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October 4, 2019
This follow-up communication to the Plaintiff’s September 25, 2019 letter [Ref. ECF No. 160]
is respectfully delivered to your Honor’s direct attention to update the Court on recent
developments in the above-referenced civil complaint. Please be advised of the following:
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I. The Defendant’s Timeline for Reaching a Mutual Agreement has Expired – as stated in
the 9/25/19 letter to your Honor, the Plaintiff had in Good Faith, extended an opportunity to
reach a mutual agreement with ALL FOURTEEN (14) Defendants associated with the
referenced Docket:
1. WELLS FARGO NA;
2. US BANK NA;
3. COMMONWEALTH OF MASSACHUSETTS;
4. FORMER MASSACHUSETTS AG - MARTHA COAKLEY;
5. HARMON LAW OFFICES, PC;
6. NELSON MULLINS, LLP;
7. PETER HALEY, Esq. (Nelson Mullins, LLP);
8. DAVID E. FIALKOW, Esq. (K&L Gates, LLP);
9. JEFFREY S. PATTERSON, Esq. (K&L Gates, LLP);
10. KURT R. MCHUGH, Esq. (Harmon Law Offices, PC);
11. KEN DAHER (Real Estate Broker, Weichert Realters/Daher
Companies);
12. Mary Daher (Real Estate Broker, Weichert Realters/Daher
Companies);
13. JEFFREY PERKINS; and
14. ISABELLE PERKINS
Previously, it was reported to your Honor that Bank Defendants – WELLS FARGO and
US BANK had expressed an interest in having a mutual agreement discussion. Despite the
Defendants statement of record, they have failed to timely provide the Plaintiff with a
settlement proposal. Therefore, the offer has expired and is off the table. Similarly,
Defendants – Jeffrey and Isabelle Perkins had expressed an interest in having a mutual
agreement discussion and have also failed to timely provide the Plaintiff with a settlement
proposal.
The remaining Defendants have failed to respond all together. That includes the Defendant –
Commonwealth of Massachusetts, where the Plaintiff’s numerous efforts to communicate
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with: (1) representing counsel – Assistant AG Jesse M. Boodoo; (2) MA Attorney
General Maura Healey; (3) Governor Charlie Baker (R-MA); and (4) Massachusetts
Congressional Leaders including US Senator (and 2020 Presidential Candidate)
Elizabeth Warren have been blatantly ignored. Rather than work together to resolve these
serious legal issues, leaders of this Commonwealth (and all Defendants) appear intent on
aligning with disqualified judicial offers who have (as a matter of record) exemplified
patterns of corrupt conduct – including (but not limited to) evidenced acts of TREASON
against The United States of America. The most recent judicial failures evidenced on this
docket - by RECUSED US District Court Judge – the Hon. Allison Dale Burroughs,
were previously brought to your Honor’s attention in the referenced letter, delivered
September 25, 2019.1 Therefore, the Plaintiff respectfully requests that your Honor first
assist with restoring jurisdiction over this docket.
II. The Plaintiff will Next Seek to Amend his Original Complaint – Once jurisdiction has
been restored (and after this Court has VOIDED all judgements issued by disqualified
judicial officers), the Plaintiff intends to amend his original complaint, pursuant to Fed. R.
Civ. P. 60(b)(2) & (3). It should appear clear to this Court (and to any objective observer)
that ALL Defendants – including: (1) the Commonwealth of Massachusetts; (2) ALL
representing counsel of record; and (3) their respective law firms appear intent on aligning
with the VOID decisions of DISQUALIFIED judicial officers who have (as a matter of
record) evidenced acts of Treason against The United States.
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Following her sua sponte recusal on June 19, 2017, US District Court Judge – Hon. Allison Dale Burroughs issued
an order on July 29, 2019 WITHOUT JURISDICTION, denying the Plaintiff’s Motion [Ref. ECF No. 157]. On
August 5, 2019, a second VOID order was issued without jurisdiction [Ref. ECF No. 158]. Both of these actions
are interpreted as clear (and incremental) violations to ARTICLE III and 18 U.S. CODE § 2381 - JUDICIAL
TREASON.
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6. Jeffrey B. Loeb, Esq. (Rich May, PC); and
7. Matthew Murphy, Esq. (Casner & Edwards, LLP)
It also should appear clear to ANY objective observer who has thoroughly researched the
historical record – that collectively, these parties are clearly in “LOCK-STEP” to successfully
commit Fraud Upon this Court. The overall INTENT to consciously commit this Fraud is (at
minimum) believed to be twofold:
A. To Prevent Legal Precedent from being Set – as it pertains to the illegal securitization
of mortgages and other crimes identified with the 2008 US Foreclosure Crisis; and
B. To Irreparably Damage the Plaintiff’s Intellectual Property/Trade Secret – known
as “THE HARIHAR FCS MODEL©” which was designed to assist The United States
with Economic growth and recovery from damages resulting from the 2008 Foreclosure/
Financial Crisis - and is ultimately protected under the Economic Espionage Act.
III. Upholding Fed. R. Civ. P. 60(b)(3) – Once jurisdiction has been restored, if the named
Defendants (including parties still to be added as Defendants) do not wish to enter into a
mutual agreement with the Plaintiff – and instead insist on maintaining their current position,
this Court must ultimately uphold the Plaintiff’s evidenced (and UNOPPOSED) Fraud on
the Court claims(s); bringing a Default judgement in favor of the Plaintiff with prejudice.
The related Criminal and Professional complaints of record – against all parties will also
need to be addressed by: (1) this Court; (2) the Department of Justice (DOJ); (3) the Board of
BAR Overseers/BAR Council; and (4) the National Association of Realtors (NAR).
IV. Assistance with the Appointment of Counsel, 28 U.S.C § 1915- The Plaintiff respectfully
reminds your Honor that he is a Pro Se litigant with NO LEGAL EXPERIENCE. While the
historical record shows a TEXTBOOK reason for this Court to exercise its discretion and
assist the Plaintiff with the appointment of counsel, it MAY be considered moot once Federal
Rule 60 is upheld.
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Please be advised, the referenced litigation is related to a new complaint now being prepared
for filing in The United States Court of Federal Claims; and includes matters perceived to
necessarily receive copies of this formal letter (via email, US Mail and/or social media):
Copies of this Letter will separately: (1) be included in a NOTICE filed with the Court; (2) be
delivered via email communication to the Court Clerk(s); and (3) will also be made available to
the Public and to media outlets nationwide for documentation purposes and out of continued
concerns for the Plaintiff’s personal safety and security. If your Honor has ANY questions
regarding any portion of this letter, or requires additional information, the Plaintiff is happy to
provide upon request. The Plaintiff is grateful for your Honor’s consideration of this very serious,
Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
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617.921.2526 (Mobile)
Mo.harihar@gmail.com