SCROLL DOWN TO VIEW THE PLAINTIFF’S NOTICE

(FILED 02-20-2020) IN ITS ENTIRETY

1
 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: MA AGO’S CONTINUED FAILURES TO ADDRESS

EVIDENCED CRIMINAL VIOLATIONS OF RECORD SHOWS CAUSE TO EXPAND

COLOR OF LAW, DUE PROCESS, RICO CLAIMS, ETC., AGAINST THE

COMMONWEALTH OF MASSACHUSETTS

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

this NOTICE to inform the Court of continued “COMMUNICATION ISSUES” – as it relates

to addressing the evidenced CRIMINAL violations of record related to this complaint,

involving NOT ONLY the named Defendants, BUT ALSO judicial (and other court) officers.

The severity of these criminal violations has shown cause to communicate with MA Attorney

General Maura Healey directly (or copied) via email communication(s), to ensure that the MA

AGO is well-informed of the legal issues at hand and also the Plaintiff’s continued GOOD

2
FAITH efforts to reach a just (and timely) resolution. However, for reasons unknown, there

continues to be no response.

At the same time, this Court is also aware that the Commonwealth of Massachusetts is a

DEFENDANT in ongoing litigation proceeding in the Federal Court (Ref. HARIHAR v US

BANK et al, Docket No. 15-cv-11880). In this related Federal complaint, the Plaintiff has

brought evidenced claims spanning nearly a decade - involving ALL three (3) branches of

government here in the Commonwealth:

1. Systemic (and egregious) abuses of judicial power;

2. Non-feasance/malfeasance evidenced by legislative leaders; and

3. The MA AGO’s continued failure (or REFUSAL) to bring criminal indictments

against ALL named Defendants for the evidenced criminal violations of record.

With regard to this docket, the Plaintiff has evidenced the SAME systemic judicial abuses of

power involving the presiding Judge – Hon. Janice W. Howe and Clerk Arthur Deguglielmo,

making it necessary to alert Clerk of the Courts – Michael A. Sullivan. Clerk Sullivan has in

turn, brought this matter to the attention of Chief Justice – Hon. Judith Fabricant. The Plaintiff

has since included Clerk Sullivan (and multiple government offices/agencies) on multiple email

communications, to ensure that the Court is aware of the Plaintiff’s good faith efforts to timely

RESOLVE ALL existing legal issues and ultimately reach a settlement agreement with ALL

Defendant parties. The Plaintiff has also made it clear that based on his interpretation of the law -

IF parties were to be successful in reaching an agreement on the civil portions of the complaint,

it MAY no longer be necessary to continue the pursuit of evidenced criminal/ethics claims

3
involving NOT ONLY the named Defendants, BUT ALSO separately against judicial (and

other court) officers.

HOWEVER, recent efforts to communicate with counsel for the named Defendants have gone

unanswered. Similarly, the Plaintiff’s documented communications to both AG Maura Healey

and Asst. AG Jesse M. Boodoo (counsel for the Commonwealth in the referenced federal

litigation), continue to be blatantly ignored. As reference and for documentation purposes, the

Plaintiff has attached the most recent email communications delivered to the Defendants’

counsel (David E. Fialkow – K&L Gates, LLP and Jeffrey B. Loeb – RICH MAY, PC),

Clerk Michael Sullivan and MA Attorney General Maura Healey.1

Respectfully, the Plaintiff makes clear for the record that based on his interpretation of the law, if

Defendants DO NOT wish to resume a settlement discussion and ultimately reach a legal

agreement, there is clear expectation for this Court to initiate corrective action, beginning with:

(1) restoring jurisdiction; and (2) for the MA AGO to bring criminal indictments against

ALL named Defendants. HOWEVER – if Defendants parties do not wish to reach a legal

settlement agreement AND these legal issues are left uncorrected, the Plaintiff will show cause

to (again) amend his original Federal complaint, at minimum expanding upon evidenced RICO,

Color of Law/Due Process (and other) claims against the Commonwealth. Sovereign Immunity,

Judicial Immunity and any litigation privilege is considered WAIVED since Fraud on the

Court has already been evidenced against ALL Defendant parties and stands UNOPPOSED as

a matter of record under both Fed./Mass. R. Civ. P. 60(b)(3).

1
See Exhibit 1

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Please be advised, due to the severity of legal issues involved, the Plaintiff will file a signed

hardcopy of this Notice via US Priority Mail and will also deliver a copy electronically via email

communication to the direct attention of Clerk of the Courts – Michael A. Sullivan. The

Executive Office of the President (EOP)2, the Department of Justice (DOJ), Governor Baker’s

Office, members of Congress and other government offices/agencies (including Defendant's

counsel in the related Federal litigation) - will be copied on the email communication to ensure

that EVERYONE is aware of the Plaintiff's ongoing, good-faith efforts to timely (and legally)

reach a just resolution. The Public and Media sources nationwide will also receive copies of the

email communication for documentation purposes and out of continued concerns for the

Plaintiff's personal safety and security. Thank you for your attention to this very serious and

sensitive legal matter.

Respectfully submitted,

Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
February 18, 2020 Mo.harihar@gmail.com

2
The EOP will be notified via www.whitehouse.gov

5
Exhibit 1

6
 Mohan Harihar <moharihar@gmail.com>

Communication Issues w/ the MA AGO - Ref. HARIHAR v WELLS

FARGO, Docket No. 1981-cv-00050
Sat, Feb 15, 2020 at
Mohan Harihar <moharihar@gmail.com>
12:50 PM
To: maura.healey@state.ma.us
Cc: jesse.boodoo@state.ma.us, Michael Anthony Sullivan <michael.sullivan@jud.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@state.ma.us>, christine bono <christine_bono@mad.uscourts.gov>, taylor halley
<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, Matthew Day <matthew.day@jud.state.ma.us>, james
mccormack <james.mccormack@jud.state.ma.us>, "C. Andrew Johnson"
<andrew.johnson@jud.state.ma.us>, Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>,
James <james.segerdahl@klgates.com>, "Michael S." <michael.caccese@klgates.com>, Mark
<mark.haddad@klgates.com>, "Beth H." <beth.weisberg@klgates.com>, Kevin Polansky
<kevin.polansky@nelsonmullins.com>, "Matthew T." <mmurphy@casneredwards.com>,
kmchugh@harmonlaw.com, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, david fialkow
<david.fialkow@klgates.com>

Dear Attorney General Healey,

As you know, I - Mohan A. Harihar (Plaintiff), have recently included both you and Asst. AG Jesse
M. Boodoo on several email communications related to ongoing litigation proceeding in the
Middlesex Superior Court (Ref. HARIHAR v WELLS FARGO, et al, Docket No. 1981-cv-00050).
I've attached the emails (Below) for your reference. You are also aware that as a matter of court
record (and as officially reported to the MA AGO), this civil complaint has included substantial criminal
violations involving NOT ONLY the named Defendants, but also judicial (and other court) officers.
However, there continues to be serious communication concerns with your office as it pertains
to addressing evidenced criminal violations of record, NOT ONLY: (1) in the referenced Superior
Court complaint(s); BUT ALSO (2) historically in the related MA Land Court, Northeast Housing Court
and Lowell District Court dockets; and (3) in the related Federal complaint (Ref. HARIHAR v US
BANK et al, Docket No. 15-cv-11880), which includes the Commonwealth of Massachusetts as
a Defendant. It remains unclear as to WHY the Plaintiff's countless efforts to communicate directly
with you and Asst. AG Boodoo continue to go unanswered. Based on my interpretation of the law - if
left uncorrected, the Plaintiff shows cause to (again) amend his original Federal complaint, at
minimum expanding upon evidenced RICO, Color of Law/Due Process (and other) claims against
the Commonwealth. Respectfully, based on the Plaintiff's interpretation of the law - Sovereign
Immunity, Judicial Immunity and any litigation privilege is considered WAIVED since Fraud on
the Court has already been evidenced against ALL Defendant parties and stands UNOPPOSED
as a matter of record under both Fed./Mass. R. Civ. P. 60(b)(3).

7
Right now, you are aware that in the referenced Superior Court complaint, I am trying to validate the
Defendants' legal position - as it pertains to verifying: (1) their retained counsel of record; and (2)
whether or not the Defendants wish to resume a settlement discussion. Based on my interpretation of
the law, it is my understanding that - IF parties were to be successful in reaching an agreement on
the civil portions of the complaint, it MAY no longer be necessary to continue the pursuit of
evidenced criminal/ethics claims involving NOT ONLY the named Defendants, BUT ALSO separately
against judicial (and other court) officers. I respectfully re-state that due to the severity of these
evidenced legal issues - you, as the Attorney General of this Commonwealth, along with the
Clerk of the Courts - Michael A. Sullivan and multiple government offices/agencies have been
regularly copied on these communications for documentation purposes, transparency to the public
and for the purpose of ultimately reaching a timely and just resolution. Once the Plaintiff's
referenced concerns have been validated and the Court has re-established jurisdiction, if a settlement
agreement between parties is NOT an option, there is a clear expectation for the Court to address
and initiate corrective action as it pertains to the lengthy list of unresolved legal issues which
remain. This would also include the MA AGO bringing criminal indictments that tie to the
Plaintiff's evidenced criminal claims of record.

I truly believe that there exists a unique opportunity to resolve ALL of these legal issues and reach a
legal agreement that is beneficial to ALL parties, both here and in the related Federal litigation.
However, it must begin with improved communication - both with your office, as well as with
the named Defendants. I respectfully request that the MA AGO provide a timely response to this
email by 5pm on Monday, February 17, 2020, to clarify its position and to discuss the next legal
steps moving forward.

Please be advised, due to the severity of legal issues involved, the Executive Office of the
President (EOP)*, the Department of Justice (DOJ), members of Congress and other
government offices/agencies (including Defendant's counsel in the related Federal litigation) - will be
copied on this email communication to ensure that EVERYONE is aware of the Plaintiff's ongoing,
good-faith efforts to timely (and legally) reach a just resolution. The Public and Media sources
nationwide will also receive copies of this email communication for documentation purposes and out
of continued concerns for the Plaintiff's personal safety and security. Thank you for your attention to
this very serious and sensitive legal matter. I look forward to your response.

* The EOP will be notified via www.whitehouse.gov

Respectfully,

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

8
 Mohan Harihar <moharihar@gmail.com>

COMMUNICATION ISSUES - HARIHAR v WELLS FARGO, et al, Docket

No. 1981-cv-00050
Mon, Feb 10, 2020 at
Mohan Harihar <moharihar@gmail.com>
12:24 PM
To: Michael Anthony Sullivan <michael.sullivan@jud.state.ma.us>
Cc: 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@state.ma.us>, christine bono
<christine_bono@mad.uscourts.gov>, taylor halley <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, Matthew Day <matthew.day@jud.state.ma.us>, james mccormack
<james.mccormack@jud.state.ma.us>, "C. Andrew Johnson" <andrew.johnson@jud.state.ma.us>,
Arthur T Deguglielmo <arthur.deguglielmo@jud.state.ma.us>, James
<james.segerdahl@klgates.com>, "Michael S." <michael.caccese@klgates.com>, Mark
<mark.haddad@klgates.com>, "Beth H." <beth.weisberg@klgates.com>, Kevin Polansky
<kevin.polansky@nelsonmullins.com>, "Matthew T." <mmurphy@casneredwards.com>,
kmchugh@harmonlaw.com, "Jeffrey B. Loeb" <JLoeb@richmaylaw.com>, david fialkow
<david.fialkow@klgates.com>

Dear Clerk Sullivan,

There appears to be a "Communication Issue" with counsel for the named Defendants in the
above-referenced complaint. As you know, the Plaintiff has made MULTIPLE attempts (in
GOOD FAITH) to communicate with the attorney for Bank Defendants - WELLS FARGO and
US BANK (David E. Fialkow, Esq. - K&L Gates, LLP) and also the attorney for Defendants -
MERS, Jeffrey Perkins and Isabelle Perkins (Jeffrey B. Loeb, Esq. - Rich May, PC). It should
be clear to this Court that the INTENTION for these communications is to attempt to RESOLVE
ALL existing legal issues and ultimately reach a settlement agreement with ALL Defendant
parties. The Plaintiff has also made it clear that based on his interpretation of the law - IF parties
were to be successful in reaching an agreement on the civil portions of the complaint, it MAY no
longer be necessary to continue the pursuit of evidenced criminal/ethics violations involving NOT
ONLY the named Defendants, BUT ALSO separately against judicial (and other court)
officers. Due to the severity of these evidenced legal issues - you, along with multiple
government offices/agencies have been regularly copied on these communications, for
documentation purposes, transparency to the public and with the hope of reaching a timely (and
just) resolution.

Unfortunately, there continues to be NO RESPONSE from the opposing counsel - to the extent
that I am trying to validate whether or not they have withdrawn from this litigation, changed in

9
their employment status, etc., that would explain their silence. Considering the severity of legal
circumstances at hand, this collective decision exemplifies not only a lack of professional
courtesy, but also underscores the necessity for this Court to initiate immediate corrective action
as it pertains to this litigation, beginning with jurisdiction. Unfortunately, this lack of
communication by the Defendants also makes it necessary to push forward with addressing ALL
of the evidenced judicial abuses of record. The resulting delays are unnecessarily bringing
increased hardship to the Plaintiff, who already is considered as indigent and continues to
struggle with getting basic - cost of living/health insurance bills paid. I respectfully request that
you notify Chief Justice - Honorable Judith Fabricant and bring her up to date with these latest
developments.

Please be advised, Federal/State Prosecutors, the White House and other government
offices/agencies (including Defendant's counsel in the related Federal litigation) - will again be
copied on this email communication to ensure that EVERYONE is aware of the Plaintiff's
ongoing, good-faith efforts to timely resolve ALL legal issues. The Public and Media sources
nationwide will also receive copies of this email communication for documentation purposes and
out of continued concerns for the Plaintiff's 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: Mohan Harihar <moharihar@gmail.com>
Date: Thu, Feb 6, 2020 at 10:30 AM
Subject: YOUR TIMELY RESPONSE (AND VALIDATION) IS REQUESTED TODAY 02/06/2020
RE: HARIHAR v WELLS FARGO, et al, Docket No. 1981-cv-00050
To: david fialkow <david.fialkow@klgates.com>, Jeffrey B. Loeb <JLoeb@richmaylaw.com>
Cc: Michael Anthony Sullivan <michael.sullivan@jud.state.ma.us>,
<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@state.ma.us>, christine bono <christine_bono@mad.uscourts.gov>, taylor
halley <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>, Matthew Day
<matthew.day@jud.state.ma.us>, james mccormack <james.mccormack@jud.state.ma.us>, C.

10
Andrew Johnson <andrew.johnson@jud.state.ma.us>, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, James <james.segerdahl@klgates.com>, Michael S.
<michael.caccese@klgates.com>, Mark <mark.haddad@klgates.com>, Beth H.
<beth.weisberg@klgates.com>, Kevin Polansky <kevin.polansky@nelsonmullins.com>, Matthew
T. <mmurphy@casneredwards.com>, <kmchugh@harmonlaw.com>

Attorney's Fialkow and Loeb,

I am respectfully requesting a timely response today (Thursday, 02/06/2020), confirming that you
are both still employed by the same law firms (David E. Fialkow, Esq. - K&L Gates, LLP;
Jeffrey B. Loeb, Esq. - Rich May, PC) and that you are still listed as the retained counsel in the
above-referenced complaint. The reason it becomes necessary to validate this information is
because I STILL have yet to receive ANY response from either one of you with regard to the
Plaintiff's email communication delivered to your direct attention last Wednesday, January 29,
2020 (Scroll down to view) - which included the opportunity to (in good faith) resume a legal
settlement discussion with your clients.* As you know, there are very serious civil/criminal/ethics
violations evidenced as part of the record (and which have been brought to the attention of the
American Public), involving NOT ONLY your clients, but also DISQUALIFIED Middlesex
Superior Court Judge - Hon. Janice W. Howe, RECUSED US District Court Judge - Hon.
Allison Dale Burroughs and a considerable list of additional Federal/MA State Judicial (and
other court) officers related to this MA State (and Federal) litigation. As stated in my previous
communications - based on my interpretation of the law if collectively, all parties are able to
resolve these legal issues and reach a settlement agreement, it MAY no longer be necessary
to continue the pursuit of evidenced civil/criminal/ethics violations involving NOT ONLY your
clients, BUT ALSO referenced judicial (and other court) officers. I'm sure you can understand
my concern over your silence - particularly since you have both stated in an open courtroom that
your clients are willing to have a legal settlement discussion.

After validating you place of employment, if you are still the retained counsel in the above-
referenced litigation, I again respectfully request that you provide a timely response before the
close of business today (5pm) - Thursday, February 6, 2020, as to whether or not your clients
are interested in resuming a legal settlement discussion. Please be advised, since this matter has
necessarily been brought to the attention of Chief Justice - Honorable Judith Fabricant,
Federal/State Prosecutors, the White House and other government offices/agencies (including
Defendant's counsel in the related Federal litigation) - they will again be copied on this email
communication to ensure that EVERYONE is aware of the Plaintiff's ongoing, good-faith
efforts to timely resolve ALL legal issues. The Public and Media sources nationwide will also
receive copies of this email communication for documentation purposes and out of continued
concerns for the Plaintiff's personal safety and security. Thank you for your attention to this very
serious and sensitive legal matter. It remains my sincere hope that we will be able resume the
settlement discussion in the coming days and ultimately reach an agreement that is beneficial to
ALL parties.

*Referenced Defendants include: (1) Bank Defendant - WELLS FARGO; (2) Bank Defendant
- US BANK; (3) Defendant - MERS, Inc.; (4) Defendant - Jeffrey Perkins; and (5) Defendant -
Isabelle Perkins.

11
Respectfully,

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

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

From: Mohan Harihar <moharihar@gmail.com>
Date: Tue, Feb 4, 2020 at 10:17 AM
Subject: 02-03-2020 Email Received from President Donald J. Trump RE: HARIHAR v WELLS
FARGO, et al, Docket No. 1981-cv-00050
To: Michael Anthony Sullivan <michael.sullivan@jud.state.ma.us>
Cc: <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@state.ma.us>, christine bono <christine_bono@mad.uscourts.gov>, taylor
halley <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>, Matthew Day
<matthew.day@jud.state.ma.us>, james mccormack <james.mccormack@jud.state.ma.us>, C.
Andrew Johnson <andrew.johnson@jud.state.ma.us>, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, James <james.segerdahl@klgates.com>, Michael S.
<michael.caccese@klgates.com>, Mark <mark.haddad@klgates.com>, Beth H.
<beth.weisberg@klgates.com>, Kevin Polansky <kevin.polansky@nelsonmullins.com>, Matthew
T. <mmurphy@casneredwards.com>, <kmchugh@harmonlaw.com>, Jeffrey B. Loeb
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>

Dear Clerk Sullivan,

Please be advised, on Monday, February 3, 2020, I received an email from President Donald J.
Trump, confirming his receipt of my communication which summarized the latest developments
here in this Middlesex Superior Court - and at minimum, the legal impact it potentially stands to
have with Defendant Parties in the related $42B Federal lawsuit - HARIHAR v US BANK et al,
Docket No. 15-cv-11880. Referenced Defendant Parties include (but are not limited to):

1. Defendant - WELLS FARGO;

2. Defendant - US BANK;
3. Defendant - Commonwealth of Massachusetts (and others).

12
The President's email is attached below as reference, along with the email communications
delivered to your attention on 02-01-2020 and the Mutual Agreement Opportunity delivered to
Defendants' Counsel on 01/29/2020. I respectfully request that you bring this latest update to the
direct attention of Chief Justice - Honorable Judith Fabricant.

Please be advised, as previously stated, the above-referenced government offices/agencies

(including Defendant's counsel in the related Federal litigation) are copied on this email
communication to ensure EVERYONE is aware of the Plaintiff's ongoing, good-faith efforts to
timely resolve ALL legal issues. The Public and Media sources nationwide will also receive
copies of this email communication for documentation purposes and 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

13
On Sat, Feb 1, 2020 at 12:30 PM Mohan Harihar <moharihar@gmail.com> wrote:

Dear Clerk Sullivan,

As you know, on Wednesday, January 29, 2020, an email communication was delivered to
counsel for the Defendants in good faith - offering to resume settlement discussions in the above-
referenced complaint. Referenced parties included: (1) Bank Defendant - WELLS FARGO; (2)
Bank Defendant - US BANK; (3) Defendant - MERS, Inc.; (4) Defendant - Jeffrey Perkins;
and (5) Defendant - Isabelle Perkins. Due to the severity of evidenced criminal/civil/ethics
violations involving NOT ONLY the named Defendants, but also referenced judicial (and other
court) officers, you were necessarily copied on the email, along with Massachusetts AG Maura
Healey, US Attorney Andrew Lelling (MA) and other government offices/agencies (Attached
below as reference). It was my sincere hope that counsel would respond favorably to this
opportunity. Based on my interpretation of the law - if collectively, all parties are able to resolve
these legal issues and reach a settlement agreement, it MAY no longer be necessary to continue
the pursuit of evidenced claims involving judicial (and other court) officers.

Unfortunately, I have received no response from representing counsel - Attorney David E.

Fialkow (K&L Gates, LLP) or Attorney Jeffrey B. Loeb (Rich May, PC). I respectfully request
that you bring this update to the immediate attention of Chief Justice - Honorable Judith
Fabricant on Monday, February, 3, 2020.

Please be advised, as previously stated, the above-referenced government offices/agencies

(including Defendant's counsel in the related Federal litigation) are copied on this email
communication to ensure EVERYONE is aware of the Plaintiff's ongoing efforts to timely
resolve all legal issues. The Public and Media sources nationwide will also receive copies of
this email communication for documentation purposes and 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

14
---------- Forwarded message ---------
From: Mohan Harihar <moharihar@gmail.com>
Date: Wed, Jan 29, 2020 at 10:08 AM
Subject: MUTUAL AGREEMENT OPPORTUNITY - HARIHAR v WELLS FARGO, et al, Docket
No. 1981-cv-00050
To: david fialkow <david.fialkow@klgates.com>, Jeffrey B. Loeb <JLoeb@richmaylaw.com>
Cc: Michael Anthony Sullivan <michael.sullivan@jud.state.ma.us>,
<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@state.ma.us>, christine bono <christine_bono@mad.uscourts.gov>, taylor
halley <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>, Matthew Day
<matthew.day@jud.state.ma.us>, james mccormack <james.mccormack@jud.state.ma.us>, C.
Andrew Johnson <andrew.johnson@jud.state.ma.us>, Arthur T Deguglielmo
<arthur.deguglielmo@jud.state.ma.us>, James <james.segerdahl@klgates.com>, Michael S.
<michael.caccese@klgates.com>, Mark <mark.haddad@klgates.com>, Beth H.
<beth.weisberg@klgates.com>, Kevin Polansky <kevin.polansky@nelsonmullins.com>, Matthew
T. <mmurphy@casneredwards.com>, <kmchugh@harmonlaw.com>

Dear Attorneys Fialkow (K&L Gates, LLP) and Loeb (Rich May, PC),

As you know, the severity of criminal/civil/ethics violations evidenced NOT ONLY against your
clients, but also involving judicial (and other court) officers - in both this Middlesex Superior Court,
as well as in the related MA State and Federal litigation, has made it necessary to involve:

1. Clerk of the Courts - Michael A. Sullivan;

2. Chief Justice - Honorable Judith Fabricant;
3. The Board of BAR Overseers/BAR Council;
4. The National Association of Realtors (NAR);

5. The Massachusetts Attorney General's Office (MA AGO);

6. The US Attorney's Office (MA)/Department of Justice (DOJ);
7. MA Governor Charlie Baker's Office;
8. The MA Office of the Inspector General;
9. Members of Congress - Including the Offices of US Senator (and 2020 Presidential
Candidate) Elizabeth Warrren (D-MA); US Senator Ed Markey (D-MA); US
Congresswoman Ayanna Pressley (D-MA) and US Congresswoman Lori Trahan
(D-MA);
10. The Administrative Office of US Courts;
11. The United States Office of the Inspector General; and
12. The Executive Office of the President (EOP)

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Before it becomes necessary to move forward with next legal steps, beginning with re-
establishing jurisdiction and addressing referenced judicial failures, I've made it clear to the Court
that (while under no obligation to do so) I am again (in GOOD FAITH) willing to resume a
settlement discussion with your clients to see if there is any chance of resolving the lengthy (and
still growing) list of legal issues which remain. As a respectful reminder, any potential discussion
will be based on the ENTIRE history of this litigation and ALL evidenced claims, not just a select
portion of them. As a matter of record, you have both stated in an open courtroom that your
clients are willing to have a legal settlement discussion.

Attorney Fialkow, please provide a response to this email before 5 PM this Friday, January 31,
2020, that includes an answer from each of your clients: (1) Bank Defendant - WELLS FARGO;
and (2) Bank Defendant - US Bank, as to whether or not they are willing to resume the
settlement discussion.

Attorney Loeb, I similarly request that you provide a response to this email before 5 PM this
Friday, January 31, 2020, that includes an answer from each of your clients: (1) Defendant -
MERS, Inc.; (2) Defendant - Jeffrey Perkins; and (3) Defendant - Isabelle Perkins as to
whether or not they are willing to resume the settlement discussion.

If collectively, we are successful in reaching a legal settlement agreement(s) on the CIVIL

portions of the complaint(s), it MAY not be necessary to continue the pursuit of criminal and
ethics accountability against your clients, judicial and other referenced court officers. It remains
my sincere hope that we will succeed in reaching a legal settlement agreement in the near future
that is beneficial to ALL parties.

Please be advised, the above-referenced government offices/agencies (including Defendant's

counsel in the related Federal litigation) are copied on this email communication to ensure
EVERYONE is aware of my ongoing efforts to timely resolve all legal issues. The Public and
Media sources nationwide will also receive copies of this email communication for documentation
purposes and out of continued concerns for my personal safety and security.

Thank you for your consideration. I look for to your timely response and will plan to update the
Court and all above-referenced government offices/agencies accordingly.

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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