FOR IMMEDIATE RELEASE

Color of Law Violations may be extending to a Federal level

in Harihar vs. US Bank, et al.
Boston, MA, March 25, 2016 In Harihar vs. US Bank et al. (Docket No: 15cv11880, US District
Court, Boston, MA), the Plaintiff, Mohan A. Harihar has delivered a follow-up email communication
to the United States Inspector General Michael E. Horowitz:
---------- Forwarded message ---------From: Mohan Harihar <moharihar@gmail.com>
Date: Fri, Mar 25, 2016 at 12:31 PM
Subject: UPDATE TO 3/14/16 COMMUNICATION DELIVERED TO INSPECTOR GENERAL - MICHAEL E. HOROWITZ
To: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>
Cc: Valerie_jarrett@who.eop.gov, jarrettpublic@who.eop.gov, kbranch@who.eop.gov, "elizabeth_warren@warren.senate.gov"
<elizabeth_warren@warren.senate.gov>, "mark_bayer@markey.senate.gov" <mark_bayer@markey.senate.gov>,
mark_gallagher@markey.senate.gov, "june.black@mail.house.gov" <june.black@mail.house.gov>, "timothy.sheehan@cfpb.gov"
<timothy.sheehan@cfpb.gov>, Press@usdoj.gov, bryan.olson@klgates.com, Jim Gray <jim.gray@nelsonmullins.com>

Dear Inspector General Horowitz,

This communication is respectfully sent as an update and follow-up to the March 14, 2016 email delivered to your direct attention (Attached below
for reference). In the referenced Docket No: 15-cv-11880, Harihar vs. US Bank, et al. (US District Court, Boston, MA), please be advised - A
timeline extension for service to ALL Defendants has been granted by the Court to April 27, 2016 (A copy of the order has been attached below).
The Court has also been informed, that it MAY become necessary to expand EVIDENCED - COLOR OF LAW allegations (18 U.S.C. 242;
18 U.S.C. 245; 42 U.S.C. 1983) beyond the Commonwealth to a Federal Level, should corrective action fail to take place by the
Department of Justice (DOJ). A copy of the Motion has been attached for reference.
I have yet to receive a response to the 3/14/16 email communication from you, your office (OIG) or the DOJ. For documentation purposes with the
Court, I respectfully request that a detailed response be received on or prior to March 31, 2016.
Copied on this email communication, and serving as witness to this communication are the following:
1.
2.
3.
4.
5.
6.
7.
8.

President Barack Obama (via Senior Advisor, Valerie Jarrett)

US Senator - Elizabeth Warren (MA)
US Senator - Ed Markey (MA)
Congresswoman - Nikki Tsongas (MA)
Assistant Deputy Director - Timothy Sheehan (CFPB)
The US Department of Justice (DOJ)
K & L Gates, LLP
Nelson Mullins, LLP

It remains my sincere hope that corrective action will be taken by the OIG/DOJ; that a mutual agreement will ultimately be reached by all parties in
the referenced litigation; and that successful alignment with the appropriate parties creates a path leading to historic economic growth for our
Country.

Respectfully,
Mohan A. Harihar
For Further Media Information Contact: Mohan A. Harihar
Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)
Follow on Twitter: Mohan Harihar@MH_Foreclosur

03/24/2016 40

Judge Allison D. Burroughs: ELECTRONIC ORDER entered

granting 39 Motion for Extension of Time. Plaintiff's Motion for an
Extension of Time to complete service [ECF No. 39] is hereby
ALLOWED, and Plaintiff's deadline to complete service is
extended until and including 4/27/2016. The Court, however, does
not anticipate granting any further requests for extensions of the
service deadline. (Folan, Karen) (Entered: 03/24/2016)

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR
11880

CIVIL ACTION NO: 2015-cv-

Plaintiff
v.
US BANK NA, et al.
Defendants
PLAINTIFF MOTION REQUESTING 30-DAY TIMELINE EXTENSION REGARDING
SERVICE TO DEFENDANTS

The Plaintiff, Mohan A. Harihar, respectfully files this Motion

requesting a 30-day timeline extension for service to the
referenced Defendants, based on the following:

1. Evidenced - Color of Law allegations (18 U.S.C. 242; 18

U.S.C. 245; 42 U.S.C. 1983) may now be extending beyond
the Commonwealth of Massachusetts to a Federal level
a. A letter drafted by the United States Department of
Justice (DOJ) on February 18, 2016, was received in the
first week of March 2016, by the Plaintiff.1 This Court
has already been made aware of the Plaintiffs efforts
to timely align with Federal Prosecutors regarding the
clearly evidenced civil and criminal allegations
associated with this docket. The statements made in the
referenced letter by the DOJ, stating that no
additional action will be taken in this matter,
indicate the following:

By allowing the clearly evidenced (and identified)

criminal misconduct against this Plaintiff to continue
without legal consequence, The United States Department
of Justice makes clear that it will not protect this
Plaintiff, an American born citizen, against the crimes
committed against him. Allegations signifying (at
minimum) Color of Law violations (18 U.S.C. 242; 18
U.S.C. 245; 42 U.S.C. 1983) clearly evidenced within

See Exhibit A, to view the referenced DOJ letter, in its

entirety.
3

the Commonwealth of Massachusetts will necessarily be

expanded to a Federal level.

b. In fairness to the DOJ, it is unclear as to whether

investigators have fully investigated (and VALIDATED)
ALL of the related information and evidence prior to
drafting the 2/18/16 letter. It is assumed that they
may not have.
c. This Court is respectfully reminded, that the evidenced
allegations included in the Plaintiffs second amended
complaint include allegations of evidenced RICO
violations and improper relationships/Collusion
involving the United States Attorneys Office (MA),
Massachusetts Attorney Generals Office, the Boston BAR
Association, and Defendant Law firms and attorneys in
this case.2 These evidenced allegations show clear
cause to question the intentions of the DOJ, should
corrective action fail to be taken here.
d. The Plaintiff has respectfully requested that the DOJ
take corrective action - in the event that a full
investigation (and validation) has not yet taken place.
2

See Exhibit B the West LegalEd Center course entitled,

After the Bubble Bursts, clearly revealing the improper
relationships between the US Attorneys Office (MA), Attorney
Generals Office (MA), the Boston BAR Association, Defendant
Nelson Mullins LLP and Defendant Jeffrey S. Patterson.
4

Failure to do so will show clear cause to expand Color

of Law allegations to a Federal level.
e. This Court has already been made aware, that due to the
serious and sensitive nature of the referenced
allegations, it has become necessary for the Plaintiff
to involve the Office of the United States Inspector
General (OIG). My last conversation with the OIG took
place on January 27, 2016, with Special Agent - Kevin
McCormack, who informed me that this matter had been
directed to, and was being investigated by the
Executive Office of the DOJ. Special Agent McCormack
additionally stated that pending the outcome of the DOJ
investigation, it may become necessary to return to the
Office of the Inspector General. Sadly, that is the
situation now.
f. An email communication has now been delivered to the
direct attention of US Inspector General - Michael E.
Horowitz.3 President Obama (via Senior Advisor Valerie Jarrett), US Senator Elizabeth Warren (MA),
US Senator Ed Markey (MA), and Congresswoman Niki
Tsongas (MA) are copied on the email communication and
are considered as witnesses to the DOJ 2/18/16 letter.
3

See Exhibit C, to view the E-mail communication to the direct

attention of US Inspector General - Michael E. Horowitz on
March 14, 2016, in its entirety.
5

g. The Plaintiff awaits a response from Inspector General

Horowitz, with clear expectation that a Special
Prosecutor must now be assigned. Pending this response
from the Inspector General, a 30-day extended timeline
is now necessary for proceeding with service to the
Defendants either with the assistance of Federal
Prosecutors, or without.
h. Even if Plaintiff alignment with the DOJ were to occur,
it is unlikely that service to ALL Defendants can be
timely completed, given the current service deadline of
March 27, 2016.

Should this Court grant the Plaintiffs extension request, one

(1) of the following next-step scenarios is expected:
1. The United States Department of Justice will take
corrective action to align with this Plaintiffs
civil/criminal complaint, and to prepare in bringing
criminal charges against the named Defendants, expanding
the list of Defendants if deemed necessary. Service to ALL
listed Defendants will have taken place on, or prior to
the 30-day extension timeline. As previously stated, the
filing of a third amended complaint will be necessary.
2. The United States Department of Justice does not take
corrective action thereby showing clear cause to expand

Color of Law allegations to a Federal Level; with the

President, members of the US Senate and Congress serving
as witness. Should this occur, the Plaintiff will
immediately notify/update the Court. The Plaintiff (either
with the assistance of counsel or pro se) will ensure that
service to ALL listed Defendants will have taken place on,
or prior to the allowed 30-day extension timeline. As
previously stated, the filing of a third amended complaint
will be necessary.

The Plaintiff respectfully reminds the Court that the

DOJ (and the MA Attorney Generals Office) have confirmed
publicly, violations of Federal and State Law directly
related to the Plaintiffs foreclosure. If corrective
action is NOT taken by the DOJ, the Plaintiff clearly
states before the Court, that he does not feel safe or
protected in this Commonwealth or Nation, based on the
current stance of State and Federal Prosecutors in this
matter.

It remains my sincere hope that corrective action will be taken

by the OIG/DOJ; that a mutual agreement will ultimately be
reached by all parties in the referenced litigation; and that

successful alignment with the appropriate parties creates a

path leading to historic economic growth for our Country.

The Plaintiff is grateful for the Courts consideration of the

requested timeline extension.

Respectfully submitted,

Mohan A. Harihar
Plaintiff

Exhibit A

10

Exhibit B

11

12

Exhibit C

13

---------- Forwarded message ---------From: Mohan Harihar <moharihar@gmail.com>

Date: Mon, Mar 14, 2016 at 4:16 PM
Subject: TO THE ATTENTION OF INSPECTOR GENERAL - MICHAEL E. HOROWITZ
To: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, Press@usdoj.gov
Cc: Valerie_jarrett@who.eop.gov, jarrettpublic@who.eop.gov, kbranch@who.eop.gov, "elizabeth_warren@warren.senate.gov"
<elizabeth_warren@warren.senate.gov>, "mark_bayer@markey.senate.gov" <mark_bayer@markey.senate.gov>,
mark_gallagher@markey.senate.gov, "june.black@mail.house.gov" <june.black@mail.house.gov>, "timothy.sheehan@cfpb.gov"
<timothy.sheehan@cfpb.gov>

Dear Inspector General Horowitz,

After receiving the attached letter from the Department of Justice (PDF attached), it has now become necessary to send this email
communication to your direct attention. Please be advised - Copied on this email communication, and serving as witness to this referenced DOJ
letter are the following:
1.
2.
3.
4.
5.

President Barack Obama

US Senator - Elizabeth Warren (MA)
US Senator - Ed Markey (MA)
Congresswoman - Nikki Tsongas (MA)
Assistant Deputy Director - Timothy Sheehan (CFPB)

For the record, My name is Mohan A. Harihar - I am the Plaintiff in a civil/criminal complaint proceeding in the US District Court (Boston, MA),
Docket No: 2015-cv-11880, Harihar vs. US Bank et al. The well-supported allegations within this complaint have warranted direct
communication with your office.
My last conversation with your office took place on January 27, 2016, with Special Agent - Kevin McCormack, who informed me that this
matter had been directed to, and was being investigated by the Executive Office of the DOJ. Special Agent McCormack additionally stated that
pending the outcome of the DOJ investigation, it may become necessary to return to the Office of the Inspector General. Sadly, that is the
situation now.
You may be already aware - This complaint stems from mass violations of both Federal and State law, associated with the US Foreclosure
Crisis, already confirmed by the USDOJ, Federal Bank Regulators and the MA Attorney General. Additional allegations are considerable, well
supported and currently involve (at minimum) fourteen (14) Defendants. Well-supported allegations include (but are not limited to) FRAUD,
COLOR OF LAW VIOLATIONS, SEC Violations, COLLUSION, and documented violations of the RICO Act - involving state and federal officials.
The collective body of evidence over nearly five (5) years of litigation clearly indicates a mass-scheme, aligning referenced Defendants: Lenders,
retained counsel/law firms, government officials, judges, real estate professionals, and home buyers of a confirmed illegal foreclosure.
From the beginning, I have made clear throughout this litigation, that my primary objectives have been twofold:
1.
2.

Accountability for the harm and damages I have personally incurred, associated with the confirmed misconduct the DOJ has already
identified.
Alignment with the appropriate parties (i.e. - The United States Federal Government, The Federal Reserve), regarding the
referenced Intellectual Property belonging to the Plaintiff - Mohan A. Harihar (includes the HARIHAR - FCS Model). This
alignment would provide the opportunity to implement a framework designed to bring historic economic growth (estimated in the trillions
of dollars) to the US, while assisting those harmed by the US Foreclosure/Financial Crisis.

The referenced DOJ letter appears to have been drafted on February 18, 2016 and mailed via the US Postal Service on February 23, 2016 (See
attached). It was not until the first week of March that I received the DOJ letter. On February 24, 2016, a follow-up email communication was
delivered to the OIG/DOJ, President Obama, members of the US Senate/Congress, and others (Scroll down to view in its entirety). In that
referenced email communication, the following is clearly stated,

"Before moving forward with legal next steps in the US District Court, I respectfully request your assistance with the following:
1.
2.

Confirmation from each of the Defendants regarding their willingness (or lack thereof) to enter into a mutual settlement
discussion.
Establishing a dialogue with the appropriate parties, for the specific purpose of aligning with the referenced Intellectual
property/Economic Framework. Successful alignment MAY lead to resolving civil portions of the referenced complaint."

In fairness to the DOJ, it is unclear as to whether investigators have fully investigated (and VALIATED) ALL of the related information and
evidence prior to drafting the 2/18/16 letter. It is assumed that they may not have. It is also unclear whether any steps have been taken
regarding my specific requests from the referenced 2/24/16 email communication, as re-stated above. I ask now, for you assistance with
this clarification.
The timeliness of your response is critical, as summonses are scheduled to be delivered to ALL Defendants on, or prior to March 28, 2016. Should
the DOJ re-assess their position and take corrective action pertaining to this matter, alignment with both civil and criminal portions of the
referenced complaint are required in order to move forward with the legal process. If there are ANY questions regarding ANY portion of the
referenced allegations, please advise.
However, if corrective action here is not taken, please be advised of the following:

14

1.

2.
3.

4.
5.

Should the clearly evidenced criminal misconduct against this Plaintiff be allowed to continue without legal consequence, the United
States Department of Justice makes clear that it will not protect this Plaintiff, an American born citizen, against the crimes
committed against him. Allegations involving Color of Law violations clearly evidenced within the Commonwealth of
Massachusetts will necessarily be expanded to a Federal level.
It will become necessary for the DOJ to articulate before the US District Court, exactly how they arrived at their decision, considering
the enormity of evidenced allegations presented.
The evidenced criminal allegations within this complaint are directly tied to the US FORECLOSURE CRISIS - arguably considered the
LARGEST CASE OF FRAUD IN THE HISTORY OF THESE UNITED STATES. Any failure by the DOJ to take corrective action here
threatens the safety of ALL impacted AMERICANS. The number of impacted parties range from 4.2M to as high as 25M+.
Failure by the DOJ to take corrective action would further damage the Intellectual Property of the Plaintiff (includes the HARIHAR FCS MODEL), and the economic framework specifically designed to deliver trillions of dollars in economic growth to the US.
A copy of this email communication will be filed via NOTICE with the US District Court (Boston, MA) and the associated Docket No:
2015-11880, Harihar vs. US Bank et al.)

It remains my sincere hope that corrective action will be taken by the OIG/DOJ; that a mutual agreement will ultimately be reached by all parties in
the referenced litigation; and that successful alignment with the appropriate parties creates a path leading to historic economic growth for our
Country.

Respectfully submitted,

Mohan A. Harihar
Plaintiff

---------- Forwarded message ---------From: Mohan Harihar <moharihar@gmail.com>

Date: Wed, Feb 24, 2016 at 3:15 PM
Subject: DOJ/OIG Follow-up RE: Demand Letter - HARIHAR vs. US BANK et al, Docket No: 15cv11880
To: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, "christina.sterling@usdoj.gov" <christina.sterling@usdoj.gov>,
Press@usdoj.gov
Cc: Valerie_jarrett@who.eop.gov, jarrettpublic@who.eop.gov, kbranch@who.eop.gov, "timothy.sheehan@cfpb.gov"
<timothy.sheehan@cfpb.gov>, "elizabeth_warren@warren.senate.gov" <elizabeth_warren@warren.senate.gov>,
"mark_bayer@markey.senate.gov" <mark_bayer@markey.senate.gov>, mark_gallagher@markey.senate.gov, washington.field@ic.fbi.gov,
boston@ic.fbi.gov, ma-igo-general-mail@massmail.state.ma.us, "Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
"june.black@mail.house.gov" <june.black@mail.house.gov>, "eileen.donoghue@masenate.gov" <eileen.donoghue@masenate.gov>,
maura.healey@state.ma.us, "bryson@dor.state.ma.us" <bryson@dor.state.ma.us>

To the Executive Offices of the DOJ and the OIG,

This email is a follow-up to the January 26, 2016 communication regarding the DEMAND LETTER/SETTLEMENT OPPORTUNITY (see attached
below)sent to the Defendants named in Docket No: 2015-cv-11880, HARIHAR vs. US BANK et al (US District Court, Boston, MA).
I, Plaintiff - MOHAN A. HARIHAR, have since been informed by the OIG that this matter is now under investigation by the Executive Offices of the
DOJ.
Both offices are respectfully informed of the following:
1.

2.
3.

The timeline afforded to the referenced Defendants to reach a mutual agreement has since expired. Four (4) of the Defendants: US
Bank NA, Wells Fargo NA, David E. Fialkow (Esq.), and Jeffrey S. Patterson (Esq.) have filed Motions to Dismiss, and no
answer regarding the settlement opportunity.
The remaining ten (10) Defendants have provided no answer to the settlement opportunity.
A NOTICE was filed with the Court on Friday, February 19, 2016, and included a copy of the DEMAND LETTER/Settlement
Opportunity. Opposition to the Motion(s) to Dismiss was also filed by the Plaintiff.

Both offices are aware that Summonses have already been issued for all Defendants, and it is now beyond the timeline midpoint, required for
service to Defendants. This well-supported complaint is both civil and criminal in nature, and requires the alignment with Federal Prosecutors (or
the assignment of a Special Prosecutor) to move forward. I respectfully request that this alignment take place immediately to avoid any potential
legal complications or miss-interpretations moving forward.
As you know, there are very serious, and sensitive issues at hand within this complaint. From the beginning, my primary objectives have been
twofold:

15

1.
2.

Accountability for the harm and damages I have personally incurred, associated with misconduct your office(s) has already identified.
Alignment with the appropriate parties (i.e. - The United States Federal Government, The Federal Reserve), regarding the referenced
Intellectual Property belonging to the Plaintiff - Mohan A. Harihar (includes the HARIHAR FCS Model). This alignment would provide
the opportunity to implement a framework designed to bring historic economic growth to the US, while assisting those harmed by the
US Foreclosure/Financial Crisis.

Before moving forward with legal next steps in the US District Court, I respectfully request your assistance with the following:
1.
2.

Confirmation from each of the Defendants regarding their willingness (or lack thereof) to enter into a mutual settlement discussion.
Establishing a dialogue with the appropriate parties, for the specific purpose of aligning with the referenced Intellectual
property/Economic Framework. Successful alignment MAY lead to resolving civil portions of the referenced complaint.

For documentation purposes, a copy of this communication will be filed with US District Court (Boston, MA). Additional parties copied on this
communication include: President Barack Obama (via Senior Advisor, Valerie Jarrett), the Consumer Financial

Protection Bureau (CFPB), United States Senator Elizabeth Warren (MA), United States Senator Ed Markey
(MA), the Federal Bureau of Investigation (FBI), the US Attorneys Office (MA), the Massachusetts Office of
the Inspector General, Governor Charles Baker (MA), Congresswoman Nikki Tsongas (MA), State Senator
Eileen Donoghue (MA), the Massachusetts Office of the Attorney General, and the Senior Management of
K&L Gates LLP.
Thank you for your attention to this serious matter.
Respectfully,
Mohan A. Harihar

---------- Forwarded message ---------From: <moharihar@gmail.com>

Date: Wed, Jan 27, 2016 at 12:40 PM
Subject: Fwd: Demand Letter - HARIHAR vs. US BANK et al, Docket No: 15cv11880
To: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>
Cc: Mohan Harihar <mo.harihar@gmail.com>

Resending original email communication.

Sent from my iPhone
Begin forwarded message:
From: Mohan Harihar <moharihar@gmail.com>
Date: January 26, 2016 at 10:11:34 AM EST
To: david.fialkow@klgates.com, "Constituent.services@state.ma.us" <constituent.services@state.ma.us>, jeffrey.patterson@klgates.com,
"peter.haley@nelsonmullins.com" <peter.haley@nelsonmullins.com>, mcoakley@foleyhoag.com, "kendaher@dahercompanies.com"
<kendaher@dahercompanies.com>, "maryekoontz@dahercompanies.com" <maryekoontz@dahercompanies.com>, Jim Gray
<jim.gray@nelsonmullins.com>
Cc: Valerie_jarrett@who.eop.gov, jarrettpublic@who.eop.gov, kbranch@who.eop.gov, newyorkcomplaints@usdoj.gov,
"christina.sterling@usdoj.gov" <christina.sterling@usdoj.gov>, press@usdoj.gov, washington.field@ic.fbi.gov, boston@ic.fbi.gov,
"elizabeth_warren@warren.senate.gov" <elizabeth_warren@warren.senate.gov>, "mark_bayer@markey.senate.gov"
<mark_bayer@markey.senate.gov>, mark_gallagher@markey.senate.gov, ma-igo-general-mail@massmail.state.ma.us,
maura.healey@state.ma.us, "june.black@mail.house.gov" <june.black@mail.house.gov>, "chris.mullin@mail.house.gov"
<chris.mullin@mail.house.gov>, "eileen.donoghue@masenate.gov" <eileen.donoghue@masenate.gov>, "timothy.sheehan@cfpb.gov"
<timothy.sheehan@cfpb.gov>, bryan.olson@klgates.com
Subject: RE: Demand Letter - HARIHAR vs. US BANK et al, Docket No: 15cv11880

16

January 26, 2016

FOR DOCUMENTATION, NEGOTIATION & SETTLEMENT PURPOSES ONLY

VIA US MAIL and EMAIL

To ALL Recipients:

You have been named as a Defendant in a civil/criminal complaint, filed in the United States District Court
(Boston, MA), HARIHAR vs. US BANK, et al, Docket No: 15cv11880. The CURRENT list of Defendants is as
follows:
1.

US Bank, NA

2. Wells Fargo, NA
3. Residential Mortgage-Backed Security (RMBS) - CMLTI 2006-AR1
4. The Commonwealth of Massachusetts
5. Nelson Mullins, LLP
6. Harmon Law offices, PC
7. David E. Fialkow, esq.
8. Jeffrey S. Patterson, esq.
9. Peter Haley, esq.
10. Martha Coakley, MA Attorney General (Former)
11. Ken Daher (Weichert Realtors/Daher Companies, Methuen, MA)
12. Mary Daher (Weichert Realtors/Daher Companies, Methuen, MA)
13. Jeffrey Perkins, (Resident 168 Parkview Avenue, Lowell, MA 01852)
14. Isabelle Perkins, (Resident 168 Parkview Avenue, Lowell, MA 01852)
As representing counsel in active litigation against Plaintiff - Mohan A. Harihar, the Defendant David E.
Fialkow is instructed to forward a copy of this Demand Letter to his respective clients Defendants US Bank
NA, Wells Fargo NA and RMBS CMLTI 2006-AR1.

Please be advised of the following:

1.

A second amended civil/criminal complaint for the referenced Docket No: 15cv11880, has been
accepted by the United States District Court in Boston, MA; Summonses for all Defendants have
been issued. The allegations listed in the referenced complaint are considered both civil and criminal in
nature, and ALL are fully supported. A copy of the complaint has been made available to the public, and
can be viewed by clicking on the attached link: Harihar Files Request for Special Prosecutor in
Federal Foreclosure/RICO Complaint https://www.scribd.com/doc/289241306

17

2.

The United States Department of Justice (USDOJ) and Massachusetts Office of the Attorney General,
have already identified violations of Federal and State law associated with the referenced foreclosure.

3.

Separately, the Federal Reserve, along with Federal Bank Regulators, has identified similar misconduct
involving Defendants - Wells Fargo NA and US Bank NA, regarding the referenced foreclosure through
an Independent Foreclosure Review.

4.

Confirmation of the referenced misconduct is additionally supported by the sworn testimony of FRAUD
EXPERT Lynn Syzmoniak; involves the Residential Mortgage Backed Security (RMBS) Trust
CMLTI 2006-AR1; and includes multiple case references.

5.

Civil/Criminal allegations stated in the referenced complaint include (but are not limited to) the following:

a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
6.

Violations of the RICO Act

14th Amendment Constitutional Violations to Due Process and Equal Protection Rights
Color of Law violations
Tampering Violations
Abuses of Judicial Discretion
Fraudulent Misrepresentation
Fraudulent Concealment
Fraud, Including Deceptive Practices
Fraudulent Assignments
Aiding and Abetting Fraud
Perjury violations
SEC violations
FCA (False Claims Act) claims

In addition to the direct harm and damages suffered by the Plaintiff Mohan A. Harihar, referenced
allegations threaten the Plaintiffs Intellectual Property that includes the FCS Model [1] an economic
framework designed to assist the United States with economic recovery and growth.

7.

The referenced allegations additionally expose multiple levels of corruption, warranting communication to
the Office of the Inspector General (DOJ/OIG).

8.

Summonses have been issued for all listed Defendants, and are being prepared for delivery via US
Marshalls Service.

9.

Plaintiff Mohan A. Harihar is now in contact with the Executive Office of the Department of Justice, and
the Office of the Inspector General (OIG), regarding alignment of civil/criminal complaints, and the
assignment of a special prosecutor, if necessary.

10. Before moving forward with these civil and criminal legal actions, referenced Defendants are being
offered in good faith, an opportunity to voluntarily enter into settlement negotiations, for the purpose of
reaching a mutual agreement, as it pertains to damages resulting from the alleged misconduct.

11. Should an acceptable agreement between parties be reached, the Plaintiff Mohan A. Harihar MAY
consider the withdrawal of criminal complaints filed.

12. Choosing to decline or ignore this opportunity will result in civil/criminal complaints moving forward
against ALL responsible parties as planned. Maximum penalties allowed by law will be sought for ALL

18

civil and criminal infractions, and will be addressed with the appropriate Law and Real Estate
Professional authorities.

13. The Plaintiff is committed to seeing this matter to its legal conclusion, regardless of timeline.
14. This is a very serious matter that requires your immediate attention. This letter is your final opportunity to
resolve this matter amicably.

15. A copy of this letter is being filed with the United States District Court (Boston, MA), Docket No: 15-cv11880, to inform the Court of a proposed settlement opportunity, and for documentation purposes.

16. A copy of this letter is being delivered (via email correspondence) to State and Federal authorities
including:

a.
b.
c.
d.
e.

The United States Department of Justice (DOJ), and the Office of the Inspector General (OIG).
The Federal Bureau of Investigation (FBI).
The US Attorneys Office (MA).
The Massachusetts Office of the Inspector General.
The Massachusetts Office of the Attorney General.

17. A copy of this letter is being delivered (via email correspondence) to the following government officials:
a. President Barack Obama (via Senior Advisor, Valerie Jarrett)
b. United States Senator Elizabeth Warren (MA).
c. United States Senator Ed Markey (MA).
d. Governor Charles Baker (MA).
e. Congresswoman Nikki Tsongas (MA).
f. Massachusetts State Senator Eileen Donoghue (MA).
18. A copy of this letter is being delivered (via email correspondence) to the Consumer Financial Protection
Bureau (CFPB).

19. A copy of this letter is being delivered (via email correspondence) to the Senior Management of K&L
Gates LLP.

20. A copy of this letter is being made available to the Public and to the media.
21. Finally, by extending this opportunity to ALL listed Defendants, the Plaintiff Mohan A. Harihar has
shown in good faith, a sincere effort to reach a mutual agreement, prior to moving forward with the
referenced legal proceedings associated with this Docket.
For documentation purposes, please provide a written response on or by Friday, February 5, 2016, so that it may
be filed with the United States District Court, and the associated docket. Thank you for your attention to this
matter.

Sincerely,

19

Mohan A. Harihar

[1] FCS Foreclosure Crisis Solution

20