FOR IMMEDIATE RELEASE

$42B Lawsuit Filed Against Wells Fargo, US Bank & the

Commonwealth of Massachusetts
Boston, MA, May 21, 2015 A Federal complaint has been filed at the United States District
Courthouse in Boston, by foreclosed homeowner Mohan A. Harihar. Defendants in the civil
complaint include: Wells Fargo NA, US Bank NA, the Commonwealth of Massachusetts,
associated law firms, attorneys, real estate brokers, and parties who knowingly purchased an illegal
1
foreclosure.
For those who have been following this 4-year storyline, an overwhelming amount of evidence has
steadily come forth to support Mr. Harihars consistent claims of civil and criminal misconduct. Multiple
allegations of evidenced corruption have come forth as well. The most recent allegations reveal
criminal tampering with a MA Superior Court case file, and evidenced Collusion involving the
Massachusetts Attorney Generals Office, the US Attorneys Office, the Boston BAR Association, and
retained counsel (former) for Wells Fargo & US Bank Nelson Mullins Riley & Scarborough LLP.
While the individual damages are certainly significant, the big picture focuses on the intellectual
property belonging to Mr. Harihar, and three (3) specific projects designed to bring considerable
economic growth to the US and repairing damages suffered from the US Foreclosure/Financial
Crisis.
Scroll down to view a copy of the filed Federal Complaint in its entirety.
Mr. Harihar is now seeking to retain a qualified/experienced legal team to assist with this action.
Interested firms are encouraged to reference the contact information listed below.

For Further Media Information Contact: Mohan A. Harihar

Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)
Follow on Twitter:
Mohan Harihar@MH_Foreclosur1

Associated Law Firms include: Nelson Mullins Riley & Scarborough LLP and Harmon Law Offices
PC; Associated attorneys include: David E. Fialkow, Jeffrey S. Patterson, and Peter Haley; Associated
Real Estate Brokers include: Daher Companies Weichert Realtors (Methuen, MA); Jeffrey & Isabelle
Perkins are parties who knowingly moved forward with purchasing an illegal foreclosure.

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR

CIVIL ACTION NO: TBD

Lower Court: 11-04499

Plaintiff
v.
WELLS FARGO NA,
US BANK NA,
RMBS CMLTI 2006 AR-1,
COMMONWEALTH OF MASSACHUSETTS,
HARMON LAW OFFICES PC,
NELSON MULLINS RILEY AND SCARBOROUGH LLP,
DAVID E. FIALKOW ESQ,
JEFFREY PATTERSON ESQ,
PETER HALEY ESQ,
MARY AND KEN DAHER - DAHER COMPANIES,
JEFFREY AND ISABELLE PERKINS
Defendants
CIVIL COMPLAINT FOR PLAINTIFF DAMAGES AND DEMAND FOR JURY TRIAL
UNDER FED. R. CIV. P. 38(B)
I.

INTRODUCTION

1. The Plaintiff, MOHAN A. HARIHAR, acting pro se, brings this

enforcement action to hold multiple parties accountable
from their violations of both Massachusetts and Federal law,
stemming from the US Foreclosure Crisis that has gripped
Massachusetts
damages
pursuant

to

and

this

to

(at

this

Nation

Plaintiff
minimum)

since

are

2007.

The

considerable.

the

resulting

Accordingly,

Massachusetts

Consumer

Protection Act, G.L.c. 93A, the Plaintiff seeks to require

Defendants Wells Faro NA, US Bank NA, Harmon Law Offices PC,

Nelson

Mullins

LLP,

David

E.

Fialkow

Esq.,

Jeffrey

Patterson Esq., Peter Haley Esq., Mary and Kenneth Daher

Daher Companies, Jeffrey and Isabelle Perkins, and the
Commonwealth

of

Massachusetts,

restitution,

and

other

their

unfair

and

to

pay

compensation

deceptive

civil

for

conduct

harms

(at

penalties,
caused

minimum),

by
in

Massachusetts, and additionally the infringement and damage

to the Plaintiffs Intellectual property.
2. The

Plaintiff

also

seeks

injunctive

relief

in

order

to

remedy, address and prevent additional harm from arising out

of

the

Defendants

conduct.

The

request

for

Injunctive

relief has been initially filed with the Middlesex Superior

Court.2 However, nearly fourteen (14) weeks later, still no
decision

has

referenced

been

case

made,

file

and

went

approximately three(3) weeks.

it

was

missing

revealed
for

that

the

period

of

On Thursday, May 13, 2015,

Plaintiff Mohan A. Harihar requested to review the newly

found

file.

Upon

review,

clear

signs

of

tampering

were

evident, ranging from (at minimum) the dis-assembly of the

Plaintiffs submitted 9A package, mislabeling, items out of
order, missing documents, and unidentified notations made to
a separate and re-assembled set of Court documents which
appear as the first items to be reviewed by the Court. The

Reference Docket No: 2011-04499, Harihar vs. US Bank NA, Wells

Fargo NA, Harmon Law Offices PC, et al.
2

Plaintiff immediately notified the Clerk Michael Brennan

of

these

findings,

and

the

Clerks

office

is

currently

reviewing the file.

3. The clearly evidenced discovery of improper relationships
including Collusion and Conflict, involving Nelson Mullins
Riley and Scarborough LLP, the MA Attorney Generals Office,
the US Attorneys Office, and the Boston Bar Association has
necessitated the involvement of the Massachusetts Inspector
Generals

Office,

the

requested

call

for

(at

minimum)

multiple internal investigations, and the assignment of a

special

prosecutor

to

address

the

numerous

criminal

allegations associated with this complaint, including (but

not limited to) Corruption.3
4. The

announcement

just

released

by

the

former

Attorney

General - Martha Coakley on January 16, 2015 addresses the

consent judgment from the amended 2011 complaint filed by
the Commonwealth against four banks including the Defendant,
Wells

Fargo

N.A.

The

complaint

details

the

Defendants

unlawful conduct resulting in void/illegal foreclosures. The

Attorney

General

states,

Wells

Fargo

Bank

violated

Massachusetts foreclosure law and the Massachusetts Consumer

Protection Act by illegally foreclosing upon Massachusetts
residents when the banks lacked the legal authority to do
so. This declaration by the Massachusetts Attorney General
3

See Attachment A
4

reaffirms the consistent claims by this Plaintiff, through

nearly four (4) years of litigation.4
5. The

historical

record

associated

with

this

matter

collectively reflects an overwhelming (and still growing)

amount of evidence and information which has steadily come
forth, in full support of this Plaintiffs consistent claims
thus clearly warranting new trial and a move to Federal
Court.
6. The scope of both civil and criminal misconduct alleged is
significant,
require

involves

voluminous

complex

discovery,

facts,

will

subpoenaed

(at

minimum)

testimony

by

multiple parties, and the likely need for substantial case

management.
7. Plaintiff

reserves

the

right

to

expand

the

list

of

Defendants, as the depth of related misconduct is revealed.

This

includes

any

party,

agency,

employer,

etc

who

so

chooses to support any portion of the referenced misconduct.

Defendants newly retained counsel - K & L Gates, LLP, has
been given notice, that any alignment or show of support to
any portion of the referenced misconduct will show cause to
add their firm as a Defendant in this matter. This includes
(but is not limited to) the recent decisions to newly employ
Defendants Attorney David E. Fialkow and Attorney Jeffrey
4

Reference Suffolk County Superior Court Docket No: 11-4363,

filed by the Commonwealth of Massachusetts, and includes
Defendant Wells Fargo NA; See Attachment B.
5

S. Patterson. Both Defendants Fialkow and Patterson have

recently separated from Defendant - Nelson Mullins Riley and
Scarborough LLP for reasons unknown.5
8. Defendant Harmon Law Offices, PC has been in Default,
since

this

matter

was

brought

before

the

Massachusetts

Appeals Court, again as injunctive relief is sought in the

Middlesex

Superior

investigation

by

Court,

the

MA

and

since

Attorney

coming

Generals

under

Office

for

wrongful foreclosure and eviction practices.6

9. There

has

Nelson

been

Mullins,

NO
to

ATTEMPT
deny,

MADE,
defend,

by

the
or

Commonwealth

even

address

or
the

evidenced allegations of COLLUSION made against them.7

10.

While the Plaintiff has historically acted as a pro se

litigant (out of financial necessity), a significant effort

is

now

made

to

retain

counsel

with

the

filing

of

this

action. If attempts to secure counsel are unsuccessful, the

Plaintiff intends to file with the Court a separate Motion
for the Appointment of Counsel per Title 28 U.S.C. 1915.8

K & L Gates, LLP is the 3rd law firm to appear as retained

counsel to Defendants US Bank NA, Wells Fargo NA, and CMLTI
2006-AR1 (Replacing Defendant - Nelson Mullins Riley and
Scarborough LLP, and Defendant - Harmon Law Offices PC). See
Notice, Attachment C.
6
The Massachusetts Attorney Generals office is believed to be
still conducting this ongoing investigation.
7
Similarly, there has been no effort made by the US Attorneys
Office or the Boston BAR Association, to deny, defend or
address these allegations.
8
See Motion for Appointment of Counsel and/or Special
Prosecutor (filed separately).
5

II.
11.

JURISDICTION AND VENUE

While the Plaintiff has been granted leave to file for new

trial

by

the

Massachusetts

Court9,

Appeals

the

facts

surrounding this matter satisfy (at minimum) the Federal

requirements of diversity (28 U.S. Code 1332),

damages

exceeding

Federal

threshold

Antitrust

laws;

Amendment

to

of

$75,000;

Constitutional

Due

Process

and

violations

Violations
Equal

to

of

Protection

14th

the

Rights;

Evidenced Collusion and Conflict, in which the Commonwealth

thus far has failed to address and take corrective action.
12.

The

growing

Plaintiff

to

complexity
actively

of

seek

this
and

matter
retain

warrants

the

qualified

and

experienced counsel to assist with this action. The severity

of

evidenced

Massachusetts

allegations

involving

additionally

warrants

the
the

Commonwealth
assistance

of

of
a

special prosecutor.
13.

The parties are joined in a single lawsuit pursuant to

Mass R. Civ. P.20, and with meeting the Federal requirements

of Diversity, due to a significant number of common issues
of fact and law raised by the claims detailed within and
because these claims originate out of the same series of

See MA Appeals Court Docket Sheet for No: 2013-P-1829,

Harihar v. US Bank NA, Wells Fargo NA, et al.; Reference #19.
7

transactions

or

occurrences,

namely,

foreclosures

that

failed to comply with Massachusetts law.

14.

Trial by jury is hereby respectfully demanded under Civil

Procedure

Rule

38

(a),

taking

into

consideration

the

historical abuses of judicial discretion throughout multiple

state

courts,

irrefutable

negligence

by

the

Northeast

Housing Court, 14th Amendment infractions to Due Process and

Equal

Protection

Rights,

and

the

Commonwealths

failure/refusal to address and prosecute Defendants (and

counsels)

evidenced

criminal misconduct, or to

take

ANY

corrective action.

III.
15.

THE PARTIES

The Plaintiff is Mohan A. Harihar, a wrongfully foreclosed

and wrongfully displaced homeowner, who brings this action

to

recover

damages

suffered,

and

also

in

the

public

interest. Mr. Harihar is also the originator/owner of three

(3) separate projects specifically designed to assist this
Nations and overall Global economic recovery from damages
suffered

from

the

US

Foreclosure/Financial

Crisis.

These

projects include the FCS model10.

16.

Defendant Wells Fargo Bank, N.A. ("Wells Fargo") is a

national bank with a principal place of business in Sioux

10

The FCS Model , is the Intellectual Property belonging to

the Plaintiff Mohan A. Harihar. See Attachment D for
completed form AO 121.
8

Falls, South Dakota. As described below, Wells Fargo either

directly and/or indirectly through its agents, employees,
subsidiaries

and/or

related

companies,

including

without

limitation Wells Fargo Home Mortgage, Inc., held, serviced

and/or engaged in transactions related to, mortgages of real
property within the Commonwealth, including the Plaintiffs
foreclosed property.11
17.

Defendant US Bank, N.A. (US Bank), is a national bank

with a principal place of business in Saint Paul, MN. As

described below, US Bank either directly and/or indirectly
through its agents, employees, subsidiaries and/or related
companies,

including

Mortgage,

Inc.,

without

held,

limitation

serviced

Wells

and/or

Fargo
engaged

Home
in

transactions related to, mortgages of real property within

the

Commonwealth,

including

the

Plaintiffs

foreclosed

property.
18.

Defendant

CMLTI

2006-AR1

is

the

residential

mortgage-

backed security (RMBS) trust associated with the Plaintiffs

wrongful foreclosure.
19.

Defendant Harmon Law Offices PC is a law firm with a

principal office in Newton, MA. Harmon is the originally

retained counsel by US Bank in this matter, who withdrew
from

this

case

shortly

after

the

MA

Attorney

Generals

11

The referenced illegal foreclosure is located at 168

Parkview Avenue, Lowell, MA 01852.
9

Office began its investigation of Harmons involvement with

unlawful

foreclosures.

Harmon

has

been

labeled

the

Foreclosure Mill of Massachusetts, tied to over 50,000

foreclosures throughout the Commonwealth. Harmon has also
been

directly

linked

to

disbarred

Florida

foreclosure

kingpin David Stern.

20.

Defendant Nelson Mullins Riley and Scarborough LLP is a

law firm with multiple locations primarily along the east

coast

of

the

United

States,

including

Boston

Office

located at One Post Office Square, 30th floor, Boston, MA

02109. Nelson Mullins Riley and Scarborough LLP served as
prior counsel to both Defendants - Wells Fargo and US Bank
(Nelson Mullins Riley & Scarborough LLP).
21.

Defendant David E. Fialkow is a newly employed attorney

for K & L Gates, LLP in Boston, MA (formerly with Nelson

Mullins Riley and Scarborough LLP, located in Boston).
22.

Defendant Jeffrey Patterson is a newly employed attorney

for K & L Gates, LLP in Boston, MA (formerly with Nelson

Mullins Riley and Scarborough LLP, located in Boston).
23.

Defendant Peter Haley is the Managing Partner for Nelson

Mullins Riley and Scarborough LLP, located in Boston, MA.

24.

Defendants Mary and Ken Daher are Real Estate Brokers

associated with Weichert Realtors Daher Companies located

in Methuen, MA.

10

25.

Defendants Jeffrey and Isabelle Perkins, who are believed

to have moved to the Commonwealth from the state of New

Jersey, are parties who have moved forward in purchasing the
referenced wrongful foreclosure. Isabelle Perkins is also
believed to be a licensed Real Estate Broker, associated
with Weichert Realtors in the State of New Jersey.
26.

The Commonwealth of Massachusetts now becomes a Defendant

in this matter.

IV.
27.

This

matter

association

STATEMENT OF FACTS

originates

with

the

US

from

direct

and

irrefutable

Foreclosure/Financial

Crisis

considered by many to be the largest case of FRAUD in the

history of these United States. Misconduct associated with
the Plaintiffs foreclosure has been identified by both the
Massachusetts Attorney Generals Office, and separately by
Federal Bank Regulators.
28.

A historical review of the complete record will reveal

related

complaints

against

referenced

Defendants

filed

with multiple agencies, organizations, etc, including:

1. The Federal Bureau of Investigation (Fraud Investigations
Unit).
2. The Massachusetts Office of the Attorney General (Criminal
Complaints).

11

3. The Massachusetts Board of BAR Overseers/BAR Counsel.

4. The Northeast Association of Realtors (NEAR).
5. The Securities and Exchange Commission (SEC).
6. The Federal Trade Commission (FTC).
7. The American Civil Liberties Union (ACLU).
29.

Defendant

misconduct

associated

with

the

Plaintiffs

referenced foreclosure is supported by the sworn testimony

of Fraud expert Lynn Syzmoniak.
30.

Defendant

misconduct

deceptive

practices

conversations
modification
(Mortgage

including
is

during
process,

servicer),

(but

supported

the

in

attempted

between
Wells

not

Plaintiff
Fargo

NA.

limited
the

to)

recorded

22-month

loan

and

Defendant

The

Plaintiff

respectfully insists that this Court issue an order for the

production of these recordings in the Discovery phase. The
historical record will show that Defendants Wells Fargo NA
and

US

Bank

evidence,
failed

to

NA

and

have

repeatedly

Massachusetts

order

Defendants

State
to

refused
Courts
provide

to

produce

have
this

this

repeatedly
critical

Discovery.
31.

A thorough review AND VALIDATION of the historical record

from

ALL

related

Massachusetts

Courts

will

reveal

substantial amount documented evidence and support (already

on file) for the Plaintiffs consistent claims of misconduct
against referenced parties.

12

V.
32.

ALLEGATIONS

The Harihar case, which began nearly four years ago, has

steadily gained the attention of many - both nationally and

globally, as supporting evidence continues still, to come
forth. The list of evidenced misconduct against referenced
Defendants includes (at minimum):
1. Fraud
2. Deceptive Practices
3. Anti-trust Violations
4. Fraudulent Misrepresentation
5. Fraudulent Assignments
6. Perjury
7. Aiding and Abetting Fraud
8. 14th Amendment Constitutional infraction to Due Process
and Equal Protection Rights.
9. Improper

relationships

revealing

evidenced

Collusion

involving the MA Attorney Generals Office, the MA US

Attorneys
Defendants

Office,
counsel

the

Boston

(prior)

BAR
Nelson

association,
Mullins

and

Riley

&

Scarborough LLP.
10.

Abuses of Judicial discretion

11.

Infractions/Infringement to the Intellectual property

belonging to Mohan A. Harihar, including projects designed

13

to

assist

with

this

Nations

(and

Global)

economic

recovery from the US Foreclosure/Financial Crisis.

33.

The

Appellant

attention,

that

respectfully
upon

review

brings
of

to

the

this

Courts

supporting

cases

submitted by Defendants over the past four (4) years, there

does not appear to be one (1) case example provided, which
reflects

the

depth

of

circumstances

equivalent

to

this

matter. Specifically, no case example has been provided to

the

Court(s)

which

includes

the

magnitude

of

documented

civil and criminal misconduct as does this matter. In fact,

the Appellant does not believe there to be a single case
decision, in this Commonwealth, or any state in the Nation,
which

articulates

documented

civil

and

provides

and

justification

criminal

in

misconduct

lieu

of

provided.

Therefore, all such related arguments by these Defendants,

and their impact to ALL related

decisions, respectfully,

must be considered VOID. Any continued argument by opposing

parties based on the same premise, should be disallowed.

VI.
34.

RELIEF SOUGHT

The Plaintiffs collective injuries are divided into six

(6) sections:
1. Injunctive Relief Decisions are currently pending in the
Middlesex

Superior

Court

and

the

Northeast

Housing

14

Court12,

as

injunctive

it

relates

relief

and

to

the

Plaintiffs

corrective

request

action

by

for
the

Commonwealth of Massachusetts. The Plaintiff respectfully

calls for the Court to recognize any injunctive relief
and/or corrective action taken by the Commonwealth (or
their failure to do so). The Plaintiff calls for a formal
Federal investigation as it pertains to the referenced
tampering

allegations

stated

within.

The

Plaintiff

additionally reserves the right to revisit the requests

for

injunctive

relief

with

this

Court,

pending

the

decisions made by the Middlesex Superior Court and the

Northeast Housing Court.
2. Personal

damages

to

marriage,

family,

career,

credit,

future retirement and everyday living. Personal damages

include loss of Plaintiffs home, to which the Plaintiff
is still HOMELESS. A review of the historical record will
additionally reveal Slander/Defamation of the Plaintiffs
character for the past four (4) years. Collective damages
easily meet the Federal minimum requirement of $75,000 and
are considered greater than $1M.
3. Damage to Plaintiffs Intellectual Property involving a
project
economic

designed
recovery

to

assist

from

this

damages

Nations

suffered

and

during

overall
the

US

12

Reference Middlesex Superior Court Docket No: 2011-04499;

Reference Northeast Housing Court Docket No: 11-SP-3032.
15

Foreclosure/Financial

Crisis.

The

documented

MERITS

of

this project are significant, having successfully reached

the Executive Offices of the President of these United
States (EOP) at the specific request of Vice President
Joe Biden, the Deputy Chief Counsel of the House Finance
Committee, Senior Economic adviser to US Senator Elizabeth
Warren (MA), Congresswoman Niki Tsongas Office (MA), the
Chairman of a nationally ranked Strategic Communications
firm, the Attorney General Offices of Massachusetts and
New Hampshire, and two (2) Massachusetts State Senators.
Effectively implemented, this project is expected to have
a positive economic impact estimated in the trillions of
dollars.

The

collective

actions

of

the

Defendants

are

considered to have negatively impacted and caused damage

to

this

project.

Economic

experts

will

be

called

to

articulate the measure of all variables, in a successfully

implemented FCS model. The value of the FCS model is
equated

to

the

total

positive

economic

impact

of

successfully implemented model (measured in US dollars).

4. Damage to Plaintiffs Intellectual Property involving a
template designed to assist (at minimum) the 4.2 million
FORECLOSED

parties,

identified

in

the

US

Foreclosure

Crisis, with filing a civil action against the responsible

Lender/party.

Any

party,

agency,

court,

employer,

etc

whose actions negatively impact or cause damage to any

16

portion of this project are expected to be included as

Defendants in this civil/criminal action(s).

An

expanded

overview

of

this

Project

is

described

as

follows:
i) As

pro

se

demonstrated

litigant,

the

ability

the
to

Plaintiff
properly

has

clearly

construct

(and

argue) a civil complaint as it relates to this matter.

ii)

The final product of the proposed template can be

described as a cleaned up version of what already

exists on record. This version will be simplified in a
step by step manual, modified by state, as needed.
iii) Accessibility to this template is expected to come
(at

minimum)

with

incorporating

website.

Numerous

media sources including social media will be used to

communicate, educate, and inform the public, and ALL
affected parties of this new available tool.

To

put

into

context

value

for

this

template,

the

following formula is used:

i) A

baseline

of

4.2M

affected

parties

with

similar

$1M

(average

damages averaging an estimated $1M each.

ii)

Multiply

4.2M

(affected

parties)

by

damages per) to estimate total damages; equating the

value of this template at 100% to an estimated $4.2T.

17

e. Damage to Plaintiffs Intellectual Property involving a

template designed to assist (at minimum) the 4.2 million
parties,
filing

identified
a

in

criminal

the
action

US

Foreclosure
against

Crisis,

the

with

responsible

Lender/party. Any party, agency, court, employer, etc whose

actions negatively impact or cause damage to any portion of
this project are expected to be included as Defendants in
this civil action. Accessibility and communication of this
template, once complete, will be released in conjunction
with

the

civil

complaint

model.

The

Plaintiff

elects

to

refrain at this time, from assigning an estimated value to

this criminal

complaint

template, until

counsel has been

retained, and/or a special prosecutor has been assigned.

f. The

reimbursement

of

All

associated

legal

fees/costs

affecting this Plaintiff.

g. While the Plaintiff has every right to seek 100% of the
damages/infringement as described within, the Plaintiff
will initially set the total relief sought equivalent to
1 percent (1%) of the template defined in 34(d), or $42B.
Should an agreement between parties be reached based on
this fraction of damages, Plaintiff MAY consider various
options

of

payment

to

lessen

the

burden

of

payment.

However, if it is instead the Defendants decision not to

seek agreement based on this very minimal percentage, the

18

Plaintiff reserves the right to adjust damages up to and

including 100 percent (100%) of ALL six (6) sections of
damages as described within, and without consideration for
various options of payment.
h. The Plaintiff will look to the recommendations of counsel
(once retained) and the Court to assist with a breakdown
of relief due to the Plaintiff by each of the Defendants,
along with their ability to pay.
i. The Plaintiff makes very clear before this Court; the
formula used to calculate damages here, ONLY takes into
consideration the measured timeline of the US Foreclosure/
Financial

crisis

(estimated

2006

affected

parties

identified

are

2010).

similarly

The

4.2M

from

this

estimated timeline only. It is NOT to say that similar

misconduct
since.

has

not

Additionally,

occurred
the

before

formula

this

is

ONLY

timeline,

or

applied

to

impacted FORECLOSURES within this estimated timeline.

THE PLAINTIFF MAKES VERY CLEAR, THAT ASSOCIATED MISCONDUCT

IS NOT LIMITED TO FORECLOSURES ALONE.

Should an agreement here between parties be unsuccessful,

the

plaintiff

will

reserve

the

right

to

address

this

expanded misconduct in a separate action(s).

19

35.

Restating that a Trial by jury is hereby respectfully

demanded under Civil Procedure Rule 38 (a), taking into

consideration the historical abuses of judicial discretion
throughout multiple state courts, irrefutable negligence by
the Northeast Housing Court, 14th Amendment infractions to
Due

Process

and

Commonwealths

Equal

Protection

failure/refusal

to

Rights,

address

and

and

the

prosecute

Defendants (and counsels) evidenced criminal misconduct,

or to take ANY corrective action.

It is through sheer arrogance and the apparent belief of

being

ABOVE

THE

LAW

that

these

Defendants

now

find

themselves in this position of increased legal risk. This

Plaintiff has followed the rules of the Court; has clearly
conducted himself in an ethical manner; exemplified complete
transparency,

and

shown

beyond

ANY

doubt,

evidenced

misconduct by Defendants and their retained counsel. It is

understandable to suspect, that a degree of embarrassment
exists knowing that this pro se litigant has historically
exemplified the ability to successfully argue this matter in
a Court of law. Regardless, their position now comes by
their own hand.
rules

of

the

As this pro se Plaintiff has abided by the

Court,

so

too,

must

these

Defendants

and

counsel be held accountable when they violate and abuse the

law.

20

The Plaintiff - Mohan A. Harihar, has clearly gone over and

above,

perhaps

more

so

than

any

individual

in

this

Commonwealth or Country, not only to irrefutably prove this

case, but to also provide a solution which aids in this
Nations economic recovery, and ALL parties affected.

It remains my sincere hope, that a mutual agreement will be

reached here, while paving the way for an economic framework
that brings historic economic growth to these United States.

Respectfully Submitted,
Mohan A. Harihar

21

Attachment A

22

23

Attachment B

24

25

Attachment C

26

May 20, 2015

VIA EMAIL CORRESPONDENCE

K&L Gates, LLP
Attn: Brian L. Olson, Chief Human Resources Officer
State Street Financial Center
One Lincoln Street
Boston, MA 02111-2950
RE: Attorneys David E. Fialkow and Jeffrey S. Patterson.

Mr. Olson:
It is my understanding that K&L Gates LLP has made the decision to recently employ, as
Partners in the Boston Office, Attorneys David E. Fialkow and Jeffrey S. Patterson
(Previously with Nelson Mullins Reilly & Scarborough, LLP). It is also my understanding that
K&L Gates has made the decision to replace Nelson Mullins as retained counsel to both US
Bank NA and Wells Fargo NA, in litigation against Mohan A. Harihar.
Please be advised of the following:
1. The evidenced civil and criminal misconduct associated with the historical record of
this matter is included as part of a new complaint being filed in Federal Court. The
evidenced misconduct includes (at minimum):
a. Fraud
b. Deceptive Practices
c. Anti-trust Violations
d. Fraudulent Misrepresentation
e. Fraudulent Assignments
f. Perjury
g. Aiding and Abetting Fraud
h. 14th Amendment Constitutional infraction to Due Process and Equal
Protection Rights.
i. Improper relationships revealing evidenced Collusion involving the MA
Attorney Generals Office, the MA US Attorneys Office, the Boston BAR

27

association, and Defendants counsel (prior) Nelson Mullins Riley &

Scarborough LLP.
j. Abuses of Judicial discretion
k. Infractions/Infringement to the Intellectual property belonging to Mohan A.
Harihar, including projects designed to assist with this Nations (and Global)
economic recovery from the US Foreclosure/Financial Crisis.
2. David E. Fialkow, Jeffrey S. Patterson, and their former employer Nelson Mullins
Riley and Scarborough LLP will now be included Defendants in this Federal
complaint(s). Nelson Mullins is on record as supporting the documented misconduct
of retained counsel. Senior management has remained silent for nearly two (2) years
since having been implicated by the managing partner of the Boston Office, Peter
Haley.
3. Clear evidence of improper relationships including Collusion is on record.
Furthermore, there has been no denial by ANY party the Massachusetts Attorney
Generals Office, the US Attorneys Office, the Boston BAR Association, or Nelson
Mullins Riley and Scarborough LLP, of these very serious, and clearly evidenced
allegations.
4. Any party, agency, employer, etc who so chooses to align themselves in support of
this referenced misconduct, is expected to be added as a Defendant in the forthcoming
Federal action(s).
5. A copy of this correspondence will be included in the referenced Federal complaint.
6. While K&L Gates has yet to been listed as a Defendant, Plaintiff Mohan A. Harihar
has reserved the right to expand the list of Defendants as the depth of misconduct
continues to be revealed/exposed.
You are now respectfully requested to articulate for the record, your intentions as they pertain
to this matter. Please note, a failure to do so will be interpreted as a decision to support the
evidenced misconduct of referenced clients and new employees/partners of K&L Gates, LLP.
Thank you for your attention to this matter.
Sincerely,
Mohan A. Harihar
28

Attachment D

29

30