Professional Documents
Culture Documents
The Plaintiff – Mohan A. Harihar respectfully makes clear to this Court, that he opposes
EMERGENCY NOTICE on January 22, 2018 – nearly TWO (2) months ago, there
Transfer Order from the MA Land Court. The Plaintiff again re-states that this Court has
the complete MA Land Court docket that irrefutably shows how his evidenced
whether or not this Court has jurisdiction to proceed further. There is nothing to “sort
through” here.
2. FRAUD ON THE COURT – by filing their motion, Defendants - the Perkinses and
MERS show the intention to: (1) ignore jurisdiction (and all other) issues; and (2)
continue deceiving this (and every other related) court. The Plaintiff therefore shows
cause to expand upon existing Fraud on the Court claims against these Defendants and
their attorney – Jeffrey B. Loeb, under Mass R. Civ. P. 60(b)(3) – here, in ALL related
MA State Courts and similarly under Fed. R. Civ. P. 60(b)(3) in the related Federal
these issues are JUSTLY resolved, each attempt by Defendants to purposefully deceive
3. The Plaintiff respectfully restates that - based on his interpretation of the law, any
judicial officer who proceeds here before establishing jurisdiction for the record, will
be considered to have warred against the Constitution of The United States – an act of
Treason under ARTICLE III, Section 3. Should this occur (and as required by Federal
law), the Plaintiff will necessarily inform/update Governor Charlie Baker (R-MA) and
also the President of The United States (POTUS). All Defendants, their counsel and the
4. This court is already aware of the severity of evidenced claims raised against more than
FIFTEEN (15) Federal (and State) judicial officers. These evidenced claims have
resulted in an UNPRECEDENTED EIGHT (8) Federal Recusals thus far. Should the
presiding judge here disagree with ANY PART the Plaintiff’s assessment, clarification
will be requested for the record as to how their conclusion was reached (including exactly
which documents were reviewed), as it may (at minimum) bear impact to ongoing
Federal litigation;
discussion (Mass. R. Civ. P. 16(9)), it is the Plaintiff’s understanding that legally, they
should privately submit their proposal to the Plaintiff for consideration. Anything other
6. NEW EVIDENCE Pursuant to Mass. R. Civ. P. 60(b)(2) – has now surfaced with the
sworn testimony of Wells Fargo CEO – Tim Sloan, before the House Financial Services
Committee on March 12, 2019. In his testimony and after an admission to mortgage-
related abuses, Mr. Sloan states that his company has reached out to every customer in an
effort to resolve these issues. This testimony clearly contradicts what has been evidenced
in this (and all related State/Federal) litigation over the past eight (8) years. In a statement
released Thursday, March 14, 2019 by the House Financial Services Committee,
“It was very clear from Mr. Sloan’s testimony that Wells Fargo has failed to clean up
its act.” Remarkably, following his testimony, the OCC publicly rebuked Wells Fargo,
While jurisdiction remains an issue here, this new evidenced testimony shows cause to
again amend all related State/Federal complaints, including: (1) Middlesex Superior
Court Docket No. 1181-CV-04499; (2) Northeast Housing Court Docket No.
11H77SP3032; (3) MA Land Court Docket No. 18-MISC000144; and (4) SCOTUS
For the reasons described within, this Court should first address jurisdiction issues before
addressing ANYTHING ELSE related to this docket. The Court should also allow the Plaintiff
to AMEND his related complaint - Middlesex Superior Court Docket No. 1181-CV-04499,
based (at minimum) on the referenced new evidence from Defendant – Wells Fargo, and the
Since this case is related to the referenced Federal litigation now before The United States
Supreme Court and includes matters perceived to impact National Security, the following
government offices/agencies/committees will necessarily receive copies of this filing (via email,
b. US Secret Service;
f. FBI;
Copies of this email will also be made available to the Public and to media outlets nationwide
out of continued concerns for my personal safety and security. If your Honor has ANY
questions regarding any portion of this Response, or requires additional information, the
Respectfully submitted,
Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
March 15, 2019
CERTIFICATE OF SERVICE
I hereby certify that on March 15, 2019, I filed the foregoing REPLY with the Clerk of the
Court and counsel for the Defendants (listed below) via US Mail:
David E. Fialkow
K&L Gates, LLP
State Street Financial Center
One Lincoln Street
Boston, MA 02111
david.fialkow@klgates.com
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com