COMMONWEALTH OF MASSACHUSETTS

THE TRIAL COURT

MIDDLESEX SUPERIOR COURT

) CIVIL ACTION NO. 1981-CV-00050

MOHAN A HARIHAR )
)
Plaintiff )
)
v. )
)
WELLS FARGO NA, et al. )
)
Defendants )
)
)

PLAINTIFF REPLY TO DEFENDANTS’ OPPOSITION RE:

VOID LAND COURT ORDER AND ADDITIONAL DOCUMENTS

FILED 01/31/19

On February 1, 2019 the Plaintiff – Mohan A. Harihar received six (6) separate documents from

counsel representing the Defendants - Jeffrey/Isabelle Perkins and MERS Inc:

1. Motion for Entry of Separate and Final Judgment;

2. Memorandum in support of Motion for Entry of Separate and Final Judgment;

3. Affidavit of compliance with Superior Court Rule 9A;

4. Objection to The Plaintiff's Emergency Notice of Void Land Court Order;

5. Motion for reconsideration; and

6. Affidavit of compliance with Superior Court Rule 9A

After reviewing the Defendants’ filed opposition, the Plaintiff - Mohan A. Harihar disagrees, as

its content continues to exemplify deceptive tactics and (at minimum) shows cause to expand

upon – Fraud on the Court claims here, under Mass. R. Civ. P. 60(b)(3) and similarly in the

related federal litigation under Fed. R. Civ. P. 60(b)(3) - referencing HARIHAR v US BANK et

al (Appeal No. 17-1381). The Plaintiff respectfully reminds this Court of the following facts of

record:

1. The Plaintiff has clearly articulated for the record the judicial failures of the presiding

MA Land Court Judge – Hon. Michael Vhay, who lost jurisdiction to issue a dismissal,

transfer, OR ANY OTHER order associated with this litigation. In their opposition,

Defendants state that, “this is a tactic the Plaintiff resorts to when a court rules against

him.” To the contrary – the mere suggestion that this court should IGNORE the

PLETHORA of evidenced arguments including (but not limited to): (1) JURISDICTION;

(2) Evidenced Failures by MA State Courts; (3) Evidenced Failures by the MA AGO; (4)

Discovery of NEW Evidence and others, shows cause to expand upon (or file NEW)

claims against these parties and their counsel. Even the Bank Defendants – WELLS

FARGO and US BANK have not Filed Opposition to the Plaintiff’s 01/22/19

Emergency Notice;

2. This Court is respectfully reminded that SCOTUS has acknowledged for a SECOND

time, a lengthy list of extraordinary, unresolved issues related to this litigation.1

These issues include PATTERNS OF CORRUPT CONDUCT evidenced by both the

Federal and MA State Judiciaries. This Court’s past erred judgments including the recent

failure (July 2018) to acknowledge and uphold Massachusetts (and Federal) Rules of

1
Reference SCOTUS Applications 17A1359, 18A545 and the Petition for Writ of Certiorari, Petition No. 18-7752,
docketed January 28, 2019.
 Civil Procedure shows cause expand upon existing claims against this Commonwealth

(referencing the Federal litigation, HARIHAR v US BANK et al, Appeal No. 17-1381).2

Please be advised, ANY action(s) by this Court that appears to resemble referenced

patterns of corrupt conduct will show cause to expand upon (or file NEW) legal

claims against the Commonwealth of Massachusetts. Conversely, if this MA Superior

Court begins to finally initiate corrective action for its past erred judgments, the Plaintiff

will address accordingly in the Federal Court.

The Plaintiff respectfully states that until ALL issues from the Plaintiff’s 1/22/19 Notice –

beginning with JURISDICTION are resolved, the Defendant’s Motions for: (1) separate/final

judgment; (2) reconsideration, etc.… should not even be considered and struck from the record.

Based on the Plaintiff’s interpretation of the law, he is under no obligation or legal timeline to

respond to the Defendant’s attempted filings until jurisdiction (and all other) issues are resolved.

Finally, the Plaintiff informs the Court that the deceptive practices exemplified by these

Defendants and their counsel - RICH MAY PC law firm are considered identical (or extremely

similar) to those historically evidenced by counsel for bank Defendants – WELLS FARGO and

US BANK. On February 4, 2019 Attorney Loeb was informed via email3 of the following:

1. A Motion to Amend the original Federal Complaint (associated with Appeal No. 17-

1381) is being prepared to ADD as Defendants – Jeffrey Loeb, Esq. and Rich May PC

2
The Plaintiff references the recent failure by this Court to re-open Docket No. 1181CV04499, after UNOPPOSED
Fraud on the Court claims had been evidenced in the Federal Court. Judge Wall’s explanation of record indicates an
identical pattern of corrupt conduct to that evidenced in the Federal Court – resulting thus far in an unprecedented
eight (8) federal recusals.
3
See Exhibit 1, to view the 02/04/19 email delivered to all Managing Directors/Shareholders of Rich MA PC Law
firm, including Attorney Jeffrey Loeb and referenced government offices/agencies/committees.
 Law firm. Evidenced claims include (but are not limited to): (1) FRAUD ON THE

COURT, under Fed. R. Civ. P 60(b)(3); (2) Economic Espionage claims under 18 U.S.C.

§ 1831; (3) RICO violations and matters perceived to impact National Security.

2. Since this Appeal is currently set for Conference before SCOTUS on February 15,

2019, a supplement to STAY Application No. 18A554 (and also for Certiorari Petition

18-7752) is being prepared for filing;

3. The BAR complaint already filed with the MA Board of BAR Overseers, against attorney

Loeb is being updated. The Plaintiff will plan to file a copy with this Court for the record;

4. The Criminal complaint already filed with the FBI/DOJ against attorney Loeb is being

updated. The Plaintiff will plan to file a copy with this Court for the record. Since the

evidenced criminal claims are perceived to impact matters of National Security, the

following government offices/agencies/committees will necessarily be copied (via email,

US Mail and/or social media):

a. POTUS (via www.whitehouse.gov)4;

b. US Secret Service;

c. Securities and Exchange Commission (SEC);

d. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;

e. Department of Justice (DOJ) - specifically, acting Attorney General, Matthew

Whitaker;

f. FBI;

g. Administrative Office of US Courts - specifically, Director James C. Duff;

h. House/Senate Judiciary Committees;

4
See Exhibit 2
 i. Governor Charlie Baker (R-MA);

j. US Senator Elizabeth Warren (D-MA);

k. US Senator Ed Markey (D-MA);

l. US Congresswoman Lori Trahan (D-MA); and

m. The MA Board of BAR Overseers

Copies of this email will also be made available to the Public and to media outlets nationwide

out of continued concerns for my personal safety and security. If your Honor has any questions

regarding any portion of this Reply, or requires additional information, the Plaintiff is happy to

provide upon request.

The Plaintiff is grateful for this Court’s consideration.

Respectfully submitted,

Mohan a. Harihar
Plainitff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526
Mo.harihar@gmail.com

February 7, 2019
Exhibit 1
 Mohan Harihar <moharihar@gmail.com>

Intention to File Suit and Criminal Complaints against Rich May PC Law
Firm
Mohan Harihar <moharihar@gmail.com> Mon, Feb 4, 2019 at 2:17 PM
To: "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, tbilodeau@richmaylaw.com, skane@richmaylaw.com,
nkensington@richmaylaw.com, ekrathwohl@richmaylaw.com, wlandergan@richmaylaw.com,
elyne@richmaylaw.com, rtedesco@richmaylaw.com
Cc: lwood@supremecourt.gov, NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>,
pacermail@psc.uscourts.gov, theresa.watson3@usdoj.gov, andrew.lelling@usdoj.gov,
mary.murrane@usdoj.gov, christina.sterling@usdoj.gov, chairmanoffice@sec.gov,
CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov, CommissionerStein@sec.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
elizabeth_warren@warren.senate.gov, Nora_Keefe@warren.senate.gov,
Nairoby_Gabriel@warren.senate.gov, scheduling@warren.senate.gov, sydney_levin-
epstein@markey.senate.gov, lori.trahan@mail.house.gov, maura.healey@state.ma.us,
jesse.boodoo@state.ma.us, igo-fightfraud@state.ma.us, ma-igo-general-mail@state.ma.us, Susan
Goldberg <susan_goldberg@ca1.uscourts.gov>

To the Managing Directors/Shareholders of Rich May PC,

This email communication is respectfully delivered to your attention to inform you that a lawsuit
(including criminal complaints) is being filed against your firm, based on the evidenced claims of
misconduct involving Attorney Jeffrey Loeb, Managing Director/Shareholder. These evidenced
claims of record are affiliated with the ongoing Federal litigation - HARIHAR v US BANK et al,
Appeal No. 17-1381; and also ongoing State litigation in the Commonwealth of Massachusetts - (1)
HARIHAR v WELLS FARGO et al, Case No.18MISC000144 (MA Land Court); (2) HARIHAR v US
BANK et al, Case No.'s 1981CV00050 and 1181CV04499 (Middlesex Superior Court). The Defendant
clients represented by the Rich May PC law firm include: Jeffrey/Isabelle Perkins (Lowell, MA) and
MERS, Inc.

Your firm is aware that a list of serious civil and criminal claims have been evidenced (as a matter of
record) against these referenced clients and attorney Loeb, beginning with FRAUD ON THE COURT,
under Fed. R. Civ. P 60(b)(3). You are also aware that as a matter of record, this evidenced claim(s),
stands UNOPPOSED. It is my understanding that any attempt to purposefully deceive the Court for
reasons including (but not limited to) FRAUD automatically waives any attorney/client (or any
other) privilege. Additional claims evidenced against these clients and Attorney Loeb include (but
are not limited to): (2) Economic Espionage claims under 18 U.S.C. § 1831; (3) RICO violations
and matters perceived to impact National Security.

You firm is aware that collectively, there has been an UNPRECEDENTED level of judicial misconduct
associated with this litigation, resulting thus far in: (1) EIGHT (8) Federal RECUSALS; (2) FIFTEEN
(15) evidenced judicial misconduct complaints; and (3) evidenced TREASON claims formally
filed against NINE (9) Federal judges under ARTICLE III, Section 3. Since these evidenced (and
similarly unopposed) claims are part of the record, both Attorney Loeb and the referenced clients are
considered as witnesses and therefore stand accused of Misprision of Treason under 18 U.S.C. §
2382. You are aware that SCOTUS has now TWICE acknowledged a lengthy list of - extraordinary,
unresolved issues that include these referenced claims.

While under no obligation to do so, I've offered your clients and attorney Loeb multiple opportunities
to seek a mutual agreement - all of which have been denied or ignored entirely. It seems clear that
this law firm stands in support of these unlawful acts, led by its Managing Director/Shareholder -
Jeffrey Loeb. Therefore, there is cause to amend the original complaint, associated with HARIHAR v
US BANK et al, Federal Appeal No. 17-1381, adding RICH MAY PC as a Defendant. Since this
Appeal is currently set for Conference before SCOTUS on February 15, 2019, a supplement to
STAY Application No 18A554 is being prepared for filing. Since this ongoing litigation includes
evidenced criminal claims and matters perceived to impact National Security, the following
government offices/agencies/committees will necessarily be copied (via email, US Mail and/or social
media):

1. POTUS (via www.whitehouse.gov);

2. US Secret Service;
3. Securities and Exchange Commission (SEC);
4. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;
5. Department of Justice (DOJ) - specifically, acting Attorney General, Matthew Whitaker;
6. FBI - criminal complaints already filed against Attorney Loeb and referenced clients will be
updated and to include Rich May PC Law Firm;
7. Administrative Office of US Courts - specifically, Director James C. Duff;
8. House/Senate Judiciary Committees;
9. Governor Charlie Baker (R-MA);
10. US Senator Elizabeth Warren (D-MA);
11. US Senator Ed Markey (D-MA);
12. US Congresswoman Lori Trahan (D-MA); and
13. MA Board of BAR Overseers - BAR complaints already filed against Attorney Loeb will be
updated and will include Rich May PC Law Firm;

Copies of this email will also be made available to the Public and to media outlets nationwide out of
continued concerns for my personal safety and security. Thank you for your attention to this very
serious and sensitive matter.

Sincerely,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Exhibit 2
 CERTIFICATE OF SERVICE

I hereby certify that on February 7, 2019, I filed the foregoing NOTICE with the Clerk of the
Court and counsel for the Defendants (listed below) via US Mail:

Jeffrey B. Loeb, Esq.

Rich May, PC
176 Federal Street
Boston, MA 02110
617.556.3871
JLoeb@richmaylaw.com

David E. Fialkow
K&L Gates, LLP
State Street Financial Center
One Lincoln Street
Boston, MA 02111
david.fialkow@klgates.com

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com