FOR IMMEDIATE RELEASE

After the Bubble Bursts Reveals Concerns of Collusion,

and Certain Conflict in Massachusetts Foreclosure Case.

Boston, MA, August 5, 2014 Since the July 17
th
decision by the MA Appeals Court, allowing
foreclosed homeowner Mohan A. Harihar to file for new trial, the Court has additionally allowed Mr.
Harihar to file appropriate motions for the purpose of seeking affirmative relief. A motion has since
been filed requesting to initiate a Validation Process as described in prior Media Alert publications
released 7/12/2014 and 7/25/2014. Appellees Wells Fargo NA and US Bank NA, who continue to
claim ZERO MISCONDUCT in this matter, have filed opposition in effort to prevent a validation
process from reviewing the accuracy of information filed with the Court(s), including concerns related
to due process, infringement of intellectual property, and the resulting impact to Court
decisions when information is not validated, not supported, or not even produced. A recap of
this validation is expected to determine whether a corrective path is attainable in the Commonwealth of
Massachusetts, or if transfer to Federal Court and involvement of the MA/US Inspectors General is
deemed necessary.

Appellee - Harmon Law offices PC has filed NO OPPOSITION to this Validation Process request.
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Perhaps the most troubling discovery to date, however, comes from West LegalEdcenter: Online
Continuing Education and a class entitled, "After the Bubble Bursts: Mortgage and Foreclosure
Issues in Criminal and Civil litigation. A portion of the description reads as follows:

Attendees will gain insight into the priorities of leading prosecution officials, including the
Attorney General and the United States Attorney in mortgage fraud and foreclosure cases.
Learn about important practical issues and valuable strategies for criminal defense attorneys
in this area, including the likely impact of new regulations at the state and federal level in the
area of consumer protection in connection with mortgages. Two panels of experts will present
some of the latest breaking developments in this area, including the impact of the SJCs
ground-breaking Ibanez decision.
2


The Content Partner is the Boston Bar Association. The Program Co-Chairs are from Nelson Mullins
Riley & Scarborough LLP and the US Attorneys Office. Program Speakers include an Assistant MA
Attorney General, an Assistant US Attorney (Panel I Moderator), a Partner from Nelson Mullins Riley &
Scarborough LLP (Panel II Moderator), and Attorney Jeffrey S. Patterson of Nelson Mullins Riley &
Scarborough LLP, who is 1 of 2 attorneys representing Appellees Wells Fargo NA and US Bank NA, in
the case involving Mr. Harihars foreclosure.
3


1
Appellee Harmon Law Offices PC has made a decision to file NO Appellee Brief or any related Opposition to
this Docket No. 2013-P-1829.
2
Scroll down to view the Program Details in their entirety, attached in Exhibit A, Reply to Opposition, filed by
Appellant Mohan A Harihar.
3
The second representing attorney is David E. Fialkow in litigation against Mohan A. Harihar.
2
While it is uncertain if there is any legal issue pertaining to the creation of this specific class, there are
clear concerns of Collusion and irrefutable Conflict which now must be addressed, and include the
need to appoint/petition for a special prosecutor (Civil and Criminal) in this matter. The filed Reply to
Appellee Opposition can be viewed in its entirety (Scroll down to view), along with the Class offering of
After the Bubble Bursts (See Exhibit A).




Prior Media Alerts are also available for viewing by clicking on the following links:

Decision allowing pro se MA foreclosed homeowner to file for new trial - STANDS. Wells Fargo/ US
Bank DENIED reconsid http://www.scribd.com/doc/235071783

MASSACHUSETTS APPEALS COURT ALLOWS FORECLOSED HOMEOWNER TO FILE FOR NEW
TRIAL, BASED ON NEW EVIDENCE http://www.scribd.com/doc/232686869

MASSACHUSETTS APPEALS COURT ALLOWS FORECLOSED HOMEOWNER TO FILE FOR NEW
TRIAL, BASED ON NEW EVIDENCE http://www.scribd.com/doc/232686869

FORECLOSED HOMEOWNER FILES FOR NEW TRIAL & TRANSFER TO FEDERAL COURT W/
NEW INFO http://scribd.com/doc/231548551

WRONGFULLY FORECLOSED HOMEOWNER TO ADDRESS INSPECTORS' GENERAL, &
PETITION TRANSFER TO FEDERAL COURT http://www.scribd.com/doc/225049527





For Further Media Information Contact : Mohan A. Harihar
Email: mo.harihar@gmail.com
Phone: 617.921.2526 (Mobile)

Follow on Twitter:
Mohan Harihar@Mo_Harihar




















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COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX APPEALS COURT OF
THE COMMONWEALTH
DOCKET NO: 2013P1829

MOHAN A. HARIHAR

Appellant

vs.

US BANK NA,
WELLS FARGO NA,
HARMON LAW OFFICES PC, et al.

Appellees


APPELLANT REPLY TO APPELLEES OPPOSITION TO INITIATE VALIDATION
PROCESS, AND REQUEST FOR SPECIAL PROSECUTOR


After a review of the Appellees Opposition to initiate a
validation process, Appellant Mohan A. Harihar respectfully
submits to the Court this reply to address multiple concerns
found within this Opposition, and additionally reveals to this
Court new evidence which continues to come forth, and what can
only be described as an apparent form of COLLUSION and
irrefutable conflict directly related to this matter:

1. No Opposition filed by Appellee, Harmon Law Offices PC

As the third Appellee in this matter, and as the initially
retained counsel to Appellee US Bank in this matter,
Harmon has full knowledge of the intricate details
involved, and has AGAIN chosen to file No Opposition, this
time regarding the Appellants request for Validation.
This Court is already aware of Harmons decisions not to
file an opposing Appellee Brief or any related opposition
with this associated Docket No. 2013-P-1829.

As the initially retained counsel to Appellee US Bank
NA, initiated in Lowell District Court
4
, the continued

4
Lowell District Court, US Bank NA vs. Mohan A. Harihar, Docket
No: 201111SU001495.
4
decisions not to file ANY Opposition or Appellate Brief
clearly exemplifies a disconnect, lacking both consistency
and alignment, with the current counsel for the
Appellee(s) Nelson Mullins LLP (See also Appellants
filed Opposition to Appellees Reconsideration Motion for
New Trial, for additional historical detail of Harmon Law
Offices PC, including the 3+ year on-going investigation
by the MA Office of the Attorney General). These facts
alone question the accuracy of information filed by these
Appellees, warranting validation of this entire matter.
5


2. Appellees continued statements - Failure to state a
claim are incorrect.

Appellees continued statements here are incorrect and
considered false. In fact, the Appellant from the very
beginning has referenced the synonymous Civil Action filed
by the MA Office of Attorney General, dated December 1,
2011, on file with Suffolk County Superior Court, Docket
No: B.L.S. 11-4363, and which additionally has in common
the Appellee - Wells Fargo NA.

As with the Commonwealths action, Mr. Harihar has sought
restitution, civil penalties and injunctive relief for
claimed violations of M. G. L. c. 93A arising out
Defendants' unfair and deceptive acts during the height of
the foreclosure crisis in Massachusetts. The conduct
alleged has similarly affected thousands of homeowners
through their residential mortgage loans, and includes,
without limitation:
a. Engaging unfair and deceptive foreclosure
practices by conducting foreclosures when the
defendants lacked the right to do so.
b. Validation questions regarding the engagement of
false documentation practices to facilitate their
foreclosure practices
c. Deceiving homeowners in the course of servicing
mortgage loans by misrepresenting to borrowers
regarding its loan modification programs.

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See - Docket No. 12-P-407, Harmon Law Offices vs. Attorney
General, filed with this Appeals Court. A recent unanimous
ruling by this Appeals Court affirmed a 2011 Suffolk Superior
Court decision allowing the MA Attorney Generals office to
continue examining Harmon Law Offices for alleged unfair and
deceptive acts related to the firms foreclosure and eviction
work.
5
The Attorney General additionally states, The Defendants,
and their subsidiaries and related entities, are
responsible for the vast majority of unlawful foreclosures
that occurred in the Commonwealth in the last four years.
Given the scope of the conduct alleged, the complex facts
involved, voluminous discovery anticipated, and the likely
need for substantial case management, the Commonwealth
contends that determination of this matter by the BLS is
appropriate.
6


Shortly thereafter, it became public knowledge that the
Commonwealth joined the $25B National Mortgage Settlement
for related misconduct, securing $318M in relief for the
Commonwealth, and additionally reserving the right to
pursue future legal action against referenced parties.

The Appellant has clearly been entitled to the
historically requested, critical Discovery evidence, and
the consistent refusal by Appellees US Bank NA and Wells
Fargo NA to provide this evidence, along with the Courts
failure to enforce its production re-affirms the concerns
articulated in the Appellants Brief/Reply Brief, whether
or not a corrective path is attainable within this
Commonwealth, or if transfer to Federal Court and
involvement of the MA/US Inspectors General is deemed
necessary. Validation here is in part to determine if the
evidence still exists, or if it has been tampered with,
destroyed, lost, etc...It is also to ensure its
availability for the filing of a new trial.

To be clear, the Appellant has not requested this Appeals
Court to retry the case, as suggested by the Appellees.
The Appellant has respectfully requested permission from
the Court to file for new trial, and the Court has
rightfully granted that request, based on the overwhelming
amount of information and evidence which continues to come
forth in support of the Appellants consistent claims. The
collective orders requested in the validation motion
address historical accuracy concerns pertaining to filed
information provided (or not provided) by Appellees;
concerns pertaining to the illegal tampering/availability
of evidence; restraining speech of unsupported statements;
clarifying the relationship of this matter to the MA
Attorney Generals 3+ on-going investigation of Appellee

6
A copy of Docket No: B.L.S. 11-4363 is available for
submission and review in its entirety, upon request.
6
Harmon Law offices PC; validating clear Constitutional
Amendment Infractions; and finally to address what appears
to be continued acts of deception by these Appellees
(Wells Fargo NA and US Bank NA) in the attempted re-sale
of the referenced foreclosure property.

It is also to acknowledge a clear effort by this Appellant
to establish a corrective path within this Commonwealth.

3. Accreditation Class reveals concerns of Collusion, and
irrefutable Conflict with this matter.
7


New evidence which has now surfaced reveals what is
perhaps the most disturbing information to date.

West LegalEdcenter is described as providing online access
to the largest, most current library of live and on-demand
continuing legal education programs from leading local,
state, and national CLE providers.

The course in question is entitled, After the Bubble
Bursts: Mortgage and Foreclosure Issues in Criminal and
Civil Litigation.

The Content Partner is the Boston Bar Association.

Program Co-Chairs:

a. Juliane Balliro, Esq. Partner, Nelson Mullins
Riley and Scarborough LLP.
b. Paul G. Levenson, Esq. Assistant U.S. Attorney,
The United States Attorneys Office District of
Massachusetts.


Program Speakers:

a. James H. OBrien Assistant Attorney General, MA
Office of the Attorney General.
b. Paul Levenson Assistant U.S. Attorney (Panel I
Moderator), U.S. Attorneys Office.
c. Jeffrey S. Patterson, Esq. Nelson Mullins Riley
and Scarborough LLP
8


7
See Exhibit A
8
Attorney Jeffrey S. Patterson, along with Attorney David E.
Fialkow, both Partners at Nelson Mullins Riley and Scarborough
7
d. Juliane Balliro Partner (Panel II Moderator),
Nelson Mullins Riley and Scarborough LLP.
e. James Patrick Dowden Assistant U.S. Attorney, US
Attorneys Office.
f. Thomas P. Quinn, Esq. Pierce Atwood, LLP.

A Description of the Course is as Follows:

Criminal and civil litigation in mortgage and foreclosure cases
is an area in which legal issues are rapidly evolving, stakes
are high and uncertainty is rampant. As a result, a variety of
different areas of practice overlap for many clients and
practitioners.

This program will focus on criminal and regulatory issues
emerging from the collapse of the national real estate and
secondary mortgage markets. Among the topics to be explored
are: the uncovering of widespread fraud in the origination of
mortgages prior to the collapse, and the priorities of state
and federal authorities in prosecuting such cases; civil and
criminal authorities priorities in confronting fraud in
connection with post-collapse foreclosure rescue
transactions; and criminal and regulatory issues relating to
banking and foreclosure practices in connection with mortgages
held in pooled investment vehicles.

Attendees will gain insight into the priorities of leading
prosecution officials, including the Attorney General and the
United States Attorney in mortgage fraud and foreclosure cases.
Learn about important practical issues and valuable strategies
for criminal defense attorneys in this area, including the
likely impact of new regulations at the state and federal level
in the area of consumer protection in connection with
mortgages. Two panels of experts will present some of the
latest breaking developments in this area, including the impact
of the SJCs ground-breaking Ibanez decision.

Accreditation was offered for the following States/Areas: AK,
AR, AZ, CA, CO, FL, ME, MO, MT, ND, NJ, NY, OK, PA, RI, VI, VT,
WV.




LLP, are the representing Attorneys for the Appellees Wells
Fargo NA and US Bank NA in this matter vs. Mohan A. Harihar.
8
While it is uncertain if there is any legal issue pertaining to
the creation of this specific class, there are a number of
clear concerns which now must be addressed including (but not
limited to):

1. The creation of this type of course can disrupt a level of
fairness, favoring parties accused of fraudulent
misconduct, thus placing opposing parties (ex. Foreclosed
Homeowners) at a clear dis-advantage, certainly impacting
Foreclosed Homeowner efforts from some of the hardest-hit
foreclosure states in this country.
2. The involvement of the MA Attorney Generals Office.
3. The involvement of the US Attorneys Office.
4. The involvement of Nelson Mullins Riley and Scarborough
LLP, counsel for the Appellees Wells Fargo NA and US
Bank NA in this matter. More specifically, Speaker
Jeffrey Patterson, who has been one of two attorneys
assigned to this case/matter for over three years, along
with Attorney - David E. Fialkow.
5. The involvement of the Boston Bar Association as Content
Partner.
6. Red Flags are raised regarding these relationships and
criminal complaints filed with the MA Attorney Generals
Office, and the Fraud Investigations Unit of the FBI.
7. The decision by the Attorney Generals Office to ignore
multiple requests for communication affirming the
relationship of documented misconduct identified in this
matter, with the 3+ year investigation of Appellee
Harmon Law Offices PC.
8. Red Flags are additionally raised with complaints filed
with the MA Board of Bar Overseers/Bar Counsel.


It is a concern, that the Attorney Generals Office has thus
far ignored requests to provide this Court with supporting
documents to show the relationship of this matter to their 3+
year on-going investigation of Appellee Harmon Law Offices
PC, particularly since it will only aid in their own
investigation.

What is being revealed instead is a necessity to expand this
investigation to include Law Firms which clearly represent a
second tier to the Foreclosure-Mill process.




9
This Appellant has afforded the Appellees Wells Fargo NA and
US Bank NA numerous opportunities to Cease and Desist, and seek
agreement for harm and accruing damages caused to Mohan A.
Harihar. They have either declined or ignored these
opportunities all of them. The result has been an
overwhelming amount of evidence and information in complete
support of this Appellants consistent claims, with more
information and related facts coming forth, and more questions
concerning the depth of misconduct.

Based on these recent (and overall) findings, it has become
clear, that in addition to initiating a validation process, a
special prosecutor is necessary for both civil and criminal
actions.

Clearly, a significant and continuing effort is being made by
Appellees Wells Fargo NA and US Bank NA to prevent the facts
of this matter from being presented to the Court(s). If the
Appellees claim of Zero Misconduct was actually true, there
would be no need for such effort. However, that is not the
case. These Appellees have not been truthful with this, or ANY
Court related to this matter, and the decision to continue
causing harm and accruing damages to this Appellant, while
ignoring/refusing opportunities to seek agreement, exemplifies
clear signs of ignorance, and must no longer be tolerated.


CONCLUSION

The decision(s) by Appellee Harmon Law Offices PC, NOT to
file any Opposition again exemplifies clear disconnect, and any
explanation for this disconnect by Appellees Wells Fargo and US
Bank has been avoided entirely. Adding to this, the continued
incorrect/false statements made by Appellees to the Court, and
the now emerging concerns of collusion and irrefutable conflict
warrant the appointing/petitioning for a special prosecutor for
both civil litigation in filing for new trial, as well as the
pursuit of criminal charges at both state and federal levels
for complaints already filed against referenced parties.
Complaints are also being amended to include additional
parties:

1. Jeffrey S. Patterson (Nelson Mullins Riley and Scarborough
LLP)
2. Mary Koontz-Daher, Real Estate Broker/Owner (Daher
Properties - Methuen, MA).
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3. Kenneth Daher, Real Estate Broker/Owner (Daher Properties
Methuen, MA).

Since the Appellees US Bank NA and Wells Fargo NA, have made
clear they have no intention to seek agreement in this matter,
and for the collective reasons stated within this reply and the
original motion, the Court should deny the Appellees
opposition, and the Appellant respectfully requests that the
affirmation orders initiating a validation process listed in
the original motion be granted; that the Appellant is allowed
to rightfully return to his home, while this legal matter
proceeds; for Appellees to incur all costs associated with the
Wrongful Displacement of the Appellant; and for the Court to
either appoint, or allow the petition filing for a special
prosecutor in this matter (Civil and Criminal).



Thank you for your attention to this matter.





Respectfully submitted,



Mohan A. Harihar
168 Parkview Avenue
Lowell, MA 01852
617.921.2526 (Mobile)

















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EXHIBIT A










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