Professional Documents
Culture Documents
______________________________________________________________________________
The Plaintiff, Mohan A. Harihar, acting pro se, respectfully prefaces this complaint with the
following Disclosure(s):
1. The gravity of serious legal issues addressed in this Complaint against the Defendants are
directly related to ongoing Federal litigation in the First Circuit Court of Appeals.1 This
related Federal litigation includes (but is not limited to): a.) Evidenced allegations of
1
The related Federal litigation references: 1.) HARIHAR v. US BANK et al, Appeal No. 17-
cv-1381 (Lower Court Docket No. 15-cv-11880) and 2.) HARIHAR v. THE UNITED
STATES, Appeal No. 17-2074 (Lower Court Docket No. 17-cv-11109).
TREASON under ARTICLE III, Section 3 of the Constitution, and b.) Economic
Security. Therefore, copies of this related COMPLAINT are sent via email, social
media and/or certified mail to: The Executive Office of the President (EOP), the US
(FBI). Copies are similarly delivered to Massachusetts State Legislators, to the direct
Healey. A copy will also be made available to the Public. THEREFORE, ALL
documentation purposes, and out of the Plaintiff’s continued concerns for his personal
safety/security.
2. The TREASON claims referenced above pertain to evidenced judicial misconduct claims
now alleged against SEVEN (7) Federal (District and Circuit Court) judges –
The Plaintiff has necessarily brought judicial misconduct complaints against TEN (10)
Officers of the (Federal) Court,2 for their collective failures to uphold Federal Law(s)
and the judicial machinery of the Court. Plaintiff reserves the right to expand upon by
amendment, the list of Defendants that allegedly bear some responsibility and have
2
The referenced TEN (10) officers of the Court include: US District Court Judge’s - Allison
Dale Burroughs, Chief Judge Joseph N. Laplante (NH), Judge John J. McConnell, Jr. (RI), and
Judge John David Levy (ME), First Circuit Judges - Juan R. Torruella, William J. Kayatta, Jr.,
David J. Barron, O. Rogeriee Thompson, Chief Justice Jeffrey R. Howard and District Court
Judge Denise J. Casper.
contributed (at least in part) to the damages and increased hardships of the Plaintiff.
Additional Defendants may include (but would not be limited to) related officers of the
Court (State and Federal) who have failed to uphold the judicial machinery of the Court,
judicial misconduct claims of record brought against the initial presiding US District
Court Judge – Allison Dale Burroughs eventually led to her RECUSAL from
HARIHAR v. THE UNITED STATES. This recusal: 1.) re-affirms ALL judicial
claims – including (but not limited to) six (6) counts of TREASON for ruling
WITHOUT Jurisdiction; 2.) shows cause for the Plaintiff to attack ALL related orders;
3.) mandates that the District Court VOID ALL related orders, including the dismissal
order.
Coakley are Appellees in the related federal litigation, with evidenced allegations that
include (but are not limited to): 1.) RICO (Civil/Criminal), 2.) Fraud on the Court, 3.)
Due Process, 4.) Color of Law, 5.) Misprision 6.) Conspiracy 7.) Perjury and other
violations. The SEVEN (7) year historical record(s) of this litigation shows an
obvious cause for concern and questions whether this referenced pattern of corrupt
conduct will continue here. While there certainly is concern, this is the Plaintiff’s initial
appearance before this Massachusetts Land Court. Therefore, there is FULL expectation
for this Court to uphold the law and correct (within its jurisdiction) any erred judgments
full public view, and will (at minimum) warrant filing incremental Judicial misconduct
complaints.
5. Although Federal litigation is ongoing, the evidenced record3 shows cause to correct the
erred judgments of the Commonwealth and seek damages including (but not limited to)
Quiet Title. The Plaintiff makes clear that with this complaint, it is not intended to
duplicate damages sought in the related Federal litigation. At the conclusion of this
litigation, any relief awarded to the Plaintiff here will be appropriately deducted from
warranted) against ALL Defendants (and ALL responsible parties) for the criminal
components associated with this litigation including (but not limited to) FRAUD. Along
with this civil complaint, the Plaintiff has necessarily filed incremental criminal
complaints with the Massachusetts Attorney General’s Office and the FBI. Copies of
both this civil complaint and the referenced criminal complaints have been delivered to
Baker (R-MA), and the FBI via e-mail and/or social media communication. ANY
3
The evidenced record includes (but is not limited to) the argument and sworn testimony by
Fraud Expert – Lynn Syzmoniak, representing The United States in the related case:
0:2013CV00464 USA VS ACE SEC. CORP. ET AL. The Fraud Expert’s testimony
conclusively shows that the referenced Residential Mortgage Backed Security (RMBS) Trust –
CMLTI 2006-AR1 is considered VOID, and therefore has NO LEGAL STANDING to the
Plaintiff’s property located at 168 Parkview Avenue, Lowell, MA 01852.
continued failures by State and/or Federal Prosecutors to bring criminal charges
against referenced parties will be in full public view AND will (at minimum) show cause
to expand upon (or bring new) Color of Law/Due Process claims against the
7. A review of the historical record shows that EVERY State and Federal Court associated
with this litigation has been made aware that the referenced property in question has been
(DOJ), 2.) Federal Bank Regulators, and 3.) The Massachusetts Office of the
Attorney General (AGO). If necessary, the Plaintiff will seek subpoenaed testimony
from each of the above referenced offices/agencies to articulate (at minimum) exactly
how they reached a definitive conclusion that identified the Plaintiff’s foreclosure as
ILLEGAL.
8. Plaintiff has also filed a FOIA (Freedom of Information Act) request, to provide
9. The Plaintiff respectfully brings to this Court’s attention, that as recently as Friday,
April 20, 2018, the Consumer Financial Protection Bureau issued a $1B Fine to
Defendant – Wells Fargo for abuses tied to its auto lending and mortgage
10. Plaintiff – MOHAN A. HARIHAR, an American-born citizen, is now, and at all times
11. Defendant - US BANK NA (hereafter “US Bank”), as Trustee for securitized Trust
“CMLTI 2006-AR1 Trust”), whose last known address is 800 Nicollet Mall Minneapolis,
Minnesota 55402. Plaintiff is informed and believes, and thereon alleges, that Defendant
State of Massachusetts, and is the purported Master Servicer for Securitized Trust and/or
a purported participant in the imperfect securitization of the Note and/or Deed of the
MERS (“MERS”), Plaintiff is informed and believes, and thereon alleges, that MERS is
a corporation duly organized and existing under the laws of MIDDLESEX, whose last
known address is 1818 Library Street, Suite 300, Reston, Virginia, 20190; website:
of Massachusetts. Plaintiff is further informed and believes, and thereon alleges, that
Defendant MERS is the purported beneficiary under the Deed of Trust and/or a purported
participant in the imperfect securitization of the Note and/or Deed of the Trust as more
13. Defendants - ISABELLE AND JEFFREY PERKINS are the BORROWERS to the
mortgage associated with the property located at 168 Parkview Avenue, Lowell, MA
01852. The Defendants also reside at the referenced property. Isabelle Perkins is the
Principle of a business specializing in Real Estate Education, offering real estate
Education, 3.) NAR Certification and Designations and 4.) MCNE Designation
http://isabelleperkins.com.
14. Defendant – WELLS FARGO NA, (hereafter "Wells Fargo") is a national bank with a
principal place of business in Sioux Falls, South Dakota. As described below, Wells
Fargo either directly and/or indirectly through its agents, employees, subsidiaries and/or
related companies, including without limitation Wells Fargo Home Mortgage, Inc., held,
serviced and/or engaged in transactions related to, mortgages of real property within the
15. At all times relevant to this action, the Plaintiff has owned the property located at 168
16. Aside from Defendants – Isabelle and Jeffrey Perkins, and the other parties identified in
the related federal litigation, Plaintiff does not know the true names, capacities of basis
for liability of Defendants sued herein as Does 1 through 100, inclusive, each as
fictitiously named Defendant is some manner liable to the Plaintiff, or claims some right,
title or interest in the Property. Plaintiff will amend this Complaint to allege their true
names and capacities when ascertained. Plaintiff is informed and believes, and therefore
alleges, that at all relevant times mentioned in this complaint, each of the Defendants are
responsible in some manner for injuries and damages to Plaintiff so alleged and that such
injuries and damages were proximately caused by such Defendants, and each of them.
17. Plaintiff is informed and believes, and thereon alleges, that at all times herein mentioned,
each of the defendants were the agents, employees, servants, and/or joint-venturers of the
remaining Defendants, and each of them, and in doing the things alleged herein below,
were acting within the scope of such agency, employment and/or joint venture.
II. JURISDICTION
18. The transactions and events which are the subject matter of this complaint all occurred
19. The Property is located within the County of Middlesex, State of Massachusetts with an
III. INTRODUCTION
20. This is an action involving the foreclosure of the residential Property belonging to the
Plaintiff. As a matter of record, this foreclosure was declared ILLEGAL by: 1.) The
Department of Justice (DOJ), 2.) Federal Bank Regulators and 3.) The
21. Litigation pertaining to this referenced illegal foreclosure has been ongoing for over
seven (7) years – four (4) years in Massachusetts State Court(s) and nearly three (3)
years in Federal Court(s). There are two (2) Appeals which are ongoing: 1.) Appeal No.
17-1381, HARIHAR v. US BANK et al4 and 2.) Appeal No. 17-2074, HARIHAR v.
4
Lower Docket No. 15-cv-11880
5
Lower Docket No. 17-cv-11109
22. In the related Federal litigation, the EVIDENCED and UNOPPOSED Fraud on the
Court (and other) claims brought against ALL related Defendants named here shows
cause (at least in part) to: 1.) File this NEW complaint for Quiet Title with the Land
Court 2.) Address evidenced Fraud on the Court claims and correct erred judgments in
other Massachusetts State Courts and 3.) Seek monetary and all applicable damages
through a separate, NEW complaint(s) to be filed with the Middlesex Superior Court.
23. This is an action brought by the Plaintiff for declaratory judgment, injunctive and
equitable relief, and (if allowed) for compensatory, special, general and punitive
damages. The Plaintiff also seeks reimbursement for legal (and associated costs). While
Plaintiff is initially proceeding as a pro se litigant (out of financial necessity) his time is
24. The evidenced allegations brought by the Plaintiff here, and throughout the history of this
Defendants. Plaintiff retains the right to expand upon by amendment, additional related
claims and/or parties, should it become necessary; also, in the event Plaintiff is successful
in retaining counsel.
historically by both Federal and State Judiciaries, the Plaintiff here respectfully demands
a TRIAL BY JURY.
26. A thorough review of the record(s) in the related Federal proceedings reveal evidenced
arguments which conclusively show that the referenced CMLTI 2006-AR1 Trust (and
all other referenced parties), have NO LEGAL STANDING to the Plaintiff’s Property
and that the trust itself is considered VOID. Therefore, the Plaintiff shows cause to
address with this Land Court, these evidenced arguments, and also to correct erred
HOMESTEAD PROTECTION.6
27. Plaintiff, homeowner, disputes the title and ownership of the real property in question
(the “Home”), which is the subject of this action, in that the originating mortgage lender,
and others alleged to have ownership of Plaintiff’s mortgage note and/or Deed of Trust,
have unlawfully sold and/or transferred their ownership and security interest in a
Promissory Note and Deed of Trust related to the Property, and, thus, do not have lawful
ownership or security interest in Plaintiff’s Home which is described in detail herein. For
28. Before proceeding further, Defendants will be given a single opportunity – as a sign of
record(s), Defendants who are also associated with the referenced Federal litigation have
been given MULTIPLE opportunities to seek mutual agreement and have either denied
or ignored them. Should this opportunity here be denied or ignored, there will not be
another.
29. The Plaintiff respectfully makes known to this Court (and as a matter of record), that in
the related federal litigation, the other major component of the Plaintiff’s Appeals
a Trade Secret, protected under the Economic Espionage Act of 1996. Evidenced
claims of Economic Espionage are issues of record. Therefore, any failure to initiate
6
See Attachment A
correct action here will show cause to expand upon existing, or to bring NEW claims
30. Nationally recognized FRAUD EXPERT - Lynn Szymoniak has stated under oath in
her lawsuit (along with The United States)7 that, “Defendants used fraudulent
mortgage assignments to conceal that over 1400 MBS trusts, each with mortgages
valued at over $1 billion, are missing critical documents,” meaning that at least $1.4
Because of the strict laws governing of these kinds of securitizations, there’s no way to
make the assignments after the fact. Activists have a name for this: “securitization
FAIL.” The Department of Justice is well aware of this FACT, as is the Commonwealth
of Massachusetts.
31. Every securitization — requires the creation and funding of a securitization trust that
must take physical possession and control of the trust property on or before the closing
date of the trust. The securitization trustee is the sole and exclusive legal title holder of
the thousands of promissory notes, original mortgages and assignments of mortgage. This
transfer of the trust property, the legal res, to the trust at or around the loan origination is
reasons:
7
Docket No: 2013CV00464 USA VS ACE SEC. CORP. ET AL
a. First, someone must be the “legal” owner of the mortgage loan. Only the legal
owner of the loan has the legal right to sell mortgage-backed securities (“MBS”)
to investors.
b. Second, actual physical transfer of ownership is necessary because the cash flows
that go from the homeowner through the securitization trust to the MBS
purchasers are tax exempt. If the trust does not perfect legal title by taking
physical possession of the notes and mortgages, the Internal Revenue Code,
c. Third, the legal ownership of the loans must be “bankruptcy remote” that is,
because bankruptcy trustees have the right to reach back and seize assets from
bankrupt entities, the transfer to the trustee must be clean and no prior transferee
in the securitization chain of title can have any cognizable interest in the loans.
For this reason, all securitization trusts are “special purpose vehicles”
(“SPVs”) created for the sole purpose of taking legal title to securitized loans and
all securitization trustees represent and certify to the MBS purchasers that the
purchase is a “true sale” in accordance with FASB 140.8 But it never happened.
2001 to 2008 ever obtained legal title or FASB 140 “control” of any
securitized loan.
32. THEREFORE – a.) The securitized trust CMLTI 2006 AR-1 (nor ANY other party)
Servicer, etc… cannot make a legal claim to the property, it had no right to collect
any monies from the Plaintiff or to foreclose on the Plaintiff; c.) Since these parties
had no right to foreclose, they also had no right to re-sell the property, thereby
argument here.
The Plaintiff respectfully makes clear, that this AMENDED complaint does not currently
Defendant argument here that resembles their past arguments of State (and Federal) record,
OR that conflicts with an UNOPPOSED claim of federal record, the Plaintiff will show
cause to bring (either by amendment or by filing) a NEW Fraud on the Court claim(s) before
this Land Court pursuant to (at minimum) Massachusetts Rules of Civil Procedure
60(b)(3).
33. The sua sponte RECUSAL of US District Court Judge Allison Dale Burroughs from
shows cause for this Plaintiff to attack ALL related orders, INCLUDING related
34. As with the identified deceptive techniques by US District Court Judge – Allison Dale
AND State record(s) shows the Plaintiff has similarly identified IDENTICAL tactics by
ALL presiding State and Federal judges. It becomes necessary to respectfully inform
this Court of these evidenced techniques which include (but are not limited to):
e. Ignoring Issues;
explanation whatsoever;
j. Violating the Judicial Oath of Office and the Code of Judicial Conduct;
k. Allowing Perjury;
10
Related judgments from Massachusetts State Courts include the following Appeal/Dockets
No.’s: 1.) 2013-P-1829, 2.) 2013-P-0671, 3.) 2011-P-1515, 4.) 11-04499, 5.) 11-SP-3032, 6.)
1311AC001497, 7.) 1311AC001498, 8.) 1311AC001499, 9.) 1311AC001500, 10.)
1311AC001501 and 11.) 1311AC001502
l. Premature Dismissal PRIOR to DISCOVERY; and
35. EACH ONE of these DECEPTIVE TACTICS detailed within the record constitute
obvious and egregious judicial errors that (at minimum) warrant vacating referenced
Argument(s)
36. EVEN IF the UNOPPOSED arguments of Federal record did not exist, the Plaintiff will
WELLS FARGO NA (as servicer) during the 22-month loan modification effort
b. The collective actions which led to the $25B Mortgage Settlement, where the
c. The collective actions which similarly led to the $8B+ settlement between
boasted publicly about the AGO’s settlement with Nationstar (aka Mr. Cooper),
which included fines and sanctions over servicing abuses. However, it remains
(Federal Reserve, Office of the Comptroller of the Currency, and Office of Thrift
Supervision);
f. “Wall Street and the Financial Collapse”; Majority and Minority Staff Report,
g. The Financial Crisis Inquiry Report - Final Report of the National Commission
on the Causes of the Financial and Economic Crisis in the United States;
Release;
j. Fiscal Year 2010 Annual Report - Attorney General Martha Coakley, (Public
37. The Plaintiff references Attachment A, which shows the filed DECLARATION OF
HOMESTEAD, associated with his property located at 168 Parkview Avenue, Lowell,
MA 01852, filed with the North Middlesex County Registry of Deeds on January 26,
2009. The historical record(s) shows that EVERY State and Federal Court related to this
litigation has COMPLETELY IGNORED the Plaintiff’s evidenced claims regarding
conclusively show that ALL Defendants/Appellees11 KNEW that there was NO LEGAL
38. Before a trial Jury, Plaintiff will call for a thorough review of ALL related State litigation
drawing identical and/or similar comparison to numerous judicial failures and erred
39. The Plaintiff will additionally seek subpoenaed testimony from multiple sources
including (but not limited to): 1.) The Massachusetts Attorney General’s Office 2.) The
Department of Justice and 3.) Federal Bank Regulators to articulate ALL factors which
led to their conclusion that the referenced Foreclosure of the Plaintiff’s Property was in
fact - ILLEGAL.
40. A thorough review of the related federal litigation reveals evidenced claims by this
Plaintiff that are believed to impact matters of National Security, and include: 1.) The
Economic Espionage Act of 1996, pursuant to 18 U.S.C. § 1832, and 2.) Acts of
TREASON under ARTICLE III, warranting the intervention of Congress, the FBI and
the Department of Justice, to address associated criminal (and other) legal components.
Evidenced Treason claims of record have been raised against referenced judges for
ruling without jurisdiction. The record clearly shows that with each claim of evidenced
11
The Plaintiff references ALL Defendants/Appellees associated with Harihar v. US Bank et
al, Docket No. 15-cv-11880, Appeal No. 17-1381.
Treason, the President has been notified by the Appellant (as is required by Federal
from the White House is included as attachments with each court filing. Since this
complaint is related to the referenced federal litigation, a copy has necessarily been
Property
41. Plaintiff re-alleges and incorporates by reference all preceding paragraphs as though fully
42. An actual controversy has arisen and now exists between Plaintiff and Bank Defendants
(Wells Fargo NA and US Bank NA) specified hereinabove, regarding their respective
rights and duties, in that Plaintiff contends that Defendants, and each of them, had no
right to displace the Plaintiff, nor did they have a right to foreclose and re-sell the
Property because Defendants, and each of them, have failed to perfect any security
interest in the Property, or cannot prove to the court they have a valid interest. Thus, the
purported power of sale by the above specified Defendants, and each of them, no longer
applies.
43. Plaintiff is informed and believes and there upon alleges that the only individual who has
standing to foreclose is the holder of the note because they have a beneficial interest. The
12
See Attachment B, for proof of delivery (and receipt) of this Civil Complaint sent to the direct
attention of the President.
only individuals who are the holder of the note are the certificate holders of the
securitized trust because they are the end users who pay taxes on their interest gains;
furthermore, all of the banks or other entities holding the note in the middle of the chain
44. Plaintiff further contends that the above specified Defendants, and each of them, had no
right to foreclose on the Property because said Defendants, and each of them, did not
properly comply with the terms of Defendants’ own securitization requirements and
falsely or fraudulently prepared documents required for Defendants, and each of them, to
45. Plaintiff requests that this Court find that the purported power of sale contained in the
Note and Deed of Trust has no force and effect at this time, because Defendants’ actions
in the processing, handling and foreclosure of this loan involved numerous fraudulent,
false, deceptive and misleading practices, including, but not limited to, violations of State
disadvantage to Defendants, and each of them. Plaintiff further requests that title to the
Property remain in its name, with said Deed of Trust remaining in beneficiaries’ name,
during the pendency of this litigation, and deem that any attempted sale of the Property is
46. The irrefutable argument referenced above which voids all mortgages contained within
the referenced trust and the trust itself, indicates that all actions having occurred since are
considered “unlawful and void.” Therefore, not a single Defendant listed above
including Defendant MERS can have any legal, equitable or actual beneficial
interest whatsoever in the Property. Plaintiff re-states that ALL referenced Defendants
also named in the related federal litigation stand UNOPPOSED to this evidenced
same Defendants to bring a contradicting (or ANY) argument will show cause for the
Plaintiff to raise (at minimum) a Fraud on the Court claim here, pursuant to
47. Defendants, and each of them, through the actions alleged above, have or claimed the
right to illegally commence foreclosure under the Note on the Property via a foreclosure
action supported by false or fraudulent documents. Said unlawful foreclosure action has
caused and continues to cause Plaintiff’s great and irreparable injury in that real property
is unique.
48. The wrongful conduct of the above specified Defendants, and each of them, unless
restrained and enjoined by an Order of the Court, will continue to cause great and
irreparable harm to the Plaintiff. Plaintiff has not had the beneficial use and enjoyment of
his home since being wrongfully displaced by Defendants following the referenced
49. Plaintiff has no other plain, speedy or adequate remedy and the injunctive relief prayed
for below is necessary and appropriate at this time to remedy the irreparable loss to
Plaintiff. Plaintiff has suffered and will continue to suffer in the future unless
inherently unique and it will be impossible for Plaintiff to determine the precise amount
December 30, 2005 (hereafter referred to as “Closing Date”) Plaintiff entered into a
loan secured by Plaintiff’s principal residence (Subject Property). This note was secured
51. ALL Defendants named herein claim an interest and estate in the property adverse to
Plaintiff in that Defendant asserts he is the owner of the note secured by the deed of trust
52. ALL Defendants named herein claim an interest and estate in the property adverse to
Plaintiff in that Defendant asserts he is the owner of the deed of trust securing the note to
53. The claims of ALL Defendants are without any right whatsoever, and Defendants have
no right, estate, title, lien or interest in or to the property, or any part of the property.
54. The claim of ALL Defendants herein named, and each of them, claim some estate, right,
title, lien, or interest, in or to the property adverse to Plaintiff’s title, and these claims
55. Plaintiff, therefore, alleges upon information and belief, that none of the parties, to
neither the securitization transaction, nor any of the Defendants in this case, hold a
perfected and secured claim in the Property, and that all Defendants are estopped and
persons claiming under them, from asserting any adverse claim to Plaintiff’s title to the
Property; and
57. Plaintiff requests the Court award Mohan A. Harihar costs associated with this action,
58. Plaintiff re-alleges and incorporates by reference all preceding paragraphs as though fully
59. An actual controversy has arisen and now exists between Plaintiff and Defendants
concerning their respective rights and duties regarding the Note and Trust Deed.
60. Plaintiff contends that Bank Defendants had no authority to Displace the Plaintiff from
his Property, nor did they have the authority to Foreclose upon and sell the property.
61. Plaintiff is informed and believes and upon that basis alleges that Bank Defendants
dispute Plaintiff’s contention and instead contend they had the authority to displace,
62. Plaintiff therefore requests a judicial determination of the rights, obligations, and interest
of the parties with regards to the Property, and such determination is necessary and
appropriate at this time under the circumstances so that all parties may ascertain and
know their rights, obligations, and interest with regard to the property.
63. From (at minimum) the UNOPPOSED argument(s) of Federal record previously
described, Plaintiff requests a determination of the validity of the Trust Deeds as of the
Date the Notes were assigned without a concurrent assignation of the underlying Trust
Deeds.
64. From (at minimum) the UNOPPOSED argument(s) of Federal record previously
Default).
65. From (at minimum) the UNOPPOSED argument(s) of Federal record previously
66. Plaintiff requests all adverse claims to the real property must be determined by a decree
of this Court.
67. Plaintiff requests the decree declare and adjudge that Plaintiff is entitled to the exclusive
68. Plaintiff requests the decree declare and adjudge that Plaintiff owns in fee simple and is
entitled to the quiet and peaceful possession of, the above-described real property.
69. Plaintiff requests the decree declare and adjudge that Defendants, and each of them, and
all persons claiming under them, have no estate, right, title, lien or interest in or to the
70. Plaintiff re-alleges and incorporates by reference all preceding paragraphs as though fully
71. Plaintiff is entitled to rescind the loan and all accompanying loan documents for all of the
foregoing reasons: 1.) Lack of Standing; 2.) Failure to provide a VALID Mortgage Loan
Origination Agreement; 3.) Failure to abide by the PSA; 4.) making illegal or fraudulent
transfers of the note and deed of trust; and 5.) Public Policy Grounds, each of which
72. The Public interest would be prejudiced by permitting the alleged contract to stand; such
73. As a proximate result of Defendants’ actions, Plaintiff has been damaged in an amount
WHEREFORE, Plaintiff prays for rescission of the stated loan AND mortgage in their
entirety.
WHEREFORE Plaintiff, will ask for the following for each Cause of Action to be
awarded:
PRIOR to moving forward, the Plaintiff respectfully requests that this Court FIRST issue a
Housing, 2.) Transportation and 3.) other related costs as they existed BEFORE the
CONCLUSION
In summary, the Plaintiff wants to rightfully return to HIS HOME, without further
SHOULD be more than enough to correct past erred judgments made by this Commonwealth as
regarding ANY portion of this Complaint, the Plaintiff is happy to provide additional supporting
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
Attachment A
Attachment B
CERTIFICATE OF SERVICE
I hereby certify that on May 11, 2018 and as directed by the Court, I filed the foregoing with the
Clerk of Court via certified (USPS) mail. Copies of the amended complaint along with the
associated summons’ were sent via certified (USPS) mail (as allowed by the Court) to the
following Defendants at their last known address:
1. US BANK, NA
Attn: Andrew J. Cecere, Chairman/President/CEO
800 Nicollet Mall
Minneapolis, Minnesota 55402
2. WELLS FARGO, NA
Attn: Michael Bradford, President
101 North Phillips Avenue
Sioux Falls, SD 57104
United States
3. MERS, Inc.
Bill Beckmann, President/CEO
1818 Library Street, Suite 300
Reston, Virginia, 20190
4. JEFFREY PERKINS
168 Parkview Avenue
Lowell, MA 01852
5. ISABELLE PERKINS
168 Parkview Avenue
Lowell, MA 01852
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com