---------- Forwarded message ----------

From: Mohan Harihar <moharihar@gmail.com>

Date: Fri, May 18, 2018 at 12:58 PM
Subject: Demand for State Prosecutors to Address Filed Criminal Complaints
To: maura.healey@state.ma.us
Cc: elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
scheduling@warren.senate.gov, sydney_levin-epstein@markey.senate.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>, june.black@mail.house.gov,
NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, mary.murrane@usdoj.gov,
christina.sterling@usdoj.gov, washington.field@ic.fbi.gov, boston@ic.fbi.gov

Attorney General Healey,

This email communication is delivered to your direct attention for the purpose of bringing criminal charges
associated with an ILLEGAL FORECLOSURE identified by your office. You are aware of ongoing litigation
related to this matter - HARIHAR v. US BANK et al, Appeal No. 17-1381 (Lower Court Docket No. 15-cv-
11880), which includes the Commonwealth as a Defendant/Appellee. You are also aware that in this
referenced litigation and as part of Federal record, the UNOPPOSED FRAUD on the COURT claim(s) under
FRCP 60(b)(3), shows cause to re-address (and correct) prior judgments that have been impacted.

There are two (2) motions being filed to address these Fraud on the Court claims - pursuant to Massachusetts
Civil Rule of Procedure 60(b)(3). The first is being filed with the Northeast Housing Court in Lawrence, MA.
The second is intended to be filed in the coming days with the Middlesex Superior Court. You are aware that
I continue to seek CRIMINAL CHARGES against ALL responsible parties associated with these (and other)
related claims of record. Updated criminal complaints have been filed with your office, however, it is unclear as
to why I have yet to receive a response.

Attached, please find a copy of the Motion to RE-OPEN the referenced case, US BANK NA v. MOHAN A.
HARIHAR, 11-SP-3032 being filed today with the Northeast Housing Court. State Prosecutors are now called
to enjoin this civil matter, bringing criminal charges against the Plaintiff - US BANK NA and their attorneys.
Respectfully, please be advised of the following:

1. SHOULD the Commonwealth initiate corrective action including (but not limited to) bringing criminal charges
against referenced parties, there MAY be opportunity for discussing a mutual agreement in the related
Federal litigation;
2. ANY FAILURE to initiate corrective action here will certainly show cause to EXPAND upon or bring NEW -
COLOR OF LAW, DUE PROCESS and other claims against the Commonwealth of Massachusetts;
3. It has been made ABUNDANTLY CLEAR that the evidenced arguments related to this (State and Federal)
litigation are believed to impact matters of National Security, as they include (but are not limited to)
TREASON Claims under ARTICLE III and ECONOMIC ESPIONAGE pursuant to 18 U.S.C. § 1832.
Therefore, The President, members of Congress, Governor Baker, the FBI and the Department of Justice
(DOJ) will be copied on this email. The PUBLIC will also be copied for documentation purposes and out of
continued concern for my personal safety and security.

Please provide a documented response NO LATER THAN FRIDAY, MAY 25, 2018, stating your office's
intentions moving forward. Thank you for your attention to this very serious matter.

Respectfully,

Mohan A. Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
 COMMONWEALTH OF MASSACHUSETTS
THE TRIAL COURT
NORTHEAST HOUSING COURT

US BANK NA, AS TRUSTEE FOR ) Case No. 11-SP-3032

SECURITIZED TRUST CMLTI )
MORTGAGE PASS THROUGH )
CERTIFICATE SERIES 2006-AR1 )
TRUST )
)
Plaintiff )
)
v. )
)
MOHAN A HARIHAR )
)
Defendant )

DEFENDANT MOTION TO RESTORE CASE, PURSUANT TO MASSACHUSETTS CIVIL

RULES OF PROCEDURE 60(b)(3)

The Defendant, Mohan A. Harihar, acting pro se, respectfully prefaces this motion with the

following Disclosure(s):

1. The gravity of serious legal issues addressed in this motion against the Plaintiff – US

BANK NA is directly related to ongoing Federal litigation in the First Circuit Court of

Appeals.1 This related Federal litigation includes (but is not limited to): a.) Evidenced

allegations of TREASON under ARTICLE III, Section 3 of the Constitution, and b.)

Economic Espionage pursuant to 18 U.S.C. § 1832, - believed to impact matters of

National Security. Therefore, copies of this related MOTION are sent via email, social

1
The related Federal litigation references: 1.) HARIHAR v. US BANK et al, Appeal No. 17-
cv-1381 (Lower Court Docket No. 15-cv-11880) and 2.) HARIHAR v. THE UNITED
STATES, Appeal No. 17-2074 (Lower Court Docket No. 17-cv-11109).
 media and/or certified mail to: The Executive Office of the President (EOP), the US

Inspector General - Michael Horowitz, US Attorney General - Jeff Sessions,

members of the US Senate and House of Representatives, the House Judiciary

Committee, House Oversight Committee and to the Federal Bureau of Investigation

(FBI). Copies are similarly delivered to Massachusetts State Legislators, including

Governor - Charlie Baker (R-MA) and MA Attorney General - Maura Healey. A

copy will also be made available to the Public. THEREFORE, ALL AMERICANS

serve here as WITNESS. Parties are additionally informed for documentation purposes,

and out of the Defendant’s continued concerns for his personal safety/security.

2. The TREASON claims referenced above pertain to evidenced judicial misconduct claims

now alleged against SEVEN (7) Federal (District and Circuit) judges – INCLUDING

Chief Justice – Jeffrey R. Howard, for ruling WITHOUT JURISDICTION. Mr.

Harihar has necessarily brought judicial misconduct complaints against TEN (10)

Officers of the (Federal) Court,2 for their collective failures to uphold Federal Law(s)

and the judicial machinery of the Court. Mr. Harihar reserves the right to expand upon by

amendment, the list of parties that allegedly bear some responsibility and have

contributed (at least in part) to the damages and increased hardships to him. Additional

parties MAY include (but would not be limited to) related officers of the Court (State and

Federal) who have failed to uphold the judicial machinery of the Court, as evidenced by

the record(s).

2
The referenced TEN (10) officers of the Court include: US District Court Judge’s - Allison
Dale Burroughs, Chief Judge Joseph N. Laplante (NH), Judge John J. McConnell, Jr. (RI), and
Judge John David Levy (ME), First Circuit Judges - Juan R. Torruella, William J. Kayatta, Jr.,
David J. Barron, O. Rogeriee Thompson, Chief Justice Jeffrey R. Howard and District Court
Judge Denise J. Casper.
3. In the referenced federal litigation – HARIHAR v. US BANK et al, the evidenced

judicial misconduct claims of record brought against the initial presiding US District

Court Judge – Allison Dale Burroughs eventually led to her RECUSAL from

HARIHAR v. THE UNITED STATES. This recusal: 1.) re-affirms ALL judicial

claims – including (but not limited to) six (6) counts of TREASON for ruling

WITHOUT Jurisdiction; 2.) shows cause for the Plaintiff to attack ALL related orders;

3.) mandates that the District Court VOID ALL related orders, including the dismissal

order.

4. The evidenced PATTERN(S) OF CORRUPT CONDUCT alleged against the Federal

Judiciary is IDENTICAL and/or resembles similar patterns of corrupt conduct evidenced

by related judgments here in this Commonwealth. This Court is respectfully reminded

that the Commonwealth of Massachusetts and former Attorney General – Martha

Coakley are Appellees in the related federal litigation, with evidenced allegations that

include (but are not limited to): 1.) RICO (Civil/Criminal), 2.) Fraud on the Court, 3.)

Due Process, 4.) Color of Law, 5.) Misprision 6.) Conspiracy 7.) Perjury and other

violations. The nearly SEVEN (7) year historical record(s) of this litigation shows an

obvious cause for concern and questions whether this referenced pattern of corrupt

conduct will continue here. While there certainly is concern, there is FULL expectation

for this Housing Court to uphold the law and correct any past erred judgments of

record. Respectfully, any perceived failure to uphold the judicial machinery of the Court

will be in full public view and will (at minimum) warrant filing incremental Judicial

misconduct complaints.
 5. Although Federal litigation is ongoing, the evidenced record3 shows cause to correct the

erred judgments of the Commonwealth and seek damages including (but not limited to)

Quiet Title.4 Mr. Harihar makes clear that with this motion, it is not intended to duplicate

damages sought in related Federal/State litigation. At the conclusion of these

proceedings, any relief awarded to Mr. Harihar here will be appropriately deducted from

relief sought in related proceedings, to avoid duplication.

6. The Plaintiff respectfully makes clear that he additionally seeks CRIMINAL

CHARGES (State AND Federal) and PROFESSIONAL PENALTIES (where it is

warranted) against ALL responsible parties for the criminal components associated with

this litigation including (but not limited to) FRAUD. Mr. Harihar has necessarily filed

incremental criminal complaints with the Massachusetts Attorney General’s Office and

the FBI and seeks to enjoin his civil claims with his evidenced criminal claims with the

assistance (here) of State Prosecutors.5 Copies of motion and the referenced criminal

complaints will also be delivered to the direct attention of MA Attorney General –

Maura Healey, Governor Charlie Baker (R-MA), and the FBI via e-mail

communication.6 ANY continued failures here by State Prosecutors to bring criminal

3
The evidenced record includes (but is not limited to) the argument and sworn testimony by
Fraud Expert – Lynn Syzmoniak, representing The United States in the related case:
0:2013CV00464 USA VS ACE SEC. CORP. ET AL. The Fraud Expert’s testimony
conclusively shows that the referenced Residential Mortgage Backed Security (RMBS) Trust –
CMLTI 2006-AR1 is considered VOID, and therefore has NO LEGAL STANDING to the
Plaintiff’s property located at 168 Parkview Avenue, Lowell, MA 01852.
4
The Defendant has recently filed a NEW Complaint for Quiet Title in the MA Land Court,
Case No. 18-MISC-000144
5 See Attachment A – UPDATED FBI AND MA AGO criminal complaints were filed

separately against each Defendant. To avoid excessive repetition, a condensed version is attached
with this complaint.
6 See Attachment B
 charges against referenced parties will be in full public view and will (at minimum) show

cause to expand upon (or bring new) claims against the Commonwealth.

7. A review of the historical record shows that EVERY State and Federal Court associated

with this litigation has been made aware that the referenced property in question has been

identified as an ILLEGAL FORECLOSURE by: 1.) The Department of Justice

(DOJ), 2.) Federal Bank Regulators, and 3.) The Massachusetts Office of the

Attorney General (AGO). Here, Mr. Harihar will seek subpoenaed testimony from each

of these offices/agencies to describe in detail, ALL variables which led to conclusively

determining that (at minimum) Mr. Harihar’s Foreclosure was in FACT, ILLEGAL.

8. The Defendant has also filed a FOIA (Freedom of Information Act) request, to provide

incremental supporting evidence before a trial jury, if it becomes necessary.

COMES NOW the Defendant – MOHAN A. HARIHAR, who respectfully files this motion to

RE-OPEN this case pertaining to a past SUMMARY JUDGMENT, as Federal records

conclusively reveal – UNNOPOSED CLAIMS OF FRAUD ON THE COURT, pursuant to (at

minimum) FRCP 60(b)(3).

I. INTRODUCTION

The original action involves the foreclosure of the residential Property belonging to the

Defendant. As a matter of record, this foreclosure was declared ILLEGAL by: 1.) The

Department of Justice (DOJ), 2.) Federal Bank Regulators and 3.) The Massachusetts

Attorney General’s Office). Litigation pertaining to this referenced illegal foreclosure has been

ongoing for more than seven (7) years – four (4) in Massachusetts State Court(s) followed by
more than three (3) years in Federal Court(s). There are two (2) Appeals which are ongoing: 1.)

Appeal No. 17-1381, HARIHAR v. US BANK et al7 and 2.) Appeal No. 17-2074, HARIHAR

v. THE UNITED STATES.8 In the related Federal litigation, the EVIDENCED and

UNOPPOSED Fraud on the Court claims brought against ALL related parties named here

shows cause (at least in part) to: 1.) File a new complaint with the Land Court for Quiet Title and

2.) Address and correct erred judgments of the Commonwealth stemming from the Northeast

Housing Court and the Middlesex Superior Court. As described within the referenced federal

record(s), Sovereign (and any other form) of immunity as well as litigation privilege is

waived when there exists an evidenced Fraud on the Court claim(s) – as is the case here.

This is an action brought by the Defendant seeking corrective action including (but not limited

to) a REVERSAL of SUMMARY JUDGMENT as it pertains to the referenced foreclosure,

followed by his wrongful displacement and sale of his property. Mr. Harihar additionally seeks

damages for declaratory judgment, injunctive and equitable relief, and for compensatory, special,

general, punitive and ANY OTHER relief/corrective action deemed appropriate by this Court.

Mr. Harihar also seeks reimbursement for legal (and associated costs). While the Defendant is

initially proceeding as a pro se litigant (out of financial necessity) his time is considered no less

valuable than that of opposing counsel.

The evidenced allegations brought by the Defendant here, and throughout the history of this

litigation are believed to represent only a portion of infractions against the identified Trustee, US

7
Lower Docket No. 15-cv-11880
8
Lower Docket No. 17-cv-11109
BANK AND their affiliated counsel of record. The Defendant retains the right to expand upon

by amendment, additional related claims and/or parties, should it become necessary; also, in the

event Defendant is successful in retaining counsel.

II. FACTUAL ALLEGATIONS

A. Evidenced (AND UNOPPOSED) Fraud on the Court Claims

1. Per Fed. R. Civ. Proc. Rule 60(b)(3) - fraud (whether previously called intrinsic or

extrinsic), misrepresentation, or misconduct by an opposing party. “That cheaters

should not be allowed to prosper has long been central to the moral fabric of our

society and one of the underpinnings of our legal system.”9

2. The basic standards governing fraud on the court are reasonably straightforward. As set

forth in Cox v. Burke, 706 So. 2d 43, 47 (Fla. 5th DCA 1998): The requisite fraud on the

court occurs where “it can be demonstrated, clearly and convincingly, that a party has

sentiently set in motion some unconscionable scheme calculated to interfere with the

judicial system’s ability impartially to adjudicate a matter by improperly influencing

the trier of fact or unfairly hampering the presentation of the opposing party’s claim or

defense.” Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118 (1st Cir. 1989) . . .

3. Fraud on the court as described in Cox typically refers to substantive, not procedural,

misconduct. The same is true here as it pertains to clear title. The Plaintiff – US BANK

NA was aware or should have been aware that clear title did not exist with the Mr.

Harihar’s property and collectively participated in a scheme to defraud him of his

HOMESTEAD. This Court is well aware that this is not an isolated incident. The

9
Florida Bar Journal, February, 2004 Volume LXXVIII, No. 2, p.16
 Defendant is able to conservatively provide 4.2 million other examples of this scheme, as

described by the DOJ, Federal Bank Regulators, and the MA AGO.

4. A summary overview of the scheme begins with the RMBS Trust has no legal standing

to the Defendant’s property.10 Every action thereafter is impacted; has no legal

standing and therefore is moot/void; ranging from collecting monthly mortgage

payments, to foreclosure, resale, etc... As previously detailed, the Plaintiff (and other

referenced parties, including their attorneys) have benefited from the alleged scheme

against the Defendant, either personally or financially (or both); Litigation privilege

should not apply when there exists a supported claim of Fraud on the Court, nor

should Sovereign (or ANY OTHER) immunity. The referenced: 1.) RMBS Trust, 2.)

Bank Defendants, 3.) Attorneys and Law Firms, 4.) Real Estate Brokers and 5.)

Defendant Homebuyers have benefitted financially from the alleged scheme – when they

had no legal standing to do so; resulting in severe detriment to the Plaintiff.

5. The Defendant believes the Commonwealth has THUS FAR refused to prosecute and

correct erred judgments (at minimum) out of fear of implicating themselves, and to

avoid setting a legal precedent for the Nation. Regardless, their failure to hold

parties accountable is UNACCEPTABLE. As evidenced by the Federal record(s), the

UNOPPOSED Fraud on the Court Claim against Defendant – Commonwealth of

Massachusetts and Defendant – Former Attorney General Martha Coakley,

mandates waiver of their right to sovereign (or any other form of) immunity.

10
If it becomes necessary, the Defendant will provide the evidenced supporting argument to
show LACK OF STANDING.
6. As a general proposition, substantive misconduct provides grounds for default with

prejudice because it more clearly and directly subverts the judicial process. The

Defendant respectfully calls for this Court to recognize the evidenced Federal and State

records and conclude that the conduct forming the basis for Plaintiff default was willful

or done in BAD FAITH or was deliberate and in contumacious disregard of the Court’s

authority.

7. In the referenced Federal litigation, HARIHAR v. US BANK et al (Lower Docket No.

15-cv-11880), Mr. Harihar raised – “Fraud on the Court” claims against ALL Defendants

under Fed. R. Civ. P. 60(b)(3). The record clearly shows that the Defendants’ arguments

show the intention to purposefully DECEIVE the Court. The Plaintiff’s Rule 60(b)

motion went UNOPPOSED, warranting DEFAULT with Prejudice in favor of the

Plaintiff – Mohan A. Harihar. But that’s not all – the Defendants’ federal arguments

of record are identical to previous arguments from related litigation in

Massachusetts State Court(s). Therefore:

a. Mr. Harihar shows cause here to (at minimum) bring NEW Fraud on the Court

claims against Bank Defendants, their Attorneys and the RMBS Trust – CMLTI

2006-AR1;

b. Since Federal Fraud on the Court Claims against ALL Defendants stand as

UNOPPOSED, there CANNOT be a deviation from that position as it relates to

the SAME evidenced claims here. Any attempt to do so will undoubtedly impact

both Federal and State litigation, bringing incremental misconduct claims;

 c. By law, once validated, this UNOPPOSED Fraud on the Court claims must result

in a DEFAULT Judgment IN FAVOR of the Defendant – MOHAN A.

HARIHAR, WITH PREJUDICE;

d. Respectfully, any failure to uphold evidenced Fraud on the Court claims will be

interpreted as a failure to uphold the judicial machinery on the Court,

IDENTICAL to the PATTERNS OF CORRUPT CONDUCT currently

experienced in the related Federal litigation. Should this occur, the Defendant will

similarly show cause here to (at minimum) file a judicial misconduct

complaint(s).

PRIOR to moving forward, the Defendant respectfully requests that this Court FIRST issue a

separate INJUNCTION to establish a BALANCE OF HARDSHIPS as it pertains to: 1.)

Housing, 2.) Transportation and 3.) other related costs as they existed BEFORE the

referenced ILLEGAL FORECLOSURE.

Finally, for documentation purposes, after sending a copy of the motion to the attention of The

President, confirmation from the White House is attached (See Attachment C) with the filed

Court copy. If there is a question regarding ANY portion of this motion, the Defendant is happy

to provide additional supporting information upon request.

Mr. Harihar is grateful for the Court’s consideration of this very serious matter.
Respectfully submitted this 18th Day of May, 2018

Mohan A. Harihar
Defendant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
Attachment A
The INFORMATION (Text Box) reads as follows:

“This UPDATED Criminal Complaint is filed by Massachusetts resident - Mohan A. Harihar for
the specific purpose of bringing CRIMINAL CHARGES (Federal and State) against ALL
identified parties associated with the ILLEGAL FORECLOSURE of his residential
Property/HOMESTEAD located at 168 Parkview Avenue, Lowell, MA 01852. As a respectful
reminder: 1.) The Department of Justice (DOJ), 2.) The MA Attorney General’s Office and 3.)
Federal Bank Regulators have ALL identified the referenced foreclosure as ILLEGAL. Civil
litigation related to the referenced illegal foreclosure is ongoing in the First Circuit Appeals
Court – Appeal No. 17-1381, HARIHAR v US BANK et al, and Appeal No. 17-2074
HARIHAR v THE UNITED STATES. A third complaint is now being filed with the
Massachusetts Land Court, in conjunction with this criminal complaint (which will be included
as an attachment for the Court’s records). Evidenced CRIMINAL claims of record include (but
are not limited to): FRAUD, Criminal RICO, Conspiracy, Economic Espionage, Treason,
Misprision, Fraud on the Court and others. ANY continued failure to prosecute these evidenced
criminal claims will show cause to expand upon (or bring NEW) Color of LAW/Due Process
violations against THE UNITED STATES and ALL responsible parties. Please be advised - on
January 24, 2018, 10:12am (EST), I placed a call to FBI Headquarters to report an evidenced act
of TREASON and ECONOMIC ESPIONAGE against The United States. After nine (9) minutes
of articulating these evidenced claims (ALL of which are documented by court record(s)), the
intake FBI agent HUNG UP on the phone call. This is a serious concern which must be legally
addressed, as it impacts the ongoing litigation. It is also interpreted that these evidenced criminal
claims impact NATIONAL SECURITY. It is my understanding that ALL calls are recorded. Out
of fear for my personal SAFETY AND SECURITY, copies of this criminal complaint are made
available to the public.”
Attachment B
 ---------- Forwarded message ----------
From: Mohan Harihar <moharihar@gmail.com>
Date: Fri, May 18, 2018 at 12:58 PM
Subject: Demand for State Prosecutors to Address Filed Criminal Complaints
To: maura.healey@state.ma.us
Cc: elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
scheduling@warren.senate.gov, sydney_levin-epstein@markey.senate.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>, june.black@mail.house.gov,
NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, mary.murrane@usdoj.gov,
christina.sterling@usdoj.gov, washington.field@ic.fbi.gov, boston@ic.fbi.gov

Attorney General Healey,

This email communication is delivered to your direct attention for the purpose of bringing criminal charges
associated with an ILLEGAL FORECLOSURE identified by your office. You are aware of ongoing litigation
related to this matter - HARIHAR v. US BANK et al, Appeal No. 17-1381 (Lower Court Docket No. 15-cv-
11880), which includes the Commonwealth as a Defendant/Appellee. You are also aware that in this
referenced litigation and as part of Federal record, the UNOPPOSED FRAUD on the COURT claim(s) under
FRCP 60(b)(3), shows cause to re-address (and correct) prior judgments that have been impacted.

There are two (2) motions being filed to address these Fraud on the Court claims - pursuant to Massachusetts
Civil Rule of Procedure 60(b)(3). The first is being filed with the Northeast Housing Court in Lawrence, MA.
The second is intended to be filed in the coming days with the Middlesex Superior Court. You are aware that
I continue to seek CRIMINAL CHARGES against ALL responsible parties associated with these (and other)
related claims of record. Updated criminal complaints have been filed with your office, however, it is unclear as
to why I have yet to receive a response.

Attached, please find a copy of the Motion to RE-OPEN the referenced case, US BANK NA v. MOHAN A.
HARIHAR, 11-SP-3032 being filed today with the Northeast Housing Court. State Prosecutors are now called
to enjoin this civil matter, bringing criminal charges against the Plaintiff - US BANK NA and their attorneys.
Respectfully, please be advised of the following:

1. SHOULD the Commonwealth initiate corrective action including (but not limited to) bringing criminal charges
against referenced parties, there MAY be opportunity for discussing a mutual agreement in the related
Federal litigation;
2. ANY FAILURE to initiate corrective action here will certainly show cause to EXPAND upon or bring NEW -
COLOR OF LAW, DUE PROCESS and other claims against the Commonwealth of Massachusetts;
3. It has been made ABUNDANTLY CLEAR that the evidenced arguments related to this (State and Federal)
litigation are believed to impact matters of National Security, as they include (but are not limited to)
TREASON Claims under ARTICLE III and ECONOMIC ESPIONAGE pursuant to 18 U.S.C. § 1832.
Therefore, The President, members of Congress, Governor Baker, the FBI and the Department of Justice
(DOJ) will be copied on this email. The PUBLIC will also be copied for documentation purposes and out of
continued concern for my personal safety and security.

Please provide a documented response NO LATER THAN FRIDAY, MAY 25, 2018, stating your office's
intentions moving forward. Thank you for your attention to this very serious matter.

Respectfully,

Mohan A. Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Attachment C
 CERTIFICATE OF SERVICE

I hereby certify that on May 18, 2018 I filed the foregoing with the Clerk of Court via (USPS)
mail. A Copy of the motion was also sent via certified (USPS) mail to the following counsel of
the Defendant at their last known address:

David E. Fialkow
K&L Gates, LLP
State Street Financial Center
One Lincoln Street
Boston, MA 02111

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