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 BANK DEFENDANTS’ OPPOSITION RE:

VOID LAND COURT ORDER AND ADDITIONAL DOCUMENTS

FILED 02/13/19

On February 15, 2019, TWENTY-FOUR (24) days after the Plaintiff – Mohan A. Harihar

raised questions surrounding the improper transfer and jurisdiction of this Court, opposition (and

additional documents) was received from counsel representing the Bank Defendants – WELLS

FARGO and US BANK.

Respectfully, the Plaintiff is still waiting for this Court to address 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, his 1/22/19 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. Additionally, please be

advised of the following:

1. The documents filed here by ALL Defendants (Bank Defendants, Isabelle/Jeffrey Perkins

and MERS Inc.) indicate the intention to continue deceiving this court. 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 in the related Federal

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

supplement to the Petition will necessarily be filed next by the Plaintiff;

2. 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 Governor Charlie Baker (R-MA) and also the President. 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;

3. By now, this court should be 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

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

will be requested for the record as to how a conclusion was reached (including exactly
 which documents were reviewed), as it may (at minimum) also bear impact to ongoing

Federal litigation;

4. 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

AGO; (2) the US Attorney’s Office; and (3) the former law firm representing the Bank

Defendants here (Referencing Nelson Mullins, LLP, who withdrew from this case). The

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. 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. 1 The Plaintiff requests that this Court now 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

5. Finally, there also appears to be a document filed by counsel for Defendants –

Jeffrey/Isabelle Perkins and MERS on February 13, 2019. The Plaintiff has not received a

copy of said document. Regardless, for the reasons described within, documents filed by

ALL Defendants should be stricken from the record until jurisdiction (and all other)

issues have been resolved.

1
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”.
Since this case is related to the referenced Federal litigation and 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)2;

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;

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.

2
See Exhibit 2
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 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 February 20, 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
Mo.harihar@gmail.com