Академический Документы
Профессиональный Документы
Культура Документы
for the
DISTRICT OF MASSACHUSETTS
)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. 17-cv-11109
v. )
)
THE UNITED STATES OF AMERICA, )
)
Defendant )
)
The Plaintiff, Mohan A. Harihar, a pro se litigant with no legal experience, respectfully files this
REPLY after a DISQUALIFIED judicial officer – acting on behalf of The United States issued
an incremental (VOID) order without jurisdiction. The Plaintiff references the following court
Amend Complaint. Given D. 14,15, prior dismissal of complaint, Court of Appeals affirming
same over a year ago, D. 207, there is no complaint to amend and this case remains closed.
(Hourihan, Lisa)”1
1
See Exhibit 1
In the Plaintiff’s original motion, the Court is respectfully reminded that US District Court
Judge – Hon. Denise J. Casper has already LOST jurisdiction to rule further in this or ANY
related litigation, for the SAME IDENTICAL reasons that brought the sua sponte recusal of
the Hon. Allison Dale Burroughs.2 A review of the historical record shows that the Plaintiff has
articulated the evidenced FACTS that clearly support his position – including a VOID Dismissal
order associated with this complaint (Reference ECF No.’s [13], [14], [15] and [16]). Therefore,
jurisdiction has NOT yet been restored. Respectfully, the conscious decision to continue
ruling without jurisdiction shows cause to now bring incremental misconduct claims against
Judge Casper including (but not limited to): (1) Judicial Treason under ARTICLE III and 18
U.S.C. § 2381. Serving as witnesses to this evidenced act of Judicial Treason (aside from the
Plaintiff) is counsel for the Defendant – The United States, Assistant US Attorney Mary
Murrane and Clerk of the Court Lisa Hourihan; (2) Judicial Fraud on the Court claims
under Fed. R. Civ. P.60(b)(2),(3), (4) and (6); (3) Color of Law Violations under 18 U.S.
Code § 242; (4) Due Process and other claims. Separately, since Judge Casper is a judicial
officer acting on behalf of The United States, the Plaintiff AGAIN shows cause to amend his
original complaint.
2. Judge Casper has REFUSED to recuse herself - despite the evidenced allegations of
record that immediately disqualify her from ruling further in this (or any related)
litigation;
2
See Exhibit 2
3. The Dismissal Order is VOID – Therefore, the case is still OPEN;
4. The District Court’s failure to VACATE orders following the sua sponte RECUSAL
of Judge Allison Dale Burroughs and the unprecedented EIGHT (8) related recusals
5. The RECUSALS of the initial First Circuit Panel assigned to this Appeal – which
included Circuit Judges: (1) Hon. Juan R. Torruella; (2) Hon. William J. Kayatta, Jr.;
and (3) Hon. David J. Barron. As a respectful reminder, these recusals resulted from the
that brought the recusal(s) of the initial panel and Judge Burroughs. This replacement
panel consisted of: (1) Chief Judge – Hon. Jeffrey R. Howard; (2) Circuit Judge –
Hon. O. Rogeriee Thompson; and (3) Circuit Judge – Hon. Kermit V. Lipez. The
conscious decision by the replacement panel to brush aside all of the Appellant’s
evidenced claims and issue a VOID order without jurisdiction ultimately showed the
Federal law, the Appellant similarly brought evidenced Judicial Treason claims under
ARTICLE III and 18 U.S.C. § 2381 - updating the White House, members of Congress,
as well as the Office of the First Circuit Executive and the Administrative Office of
US Courts. The failure to acknowledge these facts of record re-affirm the systemic
for impeachment and potential removal from the bench under ARTICLES II & III.
updated throughout the 8-year history of this litigation – along with the demand to bring
these systemic judicial failures to the immediate attention of the House and Senate
Judiciary Committees. Informed Congressional leaders include (but are limited to): (1)
Senator Ed Markey (D-MA); (3) US Congresswoman Lori Trahan (D-MA); and (4)
legal issues associated with this litigation has provided a TEXTBOOK example to
exercise judicial discretion under 28 U.S.C. § 1915, by assisting the Plaintiff with the
appointment of counsel. This continued failure is a contributing factor that re-affirms the
systemic judicial abuses plaguing this First Circuit; and what appears as complete disdain
9. The Plaintiff awaits a response from the Office US Attorney General - as a sign of his
continued Good Faith, the Plaintiff has respectfully extended an opportunity to have a
mutual agreement discussion – with US Attorney General Barr and the EOP
(Executive Office of the President) regarding the civil portions associated with this
complaint.3 Ultimately, the Plaintiff believes there exists an opportunity to reach a mutual
agreement that is both constructive and which contributes to the overall benefit of our
great Nation.
3
See Exhibit 3 - Referencing the Plaintiff email directed to the attention of UA Attorney General William Barr.
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 REPLY: (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
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 REPLY otherwise complies with the requirements of Rule 11.
Please be advised, the referenced litigation is related to a new complaint now being
prepared for filing in The United States Court of Federal Claims; and includes matters
committees will necessarily receive copies of this formal letter (via email, US Mail and/or social
media):
Copies of this REPLY will also be made available to the Public and to media outlets nationwide
4
See Exhibit 4 to review to the email confirmation of receipt from the White House.
for documentation purposes and out of continued concerns for the Plaintiff’s personal safety
and security. Once jurisdiction has been re-established, If the Court has ANY questions
regarding any portion of this REPLY, or requires additional information, the Plaintiff is happy to
provide upon request. The Plaintiff is grateful for the Court’s consideration of this very serious,
Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
Exhibit 1
Exhibit 2
Exhibit 3
Mohan Harihar <moharihar@gmail.com>
I respectfully request that you forward this email to the direct attention of US Attorney General
William Barr, as numerous efforts to communicate with the US Attorney's Office in the District of
Massachusetts are apparently being ignored. Since you have historically been copied on multiple
email communications related to the referenced litigation (Attached Below), you are aware of the
systemic judicial failures evidenced by the First Circuit, including the Office of the First Circuit
Executive. A portion of these evidenced failures include (but are not limited to): (1) Judicial Treason;
(2) Economic Espionage; (3) RICO violations; (4) Color of Law/Due Process violations - and a
host of others. The most recent examples have been evidenced by RECUSED US District Court
Judge - Hon. Allison Dale Burroughs, who issued two (2) orders without jurisdiction on 7/29/19 and
8/2/19 (Referencing HARIHAR v US BANK et al, Docket No. 15-cv-11880, See Below) and included
the threat of sanctions against the Plaintiff.
After updating my judicial misconduct complaint filed with the Circuit Executive, I received a letter
(dated 8/21/19, attached below) which stated that I was no longer allowed to report judicial
misconduct - including evidenced acts of Treason against The United States of America. Due
to the severity of these evidenced claims, I respectfully request that you now bring these recent
developments to the direct attention of US Attorney General William Barr - as they include
evidenced criminal violations by judicial officers and are perceived to impact matters of National
Security.
Copies of this letter will also be made available to the Public and to media outlets nationwide for
documentation purposes and out of continued concerns for the Plaintiff's personal safety and
security. If you have ANY questions regarding any portion of this email, or require additional
information, I will be happy to provide upon request.
Thank you for your attention to this very serious matter. I look forward to a response from the
Attorney General.
Respectfully,
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
mo.harihar@gmail.com
Exhibit 4