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 RESPONSE TO DOCUMENTS FILED 02/22/2019 BY

DEFENDANTS – ISABELLE PERKINS, JEFFREY PERKINS AND MERS INC.

On Monday, February 25, 2019, THIRTY-FIVE (35) days after the Plaintiff – Mohan A.

Harihar evidenced the improper transfer and jurisdiction issues related to this Docket, a Motion

for Summary Judgement (and additional documents) was received from counsel representing the

Defendants – Isabelle Perkins, Jeffrey Perkins and MERS INC.

Respectfully, the Plaintiff first states that it is unclear as to WHAT is causing such a delay for

this Court to address what CLEARLY is: (1) the IMPROPER TRANSFER of this docket from

the MA Land Court; and (2) the lack of JURISDICTION to proceed further until ALL issues

have been justly resolved. There appears however (at least on its surface), to be the

EXPECTATION by ALL Defendants, that these evidenced legal issues will be overlooked

and/or disregarded – questioning whether there is knowledge that the presiding judicial
officer(s) will ultimately brush aside ALL referenced issues in order to reach a CORRUPT

AND PRE-DETERMINED OUTCOME. This has been the common theme – PUBLICLY

EVIDENCED throughout the EIGHT (8) YEAR history of this litigation – that includes

SCOTUS,1 exposing what is now being recognized nationwide as the largest case of judicial

fraud in the history of The United States. It therefore becomes necessary to re-state the

following for the record:

1. The Plaintiff is still waiting for this Court to address the EMERGENCY NOTICE filed

on January 22, 2019 - regarding the improper transfer of this case and referenced

jurisdiction issues for the record before proceeding further. This Court has the complete

docket from the Land Court that includes ALL evidenced arguments that show precisely

how the Plaintiff arrived at his conclusions. The Plaintiff re-states that based on his

interpretation of the law, the referenced notice is considered proper and should not

require submission under Rule 9A for clarifying jurisdiction and transfer issues. Until

these issues are resolved for the record, these proceedings cannot legally move forward.

2. The documents collectively filed by ALL Defendants before jurisdiction (and all other)

issues are justly resolved, indicate (at minimum) the intention to continue deceiving

this (and ALL other related) court(s). The Plaintiff therefore shows cause to expand

upon existing Fraud on the Court claims under Mass R. Civ. P. 60(b)(3) – in ALL

related MA State Courts and similarly under Fed. R. Civ. P. 60(b)(3) in the related

Federal litigation – HARIHAR v US BANK, et al, Certiorari Petition No. 18-7752. A

supplement to the Petition is currently being prepared for filing;

1
SCOTUS – Supreme Court of The United States. The Plaintiff references the recent UNPUBLISHED 02/19/19
decision of Application No. 18A554, which denied the Plaintiff/Petitioner’s request for a STAY of Judgement and
assistance with the appointment of counsel, without cause.
 3. Respectfully, based on the Plaintiff’s interpretation of the law, any judicial officer who

proceeds here before establishing jurisdiction for the record, will be considered to

have warred against the Constitution of The United States – an act of Treason under

ARTICLE III, Section 3. Should this occur (and as required by Federal law), the

Plaintiff will necessarily inform/update Governor Charlie Baker (R-MA) and also the

President of The United States (POTUS). All Defendants, their counsel and the court

clerk(s) will be considered as witnesses. Since the Commonwealth of Massachusetts is

a Defendant in the referenced Federal litigation, it will again become necessary to file

a supplement to Certiorari Petition No. 18-7752;

4. This court is already aware of the severity of evidenced claims raised against more than

FIFTEEN (15) Federal (and State) judicial officers. These evidenced claims have

resulted in an UNPRECEDENTED EIGHT (8) Federal Recusals thus far. Should the

presiding judge here disagree with ANY PART the Plaintiff’s assessment, clarification

will be requested for the record as to how their conclusion was reached (including exactly

which documents were reviewed), as it may (at minimum) bear impact to ongoing

Federal litigation;

5. The Plaintiff necessarily re-states that this Court is aware that criminal complaints have

long been filed with the MA Attorney General’s Office against all listed Defendants and

their retained counsel. This Court is also aware that the Plaintiff has evidenced an

improper relationship between: (1) the MA AGO2; (2) the US Attorney’s Office (MA);

and (3) the former law firm representing Bank Defendants – WELLS FARGO and

US BANK (Referencing Nelson Mullins, LLP, who withdrew from this case). The

2
MA AGO – Massachusetts Attorney General’s Office.
 argument has long been made that this improper relationship/collusion is (at least in part)

the reason why criminal indictments have not been brought against named Defendants

and their counsel. It is also the reason for bringing (at minimum) evidenced Civil RICO

claims under 18 U.S. Code § 1964 in the referenced federal litigation. On Sunday,

February 17, 2019, the Plaintiff sent an email communication to Governor Charlie

Baker (R-MA), informing him of these continued failures by the MA AGO. 3 Upon

establishing jurisdiction, the Plaintiff requests that this Court issue an order that calls for

the MA AGO to clarify for the record their intentions to bring criminal indictments

against referenced parties prior to moving forward with this litigation; and

6. Finally, for the reasons described within, ALL documents filed by the Defendants should

be stricken from the record until jurisdiction (and all other) issues have been resolved.

Since this case is related to the referenced Federal litigation now before The United States

Supreme Court and includes matters perceived to impact National Security, the following

government offices/agencies/committees will necessarily receive copies of this filing (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, US Attorney General, William Barr;

3
See Exhibit 1, to view the email delivered to Governor Baker, followed by the referenced improper relationship
evidenced in the continuing education class entitled, “AFTER THE BUBBLE BURSTS”.
4
See Exhibit 2
 f. FBI;

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

h. House/Senate Judiciary Committees;

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 Response, 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
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
February 20, 2019
Exhibit 1
 Mohan Harihar <moharihar@gmail.com>

CRIMINAL INDICTMENTS - HARIHAR v US BANK et al, Docket No.

1981CV00050
Mohan Harihar <moharihar@gmail.com> Sun, Feb 17, 2019 at 2:37 PM
To: "Constituent.services@state.ma.us" <constituent.services@state.ma.us>
Cc: lwood@supremecourt.gov, NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>,
andrew.lelling@usdoj.gov, theresa.watson3@usdoj.gov, christina.sterling@usdoj.gov,
mary.murrane@usdoj.gov, 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, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, maura.healey@state.ma.us, jesse.boodoo@state.ma.us,
chairmanoffice@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov,
CommissionerStein@sec.gov, Susan Goldberg <susan_goldberg@ca1.uscourts.gov>

Dear Governor Baker,

It again becomes necessary to bring to your attention the evidenced failure(s) of MA Attorney
General MAURA HEALEY - to bring criminal indictments against named Defendants in the above
referenced litigation proceeding in the Middlesex Superior Court. Respectfully, you are aware that
this is nothing new, as I have regularly brought this INACTION to your attention (as a matter of
record) and previously to the attention of Governor Patrick's administration over the past EIGHT (8)
years. You are also aware that it is this continued failure that has shown cause (at least in part) to
include the Commonwealth (and former AG Martha Coakley) as Defendants in the related Federal
Litigation now before SCOTUS (Reference HARIHAR v US BANK et al, Certiorari Petition 18-
7752). You are respectfully reminded that aside from evidenced Color of Law, Due Process and
(Unopposed) Fraud on the Court claims, I have evidenced RICO claims involving: (1) the
Massachusetts AGO; (2) the US Attorney's Office (MA); and (3) the (former) representing law firm for
Bank Defendants - US BANK and WELLS FARGO (Nelson Mullins Riley and Scarborough,
LLP). Click on the attachment below to view the evidenced RICO claim - "After the Bubble Bursts".
This TEXTBOOK case of COLLUSION identifies an IMPROPER relationship that - at least in part,
provides an irrefutable argument as to WHY criminal indictments have NEVER been brought by the
MA AGO.

And then there's the judicial misconduct that has been irrefutably evidenced by both the Federal and
MA State judiciaries - now TWICE acknowledged by the United States Supreme Court. This
includes formal TREASON claims under ARTICLE III, brought against NINE (9) Federal judges. As
required by Federal Law, I have notified you directly following each violation, yet your office
remains silent.

It has NEVER been my intention to expose such historic levels of corruption between BANKING and
GOVERNMENT. Evidenced failures in all three (3) branches of state and federal government is the
reason why we're in this legal position now. I've also never intended to BANKRUPT this
Commonwealth - considering if there is no agreement and the law is actually upheld, the
Commonwealth will be responsible for its portion of $42B (excluding treble damages for
evidenced RICO claims). Again, these evidenced government failures bring us to where we are
today. My legal intentions from the beginning have been quite clear:
 1. To recoup damages from MY ILLEGAL FORECLOSURE - as identified by the MA AGO,
DOJ and Federal Bank Regulators;
2. To recoup damages for MY Intellectual Property/Trade Secret known as the "HARIHAR
FCS MODEL"; and
3. To reach an agreement with the Commonwealth and the Federal Government to potentially
implement this Economic Model - helping all those negatively impacted by illegal
foreclosure while generating historic economic growth for this Commonwealth and the
Nation.

Please be advised, the Middlesex Superior Court has an opportunity now to correct some of its past
erred judgments and I'm now respectfully calling for the MA AGO to TIMELY bring criminal
indictments against ALL named Defendants in the referenced Docket No. 1981CV00050.
Should the Commonwealth initiate such corrective action, I will plan to notify/update SCOTUS via a
supplement to Petition No. 18-7752. Conversely, should this collective pattern of corrupt conduct
continue, SCOTUS will similarly be notified of this NEW evidenced government failure, pursuant to
Fed. R. Civ. P. 60(b)(2).

For documentation purposes, a copy of this email will be filed with the Middlesex Superior Court.
Copies will also be made available to: (1) POTUS
(via www.whitehouse.gov); (2) the US Secret Service/ Department of Homeland Security; (3) the
DOJ; (4) members of Congress; (5) the Public; and (6) to media outlets nationwide out of continued
concerns for my personal safety and security. If you have any questions regarding any portion of this
email, or require additional information, please advise. Governor Baker, thank you for your attention
to this very serious and sensitive matter. I look forward to your response.

GOD BLESS THE COMMONWEALTH OF MASSACHUSETTS AND THE UNITED STATES OF

AMERICA!

Respectfully submitted,

Mohan A. Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526
Mo.harihar@gmail.com

After the Bubble Bursts.pdf

251K
Exhibit 2
 CERTIFICATE OF SERVICE

I hereby certify that on March 1, 2019, I filed the foregoing REPLY 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
617.921.2526 (Mobile)
Mo.harihar@gmail.com