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 NOTICE RE: 01/20/2020 EMAIL COMMUNICATION DELIVERED TO

MA ATTORNEY GENERAL – MAURA HEALEY, INCLUDING EFFORT TO REACH

A (LEGAL) MUTUAL AGREEMENT WITH THE COMMONWEALTH

AND ALL DEFENDANTS

The Plaintiff – Mohan A. Harihar, a pro se litigant with no legal experience, respectfully files

this NOTICE to inform the Court that on Monday, January 20, 2019, an email communication

was delivered to the direct attention of Massachusetts Attorney General – Maura Healey, to

address the following:

1. The 01/12/2020 formal Civil Rights Complaint filed with the MA AGO,1 against

multiple judicial (and other court) officers including RECUSED US District Court

1
MA AGO – Massachusetts Attorney General’s Office

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 Judge – Hon. Allison Dale Burroughs and DISQUALIFIED Middlesex Superior

Court Judge – Hon. Janice W. Howe. The Civil Rights Complaint addresses a lengthy

list of criminal violations and judicial abuses of power that have been evidenced by the

record in this complaint, as well as in the related MA State and Federal Litigation;2

2. There are legal ramifications that will necessarily follow, should the Commonwealth fail

(or refuse) to address and ultimately bring criminal indictments for the evidenced

violations involving NOT ONLY the named Defendants, but also referenced judicial

(and other court) officers. Should this occur, the Plaintiff will at minimum show cause to

amend his complaint, expanding upon existing violations under 18 U.S. Code § 242 -

Deprivation of rights under color of law, against the DEFENDANT –

Commonwealth of Massachusetts, in the above-referenced Federal litigation (Ref.

HARIHAR v US BANK et al, Docket No. 15-cv-11880);

3. The Plaintiff also states that he has consistently, throughout the 9-year history of this

litigation, extended in GOOD FAITH the opportunity to reach a legal agreement with

ALL Defendant parties, including the Defendant - Commonwealth of Massachusetts.

The Plaintiff’s intentions have NEVER been to call out evidenced corruption and

systemic judicial abuses of power. HOWEVER, IF: (1) Defendants choose NOT to

accept my good faith offer to reach a legal agreement; and (2) the law is NOT going to

be enforced, the Plaintiff is compelled to continue seeking accountability for ALL

evidenced civil/criminal/ethics violations, regardless of timeline;

2
The related Federal litigation includes: (1) HARIHAR v US BANK et al, Docket No. 15-cv-11880; (2)
HARIHAR v THE UNITED STATES, Docket No. 17-cv-11109; and (3) HARIHAR v HOWARD et al, Docket
No. 18-cv-11134.

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 4. The Plaintiff is aware that the severity of legal issues related to this docket has recently

been brought to the attention of Chief Justice - Honorable Judith Fabricant. Before it

becomes necessary to move forward with next legal steps, the Plaintiff informs the Court

that he has again extended to Attorney General Healey (and ALL named Defendants), an

opportunity to have a mutual agreement discussion and has respectfully requested a

response by 5pm EST, Friday, January24, 2020 (See Exhibit 1, to view the 1/20/2020

email to Attorney General Healey in its entirety). Based on the Plaintiff’s interpretation

of the law - should a legal agreement ultimately be made with the Commonwealth and/or

other named Defendants, it MAY not be necessary to continue addressing the referenced

claims against judicial (and other court) officers.

Finally, the Plaintiff has evidenced his concerns regarding the filing of his documents with this

Court – including what is believed to be INSTRUCTION from Judge Howe to Clerk Arthur

Degugliemo NOT to docket certain documents filed by the Plaintiff (some of which STILL

have yet to be entered upon the docket). Therefore, it has become necessary to deliver all filings

to the direct attention of Michael A. Sullivan – Clerk of the Courts (Middlesex County). Due

to the severity of evidenced criminal violations involving not only the Defendants, but also

referenced judicial (and other court) officers - Federal/State Prosecutors, Governor Baker’s

Office and other government offices/agencies will receive copies of this Notice. The Public

and media outlets nationwide will also receive copies for documentation purposes and out of

continued concerns for my personal safety and security. If the Court has ANY questions

regarding any portion of this Notice, the Plaintiff is happy to provide upon request. The Plaintiff

is grateful for the Court’s attention to this very serious and sensitive legal matter.

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 Respectfully submitted,

Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
January 21, 2020 Mo.harihar@gmail.com

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Exhibit 1

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 Mohan Harihar <moharihar@gmail.com>

Letter Received from MA AGO - CIVIL RIGHTS DIVISION, Dated

01/13/2020
Mon, Jan 20, 2020 at
Mohan Harihar <moharihar@gmail.com>
1:50 PM
To: maura.healey@state.ma.us
Cc: andrew lelling <andrew.lelling@usdoj.gov>, "Cc:" <dan_jackson@ao.uscourts.gov>, Susan Goldberg
<susan_goldberg@ca1.uscourts.gov>, NewYorkComplaints Dojoig
<dojoig.newyorkcomplaints@usdoj.gov>, theresa watson3 <theresa.watson3@usdoj.gov>, governor
schedule <governor.schedule@massmail.state.ma.us>, mary murrane <mary.murrane@usdoj.gov>,
christina sterling <christina.sterling@usdoj.gov>, "Constituent.services@state.ma.us"
<Constituent.services@state.ma.us>, christine_bono@mad.uscourts.gov,
taylor_halley@mad.uscourts.gov, elizabeth warren <elizabeth_warren@warren.senate.gov>, sydney
levin-epstein <sydney_levin-epstein@markey.senate.gov>, ayanna pressley
<ayanna.pressley@mail.house.gov>, lori trahan <lori.trahan@mail.house.gov>, ma-igo-general-
mail@state.ma.us, igo-fightfraud@state.ma.us, jesse.boodoo@state.ma.us, Michael Anthony Sullivan
<michael.sullivan@jud.state.ma.us>, Matthew Day <matthew.day@jud.state.ma.us>,
james.mccormack@jud.state.ma.us, "C. Andrew Johnson" <andrew.johnson@jud.state.ma.us>,
Karen_Folan@mad.uscourts.gov, Tracy_McLaughlin@mad.uscourts.gov, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, chairmanoffice@sec.gov, CommissionerStein@sec.gov,
CommissionerJackson@sec.gov, CommissionerPeirce@sec.gov, James
<james.segerdahl@klgates.com>, "Michael S." <michael.caccese@klgates.com>, Mark
<mark.haddad@klgates.com>, "Beth H." <beth.weisberg@klgates.com>, david fialkow
<david.fialkow@klgates.com>, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, Kevin Polansky
<kevin.polansky@nelsonmullins.com>, "Matthew T." <mmurphy@casneredwards.com>,
kmchugh@harmonlaw.com

Dear Attorney General Healey,

After filing a Civil Rights complaint with your office on January 12, 2020 (Scroll down to view), I
want to thank you for the prompt response from the Civil Rights Division and letter dated the
following day - January 13, 2020 (See attached pictures, below). After reviewing the content of the
letter however, there are now a number of serious, incremental issues involving your office and the
Commonwealth (as a Defendant in the Federal Lawsuit - HARIHAR v US BANK et al, Docket No.
15-cv-11880) which must be clarified for the record.

First, please clarify for the record - the name and title of the individual officer within the MA AGO -
Civil Rights Division who is responsible for sending the letter, as the signature is not legible and there
is no printed name or title that appears below the signature.

Second, the content of the letter includes the following statement:

"...The Office of the Attorney General is required by statute to provide legal representation for
other state agencies. As a result, I regret to inform you that we are not able to assist you with
your complaint against Hon. Allison Dale Burroughs; Hon. Janice W. Howe, et al. However,
your complaint will remain a public record with the Civil Rights Division..."

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As a matter of record, I have brought to your direct attention (as well as to the direct attention of US
Attorney (MA) - Andrew Lelling), EVIDENCED CRIMINAL VIOLATIONS (FEDERAL AND MA
STATE) involving NOT ONLY the Defendants in the above-referenced litigation (including all related
litigation), but also JUDICIAL OFFICERS who rights to Judicial Immunity are automatically
considered WAIVED. As evidenced by the record, the severity of these criminal violations - as stated
in the filed Civil Rights complaint include (but are not limited to):

Attorney General Healey - Is the MA AGO stating that they have NO RESPONSIBILITY for
addressing these evidenced crimes of record? If so, please articulate further as to how your office
has arrived at their conclusion(s). Respectfully, you are already aware that in the referenced
Federal litigation, the Commonwealth of Massachusetts is a Defendant (in part) for the evidenced
failures (or refusal) by your Office to bring indictments for criminal violations evidenced by co-
Defendants (including Bank Defendants - WELLS FARGO and US BANK) and other judicial officers
in MA State Courts. Please be advised, based on my interpretation of the law, if your office
chooses NOT to initiate corrective action here - and instead maintains its current position, it
will (at minimum) show cause to amend the existing federal complaint against the
Commonwealth. This (at minimum) includes an expansion of COLOR OF LAW violations
against not only judicial officers but also against individual officers within the MA AGO. Any
Sovereign/Judicial Immunity or litigation privilege is considered waived.

Finally, it becomes necessary to re-state that I have consistently, throughout the 9-year history of
this litigation, extended in GOOD FAITH the opportunity to reach a legal agreement with ALL
Defendant parties, including the Defendant - Commonwealth of Massachusetts. My intentions have
NEVER been to call out evidenced corruption and systemic judicial abuses of power. HOWEVER, if:
(1) Defendants choose NOT to accept my good faith offer to reach a legal agreement; and (2) the law
is NOT going to be enforced, I am compelled to continue seeking accountability for ALL evidenced
civil/criminal/ethics violations, regardless of timeline.

Attorney General Healey - with this email I will again in good faith and in full public view, respectfully
offer the Commonwealth and ALL Defendants associated with the referenced Federal and related
MA State litigation, the opportunity to have a mutual agreement discussion, PRIOR to moving forward
with this legal matter. Please provide your response no later than 5pm this Friday, January 24,
2020. Please be advised, due to the severity of evidenced (civil/criminal/ethics) violations involving
not only the Defendants, but also Judicial (and other court) officers: (1) the Executive Office of the
President (EOP); (2) DOJ/US Attorney's Office (MA); (3) members of Congress; (4) Governor
Baker's Office; (5) the Administrative Office of US Courts and other government offices/agencies,
will necessarily be copied on this email communication. The Public and Media sources nationwide will
also receive copies of this email communication for documentation purposes and out of continued

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concerns for my personal safety and security. Thank you for your attention to this very serious and
sensitive legal matter.

Respectfully,

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

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---------- Forwarded message ---------
From: Mohan Harihar <moharihar@gmail.com>
Date: Sun, Jan 12, 2020 at 1:54 PM
Subject: MOHAN A. HARIHAR - CIVIL RIGHTS Complaint Submitted to the Massachusetts Attorney
General’s Office
To: <maura.healey@state.ma.us>, andrew lelling <andrew.lelling@usdoj.gov>
Cc: <dan_jackson@ao.uscourts.gov>, Susan Goldberg <susan_goldberg@ca1.uscourts.gov>,
NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, theresa watson3
<theresa.watson3@usdoj.gov>, governor schedule <governor.schedule@massmail.state.ma.us>,
mary murrane <mary.murrane@usdoj.gov>, christina sterling <christina.sterling@usdoj.gov>,
Constituent.services@state.ma.us <constituent.services@massmail.state.ma.us>,
<christine_bono@mad.uscourts.gov>, <taylor_halley@mad.uscourts.gov>, elizabeth warren
<elizabeth_warren@warren.senate.gov>, sydney levin-epstein <sydney_levin-
epstein@markey.senate.gov>, ayanna pressley <ayanna.pressley@mail.house.gov>, lori trahan
<lori.trahan@mail.house.gov>, <ma-igo-general-mail@state.ma.us>, <igo-fightfraud@state.ma.us>,
<maura.healey@state.ma.us>, <jesse.boodoo@state.ma.us>, Michael Anthony Sullivan
<michael.sullivan@jud.state.ma.us>, Matthew Day <matthew.day@jud.state.ma.us>,
<james.mccormack@jud.state.ma.us>, C. Andrew Johnson <andrew.johnson@jud.state.ma.us>,
<Karen_Folan@mad.uscourts.gov>, <Tracy_McLaughlin@mad.uscourts.gov>, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, <chairmanoffice@sec.gov>,
<CommissionerStein@sec.gov>, <CommissionerJackson@sec.gov>,
<CommissionerPeirce@sec.gov>, James <james.segerdahl@klgates.com>, Michael S.
<michael.caccese@klgates.com>, Mark <mark.haddad@klgates.com>, Beth H.
<beth.weisberg@klgates.com>, david fialkow <david.fialkow@klgates.com>, Jeffrey B. Loeb
<JLoeb@richmaylaw.com>, Kevin Polansky <kevin.polansky@nelsonmullins.com>, Matthew T.
<mmurphy@casneredwards.com>, <kmchugh@harmonlaw.com>

Dear Attorney General Healey and US Attorney Lelling,

A formal, Civil Rights Complaint was filed with the MA AGO today - Sunday, January 12, 2020,
against RECUSED US District Court Judge - Hon. Allison Dale Burroughs, Disqualified
Middlesex Superior Court Judge - Hon. Janice W. Howe and other judicial/court officers (See
Attached, BELOW). Respectfully, you are both aware that in the referenced litigation, I have extended
in GOOD FAITH (while under NO obligation to do so), the opportunity to have settlement agreement
discussions with ALL Defendant parties, including the Defendant - Commonwealth of
Massachusetts (Ref. HARIHAR v US BANK et al, Docket No. 15-cv-11880) and separately, the
Defendant - THE UNITED STATES (Ref. HARIHAR v THE UNITED STATES, Docket No. 17-cv-
11109). It remains my sincere hope that collectively through mediation, we are able to resolve the
substantial list of legal issues which remain in the referenced Federal (and MA State) litigation.

Based on the Plaintiff's interpretation of the law, each incremental violation or failure to initiate
corrective action in this legal matter - whether it is committed by a judicial officer or ANY party who
acts on behalf of the Commonwealth or The United States shows cause for the Plaintiff to amend the
Federal (and/or State) complaint(s) referenced above.

Please be advised, due to the severity of evidenced (civil/criminal/ethics) violations involving not only
the Defendants, but also Judicial (and other court) officers: (1) the Executive Office of the President
(EOP); (2) DOJ; (3) members of Congress; (4) Governor Baker's Office; (5) the Administrative
Office of US Courts and other government offices/agencies (referenced above), will necessarily be
copied on this email communication. The Public and Media sources nationwide will also receive

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copies of this Civil Rights complaint out of continued concerns for my personal safety and security.
Thank you for your attention to this very serious and sensitive legal matter.

Respectfully,

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

---------- Forwarded message ---------

From: <ago-complaint-submission@state.ma.us>
Date: Sun, Jan 12, 2020 at 12:46 PM
Subject: Complaint submitted to the Massachusetts Attorney General’s Office
To: <mo.harihar@gmail.com>

Thank you for contacting the Civil Rights Division. We review each complaint submitted to us to
determine the best course of action. Although we will attempt to respond to your complaint as quickly
as possible, there may be a wait depending on the number of complaints that we receive. In addition,
depending on the nature of your complaint, we may request copies of documents and other relevant
information – but please do not send us additional information unless we ask you to do so.

Please note that we sometimes receive complaints that raise issues that generally are not handled by
our office or are better handled by another agency or organization. If that is the case, we will
recommend other resources.

In the meantime, more information about our division can be found at:
http://www.mass.gov/ago/bureaus/public-protection-and-advocacy/the-civil-rights-division/

AGO CONSUMER COMPLAINT - - PDF.pdf

232K

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