UNITED STATES DISTRICT COURT

for the
DISTRICT OF MASSACHUSETTS

)
MOHAN A HARIHAR )
)
Plaintiff )
) Docket No. TBD
v. )
)
CHIEF JUDGE JEFFREY R. HOWARD; )
CIRCUIT JUDGE JUAN R. TORUELLA; )
CIRCUIT JUDGE WILLIAM J. KAYATTA, )
JR; )
CIRCUIT JUDGE DAVID J. BARRON; )
CIRCUIT JUDGE O. ROGERIEE )
THOMPSON; )
JUDGE ALLISON DALE BURROUGHS; )
JUDGE DENISE J. CASPER; )
JUDGE JON DAVID LEVY; )
JUDGE JOHN J. McCONNELL, JR.; )
CHIEF JUDGE JOSEPH N. LAPLANTE; )
MARGARET CARTER, ESQ.; )
JESSE M. BOODOO, ESQ.; )
KEVIN PATRICK POLANSKY, ESQ.; )
MATTHEW T. MURPHY, ESQ.; )
JEFFREY B. LOEB, ESQ.; )
DAVID GLOD, ESQ. )
)
Defendants )

COMPLAINT AND REQUEST FOR INJUNCTION

I. PLAINTFF DISCLOSURE

ALL DEFENDANT’S named above have been given proper notice regarding the Plaintiff’s

intention to file suit and have been given an opportunity to reach a mutual agreement. All parties

have ignored this opportunity to reach agreement and have failed to ADDRESS, DEFEND or
DENY a single claim against them. Therefore, it becomes necessary to bring this complaint

before the Court. ALL claims against the listed Defendants have occurred within Court walls, as

part of Federal record related to the following actions:

1. HARIHAR v. US BANK et al, Appeal No. 17-1381;

2. HARIHAR v. US BANK et al, Lower Court Docket No. 15-cv-11880;

3. HARIHAR v. THE UNITED STATES, Appeal No. 17-2074;

4. HARIHAR v. THE UNITED STATES, Lower Court Docket No. 17-cv-11109;

5. Judicial Misconduct Complaint No’s: 01-16-90033, 01-17-90021, 01-17-90011 thru

01-17-90018;

6. Complaint filed with the Administrative Office of US Courts, to the attention of

Director James C. Duff.

Therefore, upon filing this NEW Civil Complaint, all dates, times and details of the Plaintiff’s

claims are considered already captured by Federal record, including the Appellate Briefs of the

referenced Appeals. This Court is already aware that the Plaintiff is NOT an attorney and has no

legal background aside from the related litigation. The complexity of issues in the referenced

litigation certainly raises a “TEXTBOOK” scenario for the Court’s assistance with the

appointment of counsel pursuant to 28 U.S.C. § 1915. Those complex legal issues are now

certainly compounded with the filing of this complaint. The Plaintiff will again seek assistance

with the appointment of counsel here, pursuant to 28 U.S.C. § 1915. The Court is also aware of
the Plaintiff’s state of INDIGENCY, therefore a waiver of associated court and service fees is

respectfully requested.1

The gravity of serious legal issues addressed in this new complaint include (but are not limited

to): 1.) Evidenced allegations of TREASON under ARTICLE III, Section 3 of the

Constitution, 2.) Economic Espionage pursuant to 18 U.S.C. § 1832 and 3.) Conspiracy claims

which are believed to impact matters of National Security. The evidenced allegations against

referenced officers of the Court include CRIMINAL MISCONDUCT - On March 19,

2018, Criminal Complaints were filed with the Federal Bureau of Investigation (FBI)

against the TEN (10) identified Federal (Circuit and District) Court Judges. Therefore,

copies of this complaint are necessarily sent via email, social media and/or certified mail to the:

1. Executive Office of the President (EOP);

2. US Inspector General - Michael Horowitz;

3. US Attorney General - Jeff Sessions;

4. Members of the US Senate and House of Representatives;

5. House and Senate Judiciary Committees;

6. House Oversight Committee;

7. Federal Bureau of Investigation (FBI);

8. Office of the Special Inspector General for the Troubled Asset Relief

Program (SIGTARP);

9. Securities and Exchange Commission (SEC);

1
Motions are filed separately for: 1.) Assistance with the Appointment of Counsel and 2.) In
Forma Pauperis, waiver of filing/service fees.
 10. Federal Trade Commission (FTC);

11. The Internal Revenue Service (IRS);

12. Office of the Comptroller of the Currency (OCC).

A copy will also be made available to the PUBLIC, as this judiciary’s effort to “promote

public confidence in the impartiality of the judicial process,” has irrefutably been

compromised. By informing the Public, ALL AMERICANS serve here as WITNESS. Parties

are additionally informed for documentation purposes, and out of the Appellant’s continued

concerns for personal safety/security.

II. JURISDICTIONAL BASIS

Plaintiff claims federal jurisdiction pursuant to Article III § 2 which extends the jurisdiction to

cases arising under the U.S. Constitution. 28 U.S. Code § 1331 - Federal question. The district

courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or

treaties of the United States. Title 28 U.S. Code §1331 is also considered an appropriate basis

for jurisdiction in this action against referenced federal judicial officers, for claims arising from

violations of federal constitutional rights guaranteed in the fifth and fourteenth amendments to

the U.S. Constitution and redressable pursuant to Bivens v. Six Unknown Narcotics Agents 403

U.S. 388 (1971)."

Please be advised, since evidenced claims against named Defendants include: 1.) Fraud on

the Court, 2.) Judicial Fraud on the Court, 3.) Treason and other civil/criminal claims of

record – Litigation Privilege, Judicial Immunity, Sovereign (or any other form of)
Immunity is considered WAIVED. The Plaintiff seeks criminal charges against ALL

parties with the assistance of Federal Prosecutors and respectfully wishes to enjoin this

civil complaint with a criminal complaint and associated criminal charges. Evidenced

misconduct is also grounds for professional accountability, including (but not limited to)

disbarment and removal from the bench, where applicable. This Court is respectfully

reminded that for all misconduct claims related to the referenced litigation, the Department

of Justice (DOJ) has served as witness (either directly or indirectly) through the US

Attorney’s Office (MA), specifically, Assistant US Attorneys - Mary Murrane and Dina M.

Chaitowitz.

While initiating this Complaint in this District Court is considered proper, TRANSFER to a

different Circuit, or perhaps even REMOVAL to the US Supreme Court MAY likely be

necessary, considering: 1.) The severity of these evidenced allegations and 2.) TEN (10) Federal

(District and Circuit) Court judges, ALL from this First Circuit, are named Defendants. By

filing this complaint, the Plaintiff also shows INCREMENTAL cause for RECUSAL(S) in the

related litigation – HARIHAR v US BANK et al (Appeal No. 17-1381) and HARIHAR v.

THE UNITED STATES (Appeal No. 17-2084).

III. THE PARTIES

A. The Plaintiff
Name – Mohan A. Harihar
Street Address – 7124 Avalon Drive
City and County – Acton, Middlesex County
State and Zip Code – MA, 01720
Telephone Number – 617.921.2526 (Mobile)
 E-mail Address – mo.harihar@gmail.com

B. The Defendant
Name – Chief Judge Jeffrey R. Howard
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

C. The Defendant
Name – Circuit Judge Juan R. Torruella
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

D. The Defendant
Name – Circuit Judge William J. Kayatta, Jr.
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available’

E. The Defendant
Name – Circuit Judge David J. Barron
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

F. The Defendant
Name – Circuit Judge O. Rogeriee Thompson
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

G. The Defendant
Name – Judge Allison Dale Burroughs
Street Address – One Courthouse Way
 City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

H. The Defendant
Name – Judge Denise J. Casper
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available

I. The Defendant
Name – Judge Jon David Levy
Street Address – 156 Federal Street
City and County – Portland, ME
Zip Code – 04101
Telephone Number – 207.780.3356
E-mail Address – Not Available

J. The Defendant
Name – Judge John J. McConnell, Jr.
Street Address – 2 Exchange Terrace #234
City and County – Providence, RI
Zip Code – 02903
Telephone Number – 401.752.7200
E-mail Address – Not Available

K. The Defendant
Name – Chief Judge Joseph N. LaPlante
Street Address – 55 Pleasant Street
City and County – Concord, NH
Zip Code – 03301-3941
Telephone Number – 603.225.1423
E-mail Address – Not Available

L. The Defendant
Name – Margaret Carter, Esq.
Street Address – One Courthouse Way
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.748.9057
E-mail Address – Not Available
M. The Defendant
Name – Jesse M. Boodoo, Esq. (MA Office of the Attorney General)
Street Address – One Ashburton Place, 18th Floor
City and County – Boston, MA
Zip Code – 02108
Telephone Number – 617.727.2200 x 2592
E-mail Address – jesse.boodoo@state.ma.us

N. The Defendant
Name – Kevin Patrick Polansky, Esq. (Nelson Mullins, LLP)
Street Address – One Post Office Square, 30th Floor
City and County – Boston, MA
Zip Code – 01960
Telephone Number – 617.217.4720
E-mail Address – kevin.polansky@nelsonmullins.com

O. The Defendant
Name – Matthew T. Murphy, Esq. (Casner & Edwards, LLP)
Street Address – 303 Congress Street
City and County – Boston, MA
Zip Code – 02210
Telephone Number – 617.426.5900
E-mail Address – mmurphy@casneredwards.com

P. The Defendant
Name – Jeffrey B. Loeb, Esq. (Rich May, PC)
Street Address – 176 Federal Street
City and County – Boston, MA
Zip Code – 02110
Telephone Number – 617.556.3871
E-mail Address – Not Available

Q. The Defendant
Name – David Glod, Esq. (Rich May, PC)
Street Address – 176 Federal Street
City and County – Boston, MA
Zip Code – 02110
Telephone Number – 617.556.3871
E-mail Address – Not Available
 IV. STATEMENT OF THE CASE

After more than THREE (3) years of Federal litigation, the Plaintiff has evidenced - IN FULL

PUBLIC VIEW, a PATTERN OF CORRUPT CONDUCT by TEN (10) members of this

Federal Judiciary, ALL of which has been WITNESSED by the Clerk of the Court and by the

US Attorney’s Office (MA).

First, the Plaintiff references the RECUSAL of Judge Allison Dale Burroughs, and the body

of evidence articulated by the Plaintiff – identifying this initial pattern of corrupt conduct that

eventually led to the judge’s recusal. Since then, the Plaintiff has identified the same (or similar)

patterns of corrupt conduct with NINE (9) additional Federal (District and Circuit) Court Judges,

including Chief Judge Jeffrey R. Howard. There have been TWO (2) additional RECUSALS

since then – 1.) Judge Jon David Levy recusal was announced (for reasons UNKNOWN) in

the March 14, 2018 order associated with Appeal No. 17-1381, and 2.) Most recently, Circuit

Judge David Barron recused himself sua sponte on May 18, 2018, after he allegedly “just

discovered” having a FINANCIAL INTEREST with Bank Appellee/Defendant, WELLS

FARGO NA.

Second, the Plaintiff has clearly identified and articulated throughout the record a breakdown in

the PROCESS for addressing judicial misconduct; warranting the involvement of the First

Circuit Executive – Susan Goldberg and the Administrative Offices of US Courts. Further

investigation is certainly needed to determine exactly why TEN (10) Federal Judges have gone

against their Judicial Oath in the referenced litigation to reach a corrupt and pre-determined

outcome. The Plaintiff has clearly articulated throughout the record several supported arguments
which likely contributed (at least in part) to their UNLAWFUL decisions:

1. To avoid setting a legal precedent associated with ILLEGAL FORECLOSURE that

would assist (at minimum) 4.2M illegally foreclosed homeowners nationwide;

2. To avoid setting legal precedent that would assist 4.2M illegally foreclosed homeowners

with the appointment of counsel;

3. To cause IRREPARABLE DAMAGE to the Plaintiff’s Intellectual Property/Trade

Secret designed to economically benefit The United States.2 Based on the Plaintiff’s

interpretation of the law, parties who consciously choose to engage in such conduct –

including TREASON are considered DOMESTIC ENEMIES of THE UNITED

STATES;

4. Out of clear DISDAIN for the PRO SE LITIGANT.

Collectively, the Plaintiff has evidenced that these officers of the Court are considered

INFERIOR judges, showing cause to include them as Defendants in this complaint. The Clerk

of the Court – Margaret Carter is included as a Defendant for her decision to consciously remain

silent after personally witnessing this pattern of judicial misconduct and the COMPLETE

FAILURE to uphold the JUDICIAL MACHINERY OF THE COURT. The remaining

Defendants are representing attorneys in the related litigation where UNOPPOSED Fraud on the

Court claims shows cause to now include them in this new complaint. Litigation privilege is

waived when an evidenced (and UNOPPOSED) Fraud on the Court Claim is presented as part of

the record. Once JURISDICTION has been re-established in the related litigation (and here), it

2
References the HARIHAR FCS Model©, an economic framework designed to assist The
United States with economic growth/recovery stemming from the US Foreclosure Crisis.
is the Plaintiff’s intention to enjoin this complaint with HARIHAR v. US BANK et al, along

with a Criminal complaint(s) led by Federal Prosecutors.

Title 42 U.S. Code § 1983 reads as follows: Every person who, under color of any statute,

ordinance, regulation, custom, or usage, of any State or Territory, subjects, or causes to be

subjected, any citizen of the United States or other person within the jurisdiction thereof to the

deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be

liable to the party injured in an action at law, suit in equity, or other proper proceeding for

redress.

The events giving rise to the Plaintiff’s claims occurred in the Commonwealth of Massachusetts.

These evidenced claims stem from litigation which is STILL ONGOING3:

1. HARIHAR v. US BANK et al, Appeal No. 17-1381 (Lower Court Docket No. 15-cv-

11880) and;

2. HARIHAR v. THE UNITED STATES, Appeal No. 17-2074 (Lower Court Docket

No. 17-cv-11109).

The listed Defendants are associated with the referenced ongoing litigation, as one (1) of the

following:

1. An Officer of the Court, as a Presiding Judge;

Successful implementation is designed to deliver over $5T in economic growth.

3
This referenced Federal litigation includes (but is not limited to) UNOPPOSED Fraud on the
Court and Lack of Standing Claims, showing cause for the Plaintiff to revisit/restore litigation
in MA State Courts. Mr. Harihar has now filed Motions to restore cases in the Middlesex
Superior Court and the Northeast Housing Court to address evidenced Fraud on the Court
Claims (pursuant to MA Civil Rules of Procedure 60(b)(3)). A NEW Complaint for Quiet Title
 2. An Officer of the Court who IS NOT a presiding Judge, but has issued an Order in

the referenced litigation;

3. An Officer of the Court Addressing a Related Judicial Misconduct Complaint(s);

4. An Officer of the Court with the title – “Clerk of the Court”;

5. Retained Counsel for a Defendant/Appellee.

The Plaintiff addresses each Defendant Group separately, providing a factual pattern that gives

rise to a successful claim(s) under the federal civil rights law(s):

1. Defendants, Officers of the Court as a Presiding Judge – References: 1.) Judge

Allison Dale Burroughs4; 2.) Judge Denise J. Casper5; 3.) Circuit Judge Juan R.

Torruella6; 4.) Circuit Judge William J. Kayatta, Jr.7; 5.) Circuit Judge David J.

Barron.8 As a general rule, judges cannot be held liable for money damages for acts done in

the exercise of his judicial function, within the limits of his jurisdiction, no matter how

erroneous, illegal or malicious his acts may be (48A Corpus Juris Secundum §86).

HOWEVER, if an INFERIOR judge acts maliciously or corruptly he may incur liability.

Kalb v. Luce, 291 N.W. 841, 234, WISC 509. In the referenced litigation, the record

CONCLUSIVELY shows what can only be described as an egregious PATTERN OF

CORRUPT CONDUCT, where presiding judges have ALL blatantly refused to uphold

Federal laws, brushing aside all claims in order to reach a corrupt and pre-determined

has also been filed with the MA Land Court.

4
Presiding Judge for Docket No. 15-cv-11880, HARIHAR v. US BANK et al
5
Presiding Judge for Docket No. 17-cv-11109, HARIHAR v. THE UNITED STATES.
6
Presiding Judge for BOTH Appeal No. 17-1381, HARIHAR v US BANK et al and Appeal No.
17-2074, HARIHAR v. THE UNITED STATES.
7
Presiding Judge for BOTH Appeal No. 17-1381, HARIHAR v US BANK et al and Appeal No.
17-2074, HARIHAR v. THE UNITED STATES.
8
Presiding Judge for BOTH Appeal No. 17-1381, HARIHAR v US BANK et al and Appeal No.
 outcome. Examples of this misconduct include (but are not limited to) the following:

a. Failure/Refusal to uphold 28 U.S.C. § 1915 – Assistance with the Appointment of

Counsel;

b. Failure/Refusal to uphold Fed. R. Civ. P. 60(b)(3) – Fraud on the Court;

c. JUDICIAL Fraud on the Court;

d. Failure/Refusal to uphold 18 U.S. Code § 1832 – Misappropriation of Trade

Secrets/Economic Espionage Act, and resulting impact to National Security;

e. Refusing to CLARIFY decisions;

f. Ignoring or failing to address Complainant’s repeated concerns for personal safety and

security;

g. Failure/Refusal to uphold 18 U.S. Code § 2382; Misprision of Treason;

h. Failure/Refusal to uphold 18 U.S. Code § 4; Misprision of a Felony;

i. Failure/Refusal to address evidenced Acts of TREASON, under Article III, Section 3,

of the United States Constitution;

j. Ignoring EVIDENCED claims believed to impact matters of National Security;

k. Federal Tort Claims, pursuant to (at minimum): 28 USC § 2671, 28 USC § 2674 and

28 USC § 1346;

l. Color of Law violations, pursuant to 18 U.S. Code § 242;

m. Civil RICO Claims pursuant to 18 U.S. Code § 1964

n. Ignoring the impact of the sua sponte RECUSAL of Judge Allison Dale Burroughs

from Docket No. 17-cv-11109, HARIHAR v. THE UNITED STATES;

o. Evidence within the record demonstrating Unnecessary Judicial Delay;

17-2074, HARIHAR v. THE UNITED STATES.

 p. Refusal(s) to RECUSE9;

q. Demonstrated INTENT to cause increased hardship to Plaintiff/Appellant/

Complainant, Mohan A. Harihar;

r. False Statements; and others.

The record CONCLUSIVELY shows that ALL referenced presiding judges (including

Chief Justice Jeffrey R. Howard) have previously LOST JURISDICTION to rule in the

referenced litigation for ONE (1) or more of the evidenced claims listed above and

continued to issue orders without jurisdiction. Based on the Plaintiff’s interpretation of

Federal law, any judge who rules without jurisdiction is considered to have committed an

ACT OF TREASON under ARTICLE III, Section 3 of the US Constitution. In

compliance with Federal Law, the Plaintiff informed: 1.) The Court, 2.) Governor Charlie

Baker (R-MA) and 3.) The President of The United States. Serving as witness to these

evidenced claims of Treason include: 1.) Asst. US Attorneys – Mary Murrane and Dina

Chaitowitz, 2.) Clerk of the Court - Margaret Carter and 3.) All Defendants in the

referenced litigation along with their retained Counsel of record.

Since initiating his original Federal complaint in 2015, a thorough review of the record will

reveal that the Plaintiff has attempted to address jurisdiction issues with presiding judges

(and through judicial misconduct complaints) in OVER FIFTY (50) separate court filings,

9
The Plaintiff recognizes that the record now reflects THREE (3) Recusals: 1.) US District
Court Judge Allison Dale Burroughs, 2.) US District Court Judge Jon David Levy, and most
recently on Friday May 18, 2018, Circuit Judge David J. Barron, who has acknowledged a
FINANCIAL INTEREST with Defendant/Appellee – WELLS FARGO NA.
ALL OF WHICH HAVE BEEN BLATANTLY IGNORED. Not only is this

UNACCEPTABLE, but this valid argument alone indicates that these referenced judges

have LOST their jurisdiction to rule in this (or any related) litigation and are considered as

INFERIOR judges.

Aside from evidenced Treason claims, the Plaintiff has made abundantly clear (including in

the referenced disclosure of this complaint) that based on his interpretation of the Law, his

evidenced claims include Economic Espionage pursuant to 18 U.S.C. § 1832 and matters

which are believed to impact NATIONAL SECURITY. A thorough review of the record

will reveal that NOT ONCE, does ANY presiding judge, Chief Justice Howard, or any other

referenced Federal judge EVER even reference the words: TREASON, ECONOMIC

ESPIONAGE or NATIONAL SECURITY. Therefore, the Plaintiff collectively shows

cause to (at minimum) include CONSPIRACY and CIVIL RICO claims against referenced

Federal Judges.

2. An Officer of the Court who IS NOT a presiding Judge but has issued an Order in

the referenced litigation – References: 1.) Chief Judge Jeffrey R. Howard and 2.)

Circuit Judge O. Rogeriee Thompson. A thorough review of the record will reveal an

identical pattern of corrupt conduct to that of presiding judges that (at minimum)

evidences 1.) Continuing to rule after losing jurisdiction, 2.) RICO Violations, 3.)

Conspiracy Claims, 4.) Due Process Violations; 5.) Economic Espionage and other

claims.

Both Chief Judge Howard and Judge Thompson have issued orders in the referenced

Appeals where they failed to address and/or uphold Federal Rules and continued to rule
 after losing jurisdiction.

3. An Officer of the Court Addressing a Related Judicial Misconduct Complaint(s) –

References: 1.) Chief Justice Jeffrey R. Howard, 2.) Circuit Judge Juan R.

Torruella; 3.) Circuit Judge William J. Kayatta, Jr.; 4.) Circuit Judge David J.

Barron, 5.) Circuit Judge O. Rogeriee Thompson, 6.) Judge Jon David Levy, 7.)

Judge John J. McConnell, Jr. and 8.) Chief Judge Joseph N. LaPlante, as members

of the First Circuit Judicial Council.

Here, a thorough review of the filed Judicial Misconduct Complaints and Petitions again

reveals the same (and/or similar) patterns of corrupt conduct, where Chief Judge Howard

and members of the Judicial Council have failed to recognize a SINGLE EVIDENCED

claim of judicial misconduct. Here too, despite disclosures and reference to matters

perceived to impact National Security, there is NOT EVEN an acknowledgment that

these claims were even a part of the plaintiff’s complaint.

4. An Officer of the Court with the title – “Clerk of the Court” – Per the direction of the

Circuit Executive’s Office, the Plaintiff submitted to the direct attention of Circuit

Executive – Susan Goldberg, a formal complaint against First Circuit Clerk of the

Court – Margaret Carter. As Clerk, Ms. Carter is aware first-hand, of the evidenced

judicial misconduct allegations raised against referenced Federal Judges. These

evidenced allegations have ALL occurred within Court walls, each action observed

directly by the Clerk Carter.

The law clerks’ duty of confidentiality ends when a clerk believes a federal judge(s)

has done something wrong outside of the deliberative process. The confidentiality
guidelines for law clerks are intended to preserve the judiciary’s integrity. The

fundamental goal of the confidentiality guidelines would be subverted if the rules forced

law clerks to be silent about judicial misconduct. WHEN A JUDGE engages in illegal

activities or inappropriate behavior (as is the case here), that’s clearly NOT what’s

intended to be confidential.

For Ms. Carter, her conscious decision to IGNORE evidenced judicial misconduct

including CRIMINAL claims of Treason shows cause to (at minimum):

1. Question her ability to perform her duties as Circuit Clerk;

2. Question whether Ms. Clark is (at minimum) COLLUDING with presiding

Circuit Judge’s – Torruella, Kayatta and Barron in order to reach a

CORRUPT and PRE-DETERMINED outcome as it relates to the Plaintiff’s

related litigation; and

3. Initiate legal next steps for her removal as Clerk.

Based on the evidenced claims of record before you, and under the CODE OF

CONDUCT FOR JUDICIARY EMPLOYEES, there appears to be (at minimum),

numerous infractions by Clerk Margaret Carter with regard to the following Canons:

Canon 1: A Judicial Employee Should Uphold the Integrity and Independence of

the Judiciary and of the Judicial Employee's Office;

Canon 2: A Judicial Employee Should Avoid Impropriety and the Appearance of

Impropriety in All Activities;

 Canon 3: A Judicial Employee Should Adhere to Appropriate Standards in

Performing the Duties of the Office.

Therefore, the Plaintiff has shown just cause to include Clerk Margaret Carter in this civil

complaint.

5. Retained Counsel for a Defendant/Appellee – References: 1.) Jesse M. Boodoo, Esq.,

2.) Kevin Patrick Polansky, Esq., 3.) Matthew T. Murphy, Esq., 4.) Jeffrey B. Loeb,

Esq. and 5.) David Glod, Esq. The evidenced and UNOPPOSED FRAUD ON THE

COURT CLAIMS of record indicate that referenced counsel has waived litigation

privilege and any other assumed form of immunity. Counsel has served as witness to

referenced Treason and other judicial misconduct claims and has chosen to remain silent.

Collectively, the Plaintiff shows cause to raise multiple civil claims here against

referenced attorneys, at minimum for the following: 1.) Civil RICO violations, 2.) Civil

Conspiracy claims, 3.) Economic Espionage violations and 4.) Fraud on the Court

claims, pursuant to FRCP 60 (b)(3). The Plaintiff has already filed CRIMINAL claims

against referenced attorneys with the FBI and makes clear that he seeks to enjoin this

civil complaint with criminal charges brought by Federal Prosecutors.

V. ISSUES RAISED

Based on the evidenced allegations described above, the Plaintiff shows cause to (at

minimum) bring the following claims against named Defendants:

1. Judicial Fraud on the Court, pursuant to Fed. R. Civ. P. 60(b)(3), (4), and (6)

(ALL JUDICIAL OFFICERS);

 2. Misappropriation of a Trade Secret, which is also considered the Intellectual

Property belonging to the Plaintiff – MOHAN A. HARIHAR, protected under

the Economic Espionage Act, 18 U.S. Code § 1832 (ALL PARTIES);

3. 18 U.S.C. § 371— Conspiracy to Defraud the United States (ALL PARTIES);

4. Federal Tort Claims, pursuant to (at minimum) 28 USC § 2671, 28 USC § 2674

and 28 USC § 1346 (ALL PARTIES);

5. Color of Law violations, pursuant to 18 U.S. Code § 242 (ALL JUDICIAL

OFFICERS, CLERK MARGARET CARTER and ASSISTANT AG JESSE

BOODOO);

6. Civil RICO Claims pursuant to 18 U.S. Code § 1964 (ALL PARTIES);

7. Obstruction of Justice pursuant to 18 USC Chapter 73 (ALL PARTIES);

8. Demonstrated INTENT to cause an increased hardship to the Plaintiff (ALL

PARTIES).

The Plaintiff retains the right to expand upon and/or amend this complaint: 1.) Once jurisdiction

has been established and 2.) Once the Court has assisted the Plaintiff with the Appointment of

Counsel under 28 U.S.C. § 1915. Irreparable injury to the Plaintiff is clearly articulated in the

referenced docket(s), and in conjunction with the filed SF-95 form (associated with HARIHAR

v. THE UNITED STATES).

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays this Court issue equitable relief as follows:

1. Issue injunctive relief commanding Defendants to:

 a. Assist the Plaintiff with the Appointment of Counsel, pursuant to 28 U.S.C. §

1915;

b. Establish a Balance of Hardships;

c. Issue a STAY order pertaining to the timeline for petitioning the US Supreme

Court, as it relates to Appeal No. 17-1381 until ALL issues related to the Appeal

have been resolved. Currently, the Plaintiff’s deadline for filing his petition for

Writ of Certiorari with the Supreme Court is set for Tuesday, June 12, 2018.

PLEASE NOTE: By identifying the PLETHORA of STILL UNRESOLVED

ISSUES within APPEAL NO. 17-1381, the DISMISSAL ORDER AND

MANDATE are considered VOID and MUST be VACATED. The Plaintiff

requests that the Court update The US Supreme Court to ensure that any

unnecessary penalty is incurred;

2. Issue equitable relief for proportionate civil damages as described in the related civil

litigation;

3. Issue punitive damages as this Court deems appropriate and just;

4. Issue declaratory relief as this Court deems appropriate and just;

5. Issue ANY OTHER relief as this Court deems appropriate and just;

6. Award Plaintiff his costs of litigation.

 Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my

knowledge, information, and belief that this Notice: (1) is not being presented for an improper

purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;

(2) is supported by existing law or by a non-frivolous argument for extending, modifying, or

reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so

identified, will likely have evidentiary support after a reasonable opportunity for further

investigation or discovery; and (4) the Motion otherwise complies with the requirements of Rule

11.

Respectfully submitted this 29th day of May, 2018.

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