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IN THE UNITED STATES COURT OF APPEALS

FOR THE FIRST CIRCUIT

)
MOHAN A. HARIHAR, )
)
Plaintiff/Appellant, )
) Case No. 17-1381
v. )
)
US BANK, et al )
)
Defendants/Appellees. )
)

APPELLANT MOTION TO FIND JUDICIAL ORDER (DOCUMENT NO. 146) ISSUED


WITHOUT JURISDICTION

The Appellant, Mohan A. Harihar, acting pro se, respectfully files with this Court a motion to

find a judicial order from the lower US District Court VOID, and is believed to be ONE (1)

of SIX (6) orders - issued without jurisdiction by the presiding Judge Allison Dale

Burroughs. The referenced order was issued by Judge Burroughs on May 25, 2017 (Reference

Document No. 146). Specifically, the Appellant draws reference to the filed Motion with

Accompanying Affidavit for Permission to Appeal In Forma Pauperis (IFP), Document No.

145, filed April 20, 2017.

The Appellant has respectfully filed with the District Court a RESPONSE to the referenced

order (see Attachment A, Document No. 148). The filed response addresses the following

issues with the referenced order:


1. Treason to the Constitution, pursuant to Article III (6th Count);

2. Content of the Text within Document No. 146;

3. Continued Pattern of Corrupt Conduct;

4. Unnecessary Judicial Delay;

5. Re-affirming the Need to Assist with the Appointment of Counsel;

6. Continued Concerns for Personal Safety

After reviewing Document No.s 145 thru 148, the Appellant respectfully requests the

following actions:

1. Re-affirm that the Order associated with Document No. 146 is indeed VOID;

2. VALIDATE the list of issues referenced above, and as articulated in Document No. 148.

3. Acknowledge the reimbursement for referenced COSTS and LEGAL FEES due to the

Appellant, and instruct the Treasury Department to issue reimbursement, as requested.

Reimbursement to the Appellant is respectfully requested to be received on or before

June 10, 2017. Upon receiving reimbursement, the Appellant will arrange to make a

timely payment with the Clerk of the Appeals Court, as required.

4. Provide the Appellant with an update for the record, regarding the filed requests to the

Executive Branch/DOJ to: ASSIGN a Federal/Special Prosecutor, ASSEMBLE a Grand

Jury, and begin a full-Criminal Investigation.

Due to the severity of these civil/criminal claims, and also out of concerns for personal safety

and security, copies of this filed Motion are sent via email and/or certified mail to: The

Executive Office of the President (EOP), the US Inspector - General Michael Horowitz, US
Attorney General - Jeff Sessions, the House Judiciary Committee, and to the Federal Bureau of

Investigation (FBI). A copy will also be made available to the Public.

Respectfully submitted this 30th Day of May, 2017.

Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR CIVIL ACTION NO: 15-cv-11880

Plaintiff

vs.

US BANK NA, et al.

Defendants

RESPONSE TO JUDICIAL ORDER, DOCUMENT NO. 146, AND SIXTH (6TH)

ALLEGATION OF TREASON, PURSUANT TO ARTICLE III

The Plaintiff, Mohan A. Harihar, acting pro se, respectfully

files this RESPONSE to the judicial order, Document No. 146,

believed to have been issued WITHOUT JURISDICTION on May 25,

2017 by Judge Allison D. Burroughs. This order is considered

VOID, for reasons previously articulated - in this docket; in

the Judicial Misconduct Petition pending before the Judicial

Council of the First Circuit; and in filings now before the

Appellate Court. ALL related orders issued by Judge Burroughs

are too, considered VOID.


A copy of the referenced order, Document No. 146, reads as

follows:

Docket Text:

Judge Allison D. Burroughs: ELECTRONIC ORDER entered. Plaintiffs

Motion for Leave to Appeal In Forma Pauperis [ECF No. 145] is

granted because plaintiff has made an adequate showing that he

is without sufficient funds to pay the filing fee for appeal. I

decline to make any determination concerning whether this appeal

is taken in good faith. The Clerk shall transmit this Order to

the First Circuit Court of Appeals. (PSSA, 4)

The Judicial Misconduct Petition now before the Judicial Council

of the First Circuit reveals evidenced allegations, any one of

which will remove jurisdiction, once validated. These evidenced

allegations include (but are not limited to):

1. Treason to the Constitution, pursuant to Article III

(previously 5, now 6 counts);

2. Intellectual Property Rights Infringement and Economic

Espionage, Pursuant to 18 U.S. Code 1832;

3. Refusal to Assist with the Appointment of Counsel, 28 U.S.C.

1915;

4. Judicial Fraud on the Court;

5. Refusal to Recuse (2 Counts);


6. Violations of the Due Process Clause of the U.S. Constitution;

7. Ignoring evidenced Claims against the United States;

8. Judicial Prejudice/Bias;

9. Failure to maintain a Balance of Hardships and CAUSING

INCREASED HARDSHIP to the Plaintiff;

10. Unnecessary Judicial Delay; and

11. Color of Law violations

Now, considering the related list of serious claims evidenced

against Judge Burroughs, the conscious decision to AGAIN, issue

an order without jurisdiction warrants continued communication

to the following Offices/Agencies/Courts:

1. The Executive Office of the President (EOP);

2. The US Inspector General Michael Horowitz;

3. The US Attorney General Jeff Sessions;

4. The Federal Bureau of Investigation (FBI);

5. The Judicial Council of the First Circuit;

6. The US Court of Appeals for the First Circuit; and

7. The House Judiciary Committee.

By issuing the order associated with Document No. 146, the

following serious issues are additionally raised, showing cause


to expand upon existing claims against Judge Burroughs. They

include (but are not limited to):

1. Treason to the Constitution, pursuant to Article III - is

now evidenced for the sixth (6th) time, following an order

issued without jurisdiction.

2. Content of the Text within Document No. 146 EVEN IF,

Judge Burroughs still had jurisdiction to rule in this

matter, there are issues within the content of its text:

a. First, while Judge Burroughs rightfully acknowledges the

indigence of the Plaintiff, she has IGNORED line item six

(6), located on page 3 of the IFP form.1 Line item 6

states:

State every person, business or organization owing you and

your spouse money, and the amount owed.

Line item 6 CLEARLY identifies The UNITED STATES as a party

owing the Plaintiff/Appellant reimbursement for COSTS and

associated LEGAL FEES, totaling $12,309,420.00.2 The

1 Reference Document No. 145 to view the completed IFP - In Forma


Pauperis form.
2 As previously stated within the Docket, the Plaintiff/

Appellants Legal Fees continue to accrue at an hourly rate of


$1000 per hour, and will remain capped at 40 hours per week. The
TOTAL updated accrual due to the Plaintiff thru week ending June
Plaintiff/Appellant has CLEARLY ARTICULATED HIS SUPPORTED

ARGUMENT to this Court, to the Judicial Council, and to

the Appellate Court, justifying the reimbursement claim -

with NO VALID ARGUMENT on record to dispute the claim, or

why the reimbursement payment has not already been issued

by the Treasury Department. The Plaintiff/Appellant

respectfully waits for the Court (either the US District

Court, or the First Circuit Court of Appeals) to notify the

Department of the Treasury, so that payment can issue

without further delay - noting that as of May 30, 2017, no

payment has been received, and reimbursement costs continue

to accrue. Upon rightfully receiving reimbursement for

costs and associated legal fees as filed, the

Plaintiff/Appellant will be in a position to pay the

required $500 fee for his appeal. Therefore, EVEN WITH

JURISDICTION, ignoring line item 6 shows just cause to

expand upon existing judicial misconduct claims.

b. Second, Judge Burroughs states that she declines to make

any determination concerning whether this appeal is taken

in good faith.

10, 2017 will be $4,343,140 (includes previously reported


Transportation, Housing and Legal costs). The evidenced Acts of
Bad Faith by an officer of the Court acting on behalf of the
United States, warrant treble costs bringing the updated total
to $13,029,140, and is considered tax-exempt.
For over two (2) years, Judge Burroughs has presided over

this case, NEVER ONCE, questioning the good faith of the

Plaintiff/Appellant. Similarly, for over four (4) years

in Massachusetts State Courts NO presiding JUDGE has

EVER ONCE questioned the GOOD FAITH of the

Plaintiff/Appellant.

Now, in Document No. 146, Judge Burroughs states that she

declines to make any determination whether the appeal is

taken in good faith. While there is absolutely NO

justifiable reason to question the Good Faith of the

Plaintiff/Appellant through over six (6) years of

litigation, it is believed that the filed Judicial

Misconduct Complaint/Petition has perhaps prompted this

indirect attempt to somehow unfairly discredit him. The

judges statement shows cause to again expand upon

existing Judicial Misconduct claims.

The following conclusions are additionally made regarding

Judge Burroughs referenced statement:

a. The record shows that the Plaintiff/Appellant has

brought irrefutable claims alleging BAD FAITH ACTS

committed by the presiding Judge Allison D.


Burroughs. The Court is respectfully reminded that

since August 2016, Judge Burroughs HAS YET TO ADDRESS,

CHALLENGE, DENY or DEFEND ANY of these serious

allegations brought against her.

b. The list of evidenced judicial misconduct allegations

against Judge Burroughs is substantial, and includes

claims of Treason against the United States

Constitution. Any acknowledgment that the

Plaintiff/Appellant continues to act in good faith MAY

be held against her, as it pertains to these judicial

misconduct allegations;

c. Any UNFOUNDED suggestion that the Plaintiff/Appellant

has acted in BAD FAITH shows clear cause to expand

upon existing judicial misconduct claims.

d. Even if the referenced order is ultimately considered

VOID, the underlying insinuation within the judges

statement is completely unfounded, and contributes to

the existing claims against her.

3. Continued Pattern of Corrupt Conduct The issued order

associated with Document No. 146 demonstrates a Continued

PATTERN OF CORRUPT CONDUCT and an INCREMENTAL ACT of BAD

FAITH by an Officer of the Court - acting on behalf of the

United States. It further exemplifies the Judges CLEAR

INTENT to discredit, and cause irreparable harm and damages


to this Plaintiff/Appellant, and ultimately to the United

States as a whole. The clear ABUSE of JUSTICE is so

extensive, MENTAL ILLNESS should not be ruled out. While

these acts of judicial misconduct are clear and

irrefutable, further investigation is needed to determine

if Judge Burroughs has acted alone, or has perhaps COLLUDED

with other parties. Already, there is considerable concern

that misconduct extends BEYOND the US District Court,

citing the documented (and still uncorrected) OPINION of

Chief Justice Howard, of the First Circuit Appeals Court.

In addition to the pending Judicial Misconduct Petition, the

Plaintiff/Appellant awaits the Executive Branchs: 1.)

Appointment of A Federal/Special Prosecutor, 2.) Assembly

of a Grand Jury, and 3.) Start of a Full-Criminal

Investigation.

4. Unnecessary Judicial Delay Since the order associated

with Document No. 146 is believed to have been issued

without jurisdiction, there is just cause to expand upon

existing judicial misconduct claims that include (but are

not limited to) unnecessary delay and abuse of process/

judicial discretion.

5. The issued order associated with Document No. 146 re-

affirms the pending motion before the Appellate Court that

the Courts assistance with the Appointment of Counsel


continues to be warranted, pursuant to Title 28 U.S.C.

1915.

6. Plaintiffs/Appellants Concerns for Personal Safety

Continue to be IGNORED despite numerous efforts

documented throughout the record indicating concerns for

safety and security, these concerns have been completely

ignored by the District Court.

CONCLUSION

Based on the continued pattern of corrupt conduct exemplified in

the (VOID) order (Document No. 146) issued by Judge Allison Dale

Burroughs AND the related concerns stated within, it seems clear

that the presiding judge has no intention of accepting

accountability or taking corrective action here. Therefore:

1. The Plaintiff/Appellant necessarily updates the Executive

Office of the President, US Inspector General, US Attorney

General, House Judiciary Committee, the Judicial Council of

the First Circuit, and the First Circuit Court of Appeals;

2. A Motion is now filed with the Appellate Court to address the

concerns states within this response (Document No. 148).


3. A copy of the email communication delivered to the President,

DOJ and other referenced offices/agencies is attached for

documentation purposes, and as part of the record.3

4. A third supplemental Complaint is also filed with the Judicial

Council of the First Circuit.

5. Due to the continued concerns for personal safety and

security, a copy of this response is made available to the

public.

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.

3 See Attachment A
If the Court has ANY questions, or requires ANY additional

information or clarification, the Plaintiff is happy to provide

upon request.

Respectfully Submitted,

Mohan A. Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526
Mo.harihar@gmail.com
EXHIBIT A
From: Mohan Harihar <moharihar@gmail.com>
Date: Tue, May 30, 2017 at 10:33 AM
Subject: Re: HARIHAR v US BANK, 6th Claim of Treason alleged against Judge Allison Dale Burroughs
To: president@whitehouse.gov
Cc: NewYorkComplaints Dojoig <dojoig.newyorkcomplaints@usdoj.gov>, Civil.Feedback@usdoj.gov,
washington.field@ic.fbi.gov, boston@ic.fbi.gov

Dear Mr. President,

This email communication is necessarily delivered to your direct attention, as a sixth (6th) count of
Treason to the Constitution, pursuant to ARTICLE III has been alleged against US District Court
Judge - Allison Dale Burroughs (Reference Harihar v. US Bank, Docket No. 15-cv-11880, Boston,
MA, Document No.'s 145 thru 147). This latest allegation of Treason comes as a US District Court
Judge has again issued an order without having the jurisdiction to do so. As the Plaintiff/Appellant, I have
respectfully filed a RESPONSE to the order (Document No. 147). Since this matter has transitioned to
the US Court of Appeals (First Circuit, Docket No. 17-1381), a motion will be filed to inform the Court of
this latest judicial misconduct allegation(s), and additional concerns. A THIRD supplement to the Judicial
Misconduct Petition now before the Judicial Council of the First Circuit will also be submitted.

Mr. President - as follow-up to the email communication from April 17, 2017, I respectfully request an
update from the DOJ regarding: 1.) The Assignment of a Federal/Special Prosecutor, 2.) The
Assembly of a Grand Jury, and 3.) Opening of a full, criminal investigation. Please note, for
documentation purposes and as part of the record, a copy of this email communication is filed with the
related US District Court and Appellate Court Dockets, and additionally with the Judicial Council of the
First Circuit.

Mr. President - Thank you for your time and consideration of this very serious matter. I look forward to
your response.

GOD BLESS THE UNITED STATES OF AMERICA!

Most respectfully,

Mohan A. Harihar
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
CERTIFICATE OF SERVICE

I hereby certify that on May 30, 2017 I electronically filed the foregoing with the Clerk of Court
using the CM/ECF System, which will send notice of such filing to the following registered
CM/ECF users:

Jeffrey B. Loeb
David Glod
David E. Fialkow
Kevin Patrick Polansky
Matthew T. Murphy
Kurt R. McHugh
Jesse M. Boodoo

Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com