Professional Documents
Culture Documents
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MOHAN A HARIHAR ) Case No. 18-MISC-000144
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Plaintiff )
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v. )
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WELLS FARGO BANK NA, et al )
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Defendants )
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PLAINTIFF DISCLOSURE
The gravity of serious legal issues addressed in the related Federal Appeals, and newly filed
(Federal) Civil Complaint1 include (but are not limited to): 1.) evidenced allegations of
TREASON under ARTICLE III, Section 3 of the Constitution, and 2.) Economic Espionage
pursuant to 18 U.S.C. § 1832, which are believed to impact matters of National Security. The
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The related Federal Appeals reference HARIHAR v US BANK et al, Appeal No. 17-
1381(lower court Docket No. 15-cv-11880) HARIHAR v. THE UNITED STATES, Appeal
No. 17-cv-2074 (Also, lower court Docket No. 17-cv-11109). A third complaint has been filed
against referenced INFERIOR Federal Judges and Defendant counsel including Attorneys
David E. Fialkow and Jeffrey Loeb (See HARIHAR v. CHIEF JUDGE JEFFREY R.
HOWARD, Docket No. 18-cv-11134).
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MISCONDUCT - On March 19, 2018, Criminal Complaints were filed with the Federal
Bureau of Investigation (FBI) against the TEN (10) identified Federal (Circuit and District)
Court Judges. Therefore, since this is a RELATED ACTION, copies of this MOTION are
necessarily sent via email, social media and/or certified mail to the:
9. Office of the Special Inspector General for the Troubled Asset Relief
Program (SIGTARP);
A copy will also be made available to the PUBLIC, since collectively, the judiciary’s effort to
“promote public confidence in the impartiality of the judicial process,” has irrefutably been
compromised. By informing the Public, ALL AMERICANS serve here as WITNESS. Parties
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are additionally informed for documentation purposes, and out of the Plaintiff’s continued
COMES NOW the Plaintiff, who necessarily files this MOTION following the June 8, 2018
filing his Petition for Writ of Certiorari. On June 14, 2018, the First Circuit Appeals Court
acknowledged the SCOTUS decision, informing all parties by email, Document: 00117301445,
more however, is that the Appellees (INCLUDING HERE - Bank Defendants Wells Fargo,
the Appellant’s reasons for requesting this extension. This now creates a substantial
motion re-affirms the original (Federal) FRAUD ON THE COURT CLAIM pursuant to FRCP
60(b)(3). Here, the Plaintiff’s position is re-affirmed where the Defendants AGAIN have
consciously chosen NOT to oppose a motion to this Nation’s highest Court, creating clear
2See Exhibit 1
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See Exhibit 2, the June 4, 2018 filed RESPONSE to Judge David Barron’s RECUSAL,
which provides a (partial) list of unresolved issues which must be addressed before the Appellant
can appropriately file his Petition for Writ of Certiorari (if it even becomes necessary).
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conflict with their arguments here. Since Appellees chose not to file any opposition with the
Supreme Court, similarly, they CANNOT be allowed to bring an opposing position here.
THEREFORE, based on this recent development from SCOTUS, and the Defendant’s
clear effort to deceive this Court, the Plaintiff’s position is re-affirmed, showing cause for this
with prejudice. This Court should award the Plaintiff - Quiet Title to HIS Property, ALL
requested relief and any other relief deemed appropriate, including (but not limited to) relocation
costs. Additionally, Defendants – Jeffrey and Isabelle Perkins should be similarly given a
County Sherriff’s Department. Corrective action initiated by this Land Court MAY allow for
consideration in resolving (at least a portion of) existing misconduct claims against
BANK). If there is a question regarding ANY portion of this Motion, the Plaintiff is happy to
The Plaintiff is grateful for the Court’s efforts to address and initiate the referenced corrective
action(s). For documentation purposes, after sending a copy of this MOTION to the attention of
POTUS, confirmation of its receipt is attached (See Exhibit 3) with the filed Court copy. If
there is a question regarding ANY portion of this motion, the Plaintiff is happy to provide
additional supporting information upon request, in a separate hearing and with the presence of an
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Respectfully submitted this 24th Day of June, 2018
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
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Exhibit 1
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Exhibit 2
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IN THE UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
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MOHAN A. HARIHAR, )
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Appellant )
) Case No. 17-1381
v. )
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US BANK, et al )
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Defendants/Appellees )
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APPELLANT DISCLOSURE
The gravity of serious legal issues addressed in this Appeal (lower court Docket No. 15-cv-
11880), and in the RELATED Appeal,4 include (but are not limited to): 1.) evidenced
allegations of TREASON under ARTICLE III, Section 3 of the Constitution, and 2.)
Economic Espionage pursuant to 18 U.S.C. § 1832, which are believed to impact matters of
National Security. The evidenced allegations against referenced officers of the Court
filed with the Federal Bureau of Investigation (FBI) against the TEN (10) identified Federal
4
The related Appeal references HARIHAR v. THE UNITED STATES, Appeal No. 17-cv-
2074 (Also, lower court Docket No. 17-cv-11109).
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(Circuit and District) Court Judges. Therefore, copies of this RESPONSE are necessarily sent
22. Office of the Special Inspector General for the Troubled Asset Relief
Program (SIGTARP);
A copy will also be made available to the PUBLIC, as this judiciary’s effort to “promote
public confidence in the impartiality of the judicial process,” has irrefutably been
compromised. By informing the Public, ALL AMERICANS serve here as WITNESS. Parties
are additionally informed for documentation purposes, and out of the Appellant’s continued
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COMES NOW the Appellant, who files this timely RESPONSE after being notified on May
18, 2018 of the RECUSAL by Circuit Judge David Barron. The announcement of this recusal
raises a number of issues, including (but not limited to) the following:
II. This Court MUST Address the PRIOR Recusals of Judge Allison Dale Burroughs
III. This Court MUST Finally Address ALL previously referenced, and STILL
UNRESOLVED ISSUES;
V. Impacted Orders;
__________________________________________________________________
After reviewing the referenced 5/18/2018 letter5 announcing the recusal of Judge David
Barron, the explanation provided is considered insufficient, in that far more detail is required
in order to fully understand ALL factors leading up to this recusal. The Appellant
respectfully requests that Judge Barron provide for the record a detailed explanation of
exactly HOW, at this time he came to find out about a Financial interest in the
Appellee/Defendant – Wells Fargo. While the Appellant does not necessarily question the
conflict itself, there is cause to question the timing of its discovery. This Appeal was initiated
5 See Attachment A
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in April 2017 – therefore, further validation is needed to confirm all details related to the
II. This Court MUST NOW Address the PRIOR Recusals of Judge Allison Dale Burroughs
This Court is aware that the announced recusal of Judge Barron is the THIRD (3rd)
RECUSAL associated with this litigation. On June 19, 2017, the first Judge to recuse was
Judge Allison Dale Burroughs from the RELATED case – HARIHAR v THE UNITED
STATES, Docket No. 17-cv-11109. Despite multiple documented efforts by the Appellant,
the record will conclusively reveal multiple failures by BOTH the District and Appellate
Courts to address and remedy the list of resulting conflicts and impacted orders associated
The second recusal was announced by Chief Judge Howard, who recused Circuit Judge
Sandra Lynch from ruling on the 3/14/2018 decision for reasons UNKNOWN.6
III. This Court MUST Finally Address ALL previously referenced, and STILL
UNRESOLVED ISSUES
Aside from the issues related to the referenced recusals, this Court is reminded of the list of
existing issues which, as evidenced by the record, have been IGNORED by this Court –
BEGINNING WITH JURISDICTION ISSUES. This Court AND the American Public
have now witnessed the following acts, EACH of which constitute judicial misconduct –
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The 3/14/18 Order referenced the Appellant’s Petition for re-hearing en banc. Questions are
raised regarding not only the recusal of Judge Lynch, but also regarding the jurisdiction of other
judges issuing the referenced order(s).
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A. Continued REFUSAL to address/clarify JURISDICTION issues7;
WITHOUT VALID CAUSE - repeated requests for the Court to assist with the
COURT, pursuant to Fed. R. Civ. P. 60(b)(3) and clear violations to the Judicial Code
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The record shows that the Appellant has filed over FIFTY (50) + court documents which raise
a JURISDICTION issue, ALL of which have been IGNORED by referenced Federal (District
and Circuit) Judges.
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M. Refusing to address Title 18, U.S.C., Section 242 Deprivation of Rights Under Color
of Law;
N. Refusing to address Title 18, U.S.C., Section 241 Conspiracy Against Rights;
O. Refusing to address Title 18, U.S.C., Section 1001 Fraud and False Statements;
P. Refusing to address Title 42 Sec. 1983, Civil action for Deprivation of Rights;
R. Refusing to promptly reimburse accruing Legal (and other) Fees due to the Appellant, as
This Court must now address ALL litigation, associated orders and misconduct complaints
impacted by Judge Barron’s recusal, not just Appeal No. 17-1381. Judge Barron is also a
presiding judge in the RELATED APPEAL No. 17-2074 – HARIHAR v. THE UNITED
This Court is now aware that on May 30, 2018, the Appellant filed a NEW Complaint with
the District Court against multiple Defendants including TEN (10) Officers of the Court
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HARIHAR v. CHIEF JUDGE JEFFREY R. HOWARD, et al). Judge Barron is listed
here as a Defendant and as an inferior judge. The DEMAND is now respectfully made to
address ALL referenced litigation and judicial misconduct complaints impacted by recusal.
V. Impacted Orders
The Appellant first addresses the EIGHT (8) impacted orders of Appeal No. 17-1381:
A. ORDER OF COURT Entered: June 5, 2017 - Here, the appellant's motions for
appointment of counsel, for a stay, and for entry of default are denied. ALL requests
here have been denied WITHOUT VALID CAUSE, even when clarification and
reconsideration had been respectfully requested. With the recusal of Judge Barron
(and the previous RECUSAL of Judge Burroughs), the Appellant shows cause to
attack this order and have it VOIDED by the Court. Before any attempt to re-address
the issues contained in the original motion, the Court is respectfully reminded that
JURISDICTION remains an issue. The remaining TWO (2) presiding Circuit Judges
– Judge Torruella and Judge Kayatta are considered to have ALREADY LOST
been properly restored, evidenced arguments supporting the Appellant’s motion (at
evidenced errors, beginning with actions two (2) thru five (5) listed below. IF
withdraw judicial misconduct (and other) complaints (if allowed by law). Any
failure to initiate corrective action here will certainly contribute to the ongoing
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2. An ORDER granting the Appellant assistance with the appointment of counsel
retained, the Appellant reserves the right to further amend this response as
deemed necessary;
B. Once corrective action is initiated (as described above), the remaining orders8
associated with this Appeal No. 17-1381 are perceived as MOOT. The Appellant
restates that he retains the right to amend this response, if only partial corrective action
Based on Judge Barron’s recusal, the reasons stated above and throughout this Appeal,
shows absolute cause to initiate corrective action. Once these critical errors have been
corrected (as described by the Appellant), there will no longer be a need to petition the
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Remaining orders impacted by recusal (Appeal No. 17-1381 ONLY) include orders issued on
the following dates: July 31, 2017, August 8, 2017, March 14, 2018, April 4, 2018 and April
11, 2018 Orders, as well as the January 17, 2018 Judgment.
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US Supreme Court. HOWEVER, until corrective action is initiated, the due date for filing
the Appellant’s Petition for Writ of Certiorari is fast approaching on June 12, 2018.
THEREFORE, with the filing of this response, the Appellant respectfully requests that
the Court issue an EMERGENCY STAY ORDER, that would temporarily suspend the
timeline for filing his petition until ALL unresolved issues have been appropriately
addressed.
A. Initiate corrective action by assisting the Appellant with the Appointment of Counsel
timeline for filing his petition with the Supreme Court until ALL unresolved issues
D. VACATE the Judgment and Mandate ORDER associated with this Appeal;
F. Issue an order for additional relief to the Appellant for: 1.) Punitive damages, 2.)
Declaratory relief and 3.) ANY OTHER relief deemed appropriate by the Court;
G. Issue an order for a reimbursement of legal fees (and ALL associated costs) as
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H. Appropriately address for the record, related issues pertaining to (at minimum)
and others. This will require the input from the Executive Branch of Government,
including (but not limited to): 1.) The President, 2.) The Department of Justice
The Appellant is grateful for the Court’s efforts to address and initiate the referenced corrective
action(s). For documentation purposes, after sending a copy of this RESPONSE to the attention
of The President, confirmation of its receipt is attached (See Attachment B) with the filed Court
copy. If there is a question regarding ANY portion of this response, the Appellant is happy to
provide additional supporting information upon request, in a separate hearing and with the
Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
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Exhibit 3
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CERTIFICATE OF SERVICE
I hereby certify that on June 24, 2018 I electronically filed the foregoing with the Clerk of Court
and counsel for the Defendants (listed below) via email communication. The Plaintiff will also
plan to bring additional hardcopies for all parties and the Court for the Case Management
Conference scheduled for Monday, June 25, 2018.
Jeffrey B. Loeb
David E. Fialkow
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
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