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UNITED STATES DISTRICT COURT

for the
DISTRICT OF MASSACHUSETTS

)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. 17-cv-11109
v. )
)
THE UNITED STATES OF AMERICA, )
)
Defendant )
)

PLAINTIFF REPLY TO VOID ORDER ISSUED BY DISQUALIFIED JUDICIAL


OFFICER – HON. DENISE J. CASPER IDENTIFIES INCREMENTAL VIOLATIONS
OF JUDICIAL TREASON UNDER ARTICLE III AND 18 U.S.C. § 2381

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

REPLY after a DISQUALIFIED judicial officer – acting on behalf of The United States issued

an incremental (VOID) order without jurisdiction. The Plaintiff references the following court

document he received by US mail on Saturday, September 14, 2019, which stated:

“Judge Denise J. Casper: ELECTRONIC ORDER entered denying as moot22 Motion to

Amend Complaint. Given D. 14,15, prior dismissal of complaint, Court of Appeals affirming

same over a year ago, D. 207, there is no complaint to amend and this case remains closed.

(Hourihan, Lisa)”1

1
See Exhibit 1
In the Plaintiff’s original motion, the Court is respectfully reminded that US District Court

Judge – Hon. Denise J. Casper has already LOST jurisdiction to rule further in this or ANY

related litigation, for the SAME IDENTICAL reasons that brought the sua sponte recusal of

the Hon. Allison Dale Burroughs.2 A review of the historical record shows that the Plaintiff has

articulated the evidenced FACTS that clearly support his position – including a VOID Dismissal

order associated with this complaint (Reference ECF No.’s [13], [14], [15] and [16]). Therefore,

jurisdiction has NOT yet been restored. Respectfully, the conscious decision to continue

ruling without jurisdiction shows cause to now bring incremental misconduct claims against

Judge Casper including (but not limited to): (1) Judicial Treason under ARTICLE III and 18

U.S.C. § 2381. Serving as witnesses to this evidenced act of Judicial Treason (aside from the

Plaintiff) is counsel for the Defendant – The United States, Assistant US Attorney Mary

Murrane and Clerk of the Court Lisa Hourihan; (2) Judicial Fraud on the Court claims

under Fed. R. Civ. P.60(b)(2),(3), (4) and (6); (3) Color of Law Violations under 18 U.S.

Code § 242; (4) Due Process and other claims. Separately, since Judge Casper is a judicial

officer acting on behalf of The United States, the Plaintiff AGAIN shows cause to amend his

original complaint.

Collectively, the following issues remain unresolved on this docket:

1. Jurisdiction has NOT been restored – for reasons described above;

2. Judge Casper has REFUSED to recuse herself - despite the evidenced allegations of

record that immediately disqualify her from ruling further in this (or any related)

litigation;

2
See Exhibit 2
3. The Dismissal Order is VOID – Therefore, the case is still OPEN;

4. The District Court’s failure to VACATE orders following the sua sponte RECUSAL

of Judge Allison Dale Burroughs and the unprecedented EIGHT (8) related recusals

that have followed since;

5. The RECUSALS of the initial First Circuit Panel assigned to this Appeal – which

included Circuit Judges: (1) Hon. Juan R. Torruella; (2) Hon. William J. Kayatta, Jr.;

and (3) Hon. David J. Barron. As a respectful reminder, these recusals resulted from the

SAME IDENTICAL PATTERN OF CORRUPT CONDUCT that brought the initial

recusal of Judge Burroughs.

6. The Replacement Circuit Panel’s REFUSAL to RECUSE – after the

Plaintiff/Appellant AGAIN evidenced the same identical pattern of corrupt conduct

that brought the recusal(s) of the initial panel and Judge Burroughs. This replacement

panel consisted of: (1) Chief Judge – Hon. Jeffrey R. Howard; (2) Circuit Judge –

Hon. O. Rogeriee Thompson; and (3) Circuit Judge – Hon. Kermit V. Lipez. The

conscious decision by the replacement panel to brush aside all of the Appellant’s

evidenced claims and issue a VOID order without jurisdiction ultimately showed the

continued intent to reach a corrupt and pre-determined outcome. As required by

Federal law, the Appellant similarly brought evidenced Judicial Treason claims under

ARTICLE III and 18 U.S.C. § 2381 - updating the White House, members of Congress,

as well as the Office of the First Circuit Executive and the Administrative Office of

US Courts. The failure to acknowledge these facts of record re-affirm the systemic

judicial failures evidenced by this First Circuit.

7. Congressional intervention is expected – Based on the Plaintiff’s interpretation of the


law, the severity of evidenced claims against First Circuit judicial officers shows cause

for impeachment and potential removal from the bench under ARTICLES II & III.

Congressional leaders in the Commonwealth of Massachusetts have been regularly

updated throughout the 8-year history of this litigation – along with the demand to bring

these systemic judicial failures to the immediate attention of the House and Senate

Judiciary Committees. Informed Congressional leaders include (but are limited to): (1)

US Senator (and 2020 Presidential Candidate) Elizabeth Warren (D-MA); (2) US

Senator Ed Markey (D-MA); (3) US Congresswoman Lori Trahan (D-MA); and (4)

US Congresswoman Ayanna Pressley (D-MA).

8. Refusal to assist with the appointment of counsel – the ever-growing complexity of

legal issues associated with this litigation has provided a TEXTBOOK example to

exercise judicial discretion under 28 U.S.C. § 1915, by assisting the Plaintiff with the

appointment of counsel. This continued failure is a contributing factor that re-affirms the

systemic judicial abuses plaguing this First Circuit; and what appears as complete disdain

for the pro se litigant.

9. The Plaintiff awaits a response from the Office US Attorney General - as a sign of his

continued Good Faith, the Plaintiff has respectfully extended an opportunity to have a

mutual agreement discussion – with US Attorney General Barr and the EOP

(Executive Office of the President) regarding the civil portions associated with this

complaint.3 Ultimately, the Plaintiff believes there exists an opportunity to reach a mutual

agreement that is both constructive and which contributes to the overall benefit of our

great Nation.

3
See Exhibit 3 - Referencing the Plaintiff email directed to the attention of UA Attorney General William Barr.
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 REPLY: (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 identified, will likely

have evidentiary support after a reasonable opportunity for further investigation or discovery; and

(4) the REPLY 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)4;


2. US Secret Service;
3. The US Supreme Court (SCOTUS);
4. Securities and Exchange Commission (SEC);
5. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;
6. Department of Justice (DOJ) - specifically, US Attorney General, William Barr;
7. Federal Bureau of Investigation (FBI);
8. Administrative Office of US Courts - specifically, Director James C. Duff;
9. House/Senate Judiciary Committees;
10. Governor Charlie Baker (R-MA);
11. US Senator Elizabeth Warren (D-MA);
12. US Senator Ed Markey (D-MA);
13. US Congresswoman Lori Trahan (D-MA);
14. US Congresswoman Ayanna Pressley (D-MA);

Copies of this REPLY will also be made available to the Public and to media outlets nationwide

4
See Exhibit 4 to review to the email confirmation of receipt from the White House.
for documentation purposes and out of continued concerns for the Plaintiff’s personal safety

and security. Once jurisdiction has been re-established, If the Court has ANY questions

regarding any portion of this REPLY, 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.

Respectfully submitted this 17th Day of September, 2019

Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
Exhibit 1
Exhibit 2
Exhibit 3
Mohan Harihar <moharihar@gmail.com>

Please Forward to the Direct Attention of US Attorney General - William


Barr
Mohan Harihar <moharihar@gmail.com> Sat, Sep 7, 2019 at 2:59 PM
To: theresa watson3 <theresa.watson3@usdoj.gov>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>,
governor.schedule@state.ma.us, "Constituent.services@state.ma.us"
<constituent.services@massmail.state.ma.us>, elizabeth warren
<elizabeth_warren@warren.senate.gov>, Nora Keefe <Nora_Keefe@warren.senate.gov>, Nairoby
Gabriel <Nairoby_Gabriel@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>, chairmanoffice@sec.gov, CommissionerJackson@sec.gov,
CommissionerStein@sec.gov, CommissionerPeirce@sec.gov, andrew lelling
<andrew.lelling@usdoj.gov>, mary murrane <mary.murrane@usdoj.gov>, christina sterling
<christina.sterling@usdoj.gov>

Dear Director Watson,

I respectfully request that you forward this email to the direct attention of US Attorney General
William Barr, as numerous efforts to communicate with the US Attorney's Office in the District of
Massachusetts are apparently being ignored. Since you have historically been copied on multiple
email communications related to the referenced litigation (Attached Below), you are aware of the
systemic judicial failures evidenced by the First Circuit, including the Office of the First Circuit
Executive. A portion of these evidenced failures include (but are not limited to): (1) Judicial Treason;
(2) Economic Espionage; (3) RICO violations; (4) Color of Law/Due Process violations - and a
host of others. The most recent examples have been evidenced by RECUSED US District Court
Judge - Hon. Allison Dale Burroughs, who issued two (2) orders without jurisdiction on 7/29/19 and
8/2/19 (Referencing HARIHAR v US BANK et al, Docket No. 15-cv-11880, See Below) and included
the threat of sanctions against the Plaintiff.

After updating my judicial misconduct complaint filed with the Circuit Executive, I received a letter
(dated 8/21/19, attached below) which stated that I was no longer allowed to report judicial
misconduct - including evidenced acts of Treason against The United States of America. Due
to the severity of these evidenced claims, I respectfully request that you now bring these recent
developments to the direct attention of US Attorney General William Barr - as they include
evidenced criminal violations by judicial officers and are perceived to impact matters of National
Security.

Separately - as a sign of my continued Good Faith, I am respectfully extending an opportunity to


have a mutual agreement discussion - with Attorney General Barr and the EOP (Executive Office
of the President) regarding the civil portions associated with HARIHAR v THE UNITED STATES
(Docket No. 17-cv-11109). This would include a discussion over rights to the Plaintiff's Intellectual
Property/Trade Secret known as the HARIHAR FCS Model. Ultimately, I believe there is an
opportunity to reach a mutual agreement that is both constructive and which contributes to the overall
benefit of our great Nation.
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 email communication (via email, US Mail and/or social media):

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


2. US Secret Service;
3. The US Supreme Court (SCOTUS);
4. Securities and Exchange Commission (SEC);
5. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;
6. Administrative Office of US Courts - specifically, Director James C. Duff;
7. House/Senate Judiciary Committees;
8. Governor Charlie Baker (R-MA);
9. US Senator Elizabeth Warren (D-MA);
10. US Senator Ed Markey (D-MA);
11. US Congresswoman Lori Trahan (D-MA);
12. US Congresswoman Ayanna Pressley (D-MA);

Copies of this letter will also be made available to the Public and to media outlets nationwide for
documentation purposes and out of continued concerns for the Plaintiff's personal safety and
security. If you have ANY questions regarding any portion of this email, or require additional
information, I will be happy to provide upon request.

Thank you for your attention to this very serious matter. I look forward to a response from the
Attorney General.

Respectfully submitted this 7th Day of September, 2019

Respectfully,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Exhibit 4