Part 19 Doc. 02-E.2.

Date: Sunday, June 29, 2025, 7:20:42 PM

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, QBE INSURANCE CORP., CRUM & FORSTER INSURANCE
COMPANY, AND THE SBGA APPELLEES, 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’ SUPPLEMENTAL MEMORANDUM OF LAW REGARDING THE

SBGA APPELLEES’ BINDING JUDICIAL ADMISSION OF "APPELLEE" STATUS VIA
THEIR RULE 8020 MOTION FOR SANCTIONS (DKT. 46).

TO: THE STATE BAR OF GEORGIA APPELLEES ("SBGA APPELLEES"), NALL &
MILLER, LLP, PATRICK N. ARNDT, ESQ., AND ALL OTHER APPELLEES.

Respectfully submitted,

/s/ Ulysses T. Ware

Ulysses T. Ware
Attorney in fact for the Appellants

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Order ¶(m) duty to meet and confer regarding Dkt. 45 and Dkt. 46’s manifest frivolity and fraud on the
court.
 Table of Contents
I. INTRODUCTION. .................................................................................................................................. 3
II. A GRANULAR ANALYSIS OF FEDERAL RULE OF BANKRUPTCY PROCEDURE 8020(a).
...................................................................................................................................................................... 3
Rule 8020. Frivolous Appeal and Other Misconduct ........................................................................... 4
A. The Conditional Prerequisite: "If... determines that an appeal is frivolous..."........................ 4
B. The Procedural Sequence: "then, after a separate motion is filed..." ....................................... 4
III. DKT. 46 IS AN IRREVOCABLE JUDICIAL ADMISSION OF "APPELLEE" STATUS. ........ 6
IV. CONSEQUENCES OF THE JUDICIAL ADMISSION: MOOTNESS OF DKT. 45 AND
SANCTIONABLE CONDUCT. ................................................................................................................ 7
V. Adjudicative Facts for which the Court is required to take mandatory FRE 201(c)(2) judicial
notice. ......................................................................................................................................................... 10

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court.
I. INTRODUCTION.
This Supplemental Memorandum of Law to Part 19 Doc. 02-E is submitted by Appellants

as part of their ongoing Federal Rule of Civil Procedure 11(b)(1-4) prefiling investigation. It

provides a granular analysis of Federal Rule of Bankruptcy Procedure 8020(a), the very rule under

which the SBGA Appellees have moved for sanctions against Appellants in their manifestly

frivolous, fraudulent, and ultra vires "Special Appearance Motion for Sanctions of Non-Parties"

(Dkt. 46).

A meticulous, textualist deconstruction of Rule 8020(a) reveals that the SBGA Appellees,

by the very act of invoking this specific rule, have made an irrevocable and binding judicial

admission of their status as "appellees" in this proceeding. This admission stands in direct, fatal

contradiction to the central premise of their "Special Appearance Brief of State-Bar Non-Parties"

(Dkt. 45), wherein they assert they are "non-parties" over whom this Court lacks personal

jurisdiction. This self-inflicted contradiction not only moots the entirety of Dkt. 45 but also

exposes both Dkt. 45 and Dkt. 46 as manifestly frivolous, bad-faith, fraudulent filings designed

to perpetrate a fraud upon this Court.

II. A GRANULAR ANALYSIS OF FEDERAL RULE OF

BANKRUPTCY PROCEDURE 8020(a).
Federal Rule of Bankruptcy Procedure 8020(a) provides a specific, conditional, and

sequential process for awarding sanctions for a frivolous appeal. Its precise language is not

suggestive but prescriptive. The full text reads:

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court.
Rule 8020. Frivolous Appeal and Other Misconduct

(a) Frivolous Appeal; Damages and Costs. If the district court or BAP [first] determines1

that an appeal is frivolous, then after a separate motion is filed or the court gives notice and a

reasonable opportunity to respond, it may award just damages and single or double costs to the

appellee.

Each phrase in this rule carries independent legal significance that the SBGA Appellees have either

ignored or willfully misrepresented in their filings.

A. The Conditional Prerequisite: "If... determines that an appeal is frivolous..."

The word "if" establishes a condition precedent. The entire mechanism of Rule 8020(a) is

inoperative unless and until the appellate court—in this case, the District Court—first undertakes

an analysis and makes a substantive "determination[]" that the appeal is, in fact, "frivolous." This

is a threshold judicial finding. The SBGA Appellees' Dkt. 46 improperly puts the cart before the

horse, demanding sanctions before the Court has made any such threshold determination. This

procedural error, while significant, pales in comparison to their dispositive judicial admission in

identifying themselves as the party eligible for relief in Dkt. 46.

B. The Procedural Sequence: "then, after a separate motion is filed..."

The word "then" establishes a mandatory temporal sequence. Only after the Court makes

the prerequisite determination of frivolousness does the next step—a motion for sanctions—

become procedurally ripe. The phrase "after a separate motion is filed" confirms that the request

1
Which requires the District Court to have subject matter jurisdiction over the issues and subject matter of
the appeal (i.e., the predatory criminal usury unlawful debts, GX 1-4 and GX 5), see Steel Co., 523 U.S. at
93-95.

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court.
for sanctions must be a distinct procedural event that follows the Court's substantive finding on

the merits of the appeal's frivolousness. The SBGA Appellees' filing of Dkt. 46 before any such

determination by this Court renders their motion premature, ultra vires, and procedurally

improper and moot on its face.

C. The Designated Beneficiary of Relief: "...it may award just damages ... to the appellee."

This final clause is the most critical and damning for the SBGA Appellees' perilous legal

position. The rule is exceptionally precise about who is eligible to receive an award of sanctions

under this provision. The language does not state that the court may award damages to a "non-

party," to an "aggrieved entity," or to a "person burdened by the appeal." It explicitly and

restrictively designates the beneficiary of any award as "the appellee."

i. "The Appellee" as a Term of Art: In the context of any appeal, the term "appellee" has

a specific, non-ambiguous legal meaning: it is the party who prevailed in the lower court

or who is an interested party affected by an order being appealed, and against whom the

appeal is taken; the party who has an interest in defending the lower court's judgment. It is

a defined status, not a general description.

ii. No Other Party is Authorized Relief: By drafting the rule with such specificity, the rule

makers deliberately excluded any other type of entity from seeking damages for a frivolous

appeal under this particular rule. A "non-party," as fraudulently claimed by the SBGA

Appellees in Dkt. 45 by definition, cannot be an "appellee." The two statuses are mutually

exclusive.

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court.
III. DKT. 46 IS AN IRREVOCABLE JUDICIAL ADMISSION OF
"APPELLEE" STATUS.
The doctrine of judicial admission holds that a party is bound by its deliberate, clear, and

unequivocal factual assertions or legal positions taken in its pleadings, motions, or in open court.

See, e.g., Gibbs ex rel. Estate of Gibbs v. CIGNA Corp., 440 F.3d 571, 578 (2d Cir. 2006). A party

cannot "play fast and loose with the courts" by asserting contradictory positions to suit its tactical

advantages.

When the SBGA Appellees and their counsel, Nall & Miller, LLP, and Patrick N. Arndt,

Esq., signed pursuant to Rule 11(b)(1-4) and filed Dkt. 45 and Dkt. 46, they explicitly invoked

"Rule 8020" as the source of authority for their requested relief. By invoking a rule that grants

relief exclusively "to the appellee," they have made a deliberate, unequivocal, and binding

judicial representation to this Court that they hold the legal status of "appellees" for the purpose

of seeking relief under that rule. They cannot selectively embrace the remedies of Rule 8020 while

simultaneously disavowing the status required to invoke it.

This voluntary act and affirmative statement constitute a conclusive and dispositive judicial

admission that:

1. They are, in fact, Appellees in Case No. 1:25-cv-00613-MLB.

2. They are submitting themselves to this Court's jurisdiction as Appellees to seek affirmative

relief.

3. They knowingly and willfully defaulted and did not timely file a Rule 8018 merits brief.

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court.
IV. CONSEQUENCES OF THE JUDICIAL ADMISSION:
MOOTNESS OF DKT. 45 AND SANCTIONABLE CONDUCT.
This binding dispositive judicial admission has two immediate and fatal consequences for

the SBGA Appellees' litigation posture.

First, it completely vitiates and renders moot the entirety of their "Special Appearance

Brief" (Dkt. 45). A party cannot, in good faith or with any logical consistency, simultaneously, on

the one hand, represent to the Court that it is a "non-party" over whom the Court lacks personal

jurisdiction (Dkt. 45) and, on the other hand, claim to be an aggrieved Rule 8020(a) "appellee"

entitled to seek affirmative relief from that same Court (Dkt. 46). The admission of "appellee"

status in Dkt. 46 legally nullifies the contrary fraudulent assertion in Dkt. 45.

Second, the filing of two diametrically opposed pleadings—a classic case of incongruent

duplicity, demonstrates manifest per se, ipso facto, bad faith and constitutes sanctionable conduct

under Federal Rule of Civil Procedure 11 and personally against Mr. Arndt, and Mr. NeSmith,

both officers of the court, pursuant to 28 USC § 1927. By advancing these contradictory and

inverted positions, the SBGA Appellees and their counsel have violated:

i. Rule 11(b)(1): They have presented filings for an improper purpose—to harass Appellants,

cause unnecessary delay, and to advance a confused and abusive litigation strategy.

ii. Rule 11(b)(2) & (3): Their legal and factual contentions regarding their status are not based

in law or fact; rather, they are based on a self-contradictory premise, demonstrating a failure

to conduct a reasonable prefiling inquiry.

V. CONCLUSION

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Part 19 Doc. 2-E.2 re Supplemental Rule 11(b)(1-4), 28 USC 1927 Prefiling Investigation and Standing
Order ¶(m) duty to meet and confer regarding Dkt. 45 and Dkt. 46’s manifest frivolity and fraud on the
court.
 The plain language of Federal Rule of Bankruptcy Procedure 8020(a) is clear: only an

"appellee" may be awarded damages (which requires a “concrete injury in fact” caused by the

Appellant), for a frivolous appeal under that rule. By filing a motion (Dkt. 46) seeking

affirmative judicial relief under this specific rule, the SBGA Appellees have made a binding

judicial admission that they are, in fact, Appellees. This admission is fatal to their frivolous and

fraudulent personal jurisdictional challenge in Dkt. 45 and exposes both filings as a sanctionable

abuse of the judicial process. They have, through their own negligent and apoplectic procedural

choices,2 trapped themselves in a web of their own making, a hole they dug, confirming their status

as parties to this appeal, appellees, and underscoring the bad faith of their attempt to argue

otherwise.

(A) The undersigned will attempt to “meet and confer” as required by the District

Court’s Standing Order’s ¶(m), Dkt. 2, with the SBGA Appellees (William D. NeSmith, Esq.),

QBE Insurance Corp. (James Ted Turner, Esq.), and their legal counsel (Nall & Miller, LLP and

Patrick N. Arndt, Esq.), on Monday, June 30, 2025, between 10 and 11 AM EDT via telephone

to discuss the resolution of this dispositive matter; or (B) alternatively, the SBGA Appellees and

their conflicted legal counsel, Patrick N. Arndt, Esq., an officer of the court, subject to GA Bar

Rules 3.3 and 8.4, can provide a sworn Declaration from each of the SBGA Appellees, and himself

2
The characterization of the SBGA Appellees’ strategy as an “apoplectic procedural choice” refers to the
legally schizophrenic act of contemporaneously filing Dockets 45 and 46. These pleadings are mutually
exclusive and doctrinally irreconcilable. Dkt. 45 disavows personal jurisdiction by claiming “non-party”
status, while Dkt. 46 affirmatively seeks relief under Rule 8020(a)—a rule granting relief only “to the
appellee.” This creates an untenable legal paradox, a judicial blackhole, that is instantaneously fatal to their
personal jurisdictional challenge. It represents a form of strategic self-immolation, where the very act of
seeking an advantage (sanctions) in Dkt. 46 irrevocably destroys the foundation of their primary defense in
Dkt. 45, leaving them in a doctrinal cul-de-sac (checkmate) of their own making from which there is no
escape. This is not a mere tactical error, but a conclusive, binding admission of their status as appellees.

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court.
(Mr. Arndt), regarding the below ten (10) dispositive adjudicative facts which the Appellants will

request that the District Court take mandatory FRE 201(c)(2) judicial notice. Appellants will

initiate the telephone call.

Respectfully submitted,

/s/ Ulysses T. Ware

Ulysses T. Ware
Attorney in fact for the Appellants

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Part 19 Doc. 2-E.2 re Supplemental Rule 11(b)(1-4), 28 USC 1927 Prefiling Investigation and Standing
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court.
 V. Adjudicative Facts for which the Court is required to take
mandatory FRE 201(c)(2) judicial notice.

Appellants will respectfully request that the Honorable Court, pursuant to Federal Rule of

Evidence 201(c)(2), take mandatory judicial notice of the following ten (10) dispositive

adjudicative facts. These facts are not subject to reasonable dispute as they can be accurately and

readily determined from sources whose accuracy cannot reasonably be questioned, namely, the

"Special Appearance Brief of State-Bar Non-Parties" (Dkt. 45) and the "Special Appearance

Motion for Sanctions of Non-Parties" (Dkt. 46) filed by the State Bar of Georgia Appellees

("SBGA Appellees") and their counsel, as well as the text of the Federal Rules of Bankruptcy

Procedure Rule 8020.

These judicially noticed facts, when viewed in concert, establish a clear and long

incontrovertible record of bad-faith and fraudulent litigation tactics, the advancement of self-

contradictory and frivolous legal positions, and the vexatious multiplication of proceedings,

thereby compelling the denial of Dkts. 45 and 46, and the personal imposition of sanctions against

the SBGA Appellees and their counsel, Patrick N. Arndt, Esq., and William D. NeSmith, III, Esq.

Fact #1: The Identity of the Movants and the Filing of Dkt. 46.

On June 13, 2025, the entities and individuals listed in the caption of Dkt. 46, including
The State Bar of Georgia, The Office of General Counsel, William D. NeSmith, III, Patrick N.
Arndt, Esq., and Nall & Miller, LLP (collectively, the "Movants"), filed a "SPECIAL
APPEARANCE MOTION FOR SANCTIONS OF NON-PARTIES."

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court.
 • Adjudicative Effect: This fact establishes the identity of the parties seeking affirmative
relief from this Court, and consenting to personal jurisdiction in the 25cv00613 appeal
• FRE 201(c)(2) Confirmation Source: Dkt. 46, Page 1, Case No. 1:25-cv-00613-MLB
(N.D. Ga.).

Fact #2: The Explicit Invocation of Federal Rule of Bankruptcy Procedure 8020.

Dkt. 46 explicitly states on its second page that the "State Bar Non-Parties ... hereby file their
Motion for Sanctions Pursuant to Rule 8020."

• Adjudicative Effect: This fact establishes the precise and sole legal authority under which
the Movants are seeking sanctions from this Court.
• FRE 201(c)(2) Confirmation Source: Dkt. 46, Page 2, Case No. 1:25-cv-00613-MLB
(N.D. Ga.).

Fact #3: The Exclusive Beneficiary of Relief Under Rule 8020(a).

The plain text of Federal Rule of Bankruptcy Procedure 8020(a) exclusively authorizes the
Court, upon a finding that an appeal is frivolous, to "award just damages and single or double costs
to the appellee." (Emphasis added). The rule provides no mechanism for awarding such damages
to any other category of person or entity, such as a "non-party."

• Adjudicative Effect: This establishes the limited and defined legal status a movant must
possess to be eligible for the relief sought in Dkt. 46.
• FRE 201(c)(2) Confirmation Source: The text of Federal Rule of Bankruptcy Procedure
8020(a).

Fact #4: The Contemporaneous Contradictory Assertion of "Non-Party" Status in Dkt. 45.

Contemporaneously with filing Dkt. 46, the exact same Movants filed Dkt. 45, their
"Appellee's BRIEF," which is predicated on the central and repeated assertion that they are "State
Bar Non-Parties" and that "neither the bankruptcy court nor this Court has personal jurisdiction
over them."

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court.
 • Adjudicative Effect: This fact establishes the Movants' primary legal and factual
argument, which is diametrically opposed to the status required to seek relief under Rule
8020(a).
• FRE 201(c)(2) Confirmation Source: Dkt. 45, Pages 5-6 ("The State Bar Non-Parties
were not added as parties..."), Case No. 1:25-cv-00613-MLB (N.D. Ga.).

Fact #5: The Binding Judicial Admission of "Appellee" Status.

By affirmatively and voluntarily invoking Rule 8020(a) to seek the remedy of "just
damages"—a form of relief available exclusively "to the appellee"—the SBGA Appellees and their
counsel made a deliberate, clear, and unequivocal judicial admission that, for the purposes of this
proceeding, they hold the legal status of "appellees."

• Adjudicative Effect: This admission is legally conclusive and estops the Movants from
arguing the contrary position asserted in Dkt. 45. It is a definitive (equitable estoppel)
waiver and stipulation of their "non-party" defense.
• FRE 201(c)(2) Confirmation Source: The logical and legal consequence derived from
comparing Fact #2 (invoking Rule 8020) and Fact #3 (the text of Rule 8020(a)), as analyzed
in Part 19 Doc. 02-E.2.

Fact #6: The Procedural Impropriety and Prematurity of Dkt. 46.

Dkt. 46 was filed before the Court made the prerequisite determination that "an appeal is
frivolous," as mandated by the plain text of Rule 8020(a) ("If the district court ... determines ...,
then after a separate motion is filed ...").

• Adjudicative Effect: This demonstrates that the Motion for Sanctions was filed in
violation of the rule's mandatory procedural sequence, providing evidence of a lack of
reasonable inquiry under Rule 11(b)(2).
• FRE 201(c)(2) Confirmation Source: The docket of Case No. 1:25-cv-00613-MLB
(showing no such prior determination by the Court) and the text of Rule 8020(a).

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court.
Fact #7: The Absence of Pleading Article III Standing in Dkt. 46.

The Motion for Sanctions (Dkt. 46) contains no sworn factual allegations, evidence, or
argument establishing that the SBGA Parties have suffered “a concrete, particularized,” and non-
self-inflicted "injury in fact" fairly traceable to Appellants' conduct, which is the "irreducible
constitutional minimum" for Article III standing required to seek affirmative relief, Dkt. 46, from
a federal court, as articulated in Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992).

• Adjudicative Effect: This fatal pleading defect and deficiency renders Dkt. 46 legally
baseless from its inception, as the Movants failed to plead the threshold jurisdictional
requirement for seeking the relief they demand.
• FRE 201(c)(2) Confirmation Source: The text of Dkt. 46 itself, which lacks any such
allegations.

Fact #8: The Rule 11 Certification by Counsel.

Patrick N. Arndt, Esq., of Nall & Miller, LLP, signed both Dkts. 45 and 46, as an officer of
the court, thereby certifying to the Court under Federal Rule of Civil Procedure 11(b) that, to the
best of his knowledge after an objective and reasonable inquiry, the legal contentions therein
were warranted by existing law and the factual contentions had evidentiary support.

• Adjudicative Effect: This establishes counsel's personal and professional responsibility

for the contents of these contradictory filings.
• FRE 201(c)(2) Confirmation Source: Dkt. 45, Page 7 (signature block); Dkt. 46, Page 7
(signature block), Case No. 1:25-cv-00613-MLB (N.D. Ga.).

Fact #9: The Inherent Falsity of the Simultaneous, Contradictory Certifications.

The simultaneous submission of Dkt. 45 (denying appellee status and jurisdiction) and Dkt. 46
(affirmatively invoking a rule that requires appellee status and jurisdiction) represents a direct,
irreconcilable contradiction. This demonstrates that Mr. Arndt’s certifications made under Rule
11(b) for at least one, if not both, of the filings were objectively false at the time they were made.

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court.
A party cannot simultaneously be, and not be, an appellee. Cf., George Orwell’s 1984
newspeak—up is down, hot is cold, and peace is war.

• Adjudicative Effect: This establishes a per se violation of Rule 11(b)(2) and 11(b)(3), as
no reasonable inquiry could support two mutually exclusive legal and factual positions.
• FRE 201(c)(2) Confirmation Source: A direct comparison of the legal arguments and
requirements of Dkt. 45 and Dkt. 46.

Fact #10: The Vexatious and Bad-Faith Nature of the Filings.

The cumulative effect of filing a procedurally premature (Fact #6) and constitutionally
unsupported (Fact #7) motion for sanctions (Dkt. 46) that makes a binding judicial admission (Fact
#5) directly refuting the central premise of its companion brief (Dkt. 45, Fact #4) constitutes a
manifest abuse of the judicial process, demonstrates objective bad faith, and vexatiously multiplies
the proceedings in violation of the standards set forth in Rule 11(b)(1)-(4) and 28 U.S.C. § 1927.

• Adjudicative Effect: This ultimate fact, derived from the preceding nine, compels a
finding that the SBGA Appellees' litigation conduct is sanctionable.
• FRE 201(c)(2) Confirmation Source: The logical synthesis of Adjudicative Facts 1
through 9 as established by the record and analyzed in Part 19 Doc. 02-E.2.

[End of document]

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court.