Académique Documents
Professionnel Documents
Culture Documents
The Plaintiff – MOHAN A. HARIHAR, a pro se litigant, respectfully informs the Court of
the following – including specific requests for the approaching Rule 16 conference scheduled
for 05/14/2019:
1. The Plaintiff requests clarification to confirm this Rule 16 conference is open for the
general Public to attend, including the Media. The Plaintiff has consistently stated his
concerns for personal safety and security – concerns which continue to be ignored by
2. This Court is aware that claims against the named Defendants AND their retained
counsel include evidenced criminal complaints filed with both the Massachusetts
Office of the Attorney General (MA AGO) and the US Department of Justice (DOJ).
This is just one (1) of the primary issues to be addressed at this scheduled Rule 16
informing both Offices of the upcoming conference1; and requests for their
indictments against all named Defendants and counsel. Please be advised, based on
indictments against referenced parties will show cause to expand upon (or file new)
existing Color of Law and Due Process violations against the Commonwealth and
separately against The United States.2 The Plaintiff requests that the Court issue a
timely order requiring the attendance of the MA AGO and the US Attorney’s office
for the purpose of providing for the record - their respective intentions to bring
3. To be clear, if it is revealed that the MA AGO does not intend to bring criminal
indictments against all named Defendants, the Plaintiff will (at minimum) show cause
to expand upon (or file NEW) Due Process/Color of Law violations against the
Commonwealth.
4. Similarly, if the US Attorney’s Office (MA) reveals that it does not intend to bring
criminal indictments against all named Defendants, the Plaintiff will (at minimum)
show cause to expand upon (or file NEW) Due Process/Color of Law violations
5. The Plaintiff has now evidenced before the American Public systemic judicial abuses
of power at EVERY level of the Massachusetts State Judiciary AND the Federal
1
See Exhibit 1.
2
The Plaintiff references the related Federal Complaints: (1) HARIHAR v US BANK, et al, Certiorari Petition No.
18-7752, which includes the Commonwealth as a Defendant; and (2) HARIHAR v THE UNITED STATES,
Appeal No. 17-2074.
Judiciary, including the Supreme Court of The United States (SCOTUS). If after a
THOROUGH review of this litigation’s eight 8-year history, this Court fails to
recognize or acknowledge ANY: (1) judicial failures; (2) erred judgments; or (3)
misconduct by the Defendants AND their retained counsel, it will add incrementally
to claims against this Commonwealth and show cause for recusal. As part of the
issues to be addressed at the Rule 16 Conference, there is a clear expectation for the
Hon. Judge Maureen Hogan to identify and correct erred judgements made by: (1)
this Middlesex Superior Court; (2) the Northeast Housing Court; and (3) the MA
Land Court – including the improper Transfer of this Docket. Any failure to do so
6. The Plaintiff respectfully requests that the Defendants provide for the record – in
writing and prior to the scheduled Rule 16 conference, whether or not they are
7. This Court is respectfully reminded that another primary issue for discussion includes
the UNOPPOSED – Mass. R. Civ. P. 60(b)(3), Fraud on the Court claim, which
was blatantly ignored by THIS Court.3 Based on this clearly evidenced and
into a mutual agreement discussion with these Defendants. However, as a sign of his
continued GOOD FAITH, Mr. Harihar is willing to extend this opportunity to reach
a mutual agreement on the CIVIL portions of this complaint. If Defendants state for
the record that they have no interest in reaching a mutual agreement, this Court must
correct their previous errors and uphold the evidenced Rule 60 claim with a
3
The Plaintiff references Middlesex Superior Court Docket No. 1181CV04499.
DEFAULT judgement in favor of the Plaintiff – Mohan A. Harihar, with
prejudice.
8. Another issue for discussion involves related litigation in the Lowell District Court –
Jeanne D’Arc Credit Union v. Mohan A. Harihar, Docket No. 1211SP442. The
UNNECESSARILY for the following reasons: (1) judicial errors; (2) failures by
state/federal prosecutors; and (3) the Defendants refusal to reach a mutual agreement.
Therefore, the Plaintiff also seeks this court’s assistance with the following: (1) A
STAY order issued against ALL creditors while this litigation over the identified
illegal foreclosure and subsequent damages is ongoing; and (2) consideration for a
TRANSFER of the District Court docket to this Superior Court – since the cause of
Plaintiff’s financial hardship stems from the evidenced actions of these Defendants
Please be advised, based on the Plaintiff’s interpretation of the law, any attempt by a presiding
judicial officer to continue these proceedings without FIRST clarifying jurisdiction – for the
record, will be interpreted as an act of Treason under ARTICLE III. The Plaintiff respectfully
restates this Court should FIRST: (1) initiate CORRECTIVE action associated with referenced
erred judgments related to this docket; and (2) determine whether parties are willing to consider
litigation and includes matters perceived to impact National Security. Therefore, the
2. US Secret Service;
6. FBI;
Copies of this email will also be made available to the Public and to media outlets nationwide for
documentation purposes and out of continued concerns for my personal safety and security.
If your Honor has ANY questions regarding ANY portion of this Notice, or requires
additional information, the Plaintiff is happy to provide upon request. The Plaintiff is
Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
May 6, 2019 Mo.harihar@gmail.com
Exhibit 1
Mohan Harihar <moharihar@gmail.com>
As you know, formal state and federal criminal complaints have long been filed against the
Defendants (including their retained counsel) associated with:
On Tuesday, May 14, 2019, a Rule 16 Conference is scheduled in the Middlesex Superior Court
(Woburn, MA) for the purpose of discussing multiple issues impacting this litigation. These issues
include the evidenced criminal complaints filed against named Defendants including their retained
counsel - and the Plaintiff's intention to enjoin the civil complaint(s) with criminal indictments. Both the
MA AGO and the US Attorney's Office are requested to attend this scheduled conference, for the
purpose of informing the Court as a matter of record - their respective intentions to bring criminal
indictments against referenced parties. Please be advised, a copy of this email communication will be
included in a Notice to the Court. Respectfully, both offices are aware that this State litigation is
related to referenced Federal litigation and includes matters perceived to impact National
Security. Therefore, the following government offices/agencies/committees will necessarily receive
copies of this communication (via email, US Mail and/or social media):
Copies of this email will also be made available to the Public and to media outlets nationwide for
documentation purposes and out of continued concerns for my personal safety and security. If
you have ANY questions regarding ANY portion of this Notice, please advise. Thank you for your
Respectfully submitted,
Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
CERTIFICATE OF SERVICE
I hereby certify that on May 6, 2019, I filed the foregoing Opposition with the Clerk of the
Court and counsel for the Defendants (listed below) via US Mail and Email Communication:
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
617.921.2526 (Mobile)
Mo.harihar@gmail.com