FOR IMMEDIATE RELEASE

TREASON allegations against the Constitution brought

against judge in the $42B lawsuit, Harihar vs. US Bank
Boston, MA, November 2, 2016 A response to a judicial order was filed today in the US District
Court (Boston, MA, Docket No: 15-cv-11880, Harihar vs. US Bank et al) by the pro se Plaintiff,
Mohan A. Harihar, bringing a second allegation of Treason to the Constitution against Judge
Allison D. Burroughs. With documents supporting allegations of judicial misconduct now before the
Judicial Council of the First Circuit, Harihar considers Judge Burroughs disqualified by law, which
prohibits her from issuing ANY further rulings in this case. The Plaintiffs interpretation of the law is that
Judge Burroughs no longer has jurisdiction to rule on this Docket. By doing so, the judge has twice
acted in a personal capacity versus a judicial capacity. Furthermore, Judge Burroughs has refused to
recuse herself, and has made no effort to address, dispute or deny any of the supported
allegations exemplifying judicial misconduct, including Treason.
Judge Burroughs knew, or should have known that, by her previous allegation that she had no
jurisdiction, and still AGAIN, committed treason against the Constitution.
In his filed response, Harihar states, We live in a time where Americans have begun to question
the integrity of our Federal Government, believing that corruption exists at a very high level.
Were hearing about it practically every day - reported in this Presidential election, within the
Department of Justice (DOJ) and the Federal Bureau of Investigation (FBI). Anyone who
reviews and understands the historical facts of this litigation, will too, question the integrity of
our government, and certainly this United States District Court. If there is going to be ANY
chance of re-building that integrity, it should begin with correcting documented BAD FAITH
actions committed by the United States against this Plaintiff

(Scroll down to view a copy of Harihars filed Motion, in its entirety.)

For Further Media Information Contact: Mohan A. Harihar
Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR
11880
Plaintiff

CIVIL ACTION NO: 15-cv-

vs.
US BANK NA, et al.
Defendants

PLAINTIFF RESPONSE TO DOCUMENT NO. 129

After reviewing Document No. 129 issued by Judge Allison D.

Burroughs, the Plaintiff, Mohan A. Harihar, acting pro se,
respectfully DISAGREES with its content, and files with the
Court the following response:

1. The Plaintiff DID NOT Expect an Order Issued by Judge

Burroughs For the supported allegations of judicial
misconduct now before the Judicial Council of the First
Circuit, the Plaintiff considers Judge Burroughs
disqualified by law. Because the judge is considered
disqualified, and due to the EMERGENCY status of the
motion, it was expected that the JUDICIAL COUNCIL would

dictate next steps in this litigation, adhering to 28 U.S.

Code 2412 (c)(2).1 For this reason, the Plaintiff
respectfully expressed caution in the original motion, and
a copy of the motion was filed with a second supplemental
complaint to the Judicial Council.

It is important to RE-STATE, that the Plaintiff relief

sought at this point in the litigation, stems from BAD
FAITH ACTIONS caused by the UNITED STATES and JUDGE
ALLISON D. BURROUGHS. Document No. 129 makes NO MENTION of
Bad Faith acts, appearing to avoid accountability and
resulting harm to this Plaintiff. If these referenced BAD
FAITH acts had not been committed by the United States, AT
MINIMUM, the Plaintiff would not be suffering increased
hardships; there would likely be experienced legal counsel
representing the Plaintiff; and this litigation would
likely be constructively farther along than it is now. If
28 U.S. Code 2412 (c)(2) is not the appropriate legal

Per 28 U.S. Code 2412 (c)(2) - Any judgment against the

United States or any agency and any official of the United
States acting in his or her official capacity for fees and
expenses of attorneys pursuant to subsection (b) shall be paid
as provided in sections 2414 and 2517 of this title, except
that if the basis for the award is a finding that the United
States acted in bad faith, then the award shall be paid by any
agency found to have acted in bad faith and shall be in
addition to any relief provided in the judgment.
1

reference for addressing ACTIONS MADE IN BAD FAITH, it

further underscores the need for the COURT to assist the
Plaintiff with retaining (already requested) legal
counsel.
2. TREASON AGAINST THE CONSTITUTION

- By issuing the order

associated with Document No. 129 (and previously with

Document No. 125), the Plaintiff brings a second
allegation of Treason to the Constitution against Judge
Allison D. Burroughs. For the reasons previously stated,
the Plaintiff considers Judge Burroughs disqualified by
law, prohibiting her from issuing ANY further rulings in
this case. The Plaintiffs interpretation of the law is
that Judge Burroughs no longer has jurisdiction to rule on
this Docket. By doing so, the judge has AGAIN acted in a
personal capacity versus a judicial capacity. Furthermore,
Judge Burroughs has refused to recuse herself, and has
made no effort to address, dispute or deny any of the
supported allegations exemplifying judicial misconduct,
including Treason.

Judge Burroughs knew, or should have known that, by her

previous allegation that she had no jurisdiction, she
The first allegation of Treason to the Constitution against
Judge Burroughs is supported by the issued Order in Document
No. 125.
2

committed treason against the Constitution. "We [Judges]

have no more right to decline the exercise of jurisdiction
which is given, then to usurp that which is not given. The
one or the other would be treason to the Constitution."
[clarification added] U.S. v. Will, 449 U.S. 200, 216, 101
S.Ct. 471, 66 L.Ed.2d 392, 406 (1980); Cohens v. Virginia,
19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821).
Judge Burroughs should not have engaged in treason to the
Constitution, a Constitution to which she has taken a
personal oath to support. VIOLATION OF SUPREME LAW OF THE
LAND - All judges have taken an oath to, and their lawful
authority depends on their complete and full compliance
with, the Constitution of the United States of America,
and the Supreme Law of the Land.
The Supreme Law of the Land can be found in the decisions
of the U.S. Supreme Court. In Old Wayne Mut. L. Assoc. v.
McDonough, 204 U.S. 8, 27 S.Ct. 236 (1907), the Supreme
Court ruled that:
"Chief Justice Marshall had long before observed in Ross
v. Himely, 4 Cranch 241, 269, 2 L.ed. 608, 617, that, upon
principle, the operation of every judgment must depend on
the power of the court to render that judgment. In
Williamson v. Berry, 8 How. 495, 540, 12 L.ed. 1170, 1189,
it was said to be well settled that the jurisdiction of

ANY COURT exercising authority over a subject `may be

inquired into in EVERY OTHER COURT when the proceedings in
the former are relied upon and brought before the latter
by a party claiming the benefit of such proceedings,' and
the rule prevails whether `the decree or judgment has been
given, in a court of admiralty, chancery, ecclesiastical
court, or court of common law, or whether the point ruled
has arisen under the laws of nations, the practice in
chancery, or the municipal laws of states.'" [Emphasis
added].
In Elliott v. Peirsol, 1 Pet. 328, 340, 26 U.S. 328, 340
(1828), the court stated that "without authority, its
judgments and orders are regarded as nullities. They are
not voidable, but simply void; and form no bar to a
recovery sought, even prior to a reversal in opposition to
them. They constitute no justification; and all persons
concerned in executing such judgments or sentences, are
considered, in law, as trespassers. This distinction runs
through all the cases on the subject; and it proves, that
the jurisdiction of ANY COURT exercising authority over a
subject, may be inquired into IN EVERY COURT, when the
proceedings of the former are relied on and brought before
the latter, by the party claiming the benefit of such
proceedings." [Emphasis added].

Judge Burroughs knew, or should have known, the law and

the U.S. Supreme Court decisions that ANY COURT and EVERY
COURT can vacate a void order. Judge Burroughs
conscientiously, arbitrarily, capriciously, deliberately,
intentionally, and knowingly engaged in conduct in
violation of the Supreme Law of the Land, and of Rule
62(A) and Rule 63(A).

3. Mutual Agreement Opportunity with the United States The

Court is aware that the Plaintiff has respectfully
extended an opportunity to reach a mutual agreement with
the United States. In Document No. 128, the Plaintiff
requested that the Court clarify the United States
position regarding the opportunity. After reading Document
No. 129, it appears that Judge Burroughs has ignored the
request to clarify for the record whether or not the
United States is interested in reaching a mutual agreement
with the Plaintiff. The Plaintiff respectfully restates
this request for clarification. IF the United States were
to ultimately reach a mutual agreement with the Plaintiff,
and ONLY IF it is allowed by law, there MAY be
consideration for withdrawing and/or amending existing
judicial complaints. Consideration will additionally be

given, should Judge Burroughs decide to immediately RECUSE

herself from this civil action.

If, however, the United States is NOT interested in

seeking a mutual agreement with the Plaintiff, then the
Plaintiff SHOULD (at minimum) be allowed to AMEND his
complaint, adding the United States as a Defendant for
reasons already presented to the Court.
4. Third Supplemental Complaint filed with the Judicial
Council With the second allegation of Treason against
the Constitution brought against Judge Allison D.
Burroughs, the Plaintiff files with the Judicial Council,
a Third Amended complaint, and attaches a copy of this
filed response, Document No. 131, as a reference.

CONCLUSION

We live in a time where Americans have begun to question the

integrity of our Federal Government, believing that corruption
exists at a very high level. Were hearing about it practically
every day - reported in this Presidential election, within the
Department of Justice (DOJ) and the Federal Bureau of
Investigation (FBI). Anyone who reviews and understands the
historical facts of this litigation, will too, question the

integrity of our government, and certainly this United States

District Court. If there is going to be ANY chance of rebuilding that integrity, it should begin with correcting
documented BAD FAITH actions committed by the United States
against this Plaintiff, and clarifying the mutual agreement
opportunity between the United States and the Plaintiff.

If the Court has ANY questions, or requires additional

information or clarification, the Plaintiff is happy to provide
upon request.

Respectfully Submitted,
Mohan A. Harihar