Mohan Harihar <moharihar@gmail.

com>

Re: 18 MISC 000144 - Plaintiff Files Formal JUDICIAL FRAUD ON THE

COURT and TREASON Claims
Mohan Harihar <moharihar@gmail.com> Tue, Nov 20, 2018 at 1:28 PM
To: andrew.lelling@usdoj.gov, maura.healey@state.ma.us
Cc: "Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
Nora_Keefe@warren.senate.gov, scheduling@warren.senate.gov, sydney_levin-
epstein@markey.senate.gov, june.black@mail.house.gov, christina.sterling@usdoj.gov,
mary.murrane@usdoj.gov, ma-igo-general-mail@state.ma.us, igo-fightfraud@state.ma.us,
jesse.boodoo@state.ma.us, emily.rosa@jud.state.ma.us, Jennifer Masello
<jennifer.masello@jud.state.ma.us>, jennifer.noonan@jud.state.ma.us, "Jeffrey B. Loeb"
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>

Dear US Attorney Lelling and MA Attorney General Healey,

Please be advised, after informing the MA Land Court of evidenced jurisdiction (and other) issues
(See the 11/13/18 email and filed RESPONSE attached below), the presiding Judge - Michael Vhay,
an INFERIOR judicial officer of the court, has: (1) refused to recuse himself; (2) failed to provide for
the record a VALID reason that justifies jurisdiction in the referenced proceeding; and (3) issued a
second order on November 14, 2018 without jurisdiction (Attached). Based on my interpretation
of the (State/Federal) law, a judge who continues to rule after losing jurisdiction has by definition -
WARRED AGAINST THE CONSTITUTION. This is considered a serious CRIMINAL offense under
ARTICLE III, Section 3 - TREASON. It is also IDENTICAL to the PATTERN OF CORRUPT
CONDUCT exemplified by judicial officers in the related Federal litigation (Referencing: (1) HARIHAR
v US BANK et al, Appeal No. 17-1381; (2) HARIHAR v THE UNITED STATES, Appeal No. 17-2074
and (3) HARIHAR v CHIEF JUDGE JEFFREY R HOWARD, Docket No. 18-cv-11134). You are both
aware that a criminal complaint has already been filed with the FBI against Judge Michael Vhay
(Attached below as reference). Serving as witnesses to these evidenced criminal allegation(s) are:

1. MA Land Court Clerk Jennifer Masello;

2. MA Land Court Clerk Jennifer Noonan;
3. Jeffrey Loeb, Esq. (Rich May, PC); and
4. David E. Fialkow, Esq. (K&L Gates, LLP)

Additionally, the judge's evidenced actions show cause (at minimum) for the following:

1. Amending (and/or adding NEW) Due Process, Color of Law, RICO (and other) claims
against the Commonwealth in the ongoing/related Federal litigation;
2. Amending (and/or adding NEW) claims in the ongoing/related State litigation;
3. Filing a formal judicial misconduct complaint against Judge Michael Vhay;
4. Updating the Senate/House Judiciary Committees; and
5. Holding witnesses to these evidenced crimes legally accountable.

Respectfully, any failure (or continued delay) by Federal/State prosecutors to bring criminal
indictments against referenced litigants and judicial officers will similarly show cause for incremental
legal action. You are aware that the severity of these evidenced allegations are also perceived to
impact matters of National Security. Therefore, the following Offices/Agencies/Courts will be copied
on this email communication and/or via social media:

1. POTUS (via www.whitehouse.gov);

2. SCOTUS;
3. The Administrative Offices of US Courts – specifically, Director James C. Duff;
4. The House/Senate Judiciary Committees;
5. OIG (Office of the Inspector General) – specifically, IG Michael Horowitz;
6. MA Legislative Leaders - Gov. Charlie Baker (R-MA), US Senator Elizabeth Warren (D-
MA), US Senator Ed Markey (D-MA) and US Congresswoman Niki Tsongas (D-MA);
7. MA OIG – specifically, MA IG Glenn Cunha;
8. The DOJ - including acting US Attorney General Matthew Whitaker;
9. The FBI;
10. Referenced MA Land Court Clerks - Jennifer Masello and Jennifer Noonan;
11. Counsel of record in the referenced MA Land Court litigation;
12. A copy of this email will be included with the mailed hardcopy to the MA Land Court as a
matter of record.
13. The Public is also informed, for documentation purposes and out of continued concerns
for my personal safety and security.

Thank you for your attention to this very serious matter. I look forward to your timely response.

Respectfully submitted,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
---------- Forwarded message ---------
From: Mohan Harihar <moharihar@gmail.com>
Date: Tue, Nov 13, 2018 at 3:15 PM
Subject: Re: 18 MISC 000144 - Plaintiff Files Formal JUDICIAL FRAUD ON THE COURT and
TREASON Claims
To: Jennifer Masello <jennifer.masello@jud.state.ma.us>
Cc: Constituent.services@state.ma.us <constituent.services@state.ma.us>,
<elizabeth_warren@warren.senate.gov>, <Nairoby_Gabriel@warren.senate.gov>,
<scheduling@warren.senate.gov>, <Nora_Keefe@warren.senate.gov>, <sydney_levin-
epstein@markey.senate.gov>, <june.black@mail.house.gov>, <andrew.lelling@usdoj.gov>,
<christina.sterling@usdoj.gov>, <mary.murrane@usdoj.gov>, <emily.rosa@jud.state.ma.us>, <ma-
igo-general-mail@state.ma.us>, <igo-fightfraud@state.ma.us>, <maura.healey@state.ma.us>,
<jesse.boodoo@state.ma.us>, <jennifer.noonan@jud.state.ma.us>, Jeffrey B. Loeb
<jloeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>

Ms. Masello,

Attached, please find the Plaintiff's Response to the Order issued by Judge Michael Vhay, following
the Ma Land Court hearing on October 30, 2017. Please be advised, the recorded proceeding re-
affirms the Plaintiff's claims of judicial misconduct warranting immediate recusal. All personnel in
attendance are considered as witnesses. The severity of these evidenced allegations are perceived
to impact related Federal litigation and matters of National Security - Therefore, the following
Offices/Agencies/Courts will be copied on this email communication and/or via social media: (1)
POTUS (See Exhibit 3); (2) SCOTUS; (3) The Administrative Offices of US Courts – specifically,
Director James C. Duff; (4) The House/Senate Judiciary Committees; (5) OIG (Office of the
Inspector General) – specifically, IG Michael Horowitz; (6) MA Legislative Leaders including
(but not limited to): (1) Gov. Charlie Baker (R-MA); (2) US Senator Elizabeth Warren (D-MA); (3)
US Senator Ed Markey (D-MA); and (4) US Congresswoman Niki Tsongas (D-MA); (7) MA OIG –
specifically, MA IG Glenn Cunha; (8)The DOJ, including US Attorney General Jeff Sessions
and US Attorney Andrew Lelling (MA); (9) the FBI; and (10 AG Maura Healey (MA). A copy of this
email will be included with the mailed hardcopy to the Court as a matter of record (Exhibit 2).

Respectfully submitted,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
 COMMONWEALTH OF MASSACHUSETTS
THE TRIAL COURT
LAND COURT DIVISION

)
MOHAN A HARIHAR ) Case No. 18-MISC-000144
)
Plaintiff )
)
v. )
)
WELLS FARGO BANK NA, et al )
)
Defendants )
)

PLAINTIFF RESPONSE TO 10/30/18 HEARING AND ISSUED ORDER(S)

FOLLOWING the RECORDED Land Court hearing October 30, 2018, the Plaintiff –

Mohan A. Harihar respectfully identifies several issues that re-affirm judicial failures of the

presiding Judge – Michael Vhay; and (again) considers the judge – INFERIOR and

disqualified from ruling further in these proceedings. Serving as witnesses to these evidenced

judicial misconduct claims were: (1) the Court Clerk – Jennifer Noonan (temporarily

replacing Clerk Jennifer Masello); (2) two additional court officers (names unknown); and (3)

counsel for the Defendants, Atty’s - Jeffrey Loeb and David E. Fialkow. As stated by the

Court, there were two (2) separate recordings of the referenced hearing: (1) the court’s

electronic recording system; and (2) the Plaintiff’s cell phone, which he was allowed to use

after being denied an independent court reporter. The Plaintiff will first provide an overview

of the recorded judicial misconduct claims and necessary action to be taken. After doing so,
the Plaintiff will also address the circumstances involving additional parties warranting

amendment to the original complaint. As grounds therefore AND based on the Plaintiff’s

interpretation of Federal and State laws, Mr. Harihar states as follows:

I. RECORDED REFUSAL TO UPHOLD MASS R. CIV. P. 65

As a matter of record, the Plaintiff has clearly identified an imbalance of hardships

pertaining (at minimum) to his housing and transportation needs, warranting an injunction

pursuant to Mass. R. Civ. P. 65. Prior to the 10/30/18 hearing, Judge Vhay denied the

Plaintiff’s request to re-establish the balance of hardships, failing to show valid cause. The

record shows that the Plaintiff filed a RESPONSE to the order, identifying several errors

with Judge Vhay’s decision and requesting reconsideration. However, no corrective action

was taken. At the scheduled hearing on 10/30/18, the Plaintiff again re-addressed the

imbalance of hardships and requested that Judge Vhay correct his erred ruling prior to

moving forward. He refused to do so, failing to acknowledge his identified errors and

offering NO explanation to further justify his ruling. Instead, Judge Vhay indicated that if

I disagreed with his decision, my ONLY choice was to appeal. The Plaintiff (in part)

respectfully disagrees. While the Plaintiff plans to Appeal the Injunction ruling, there are

now two (2) recordings that as a matter of record, reveal the following:

1. Judge Vhay has been informed of specific errors associated with his injunction

ruling;

2. Judge Vhay failed to defend his decision, indicating for the record his intention

NOT to uphold Mass. R. Civ. P. 65. This alone shows cause for automatic

disqualification and call for recusal;

 3. All parties previously referenced (above) serve as witness to this judicial

misconduct (and other) claim(s);

4. The judge’s failure to re-establish a balance of hardships by DENYING the

requested injunction is now the CAUSE for the Plaintiff’s

INCREASED/CONTINUED HARDSHIP.

II. REFUSAL TO RECUSE

There are several issues to address here. First, Judge Vhay states the following:

“Mr. Harihar has not identified any ground for recusal that would require him, or
Judge Vhay, to testify about events to which the only witnesses are Mr. Harihar and
Judge Vhay.”

This statement is factually incorrect for several reasons:

1. Judge Vhay and Mr. Harihar ARE NOT the only witnesses to testify over

grounds for recusal. Both of the previously referenced court clerks, court officers,

the Defendants, and their retained counsel are ALL witnesses to the evidenced

claims of record;

2. Aside from failing to uphold Mass. R. Civ. Proc. 65 (as articulated in the record),

the Plaintiff has evidenced (at minimum):

a. the failure to uphold Mass. R. Civ. P. 56(g);

b. the failure to uphold Mass. R. Civ. P. 60(b)(3);

c. the failure to uphold Chapter 93A, section 2;

EACH of the above referenced judicial failures are grounds for recusal, resembling also

IDENTICAL PATTERNS OF CORRUPT CONDUCT evidenced in the related

Federal Court litigation.1 It becomes CLEAR to this Plaintiff (and should be clear to any

1
Related Federal litigation references the following: (1) HARIHAR v US BANK et al, Appeal No. 17-1381; (2)
HARIHAR v THE UNITED STATES, Appeal No. 17-2074; and (3) HARIHAR v CHIEF JUDGE JEFFREY R
 OBJECTIVE observer) that the presiding judge appears to have NO intention of re-

establishing balance or upholding other referenced laws; and instead intends to reach a

CORRUPT and PRE-DETERMINED OUTCOME. Furthermore, the following

conclusions are made:

1. “Judge Vhay is thus required to decide the motion in the first instance” – this

assertion is incorrect as there is recorded testimony along with referenced

witnesses that corroborate the Plaintiff’s judicial misconduct claims. Case

references are therefore considered improperly applied.

2. Even if Judge Vhay was allowed to decide the motion in the first instance (which

he is not), he has clearly failed the two-step process outlined in Lena v.

Commonwealth, 369 Mass. 571, 575 (1972), for evaluating a motion for recusal:

"Faced, then, with a question of his capacity to rule fairly, the judge [must]

consult first his own emotions and conscience.”

At the very least - in the presence of referenced witnesses and in a recorded

hearing, Judge Vhay has been informed of errors related to his: (1) injunction

ruling; (2) interpretation of the Plaintiff’s Fraud on the Court claims; and (3)

interpretation of the Plaintiff’s Mass. R. Civ. P. 56(g)2 claim. Recorded

HOWARD et al, Docket No. 18-cv-11134. These patterns of corrupt conduct were also acknowledged by SCOTUS
in Application No. 17A-1359, HARIHAR v US BANK et al.
2
Mass R. Civ. P. 56(g) Affidavits made in bad faith - Should it appear to the satisfaction of the court at any time
that any of the affidavits presented pursuant to this rule are presented in bad faith or solely for the purpose of delay,
the court shall forthwith order the party employing them to pay to the other party the amount of the reasonable
expenses which the filing of the affidavits caused him to incur, including reasonable attorney's fees, and any
offending party or attorney may be adjudged guilty of contempt.
 testimony reveals that the judge failed to provide a valid argument to

support his ruling and is unwilling to correct these (and other) identified

judicial errors. What’s more troubling is that in his self-assessment, after

consulting his own emotions and conscience, Judge Vhay fails to find ANY

question of his capacity to rule fairly; suggesting either the potential

existence of mental illness or a related pattern of corrupt conduct. Case

references here are thus improperly applied and Judge Vhay has failed the

internal test of freedom from disabling prejudice. Clearly, any judge who is

UNWILLING to correct his errors (and uphold the law), once they have been

identified shows partiality/prejudice against a party. The judge is also aware that

his decision impacts related litigation that stands to have NATIONAL

IMPLICATIONS. There certainly exists a (internal) stake in this litigation if the

presiding Land Court Judge exemplifies an UNCORRECTED pattern of corrupt

conduct that wrongfully disposes this case and critically damages: (1) the related

litigation; and (2) evidenced claims against (identified) inferior judicial officers.

ANY objective observer would certainly agree. While further investigation is

needed to determine WHY Judge Vhay refused to uphold the law, the end result

is clear, warranting his IMMEDIATE recusal (or removal) from the bench.

III. JUDGE’S REFUSAL TO ACKNOWLEDGE PLAINTIFF’S FILED CRIMINAL

COMPLAINT

As a matter of record, the Court has been made aware that a formal criminal complaint

has been filed with the FBI against MA Land Court Judge Michael Vhay. The Plaintiff
 states that these (and other) facts contained in the criminal complaint establish probable

cause indicating that (at minimum) the following crimes have occurred: (1) TREASON

under ARTICLE III, Section 3; (2) 18 U.S. Code § 371 - Conspiracy to commit

offense or to defraud United States; (3) ECONOMIC ESPIONAGE (Economic

Espionage Act) 18 U.S. Code § 1831; (4) Fraud on the Court, under Fed./Mass. R.

Civ. P. 60(b)(3); (5) Due Process violations; and (6) RICO claims - 18 U.S. Code

Chapter 96. Supporting Docs are part of the Court record(s) here and with the referenced

State/Federal litigation; including associated judicial misconduct complaints/petitions

filed with the Office of the First Circuit Executive. A review of the recorded 10/30/18

transcript will reveal that Judge Vhay avoided discussion of any criminal claims against

him. The Court is respectfully reminded that the following government offices/agencies

were copied on the email delivered to MA Land Court Clerk – Jennifer Noonan on

October 25, 2018, identifying Judicial Fraud on the Court and Treason Claims:3

1. Gov. Charlie Baker (R-MA);

2. IG Glenn Cunha (MA);

3. US Senator Elizabeth Warren (D-MA);

4. US Senator Ed Markey (D-MA);

5. US Congresswoman Niki Tsongas (D-MA);

6. US Attorney Andrew Lelling (MA); and

7. Attorney General Maura Healey (MA)

Please be advised, these offices/agencies will necessarily be copied (via email) again with

the filing of this response.

3
See Exhibit 1
 IV. FAILURE TO ACCEPT SCOTUS’ ACKNOWLEDGMENT OF

EXTRAORDINARY/UNRESOLVED ISSUES

As a matter of record, this Court has been made aware of the extraordinary/unresolved list

of issues impacting the related Federal (and State) litigation. These extraordinary issues –

which include an UNPRECEDENTED level of judicial misconduct claims have recently

been acknowledged by SCOTUS.4 Despite bringing these facts to the attention of the

Court, a review of the recorded 10/30/18 transcript will reveal that Judge Vhay avoided

any discussion of SCOTUS’ acknowledgment. While Judge Vhay does recognize the US

Supreme Court as the highest court in The United States, his efforts to avoid discussion

here are troubling; and further question his impartiality.

V. CAUSE TO AMEND ORIGINAL COMPLAINT

The Plaintiff has brought an evidenced argument that CONCLUSIVELY shows that the

RMBS TRUST – CMLTI 2006 AR-1 was illegally securitized and is considered VOID.

NOWHERE in the record, including the recorded transcript from the 10/30/18

hearing is there a valid argument from the Defendants stating otherwise.

Summarizing the Plaintiff’s primary argument to legal standing – ALL following actions

thereafter MUST be considered VOID. The Plaintiff therefore calls for a formal

investigation by State/Federal prosecutors to review ALL related transactions recorded

with the North Middlesex Registry of Deeds, following the identified ILLEGAL

FORECLOSURE of the Plaintiff’s Property. All parties - including attorneys, affiliated

4
References SCOTUS Application No. 17A-1359, HARIHAR v US BANK et al, which was UNOPPOSED by
Defendants.
notaries, affidavits, etc., associated with these void actions have contributed to and

support the Plaintiff’s lack of standing (and other) claims. Referenced documents from the

North Middlesex Registry of Deeds include:

1. 5/11/11 Foreclosure Deed;

2. 5/11/11 Power of Attorney;

3. 5/11/11 Judgment;

4. 6/6/12 Execution;

5. 10/24/14 Mortgage;

6. 10/24/14 Power of Attorney;

7. 10/24/14 Deed;

8. 10/24 14 Municipal Lien Certificate;

9. 10/27/14 Homestead;

10. 8/23/18 Mortgage.

The referenced mortgage involving TD Bank was IRREFUTABLY created under false

pretense that assumed the Defendants had ANY legal standing to the Plaintiff’s Property

when clearly, they did not. Therefore, AFTER JURISDICTION HAS BEEN

RESTORED HERE, the Plaintiff shows cause to amend and add as Defendants TD

BANK, LEADER BANK and all other parties associated with the above-referenced

documents.
 CONCLUSION

Upon filing this Response, the Plaintiff respectfully calls for the following:

1. A DEMAND for the RECUSAL of Judge Michael Vhay, who is considered an

inferior Land Court judge and disqualified from ruling further in these (or any

related proceedings);

2. Upon the judge’s recusal (or removal from the bench), JURISDICTION must be

re-established before proceeding further;

3. Should Judge Vhay recuse himself sua sponte, the Plaintiff will consider

withdrawing the criminal complaint filed against him;

4. Should Judge Vhay refuse to recuse, (at minimum) the following actions will be

necessary, based on the Plaintiff’s interpretation of the law: (1) the continued

pursuit of criminal indictments against ALL responsible parties, including Judge

Vhay; (2) the Plaintiff will show cause to expand upon existing claims of judicial

misconduct in the Commonwealth, as referenced in Appeal No. 17-1381; (3) As

an INFERIOR judge, the Plaintiff will show cause to bring a NEW Tort

complaint against Judge Vhay, pursuant to 48A Corpus Juris Secundum §86;

(4) A formal judicial misconduct complaint will be filed against Judge Michael

Vhay;

5. Should Judge Vhay refuse to recuse and as an INFERIOR judge issue an order

WITHOUT JURISDICTION, the Plaintiff will file an incremental claim of

TREASON under ARTICLE III, Section 3 of the US Constitution;

6. Should Judge Vhay refuse to recuse, the Plaintiff respectfully requests a

copy/transcript of the October 30, 2018 hearing, for the specific purpose of

pursuing legal action against ALL referenced parties;

7. This filed Response is also meant to serve as a Notice of Appeal pertaining to

Judge Vhay’s denial of the requested injunction;

8. Any referenced witness – including referenced officers of the Court, Defendants

or their retained counsel who (for reasons stated) refuse to be identified as such,

will be subject to forthcoming civil/criminal legal action including (but not

limited to): (1) Misprision of Treason -18 U.S. Code § 2382; (2) RICO claims -

18 U.S. Code Chapter 96; (3) ECONOMIC ESPIONAGE (Economic

Espionage Act) 18 U.S. Code § 1831; (4) Conspiracy to commit offense or to

defraud United States - 18 U.S. Code § 371; and (5) Fraud on the Court,

under Fed./Mass. R. Civ. P. 60(b)(3);

9. The severity of legal issues addressed here in this Land Court complaint and in

the related Federal/State litigation are perceived to impact matters of National

Security. The Plaintiff will therefore (in addition to hardcopies delivered via US

mail) file this response via email communication to the Court Clerk – Jennifer

Masello. The following Offices/Agencies/Courts will necessarily be copied

directly on the email or will receive a copy via social media:

a. POTUS (See Exhibit 3);

b. SCOTUS;

c. The Administrative Offices of US Courts – specifically, Director

James C. Duff;
 d. The House/Senate Judiciary Committees;

e. OIG (Office of the Inspector General) – specifically, IG Michael

Horowitz;

f. MA Legislative Leaders including (but not limited to): (1) Gov.

Charlie Baker (R-MA); (2) US Senator Elizabeth Warren (D-MA);

(3) US Senator Ed Markey (D-MA); and (4) US Congresswoman Niki

Tsongas (D-MA);

g.MA OIG – specifically, MA IG Glenn Cunha;

h. The DOJ, including US Attorney General Jeff Sessions and US

Attorney Andrew Lelling (MA);

i. The FBI.

A copy of the referenced email delivered on Tuesday, November 13, 2018, to

MA Land Court Clerk – Jennifer Masello (and referenced parties) will be

attached as Exhibit 2 of the hardcopy version filed with the Court;

9. A copy of this response will be made available to the PUBLIC and distributed to

media sources nationwide, for documentation purposes and out of the Plaintiff’s

CONTINUED CONCERNS FOR HIS PERSONAL SAFETY AND

SECURITY.

The Plaintiff – Mohan A. Harihar is grateful for the Court’s consideration in this very serious

matter.
Respectfully submitted this 13th Day of November, 2018

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
Exhibit 1
 Mohan Harihar <moharihar@gmail.com>

Re: 18 MISC 000144 - Plaintiff Files Formal JUDICIAL FRAUD ON THE

COURT and TREASON Claims

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

From: Mohan Harihar <moharihar@gmail.com>
Date: Thu, Oct 25, 2018 at 12:59 PM
Subject: Re: 18 MISC 000144 - Plaintiff Files Formal JUDICIAL FRAUD ON THE COURT and
TREASON Claims
To: Jennifer Masello <jennifer.masello@jud.state.ma.us>, Jeffrey B. Loeb
<JLoeb@richmaylaw.com>, david fialkow <david.fialkow@klgates.com>
Cc: Constituent.services@state.ma.us <constituent.services@state.ma.us>,
<elizabeth_warren@warren.senate.gov>, <Nairoby_Gabriel@warren.senate.gov>,
<scheduling@warren.senate.gov>, <Nora_Keefe@warren.senate.gov>, <sydney_levin-
epstein@markey.senate.gov>, <june.black@mail.house.gov>, <andrew.lelling@usdoj.gov>,
<christina.sterling@usdoj.gov>, <mary.murrane@usdoj.gov>, <emily.rosa@jud.state.ma.us>, <igo-
fightfraud@state.ma.us>, <ma-igo-general-mail@state.ma.us>, <maura.healey@state.ma.us>,
<jesse.boodoo@state.ma.us>

Clerk Masello and Counsel,

Please be advised of the following:

1. Attached is the Plaintiff's NOTICE/RESPONSE to the VOID Order issued by the presiding
Judge - Michael Vhay on Tuesday, October 23, 2018;
2. Upon filing this legal document, formal claims are now brought against the presiding judge
that include (but are not limited to): (1) Judicial Fraud on the Court under Fed. R. Civ. P.
60(b)(3) AND Mass. R. Civ. P. 60(b)(3); (2) TREASON under ARTICLE III, Section 3; and
(3) Violations of the Due Process Clause of the U.S. Constitution;
3. The Court Clerk, ALL Defendants and their respective counsel serve as witnesses to these
evidenced civil/criminal claims;
4. These claims are IDENTICAL to the EGREGIOUS PATTERN OF CORRUPT CONDUCT, as
evidenced in the related Federal/State litigation, where FIFTEEN (15) Judicial Officers are
now identified, including the presiding Judge Michael Vhay;
5. Based on the severity of these claims and Plaintiff's interpretation of the law, the following
parties are necessarily copied on this Court filing: (1) Governor Charlie Baker (R-MA); (2)
US Senator Elizabeth Warren (D-MA); (3) US Senator Ed Markey (D-MA); (4) US
Congresswoman Niki Tsongas (D-MA); (5) the DOJ, including US Attorney Andrew
Lelling (MA); (6) US Inspector General Michael Horowitz; (7) MA Inspector General
Glenn Cunha; and (8) Attorney General Maura Healey (MA).
6. POTUS and SCOTUS will necessarily be informed through separate communication(s), as
required by Federal law.
7. A copy of this email and court filing will be made available to the PUBLIC out of the Plaintiff's
CONTINUED CONCERNS for HIS PERSONAL SAFETY AND SECURITY.
Thank you for your attention to this very serious matter.

Respectfully submitted,

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Exhibit 2
 Mohan Harihar <moharihar@gmail.com>

Re: 18 MISC 000144 - Plaintiff Files Formal JUDICIAL FRAUD ON THE

COURT and TREASON Claims
Mohan Harihar <moharihar@gmail.com> Tue, Nov 13, 2018 at 3:15 PM
To: Jennifer Masello <jennifer.masello@jud.state.ma.us>
Cc: "Constituent.services@state.ma.us" <constituent.services@state.ma.us>,
elizabeth_warren@warren.senate.gov, Nairoby_Gabriel@warren.senate.gov,
scheduling@warren.senate.gov, Nora_Keefe@warren.senate.gov, sydney_levin-
epstein@markey.senate.gov, june.black@mail.house.gov, andrew.lelling@usdoj.gov,
christina.sterling@usdoj.gov, mary.murrane@usdoj.gov, emily.rosa@jud.state.ma.us, ma-igo-general-
mail@state.ma.us, igo-fightfraud@state.ma.us, maura.healey@state.ma.us, jesse.boodoo@state.ma.us,
jennifer.noonan@jud.state.ma.us, "Jeffrey B. Loeb" <jloeb@richmaylaw.com>, david fialkow
<david.fialkow@klgates.com>

Ms. Masello,

Attached, please find the Plaintiff's Response to the Order issued by Judge Michael Vhay, following
the Ma Land Court hearing on October 30, 2017. Please be advised, the recorded proceeding re-
affirms the Plaintiff's claims of judicial misconduct warranting immediate recusal. All personnel in
attendance are considered as witnesses. The severity of these evidenced allegations are perceived
to impact related Federal litigation and matters of National Security - Therefore, the following
Offices/Agencies/Courts will be copied on this email communication and/or via social media: (1)
POTUS (See Exhibit 3); (2) SCOTUS; (3) The Administrative Offices of US Courts – specifically,
Director James C. Duff; (4) The House/Senate Judiciary Committees; (5) OIG (Office of the
Inspector General) – specifically, IG Michael Horowitz; (6) MA Legislative Leaders including
(but not limited to): (1) Gov. Charlie Baker (R-MA); (2) US Senator Elizabeth Warren (D-MA); (3)
US Senator Ed Markey (D-MA); and (4) US Congresswoman Niki Tsongas (D-MA); (7) MA OIG –
specifically, MA IG Glenn Cunha; (8)The DOJ, including US Attorney General Jeff Sessions
and US Attorney Andrew Lelling (MA); (9) the FBI; and (10 AG Maura Healey (MA). A copy of this
email will be included with the mailed hardcopy to the Court as a matter of record (Exhibit 2).

Respectfully submitted,

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

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Plaintiff Response to 10-30-18 Land Court Hearing.pdf

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Exhibit 3
 CERTIFICATE OF SERVICE

I hereby certify that on November 13, 2018, I filed the foregoing with the Clerk of Court and
counsel for the Defendants (listed below) via email communication. Hardcopies will also be
delivered via US Mail to:

Jeffrey B. Loeb, Esq.

David E. Fialkow, Esq.

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
 TEXT BOX READS AS FOLLOWS:

I, Mohan A. Harihar, complainant in this case, state that the following is true to the best of my
knowledge and belief.

DEFENDANT: Judge Michael Vhay

CONTACT INFORMATION:3 Pemberton Square, Boston, MA 02108, 617.788.7470 (Phone)

ALLEGATIONS AND SUPPORTING FACTS: The crimes alleged against Judge Vhay are
identical (at least in part) to the evidenced claims brought against an UNPRECEDENTED 14
Federal judges associated with: (1) HARIHAR v. US BANK et al, Appeal No. 17-1381; (2)
HARIHAR v. THE UNITED STATES, Appeal No. 17-2074; and (3) HARIHAR v.
HOWARD, Docket No. 18-cv-11134.

The evidenced allegations conclusively show that (at minimum) Judge Vhay has exemplified a
PATTERN OF CORRUPT CONDUCT identical to that publicly exposed in related Federal
litigation; as it appears that the accused judge intends to reach a corrupt and PRE-
DETERMINED outcome. Based on the evidenced record, Judge Vhay has (at minimum)
exemplified: (1) a failure show impartiality; (2) a failure to uphold his judicial oath; (3) a failure
to uphold laws of the Commonwealth (and US Constitution), constituting JUDICIAL FRAUD
warranting immediate disqualification; (4) a failure to initiate corrective action; and (5)
continuing to rule without JURISDICTION. While a portion of the allegations warrant a
judicial misconduct complaint and incremental civil action, there are evidenced CRIMINAL
claims as well, including: (1) TREASON; (2) Judicial Fraud; (3) RICO viol; and (4) Due
Process viol. By these actions (or lack thereof) the accused is believed to have contributed to the
Misappropriation of a Trade Secret designed to assist the United States with economic
growth/repair associated with the US Foreclosure Crisis. The complainant believes that upon
further investigation, additional claims against Judge Vhay are likely. The Complainant
maintains the right to expand upon/file new claims.

Collectively, the severity of these evidenced allegations warrants regular updates to the
following Offices/Agencies/Courts: (1) POTUS; (2) SCOTUS; (3) DOJ; (4) FBI; (5) Gov.
Charlie Baker (R-MA); (6) MA Congressional Leaders – US Senator Elizabeth Warren (D-
MA), US Senator Ed Markey (D-MA) and US Congresswoman Niki Tsongas (D-MA).

STATEMENT OF PROBABLE CAUSE: The Complainant states that these (and other) facts
establish probable cause indicating that (at minimum) the following crimes have occurred: (1)
TREASON under ARTICLE III, Section 3; (2) 18 U.S. Code § 371 - Conspiracy to commit
offense or to defraud United States; (3) ECONOMIC ESPIONAGE (Economic Espionage
Act) 18 U.S. Code § 1831; (4) Fraud on the Court, under Fed./Mass. R. Civ. P. 60(b)(3); (5)
Due Process violations; and (6) RICO claims - 18 U.S. Code Chapter 96
Supporting Docs are part of the Court record(s) associated with the referenced State/Federal
litigation and include associated judicial misconduct complaints/petitions filed with the Office of
the Circuit Executive.