FOR IMMEDIATE RELEASE

Reconsideration request by Wells Fargo & US Bank is

Denied. Decision allowing pro se MA foreclosed
homeowner to file for new trial - Stands.

Boston, MA, July 17, 2014 Last Thursday, the MA Appeals Court denied a motion filed by 2 out of
3 Appellees Wells Fargo NA and US Bank, requesting that the Court reconsider its decision granting
foreclosed homeowner Mohan A. Harihar (Appellant), leave to file for new trial, thus allowing the
initial ruling to stand. The 3
rd
Appellee, Harmon Law Offices PC, who is also the originally retained
counsel for US Bank in this matter, elected not to align with this reconsideration request.
1


As prelude to filing for new trial, Mr. Harihar has filed a motion requesting to initiate a validation
process, which will include concerns related to due process, infringement of intellectual property,
and the resulting impact to Court decisions when information is not validated, not supported,
or not even produced. A recap of this validation is expected to determine whether a corrective path is
attainable in the Commonwealth of Massachusetts, or if transfer to Federal Court and involvement of
the MA/US Inspectors General is deemed necessary.
2


As the impact of the US Foreclosure Crisis continues to be Headline News, this growing storyline
continues to become more complex, as acts of deception appear to continue with the attempted re-
sale of the referenced foreclosure. Regarding the Ethics Complaint filed with the Northeast Association
of Realtors (NEAR), the 7/14/2014 meeting by the Grievance Committee has determined potential
Ethics violations by the associated listing Real Estate Broker/Agent representing the Appellees
(US Bank NA, Wells Fargo NA) and is moving forward with charging violations of the NAR Code
of Ethics, Articles 1, 2, and 12 against the listing Broker/Agent(s).
3
Further investigation and
validation pertaining to the listing of the referenced foreclosure is expected to reveal acts of deception
by these Appellees (Wells Fargo NA and US Bank NA) appear to continue, and include the aid of the
listing real estate broker/agent(s). Upon filing for new trial, Mr. Harihar intends to amend filing to
include ANY additional parties who have willfully chosen to align themselves with the referenced
misconduct.

For additional information regarding this growing storyline, follow on Twitter:
Mohan Harihar@Mo_Harihar


1
Additional information can be viewed in the previous 7/12/14 Media Alert - Foreclosed Homeowner calls for
VALIDATION, & keeps multiple parties informed, including the EOP http://www.scribd.com/doc/233619077
2
A copy of the Motion filed with the MA Appeals Court requesting validation is attached in its entirety (below
scroll down to view).
3
See attached Motion, Exhibit B, letter received recapping the 7/14/2014 NEAR Grievance Committee meeting,
followed by the NAR Code of Ethics, highlighting the articles of alleged violations by the listing
Broker/Agent(s).
2
COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX APPEALS COURT OF
THE COMMONWEALTH
DOCKET NO: 2013P1829

MOHAN A. HARIHAR

Appellant

vs.

US BANK NA,
WELLS FARGO NA,
HARMON LAW OFFICES PC, et al.

Appellees


MOTION - APPELLANT REQUEST FOR ORDER TO INITIATE VALIDATION
PROCESS

As follow-up to this Courts 7/17/14 decision on paper #19
allowing the Appellants leave to file for new trial to stand,
and in effort to ensure accuracy of information moving forward
in this legal process, a motion is respectfully filed with the
Court, requesting an order to initiate a validation process to
include the following:

1. An order for the production and validation of consistently
requested Discovery evidence the recorded conversations
during the 22-month loan modification process, between the
Appellee - Wells Fargo NA (Mortgage Servicer) and the
Appellant Mohan A. Harihar, which are believed to
support (at minimum) Deceptive Practices (G.L. c. 93A,
2)by the Appellee(s). The purpose of the Order is to
additionally validate if these recordings still exist or
if they have been tampered with, destroyed, lost, etc

2. Validation regarding signatures on file.

3. Validation regarding Chain of Title.

4. Due to the potential complexity of validation, the
Appellant additionally requests an order for assistance
from the Internal Revenue Service (IRS), and also the
Securities and Exchange Commission (SEC), particularly
3
with validation concerns surrounding the associated
Securitized Mortgage Trust CMLTI 2006-AR1.

5. An order for subpoenaed testimony from MA Attorney General
Martha Coakley regarding the relationship of this matter
to the 3+ year ongoing investigation of APPELLEE - Harmon
Law Offices PC.
4


6. An order for Appellees to provide sworn testimony
supporting all claims on file pertaining to alleged
harassment, dis-interest, etc...According to the
Appellees, these claims stem from parties including the MA
Attorney General, members of the media, and other
lenders/mortgage servicers found to have committed
unsafe/unsound mortgage serving and foreclosure practices.

7. Completion of the VALIDATION QUESTIONNAIRE previously
provided to the Appellees, which Apellees (Wells Fargo NA
and US Bank NA) have historically refused to answer.
5


8. Validation of 14
th
Amendment infractions, pertaining to
Due Process and Equal Protection Rights of the Appellant,
Mohan A. Harihar.
6


9. A recap of the validation results, comparing these results
to the information initially filed by the Appellees with
the Court. This recap will additionally aid with
determining next steps pertaining to:

a. A better understanding of whether or not a corrective
path is attainable within this Commonwealth or if
transfer to Federal Court and involvement of the MA/US
Inspectors General is deemed necessary.
b. Addressing State and Federal Criminal Charges against
referenced parties, regarding criminal complaints

4
See - Docket No. 12-P-407, Harmon Law Offices vs. Attorney
General, filed with this Appeals Court. A recent unanimous
ruling by this Appeals Court affirmed a 2011 Suffolk Superior
Court decision allowing the MA Attorney Generals office to
continue examining Harmon Law Offices for alleged unfair and
deceptive acts related to the firms foreclosure and eviction
work.
5
See Exhibit A Clarification request, Questionnaire, and
Refusal to Clarify Notice.
6
See Appellant Brief associated with this Docket No: 2013-P-
1829 for further detail, pages 13, 21, and 42-45.
4
already filed with the MA Office of the Attorney
General and Fraud Investigations Unit of the FBI.
c. Follow-up by the Court regarding Counsel accountability
and complaints already filed with the MA Board of Bar
Overseers/Bar Council against the following parties:
Attorney David E. Fialkow (Partner, Nelson Mullins
Riley & Scarborough LLP), Peter Haley (Managing
partner, Boston Office Nelson Mullins Riley &
Scarborough LLP), Nelson Mullins LLP in its entirety,
and Harmon Law offices PC.
d. Concerns surrounding the related Summary Judgment
associated with Docket No. 2012-P-1515, and
additionally Docket No. 2013-P-0671.

10. Appellant additionally seeks to introduce a special
prosecutor to address the number of concerns (on multiple
levels), involving the infringement of intellectual
property of the Appellant, and increased risk to a project
designed to assist the US and overall global economic
recovery, as detailed in the filed Appellant Brief to
Docket 2013-P-1829.


Mr. Harihar respectfully requests an immediate reversal of the
associated eviction order, based on the irrefutable 14
th

Amendment infractions to due process, thus allowing the
Appellant to rightfully return to his home, while this legal
matter proceeds, and for Appellees to incur all costs
associated with the Wrongful Displacement of the Appellant.

Since the initial decisions rendered in the Lower Courts, and
with the overwhelming amount of information which has come
forth since, it has become clear that one side has been
truthful with the Court(s), and one side has not. Validation
will make clear that distinction.

Finally, and as follow-up to the originally filed motion for
new trial, the Appellant informs the Court of the following:

1. As of July 9, 2014 at 5pm EST, no reply was received
pertaining to the final opportunity to voluntarily seek
agreement afforded to Appellees US Bank NA and Wells
Fargo NA (see original motion). That offer is now
considered VOID. This validation process will reveal the
number of opportunities afforded to these Appellees in
effort to seek agreement for harm and accruing damages,
all of which have been either declined or simply ignored.
5

2. Regarding the Ethics Complaint filed with the Northeast
Association of Realtors, the 7/14/2014 meeting by the
Grievance Committee has determined potential Ethics
violations by the associated listing Real Estate Broker
representing the Appellees (US Bank NA, Wells Fargo NA)
and is moving forward with charging violations of the NAR
Code of Ethics, Articles 1, 2, and 12 against the listing
Broker/Agent(s).
7
Further investigation and validation
pertaining to the listing of the references foreclosure is
expected to reveal that acts of deception by these
Appellees (Wells Fargo NA and US Bank NA) appear to
continue, and include the aid of the listing real estate
broker/agent(s). Upon filing for new trial, this Appellant
intends to amend filing to include ANY additional parties
who have willfully chosen to align themselves with the
referenced misconduct.

3. New Evidence continues to come forth Since the
Appellants filing request for new trial, new evidence has
again come forth, involving Appellee - US Bank vs. Mary
McCulley, Docket No. DV 09-562C, the Honorable John C.
Brown presiding. The jury rendered its verdict and found
that Defendant: US Bank committed fraud and constructive
fraud against Plaintiff Mary McCulley and that the fraud
and constructive fraud injured and caused damage to Ms.
McCulley. The jury also rendered its verdict that found US
Bank liable for punitive damages.


Thank you for your attention to this matter.


Respectfully Submitted,


Mohan A. Harihar
168 Parkview Avenue
Lowell, MA 01852




7
See Exhibit B, letter received recapping the 7/14/2014
Grievance Committee meeting, followed by the NAR Code of
Ethics, highlighting the articles of alleged violations by the
listing Broker/Agent.
6

























EXHIBIT A
























7


July 16, 2013
Nelson, Mullins, Riley & Scarborough, LLP
Attn: David Fialkow FOR DOCUMENTATION PURPOSES
One Post Office Square, 30
th
Floor
Boston, MA 02109
RE: CLARIFICATION REQUESTED

VIA US MAIL

Attorney Fialkow:
As representing counsel in active litigation against Mohan A. Harihar, you are instructed to forward a copy of this
Communication to your respective clients US Bank NA and Wells Fargo NA.
After reviewing the collective documents submitted to the Court(s) by you (David E. Fialkow) on behalf of your clients Wells
Fargo NA and US Bank NA, there are numerous statements contained within that I wish to clarify, so that there are no
misunderstandings as we move forward with the Legal process.
For simplicity, a separate questionnaire has been prepared which lists the areas requiring clarification (see attached). After each
question, space has been provided for your response. Once completed, please mail back a signed hardcopy to my attention.
Please be advised, other parties are included in this communication including: The Massachusetts Attorney Generals Office
(Criminal Bureau), other government officials, other Lenders and Mortgage Servicers associated with unsafe and unsound
mortgage servicing and foreclosure practices, and numerous members of the media. In addition, a copy of this communication
and your subsequent reply will be filed with both the Massachusetts Appeals Court as well as the Middlesex Superior Court, to
assist with the Legal process as it moves forward.
Thank you in advance for your cooperation.

Sincerely,
Mohan A. Harihar
168 Parkview Avenue
Lowell, MA 01852
617.921.2526 (Mobile)





Mohan A. Harihar
168 Parkview Avenue
Lowell, MA 01852
617.921.2526 (Mobile)
8
REQUESTED CLARIFICATION OF STATEMENTS REGARDING HARIHAR vs.
WELLS FARGO NA, US BANK NA, et al.
The following questions are raised by Mohan A. Harihar following a review of statements contained within Court
documents, made by US Bank NA and Wells Fargo NA, on behalf of their retained counsel David E. Fialkow of Nelson
Mullins Riley and Scarborough LLP, in active litigation against Mohan A. Harihar. These documented statements require
further clarification for the record, as they are either unsupported, or where evidence/information supporting Mr. Harihars
consistent claims are ignored and/or unanswered. Mr. Harihar requests clarification for the record to assist the legal process
moving forward. Please be advised, as with prior communications, additional parties will receive this communication.
Parties include (but are not limited to): The Massachusetts Office of the Attorney General (Criminal Bureau), select
government officials, select members of the media, other Lenders and Mortgage Servicers found to have committed unsafe and
unsound mortgage servicing and foreclosure practices, and other employees of Nelson Mullins LLP, for the purpose of
forwarding to senior management.

Please provide clarification in the spaces provided (highlighted in RED). Upon completion, please sign, date, and return by
mail three (3) hardcopies to Mr. Harihars attention. Two (2) copies will be filed with the Courts (MA Appeals Court and
Middlesex Superior Court), and Mr. Harihar will retain one copy on file.

Are both US Bank NA and Wells Fargo NA maintaining the position that there is NO misconduct associated with the
referenced foreclosure, or with any circumstances leading up to/or following the foreclosure, including the 22-
month Loan modification process?


[Click to type your response]


Is counsel maintaining that there is NO misconduct or deceptive practices associated with the conversations that
took place between the servicer Wells Fargo NA and Mr. Harihar during the 22-month loan modification
attempts? If so, please provide a detailed explanation why Discovery requests by Mr. Harihar throughout this
litigation, to produce these recorded conversations (in order to validate) has been repeatedly refused for over
two (2) years?


[Click to type your response]



Please explain counsels reason(s) for refusing to validate Chain of Title with regard to the referenced property.



[Click to type your response]




Is counsel stating that the Court(s) should uphold decisions made in the infancy stages of this Nations Foreclosure
crisis, when evidence/information now in possession was not yet available, or where counsel repeatedly
refused to provide critical evidence through the Discovery process? If yes, please provide documentation to
support this position.

9


[Click to type your response]

The following questions pertain to documented statements made by retained counsel David E. Fialkow, stating that Mr. Harihars
consistent claims are meritless and baseless.

With regard to the April 2011 investigation/report conducted by Federal Bank Regulators where both US Bank NA
and Wells Fargo NA were among the numerous Lenders and Mortgage Servicers found to have committed
unsafe and unsound mortgage servicing and foreclosure practices, is counsel stating that this report is
considered meritless and baseless?



[Click to type your response]



Please clarify for the record why counsel did not disclose the findings of the 2011 Investigation by Federal Bank
Regulators prior to pursuing legal action against Mr. Harihar, in any Court (Lowell District Court, Northeast
Housing Court, Middlesex Superior Court, and the Massachusetts Appeals Court)?


[Click to type your response]



Is counsel stating that the 2011 investigation by Federal Bank Regulators is incorrect, or that somehow, this
referenced foreclosure has different circumstances than the other 4.2 million affected foreclosures?


[Click to type your response]



Is counsel stating that the Federal Bank Regulators separate investigation of Mr. Harihars Foreclosure (which
stemmed from the 2011 investigation findings, and which resulted in a settlement payment to Mr. Harihar) is
baseless and meritless? It is also noted that the payment issued was an amount greater than the minimum
payment issued to 4.2 million affected recipients, indicating a greater degree of misconduct. Is this fact
considered to be baseless and meritless?



[Click to type your response]



Is counsel stating that the separate class-action litigation involving all fifty (50) Attorneys General, against lenders
including Wells Fargo NA, and which resulted in the National Mortgage Settlement and additional separate
payment to Mr. Harihar, is considered baseless and meritless?



[Click to type your response]



10
Counsels statements characterizing claims as baseless and meritless conflict with statements made by prior
counsel retained by US Bank NA - Harmon Law Offices PC, known to be associated with the vast majority of
58,000 foreclosures throughout the Commonwealth, who stated on multiple occasions before the Lowell District
Court, that Mr. Harihar has valid complaints/concerns. Court transcripts will support. Please explain counsels
change in position and provide documents to support this abrupt change. Also, please explain what
necessitated the withdrawal of Harmon Law Offices PC from this litigation?



[Click to type your response]



The following questions are in response to allegations of threats and harassment, made by US Bank NA, Wells Fargo NA and their
retained counsel against Mr. Harihar. These allegations are completely unfounded, unsupported, and utterly false, and have continued
despite being previously put on notice by Mr. Harihar to cease and desist.
Mr. Harihar has made it abundantly clear to counsel that the facts and documented misconduct associated with the referenced
foreclosure and throughout this litigation will be brought to the Publics attention, for the specific purpose of creating public awareness,
& in effort to assist the 4.2 million other parties impacted by similar misconduct. I f anything, Mr. Harihar has made it a point to over-
communicate and include counsel in most, if not all communications which have been sent to the Office of the Massachusetts Attorney
General Criminal Bureau, select government officials, select media personnel, additional employees of Nelson Mullins LLP, and other
lenders and mortgage servicers also found to have committed unsafe and unsound mortgage servicing and foreclosure practices, even
though there was no requirement to do so.
Of the multiple communications sent to the previously mentioned parties, there has been no response from any party, including the
senior management of Nelson Mullins LLP, to suggest harassment, disinterest, etcas is stated and suggested by Attorney Fialkow.


Has counsel received communication from the Massachusetts Office of the Attorney General stating that Mr.
Harihars communications are harassing, or that they are disinterested in learning more about the misconduct
associated with this litigation? If so, please provide documentation to support these statements.



[Click to type your response]




Has counsel received communication from any of the media sources stating that Mr. Harihars communications are
harassing, or that they are disinterested in learning more about the misconduct associated with this litigation? If
so, please provide documentation to support these statements.


[Click to type your response]



Has counsel received communication, from the other Lenders and Mortgage Servicers (Listed on the Federal
Reserve Website), found to have committed unsafe and unsound mortgage serving and foreclosure practices,
stating that Mr. Harihars communications are harassing, or that they are disinterested in learning more about
the misconduct and increased Lender risk associated with this litigation? If so, please provide documentation
to support these statements.

[Click to type your response]

Has counsel received communication from any of the other government officials stating that Mr. Harihars
communications are harassing, or that they are disinterested in learning more about the misconduct associate
with this litigation? If so, please provide documentation to support these statements.

11


[Click to type your response]




I t has been specifically communicated to attorney David E. Fialkow on numerous occasions that the documented misconduct associated
with this ongoing litigation is believed to exist not only with US Bank NA and Wells Fargo NA, but also their retained counsel. I t is
unclear at this time, whether the documented misconduct is limited to Attorney David E. Fialkow or if misconduct extends beyond to
include additional members of Nelson Mullins LLP. For this reason, and as previously communicated to counsel, other employees of
Nelson Mullins LLP are copied on communications for the specific purpose of forwarding to senior management. Ongoing investigations
which include the Office of the Attorney General Criminal Bureau are expected to assist in determining the depth of misconduct.

Is counsel stating that communications intended for Senior Management of Nelson Mullins LLP are harassing, or that
Senior Management of Nelson Mullins LLP is disinterested in learning more about the misconduct and
increased legal risk associated with this litigation? If so, please provide documentation to support these
statements. Additionally, if there are alternative email addresses for specific Senior Managers of Nelson Mullins
LLP, including Human Resources, which are preferred for future communications, please provide that
information as well.



[Click to type your response]
The following questions pertain to documented statements made by Attorney David E. Fialkow, stating that Mr. Harihar has made all
sorts of baseless claims about criminal, civil, and bar complaints and investigations.
To be clear, Mr. Harihar understands this is a very serious matter, and documented complaints were not filed until documents supporting
definitive misconduct were in possession.
I t is a fact, that Mr. Harihar has filed a detailed criminal complaint with the Massachusetts Attorney General Criminal Bureau, and has
in possession documentation believed to irrefutably support criminal and civil misconduct against US Bank NA as trustee, the associated
securitized mortgage trust, Wells Fargo NA, and their retained counsel. I f any party chooses to validate this fact, they may wish to call the
Massachusetts Office of the Attorney General directly 617.727.2200 (Phone), and their Boston office is located at One Ashburton Place,
Boston, MA 02108-1518.


Is counsel stating or suggesting that Mr. Harihar has not filed a criminal complaint with the Massachusetts Attorney
General Criminal Bureau, and that there is no documented evidence of criminal misconduct to support this
complaint?


[Click to type your response]


I t is a fact that, Mr. Harihar has filed a complaint against Attorney David E. Fialkow, of Nelson Mullins Riley and Scarborough LLP,
with the Massachusetts Board of Bar Overseers/Bar Counsel, for documented misconduct, has had multiple conversations with the Bar
Counsel regarding this matter, and has informed the Bar Counsel that additional complaints regarding incremental counts of both civil
and criminal misconduct against David E. Fialkow are expected and are likely to follow. I f any party chooses to validate this fact, they
may wish to call the Massachusetts Board of Bar Overseers/Bar Counsel directly 617.728.8700 (Phone), and their office is located at 99
High Street, Boston, MA 02110.

Is counsel stating or suggesting that a complaint has not been filed with the Massachusetts Board of Bar
Overseers/Bar Counsel against David E. Fialkow, and that there is no documented evidence already provided
to the Counsel to support misconduct

[Click to type your response]


I t is a fact that counsel has been made aware by Mr. Harihar that, with documented misconduct now in possession, a review of all related
court documents/transcripts submitted over the past two (2) years is under review, and is believed to now constitute numerous counts of
misconduct including (but not limited to) slander and defamation against Mr. Harihar. Court documents include ongoing active litigation
within the Massachusetts Appeals Court and the recently filed Appeal Brief/Appendix filed by counsel associated with Appeal 1 of 3.
Since this is the first of three Appeals on file with the Court, counsel is expected to file two (2) additional Briefs as required. Once all
12
Court documents are submitted and reviewed, misconduct associated with (but not limited to) slander and defamation is expected to be
addressed collectively either by New Trial (if granted by the Court) or in a separate civil complaint.


If there is any confusion regarding forthcoming litigation against all related parties, please advise.


[Click to type your response]

I t is a fact, that the misconduct associated with the referenced parties and subsequent damages to Mr. Harihar initiated what has now
been nearly five (5) years of research into this Nations Foreclosure Crisis, and has resulted in the development of two (2) separate
projects, for the specific purpose(s) of assisting those individuals impacted by this Foreclosure Crisis (for reference, entitled Project 1), as
well as providing an economic plan designed to assist with the nations recovery (for reference, entitled Project 2). Both projects are
considered the intellectual property of Mohan A. Harihar (Founder HFA llc, Copyright, All Rights Reserved, Patent pending).
Over the past two (2) years, Mr. Harihar has presented this economic plan to multiple parties including:

1. A Senior member of the House Finance Committee (Washington, DC)
2. Two (2) Attorneys General
3. Two (2) State Senators
4. A Secretary of State
5. A Congressional Office
6. A Lender Senior VP of Risk Compliance
7. The Chairman of a nationally ranked Strategic Communications firm.

This economic project has also reached a select office of the current Presidential administration, and a presentation is now being
prepared for a member of the US Senate. All meetings are documented, and ALL parties have responded favorably.
While it was not initially intended or considered necessary to inform the Court(s) of Mr. Harihars related projects, the ongoing attempts
by counsel to discredit Mr. Harihar have now made it necessary to provide this overview, restating that both projects are considered the
intellectual property of Mohan A. Harihar.
This matter now extends far beyond a singular wrongful foreclosure.
Is counsel stating that Mr. Harihar should not be allowed to assist those parties affected and harmed by this Nations
Foreclosure Crisis? Or, is counsel suggesting that Mr. Harihar has not been involved with two (2) separate
projects stemming from this Nations Foreclosure Crisis? Please explain.

[Click to type your response]




A significant portion of this matter is still being assembled and is forthcoming, involving the process and facts associated with the
securitization of mortgages and the securitized mortgage trust referenced in litigation against Mr. Harihar CMLTI 2006-AR1 .Since
numerous questions and concerns continue surround this securitized trust, a report is being filed with the I nternal Revenue Service (IRS)
to assist with clarification.





Thank you for your assistance with this clarification. Please sign and date upon completion (below).



_______________________________________ _________________
Signature Date







COMMONWEALTH OF MASSACHUSETTS

13
MIDDLESEX, SS SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO.: 11-04499



MOHAN A. HARIHAR

Plaintiff/Appellant

vs.

WELLS FARGO NA, US BANK NA as Trustee, et al.

Defendants/Appellees








NOTICE REGARDING CLARIFICATION REFUSAL BY APPELLEES/DEFENDANTS

After a review of the Defendants/Appellees opposition to the associated Motion being filed with this Court, Notice is hereby respectfully
submitted by the Plaintiff/Appellant, MOHAN A. HARIHAR, notifying the Court of the following:

1. Refusal to Clarify Statements - With regard to the associated Motion requesting a Court order against
Defendants/Appellees (submitted in accordance Superior Court Rule 9A), the request made by Mr. Harihar, for the
clarification of multiple statements, as articulated in the Motion and additionally communicated in separate Notices filed
with both this Court, as well as the Appeals Court this clarification for the record has been clearly ignored by the
Defendants/Appellees, and is viewed by Mr. Harihar as a refusal to clarify information critical to facts pertaining to this
Motion and the overall case.


This further exemplifies the tactics used by the Defendants/Appellees in effort to suppress the validation of facts associated with this case(s).
A review of the Defendants filed opposition reveals the absolute necessity for clarification.

Mr. Harihar respectfully requests that the Court take this latest action by the Defendants into account when considering this Motion and
Court Order.
















Respectfully Submitted,




Mohan A. Harihar
168 Parkview Avenue
Lowell, MA 01852





14






















EXHIBIT B


























15



July 21, 2014

Mohan Harihar
168 Parkview Avenue
Lowell, MA 01852

RE: Ethics Complaint: M. Harihar vs K. Daher and M. Koontz

Dear Mohan:
I am writing to you to inform you that the NEAR Grievance Committee has met and reviewed the complaint
referenced above and has recommended that the case be forwarded to the NEAR Professional Standards
Committee for a hearing. The Grievance Committee amended the complaint by deleting Articles 3, 11, and
14. Therefore, the complaint will go forward charging a violation of Articles 1, 2, and 12 against the
REALTOR that you named in your complaint.
I have enclosed a copy of Form E-22, Appeal of the Grievance Committee Dismissal of Ethics Complaint.
Should you choose to appeal the deletion of articles from your complaint, you would cite the articles that you
believe should have remained in the complaint, and they would be forwarded for review by our Board of
Directors Professional Standards Tribunal with your complaint. No new information may be added or
attached to the form, and the directors may consider only the documents the Grievance Committee reviewed
in making its determination. Should you choose to appeal, Form E-22 must be filed within 20 days of your
receipt of this letter.
Should the appeal period pass without an appeal, I would then forward a copy of the complaint with a
reply form to the respondent, and when the reply is received, I would forward a copy of it to you.
Additionally, both parties would then be given the opportunity to challenge any of the potential
panelists for the hearing.
In the meantime, should you require additional, please dont hesitate to contact me anytime at
978/577-6138 x15.

Best regards,




Sharon Sarvela
Member Services Coordinator & Professional Standards Secretary

enc.




16

17



18