FOR IMMEDIATE RELEASE

Plaintiff in $42B Lawsuit, Harihar vs US Bank calling for

Recusal of Judge Allison D. Burroughs for a 2nd time
Boston, MA, December 9, 2016 A response to a judicial order, denying an injunction was filed two
days ago, in the US District Court (Boston, MA, Docket No: 15-cv-11880, Harihar vs. US Bank et al) by
the pro se Plaintiff, Mohan A. Harihar. Harihars filed response calls for a 2nd time the IMMEDIATE
RECUSAL of the presiding judge Allison D. Burroughs. Since filing the Federal lawsuit in May
2015, Harihar has brought a number of judicial misconduct allegations against Judge Burroughs.
These evidenced allegations include (but are not limited to):
1. Incidents of prejudice/bias, favoring referenced Defendants;
2. Refusing to acknowledge/recognize primary issues within the Plaintiffs complaint including
(but not limited to) the Plaintiffs Intellectual Property Rights, and the Economic framework
designed to assist the United States with economic recovery/growth from damages caused by
the US Foreclosure/Financial Crisis.1
3. Failure to uphold Federal Rules of Civil Procedure;
4. Failing to maintain a fair Balance of Hardships;
5. Refusal to assist with the appointment of Counsel;
6. Refusal to schedule a hearing(s) for clarification and documentation purposes for the record,
in the event it becomes necessary for the Plaintiff to file an appeal;
7. Treason against the Constitution of the United States (three alleged acts);
8. Refusal to recuse.
9. BAD FAITH Acts
In his conclusion, Harihar states: It becomes necessary here to restate the LEGAL intentions of the
Plaintiff:
1. To hold ALL parties legally responsible for damages caused by the referenced ILLEGAL
FORECLOSURE;
2. To set a legal precedent that would allow the millions of Americans similarly harmed to
rightfully do the same; and
3. Gain alignment with the United States to potentially implement the Plaintiffs Intellectual
Property, known as the Harihar FCS Model, resulting in an estimated $5T (or greater) of
economic growth to the United States.
Litigants have the right to expect a judge hearing their case will be fair and impartial, and avoid even
the appearance of impropriety. Regrettably, neither the Plaintiff, nor ANY objective person who has
followed this litigation can have that expectation in Judge Burroughs' courtroom. It is the Plaintiffs

The Intellectual Property Rights of the Plaintiff include, (but are not limited) to the Harihar FCS
Model an economic framework recognized by the Executive Office of the President (EOP)
including Vice President Joe Biden, the (former) Deputy Chief Counsel of the House Financial
Services Committee Gail Laster, Senior Economic advisor to US Senator Elizabeth Warren
(D-MA), the Congressional Office of Congresswoman Niki Tsongas (D-MA), and others.

ABSOLUTE opinion, that the evidenced acts of judicial misconduct clearly exemplify malicious intent
to (at minimum): 1.) Critically damage the legal efforts of this Plaintiff; 2.) Negatively impact the
resulting precedent set; and 3.) Ultimately prevent the implementation of a framework designed to
repair and grow the United States Economy.
[How] to check these unconstitutional invasions of rights by the Federal judiciary? Not by
impeachment in the first instance, but by a strong protestation of both houses of Congress that
such and such doctrines advanced by the Supreme Court are contrary to the Constitution; and
if afterwards they relapse into the same heresies, impeach and set the whole adrift. For what
was the government divided into three branches, but that each should watch over the others
and oppose their usurpations?
Thomas Jefferson, 1821
A judicial complaint, filed by Harihar against Judge Burroughs is still pending before the Judicial
Council of the First Circuit, and steps are now being taken to address this matter with the House
Judiciary Committee, and the incoming Presidential Administration.
(Scroll down to view a copy of Harihars filed Motion, in its entirety.)
For Further Media Information Contact: Mohan A. Harihar
Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR
11880
Plaintiff

CIVIL ACTION NO: 15-cv-

vs.
US BANK NA, et al.
Defendants

PLAINTIFF RESPONSE TO JUDICIAL ORDER - DOCUMENT NO. 133

After reviewing the judicial order in Document No. 133 issued

by Judge Allison D. Burroughs, the Plaintiff, Mohan A. Harihar,
acting pro se, identifies a number of troubling issues that
AGAIN warrant her immediate RECUSAL. SHOULD Judge Burroughs
refuse to recuse herself, the Plaintiff will necessarily
initiate next steps in bringing this matter to the attention of
the House Judiciary Committee. The Plaintiff respectfully files
with the Court, and a copy also to the Judicial Council of the
First Circuit the following response:

10.

Third (3rd) Act of Treason against the Constitution

By issuing the order associated with Document No. 133 (and

previously with Document No. 129 and Document No. 125),
the Plaintiff brings a third (3rd) allegation of Treason
to the Constitution against Judge Allison D. Burroughs.
For the reasons previously stated and on record with the
Court,2 the Plaintiff considers Judge Burroughs
disqualified by law, prohibiting her from issuing ANY
further rulings in this case. The Plaintiffs
interpretation of the law is that Judge Burroughs no
longer has jurisdiction to rule on this Docket. By doing
so, the judge has, for a THIRD time, acted in a personal
capacity versus a judicial capacity. Therefore, the
2

Reference Document No.s 121 thru 126.

3

Plaintiff considers the order associated with Document No.

133 (and ALL those prior) as VOID.3

Furthermore, Judge Burroughs has refused to recuse

herself, and has made no effort to address, dispute or
deny any of the supported allegations exemplifying
judicial misconduct, including Treason.

11.

Plaintiffs Creditors Even if Judge Burroughs still

had jurisdiction, it is the Plaintiffs clear belief, that

her actions exemplified in her issued order(s) continue to
display a pattern of corrupt conduct. In her Order,
Document No. 133, Judge Burroughs states, First,
Plaintiff has failed to establish why an injunction can
issue against his multiple creditors. The Plaintiff
respectfully disagrees. The Plaintiff has clearly
established the FACTS which have allegedly led to his
indigence, and which the Court has ALREADY acknowledged.
These FACTS include (but are not limited to) the
referenced allegations of misconduct, against these
Defendants (which include the Commonwealth of
A judicial misconduct complaint, and three supplemental
complaints, have been filed against Judge Allison D. Burroughs
where a decision(s) is pending before the Judicial Council of
the First Circuit. A fourth supplemental complaint to the
Judicial Council is now warranted.
3

Massachusetts and ALSO the United States) which have

negatively impacted the Plaintiffs marriage, family,
career, retirement and everyday way of living. The Court
is ALREADY aware that the United States and the
Commonwealth of Massachusetts are two (2) of these
creditors.4 Both the United States and the Commonwealth
have received notice through this litigation, thus
complying with Fed. R. Civ. Pro. 65(d)(2). Furthermore,
neither party (or any other) has filed opposition to this
requested injunction. While additional creditors also
exist, Judge Burroughs SHOULD have AT MINIMUM issued a
temporary injunction against the IRS and MADOR, while
legal matters proceed. Allowing the injunction to include
additional creditors, once compliant with Fed. R. Civ.
Pro. 65(d)(2), SHOULD also have been considered.

The Plaintiff has CLEARLY established why an injunction

can, and should issue. For Judge Burroughs to state
otherwise, AGAIN clearly suggests one (1) or more of the
following conclusions:

The Plaintiff owes the United States Federal taxes to the

Internal Revenue Service (IRS) and also to the Massachusetts
Department of Revenue (MADOR).
4

a. Judge Burroughs has ruled on a motion without reading

related filings, thus further questioning the judges
ability to be impartial;
b. Judge Burroughs may have forgotten the actual content
of the Motion and related filings, suggesting that
mental illness may be an issue here;
c. A

deep-seated

favoritism

or

antagonism

does

exist

making fair judgment impossible. It would appear (at

least on its surface), that elements of corruption
may exist here; and that an effort is being made by
an officer of the Court, to brush aside all motions
in

order

to

reach

corrupt

and

predetermined

outcome;
d. A combination of scenarios a, b or c exists.
12.

Four-Factor Test Judge Burroughs next states the

following, Here, Plaintiff has failed to make an adequate

showing that he is likely to succeed on the merits of any
of his claims, which is the main bearing wall of the fourfactor test that the Court uses to evaluate motions for
preliminary injunctive relief.
Again, the Plaintiff respectfully disagrees, referencing
Document No. 119, filed in August 2016, and previously in
April 2016, where the Plaintiff has ALREADY clearly
articulated his reasoning for each portion of the four-

factor test, including success on the merits. Considering

the FACTS presented to the Court, the generic opinion and
issued order by Judge Burroughs denying relief leads this
Plaintiff to draw the same troubling conclusions as
previously described above (see No. 2).

The Plaintiff also questions ALL THREE (3) case references

believed to be improperly applied by Judge Burroughs: 1.)
Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20,
(2008); 2.) G. & C. Merriam Co. v. Webster Dictionary Co.,
639 F.2d 29, 35 (1st Cir. 1980); and 3.) Corp. Techs.,
Inc. v. Harnett, 731 F.3d 6, 10 (1st Cir. 2013). Based on
the totality of FACTS presented by the Plaintiff, it is
unclear exactly how Judge Burroughs could have reached her
conclusions. The vague, and somewhat generic language
pattern of the order(s) calls for further clarification.
The Plaintiff AGAIN respectfully calls for a formal
hearing, so that further clarification can be provided by
Judge Burroughs on this, and several other orders in
question. The Plaintiff also respectfully requests that a
court reporter be present for the scheduled hearing.

13.

Pattern of Corrupt Conduct Since filing the initial

complaint with the Court on May 21, 2015, the Plaintiff

has necessarily brought a number of judicial misconduct

allegations against the presiding judge Allison D.
Burroughs. These supported allegations are all on record
with this US District Court, and are also before the
Judicial Council of the First Circuit. Evidenced
allegations raised by the Plaintiff include (but are not
limited to):
a. Incidents of prejudice/bias, favoring referenced
Defendants;
b. Refusing to acknowledge/recognize primary issues
within the Plaintiffs complaint including (but not
limited to) the Plaintiffs Intellectual Property
Rights, and the Economic framework designed to assist
the United States with economic recovery/growth from
damages caused by the US Foreclosure/Financial
Crisis.5
c. Failure to uphold Federal Rules of Civil Procedure;
d. Failing to maintain a fair balance of Hardships;
e. Refusal to assist with the appointment of Counsel;

The Intellectual Property Rights of the Plaintiff include,

(but are not limited) to the Harihar FCS Model an economic
framework recognized by the Executive Office of the President
(EOP), a Senior Officer of the House Financial Services
Committee, a Senior Economic advisor to a sitting US Senator, a
Congressional Office, and others.
5

f. Refusal to schedule a hearing(s) for clarification

and documentation purposes for the record, in the
event it becomes necessary for the Plaintiff to file
an appeal;
g. Treason against the Constitution of the United States
(three alleged acts);
h. Refusal to recuse.
i. BAD FAITH Acts
14.

BAD FAITH Actions against the Plaintiff -

With the

order associated with Document No. 133, the Plaintiff

considers this as an additional ACT MADE IN BAD FAITH, by
Judge Burroughs and the UNITED STATES against this
Plaintiff. The Plaintiff is still waiting for the United
States to take accountability for these acts made in bad
faith.
15.

Mutual Agreement Opportunity with the United States

In addition to bad faith acts, the Plaintiff still awaits

an ANSWER regarding the respectfully proposed Mutual
Agreement Opportunity, offered to the United States by the
Plaintiff.
Conclusion

It becomes necessary here to restate the LEGAL intentions of

the Plaintiff:

4. To hold ALL parties legally responsible for damages caused

by the referenced ILLEGAL FORECLOSURE;
5. To set a legal precedent that would allow the millions of
Americans similarly harmed to rightfully do the same; and
6. Gain alignment with the United States to potentially
implement the Plaintiffs Intellectual Property, known as
the Harihar FCS Model, resulting in an estimated $5T (or
greater) of economic growth to the United States.

Litigants have the right to expect a judge hearing their case

will be fair and impartial, and avoid even the appearance of
impropriety. Regrettably, neither the Plaintiff, nor ANY
objective person who has followed this litigation can have that
expectation in Judge Burroughs' courtroom. It is the
Plaintiffs ABSOLUTE opinion, that the evidenced acts of
judicial misconduct clearly exemplify malicious intent to (at
minimum): 1.) Critically damage the legal efforts of this
Plaintiff; 2.) Negatively impact the resulting precedent set;
and 3.) Ultimately prevent the implementation of a framework
designed to repair and grow the United States Economy.

[How] to check these unconstitutional invasions of rights

by the Federal judiciary? Not by impeachment in the first
instance, but by a strong protestation of both houses of

10

Congress that such and such doctrines advanced by the

Supreme Court are contrary to the Constitution; and if
afterwards they relapse into the same heresies, impeach
and set the whole adrift. For what was the government
divided into three branches, but that each should watch
over the others and oppose their usurpations?
Thomas Jefferson, 1821

The Plaintiff - Mohan A. Harihar, respectfully repeats the

DEMAND for the immediate recusal of Judge Allison D. Burroughs.
Should Judge Burroughs again refuse to recuse herself, the
Judicial Council will again be updated, and next steps will
commence in addressing this matter with the House Judiciary
Committee and the incoming Presidential Administration. The
Plaintiff additionally requests that the United States take
accountability for the referenced acts made in bad faith, and
to provide an ANSWER regarding the referenced mutual agreement
opportunity, as requested.
If the Court has ANY questions, or requires additional
information or clarification, the Plaintiff is happy to provide
upon request.

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