Mohan Harihar <moharihar@gmail.

com>

Re: 19-50 Harihar v US Bank, NA et al - Expansion of Rule 60(b) Claims

Mohan Harihar <moharihar@gmail.com> Mon, Aug 12, 2019 at 9:23 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: "Constituent.services@state.ma.us" <constituent.services@massmail.state.ma.us>,
governor.schedule@state.ma.us, elizabeth warren <elizabeth_warren@warren.senate.gov>,
scheduling@warren.senate.gov, NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>,
theresa watson3 <theresa.watson3@usdoj.gov>, andrew lelling <andrew.lelling@usdoj.gov>, mary
murrane <mary.murrane@usdoj.gov>, christina sterling <christina.sterling@usdoj.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, CommissionerStein@sec.gov,
CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, maura.healey@state.ma.us, jesse.boodoo@state.ma.us, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>

Clerk Deguglielmo,

Over the weekend, I received by regular US Mail an opposition to the Plaintiff's Motion for recusal,
filed by K&L Gates attorney - David E. Fialkow, representing counsel for the Bank Defendants in
this case - WELLS FARGO and US BANK. Please be advised - the Plaintiff plans to file a response
to this opposition as it appears there is a continued effort to purposefully deceive this Court, showing
(at minimum) cause to expand upon the Plaintiff's existing Rule 60b claims (State and Federal). It
also appears that the Bank Defendants are suggesting that this Court should blatantly ignore
the evidenced act(s) of judicial treason by US District Court Judge - Hon. Allison Dale
Burroughs. With the exception of the Defendant - MERS, all other Defendants are considered as
witnesses to the evidenced act of Judicial Treason - a clear violation to ARTICLE III and 18 U.S.
Code § 2381. Any refusal to serve as witness to this evidenced crime will bring an incremental
MISPRISION of Treason claim, pursuant to 18 U.S. Code § 2382. The Court will notice that the
remaining Defendants have not joined in this apparent desperation effort to avoid accountability. Also,
this continued effort by a licensed attorney to continue purposefully deceiving the Court is certainly
grounds for professional sanctions, including disbarment. The Plaintiff respectfully reminds this
Court that Attorney David E. Fialkow is also a Defendant in the related Federal litigation -
HARIHAR v US BANK et al, Docket No. 15-cv-11880. As is the case in Federal Court under Fed.
R. Civ. P. 60(b)(3), litigation privilege here is also considered WAIVED, when Fraud on the
Court has been evidenced under Mass. R. Civ. P. 60(b)(3).

While further explanation will be provided in the filed response, the Plaintiff states that - based on his
interpretation of Superior Court Rules, the Plaintiff's Recusal Motion should not require filing under
Rule 9A (or require any Defendant opposition), as the cause for recusal pertains to the presiding
judge's evidenced actions (and inaction) of record. If filing under 9A was applicable, the motions
would not have been accepted by the Court and recorded on the docket in the first place - and would
have instead been returned to the Plaintiff. There is also a motion still pending in the US District Court
to remove this complaint from State Court under 28 U.S.C. § 1446 as the order issued by the
RECUSED federal judge is considered VOID.

Finally, this Court is well-aware of the severity of legal issues involving this case, the related
federal litigation (which includes the Commonwealth as a Defendant) and its overall perceived
impact to National Security. Therefore, it remains necessary to continue copying multiple
government offices/agencies (referenced above) and the Public - out of continued concerns for my
personal safety and security. The Plaintiff's response to the Bank Defendant's opposition is expected
to be filed with the Court no later than Wednesday, August 14, 2019. If the Court has any questions
or concerns, please advise.

Thank you for your attention to this very serious matter.

Respectfully,

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