ACTUAL NOTICE

Part 19 Doc. 4-D

THE OFFICE OF ULYSSES T. WARE
123 Linden Boulevard, Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
[email protected]

Date: June 26, 2025, 9:52:24 AM

VIA ELECTRONIC MAIL

Mr. Thomas A. Leghorn, Esq.
London Fischer LLP
59 Maiden Lane
New York, NY 10038
(And to any other email address used by Mr. Leghorn in prior communications)

AND TO: Your Purported Clients BAKER & MCKENZIE, LLP; LAWRENCE B.
MANDALA, ESQ.; ROBERT H. ALBARAL, ESQ.; AND DAVID MALLIBAND, ESQ.
(Served via counsel Thomas A. Leghorn, Esq.).

RE: FORMAL SERVICE AND ACTUAL NOTICE OF APPELLANTS’ REQUEST FOR

MANDATORY JUDICIAL NOTICE (FRE 201(c)(2)) AND DEMAND FOR
OPPORTUNITY TO BE HEARD (FRE 201(e)) IN CASE NO. 1:25-CV-00613-MLB
(NDGA) – URGENT RESPONSE REQUIRED PURSUANT TO STANDING ORDER
(DKT. 2, ¶ (m)) AND FED. R. CIV. P. 11(b)(1-4), AND 28 USC § 1927 – TIME IS OF THE
ESSENCE.

The legal and pecuniary interests of your clients are directly and severely implicated by
their continued adherence to legally frivolous and factually baseless personal jurisdictional
arguments. We urge you to advise them accordingly and to respond substantively and in good faith
by the deadline. You and your clients must respond under oath by June 27, 2025, by 1:00 PM;
else, you will be deemed to have stipulated and consented to the requested relief.

Respectfully,

/s/ Ulysses T. Ware

Ulysses T. Ware
Attorney in fact for the Appellants

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 Table of Contents
RE: FORMAL SERVICE AND ACTUAL NOTICE OF APPELLANTS’ REQUEST FOR
MANDATORY JUDICIAL NOTICE (FRE 201(c)(2)) AND DEMAND FOR OPPORTUNITY TO
BE HEARD (FRE 201(e)) IN CASE NO. 1:25-CV-00613-MLB (NDGA) – URGENT RESPONSE
REQUIRED PURSUANT TO STANDING ORDER (DKT. 2, ¶ (m)) AND FED. R. CIV. P. 11(b)(1-
4), AND 28 USC § 1927 – TIME IS OF THE ESSENCE. ....................................................................... 1
ATTACHMENTS: FRE 201(c)(2) Motion ............................................................................................... 8
APPELLANTS’ REQUEST FOR MANDATORY JUDICIAL NOTICE OF ADJUDICATIVE
FACTS PURSUANT TO FEDERAL RULE OF EVIDENCE 201(c)(2) AND DEMAND FOR
OPPORTUNITY TO BE HEARD PURSUANT TO FEDERAL RULE OF EVIDENCE 201(e)
REGARDING ACTUAL NOTICE TO APPELLEES BAKER & MCKENZIE, LLP, LAWRENCE
B. MANDALA, ESQ., AND ROBERT H. ALBARAL, ESQ. ................................................................. 9
A. INTRODUCTION. ............................................................................................................................... 10
I. LEGAL STANDARD FOR MANDATORY JUDICIAL NOTICE (FRE 201(c)(2)). ..................... 11
II. ADJUDICATIVE FACTS SUBJECT TO MANDATORY JUDICIAL NOTICE
ESTABLISHING ACTUAL NOTICE TO THE BAKER MCKENZIE APPELLEES AND THE
FRIVOLITY OF THEIR JURISDICTIONAL OBJECTIONS. .......................................................... 11
A. Actual Notice to Thomas A. Leghorn, Esq., as Counsel for Baker McKenzie Appellees: ......... 12
B. Actual Notice Directly to Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., and Robert
H. Albaral, Esq.:.................................................................................................................................... 14
C. Actual Notice in Bankruptcy Case 03-93031 and Appellate Case 25cv00613: ........................... 18
D. Legal Effect of Actual Notice under Espinosa and Rule 8009(e)(1): ........................................... 20
III. ARGUMENT ...................................................................................................................................... 22
IV. DEMAND FOR OPPORTUNITY TO BE HEARD (FRE 201(e)) ................................................. 23
V. CONCLUSION..................................................................................................................................... 24
VI. LIST OF ATTACHMENTS IN SUPPORT OF APPELLANTS’ REQUEST FOR
MANDATORY JUDICIAL NOTICE (FRE 201(c)(2)). ........................................................................ 25
[End of document]..................................................................................................................................... 30

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Dear Mr. Leghorn:

Please be formally advised that Appellants Ulysses T. Ware and Group Management
("Appellants") have, this 26th day of June, 2025, prepared for filing with the United States District
Court for the Northern District of Georgia in Case No. 1:25-cv-00613-MLB ("District Court
Appeal") the attached, infra, "APPELLANTS’ REQUEST FOR MANDATORY JUDICIAL
NOTICE OF ADJUDICATIVE FACTS PURSUANT TO FEDERAL RULE OF
EVIDENCE 201(c)(2) AND DEMAND FOR OPPORTUNITY TO BE HEARD PURSUANT
TO FEDERAL RULE OF EVIDENCE 201(e) REGARDING ACTUAL NOTICE TO
APPELLEES BAKER & MCKENZIE, LLP, LAWRENCE B. MANDALA, ESQ., AND
ROBERT H. ALBARAL, ESQ." (hereinafter "FRE 201 Motion").

A complete copy of this FRE 201 Motion, along with its supporting attachments
meticulously detailing twenty-five (25) specific adjudicative facts, is attached hereto for your
immediate review and action. This service constitutes further actual notice to you and your
purported clients—Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., Robert H. Albaral, Esq.,
and David Malliband, Esq. (collectively, the "Baker McKenzie Appellees")—of the irrefutable
documentary evidence establishing their comprehensive and ongoing actual notice of the
underlying Bankruptcy Case No. 03-93031-WLH ("Bankruptcy Case"), the related U.S. District
Court (S.D.N.Y.) Case No. 02cv2219 (LBS) ("SDNY Case"), and the instant District Court
Appeal.

The attached FRE 201 Motion demonstrates, through judicially noticeable facts, that any
contention by you or the Baker McKenzie Appellees asserting lack of notice or lack of personal
jurisdiction in these matters is not only factually and legally baseless but also advanced in bad
faith, in direct violation of your obligations under Federal Rule of Civil Procedure 11(b)(1)-(4).
The legal consequences of such conduct, particularly under United Student Aid Funds, Inc. v.
Espinosa, 559 U.S. 260 (2010), are severe and include waiver, forfeiture, and exposure to
significant sanctions.

URGENT RESPONSE REQUIRED PURSUANT TO STANDING ORDER (DKT. 2, ¶

(m)) AND RULE 11:

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 Pursuant to the U.S. District Court for the Northern District of Georgia's Standing Order
Regarding Civil Litigation (Dkt. 2, ¶ (m) in Case No. 1:25-cv-00613-MLB), which mandates good-
faith efforts to resolve disputes before seeking judicial intervention, and in light of your obligations
under Federal Rule of Civil Procedure 11, Appellants hereby demand that you, on behalf of each
of the Baker McKenzie Appellees, not later than Friday, June 27, 2025, 1:00 PM EDT, time is
of the essence:

1. Provide Appellants with a formal, written letter of representation unequivocally

identifying each specific individual and entity (including Baker & McKenzie, LLP,
Lawrence B. Mandala, Esq., Robert H. Albaral, Esq., and David Malliband, Esq.) on whose
behalf you, Thomas A. Leghorn, Esq., and London Fischer LLP, are authorized to act in
relation to the District Court Appeal (1:25-cv-00613-MLB), the Bankruptcy Case (03-
93031), and the SDNY Case (02cv2219).
2. Provide Appellants with duly executed and sworn declarations or affidavits, pursuant
to 28 U.S.C. § 1746, from each of your identified clients unequivocally stating, under
penalty of perjury, whether they contend they did not receive actual notice of the relevant
aspects of the aforementioned proceedings, specifically addressing the documented
instances of notice detailed in the attached FRE 201 Motion and its exhibits.
3. Provide a substantive written response to the merits of the attached FRE 201 Motion,
detailing any good-faith basis upon which you contend the twenty-five (25) adjudicative
facts are not subject to mandatory judicial notice or do not establish actual notice and
waiver under Espinosa.

TIME IS OF THE ESSENCE: DEADLINE FOR OPPOSITIONAL RESPONSE

Your comprehensive written response addressing each of the foregoing demands must be
in writing, signed pursuant to Fed. R. Civ. P. 11 as an officer of the court, and received by
Appellants’ attorney-in-fact, Ulysses T. Ware, via email at [email protected], no later than
FRIDAY, JUNE 27, 2025, BY 1:00 PM EASTERN DAYLIGHT TIME.

SEVERE LEGAL AND PECUNIARY CONSEQUENCES OF NON-RESPONSE OR

INSUFFICIENT RESPONSE:

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 Failure to provide a timely, substantive, and compliant response by the aforementioned

deadline will be deemed:

A. A conclusive admission and stipulation by you and each of the Baker McKenzie Appellees
that the twenty-five (25) adjudicative facts detailed in the FRE 201 Motion are true, correct,
and not subject to reasonable dispute.
B. A conclusive admission and stipulation that the Baker McKenzie Appellees received
constitutionally sufficient actual notice of all relevant proceedings.
C. A conclusive stipulation, waiver, and forfeiture of any and all objections to personal
jurisdiction.
D. Further stipulated and judicially admitted evidence of your and your clients' bad faith and
violation of Rule 11(b)(1)-(4), thereby compounding your exposure to sanctions.

In such event, Appellants will forthwith file the attached FRE 201 Motion with the
25cv00613 (NDGA) District Court and will concurrently seek all available remedies against you
and the Baker McKenzie Appellees, including but not limited to, an order striking any
jurisdictional objections, a finding of default, entry of final money judgment ($5.2225B), jointly
and severally, against them (including potential monetary judgments as previously detailed, see
Dkt. 27, 25cv00613), and significant monetary and non-monetary sanctions.

The legal and pecuniary interests of your clients are directly and severely implicated by
their continued adherence to frivolous and factually baseless jurisdictional arguments. We urge
you to advise them accordingly and to respond substantively and in good faith by the deadline.

Respectfully,

/s/ Ulysses T. Ware

Ulysses T. Ware
Attorney in fact for the Appellants

Attachments: Documents already in the possession of Mr. Leghorn and his clients.

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 1. Appellants’ Request for Mandatory Judicial Notice of Adjudicative Facts (FRE 201(c)(2))
and Demand for Opportunity to be Heard (FRE 201(e)) in Case No. 1:25-cv-00613-MLB
(NDGA), dated June 26, 2025.
2. Exhibit A to FRE 201 Motion: Composite Exhibit of Attachments 1-9 as detailed in the
"List of Attachments in Support of Appellants’ Request for Mandatory Judicial Notice" (or
alternatively, list each of the 9 primary attachments separately as itemized in the previous
response detailing the list of attachments). For clarity, it might be better to list them
individually if that's how they are organized. For example:

A. Attachment 2.1: Part 19 Doc. (04-C) – Appellants' June 25, 2025 Letter to Thomas
A. Leghorn, Esq.
B. Attachment 2.2: Part 19, Doc. (04A) – Appellants' June 25, 2025 (12:23 PM) Email
to Thomas A. Leghorn, Esq.
C. Attachment 2.3: Part 19, Doc. (4-B) – Appellants' June 25, 2025 Letter to Thomas
A. Leghorn, Esq., et al. (with its internal attachments 1-7, which could also be
itemized here if preferred for extreme detail).
D. Attachment 2.4: Copy of Dkt. 180, Case No. 03-93031-mhm (Bankr. N.D. Ga.),
Filed 08/04/22.
E. Attachment 2.5: Copy of Letter from Thomas A. Leghorn, Esq. to Hon. Paul A.
Engelmayer, dated April 28, 2022.
F. Attachment 2.6: Copy of Appellants' Letter "Formal Inquiry #2.0" to Lawrence B.
Mandala, Esq., dated April 5, 2022.
G. Attachment 2.7: Copy of Email from Elorian Landers to Lawrence B. Mandala,
Esq., dated February 7, 2002.
H. Attachment 2.8: Copies or Excerpts of relevant Convertible Note and Subscription
Agreement.
I. Attachment 2.9: Copy of Declaration of Lawrence B. Mandala, Esq., dated April
15, 2002 (JSAR Dkt. 5-16).

cc: Baker & McKenzie, LLP (via Mr. Leghorn)

Lawrence B. Mandala, Esq. (via Mr. Leghorn)

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Robert H. Albaral, Esq. (via Mr. Leghorn/Baker & McKenzie, LLP)
David Malliband, Esq. (via Mr. Leghorn/Baker & McKenzie, LLP)
All other parties previously served.

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 ATTACHMENTS:
FRE 201(c)(2) Motion

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 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

IN RE: GROUP MANAGEMENT CORP.,

Debtor.
ULYSSES T. WARE, et al.,
Appellants,
v.
ALPHA CAPITAL, AG, et al.,
Appellees.
Case No. 1:25-cv-00613-MLB
____________
(On Appeal from the United States Bankruptcy Court for
the Northern District of Georgia, Case No. 03-93031-WLH)
___________
APPELLANTS’ REQUEST FOR MANDATORY JUDICIAL NOTICE OF
ADJUDICATIVE FACTS PURSUANT TO FEDERAL RULE OF EVIDENCE 201(c)(2)
AND DEMAND FOR OPPORTUNITY TO BE HEARD PURSUANT TO FEDERAL RULE
OF EVIDENCE 201(e) REGARDING ACTUAL NOTICE TO APPELLEES BAKER &
MCKENZIE, LLP, LAWRENCE B. MANDALA, ESQ., AND ROBERT H. ALBARAL,
ESQ.

Date: June 26, 2025, 9:52:24 AM

Filed on behalf of Appellants,

Ulysses T. Ware and Group Management
By: /s/ Ulysses T. Ware
Ulysses T. Ware
Attorney in Fact for Appellants
The Office of Ulysses T. Ware
123 Linden Boulevard, Suite 9-L
Brooklyn, NY 11226
(718) 844-1260
[email protected]

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A. INTRODUCTION.
COMES NOW Appellants Ulysses T. Ware and Group Management ("Appellants"), by

and through their attorney-in-fact Ulysses T. Ware, and pursuant to Federal Rule of Evidence

("FRE") 201(c)(2), respectfully request this Honorable Court to take mandatory judicial notice of

the following twenty-five (25) specific dispositive adjudicative facts. These dispositive facts,

derived from Appellants’ prior correspondence with Thomas A. Leghorn, Esq.1 (purported counsel

for Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., and Robert H. Albaral, Esq. –

collectively, the "Baker McKenzie Appellees"), official court records, and documents previously

served or filed (copies of which are attached hereto or are already part of the record in this case or

the underlying Bankruptcy Case No. 03-93031-WLH), irrefutably establish that the Baker

McKenzie Appellees received extensive, repeated, and undeniable actual notice of the U.S.

District Court (S.D.N.Y.) Case No. 02cv2219 (LBS) ("SDNY Case"), the Bankruptcy Case, and

the instant appellate proceeding (Case No. 1:25-cv-00613-MLB, "District Court Appeal").

Further, pursuant to FRE 201(e), Appellants demand an opportunity to be heard regarding

the propriety of taking judicial notice of these dispositive facts and their dispositive effect on the

patently frivolous and bad-faith contentions advanced by Mr. Leghorn on behalf of the Baker

McKenzie Appellees that this Court and the Bankruptcy Court purportedly lack personal

jurisdiction over them due to an alleged lack of actual notice. Such contentions are advanced in

violation of Federal Rule of Civil Procedure 11(b)(1)-(4).

1
Mr. Leghorn, an officer of the court, has refused all requests to provide a signed letter of representation
regarding exactly who he represents and the scope of the alleged representation, for which Appellants have
been prejudiced by the very suspect and unprofessional misconduct of Mr. Leghorn and his alleged clients.

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I. LEGAL STANDARD FOR MANDATORY JUDICIAL NOTICE
(FRE 201(c)(2)).
Federal Rule of Evidence 201(b) permits a court to judicially notice a fact that is not subject

to reasonable dispute because it "can be accurately and readily determined from sources whose

accuracy cannot reasonably be questioned." FRE 201(c)(2) mandates that a court must take

judicial notice "if a party [the Appellants] requests it and the court is supplied with the necessary

information [see the attachments]." Correspondence between counsel, official court dockets (see

Dkt. 180:03-93031 providing actual notice and the designation of the Baker McKenzie Appellees

as “interested parties”), and filed declarations are quintessential sources whose accuracy, for the

purpose of establishing their existence and content, cannot reasonably be questioned.

II. ADJUDICATIVE FACTS SUBJECT TO MANDATORY

JUDICIAL NOTICE ESTABLISHING ACTUAL NOTICE TO THE
BAKER MCKENZIE APPELLEES AND THE FRIVOLITY OF
THEIR JURISDICTIONAL OBJECTIONS.
The following dispositive adjudicative facts, each verifiable through the attached exhibits

or existing court records, demonstrate that the Baker McKenzie Appellees' claims of lack of actual

notice and, consequently, lack of personal jurisdiction, are objectively frivolous, patently baseless,

and advanced in bad faith, particularly under the standard of United Student Aid Funds, Inc. v.

Espinosa, 559 U.S. 260 (2010), and in light of Federal Rule of Bankruptcy Procedure 8009(e)(1).

(Reference Key for Attachments:

A. Att. 1: Part 19 Doc. (04-C) – Appellants' June 25, 2025 Letter to Thomas A. Leghorn, Esq.

B. Att. 2: Part 19, Doc. (04A) – Appellants' June 25, 2025 (12:23 PM) Email to Thomas A.

Leghorn, Esq.

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 C. Att. 3: Part 19, Doc. (4-B) – Appellants' June 25, 2025 Letter to Thomas A. Leghorn, Esq.,

Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., and Robert H. Albaral, Esq. (with

its own internal attachments 1-7).

D. Att. 4: Dkt. 180, Case No. 03-93031-mhm (Bankr. N.D. Ga.), Filed 08/04/22 (GPMT's

designation of interested parties).

E. Att. 5: Letter from Thomas A. Leghorn, Esq. to Hon. Paul A. Engelmayer, dated April 28,

2022 (Re: Ware v. USA, 22-cv-3409).

F. Att. 6: Appellants' Letter "Formal Inquiry #2.0" to Lawrence B. Mandala, Esq., dated April

5, 2022.

G. Att. 7: February 7, 2002 Email from Elorian Landers to Lawrence B. Mandala, Esq. (re:

Escrowed Shares).

H. Att. 8: Excerpts from Convertible Note and Subscription Agreement (related to 02cv2219

SDNY Plaintiffs).

I. Att. 9: Declaration of Lawrence B. Mandala, Esq. (originally from 02cv2219 SDNY, now

JSAR Dkt. 5-16).

A. Actual Notice to Thomas A. Leghorn, Esq., as Counsel for Baker McKenzie

Appellees:

Fact #1: On April 27, 2022, Thomas A. Leghorn, Esq., sent an email to Ulysses T. Ware

acknowledging his representation of Baker & McKenzie, LLP and Lawrence B. Mandala, Esq.

* Adjudicative Effect: Establishes Mr. Leghorn's attorney-client relationship and authority to

receive notice for these entities.

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* FRE 201(c)(2) Confirmation: Referenced in Att. 2 (Appellants' response to Leghorn's email,

which quotes or describes his email) and Att. 3 (Internal Attachment 2).

Fact #2: On April 27, 2022, Appellants sent a letter to Thomas A. Leghorn, Esq., referencing his

client file "810.611" for "Lawrence B. Mandala and Baker & McKenzie, LLP," detailing

Appellants' investigation into the "February 2001 Illegal Transaction," the "Illegal Contracts,"

connections to the 02cv2219 (SDNY) "Civil Plaintiffs" (including Alpha Capital, AG), and an

August 10, 2007, Brady Court Order (Dkt. 32, 04cr1224 SDNY).

* Adjudicative Effect: Direct, detailed actual notice to counsel of the specific matters, parties,

and related criminal proceedings.

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 1); Att. 2 (detailing this letter).

Fact #3: Appellants' April 27, 2022, response to Mr. Leghorn reiterated concerns about the

predatory, criminal usury unlawful debt "Illegal Contracts, GX 1-4 and GX-5," the Adar Bays

usury decision, unregistered broker-dealers in 02cv2219 (SDNY), and the Brady Court Order.

* Adjudicative Effect: Confirms active engagement by Mr. Leghorn and his clients' actual notice

regarding these specific, intertwined disputes.

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 2); Att. 2.

Fact #4: On April 30, 2022, Appellants served on Mr. Leghorn a "Last and Final Brady Demand"

referencing 22cv3409 (SDNY), U.S. v. Ware (04cr1224 SDNY), Alpha Capital, AG, et al. v.

Group Management Corp., et al. (02cv2219 SDNY), and demands for GPMT client records related

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to the "Illegal Transaction" in the possession of "Baker" (Baker & McKenzie, LLP and/or Thomas

A. Leghorn).

* Adjudicative Effect: Further actual notice to counsel of ongoing demands, critical case

connections, and allegations of criminal conduct.

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 4); Att. 2.

Fact #5: On April 28, 2022, Thomas A. Leghorn, Esq., sent a letter to Hon. Paul A. Engelmayer

(SDNY) in Case 22-cv-3409, stating, "I am counsel to Lawrence B. Mandala, Esq. and Baker

& McKenzie."

* Adjudicative Effect: Judicial admission by Mr. Leghorn of his representation of these

specific clients in a related federal proceeding initiated by Appellants.

* FRE 201(c)(2) Confirmation: Att. 5 (Leghorn Letter to Judge Engelmayer).

B. Actual Notice Directly to Baker & McKenzie, LLP, Lawrence B. Mandala, Esq.,
and Robert H. Albaral, Esq.:

Fact #6: On April 26, 2022, Group Management (by Ulysses T. Ware) sent Memorandum #1.03

directly to "Baker & McKenzie, LLP, Robert H. Albaral, Esq. (an officer of the court), and

Lawrence B. Mandala, Esq. (an officer of the court), jointly, ('GPMT's legal counsel')."

* Adjudicative Effect: Direct addressing and service on these parties.

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 3).

Fact #7: Memorandum #1.03 (Att. 3, Internal Att. 3) made a "Demand for compensation ($2.225

billion)" against Baker & McKenzie, LLP, Mr. Albaral, and Mr. Mandala for "negligent and

reckless representation" of GPMT concerning the "illegal transaction(s) of February 1, 2001,"

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concerning GX 1-4 and GX 5, explicitly linking it to NY Penal Law §190.40 (criminal usury) and

the 03-93031 Bankruptcy Case which was filed by Appellants to defend against predatory loan-

sharking by the 02cv2219 (SDNY) plaintiffs.

* Adjudicative Effect: Direct, unequivocal actual notice to these parties of multi-billion

dollar claims against them personally and professionally, directly linking their conduct to

the 03-93031 Bankruptcy Case and 02cv2219 (SDNY).

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 3).

Fact #8: On April 5, 2022, Appellants sent "Formal Inquiry #2.0" directly to Lawrence B.

Mandala, Esq. (then at Munck, Wilson & Mandala, LLP, formerly of Baker & McKenzie, LLP)

regarding the predatory, loan sharking, unlawful debt collection activity, in violation of 18 USC

§§ 2, 371, 1951(a), 1956-57, 1961(6)(B), and 1962(a-d) "2001 Form SB-2, Legal Opinion of

Baker & McKenzie, LLP Concerning the Predatory, Criminal Usury, Unlawful Debts Notes (GX

1-4) and the Subscription Agreement (GX 5), (the 'Illegal Contracts') legal malpractice and

professional negligence."

* Adjudicative Effect: Direct actual notice to Mr. Mandala about specific allegations of

malpractice concerning the "Illegal Contracts" relevant to the 03-93031 and 02cv2219 matters.

* FRE 201(c)(2) Confirmation: Att. 6 (Formal Inquiry #2.0).

Fact #9: The April 5, 2022 "Formal Inquiry #2.0" (Att. 6) explicitly informed Mr. Mandala of the

N.Y. Court of Appeals decision in Adar Bays, LLC v. Genesys ID, Inc., holding that GPMT's

"Illegal Contracts" (GX 1-4 and GX 5) were null and void ab initio and that the $1.1 million

criminal usury "Illegal Loan" did not legally have to be repaid, directly implicating the bogus and

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negligent legal opinion provided by Mr. Mandala and Baker & McKenzie, LLP attached to

Appellant Group Management’s Form SB-2.

* Adjudicative Effect: Actual notice of a dispositive legal development affecting the legality of

the transactions they handled and for which they rendered negligent legal opinions, causing

Appellants +$522M in actual damages.

* FRE 201(c)(2) Confirmation: Att. 6.

Fact #10: The April 5, 2022 "Formal Inquiry #2.0" (Att. 6, Page 2) included FINRA's May 17,

2021, Certification (Exhibit 7 to that inquiry) stating that the alleged creditors in 02cv2219 (Alpha

Capital, AG, Stonestreet, L.P., Markham Holdings, Ltd., Amro International, S.A.) were

unregistered broker-dealers, rendering the "Illegal Contracts" and "Illegal Loan" (GX 1-4, and GX

5) null and void ab initio.

* Adjudicative Effect: Actual notice to Mr. Mandala of facts rendering the underlying

transactions his firm facilitated were illegal from inception.

* FRE 201(c)(2) Confirmation: Att. 6 and its Exhibit 7 (FINRA Certification).

Fact #11: An email dated February 7, 2002, from Elorian Landers (GPMT) was sent to, inter alia,

"[email protected]" regarding "Escrowed Shares and Convertible" note

holders (including predatory unregistered broker-dealers Alpha Capital, AG, et al.) and the status

of the fraudulent Form SB-2 registration of Appellant Group Management’s 39 million shares to

be used in the Baker & McKenzie, LLP’s sanctioned illegal unlawful debt collection activities, see

18 USC § 1961(6)(B). See JSAR Dkt. 5-16 (a stipulated fact).

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* Adjudicative Effect: Demonstrates Mr. Mandala's and Baker & McKenzie, LLP's

contemporaneous involvement and actual notice of issues with the very predatory, criminal usury,

unlawful debt, convertible notes and registration efforts at the heart of the 02cv2219 (SDNY) and

03-93031 disputes.

* FRE 201(c)(2) Confirmation: Att. 7 (Feb. 7, 2002 Email).

Fact #12: The null and void ab initio predatory, criminal usury Convertible Note (GX 1-4) and

Subscription Agreement (GX 5) for the "Illegal Transaction" (related to 02cv2219 SDNY plaintiffs

and impacting 03-93031) were documents fraudulently and negligently prepared and/or

reviewed by Lawrence B. Mandala, Esq., while at Baker & McKenzie, LLP.

* Adjudicative Effect: First-hand knowledge and involvement, constituting the most profound

form of actual notice of the terms of these critical agreements.

* FRE 201(c)(2) Confirmation: Att. 8 (Excerpts of Note & Subscription Agmt.); Att. 9 (Mandala

Declaration ¶¶ 2-3 detailing his work on this financing and SB-2).

Fact #13: Lawrence B. Mandala, Esq., submitted a sworn Declaration in the 02cv2219 (SDNY)

case (dated April 15, 2002), (see JSAR Dkt. 5-16), detailing his legal services to Group

Management Corp. from October 2000 through January 2002 "in connection with the negotiation

of financing and the preparation and filing of a registration statement...on form SB-2" relating to

his and Baker & McKenzie, LLP’s knowing and willful facilitation and direct involvement in the

illegal, unlawful debt collection transactions with the 02cv2219 plaintiffs (predatory

unregistered broker-dealers Alpha Capital, AG, et al.).

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* Adjudicative Effect: Judicial admission by Mr. Mandala under oath of his and Baker &

McKenzie, LLP's direct, intimate involvement and facilitation of the Hobbs Act extortion and loan-

sharking transactions, and thus actual notice of the core transactions and parties.

* FRE 201(c)(2) Confirmation: Att. 9 (Mandala Declaration, JSAR Dkt. 5-16, pp. 41-44 of 64).

C. Actual Notice in Bankruptcy Case 03-93031 and Appellate Case 25cv00613:

Fact #14: The official Creditor Matrix for Bankruptcy Case 03-83009-mhm (now 03-93031-

WLH), filed December 3, 2003, explicitly lists "Baker & McKenzie, 2300 Trammell Crow Center,

2001 Ross Avenue, Dallas, Texas 75201" as a creditor.

* Adjudicative Effect: Formal, constructive, and actual notice to Baker & McKenzie, LLP of its

status as a creditor and interested party in the Bankruptcy Case from its inception.

* FRE 201(c)(2) Confirmation: Att. 3 (Internal Attachment 5).

Fact #15: On August 4, 2022, Dkt. 180 was filed in the Bankruptcy Case (03-93031-mhm),

explicitly designating individuals and entities, including Baker & McKenzie, LLP and/or

Lawrence B. Mandala, Esq. (under broader categories or as counsel whose conduct was at issue),

as "interested parties" and warning of waiver/collateral estoppel for failure to object.

* Adjudicative Effect: Provided Baker McKenzie Appellees with actual notice of their

"interested party" status regarding the ongoing issues within the 03-93031 bankruptcy.

* FRE 201(c)(2) Confirmation: Att. 4 (Dkt. 180).

Fact #16: The Notice of Appeal (Dkt. 279, 03-93031 Bankr. Case; Dkt. 1, District Court Appeal)

named Appellees including those involved in the 02cv2219 (SDNY) litigation (Alpha Capital, AG,

et al.), whose transactions Baker & McKenzie, LLP and Mr. Mandala facilitated.

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* Adjudicative Effect: Notice that the appeal concerned matters directly related to their prior

clients and their own professional conduct.

* FRE 201(c)(2) Confirmation: Dkt. 1 (25cv00613); Dkt. 279 (03-93031).

Fact #17: The Bankruptcy Court Clerk’s "Imaged Certificate of Notice" (Dkt. 284, Bankr. Case)

regarding the appeal was served on parties whose interests were implicated by the 02cv2219

(SDNY) / 03-93031 nexus.

* Adjudicative Effect: Official court notice to all parties affected by the appeal, including those

whose prior counsel's actions (Baker McKenzie Appellees) are under scrutiny.

* FRE 201(c)(2) Confirmation: Dkt. 284 (03-93031).

Fact #18: The District Court Clerk served the Joint Stipulated Appellate Record (JSAR, Dkt. 5,

25cv00613), which included Mr. Mandala's 2002 Declaration (Att. 9 / JSAR Dkt. 5-16), on all

parties.

* Adjudicative Effect: Actual notice to all appellees of the contents of the appellate record,

including documents evidencing the Baker McKenzie Appellees' direct involvement.

* FRE 201(c)(2) Confirmation: Dkt. 5 (25cv00613).

Fact #19: Appellants' "Declaration of Service of Actual Notice of Adverse Consequences" (Dkt.

7, 25cv00613) certified service of notice on all Appellees (including the Baker McKenzie

Appellees, and unregistered predatory broker-dealers Alpha Capital, AG et al., clients of Baker

McKenzie in the underlying transaction) regarding Espinosa and waiver for non-participation.

* Adjudicative Effect: Specific notice to all parties, including those represented by or involving

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the Baker McKenzie Appellees, of the legal consequences of failing to appear and defend.

* FRE 201(c)(2) Confirmation: Dkt. 7 (25cv00613).

Fact #20: Counsel Thomas A. Leghorn, Esq., sent an email to Appellants on June 25, 2025 (11:27

AM EDT), explicitly acknowledging Appellants' communications and asserting lack of

jurisdiction, thereby confirming his firm's actual receipt of Appellants’ notices concerning these

proceedings.

* Adjudicative Effect: Direct admission by counsel of receiving Appellants’ actual notice

communications regarding the Baker McKenzie Appellees.

* FRE 201(c)(2) Confirmation: Referenced in Att. 1 (Leghorn Email, June 25, 2025).

D. Legal Effect of Actual Notice under Espinosa and Rule 8009(e)(1):

Fact #21: United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260, 272-73, 275-76 (2010), holds

that actual notice of a bankruptcy proceeding is constitutionally sufficient and triggers a duty to

act, with failure to do so resulting in waiver and forfeiture of objections to notice, service, or

personal jurisdiction.

* Adjudicative Effect: Establishes the controlling legal standard.

* FRE 201(c)(2) Confirmation: Published Supreme Court precedent.

Fact #22: Federal Rule of Bankruptcy Procedure 8009(e)(1) provides the exclusive mechanism

for parties to settle disputes about the 03-93031 bankruptcy court record with respect to alleged

personal jurisdiction, which the Baker Mckenzie Appellants knowingly and willfully “slept on

their rights” and thus forfeited “the opportunity to be heard” with respect to notice.

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* Adjudicative Effect: Defines the procedural path for challenging record accuracy, which the

Baker McKenzie Appellees failed to utilize.

* FRE 201(c)(2) Confirmation: Text of Fed. R. Bankr. P. 8009(e)(1).

Fact #23: The Baker McKenzie Appellees filed no motion under Rule 8009(e)(1) in the 03-

93031 Bankruptcy Court to contest their "interested party" status (designated in Dkt. 180) or

to otherwise challenge notice/service related to the 03-93031 proceedings.

* Adjudicative Effect: Failure to use the exclusive prescribed remedy, leading to waiver of

objections to the record and underlying notice concerning their involvement.

* FRE 201(c)(2) Confirmation: Review of the docket of Case No. 03-93031-WLH (Bankr. N.D.

Ga.).

Fact #24: The arguments by Mr. Leghorn asserting lack of personal jurisdiction due to alleged

lack of service, first raised in 2024, come years after extensive actual notice to him and his clients

of their involvement and Appellants' claims concerning the 02cv2219, 03-93031, and 25cv00613

proceedings.

* Adjudicative Effect: Demonstrates unreasonable delay and supports waiver/forfeiture.

* FRE 201(c)(2) Confirmation: Dates of attached correspondence (2022) versus date of Mr.

Leghorn’s email (June 25, 2025).

Fact #25: Mr. Leghorn, on behalf of the Baker McKenzie Appellees, has not provided any sworn

declaration or affidavit from his clients denying actual notice of the 02cv2219 (SDNY), 03-93031

(BC NDGA), or 25cv00613 (NDGA) proceedings, despite Appellants' demands.

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* Adjudicative Effect: The absence of sworn denials, in the face of overwhelming

documentary evidence of actual notice, renders the factual predicate of their jurisdictional

challenge baseless under Rule 11(b)(3).

* FRE 201(c)(2) Confirmation: Appellants' correspondence demanding such declarations (Atts.

1 & 2) and the absence of responsive sworn statements.

III. ARGUMENT
The foregoing twenty-five dispositive adjudicative facts, each readily verifiable from

sources whose accuracy cannot reasonably be questioned, conclusively demonstrate that Thomas

A. Leghorn, Esq., Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., and Robert H. Albaral,

Esq., received comprehensive, repeated, and undeniable actual notice of the SDNY Case, the

Bankruptcy Case, and this District Court Appeal, as well as the specific nature of Appellants'

claims implicating their conduct and interests.

Under the unambiguous mandate of Espinosa, this actual notice was constitutionally

sufficient and imposed upon the Baker McKenzie Appellees a duty to act to protect their interests

in those respective forums. Their failure to act, appear, object, or otherwise timely assert defenses

related to personal jurisdiction or service in the SDNY Case (as applicable to their involvement),

the Bankruptcy Case (particularly after the Dkt. 180 "interested party" designation and the creditor

matrix listing, and concerning Mr. Mandala’s direct involvement), or timely in this District Court

Appeal, constitutes a waiver and forfeiture of such objections. Their patently frivolous and bad

faith attempt now, through Mr. Leghorn, to claim lack of personal jurisdiction due to alleged

service defects is a classic impermissible collateral attack barred by Espinosa, Id. at 272.

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 Furthermore, their failure to utilize Fed. R. Bankr. P. 8009(e)(1) to address any perceived

inaccuracies or disputes regarding the Bankruptcy Court record as it pertained to them further

solidifies this waiver.

The contentions now advanced by Mr. Leghorn are, therefore, not only legally foreclosed

by waiver and forfeiture but are also factually baseless in light of the documented history of actual

notice. Such arguments, advanced without supporting sworn declarations denying notice and in

direct contravention of verifiable facts, violate Federal Rule of Civil Procedure 11(b)(1) (improper

purpose), 11(b)(2) (not warranted by existing law, i.e., Espinosa), and 11(b)(3) (factual contentions

lacking evidentiary support).

IV. DEMAND FOR OPPORTUNITY TO BE HEARD (FRE 201(e))

Pursuant to FRE 201(e), Appellants demand an opportunity to be heard by this Court

regarding:

1. The propriety of taking mandatory judicial notice of the twenty-five dispositive

adjudicative facts listed herein.

2. The dispositive legal effect of these judicially noticed facts, particularly concerning the

waiver and forfeiture of any personal jurisdiction defenses by the Baker McKenzie

Appellees under Espinosa and Fed. R. Bankr. P. 8009(e)(1).

3. The consequent frivolous and bad-faith nature of Mr. Leghorn's contentions regarding lack

of personal jurisdiction and the appropriateness of sanctions under Rule 11.

4. The actual legal liability of the Baker McKenzie Appellees for $5.2225B in actual damages

caused by their crimes, frauds, negligence, facilitation, and aiding and abetting predatory,

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 criminal usury, unlawful debt (GX 1-4) collection activities in violation of 18 USC §§ 2,

371, 1951(a), 1956-57, 1961(6)(B), and 1962(a-d).

V. CONCLUSION
For the reasons stated herein, Appellants respectfully request that this Court take

mandatory judicial notice of the twenty-five specified dispositive adjudicative facts and schedule

a hearing for Appellants to be heard on these matters. These facts compel the conclusion that the

Baker McKenzie Appellees have waived any objection to personal jurisdiction, that their counsel's

contrary assertions are sanctionable, and they are jointly and severally monetary liable for the sum

certain amount of $5.2225B in actual damages to the Appellants caused directly by their Hobbs

Act crimes, negligence, and willful professional misconduct.

Respectfully submitted,

/s/ Ulysses T. Ware

Ulysses T. Ware

Attorney in Fact for Appellants

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VI. LIST OF ATTACHMENTS IN SUPPORT OF APPELLANTS’
REQUEST FOR MANDATORY JUDICIAL NOTICE (FRE
201(c)(2)).
1. Attachment 1: Part 19 Doc. (04-C) – Appellants' Letter to Thomas A. Leghorn, Esq.,

dated June 25, 2025.

A. Content: References Mr. Leghorn's email of June 25, 2025 (11:27 AM EDT);

reiterates demands for client identification and sworn declarations; summarizes

legal arguments regarding Espinosa and waiver.

B. Relevance to Facts: 20, 24, 25 (Establishes Mr. Leghorn's recent communication,

Appellants' demands, and lack of sworn denials).

2. Attachment 2: Part 19, Doc. (04A) – Appellants' Email to Thomas A. Leghorn, Esq.,

dated June 25, 2025 (12:23 PM EDT).

A. Content: Appellants' response to Mr. Leghorn's June 25, 2025 (11:27 AM EDT)

email, detailing documentary evidence of actual notice and demanding client

identification and sworn declarations. (This document itself contains a list of its

own internal attachments 1-4).

B. Relevance to Facts: 1, 2, 3, 4, 20, 24, 25 (Details specific prior communications

establishing actual notice, references Leghorn's email).

3. Attachment 3: Part 19, Doc. (4-B) – Appellants' Letter to Thomas A. Leghorn, Esq.,

Baker & McKenzie, LLP, Lawrence B. Mandala, Esq., and Robert H. Albaral, Esq.,

dated June 25, 2025 (with its internal attachments 1-7).

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 A. Content: Comprehensive letter detailing proof of actual notice to Baker McKenzie

Appellees regarding 03-93031, 02cv2219, and 25cv00613.

i. Internal Attachment 3.1 (Originally Att. 1 to Doc. 4-B): Letter from

Ulysses T. Ware to Thomas A. Leghorn, Esq., dated April 27, 2022 (RE:

Immediate disclosure of GPMT's client files).

1. Relevance to Facts: 2 (Details actual notice to Leghorn regarding

specific transactions, parties, and Brady Order).

ii. Internal Attachment 3.2 (Originally Att. 2 to Doc. 4-B): Appellants'

Response to Thomas A. Leghorn, Esq.'s Email, dated April 27, 2022.

1. Relevance to Facts: 1, 3 (Confirms Leghorn's representation and

active engagement on issues of "Illegal Contracts," usury, Brady).

iii. Internal Attachment 3.3 (Originally Att. 3 to Doc. 4-B): Memorandum

#1.03 from Group Management to Baker & McKenzie, LLP, Robert H.

Albaral, Esq., and Lawrence B. Mandala, Esq., dated April 26, 2022 (RE:

Demand for compensation $2.225 billion).

1. Relevance to Facts: 6, 7 (Direct actual notice to Baker McKenzie

entities of multi-billion dollar claims linking their conduct to 03-

93031 and 02cv2219).

iv. Internal Attachment 3.4 (Originally Att. 4 to Doc. 4-B): Appellants'

"Last and Final Brady Demand" to Thomas A. Leghorn, Baker &

McKenzie, LLP, and Lawrence B. Mandala, Esq., dated April 30, 2022.

1. Relevance to Facts: 4 (Further actual notice to Leghorn and clients

of ongoing demands and critical case connections).

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 v. Internal Attachment 3.5 (Originally Att. 5 to Doc. 4-B): Bankruptcy

Case Creditors Matrix (Dkt. 1-1, Case 03-83009-mhm, filed Dec. 3, 2003).

1. Relevance to Facts: 14 (Shows Baker & McKenzie, LLP listed as a

creditor in 03-93031 from inception).

vi. Internal Attachment 3.6 (Originally Att. 6 to Doc. 4-B): Appellants'

Declaration of Service of Actual Notice of Adverse Consequences (Dkt. 7,

Case No. 1:25-cv-00613-MLB, filed March 7, 2025).

1. Relevance to Facts: 19 (Sworn notice to all appellees, including

Baker McKenzie Appellees, of appellate proceedings and Espinosa

implications).

vii. Internal Attachment 3.7 (Originally Att. 7 to Doc. 4-B): Joint Stipulated

Appellate Record Supplement F-8 (Dkt. 5-16, Pages 8-11 / pp. 41-44 of 64,

Case No. 1:25-cv-00613-MLB) – Declaration of Lawrence B. Mandala,

Esq. (originally from 02cv2219 SDNY).

1. Relevance to Facts: 13 (Mr. Mandala's own sworn declaration

detailing his and Baker & McKenzie's involvement in the core

transactions).

4. Attachment 4: Copy of Dkt. 180, Case No. 03-93031-mhm (Bankr. N.D. Ga.), Filed

08/04/22 (GPMT's designation of individuals and entities as interested parties).

A. Content: The full filed document.

B. Relevance to Facts: Adjudicative Facts 1, 2, 3, 4 of the Motion (Establishes

designation of "The State Bar of Georgia" and others as "interested parties," service,

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 and warning of waiver/collateral estoppel). It would also be reviewed for specific

designation of Baker McKenzie Appellees if applicable (for Fact #15 of the

Motion).

5. Attachment 5: Copy of Letter from Thomas A. Leghorn, Esq. to Hon. Paul A.

Engelmayer, U.S. District Judge (SDNY), dated April 28, 2022 (RE: Ware v. United

States, Case Number: 22-cv-3409).

A. Content: Mr. Leghorn's letter to Judge Engelmayer.

B. Relevance to Facts: Adjudicative Fact 5 of the Motion (Judicial admission by Mr.

Leghorn of his representation of Lawrence B. Mandala, Esq., and Baker &

McKenzie in a related federal proceeding).

6. Attachment 6: Copy of Appellants' Letter "Formal Inquiry #2.0" to Lawrence B.

Mandala, Esq., dated April 5, 2022.

A. Content: The full letter to Mr. Mandala.

B. Relevance to Facts: Adjudicative Facts 8, 9, 10 of the Motion (Direct actual notice

to Mr. Mandala regarding malpractice allegations, Adar Bays decision, and FINRA

certification of unregistered broker-dealers for the "Illegal Contracts").

7. Attachment 7: Copy of Email from Elorian Landers (GPMT) to Lawrence B.

Mandala, Esq. ([email protected]), et al., dated February 7,

2002 (RE: Escrowed Shares and Convertible).

A. Content: The email communication.

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 B. Relevance to Facts: Adjudicative Fact 11 of the Motion (Demonstrates Mr.

Mandala's and Baker & McKenzie, LLP's contemporaneous involvement and

actual notice of issues with the convertible notes and registration efforts).

8. Attachment 8: Copies or Excerpts of the relevant Convertible Note and Subscription

Agreement (related to 02cv2219 SDNY Plaintiffs).

A. Content: The contractual documents themselves.

B. Relevance to Facts: Adjudicative Fact 12 of the Motion (Evidences the terms of the

agreements Mr. Mandala and Baker & McKenzie, LLP worked on, establishing

their first-hand knowledge).

9. Attachment 9: Copy of Declaration of Lawrence B. Mandala, Esq., dated April 15,

2002 (originally filed in 02cv2219 (SDNY), and also contained within JSAR Dkt. 5-16,

Case No. 1:25-cv-00613-MLB).

A. Content: The full sworn declaration.

B. Relevance to Facts: Adjudicative Facts 13 (Judicial admission by Mr. Mandala

under oath of his and Baker & McKenzie, LLP's direct involvement in the core

transactions and parties). This is the same as Internal Attachment 3.7 but listed

separately for clarity if it's a standalone key document.

Additional Court Dockets/Filings Referenced in the Motion (to be presented to the Court via

citation or direct copies if not already attached):

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 A. Dkt. 279, Case No. 03-93031-WLH (Bankr. N.D. Ga.): Appellants' Notice of Appeal.

(Referenced in Facts 7, 8, 16, 17 of the Motion).

B. Dkt. 45, Case No. 1:25-cv-00613-MLB (N.D. Ga.): SBGA Appellees' "Special

Appearance Brief." (Referenced in Facts 9, 15, 17, 18, 19 of the Motion).

C. Dkt. 284, Case No. 03-93031-WLH (Bankr. N.D. Ga.): Bankruptcy Court Clerk's

"Imaged Certificate of Notice." (Referenced in Facts 10, 11, 17 of the Motion).

D. Dkt. 5, Case No. 1:25-cv-00613-MLB (N.D. Ga.): District Court Clerk's Notice of

Docketing Appeal and Transmitting Record (JSAR). (Referenced in Facts 12, 17, 18 of the

Motion).

E. Dkt. 7, Case No. 1:25-cv-00613-MLB (N.D. Ga.): Appellants' "Declaration of Service of

Actual Notice of Adverse Consequences." (Referenced in Facts 13, 14, 19 of the Motion).

F. Dkt. 46, Case No. 1:25-cv-00613-MLB (N.D. Ga.): SBGA Appellees' "Motion for

Sanctions." (Referenced in Facts 18, 19 of the Motion).

G. Complete Docket of Case No. 03-93031-WLH (Bankr. N.D. Ga.): For review to confirm

absence of objections or motions by SBGA/Baker McKenzie Appellees (Referenced in

Facts 5, 16, 23 of the Motion).

H. Complete Docket of Case No. 1:25-cv-00613-MLB (N.D. Ga.): For review to confirm

absence of formal appearance by counsel for Baker McKenzie Appellees prior to or with

Dkts. 45/46 (if applicable to those specific docket numbers) and other timing issues

(Referenced in Fact 20 of the Motion).

[End of document]

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