com>
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.
2. US Secret Service;
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,
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Mohan Harihar <moharihar@gmail.com>
There are two (2) reasons for sending you this email communication. First, as representing counsel
for Defendant - THE UNITED STATES in the above-referenced civil complaint, please find a copy of
the following motion filed yesterday (Attached below) - August 27, 2019 (mail date) with the US
District Court (Boston, MA) via US Priority Mail:
PLAINTIFF MOTION TO AMEND ORIGINAL COMPLAINT, PURSUANT (AT MINIMUM) TO: (1)
ARTICLE III; (2) 18 U.S.C. § 2381; AND (3) FED. R. CIV. P. 60(b)(3)
A hardcopy of the Motion has also been mailed to your direct attention and is expected to be received
today, August 28, 2019.
Secondly, I am bringing to your direct attention a letter dated 8/21/19, which was received yesterday,
8/27/19 (Attached below). According to this letter from the Asst. First Circuit Executive of Legal
Services - Gina Riccio, I am no longer allowed to report judicial misconduct - including evidenced
crimes of TREASON against The United States of America, even though I am required by
Federal law to do so. This latest failure by the Office of the First Circuit Executive exemplifies a
continued and systemic pattern of corrupt conduct within the First Circuit - showing cause to further
amend the original complaint against The United States (Referencing Docket No. 17-cv-11109). If
these systemic failures are not corrected, and/or if there is no mutual agreement between parties in
the referenced civil lawsuit, it will become necessary to file a new complaint against The United
States in the US Court of Federal Claims. As a matter of record, you are already aware that I have
evidenced judicial misconduct against FIFTEEN (15) Federal Judges in the First Circuit alone (8
First Circuit Judges and 7 District Court Judges - including identical Treason claims evidenced
against CHIEF JUDGE JEFFREY R. HOWARD. You are also aware that collectively, there has been
an unprecedented NINE (9) Federal Recusals from this (and all related) litigation. 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. As the Plaintiff in the referenced civil complaint, I re-state that it has always been my
intention to ultimately reach a mutual agreement with Defendant - The United States, on the civil
portions of the lawsuit. As a sign of my continued Good Faith, I respectfully extend the opportunity
to have such a discussion - with Attorney General Barr and the EOP (Executive Office of the
President) to see if there is an opportunity to reach a mutual agreement that is constructive and
beneficial to both parties as well as the 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):
2. US Secret Service;
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 your timely response.
Respectfully submitted this 28th Day of August, 2019
Respectfully,
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. 17-cv-11109
v. )
)
THE UNITED STATES OF AMERICA, )
)
Defendant )
)
The Plaintiff, Mohan A. Harihar, a pro se litigant with no legal experience, respectfully files this
MOTION after a RECUSED judicial officer - acting on behalf of The United States issued an
order(s) without jurisdiction. The Plaintiff references US District Court Judge – Hon. Allison
Dale Burroughs, who on June 19, 2017, recused herself from this case.1 As a matter of record,
this recusal came only AFTER the Plaintiff had evidenced judicial misconduct warranting the
judge’s recusal. However, the Court has never taken steps to VOID all related orders, despite
multiple efforts by the Plaintiff to address these evidenced violations with this US District Court,
the First Circuit Court of Appeals and The US Supreme Court. The Court is also aware that as a
matter of record, there has been an unprecedented EIGHT (8) additional Federal recusals
associated with this litigation that have followed since Judge Burroughs’ recusal. There can be
1
See Exhibit 1, to view the RECUSAL Order issued by US District Court Judge – Hon. Allison Dale
Burroughs.
no confusion in understanding that jurisdiction is lost once a judge has recused themselves from
a case, including ALL related litigation. This Court is well-aware that this docket is directly
related to the following two (2) Federal complaints also filed with this Court:
As grounds for amendment, the Plaintiff references recent activity in the related civil complaint,
HARIHAR v US BANK, et al (Referenced above). On July 25, 2019, the Plaintiff filed with
this court a Motion to amend his original complaint under Fed. R. Civ. P 60(b)(3), and for
removal of a related MA Civil Complaint to Federal Court under 28 U.S.C. § 1446 [ECF No.
156].
On July 29, 2019, US District Court Judge – Hon. Allison Dale Burroughs issued an order
WITHOUT JURISDICTION, denying the Plaintiff’s Motion [ECF No. 157].2 As a respectful
reminder, the Plaintiff had previously identified SIX (6) identical violations of ruling without
jurisdiction as part of his initially filed judicial misconduct complaint against Judge Burroughs.
As a matter of record, the 7/29/19 order is perceived as a 7th violation to Article III and 18 U.S.
CODE § 2381.
On August 2, 2019, the Plaintiff filed a REPLY to what is irrefutably considered a VOID order
issued without jurisdiction and a clear violation of ARTICLE III and 18 U.S. CODE § 2381 -
JUDICIAL TREASON [ECF No. 158]. EVEN IF jurisdiction was not an issue, the Plaintiff’s
2
See Exhibit 2, to view the VOID 7/29/19 order issued by recused US District Court Judge – Hon. Allison Dale
Burroughs.
filed REPLY entirely discredits the content of the judge’s 4-page (void) order.
On August 6, 2019, despite being respectfully reminded of her 2017 Recusal, Judge Burroughs
issued another void order - in complete (and continued) disregard of the Constitution, Federal
Law and her judicial oath.3 In this 8th documented violation to Article III and 18 U.S. CODE
§ 2381, Judge Burroughs also threatens the Complainant with potential sanctions.
On August 20, 2019, the Plaintiff filed a new judicial misconduct complaint, informing the First
Circuit Executive – Susan Goldberg of these recent developments.4 Due to the severity of
these evidenced claims that include (but are not limited to) Treason, the Plaintiff – as required by
Federal Law, also notified the White House, the DOJ, members of Congress and Governor
Charlie Baker (R-MA). The complaint also calls for the Circuit Executive to update the
Moving forward, these developments bring an increasing number of complex legal issues
impacting all three (3) civil (and related criminal) complaints which must now be addressed. The
Plaintiff first respectfully restates his request for assistance with the appointment of counsel,
pursuant to 28 U.S.C. § 1915 – IF he is still unable to retain counsel on his own. There should be
NO QUESTION that all three (3) civil complaints are TEXTBOOK examples that should
clearly support the Court’s discretion to assist with appointing counsel if needed. Additional
3
See Exhibit 3, to view the VOID 8/5/19 order issued by recused US District Court Judge – Hon. Allison Dale
Burroughs.
4
See Exhibit 4, to view the Email communication delivered to First Circuit Executive – Susan Goldberg on
8/20/19.
legal issues include (but are not limited to) the following:
1. US District Court Judge – Hon. Denise J. Casper has similarly LOST jurisdiction to
rule further in this or ANY related litigation, for the SAME IDENTICAL reasons that
brought the recusal of Judge Burroughs. A review of the historical record shows that the
Plaintiff has clearly articulated the evidenced FACTS that support his position –
Respectfully, any attempt by Judge Casper (or any other disqualified judicial officer) to
continue ruling without jurisdiction will (at minimum) show cause to expand upon
2. Cause to Expand Upon Fed. R. Civ P. 60(b)(3) claims – By continuing to rule without
jurisdiction, a Judicial Officer acting on behalf of The United States has exemplified the
intention to continue deceiving this Court. Whether Judge Burroughs’ intention was to
prevent setting legal precedent and/or to ultimately DEFRAUD The United States (or
for ANY other reason), there can be no question that there is clear intention to deceive
this Court. Therefore, the Plaintiff shows cause to expand upon his Rule 60 claims. To be
complaint seeks to recoup damages to his Intellectual Property (IP)/Trade Secret – THE
HARIHAR FCS MODEL© which Mr. Harihar created for the specific purpose of
helping The United States recover from damages associated with the 2008 US
Foreclosure Crisis. By continuing to issue orders without jurisdiction, Judge Burroughs
exemplifies the intent to continue damaging the Plaintiff’s IP/Trade Secret, which is
4. Expansion of FTCA Claim(s) against the United States – Typically, the government is
liable for the operations of “federal agencies” and “employees.” Both terms are defined
by statute found at 28 USC § 2671. Federal agencies associated with any of the three
branches of the government are responsible under the act. 28 USC § 2674 states that the
United States shall be liable “in the same manner and to the same extent as a private
individual under like circumstances.” 28 USC § 1346 (b) states the basis for claims as
the “negligent or wrongful act or omission” of any government employee while acting
within the scope of his employment. Consequently, virtually every kind of negligence
action that could be brought against private individuals can be maintained against the
judicial failures of record, there are also continued failures in both the Executive and
Legislative leaders continue to “Turn a Blind Eye” to systemic failures within the
Judicial Branch of Government. These evidenced historical actions (or lack thereof)
shows (at minimum) an INTENT to damage the Plaintiff’s Intellectual Property, and
warrants the expansion of existing Federal Tort, Due Process, and Color of Law
ultimately reach mutual agreement(s) with The United States and ALL parties associated with
the related litigation, including (but not limited to) the Defendant - Commonwealth of
born citizen and by Federal law to continue the pursuit of accountability against all parties.
Therefore, for the reasons stated within (and once jurisdiction has been restored), the Plaintiff
calls for the Court to allow amendment to his original complaint. The Plaintiff also requests that
Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge,
information, and belief that this Notice: (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
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 Motion 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
media):
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 your Honor has ANY questions regarding any portion of this Motion, or requires
additional information, the Plaintiff is happy to provide upon request. The Plaintiff is grateful for
Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
5
See Exhibit 5 to review to the email confirmation of receipt from the White House.
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Mohan Harihar <moharihar@gmail.com>
On July 25, 2019, the Plaintiff/Complainant – Mohan A. Harihar filed with the US District Court
a Motion to amend his original complaint under Fed. R. Civ. P 60(b)(3), and for removal of a
related MA Civil Complaint to Federal Court under 28 U.S.C. § 1446 [ECF No. 156].
On July 29, 2019, US District Court Judge – Hon. Allison Dale Burroughs issued an order
WITHOUT JURISDICTION, denying the Plaintiff’s Motion [ECF No. 157].7 As a respectful
reminder, the Plaintiff/Complainant had previously identified SIX (6) identical violations of
ruling without jurisdiction as part of his initially filed judicial misconduct complaint against
Judge Burroughs. As a matter of record, the 7/29/19 order is perceived as a 7th violation to
Article III and 18 U.S. CODE § 2381.
On August 2, 2019, the Plaintiff filed a REPLY to what is irrefutably considered a VOID order
issued without jurisdiction and a clear violation of ARTICLE III and 18 U.S. CODE § 2381 -
JUDICIAL TREASON [ECF No. 158]. EVEN IF jurisdiction was not an issue, the Plaintiff’s
reply entirely discredits the content of the judge’s 4-page (void) order.
On August 6, 2019, despite being respectfully reminded of her 2017 Recusal, Judge Burroughs
issued another void order - in complete (and continued) disregard of the Constitution, Federal
Law and her judicial oath.8 In this 8th documented violation to Article III and 18 U.S. CODE
6
See Exhibit 1 to view the RECUSAL ORDER issued by US District Court Judge - Hon. Allison Dale
Burroughs on June 19, 2017.
7
See Exhibit 2, to view the VOID 7/29/19 order issued by recused US District Court Judge – Hon. Allison Dale
Burroughs.
8
See Exhibit 3, to view the VOID 8/5/19 order issued by recused US District Court Judge – Hon. Allison Dale
§ 2381, Judge Burroughs also threatens the Complainant with potential sanctions.
This egregious judicial abuse of power cannot be allowed to continue and considering the
severity of issues - mental illness should not be ruled out. Ms. Goldberg, as Circuit Executive
the Complainant respectfully requests that you bring this matter to the immediate attention of
Director James C. Duff – Administrative Office of US Courts and to the attention of First
Circuit Chief Judge – Jeffrey R. Howard. There is also the clear expectation for the District
Court and the Appeals Court to finally initiate CORRECTIVE action by voiding ALL related
orders issued by Judge Burroughs. Based on my interpretation of the Constitution, the severity
of this evidenced judicial misconduct also warrants updating the Executive and Legislative
Branches under ARTICLES II and III. Please be advised, the White House, US Senator
Elizabeth Warren (D-MA) and Governor Charlie Baker (R-MA) have already been
notified of these criminal violations, as required by Federal law.
In closing, the Complainant makes clear by re-stating that it has ALWAYS been his intention to
ultimately reach mutual agreement(s) with ALL parties associated with this litigation – including
the Defendant Commonwealth of Massachusetts (Docket No. 15-cv-11880) and separately in the
related case with the Defendant - The United States (Docket No. 17-cv-11109). In recent days,
five (5) parties have expressed an interest in having a mutual agreement discussion, including:
(1) Bank Defendant – WELLS FARGO; (2) Bank Defendant - US BANK; (3) Defendant -
MERS, Inc.; (4) Defendant - Jeffrey Perkins; and (5) Defendant - Isabelle Perkins.
However, if no agreements are reached and these judicial failures are allowed to continue – the
Complainant is compelled as an American-born citizen and by Federal law to continue the
pursuit of accountability against all parties.
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):
Burroughs.
9
See Exhibit C to review to the email confirmation of receipt from the White House.
13. US Congresswoman Lori Trahan (D-MA);
14. US Congresswoman Ayanna Pressley (D-MA);
15. The MA Office of the Inspector General; and
16. MA Attorney General Maura Healey
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 Complainant’s personal
safety and security. If you have ANY questions regarding any portion of this letter, or requires
additional information, the Complainant is happy to provide upon request.
Mohan A. Harihar
Complainant/Appellant
Exhibit 5
CERTIFICATE OF SERVICE
I hereby certify that on August 27, 2019, I filed the foregoing Motion with counsel for the
Defendants (listed below) via US Mail and Email Communication:
Mary Murrane
Assistant United States Attorney at U.S. Department of Justice
Chief of the Civil Division
1 Courthouse Way
Boston, MA 02210
617.748.3100
mary.murrane@usdoj.gov
Andrew Lelling
United States Attorney for the District of Massachusetts
1 Courthouse Way
Boston, MA 02210
617.748.3100
andrew.lelling@usdoj.gov
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com