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Mohan Harihar <moharihar@gmail.

com>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Tue, Jun 25, 2019 at 9:41 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa.watson3@usdoj.gov,
andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov, christina.sterling@usdoj.gov, ma-igo-general-
mail@state.ma.us, igo-fightfraud@state.ma.us, "Constituent.services@state.ma.us"
<constituent.services@state.ma.us>, 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,
chairmanoffice@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov,
CommissionerStein@sec.gov, maura.healey@state.ma.us, david fialkow <david.fialkow@klgates.com>,
"Jeffrey B. Loeb" <JLoeb@richmaylaw.com>

Clerk Deguglielmo,

The 9A package for the following nine (9) motions was timely filed via US Priority mail yesterday -
Monday, June 24, 2019, and is expected to be delivered to the Court and to counsel today:

1. Plaintiff Motion to Clarify Defendants’ Intentions to Enter into a Mutual Agreement


Discussion;
2. Plaintiff Motion for Hearing to Acknowledge and Address Related Criminal Complaints
of Record;
3. Plaintiff Motion to Clarify Jurisdiction and Improper Transfer from MA Land Court;
4. Plaintiff Motion for Injunction and to Address the Imbalance of Hardships;
5. Plaintiff DEMAND to Enforce Evidenced Claims of Judicial Treason under ARTICLE III,
Section 3;
6. Plaintiff Motion to Address Incremental, Unresolved Issues;
7. Plaintiff Motion to Identify Additional Parties as Defendants;
8. Plaintiff Motion to Acknowledge New Evidence, pursuant to Mass. R. Civ. P. 60(b)(2)
and (3); and
9. Plaintiff Motion for Clarification to Assess Professional Penalties

However, please be advised, since June 10, 2019, there has been multiple attempts made - by both
myself and opposing counsel to communicate with the Clerk's Office to address a timeline extension
request for filing these motions and re-scheduling the summary judgement hearing, currently
scheduled for Thursday, July 11, 2019 (See referenced email communications below). It would
appear - at least on its surface, that these efforts have been completely ignored, suggesting that
patterns of corrupt conduct continue still in this Superior Court. Based on the eight (8)-year
history of this litigation, the severity of evidenced claims involving officers of the Court suggest here
a continued effort to brush aside motions, ultimately reaching a corrupt and pre-determined outcome.
Any objective observer who has thoroughly reviewed this 8-year history would agree. Since
this matter is related to ongoing Federal litigation and evidenced claims against the Commonwealth, it
becomes necessary to copy multiple government offices/agencies on this communication (See
above). Copies will also be made available to the Public and to media sources nationwide, for
documentation purposes and out of continued concerns for my personal safety and security. Thank
you for your attention to 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>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Fri, Jun 21, 2019 at 1:25 PM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa.watson3@usdoj.gov,
andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov, christina.sterling@usdoj.gov, ma-igo-general-
mail@state.ma.us, igo-fightfraud@state.ma.us, "Constituent.services@state.ma.us"
<constituent.services@state.ma.us>, 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,
chairmanoffice@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov,
CommissionerStein@sec.gov, maura.healey@state.ma.us, david fialkow <david.fialkow@klgates.com>,
"Jeffrey B. Loeb" <JLoeb@richmaylaw.com>

Clerk Deguglielmo,

I am concerned that there has been no email response or update from the Superior Court regarding
requests for a timeline extension to file the 9A package and re-scheduling the summary judgement
hearing (See previous email communications attached below). It is unclear as to what is causing the
delay. I respectfully request an update by 5pm today, Friday, June 21, 2019, as the timeline for
filing the 9A package is this coming Monday, June 24, 2019. Thank you for your attention to 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>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Thu, Jun 20, 2019 at 10:41 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: david fialkow <david.fialkow@klgates.com>, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>

Clerk Deguglielmo,

After reviewing the responses from Attorneys - Fialkow and Loeb, I am compelled to re-state and
clarify the following:

1. While this email communication with the Court may not generally be considered the norm,
there are new developments and fast-approaching timelines which warrant email
communication. Also, the Court is well aware of the severity of issues impacting not only this
complaint but related litigation in the Federal Court. Respectfully, these issues include
evidenced claims against judicial officers in this Middlesex Superior (and other MA and
Federal) Court(s).
2. The Plaintiff re-states that he requests additional time for filing his Motions with the Court, as
the Defendants have (just in the past week) expressed interest in having a confidential,
preliminary discussion in an effort to reach a mutual agreement. This new development (while
it is no indication that an agreement will be made) certainly impacts the filing of the Plaintiff's
9A package, particularly the content of the REPLY to the Defendants' Opposition.
Based on the Plaintiff's interpretation of the Rule, the complete 9A package is to be filed by
this coming Monday, June 24, 2019. The Plaintiff respectfully requests that the timeline for
filing the 9A EITHER be temporarily suspended OR that an appropriate EXTENSION OF
TIME is granted - until it is determined whether or not a mutual agreement is an available
option.
3. To clarify, the Plaintiff's Motions delivered by email and US MAIL on June 4, 2019 to counsel
also included an electronic copy to the Court, for the purpose of informing the Court of the
severity of unresolved issues which is certainly expected to impact the scheduled Summary
Judgement hearing - only five (5) weeks away. The scheduled Summary Judgement hearing
is now three (3) weeks away. Whether discussion between parties ultimately leads to a
mutual agreement OR it becomes necessary to file the NINE (9) motions with the Court, it
should be clear that the current date for the summary judgement hearing is inappropriate and
should be re-scheduled to a date/time TBD, if necessary.
4. Finally, the Plaintiff has respectfully made clear - as a matter of record, his evidenced
concerns involving judicial officers associated with this litigation - in this Superior (and other
MA Courts) as well as in the related Federal litigation. If parties are unsuccessful in reaching
a mutual agreement here, there is clear concern moving forward as to whether these judicial
concerns will continue. It is my sincere hope that parties will be able to reach a fair and
mutual agreement for the benefit of all parties and in the interest of judicial economy.

Thank you for your assistance and understanding 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>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Jeffrey B. Loeb <JLoeb@richmaylaw.com> Thu, Jun 20, 2019 at 9:02 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: david fialkow <david.fialkow@klgates.com>, Mohan Harihar <moharihar@gmail.com>

Clerk Deguglielmo,

While I do not believe that this type of communication with the Court is generally
appropriate I feel compelled to respond to Mr. Harihar’s email to you.

With respect to the motions that have not yet been filed with the Court Mr. Harihar sent
his email to the Court before asking defense counsel for additional time. As we would with
counsel, defense counsel would have agreed to a reasonable amount of additional time for him
to reply to our oppositions and to file the motions with the Court.

With the respect the motions that are currently scheduled to be heard on July 11,
defense counsel cannot agree to any continuance of that hearing.
Thank you and my apologies for communicating with you in this fashion.

Jeffrey B. Loeb
Rich May, P.C.
jloeb@richmaylaw.com
Direct: 617-556-3871

Mohan Harihar <moharihar@gmail.com>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Wed, Jun 19, 2019 at 12:32 PM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>
Cc: david fialkow <david.fialkow@klgates.com>, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>

Clerk Deguglielmo,

This is a second follow-up to the email communication, initially delivered to your attention on June 10,
2019. Please be advised, there is a recent development that warrants:

1. A suspension of timeline for submitting the referenced 9A package; and


2. Re-scheduling the Summary Judgement hearing to a day/time TBD, if necessary.

Both Counsel for the Defendants have expressed interest in having a confidential, preliminary
discussion in an effort to reach a mutual agreement. This new development (while it is no indication
that an agreement will be made) certainly impacts the filing of the Plaintiff's 9A package, particularly
the content of the REPLY to the Defendants' Opposition. Based on the Plaintiff's interpretation of
Rule, the complete 9A package is to be filed by this coming Monday, June 24, 2019. The Plaintiff
respectfully requests that the timeline for filing the 9A be temporarily suspended until it is determined
whether or not a mutual agreement will be made. Similarly, for reasons stated in the June 10, 2019
email (attached below), even if it becomes necessary to file the 9A package, the number of
unresolved issues, new evidence, subpoenaed testimony, etc... warrants re-scheduling the summary
judgement hearing (currently scheduled for Thursday, July 11, 2019) to a date/time TBD, if it
becomes necessary. Please address these matters with Judge Hogan. 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>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Wed, Jun 12, 2019 at 11:11 AM
To: "Fialkow, David E." <David.Fialkow@klgates.com>
Cc: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>,
theresa.watson3@usdoj.gov, andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
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, chairmanoffice@sec.gov,
CommissionerStein@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov, ma-igo-
general-mail@state.ma.us, igo-fightfraud@state.ma.us, maura.healey@state.ma.us

Mr. Fialkow,

You are respectfully reminded of previous email communications to the Court including re-scheduling
requests made by you personally, due to conflicts with your schedule. Furthermore, the severity of
evidenced - civil, criminal and professional claims involving both Defendants as well as judicial
officers (including you personally) warrants incremental documentation for the record.
Respectfully, if it remains your intention - and the intention of your clients, to disregard these
communications, it will be noted for the record. I look forward to receiving timely responses to all
motions as required by the rules.

Please be advised, you are aware that as a matter of record, the severity evidenced claims against
Defendants as well as judicial officers are perceived to impact matters of National/Homeland Security.
Therefore, it becomes necessary to forward copies of these documents to: (1) the United States
Secret Service; (2) POTUS; (3) Congress; (4) the DOJ; (5) Governor Charlie Baker (R-MA) and a
list of additional government offices/agencies/committees listed within the referenced motions. Copies
will also 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 attention to this very serious matter.

Sincerely,

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

Mohan Harihar <moharihar@gmail.com>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Fialkow, David E. <David.Fialkow@klgates.com> Wed, Jun 12, 2019 at 10:48 AM
To: Mohan Harihar <moharihar@gmail.com>, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>
Cc: "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>

Dear Clerk Deguglielmo:

We are not generally in the practice of communicating with the Court by email, but we would be
remiss if we did not respond under the circumstances. We oppose the request to reschedule
the summary judgment hearing as that motion has been scheduled and pending for a while. We
will respond to all motions as required under the Rules. We do not intend to have further
communications outside of written motions to the Court. We apologize if this has been any
inconvenience to the Court.
Thank you,

David E. Fialkow

Partner
K&L Gates LLP
State Street Financial Center
One Lincoln Street
Boston, MA 02111
Phone: (617) 261-3126
Fax: (617) 261-3175
david.fialkow@klgates.com
www.klgates.com

Mohan Harihar <moharihar@gmail.com>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Wed, Jun 12, 2019 at 10:00 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa.watson3@usdoj.gov,
andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov, christina.sterling@usdoj.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
Nora_Keefe@warren.senate.gov, sydney_levin-epstein@markey.senate.gov, chairmanoffice@sec.gov,
CommissionerStein@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov,
lori.trahan@mail.house.gov, ayanna.pressley@mail.house.gov, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, maura.healey@state.ma.us

Dear Clerk Deguglielmo and Counsel,

I am respectfully requesting a documented response to the email sent to your attention two (2) days
ago on June 10, 2019 (see attached below), addressing forthcoming 9A motions and re-scheduling
the hearing on Summary Judgement. Thank you for your attention to this very serious matter.
Sincerely,

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

Mohan Harihar <moharihar@gmail.com>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Mon, Jun 10, 2019 at 9:05 AM
To: Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa.watson3@usdoj.gov,
andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov, christina.sterling@usdoj.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
Nora_Keefe@warren.senate.gov, sydney_levin-epstein@markey.senate.gov, chairmanoffice@sec.gov,
CommissionerStein@sec.gov, CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov,
lori.trahan@mail.house.gov, ayanna.pressley@mail.house.gov, ma-igo-general-mail@state.ma.us, igo-
fightfraud@state.ma.us, maura.healey@state.ma.us

Dear Clerk Deguglielmo and Counsel,

The Court is aware of multiple Plaintiff motions being prepared for filing under Superior Court Rule
9A (See email delivered June 4, 2019, attached below). Considering:

1. Whether Defendants are interested in having a Mutual Agreement Discussion;


2. Timelines for receiving Defendant Opposition (if any);
3. Timeline for filing Plaintiff Replies (if necessary);
4. The amount of unresolved issues, including New Evidence; and
5. The requested subpoenaed testimony from State/Federal Prosecutors regarding
evidenced criminal complaints related to this litigation,

the current date set for the Summary Judgement hearing (currently scheduled for July 11, 2019) is
not appropriate and should be re-scheduled to a future date TBD, if necessary. Please bring these
conflicts to the attention of Judge Hogan. Thank you.
Please be advised, you are ALL aware that as a matter of record, the severity evidenced claims
against Defendants as well as judicial officers are perceived to impact matters of National/Homeland
Security. Therefore, it becomes necessary to forward copies of these documents to: (1) the United
States Secret Service; (2) POTUS; (3) Congress; (4) the DOJ; (5) Governor Charlie Baker (R-
MA) and a list of additional government offices/agencies/committees listed within the attached.
Copies will also 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 attention to 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>

RE: Case No. 1981CV00050, HARIHAR v. US BANK, et al, Rule 9A


Motions
Mohan Harihar <moharihar@gmail.com> Tue, Jun 4, 2019 at 3:50 PM
To: "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa.watson3@usdoj.gov,
andrew.lelling@usdoj.gov, mary.murrane@usdoj.gov, christina.sterling@usdoj.gov,
"Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
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, chairmanoffice@sec.gov,
CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov, CommissionerStein@sec.gov, ma-igo-
general-mail@state.ma.us, igo-fightfraud@state.ma.us, maura.healey@state.ma.us,
jesse.boodoo@state.ma.us, kevin.polansky@nelsonmullins.com, "Murphy, Matthew T."
<mmurphy@casneredwards.com>, kmchugh@harmonlaw.com, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>
Delivered VIA EMAIL and US MAIL

Attorneys Loeb & Fialkow,

Enclosed, please find the Plaintiff’s following documents for filing in accordance with
Superior Court Rule 9A in the above referenced docket:

1. Plaintiff Motion to Clarify Defendants’ Intentions to Enter into a Mutual


Agreement Discussion;

2. Plaintiff Motion for Hearing to Acknowledge and Address Related Criminal


Complaints of Record;

3. Plaintiff Motion to Clarify Jurisdiction and Improper Transfer from MA Land


Court;

4. Plaintiff Motion for Injunction and to Address the Imbalance of Hardships;

5. Plaintiff DEMAND to Enforce Evidenced Claims of Judicial Treason under


ARTICLE III, Section 3;

6. Plaintiff Motion to Address Incremental, Unresolved Issues;

7. Plaintiff Motion to Identify Additional Parties as Defendants;

8. Plaintiff Motion to Acknowledge New Evidence, pursuant to Mass. R. Civ.


P. 60(b)(2) and (3);

9. Plaintiff Motion for Clarification to Assess Professional Penalties;


Please serve your opposition, if any, within the time provided by the Rules –
beginning with the Defendant’s intentions to enter into a mutual agreement
discussion.

Please be advised, you are both aware that as a matter of record, the severity
evidenced claims against Defendants as well as judicial officers are perceived to
impact matters of National/Homeland Security. Therefore, it becomes necessary to
forward copies of these documents to: (1) the United States Secret Service; (2)
POTUS; (3) Congress; (4) the DOJ; (5) Governor Charlie Baker (R-MA) and a list
of additional government offices/agencies/committees listed within the attached.
Copies will also 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
attention to this very serious matter.

Sincerely,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
9 attachments
Plaintiff Motion to Clarify Mutual Agreement Discussion.pdf
131K
Plaintiff Motion to Address Criminal Claims.pdf
423K
Plaintiff Motion to Clarify Jurisdiction.pdf
183K
Plaintiff Motion for Injunction and Imbalance of Hardships.pdf
181K
Plaintiff Demand to Enforce Article III.pdf
186K
Plaintiff Motion to Address Incremental Claims.pdf
190K
Plaintiff Motion to Add Defendants.pdf
426K
Plaintiff Motion to Address New Evidence.pdf
379K
Plaintiff Motion re Professional Penalties.pdf
179K