IN THE UNITED STATES COURT OF APPEALS

FOR THE FIRST CIRCUIT

)
MOHAN A. HARIHAR, )
)
Appellant )
) Case No. 17-2074
v. )
)
THE UNITED STATES OF AMERICA )
)
Appellee )
)

APPELLANT MOTION FOR STAY OF APPEAL CITING UNRESOLVED ISSUES

AND CONTINUED PATTERN OF CORRUPT CONDUCT

Disclosure Statement of the Appellant - The Appellant respectfully prefaces this MOTION

with the following Disclosure statement:

The gravity of serious legal issues addressed in the Civil Complaint against THE UNITED

STATES, this associated Appeal, and in the RELATED Appeal,1 include (but are not limited

to) evidenced allegations of TREASON under ARTICLE III, Section 3 of the Constitution,

Economic Espionage pursuant to 18 U.S.C. 1832 and are believed to impact matters of

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

and/or certified mail to: The Executive Office of the President (EOP), the US Inspector

1
The related Appeal references HARIHAR v. US BANK et al, Appeal No. 17-cv-1381 (Also,
lower court Docket No. 15-cv-11880).
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). A copy will also be made

available to the Public. THEREFORE, ALL AMERICANS serve as WITNESS to these

evidenced acts of misconduct (alleged). Parties are additionally informed for documentation

purposes, and out of the Appellants continued concerns for personal safety/security.

COMES NOW the Appellant, Mohan A. Harihar, acting pro se, who respectfully calls for a

STAY of this Appeal, considering the substantial list of unresolved issues which remain,

including (but not limited to) JURISDICTION issues. It is unclear - how a briefing schedule

has been allowed to be set considering these glaring circumstances. ANY OBJECTIVE

OBSERVER will certainly agree that a PATTERN OF CORRUPT CONDUCT by officers of

the court appears to continue here still. The Appellant draws reference to the following:

1. The recently filed NOTICE OF INNACCURACIES filed with this Court on

November 6, 2017. The Notice also includes NEW Misprision of Treason claims

pursuant to 18 U.S. Code 2382 against Clerk ROBERT M. FARRELL, and

Deputy Clerk MATTHEW A. PAINE;

2. The RESPONSE TO COURT ORDER, Document No. 16 filed with the lower

Court on October 27, 2017; and

3. The MOTION TO REQUEST ASSISTANCE WITH APPOINTMENT OF

COUNSEL, PURSUANT TO 28 U.S.C. 1915 filed with this Court on November 8,

2017 which is still pending.

Considering the collective (and substantial) list of unresolved issues associated with these filed

court documents, it is unclear how Clerk - Margaret Carter could have justified this pre-

mature release of the briefing schedule. The Appellant has clear reason(s) to believe this

premature action by Clerk Carter IS NOT by accident, and shows a CONTINUED PATTERN

OF CORRUPT CONDUCT to (at minimum) interfere with the Appellants right to DUE

PROCESS. It is HIGHLY UNLIKELY that Clerk Carter was unaware of the substantial list of

unresolved issues and IF she was unaware, that too is an issue. This inappropriate and

unlawful action by a Court Clerk shows cause to (at minimum) EXPAND UPON the following

claims against The United States:

a. Title 18, U.S.C., Section 242 Deprivation of Rights Under Color of Law;

b. Title 18, U.S.C., Section 241 Conspiracy Against Rights;

c. Title 18, U.S.C., Section 1001 Fraud and False Statements;

d. Title 42 Sec. 1983, Civil action for Deprivation of Rights.

This Court is respectfully reminded that a PORTION of these unresolved issues (including but

not limited to Treason, Misprision of Treason, Fraud, Conspiracy and Economic Espionage) are

CRIMINAL in nature. Throughout this litigation both here and in the related case,

HARIHAR v. US BANK et al2, the Appellant has made clear that he seeks criminal charges

against ALL responsible parties. Despite ongoing efforts to align with Department of Justice and

bring criminal charges, it is unclear as to WHY EXACTLY that has not happened.

2
The Related litigation is HARIHAR v. US BANK et al, Appeal No. 17-1381, lower court
Docket No. 15-cv-11880.
Now however, ASSISTANT UNITED STATES ATTORNEY - Dina Michael Chaitowitz has

been assigned to represent The United States in this civil Appeal. Therefore, counsel is

considered as a witness to the evidenced criminal claims associated with this complaint, as well

as now having FIRST-HAND knowledge of ALL evidenced criminal claims in the related

litigation HARIHAR v. US BANK et al.

The Appellant respectfully reminds the Court that JURISDICTION here remains an issue.

Circuit Judges - Torruella, Kayatta, Barron, Thompson, and Chief Justice Howard are

considered to have lost jurisdiction and are no longer allowed to rule in this litigation. Any

attempt to do so will be interpreted by the Appellant as an incremental act(s) of Treason under

ARTICLE III. Already, evidenced claims of TREASON (one (1) count each) have been

brought to the attention of the President against Judge Kayatta and Chief Justice Howard.

SHOULD this Court finally initiate corrective action with regard to the requested relief, it will

certainly be taken into consideration moving forward.

CONCLUSION

Before any decision here is rendered, jurisdiction must first be re-established. Upon doing so,

based on the reasons stated within, the Appellant respectfully suggests that it is premature to

proceed with briefing at this time, and the proceedings should therefore be stayed until ALL

unresolved issues have been properly addressed. That includes, but is not limited to providing an

ANSWER as to whether or not The United States is interested in reaching a mutual agreement
with the Appellant, as it pertains to the civil portions of this complaint. There is also a clear

expectation that Assistant US Attorney Chaitowitz and the Department of Justice will take

the appropriate steps in addressing ALL criminal claims associated with this complaint and

with the related litigation, Harihar v. US BANK, et al, including bringing criminal charges.

For documentation purposes, after sending a copy of this document to the President, the email

from The White House confirming receipt is attached (See Attachment A) with the filed Court

copy. If there is a question regarding ANY portion of this Motion, the Appellant is happy to

provide additional supporting information upon request, in a separate hearing and with the

presence of an independent court reporter.

Respectfully submitted this 21st Day of November, 2017

Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
Attachment A
 CERTIFICATE OF SERVICE

I hereby certify that on November 21, 2017 I electronically filed the foregoing with the Clerk of
Court using the CM/ECF System, which will send notice of such filing to the following
registered CM/ECF users:

Dina Michael Chaitowitz

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