Mohan A.

Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)

November 22, 2019

VIA ELCTRONIC (ECF) FILING

United States District Court
Attn: Clerk’s Office
Suite 2300
1 Courthouse Way
Boston, MA 02210

RE: PLAINTIFF RESPONSE AND EMERGENCY MOTION TO AMEND ORIGINAL

COMPLAINT – HARIHAR v US BANK et al, Docket No. 15-v-cv-11880

Dear Clerk of the Court:

Enclosed, please find the following PLAINTIFF RESPONSE/EMERGENCY MOTION for

filing in the above-referenced Docket. The Plaintiff is first attempting to file electronically via
ECF, assuming his ECF privileges have been justly reinstated. Hardcopies will also be delivered
by US Certified Mail and via email to Clerks – Karen Folan and Tracy McLaughlin. Please also
deliver a hard copy to the direct attention of the Chief Judge – the Honorable Patti B. Saris:

1. PLAINTIFF RESPONSE AND EMERGENCY MOTION TO AMEND ORIGINAL

COMPLAINT PURSIANT TO FED. R. CIV. P. 60(b)(2), (3) and (4)

Please be advised, the referenced Docket is still considered OPEN, as the Dismissal (and all
related) order(s) is VOID, since it was issued by RECUSED US District Court Judge – Hon.
Allison Dale Burroughs [Ref. ECF No. 163). The void order is also considered a clear and
irrefutable violation to ARTICLE III and 18 U.S. CODE § 2381 – JUDICIAL TREASON. Due
to the severity of criminal violations evidenced against Judge Burroughs and other Officers of the
Court, it has become necessary to involve: (1) the Department of Justice (DOJ); (2) The
Administrative Office of US Courts; (3) members of Congress; and (4) The White House. Based
on my interpretation of Federal Law and the Rules of this Court, the Plaintiff respectfully states
that IF the Clerk’s Office refuses to docket the referenced Motion and instead aligns with a
recused judicial officer, there will cause to bring new claims under 18 U.S. Code § 2076,
including Tampering violations under 18 U.S. Code § 1512. Thank you for your attention to this
very serious and sensitive matter.

Respectfully submitted,

Mohan A. Harihar
Plaintiff

1
 UNITED STATES DISTRICT COURT
for the
DISTRICT OF MASSACHUSETTS

)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. 15-cv-11880
v. )
)
US BANK et al, )
)
Defendants )
)

PLAINTIFF RESPONSE TO ECF NO. 163 AND EMERGENCY MOTION TO

AMEND ORIGINAL COMPLAINT PURSUANT TO FED. R. CIV. P. 60(b)(2), (3)
and (4), FOLLOWING EVIDENCED VIOLATIONS TO ARTICLE III AND
18 U.S. CODE § 2381 - JUDICIAL TREASON

The Plaintiff, Mohan A. Harihar, a pro se litigant with no legal experience, respectfully files this

EMERGENCY MOTION, as RECUSED US District Court Judge – Hon. Allison Dale

Burroughs1 continues to issue VOID orders WITHOUT JURISDICTION [Ref. ECF No.

163].2 This latest and very blatant abuse of judicial power evidences for the record this judge’s

NINTH (9th) violation to ARTICLE III AND 18 U.S. CODE § 2381 - JUDICIAL

TREASON. The Plaintiff makes clear that he is once again compelled to report this evidenced

act of Treason to the Court - as required by Federal law, despite being personally threatened

with sanctions by Judge Burroughs [Ref. ECF No. 159].3 Besides bringing these violations to

1
See Exhibit 1, to view the sua sponte RECUSAL order issued by US District Court Judge – Hon. Allison Dale
Burroughs on June 19, 2017.
2
See Exhibit 2, to view the VOID order [Ref. ECF No. 163] issued by RECUSED US District Court Judge –
Hon. Allison Dale Burroughs on October 22, 2019.
3
See Exhibit 3 to view the VOID order [Ref. ECF No. 159] issued by RECUSED US District Court Judge –
Hon. Allison Dale Burroughs on August 5, 2019.
2
the Court’s attention, the Plaintiff has also reported these serious crimes directly to: (1) The

Department of Justice (DOJ)/US Attorney’s Office (MA); (2) The Office of the First Circuit

Executive; (3) The Administrative Office of US Courts; (4) Members of Congress – as these

evidenced crimes also show cause for impeachment and removal from the bench under

ARTICLES II & III; (5) to Governor Charlie Baker (R-MA); and (6) to The President of The

United States (POTUS), as required under ARTICLE III.

A review of the void order associated with ECF No. 163 also shows that the recused/

disqualified judge has instructed the Clerk’s Office not to accept any future filings from the

Plaintiff and has unjustly REVOKED Mr. Harihar’s electronic filing privileges. It appears

that two clerks of the Court – Clerks Karen Folan and Tracy McLaughlin are aligning with

the direction of a recused/disqualified judicial officer. Therefore, the Plaintiff shows cause to

bring new claims against the referenced Court Clerks under 18 U.S. Code § 2076.Clerk of

United States District Court:

“Whoever, being a clerk of a district court of the United States, willfully refuses or neglects to

make or forward any report, certificate, statement, or document as required by law, shall be

fined under this title or imprisoned not more than one year, or both.”

It is unclear whether Clerks Folan and McLaughlin have been pressured by Judge Burroughs (or

any other Court Officer) to commit these violations against their will. The Plaintiff also shows

cause to bring new claims of Tampering violations against Judge Burroughs and both

referenced Clerks under 18 U.S. Code § 1512(b)(2)(A):

3
“Whoever knowingly uses intimidation, threatens, or corruptly persuades another person, or

attempts to do so, or engages in misleading conduct toward another person, with intent to

withhold testimony, or withhold a record, document, or other object, from an official

proceeding.”

Respectfully, these evidenced legal issues (including re-establishing jurisdiction) must first be

addressed and corrected before proceeding further. Additionally, these egregious judicial failures

show cause for the Plaintiff to amend: (1) his original complaint here; (2) his original complaint

against The United States (Ref. HARIHAR v THE UNITED STATES, Docket No. 17-cv-

11109); and (3) his original complaint against disqualified judicial/court officers (Ref.

HARIHAR v HOWARD et al, Docket No. 18-cv-11134), pursuant (at minimum) to Fed. R. Civ.

P. 60(b)(2) – New Evidence:

I. Identical Treason Violations under ARTICLE III committed by Middlesex Superior

Court Judge – Hon. Janice W. Howe (ref. HARIHAR v WELLS FARGO, Docket No.

1981-cv-00050)

As a matter of record, the Plaintiff has historically identified what is considered

IDENTICAL PATTERNS OF CORRUPT CONDUCT by judicial officers in

Massachusetts State Courts. The most recent example occurred just a few days ago, as

disqualified Middlesex Superior Court Judge – Hon. Janice W. Howe ignored evidenced

claims impacting her jurisdiction, issuing a dismissal order on November 1, 2019 (recorded

4
 November 14, 2019, Ref. Document No. 38)4, thereby committing an incremental violation

to ARTICLE III and 18 U.S. CODE § 2381.

In addition to the evidenced Treason claim(s), the record also evidences that Judge Howe

stands formally accused of the following civil/criminal violations:

1. Judicial Fraud on the Court under Fed. R. Civ. P 60(b)(3);

2. Civil (and Criminal) RICO violations under (at minimum) 18 U.S. Code
§ 1964;
3. Color of Law violations under 18 U.S. Code § 242;
4. Due Process violations under the Fifth and Fourteenth Amendments;
5. Ignoring ARTICLE III, 18 U.S.C. § 2381 and 28 U.S.C. § 1446 - as it
pertains to the referenced Federal litigation;
6. Refusing to Recuse;
7. 18 U.S. Code § 2076 - by instructing a Court Clerk – Arthur
Deguglielmo not to accept or Docket filed documents by the Plaintiff;
8. Unnecessary Judicial Delay;
9. Failure to acknowledge and uphold Massachusetts Rules of Civil
Procedure 60(b)(3) - Fraud on the Court, as it pertains to evidenced (and
UNOPPOSED) claims against named Defendants;
10. Ignoring ELEVEN (11) judicial recusals of record (9 Federal, 2 State,
all related to this litigation) and their impact to associated judgements;
11. Refusing to accept the Plaintiff’s arguments as FACT, refusing
DISCOVERY and Refusing to Allow the Plaintiff to Depose Witnesses;
12. Refusing to acknowledge that: (1) the Department of Justice (DOJ); (2)
MA Office of the Attorney General (MA AGO); and (3) Federal Bank
Regulators – have ALL identified the Plaintiff’s referenced Foreclosure as
ILLEGAL;
13. Refusing to re-establish a balance of hardships;
14. Refusing to Acknowledge Public Perception and the
MASSACHUSETTS CODE OF JUDICIAL CONDUCT; and
15. Ignoring Continued Concerns for the Plaintiff’s Personal Safety and
Security

However, ALL evidenced violations (referenced above - and as described in the Plaintiff

Reply to Void Order Issued on 10-3-2019 by Disqualified Judicial Officer - Hon. Janice

W. Howe) were blatantly ignored. As required by Federal law, the Plaintiff has similarly

4
See Exhibit 4 to view the referenced Middlesex Superior Court Docket Sheet, including the evidenced violations
by DISQUALIFIED Judicial Officer – Hon. Janice W. Howe. Also reference Doc. 37 and the Plaintiff’s filed
REPLY, which articulates the evidenced claims which impact the judge’s jurisdiction and is completely ignored.
5
 reported the witnessed claim(s) of Treason involving a MA State Judge (and other referenced

violations) to: (1) Governor Charlie Baker (R-MA)5; (2) the DOJ; (3) Members of Congress

– since it bears impact to this federal litigation; (3) MA Attorney General Maura Healey; and

(4) The White House. These evidenced violations by a judicial officer acting on behalf of the

DEFENDANT – Commonwealth of Massachusetts, indicated identical patterns of

corrupt conduct to that evidenced in this Federal litigation - and which indicates the intent

to collectively arrive at a corrupt and pre-determined outcome. Therefore, based on this

new evidence of record, the Plaintiff shows cause to amend his original complaint against the

Defendant – Commonwealth of Massachusetts under Federal Rule 60.

II. MISPRISION of TREASON under 18 U.S. CODE § 2382 – The Plaintiff brings new

evidence under Fed. R. Civ. P. 60(b)(2) against ALL named Defendants and their retained

counsel who as a matter of record have witnessed, along with the Plaintiff, an act(s) of

Treason against The United States – committed by a Judicial Officer(s) of this Court (and

similarly in MA State Courts) choosing NOT to report it:

“Whoever, owing allegiance to the United States and having knowledge of the commission

of any treason against them, conceals and does not, as soon as may be, disclose and make

known the same to the President or to some judge of the United States, or to the governor

or to some judge or justice of a particular State, is guilty of misprision of treason and shall

be fined under this title or imprisoned not more than seven years, or both.”

5
See Exhibit 5 to view the Formal Letter delivered via email to Governor Charlie Baker (R-MA) on November
15, 2019, informing him of the evidenced Treason (and other) violations committed by Middlesex Superior Court
Judge – Hon. Janice W. Howe. Also copied on the email was the Superior Court Clerk under Judge Howe –
Arthur Deguglielmo.
6
 This new evidence shows cause to amend the Plaintiff’s original complaint, bringing a

NINETH (9th) Misprision claim as it pertains to recused/disqualified Judge – Hon. Allison

Dale Burroughs against ALL named Defendants, their retained counsel and referenced Court

Clerks under 18 U.S. CODE § 2382. Separately, the Plaintiff shows cause to bring

incremental Misprision claims against: (1) Bank Defendants – WELLS FARGO/US

BANK; (2) Defendant – David E. Fialkow, Esq. (K&L Gates, LLP); (3) Defendants

Jeffrey/Isabelle Perkins; and (4) Counsel for the Perkins’ – Jeffrey B. Loeb (Rich May, PC),

based on the evidenced Treason violations committed by Middlesex County Superior

Court Judge – Hon. Janice W. Howe.

III. Cause to Amend Original Complaint - Civil (and Criminal) RICO violations under (at

minimum) 18 U.S. Code § 1964 – The evidenced Misprision claims against all referenced

parties contributes to arguments that show the intention to collude with disqualified

judicial officers for the purpose of reaching a corrupt and pre-determined outcome – that

begins with defrauding the Plaintiff of his HOMESTEAD.

IV. Cause to Amend Original Complaint under 28 U.S. Code § 1915 – Collectively, these

latest judicial failures combined with the incremental violations evidenced against all

referenced parties shows that the complexity of legal issues associated with this litigation

continues to grow. Therefore, the Plaintiff shows cause to amend his original complaint and

expand upon his request for this Court to assist with the appointment of counsel, pursuant to

28 U.S. Code § 1915.

V. Cause to Amend Original Complaint under Fed. R. Civ. P. 60(b)(3) – For the reasons

referenced above, the Plaintiff shows cause to expand upon his Rule 60(b) arguments that

indicate: (1) the named Defendants; (2) their retained counsel of record; (3) referenced

disqualified judicial officers; (4) referenced Clerks are purposefully trying to deceive or
7
 commit Fraud Upon this Court. Similarly, the Plaintiff has clearly evidenced egregious

judicial abuse of power by Judge Burroughs, showing cause to expand upon existing

arguments under Fed. R. Civ. P. 60(b)(4).

VI. Defendant – Commonwealth of MA Attempt to Cause Incremental Harm to the

Plaintiff - The Emergency Motion associated with ECF No. 162, filed 10/21/19 identifies

evidenced claims against MA Department of Revenue, who threatened NOT to approve

the Plaintiff’s hardship status, despite the timely submission of all requested financial

documents that conclusively evidenced his qualification. A temporary levy was unjustly

attached to the Plaintiff’s bank account – and although it was ultimately lifted, the MA DOR

– specifically, Deputy Chief - Kelly Hill and an unnamed supervisor stated that they

would re-issue the levy and only approve the Plaintiff’s hardship if he first agreed to

pay $500 towards the tax balance. The Plaintiff already evidenced that he is NOT in the

financial position to do so. Documented emails to MA DOR agent Sean Comerford show

that the Plaintiff requested a detailed explanation from Deputy Chief Hill explaining for the

record how she (and the unnamed supervisor) arrived at the decision to demand the $500

payment as a qualifier for Hardship status. The Plaintiff also reminded the MA DOR of this

ongoing litigation which included the Commonwealth as a Defendant – and evidenced

claims that have (at least in part) caused and/or contributed to the referenced hardship. The

Plaintiff stated to agent Comerford that it APPEARED that the Commonwealth was

attempting to (unjustly) create a greater hardship – and if left uncorrected, would show

cause to amend the Federal complaint against the Commonwealth. On Friday, November

15, 2019, the Plaintiff received an email stating that the hardship was approved.6 While the

6
See Exhibit 6, and the referenced email communications to the MA DOR.
8
 Plaintiff is grateful that corrective action was taken to ultimately approve the hardship, there

is concern over the Commonwealth’s deceptive and unjust attempts to cause him

greater harm and damages.

Upon filing this Response and Emergency Motion, the Plaintiff respectfully requests that the

Court immediately address and initiate corrective action that begins with: (1) REMOVING the

RECUSED/DISQUALIFIED US District Court Judge – Hon. Allison Dale Burroughs from

this Docket to prevent her from causing further harm; (2) Restoring JURISDICTION; (3)

Assisting the Plaintiff with the appointment of counsel, pursuant to 28 U.S. Code § 1915; and (4)

Re-visiting the Emergency injunction motion and Whistleblower Report (filed with the House

Financial Services Committee).7

Finally, the Plaintiff – while under no obligation to do so, states for the record that he has IN

GOOD FAITH offered ALL Defendant parties the opportunity to reach a mutual agreement.

However, no agreement has been made at this stage with ANY party.

Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge,

information, and belief that this Response and Emergency Motion: (1) is not being presented for an

improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of

litigation; (2) is supported by existing law or by a non-frivolous argument for extending, modifying,

or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so

7
See Exhibit 7, which references the Whistleblower report filed October 16, 2019, with the House Financial
Services Committee.
9
identified, will likely have evidentiary support after a reasonable opportunity for further

investigation or discovery; and (4) the Motion otherwise complies with the requirements of Rule 11.

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 impact

National Security. Therefore, the following government offices/agencies/committees will

necessarily receive copies of this formal letter (via email, US Mail and/or social media):

1. President Donald J. Trump (via www.whitehouse.gov);

2. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;
3. Department of Justice (DOJ) - specifically, US Attorney General, William Barr;
4. Administrative Office of US Courts - specifically, Deputy Chief, Dan Jackson;
5. House/Senate Judiciary Committees;
6. House Financial Services Committee;
7. Governor Charlie Baker (R-MA);
8. US Senator Elizabeth Warren (D-MA);
9. US Senator Ed Markey (D-MA);
10. US Congresswoman Lori Trahan (D-MA);
11. US Congresswoman Ayanna Pressley (D-MA);

Referenced Clerks of this US District Court – Karen Folan and Tracy McLaughlin will receive a

copy of this Plaintiff Response via email, in addition to efforts to file electronically and by US

Mail. The Clerk of the Middlesex Superior Court – Arthur Deguglielmo will receive also copy to

inform the Superior Court of the new claims against Judge Howe. The Public and media outlets

nationwide will be notified for documentation purposes and out of continued concerns for the

Plaintiff’s personal safety and security. If the Court has ANY questions regarding any portion

of this Plaintiff Response/Emergency Motion, or requires additional information, the Plaintiff is

happy to provide upon request. The Plaintiff is grateful for the Court’s consideration of this very

serious, and sensitive matter.

10
Respectfully submitted this 22nd Day of November, 2019

Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com

11
Exhibit 1

12
13
Exhibit 2

14
15
Exhibit 3

16
17
Exhibit 4

18
19
Exhibit 5

20
 Mohan Harihar <moharihar@gmail.com>

FORMAL TREASON CLAIM(S) REPORTED TO THE OFFICE

MASSACHUSETTS GOVERNOR CHARLIE BAKER (R-MA)
Mohan Harihar <moharihar@gmail.com> Fri, Nov 15, 2019 at 11:08 AM
To: "Constituent.services@state.ma.us" <constituent.services@massmail.state.ma.us>,
governor.schedule@state.ma.us
Cc: maura.healey@state.ma.us, jesse.boodoo@state.ma.us, dan_jackson@ao.uscourts.gov, Susan
Goldberg <susan_goldberg@ca1.uscourts.gov>, NewYorkComplaints Dojoig
<dojoig.newyorkcomplaints@usdoj.gov>, theresa watson3 <theresa.watson3@usdoj.gov>, andrew lelling
<andrew.lelling@usdoj.gov>, mary murrane <mary.murrane@usdoj.gov>, christina sterling
<christina.sterling@usdoj.gov>, elizabeth warren <elizabeth_warren@warren.senate.gov>, sydney levin-
epstein <sydney_levin-epstein@markey.senate.gov>, ayanna pressley
<ayanna.pressley@mail.house.gov>, lori trahan <lori.trahan@mail.house.gov>, igo-
fightfraud@state.ma.us, ma-igo-general-mail@state.ma.us, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, david fialkow <david.fialkow@klgates.com>, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, Nairoby Gabriel <Nairoby_Gabriel@warren.senate.gov>, Nora Keefe
<Nora_Keefe@warren.senate.gov>

A LETTER TO GOVERNOR CHARLIE BAKER (R-MA)

November 15, 2019

Governor Charlie Baker

Massachusetts State House
Office of the Governor, Rm 280
25 Beacon Street Boston, MA 02133

RE: FORMAL TREASON CLAIM BROUGHT AGAINST DISQUALIFIED JUDICIAL OFFICER - HON.
JANICE W. HOWE

Dear Governor Baker:

It is with regret that I must report to your direct attention (and as required under ARTICLE III and 18
U.S. CODE § 2381), a witnessed act of JUDICIAL TREASON by disqualified Middlesex Superior
Court Judge - Janice W. Howe, who apparently on November 1, 2019, issued a (VOID) dismissal
order without jurisdiction or just cause (since as a matter of record, the argument of res judicata was
completely disproven, Ref. HARIHAR v WELLS FARGO et al, Docket No. 1981-cv-00050, #38,
attached below). It is unclear as to why the VOID judicial order only posted to the Massachusetts Trial
Court Website nearly two (2) weeks later on November 14, 2019. This latest judicial failure adds
incrementally to the systemic abuses of judicial power - evidenced here in Massachusetts State Courts
as well as in related Federal litigation (First Circuit, Ref. HARIHAR v US BANK et al, Docket No. 15-
cv-11880), that includes the Commonwealth of Massachusetts as a DEFENDANT. As a matter of
record, Judge Howe's assignment to this MA State civil lawsuit came only after the sua sponte
recusal of the Hon. Kenneth J. Fishman - who evidenced the same patterns of corrupt conduct prior

21
to his recusal. The record will show that Judge Howe was similarly asked to recuse herself and refused
to do so.

Also serving as witnesses to this (second) criminal violation to ARTICLE III and 18 U.S. CODE § 2381
is: (1) the Court Clerk - Arthur Deguglielmo; (2) Defendant - WELLS FARGO; (3) Defendant - US
BANK; (4) Counsel for Bank Defendants - David E. Fialkow, Esq. (K&L Gates, LLP); (5) Defendants -
Jeffrey and Isabelle Perkins; (6) Defendant - MERS Inc.; and (7) Counsel for the Perkins' and MERS -
Jeffrey B. Loeb, Esq. (Rich May, PC). Therefore, the witness requirement (2) for filing a formal Treason
claim is satisfied. In addition to notifying your office, the White House will also be formally be notified
(via www.whitehouse.gov) as will the Middlesex Superior Court via a filed RESPONSE to the VOID
Order. A copy of this letter will be included as an attachment to the filed response for documentation
purposes.

In addition to the evidenced Treason claim(s), the record also evidences that Judge Howe stands
formally accused of the following civil/criminal violations:

1. Judicial Fraud on the Court under Fed. R. Civ. P 60(b)(3);

2. Civil (and Criminal) RICO violations under (at minimum) 18 U.S. Code § 1964;
3. Color of Law violations under 18 U.S. Code § 242;
4. Due Process violations under the Fifth and Fourteenth Amendments;
5. Ignoring ARTICLE III, 18 U.S.C. § 2381 and 28 U.S.C. § 1446 - as it pertains to the
referenced Federal litigation;
6. Refusing to Recuse;
7. 18 U.S. Code § 2076 - by instructing a Court Clerk not to accept or Docket filed
documents by the Plaintiff;
8. Unnecessary Judicial Delay ;
9. Failure to acknowledge and uphold Massachusetts Rules of Civil Procedure 60(b)(3) -
Fraud on the Court, as it pertains to evidenced (and UNOPPOSED) claims against named
Defendants;
10. Ignoring ELEVEN (11) judicial recusals of record (9 Federal, 2 State, all related to this
litigation) and their impact to associated judgements;
11. Refusing to accept the Plaintiff’s arguments as FACT, refusing DISCOVERY and Refusing to
Allow the Plaintiff to Depose Witnesses;
12. Refusing to acknowledge that: (1) the Department of Justice (DOJ); (2) MA Office of the
Attorney General (MA AGO); and (3) Federal Bank Regulators – have ALL
identified the Plaintiff’s referenced Foreclosure as ILLEGAL;
13. Refusing to re-establish a balance of hardships ;
14. Refusing to Acknowledge Public Perception and the MASSACHUSETTS CODE OF
JUDICIAL CONDUCT; and
15. Ignoring Continued Concerns for the Plaintiff’s Personal Safety and Security

Please be advised, for the reasons described above, these evidenced criminal violations by a
Massachusetts State Judicial Officer show cause for legal action from your office, the MA AGO and
Federal Prosecutors. There is also cause to amend the original complaint against the Commonwealth
in the above-referenced Federal Lawsuit - HARIHAR v US BANK et al, Docket No. 15-cv-11880. ANY
American or Resident of this Commonwealth should consider these evidenced judicial abuses of power
- an absolute DISGRACE to the (State and Federal) Judicial Branch(s) of Government and should
NEVER be tolerated. Respectfully - to be clear, you are NOT being asked to interfere with any ongoing
litigation. You are - as required by Federal law, being informed of an evidenced, criminal act of
TREASON committed by a Middlesex Superior Court Judge.

Finally Governor Baker, you are respectfully reminded that on November 6, 2019, you were copied on
an email to MA Attorney General Maura Healey and Asst. AG Jesse M. Boodoo, Esq.,

22
(representing counsel for the Defendants - Commonwealth of Massachusetts and former AG Martha
Coakley) in the above-referenced Federal lawsuit. The email included an opportunity to reach a mutual
agreement - offered by the Plaintiff to the Commonwealth and the former AG, as a sign of his
continued GOOD FAITH. However, it is concerning that as a matter of professional courtesy there has
been no reply from the MA AGO. As I now begin to prepare a Motion to Amend the original Federal
complaint against the Commonwealth, please have Attorney General Healey provide a timely response
as to whether or not the Commonwealth wishes to enter into a mutual agreement discussion.

Thank you - Governor Baker, for your attention to this very serious and sensitive criminal matter.
Parties copied on this email communication will include: (1) The White House (via
www.whitehouse.gov); (2) The Department of Justice (DOJ); (3) The US Attorney's Office (MA); (4)
Members of Congress; (5) The Office of the First Circuit Executive and the Administrative Office of US
Courts - due to the related crimes and systemic judicial failures evidenced in the First Circuit; (6)
Middlesex Superior Court Clerk Arthur Deguglielmo; and (7) Representing counsel for the named
Defendants referenced above. A copy will also be made available to the Public and to media sources
Nationwide for documentation purposes and out of continued concerns for my personal safety and
security. Thank you for your attention to this very serious and sensitive legal matter.

Respectfully,

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

23
Exhibit 6

24
 Mohan Harihar <moharihar@gmail.com>

RE: M HARIHAR - URGENT Request to Lift Bank Account Levy

**EXTERNAL EMAIL**
Fri, Nov 15, 2019 at 8:19
Comerford, Sean M. (DOR) <comerfords@dor.state.ma.us>
AM
To: Mohan Harihar <moharihar@gmail.com>

Good morning,

The hardship was approved for 6 months. Attached is a copy of the letter. The original is in the mail
and should be getting to you shortly.

Thank you,

Sean Comerford

From: Mohan Harihar [mailto:moharihar@gmail.com]

Sent: Friday, November 15, 2019 7:04 AM
To: Comerford, Sean M. (DOR)
Cc: governor.schedule@state.ma.us; Constituent.services@state.ma.us; maura.healey@state.ma.us;
elizabeth warren; sydney levin-epstein; lori trahan; ayanna pressley; NewYorkComplaints Dojoig;
theresa watson3; andrew lelling; mary murrane; christina sterling; igo-fightfraud@state.ma.us; ma-igo-
general-mail@state.ma.us; jesse.boodoo@state.ma.us; Nora Keefe; Nairoby Gabriel
Subject: Fwd: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**

Mr. Comerford,

I have not received any communication from Deputy Chief Kelly Hill since responding to your last
email from earlier this week on 11/12/19 (Attached below). Please provide an update so that I can
timely update Governor Baker, AG Healey, Federal Prosecutors and the Court. Thank you for your
attention to this very serious and sensitive legal matter.

Respectfully,

Mohan A. Harihar

25
---------- Forwarded message ---------
From: Mohan Harihar <moharihar@gmail.com>
Date: Tue, Nov 12, 2019 at 10:51 AM
Subject: Fwd: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**
To: Comerford, Sean M. (DOR) <comerfords@dor.state.ma.us>
Cc: <governor.schedule@state.ma.us>, Constituent.services@state.ma.us
<constituent.services@massmail.state.ma.us>, <maura.healey@state.ma.us>, elizabeth warren
<elizabeth_warren@warren.senate.gov>, sydney levin-epstein <sydney_levin-
epstein@markey.senate.gov>, lori trahan <lori.trahan@mail.house.gov>, ayanna pressley
<ayanna.pressley@mail.house.gov>, NewYorkComplaints Dojoig
<dojoig.newyorkcomplaints@usdoj.gov>, theresa watson3 <theresa.watson3@usdoj.gov>, andrew
lelling <andrew.lelling@usdoj.gov>, mary murrane <mary.murrane@usdoj.gov>, christina sterling
<christina.sterling@usdoj.gov>,< igo-fightfraud@state.ma.us>, <ma-igo-general-mail@state.ma.us>,
<jesse.boodoo@state.ma.us>, Nora Keefe <Nora_Keefe@warren.senate.gov>, Nairoby Gabriel
<Nairoby_Gabriel@warren.senate.gov>

Mr. Comerford,

Due to the severity of evidenced civil and criminal violations associated with the referenced
litigation (HARIHAR v US BANK, et al Docket no. 15-cv-11880) - AND which includes the
Commonwealth of Massachusetts as a Defendant, ALL communications with the MA DOR will
need to be documented. My serious legal concern now is that the Commonwealth/MA DOR -
(specifically, Deputy Chief Kelly Hill and your Supervisor - whose name is still unknown), is
attempting to create a greater financial hardship by forcing me to make a $500 payment in order to
QUALIFY for hardship status. Aside from my hardship being validated by the MA State and Federal
Courts, the Commonwealth has AGAIN validated the financial hardship by recently approving my 40b
qualification for affordable housing. I respectfully restate that I am not trying to avoid paying taxes
which are due to the Commonwealth and I fully expect to be in the financial position to do so once
ALL legal issues (referenced above) have been JUSTLY resolved. Until that time however, there
remains the expectation that the Commonwealth/MA DOR will allow the hardship status to remain.
Otherwise, there will be cause to amend the original complaint against the Commonwealth in above-
referenced litigation. Please have Deputy Chief Hill communicate with me via email, if it becomes
necessary. Please be advised, parties copied on this communication include: (1) Governor Charlie
Baker (R-MA); (2) Massachusetts AG Maura Healey; (3) US Senator Elizabeth Warren (D-MA); (4)
US Senator Ed Markey; (5) US Congresswoman Lori Trahan (D-MA); (5) US Congresswoman
Ayanna Pressley (D-MA); (7) The US Department of Justice (DOJ); (8) The US Office of the
Inspector General (OIG); and (9) The MA Office of the Inspector General.

Please provide the requested information (referenced in my emails from 11/6/19 and again on 11/8/19,
attached below) so that I can timely update Governor Baker, AG Healey, Federal Prosecutors and the
Court. Thank you for your attention to this very serious and sensitive legal matter.

Respectfully,

Mohan A. Harihar

26
---------- Forwarded message ---------
From: Comerford, Sean M. (DOR) <comerfords@dor.state.ma.us>
Date: Tue, Nov 12, 2019 at 10:02 AM
Subject: RE: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**
To: Mohan Harihar <moharihar@gmail.com>

Good morning,

Can you please reach out to Deputy Chief Kelly Hill at 413-452-3873. She tried to call you but your
voicemail box was full.

Thanks

-Sean Comerford

From: Mohan Harihar [mailto:moharihar@gmail.com]

Sent: Friday, November 08, 2019 10:20 AM
To: Comerford, Sean M. (DOR)
Cc: governor.schedule@state.ma.us; Services, Constituent (GOV); maura.healey@state.ma.us;
elizabeth warren; sydney levin-epstein; ayanna pressley; lori trahan; jesse.boodoo@state.ma.us;
NewYorkComplaints Dojoig; theresa watson3; andrew lelling; mary murrane; christina sterling; ma-igo-
general-mail@state.ma.us; igo-fightfraud@state.ma.us; Nora Keefe; Nairoby Gabriel
Subject: Re: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**

Mr. Comerford,

Please provide the requested information regarding my HARDSHIP REQUEST and the email delivered
to your attention on November 6, 2019 (referenced below) so that I can timely update Governor Baker,
AG Healey, Federal Prosecutors and the Court. One last thing that I meant to add in my last email - the
Commonwealth of Massachusetts has again validated by hardship to allow 40b housing. Thank you
for your attention to this very serious and sensitive matter.

Sincerely,

Mohan A. Harihar

27
On Wed, Nov 6, 2019 at 1:25 PM Mohan Harihar <moharihar@gmail.com> wrote:

Mr. Comerford,

You are aware that I DO NOT have the disposable income that would allow me to make a $500
payment to the MA DOR without causing an increased financial hardship. I also DO NOT have a
credit card with the availability of charging that amount, nor do I have any other avenue for making
such a payment. This SHOULD already be clearly evidenced by the updated financials I provided to
you as requested. What is troubling now is that it appears that two (2) MA DOR officials: (1) your
immediate Supervisor; and (2) a Deputy Chief, are MANDATING the $500 dollar payment in order to
qualify for HARDSHIP STATUS, even though it is clear that I am unable to financially do so without
causing further hardship. Therefore, please be advised of the following:

1. Please provide the names and exact titles of your supervisor and the deputy chief for the
record. Also, I respectfully request that they provide a detailed explanation for the record,
showing how exactly they arrived at the decision NOT to approve a hardship status without
first receiving a $500 minimum payment;
2. I respectfully request that your supervisor and the deputy chief reconsider their position and
grant the hardship, since this financial hardship has additionally been validated by every MA
State and Federal Court, including the US Supreme Court;
3. As you know, the Commonwealth is a DEFENDANT in the Federal lawsuit - HARIHAR v US
BANK et al, Docket No. 15-cv-11880 - for damages related to the CAUSE of my financial
hardship. Any failure to initiate corrective action will be perceived as an attempt by the
Commonwealth of Massachusetts to cause further harm and damages to me personally,
warranting an amendment to the above-referenced litigation;
4. You were copied directly on an email to Massachusetts AG Maura Healey this morning -
11/06/19, informing her of these MA DOR concerns. Governor Baker, the DOJ and other
legislative leaders were also necessarily copied on the email;
5. As I have previously stated - I am not trying to avoid paying taxes which are due to the
Commonwealth and I fully expect to be in the financial position to do so once ALL legal
issues (referenced above) have been JUSTLY resolved. Until that time however, there
remains the expectation that the Commonwealth/MA DOR will allow the hardship status to
remain;
6. Because of the severity of evidenced criminal claims associated with the referenced
litigation (that includes the Commonwealth as a Defendant), the following parties are copied
on this email communication including: (1) Governor Charlie Baker (R-MA); (2)
Massachusetts AG Maura Healey; (3) US Senator Elizabeth Warren (D-MA); (4) US
Senator Ed Markey; (5) US Congresswoman Lori Trahan (D-MA); (5) US
Congresswoman Ayanna Pressley (D-MA); (7) The US Department of Justice (DOJ); (8)
The US Office of the Inspector General (OIG); and (9) The MA Office of the Inspector
General.

Please provide the requested information (referenced above) so that I can timely update Governor
Baker, AG Healey, Federal Prosecutors and the Court. Thank you for your attention to this very
serious and sensitive matter.

Sincerely,

Mohan A. Harihar

28
---------- Forwarded message ---------
From: Comerford, Sean M. (DOR) <comerfords@dor.state.ma.us>
Date: Tue, Nov 5, 2019 at 8:18 AM
Subject: RE: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**
To: Mohan Harihar <moharihar@gmail.com>

Good morning,

I never heard back in regards to the email I sent to you on 10/17/19. After speaking with supervisor
and deputy chief to get you in a hardship a $500.00 estimated payment must be made. I can give you
until 11/15/19 to make this payment, if no payment is made collection action will resume. Please
reach back out to me so we can get this hardship approved.

Thank you,

Sean Comerford

From: Comerford, Sean M. (DOR)

Sent: Thursday, October 17, 2019 8:35 AM
To: 'Mohan Harihar'
Subject: RE: M HARIHAR - URGENT Request to Lift Bank Account Levy **EXTERNAL EMAIL**

Good morning,

I spoke with my supervisor and deputy chief of the department in regards to your request for hardship.
It has been determined that we can put you in a hardship but absolutely no more tax can be added.
Also, an estimated payment of $500.00 has to be made towards 2019 taxes for us to put you in the
hardship. This can be done by credit card on masstax connect. Feel free to contact me with any
questions.

Sean Comerford

29
Exhibit 7

30
31