no official record of the Rule 11 proceeding according to the
custodian of records David Ng on June 5, 2023. ..................................................................................... 10
Exhibit 2C—05cr1115 docket--fabricated, fraudulent, and counterfeit 05cr1115 (SDNY) docket
supplied by the District Clerk (SDNY) Ruby Krajick regarding the alleged Sept. 22, 2006, Rule 11
proceeding of Jeremy Jones—there is no record on the official docket of any such alleged Sept. 22,
2006, Rule 11 proceeding........................................................................................................................ 11
Exhibit 2D—CJA lawyer Marlon G. Kirton, Esq., letter to the district court (Pauley, J.) confirming that
the government’s “principal witness” Jeremy Jones “cooperated” with the government and “received a
5k letter” for his substantial assistance, perjured testimony, to the government during the 05cr1115
proceedings. ............................................................................................................................................ 12
Exhibit 3G—U.S. v. Ware, 577 F.3d 442, 445 (2d Cir. 2009) (Kearse, J.) opinion finding “The
government’s principal witness was [Jeremy] Jones ….” (emphasis added). ........................................... 13
Exhibit 3H1—Ware, 577 F.3d at 445, false, unsupported by the actual trial record, and fraudulent
findings made by Circuit Judges Kearse, Sack, and Hall, which do not appear in the 05cr1115 official trial
record—according to David Ng on June 5, 2023, the District Court (SDNY) custodian of records, there is
no record of a government expert witness that testified at trial regarding “artificial” “inflation” of “stock
prices” “caused by” “press releases” which “pumped up” “increased” or “inflated” SVSY or INZS “stock
prices.” .................................................................................................................................................... 14
Exhibit 3H2—FBI Analyst Maria A. Font’s teary and distressed 05cr1115 trial testimony regarding GX 92
and GX 93, the government’s fabricated and fraudulent chart evidence which is contradicted by the
SEC-DOJ’s July 14, 20023, Article II affirmative defenses pleaded on the face of the 03-0831 (D. NV)
unsigned and void ab initio complaint—actual innocent SEC-DOJ exculpatory evidence suppressed by
the trial judge (Pauley, J.) and the government’s prosecutors’ collusion and conspiracy. ..................... 15
Exhibit 3I—03-0831 (D. NV) SEC-DOJ July 14, 2003, Article II law enforcement officials’ (SEC lawyers)
actual innocent affirmative defenses, judicial admissions, which contradicted and completely
impeached, undermined, and discredited the Ware, 577 F.3d at 445, see Ex. 3G, supra, Court’s
erroneous and unsupported by the actual trial record evidence conclusions ........................................ 16
Exhibit 5A—suppressed and concealed SEC lawyer Jeffrey B. Norris, a law enforcement official’s
determination and official litigation position regarding the Government’s alleged conspiracy, actual
innocent Brady exculpatory and impeachment email from SEC lawyer Jeffrey B. Norris to Jeremy Jones,
Page 2 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
the “government’s principal witness” required to have been disclosed and produced “prior to trial”
pursuant to the Brady court order, Ex. 1A, 1B, supra. ............................................................................. 17
Exhibit 12.1 re: 05cr1115 fabricated docket ........................................................................................... 18
End of document ......................................................................................................................................... 29
Page 3 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Memorandum for Attachment (Ex 14: GX 92, GX 93)
Case No. 07-5222cr
U.S. v. Ware and Jones
Filing Memorandum
Offices of the Chief Circuit Judge, The Hon. Amalya L. Kearse, The Hon. Robert D. Sack, the
Office of the Circuit’s Judicial Council, and the Director of the FBI.
U.S. Court of Appeals
For the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
Introduction
The government during the 2007 U.S. v. Ware, 05cr1115 (SDNY) trial presented the
known false and fabricated trial exhibits GX 92 and GX 93 through alleged FBI analyst Maria A.
Font—a federal law enforcement official, as purported evidence of "artificial inflation" in stock
Page 4 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
prices,1 a claim that is factually incorrect and deliberately fabricated. These false and fabricated
Government trial exhibits show a significant decrease in stock prices from $0.0375 to $0.01875,
contradicting the government's baseless assertions of market manipulation. This clear -200%
decrease in stock “prices” unequivocally discredits, impeached, abrogated, and vitiated the
prosecution's false and fraudulent trial theory and risible narrative and highlights the fraudulent
nature of the evidence presented.2
B. Known False, Misleading, and Perjured Testimony by alleged FBI Analyst, Law Enforcement
Official Maria A. Font at trial in U.S. v. Ware, 05cr1115 (SDNY), April 2007.
1
Cf., Ware, 577 F.3d at 442-446 (Kearse, J.)—based on the fabricated and false GX 92 and GX 93, and the
known perjured testimony of government witnesses Jeremy Jones and Maria A. Font concluded,
erroneously, that the “prices” of INZS and SVSY’s stocks were “artificially inflated” “increased” or “pumped
up” “caused by” press releases. An emphatic false and unsupported factual conclusion impeached and
abrogated by GX 92 and GX 93, and Font’s testimony under brutal cross-examination by Mr. Ware.
2
GX 92 and GX 93 are factually consistent with the SEC-DOJ 2003 Las Vegas bootleg grand jury unsigned
fake complaint’s paragraph 33, see Ex. 3I, infra, where the United States regulatory agency’s law
enforcement officials, SEC lawyers (Jeffrey B. Norris, Esq., et al.) all concluded as the Article II litigation
position of the United States, the real party in interest, equitable and judicial estoppel against the USAO
(SDNY) and the FBI in 05cr1115 (SDNY) and 04cr1224 (SDNY) that: (1) there was no conspiracy between
Mr. Ware and his employees regarding INZS and SVSY’s press releases (see Ex. 5A, infra), and (2) all
concluded there was no “artificial inflation” or “increase” of stock “prices.” (see Ex. 3I, infra)—Article II
judicial admissions binding without exception on the 05cr1115 (SDNY), 04cr1224 (SDNY), 22cv3409
(SDNY), 22cv10566 (SDNY), and 23-865 (2d Cir.) and 23-8679 (2d Cir.) courts; and binding without
exception on the Supreme Court of GA and the State Bar of GA in In re Ware, (2008) faked, fraudulent,
fabricated, and counterfeit disbarment proceedings.
Thus, you have the undisputed by the SEC or USAO basis for the collusion, conspiratorial and fraudulent
pretext for the 05cr1115 Government’s bogus motion in limine, Dkt. 28, AUSA Southwell, and the District
Court (Pauley, J.), equally bogus 01/08/2007, Dkt. 35, order, which deliberately and intentionally was
designed by Pauley, the USAO (SDNY), and the SEC to prohibit Mr. Ware from compelling the SEC’s law
enforcement officials involved in the Las Vegas 03-0831 (D. NV) bootleg grand jury proceedings from
being compelled to testify for Mr. Ware as Brady exculpatory and impeachment hostile witnesses
regarding paragraph 33, see Ex. 3I, infra, and Ex. 5A, infra, which eviscerated and completely destroyed
Maria A. Font’s deliberate perjured testimony, see Ex. 3H2, infra, and exposed the USAO’s, the SEC’s, Kent
J. Dawson, Thomas W. Thrash, Jr., Leonard B. Sand, Arie Rabinowitz, LH Financial Services, Alpha Capital,
AG (Anstalt) and the District Court (SDNY) conspiracy to retaliate against Mr. Ware by the initiation of
fraudulent and counterfeit 04cr1224 (SDNY) and 05cr1115 (SDNY) proceedings.
Page 5 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Law enforcement official FBI analyst Maria A. Font knowingly provided perjured
testimony regarding GX 92 and GX 93.3 Font's testimony on direct examination by AUSA
Southwell was knowingly false and misleading, asserting that the press releases from INZS and
SVSY artificially inflated stock prices.4 Under brutal cross-examination by Mr. Ware, Font in tears,
visibly under emotional duress, capitulated confessed and admitted there was no evidence
supporting these claims, thus revealing the deliberate fabrication and perjury involved in her
statements. This perjury was committed with the full knowledge and consent of the USAO
(SDNY), further underscoring the depth of the conspiracy to commit fraud on the court.
C. Judicial Complicity
Judicial officers, notably District Judge Edgardo Ramos and Judge William H. Pauley III,
exhibited a disturbing level of complicity by failing to enforce Brady orders. Their actions, or lack
thereof, facilitated the continued suppression of exculpatory evidence, further entrenching the
miscarriage of justice. This judicial complicity represents a flagrant breach of judicial ethics and a
gross obstruction of justice.
Legal Analysis
3
GX 92 and GX 93 purported chart evidence are nothing more than unverified numbers on a piece of
paper without any documentary or evidentiary support—that is, hearsay inadmissible extremely
prejudicial fabricated Government trial exhibits. Under brutal cross-examination the Government’s
conspiracy to commit fraud on the court was exposed. When pressured and placed under duress by Mr.
Ware Ms. Font could not hold up, visibly under emotional distress given her previous lies and perjury
under direct examination, she was shaken, she crumbled, capitulated, confessed, and in tears Ms. Font
admitted that she fabricated GX 92 and GX 93 under the supervision and request of AUSA Alexander H.
Southwell and the USAO (SDNY). See Ex. 3H2, infra.
4
Palpably, during the disastrous direct testimony conducted by AUSA Alexander H. Southwell Font offered
nothing as evidence of exactly how she determined the “prices” had been “artificially” “inflated.” For
obvious reasons given the evidence, GX 92 and GX 93, established something entirely different. Thus, Font
was set up to be crushed and humiliated under cross-examination by the inept direct examination of
perhaps the most incompetent federal prosecutor in the entire history of the United States, I present
former AUSA Alexander H. Southwell, a self-proclaimed (without any evidence to support the claim)
“best and brightest” “genius” and “expert” in trial technique.
See Local Rule (District Court SDNY) Rule 1.5(B)(5) and DOJ and District Court (SDNY) Rules on Lawyers
Professional Conduct, Rules 3.3, 3.4, 3.8, 8.4, and duty of complete candor to the tribunals all
egregiously and knowingly violated by Southwell, Feldman, Goldin, Kelley, Douvas, Fish, Garcia, Polk-
Failla, Bharara, Damian Williams, Griswold, Gitner, Xiang, Childs, McEnany, Strauss, Kim, Childs,
Garnett, Ed Kim, Lillian Evans, Merrick B. Garland, Breon Peace, Nina Gupta, Scotten, Shin, and Sassoon.
Page 6 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
A. Brady Violations
In Napue v. Illinois, the Supreme Court unequivocally held that convictions secured
through the knowing use of false evidence violate due process. The prosecution's use of perjured
testimony and fabricated exhibits in Ware's trial mirrors the injustices condemned in Napue,
rendering the trial fundamentally flawed and unjust.
The blatant violations of Ware's constitutional rights necessitate swift and decisive
judicial intervention. The Court of Appeals must recall its mandate, vacate all charges, and order
a new trial to restore integrity to the judicial process and ensure justice is served [9].
Conclusion
The judicial process in U.S. v. Ware, 05cr1115/07-5222cr, has been irreparably tainted
and contaminated by the government's reliance on perjured grand jury and trial testimony and
fabricated exhibits GX 92 and GX 93. The deliberate perjury committed by “the government’s
principal witness” Jeremy Jones and law enforcement official FBI analyst Maria A. Font, with the
knowledge and consent of the USAO (SDNY), exemplifies the conspiracy to commit fraud upon
the court. Immediate action is required to rectify these egregious violations and uphold the
principles of justice and due process.
Respectfully Submitted,
Page 7 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibits
Page 8 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 2A—Alleged Sept. 22, 2006, Rule 11 proceedings involving a person claimed to be
without any record proof to be the government’s “principal witness” in 05cr1115 (SDNY)
according to Judge Kearse to be “Jeremy Jones.” See U.S. v. Ware, 577 F.3d 442, 444 (2d
Cir. 2009). (Kearse, J.). Note that Doc. #24 does not appear on the 05cr1115 docket
during the trial or appeal of the proceedings, cf., Ex. 2C, infra.
Page 9 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 2B—Alleged Rule 11 transcript, Sept. 22, 2006, Rule 11 plea proceedings of a
person alleged to be Jeremy Jones of which there is no official record of the Rule 11
proceeding according to the custodian of records David Ng on June 5, 2023.
Page 10 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 2C—05cr1115 docket--fabricated, fraudulent, and counterfeit 05cr1115 (SDNY)
docket supplied by the District Clerk (SDNY) Ruby Krajick regarding the alleged Sept. 22,
2006, Rule 11 proceeding of Jeremy Jones—there is no record on the official docket of any
such alleged Sept. 22, 2006, Rule 11 proceeding.
Page 11 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 2D—CJA lawyer Marlon G. Kirton, Esq., letter to the district court (Pauley, J.)
confirming that the government’s “principal witness” Jeremy Jones “cooperated” with the
government and “received a 5k letter” for his substantial assistance, perjured testimony,
to the government during the 05cr1115 proceedings.
Page 12 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 3G—U.S. v. Ware, 577 F.3d 442, 445 (2d Cir. 2009) (Kearse, J.) opinion finding
“The government’s principal witness was [Jeremy] Jones ….” (emphasis added).
Page 13 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 3H1—Ware, 577 F.3d at 445, false, unsupported by the actual trial record, and
fraudulent findings made by Circuit Judges Kearse, Sack, and Hall, which do not appear in
the 05cr1115 official trial record—according to David Ng on June 5, 2023, the District Court
(SDNY) custodian of records, there is no record of a government expert witness that
testified at trial regarding “artificial” “inflation” of “stock prices” “caused by” “press
releases” which “pumped up” “increased” or “inflated” SVSY or INZS “stock prices.”
Page 14 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 3H2—FBI Analyst Maria A. Font’s teary and distressed 05cr1115 trial testimony
regarding GX 92 and GX 93, the government’s fabricated and fraudulent chart evidence
which is contradicted by the SEC-DOJ’s July 14, 20023, Article II affirmative defenses
pleaded on the face of the 03-0831 (D. NV) unsigned and void ab initio complaint—actual
innocent SEC-DOJ exculpatory evidence suppressed by the trial judge (Pauley, J.) and the
government’s prosecutors’ collusion and conspiracy.
Page 15 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 3I—03-0831 (D. NV) SEC-DOJ July 14, 2003, Article II law enforcement officials’ (SEC
lawyers) actual innocent affirmative defenses, judicial admissions, which contradicted and
completely impeached, undermined, and discredited the Ware, 577 F.3d at 445, see Ex.
3G, supra, Court’s erroneous and unsupported by the actual trial record evidence
conclusions
Page 16 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Exhibit 5A—suppressed and concealed SEC lawyer Jeffrey B. Norris, a law enforcement
official’s determination and official litigation position regarding the Government’s alleged
conspiracy, actual innocent Brady exculpatory and impeachment email from SEC lawyer
Jeffrey B. Norris to Jeremy Jones, the “government’s principal witness” required to have
been disclosed and produced “prior to trial” pursuant to the Brady court order, Ex. 1A, 1B,
supra.
Page 17 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
07-5222cr
Defendant (2)
Jeremy Jones represented by Marlon Geoffrey Kirton
TERMINATED: 09/15/2008 Kirton Law Firm
230 Park Ave., 3rd Floor West
New York, NY 10169
646-435-5519
Fax: 212-808-3020
Email: [email protected]
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: CJA Appointment
Page 18 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Highest Offense Level (Opening)
Felony
Complaints Disposition
18:371:CONSPIRACY TO
COMMIT SECURITIES AND
WIRE FRAUD;, 15:77q(a) & 77x:
SECURITIES FRAUD.
Plaintiff
USA represented by Alexander H. Southwell
U.S. Attorney's Office, SDNY (St
Andw's)
One St. Andrew's Plaza
New York, NY 10007
212-637-2200
Fax: 212-637-2429
Email:
[email protected]
LEAD ATTORNEY
Page 19 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
ATTORNEY TO BE NOTICED
Melissa A. Childs
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2711
Email: [email protected]
ATTORNEY TO BE NOTICED
Page 20 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
11/14/2011 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 11/14/11. (mn) (Entered: 11/14/2011)
06/13/2011 Payment of Fine from Jeremy Jones in the amount of $50.00. Date
Received: 6/13/11. (mn) (Entered: 06/13/2011)
04/12/2011 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 4/12/11. (mn) (Entered: 04/12/2011)
03/15/2011 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 3/15/11. (mn) (Entered: 03/15/2011)
02/15/2011 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 2/15/11. (mn) (Entered: 02/15/2011)
01/13/2011 Payment of Fine from Jeremy Jones in the amount of $50.00. Date
Received: 1/13/11. (mn) (Entered: 01/13/2011)
11/16/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 11/16/10. (mn) (Entered: 11/16/2010)
10/08/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 10/8/10. (mn) (Entered: 10/08/2010)
09/13/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 9/13/10. (mn) (Entered: 09/13/2010)
08/10/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 8/10/10. (mn) (Entered: 08/10/2010)
07/16/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 7/16/10. (mn) (Entered: 07/16/2010)
06/23/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 6/23/10. (mn) (Entered: 06/23/2010)
05/18/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 5/18/10. (mn) (Entered: 05/18/2010)
05/10/2010 136 Letter addressed to J. Michael McMahon from Ulysses Thomas
Ware dated 4/22/2010. This letter is in regard to 05-cr-1115
(WHP)and the current status of the numerous pleadings pending
before the court. District Judge Pauley was named a respondent in a
rule 60(d)(3) Fraud on the court pleading regarding 1115 (WHP)
and thus he was disqualified to adjudicate the pending motions and
as a matter of law (28 U.S.C. sections 144, 455 (a), (b)(1) to recuse
Page 21 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
himself from any further actions in 1115(WHP) (dnd) (Entered:
05/13/2010)
04/13/2010 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 4/13/10. (mn) (Entered: 04/13/2010)
02/17/2010 Payment of Fine from Jeremy Jones in the amount of $40.00. Date
Received: 2/17/10. (mn) (Entered: 02/17/2010)
11/12/2009 Payment of Fine from Jeremy Jones in the amount of $50.00. Date
Received: 11/12/09. (mn) (Entered: 11/12/2009)
08/28/2009 Payment of Fine from Jeremy Jones in the amount of $25.00. Date
Received: 8/28/09. (mn) (Entered: 08/28/2009)
04/28/2009 Payment of Fine from Jeremy Jones in the amount of $175.00. Date
Received: 4/28/09. (mn) (Entered: 04/28/2009)
04/20/2009 112 SEALED DOCUMENT placed in vault. (jri) (Entered:
04/20/2009)
03/26/2009 Payment of Fine from Jeremy Jones in the amount of $175.00. Date
Received: 3/26/09. (mn) (Entered: 03/26/2009)
02/18/2009 Payment of Fine from Jeremy Jones in the amount of $250.00. Date
Received: 2/18/09. (mn) (Entered: 02/18/2009)
01/26/2009 Payment of Fine from Jeremy Jones in the amount of $250.00. Date
Received: 1/26/09. (mn) (Entered: 01/26/2009)
10/07/2008 109 TRANSCRIPT of Sentencing Proceedings as to Jeremy Jones held
on 9/11/08 before Judge William H. Pauley, III. (tro) (Entered:
10/08/2008)
09/17/2008 108 ORDER OF FORFEITURE as to Jeremy Jones. NOW,
THEREFORE, IT IS ORDERED, ADJUDGED AND DECREED
THAT: 1. As a result of the offenses in the Indictment, for which
the defendant was found guilty, a money judgment in the amount of
$10,000 shall be entered against the defendant. 2. Pursuant to Rule
32.2 (b) (3) of the Federal Rules of Criminal Procedure, this Order
of Forfeiture shall be final as to the defendant, JEREMY JONES, at
the time of sentencing and shall be made part of the sentence of the
defendant, and shall be included in the judgment of conviction
therewith. 3. The Court shall retain jurisdiction to enforce Attorney
Steven D. Feldman, One St. Andrew's Plaza, New York, New York
Page 22 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
10007. (Signed by Judge William H. Pauley, III on 9/16/08)(jw)
(Entered: 09/17/2008)
09/15/2008 Judgment entered in money judgment book as #08,1749 as to
Page 23 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
date, to any date the week of June 2, 2008. -- Judge endorsed:
Application granted. The Sentencing is adjourned to 6/3/2008 at
02:00 PM before Judge William H. Pauley III. SO ORDERED.
(Signed by Judge William H. Pauley, III on 5/2/08)(ja) (Entered:
05/05/2008)
04/29/2008 SENTENCING MEMORANDUM by USA as to Jeremy Jones.
105
(Attachments: # 1 Exhibit Proposed Order of
Forfeiture)(Feldman, Steven) (Entered: 04/29/2008)
08/09/2007 74 TRANSCRIPT of Proceedings as to Ulysses Thomas Ware, Jeremy
Jones held on 1/16/07 before Judge William H. Pauley III. (jbe)
(Entered: 08/09/2007)
01/09/2007 36 PROPOSED EXAMINATION OF JURORS by USA as to Ulysses
Thomas Ware, Jeremy Jones. (Feldman, Steven) (Entered:
01/09/2007)
01/08/2007 NOTICE OF ATTORNEY APPEARANCE Steven David Feldman
34 appearing for USA. (Feldman, Steven) (Entered: 01/08/2007)
10/17/2006 24 TRANSCRIPT of Proceedings as to Jeremy Jones held on
9/22/2006 before Judge Michael H. Dolinger. (aba, ) (Entered:
10/17/2006)
10/11/2006 ORDER as to Jeremy Jones. With the dft's consent, his guilty
23 plea allocution was taken before a US Magistrate Judge on
9/22/06; a transcript of the allocuiton was made..., this Court
has determined that the dft entered the guilty plea knowingly
and voluntarily...; IT IS HEREBY ORDERED that the dft's
guilty plea is accepted. SO ORDERED. (Signed by Judge
William H. Pauley III on 10/11/06)(ja, ) (Entered: 10/12/2006)
09/22/2006 Minute Entry for proceedings held before Judge Michael H.
Dolinger : Plea entered by Jeremy Jones (2) Guilty as to Count
1s,2s. (pr, ) (Entered: 09/29/2006)
09/22/2006 Minute Entry for proceedings held before Judge Michael H.
Dolinger :Arraignment as to Jeremy Jones (2) Count 1s,2s held
on 9/22/2006. Deft. pres. w/atty Marlon Kirton; AUSA Alex
Southwell. Deft pleads GUILTY to counts 1 & 2. of
superceeding indictment. Bail cont'd. (Court Reporter Joanne)
(pr, ) (Entered: 09/29/2006)
Page 24 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
09/22/2006 CONSENT TO PROCEED BEFORE US MAGISTRATE
20 JUDGE ON A FELONY PLEA ALLOCUTION by Jeremy
Jones. (pr, ) Additional attachment(s) added on 9/29/2006 (pr, ).
(Entered: 09/29/2006)
09/14/2006 (S1) SUPERSEDING INDICTMENT FILED as to Ulysses Thomas
19 Ware (1) count(s) 1s, 2s, Jeremy Jones (2) count(s) 1s, 2s. (jar, )
(Entered: 09/18/2006)
09/08/2006 18 TRANSCRIPT of Proceedings as to Ulysses Thomas Ware, Jeremy
Jones held on 8/29/06 before Judge William H. Pauley III. (ja, )
(Entered: 09/08/2006)
08/29/2006 ORAL ORDER as to Ulysses Thomas Ware, Jeremy Jones. Time
excluded from 8/29/06 until 9/18/06. Brief (404b motions) due by
9/20/2006. Motions in limine due by 9/29/2006. Responses due by
10/11/2006. Replies due by 10/18/2006. Jury Selection set for
11/6/2006 09:45AM before Judge William H. Pauley III. Pretrial
Conference set for 11/3/2006 02:00 PM before Judge William H.
Pauley III.(bw, ) (Entered: 09/12/2006)
08/29/2006 Minute Entry for proceedings held before Judge William H. Pauley
III:Pretrial Conference as to Ulysses Thomas Ware, Jeremy Jones
held on 8/29/2006. Deft Ware present (on telephone) w/atty
Michael Bachner, Esq. physically present. Deft Jeremy Jones
present (on telephone) w/atty Marlon Kirton, Esq. physically
present. AUSA present Alexandr Southwell, Court Reporter present
Patricia Nielsen. 404b motions due 9/20/06. Motions in limine due
9/29/06, opposition due 10/11/06, replies due 10/18/06. Proposed
voir dire and joint request to charge due 10/30/06. FPTC
conference 11/3/06 at 2:00 p.m. Jury selection set for 11/6/06 at
9:45 a.m. SPT excluded from 8/29/06 to 9/18/06 under 18 U.S.C.
3161(h)(8)(A). Bail continued. (bw, ) (Entered: 09/12/2006)
06/23/2006 17 TRANSCRIPT of Proceedings (Conference) as to Ulysses Thomas
Ware, Jeremy Jones held on 5/19/06 before Judge William H.
Pauley III. (ja, ) (Entered: 06/23/2006)
05/19/2006 ORAL ORDER as to Ulysses Thomas Ware, Jeremy Jones Time
excluded from 5/19/06 until 9/18/06.(by Judge William H. Pauley
III on 5/19/06)(pr, ) (Entered: 06/01/2006)
05/19/2006 ORAL ORDER as to Ulysses Thomas Ware, Jeremy Jones. Jury
Selection set for 9/18/2006 09:45AM before Judge William H.
Page 25 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Pauley III. Pretrial Conference set for 9/12/2006 02:15 PM before
Judge William H. Pauley III..(by Judge William H. Pauley III on
5/19/06)(pr, ) (Entered: 06/01/2006)
05/19/2006 ORAL ORDER as to Ulysses Thomas Ware, Jeremy Jones.In
limine Motions due by 8/11/2006. Replies due by 8/29/2006.
Opposition due by 8/22/2006. 404b motions due 45 days prior to
jury selection. Proposed voir dire & joint request to charge due
9/8/06. (by Judge William H. Pauley III on 5/19/06)(pr, ) (Entered:
06/01/2006)
05/19/2006 Minute Entry for proceedings held before Judge William H. Pauley
III:Pretrial Conference as to Ulysses Thomas Ware, Jeremy Jones
held on 5/19/2006. Deft. Ware pres. w/atty MichaelBachner; deft.
Jones pres w/atty Marlon Kirton; AUSA Alexander Southwell.
404b motions due 45 days prior to jury selection. Motions in limine
due 8/11/06, opposition due 8/22/06, replies due 8/29/06. Proposed
voir dire and joint request to charge due 9/8/06. Next. conference
9/12/06 @ 2:15 pm. Jury selection set for 9/18/06 @ 9:45 am. SPT
excluded from 5/19/06 to 9/18/06 under 18:3161(h)(8)(A), bail
cont'd. (Court Reporter Sonya Huggins) (pr, ) (Entered:
06/01/2006)
01/06/2006 Set/Reset Deadlines as to Ulysses Thomas Ware, Jeremy Jones:
Motions due by 4/7/2006. Replies due by 5/8/2006..(pr, ) (Entered:
01/09/2006)
01/06/2006 Set/Reset Hearings as to Ulysses Thomas Ware, Jeremy Jones: Jury
Selection set for 9/18/2006 10:00AM before Judge William H.
Pauley III. Next Pretrial Conference set for 5/19/2006 02:15 PM
before Judge William H. Pauley III..(pr, ) (Entered: 01/09/2006)
01/06/2006 Minute Entry for proceedings held before Judge William H. Pauley
III:Pretrial Conference as to Ulysses Thomas Ware, Jeremy Jones
held on 1/6/2006 Deft. Ware pres. w/atty Michael Bachner & Deft.
Jones pres. w/atty Marlon Kirton & AUSA Alexander Southwell.
Motion due 4/7/06, Reply 5/8/06. Next conf. 5/19/06 @ 2:15 PM.
Jury selection set for 9/18/06 @ 10 AM. SPT excluded from 1/6/06
to 9/18/06 under 18:3161(h)(8)(A), bail cont'd. (Court Reporter
Carol Stanley) (pr, ) (Entered: 01/09/2006)
12/20/2005 REPLY by Jeremy Jones. (Kirton, Marlon) (Entered: 12/20/2005)
13
Page 26 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
12/13/2005 RULE 20 DOCUMENTS RECEIVED as to Jeremy Jones
transferred from the United States District Court - Northern District
of Georgia, Case Number: 1:05-mj-1495 (JFK). The following
documents were received: Original Documents of the Order
Appointing Counsel, Waiver of Rule 40 Hearings, Appearance
Bond, Order Setting conditions of release, Advice of Penalties and
Sanctions. (vb, ) (Entered: 12/13/2005)
11/07/2005 14 PRB Bond Entered as to Jeremy Jones in amount of $ 150,000. Co-
signed by 3 financially responsible person's property: Deft's parents
home (owned by Deft's mother) at: 753 Coverty Township Place,
Marietta, GA 30067. Travel restricted to SDNY, EDNY, ND GA &
Points in between for purposes of travel. Surrender travel
documents (& no new applications). Strict pretrial supervision. Deft
to be released upon following conditions: Own signature and one
co-signer. Remaining conditions to be met by 11/14/05. Deft to
have no contact with co-defts. Deft to maintain employment outside
of securities industry. Pretrial supervision to revert to "Regular"
Supervision after 30 days, if Deft in full compliance with reporting
obligations. (jw, ) (Entered: 03/27/2006)
11/07/2005 11 ADVICE OF PENALTIES AND SANCTIONS as to Jeremy Jones.
(vb, ) (Entered: 11/09/2005)
11/07/2005 Minute Entry for proceedings held before Judge Debra C. Freeman
: AUSA Nick Golden present for the government and on behalf of
AUSA Alexander Southwell. Defendant Jeremy Jones present
with CJA Attorney Marlon Kirton. Bail Set: $150,000.00 PRB;
Co-signed by 3 FRP's and secured by Property (Defendants parent's
home, owned by the defendant's mother, and located at 753
Country Township Place, Marrietta GA 30067); Travel limits are
restricted to the SDNY, EDNY and extended to the NDGA &
points between for travel purposes. Surrender of travel documents
and no new applications. Strict pre-trial supervision. Defendant
may be released upon his own signature & one co-signer with the
remaining conditions to be met by 11/14/05. Defendant may have
no contact with any co-defendants; Defendant is to maintain
employment outside of the securities industry; Pre-trial supervision
is to revert to regular supervision after 30 days if the defendant is in
full compliance with reporting obligations. Arraignment as to
Jeremy Jones (2) Count 1,2Jeremy Jones (2) Count 1,2 held on
11/7/2005., Initial Appearance as to Jeremy Jones held on
11/7/2005., Plea entered by Jeremy Jones (2) Count 1,2Jeremy
Page 27 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
Jones (2) Count 1,2 Not Guilty. Plea entered by Jeremy Jones (2)
Count 1,2Jeremy Jones (2) Count 1,2. (vb, ) (Entered: 11/09/2005)
11/07/2005 Attorney update in case as to Jeremy Jones. Attorney Marlon
Geoffrey Kirton for Jeremy Jones added. .(vb, ) (Entered:
11/09/2005)
11/07/2005 Arrest of Jeremy Jones. (vb, ) (Entered: 11/09/2005)
11/03/2005 Minute Entry for proceedings held before Judge William H. Pauley
III:Pretrial Conference as to Ulysses Thomas Ware, Jeremy Jones
held on 11/3/2005. Deft Ware present w/atty Michael Bachner. Deft
Jones not present. Deft Jones' atty Marlon Kirton present. AUSA
Alexander Southwell present. Court Reporter present. Government
requests a warrant be issued for deft Jones. Next conference
1/6/2006 at 12:30 p.m. for deft Ware. As to deft Ware, SPT
excluded from 11/3/2005 to 1/6/2006. Bail continued. (jp, )
(Entered: 11/21/2005)
10/26/2005 Case Designated ECF as to Ulysses Thomas Ware, Jeremy
Jones.(jm, ) (Entered: 10/26/2005)
10/26/2005 7 INDICTMENT FILED as to Ulysses Thomas Ware (1) count(s) 1,
2, Jeremy Jones (2) count(s) 1, 2. (jm, ) (Entered: 10/26/2005)
09/20/2005 1 COMPLAINT as to Ulysses Thomas Ware (1), Jeremy Jones (2) in
violation of 18 U.S.C. 2, 371 and 15 U.S.C. 77q(a) & 77x. (Signed
by Judge Andrew J. Peck ) (gq, ) [1:05-mj-01630-UA] (Entered:
09/27/2005)
Page 28 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.
End of document
Page 29 of 29
Wednesday, June 5, 2024
(14 Ex) re Fabricated and perjured U.S. v. Ware, 05cr1115 (SDNY) Government trial exhibits GX 92 and GX
93—fabricated by AUSAs Alexander H. Southwell, Steven D. Feldman, Nicholas S. Goldin, and FBI analyst
Maria A. Font, with the consent of U.S. Attorney (SDNY) Michael J. Garcia as a conspiracy to commit a
fraud on the court and knowingly commit perjury by Font.