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Mohan Harihar <moharihar@gmail.

com>

19-50 Harihar v U.S.Bank, N.A. et al


Mohan Harihar <moharihar@gmail.com> Tue, Apr 23, 2019 at 4:28 PM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: "Constituent.services@state.ma.us" <constituent.services@state.ma.us>, NewYorkComplaints
Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov,
christina.sterling@usdoj.gov, elizabeth_warren@warren.senate.gov,
Nairoby_Gabriel@warren.senate.gov, Nora_Keefe@warren.senate.gov, sydney_levin-
epstein@markey.senate.gov, lori.trahan@mail.house.gov, ayanna.pressley@mail.house.gov,
maura.healey@state.ma.us, jesse.boodoo@state.ma.us, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, david fialkow
<david.fialkow@klgates.com>

Mr. Deguglielmo,

I want to make sure I'm understanding you correctly, as I am a pro se litigant with no legal
experience. It appears (at least on its surface) that Middlesex Superior Court Judge - Maureen
Hogan is REFUSING to clarify her jurisdiction over this case. It also appears that ALL FOUR (4)
of my prior requests for clarification, prior to proceeding further are being blatantly ignored without
cause. Since you are a Clerk of the Court, I am respectfully asking you now to clarify this for the
record. If Judge Hogan refuses to clarify her jurisdiction over this docket - before proceeding
further, a demand will be filed for her recusal. For reasons stated in my previous email it becomes
necessary to copy: (1) Governor Charlie Baker (R-MA); (2) Legislative leaders in the Commonwealth;
and (3) State/Federal Prosecutors on all communications. Copies of this email communication will
additionally be made available to the Public and to media sources nationwide - out of continued
concerns for my personal safety and security. Thank you for your assistance with this very serious
matter.

Respectfully,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Mohan Harihar <moharihar@gmail.com>

19-50 Harihar v U.S.Bank, N.A. et al


Arthur T Deguglielmo
Tue, Apr 23, 2019 at 3:45 PM
<arthur.deguglielmo@jud.state.ma.us>
To: Mohan Harihar <moharihar@gmail.com>

If a Tuesday is a day you suggest this case be held then the next available would be
May 14th at 2:00 p.m.

Mohan Harihar
<moharihar@gmail.com>

19-50 Harihar v U.S.Bank, N.A. et al


Mohan Harihar <moharihar@gmail.com> Tue, Apr 23, 2019 at 11:24 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: "Constituent.services@state.ma.us" <constituent.services@state.ma.us>, NewYorkComplaints
Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov,
christina.sterling@usdoj.gov, elizabeth_warren@warren.senate.gov,
Nairoby_Gabriel@warren.senate.gov, Nora_Keefe@warren.senate.gov, sydney_levin-
epstein@markey.senate.gov, lori.trahan@mail.house.gov, ayanna.pressley@mail.house.gov,
maura.healey@state.ma.us, jesse.boodoo@state.ma.us, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, david fialkow
<david.fialkow@klgates.com>

Mr. Deduglielmo,

There are two (2) issues with this newly scheduled date for the Rule 16 Conference:

1. I have a conflict with May 1st, as it conflicts with my work schedule. In general, Tuesday is
my day off - and IF jurisdiction for scheduling the conference is clarified for the record, my
first available Tuesday would be 05/07/2019;
2. As stated in my opposition, if Judge Hogan is refusing to clarify jurisdiction for the record
- PRIOR to moving forward, a formal judicial misconduct complaint will be brought and call for
the judge's recusal, as it will appear to exemplify an identical pattern of corrupt conduct
exemplified throughout the history of this litigation (State & Federal). There is NO reason to
justify why ANY Court needs to wait more than three (3) months to clarify its
jurisdiction for the record. Respectfully, if Judge Hogan has already provided this
explanation in the referenced Notice, please email for review as there does not appear to be
any clarification mentioned on the Court's website.

Please be advised, as a matter of record, this litigation involves evidenced systemic failures in the
Massachusetts State (and Federal) Judiciary (including evidenced criminal claims against judicial
officers). Therefore, it becomes necessary to copy: (1) Governor Baker; (2) Legislative leaders in the
Commonwealth; and (3) State/Federal Prosecutors on all communications. Thank you.

Respectfully,

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

Mohan Harihar <moharihar@gmail.com>

19-50 Harihar v U.S.Bank, N.A. et al


Tue, Apr 23, 2019 at 10:36
Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
AM
To: david.fialkow@klgates.com, Mo.harihar@gmail.com, apinto@richmaylaw.com

Counsel and Mr. Harihar,


Judge Hogan has allowed defendants' emergency motion to continue and
reschedule the Rule 16 conference. The new date will now be May 1, 2019 at 2:00
p.m. Notice will go out in today's mail.

--
Arthur DeGuglielmo
Assistant Clerk

Middlesex Superior Court


200 Trade Center
Woburn, MA. 01801
781-939-2757
COMMONWEALTH OF MASSACHUSETTS
THE TRIAL COURT
MIDDLESEX SUPERIOR COURT

) CIVIL ACTION NO. 1981-CV-00050


MOHAN A HARIHAR )
)
Plaintiff )
)
v. )
)
WELLS FARGO NA, et al. )
)
Defendants )
)
)

PLAINTIFF OPPOSITION TO CONTINUE RULE 16 CONFERENCE

After reviewing the Defendant’s Motion to Continue the Rule 16 Conference, the Plaintiff –

MOHAN A. HARIHAR files this opposition and respectfully reminds this Court of the

following:

1. The improper TRANSFER of this docket on January 8, 2019 to this Court from the

Land Court is considered issued without jurisdiction and therefore, VOID. The

Plaintiff has articulated for the record precisely how he arrived at this evidenced

conclusion.

2. As a matter of record, the Plaintiff has – for nearly three (3) months, respectfully

called for this Court to clarify its jurisdiction over this docket prior to ANY further

proceeding, including the scheduling of a Rule 16 Conference. Despite these repeated


requests,1 this Court has refused to do so – without any explanation; at minimum

revealing PATTERNS OF CORRUPT CONDUCT - IDENTICAL to that

evidenced throughout the eight-year history of this litigation. Therefore, the

Plaintiff (at minimum) shows cause to expand upon existing: (1) Due Process, (2)

Color of Law and (3) RICO violations against the Commonwealth of Massachusetts.

3. This Court is aware that judicial misconduct claims have been formally raised against

Judge Kenneth Fishman, including criminal claims of TREASON under

ARTICLE III, Section 3 for issuing an order here without Jurisdiction. Judge

Fishman is the EIGHTH (8th) Middlesex Superior Court Judge now considered

INFERIOR and without jurisdiction to rule further on this or any related litigation2

4. The Notice issued by this Court on April 4, 2019 appears to indicate Judge Fishman’s

recusal from this case, following the Plaintiff’s demand - pursuant to 28 U.S.C.

§455(a) and 28 U.S.C. § 144. The Hon. Maureen Hogan appears now as the

presiding judicial officer.

Please be advised, based on the Plaintiff’s interpretation of the law, any attempt by a presiding

judicial officer to continue these proceedings without FIRST clarifying jurisdiction – for the

record, will similarly be interpreted as an act of Treason. It is not acceptable, nor is it considered

proper for any Court to unnecessarily delay clarifying its jurisdiction – let alone for a period of

three (3) months. The Plaintiff respectfully restates that upon establishing jurisdiction, this Court

1
As a matter of record, the Plaintiff has respectfully requested the Middlesex Superior Court to clarify jurisdiction
on 01/22/19, 02/08/2019, 02/21/2019, 03/18/2019 and most recently on 04/02/19.
2
Aside from Judge Fishman, referenced Inferior Judges include: (1) Hon. Joshua Wall; (2) Hon. Christine M.
McEvoy; (3) Hon. Jane Haggerty; (4) Hon. Maynard M. Kirpalani; (5) Hon. Edward P. Leibensperger; (6)
Hon. Daniel M. Wrenn; and (7) Hon. William Sullivan.
should FIRST initiate CORRECTIVE action associated with erred judgments related to this

docket.

To be clear, the Plaintiff has now evidenced for the record (and in FULL PUBLIC VIEW) a

SYSTEMIC PATTERN OF CORRUPT CONDUCT at every level of the Massachusetts

State and Federal Judiciary, including the Supreme Court of The United States

(SCOTUS).3 Legal steps are now necessarily being taken to update Congress and the White

House under ARTICLES II and III. Any continued failure/refusal by this Court to clarify

jurisdiction or to initiate corrective action will add incrementally to evidenced claims against the

Commonwealth – showing cause to further amend the original complaint associated with

HARIHAR v US BANK, et al (Original Docket No. 15-cv-11880) and HARIHAR v CHIEF

JUDGE JEFFREY R. HOWARD, et al, Docket No. 18-cv-11134 (US District Court, Boston,

MA).

Please be advised, this case is related to referenced Federal litigation and includes matters

perceived to impact National Security. Therefore, the following government

offices/agencies/committees will necessarily receive copies of this filing (via email, US Mail

and/or social media):

1. POTUS (via www.whitehouse.gov);

2. US Secret Service;

3. Securities and Exchange Commission (SEC);

4. Office of the US Inspector General (OIG) - specifically, IG Michael Horowitz;

3
The Plaintiff references recent decisions associated with Certiorari Petition No 18-7752 – also considered issued
without jurisdiction.
5. Department of Justice (DOJ) - specifically, US Attorney General, William Barr;

6. FBI;

7. Administrative Office of US Courts - specifically, Director James C. Duff;

8. House/Senate Judiciary Committees;

9. Governor Charlie Baker (R-MA);

10. US Senator Elizabeth Warren (D-MA);

11. US Senator Ed Markey (D-MA);

12. US Congresswoman Lori Trahan (D-MA); and

13. US Congresswoman Ayanna Pressley (D-MA)

Copies of this email will also be made available to the Public and to media outlets nationwide for

documentation purposes and out of continued concerns for my personal safety and security.

If your Honor has ANY questions regarding ANY portion of this Opposition, or requires

additional information, the Plaintiff is happy to provide upon request. The Plaintiff is

grateful for this Court’s consideration.

Respectfully submitted,

Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
April 16, 2019 Mo.harihar@gmail.com
CERTIFICATE OF SERVICE

I hereby certify that on April 16, 2019, I filed the foregoing Opposition with the Clerk of the
Court and counsel for the Defendants (listed below) via US Mail and Email Communication:

Jeffrey B. Loeb, Esq.


Rich May, PC
176 Federal Street
Boston, MA 02110
617.556.3871
JLoeb@richmaylaw.com

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