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FOR IMMEDIATE RELEASE

Increasing Concerns Surrounding MA Foreclosure Case


Now Brought to Massachusetts Supreme Judicial Court.

Boston, MA, September 14, 2014 The troubling Massachusetts foreclosure case which
continues to gain National and Global attention is now headed to the MA Supreme Judicial Court,
as Further Appellate Review (FAR) has been filed by Wrongfully Foreclosed Homeowner
Mohan A. Harihar.

The well documented and well supported list of concerns by Mr. Harihar, continues to question
whether or not corrective action is attainable within the Commonwealth. The growing list of
concerns include: Confirmation of Fraudulent Mortgage Assignments by Fraud Expert -
Lynn Syzmoniak, Irrefutable 14
th
Amendment infractions to Due Process and Equal
Protection Rights, Perjury, Fraudulent Concealment/Misrepresentation, Deceptive
practices including Fraud, Aiding and Abetting Fraud, Collusion/irrefutable conflict within
this matter, and multiple abuses of Judicial discretion. The most recent concern, involves the
MA Appeals Court decision allowing the validation/affirmation of information on file with the Court
to take place, then changing direction without cause, and refusing to clarify their decision. And
while the Appeals Court has granted leave for Mr. Harihar to file for new trial, the collective, and
growing concerns question whether a fair and just trial is possible.

The documented civil and criminal misconduct associated with this 3+ year legal matter involves
multiple parties including: US Bank NA, Wells Fargo NA, the Securitized Mortgage Trust
CMLTI 2006-AR1, Harmon Law Offices PC, and Nelson Mullins LLP. Recently updated
Criminal complaints have been sent directly to the attention of Attorney General Martha
Coakley. There has yet to be a response regarding mediation efforts to resolve the criminal
portion of this matter.

A Mediation effort is now similarly requested with the filling of the FAR Application with the
Massachusetts SJC. Scroll down to view a copy of the filed FAR Application in its entirety.

Mr. Harihar has consistently maintained the intention to hold ALL responsible parties accountable
for their associated misconduct, while providing a framework which assists the 4.2M other parties
harmed by this foreclosure/financial crisis*, and also assisting the DOJ with a path for future
prosecution.

* This Framework is a reference to a project(s) involving the intellectual property belonging to Mohan A. Harihar, designed to assist this Nations and overall
Global Economic recovery from damages suffered by the US Foreclosure/Financial Crisis.

For Further Media Information Contact : Mohan A. Harihar
Email: mo.harihar@gmail.com
Phone: 617.921.2526 (Mobile)

Follow on Twitter:
Mohan Harihar@Mo_Harihar
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Commonwealth of Massachusetts

Supreme Judicial Court




Docket No. 2013-P-1829

_________________________________________

Mohan A. Harihar
Appellant

vs.

US Bank NA, Wells Fargo NA, CMLTI 2006-AR1,
Harmon Law Offices PC
Appellees
__________________________________________

FAR Application From A Judgment Of The
MA Appeals Court

__________________________________________

Argument For The Appellant

____________________________________________



Mohan A. Harihar
Pro Se
168 Parkview Avenue
Lowell, MA 01852
617.921.2526 (Mobile)
Mo.harihar@gmail.com



3
Statement of Prior Proceedings
This matter pertains to a 3 year Foreclosure case which
has been irrefutably associated with this Nations
Foreclosure/Financial Crisis. Since the initial rulings of
the Lower Court(s), substantial new information and new
evidence has, and continues to come forth in support of the
Appellants consistent claims of both civil and criminal
misconduct against Appellees US Bank NA, Wells Fargo NA,
the Securitized Mortgage Trust CMLTI 2006-AR1, and Harmon
Law offices PC.
1
The Massachusetts Appeals Court agreed,
recently granting leave to the Appellant to file for new
trial.
2

Since inception, and consistently thereafter, the Appellant
has expressed clear concern regarding the accuracy,
availability and integrity of information provided by
Appellees which has either been inaccurate, unsupported, or

1
Civil and criminal misconduct against Appellees US Bank
NA, Wells Fargo NA and the Securitized Mortgage Trust CMLTI
2006-AR1 now additionally includes confirmation of
fraudulent mortgage assignments identified by Fraud Expert,
Lynn Syzmoniak, including declarations and testimony from
Case Nos: 10-bk-21656 DCN, United States Bankruptcy Court
for the Eastern Division of California Sacramento Division;
Also C.A. No. 10-cv-01465-JFA, United States District
Court, District of South Carolina, Rock Hill Division
2
See Docket 2013-P-1829, RE#19: Appellant is granted leave
to file for new trial, dated 07/01/2014.
4
where Appellees have refused to provide requested Discovery
evidence entirely.
To ensure the accuracy, integrity, and availability of
information prior to the commencement of a new trial, the
Appellant requested to initiate a validation/affirmation
process. The Court agreed, allowing the Appellant to file a
motion requesting affirmative relief.
3
A motion was filed by
the Appellant, itemizing the necessary and very basic
requests for validation, to ensure the accuracy and
integrity of information available and on file with the
Court.
The MA Appeals Court then changed direction and DENIED the
Appellants motion, without cause. A motion requesting
Clarification and Reconsideration was then filed by the
Appellant. The MA Appeals Court DENIED this request for
clarification, which is the primary reason for filing this
request for Further Appellate Review (FAR), and clearly
signifies an abuse of judicial discretion.
There are a number of serious historical concerns related
to this matter, as detailed in the associated Appellant

3
See Docket 2013-P-1829, RE#22: To the extent that
Plaintiff seeks affirmative relief, he may file appropriate
motions in any case that is pending in this Court.
5
Brief, Reply Brief, etc These documented and supported
concerns already filed with the Court(s) include (but are
not limited to): Irrefutable 14
th
Amendment infractions to
Due Process and Equal Protection Rights, Perjury,
Fraudulent Concealment/Misrepresentation, Deceptive
practices including Fraud, Aiding and Abetting Fraud,
Collusion/irrefutable conflict within this matter, and
multiple abuses of Judicial discretion. These collective
concerns now warrant the involvement of the MA Inspector
General and question whether or not a corrective path is
attainable within this Commonwealth. It additionally
reveals that Appellees, who have claimed ZERO related
misconduct, have historically LIED to this Court, and every
Court related to this matter. If a corrective path is
attainable, it must begin with the accuracy, integrity, and
availability of the facts in order to proceed.
Most recently, it has been discovered that Fraud Expert
Lynn Syzmoniak, has confirmed misconduct including (but not
limited to) fraudulent mortgage assignments associated with
Appellees US Bank NA, Wells Fargo NA, and the Securitized
Mortgage Trust CMLTI 2006-AR1.
4


4
C.A. No. 10-cv-01465-JFA, United States District Court,
District of South Carolina, Rock Hill Division
6
This Appellant has afforded numerous opportunities to these
Appellees to seek mutual agreement, all of which have been
either denied or ignored. If the continued insistence by
these parties is to ignore these opportunities, and to
instead continue causing harm and accruing damages to this
Appellant, both civil and criminal accountability is
undoubtedly warranted. This Appellant maintains the hope
that a corrective path is still attainable within this
Commonwealth. However, the collective concerns question
whether this can be achieved in the lower Court(s) or even
the MA Appeals Court. If a corrective path appears
unattainable within this Commonwealth, preparations are
being made for transfer to Federal Court via Writ of
Certiorari and/or Congressional Petition.
Criminal complaints related to the documented misconduct
have been recently updated with the MA Office of the
Attorney General. A request for mediation has been made, in
effort to reach a mutual agreement between parties, as it
pertains to the criminal portion of this matter. Separate
communication was additionally sent directly to the
attention of MA Attorney General Martha Coakley. Since the
misconduct associated with this matter is believed to bring
increased risk/infringement to the Appellants intellectual
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property, and a project(s) designed to assist this Nations
and overall Global Economy, additional parties copied on
the AGs communication include: Vice President Joe Biden,
the Office of the MA Inspector General, US Senator
Elizabeth Warren (MA), US Senator Ed Markey (MA), Governor
Deval Patrick (MA), US Congresswoman Niki Tsongas (MA), the
US Attorneys Office, the Consumer Financial Protection
Bureau (CFPB), the American Civil Liberties Union (ACLU),
and the Managing Partners of Nelson Mullins LLP.

Statement of the Facts
1. Consistent requests by the Appellant for basic
validation have historically either been ignored or
denied.
2. An overwhelming amount of information and evidence
supporting the Appellants consistent claims already
on file.
3. Clear disconnect between Appellees US Bank NA/Wells
Fargo NA and Appellee Harmon Law Offices PC.
4. Irrefutable 14
th
Amendment infractions to Due Process
and Equal Protection Rights.
8
5. Documented Concerns of Collusion and Irrefutable
Conflict involving the MA Attorney Generals Office,
the US Attorneys Office and counsel for the Appellees
Nelson Mullins LLP.
6. Appellees have failed to provide a single case example
with equivalent circumstances to justify argument.
7. Nationally recognized Fraud Expert confirms fraudulent
mortgage assignments associated with RMBS CMLTI 2006-
AR1.
8. Recent related $1.125B settlement between Citigroup
and includes Appellees US Bank NA, Wells Fargo NA and
CMLTI 2006-AR1 is revealed.
9. Increased Risk/Infringement to the Intellectual
property of the Appellant directly related to this
matter.
10. The Leaders of this Commonwealth recognize the
significant harm and damages to Wrongfully Foreclosed
Homeowners.
11. Northeast Association of Realtors to Address
Ethics Violations.


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Statement of the points with respect to which FAR is sought
Since the MA Appeals Court has granted the Appellant
Mohan A. Harihar, leave to file for new trial, the primary
reason for requesting FAR within this Court is to ensure
that ALL the facts related to this case are available and
accurate to render a fair and just decision. The sudden
change in direction by the MA Appeals Court, pertaining to
validation/affirmation and availability of relative
information and evidence raises serious concerns; The
refusal to Clarify decision(s) is of considerable concern,
signifying clear abuse of judicial discretion, with
multiple occurrences throughout this 3+ year legal effort,
which is also tied to irrefutable 14
th
Amendment infractions
to Due Process and Equal Protection Rights of the
Appellant, stemming from the Northeast Housing Court.
Argument
1. Consistent requests by the Appellant for basic
validation have historically either been ignored or
denied.
To ensure accuracy of information, validation efforts
by this Appellant have been made throughout these
three (3) plus years of legal proceedings in all
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Court(s), resulting in either a denial, or simply
ignored entirely. These requests include: the
availability of recorded conversations during the 22-
month loan modification attempts between Appellee
Wells Fargo NA and Appellant Mohan A. Harihar;
Validating Chain of Title as Leaders of Massachusetts
have acknowledged issues with over 65,000 Titles
within this Commonwealth; Validating signatures on
file as Forgery has been identified as a major
component of this US Foreclosure Crisis; Refusal by
Appellees to complete a validation questionnaire,
clarifying information submitted by counsel on file
with the Court(s).
This is a mere sample of basic validation which should
have been not only allowed, but confirmed prior to any
summary judgment or eviction.
2. An overwhelming amount of information and evidence
supporting the Appellants consistent claims already
on file.
Misconduct associated with the referenced foreclosure
has been confirmed by both the MA Attorney Generals
Office as well as Federal Bank Regulators; April 2011
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Report by Federal Bank Regulators confirming related
misconduct by Appellees Wells Fargo NA and US Bank
NA; Admission by Appellee Harmon Law Offices PC (and
initial counsel to US Bank NA) that the Appellants
claims are VALID
5
; December 2011 Complaint filed with
Suffolk County Superior Court by the MA Attorney
General on behalf of the Commonwealth against parties
which include Appellee Wells Fargo NA
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; the
documented 150 page Foreclosure Manual of Appellee -
Wells Fargo NA.
3. Clear disconnect between Appellees US Bank NA/Wells
Fargo NA and Appellee Harmon Law Offices PC.
7

Appellee Harmon Law Offices failure to file ANY
Appellee Brief or Opposition related to this matter

5
Lowell District Court Transcripts, Docket No:
201111SU001495
6
Docket BLS 11-4363; In this action, the Commonwealth of
Massachusetts seeks restitution, civil penalties and
injunctive relief -for violations of M. G. L. c. 93A
arising out Defendants' unfair and deceptive acts during
the height of the foreclosure crisis in Massachusetts A
complete copy of the complaint in its entirety will be
provided to the Court upon request.
7
See - Docket No. 12-P-407, Harmon Law Offices vs. Attorney
General, filed with the MA Appeals Court. A recent
unanimous ruling by this Appeals Court affirmed a 2011
Suffolk Superior Court decision allowing the MA Attorney
Generals office to continue examining Harmon Law Offices
for alleged unfair and deceptive acts related to the
firms foreclosure and eviction work.

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exemplifies lack of alignment and disconnect, clearly
questioning the accuracy and validity of information
filed by Appellees US Bank NA, Wells Fargo NA, and the
Securitized Mortgage Trust CMLTI 2006-AR1.
8

4. Irrefutable 14
th
Amendment infractions to Due Process
and Equal Protection Rights.
This Appellant seeks the acknowledgment by the
Court(s) regarding the infringement of Constitutional
Rights, specifically, 14
th
Amendment infractions to Due
Process and Equal protection rights. It is well
documented and involves the Northeast Housing Court
and their failure/refusal to process this Appellants
Notice of Appeal. This fact is irrefutable, and it has
been ignored by the Court(s), signifying an abuse of
judicial discretion, and questioning whether fair
resolution in the Commonwealth can be achieved, or if
transfer to Federal Court is deemed necessary.


8
Harmon Law Offices PC, who has been directly linked to
disbarred Foreclosure Kingpin David Stern, is the
originally retained counsel to US Bank in this matter, has
intricate knowledge of this matter, and who withdrew as
counsel as the MA Attorney General began their
investigation against them.
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5. Documented Concerns of Collusion and Irrefutable
Conflict involving the MA Attorney Generals Office,
the US Attorneys Office and counsel for the Appellees
Nelson Mullins LLP.
West LegalEdcenters course entitled, After the
Bubble Bursts: Mortgage and Foreclosure Issues in
Criminal and Civil Litigation, where the Content
Partner is the Boston Bar Association; Program Co-
Chairs are from Nelson Mullins Riley and Scarborough
LLP, and the US Attorneys Office; Program Speakers
are from Nelson Mullins Riley and Scarborough LLP, and
the US Attorneys Office, and the MA Attorney
Generals Office.
There has yet to be ANY Denial or even a response from
ANY party, refuting what is a clearly documented
example of Collusion and Conflict with this matter.
Should Criminal and/or Civil mediation efforts fail,
or new trial becomes necessary, special prosecutor(s)
are clearly warranted and necessary for future
proceedings. These concerns additionally necessitate
the involvement of the MA Inspector General.
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6. Appellees have failed to provide a single case example
with equivalent circumstances to justify argument.
The Appellant respectfully brings to this Courts
attention, that upon review of the supporting cases
submitted over three (3) years by the Appellee(s),
there does not appear to be one (1) example provided,
which reflects 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 case decision, in this Commonwealth, or
any state in the Nation, which articulates and
provides justification in lieu of documented civil and
criminal misconduct, collusion, conflict and the
confirmation of Fraud by a Fraud Expert. Therefore,
all such related arguments by Appellees, and their
impact to ALL related decisions, respectfully, should
be considered VOID. Any continued argument by opposing
parties attempting to claim ZERO misconduct, further
justifies civil and criminal accountability.
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7. Nationally recognized Fraud Expert confirms fraudulent
mortgage assignments associated with RMBS CMLTI 2006-
AR1.
The Appellants recent discovery reveals that Fraud
Expert Lynn Syzmoniak has identified fraudulent
mortgage assignments, False Claims, etc - including
(But not limited to) Massachusetts False Claims Act,
Mass. Ann. Laws ch. 12, 5(A)-(0) against Appellees
US Bank NA, Wells Fargo NA and the RMBS CMLTI 2006-
AR1. Should it become necessary to move forward with
new trial, the Appellant will call upon the Fraud
Expert to assist with articulating the depth of
associated misconduct by these parties.
8. Recent related $1.125B settlement between Citigroup
and includes Appellees US Bank NA, Wells Fargo NA and
CMLTI 2006-AR1 is revealed.
The details leading up to and including the decision
by Appellee US Bank NA to file suit against Citigroup
and the associated Trust RMBS CMLTI 2006-AR1,
resulting in a $1.125B settlement between parties
signifies clear admission by the Appellee(s) that in
fact, there is misconduct associated with this matter.
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9. Increased Risk/Infringement to the Intellectual
property of the Appellant directly related to this
matter.
It is well documented that this matter is directly
related to a project(s) considered to be the
intellectual property belonging to the Appellant
Mohan A. Harihar, created to assist the United States
and overall Global Economic recovery from the US
Foreclosure/Financial Crisis. Any party responsible
for, or contributing to increased risk or infringement
to this intellectual property is subject to future
legal action.
10. The Leaders of this Commonwealth recognize the
significant harm and damages to Wrongfully Foreclosed
Homeowners.
State legislators of this Commonwealth acknowledge not
only the related harm and damages suffered by
homeowners, but also the fact that 65,000 home titles
are considered invalid, and agree that the homeowner
should be allowed to file suit to recoup damages
incurred. If this 3+ year collective legal effort is
unsuccessful in even the validation of information,
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what chance is there of this, or any homeowner,
successfully recovering ANY appropriate amount for
damages incurred by the harm caused? What precedent
does it set, and what message does it send to
homeowners throughout this Commonwealth and across
this Nation?
11. Northeast Association of Realtors (NEAR) to
Address Ethics Violations.
Deceptive acts by Appellees and the associated Real
Estate Broker, Weichert Realtors Daher Companies in
Methuen, MA, appear to continue with the attempted re-
sale of the referenced foreclosure. After reviewing
the Ethics complaint filed by the Appellant, the NEAR
Grievance Committee agreed - violations to the
National Associations of Realtors (NAR) Code of Ethics
may exist, and a hearing is now in the process of
scheduling.
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These collective concerns respectfully call for corrective
action by this Court.


9
A copy of the Ethics Complaint is filed with the MA
Appeals Court, and will be provided to the MA SJC upon
request.
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Conclusion
The request to validate information, prior to making ANY
decision, whether it is Court related or not, is a matter
of Common Sense. For the Appeals Court to allow validation/
affirmation, change direction and deny without cause, then
refuse to clarify, reaffirms this Appellants collective
concerns whether a fair resolution is attainable in the
Commonwealth of Massachusetts. It also signifies clear
abuse of judicial discretion. The lengthy list of
documented misconduct, which now includes confirmation by a
Fraud Expert, demonstrates beyond ANY doubt, that these
Appellees and their retained counsel have blatantly LIED to
this, and every Court associated with this Matter. The
Appellee stance which for over three (3) years has claimed
ZERO MISCONDUCT, is a blatant lie, and must no longer be
allowed to continue.
With updates to criminal complaints now filed with the MA
Attorney Generals Office, mediation has now been requested
to seek resolution, as it pertains to the associated
criminal misconduct of the Appellees and their retained
counsel. With the amount of collective concerns brought to
this Courts attention, similar action is requested as it
pertains to the related civil misconduct of the Appellees.
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The Appellant respectfully requests an order for mediation
in effort to reach a mutually agreed upon solution.
Otherwise, the Appellant requests that a thorough
validation process, as previously detailed in the Motion
submitted to the Appeals Court, be initiated.
10
Following a
recap of the validation process, a determination will be
made whether filing for new trial proceeds in MA State
Court, or if transfer to Federal Court is deemed necessary.
Additionally, if mediation is unsuccessful or is not an
allowable option, the Appellant calls for Appellees and
their retained counsel to be held accountable for numerous
counts of perjury. The Court is also asked to update the MA
Board of BAR Overseers/BAR Counsel to address supported
complaints already filed against Attorney David E. Fialkow,
and Attorney Peter Haley (both of Nelson Mullins Riley and
Scarborough LLP), and Harmon Law Offices PC. An additional
complaint will be filed against Attorney Jeffrey Patterson,
also of Nelson Mullins Riley and Scarborough LLP.
With regard to the referenced foreclosed property, an
additional order is requested for the property to be taken
off the market, as this legal matter proceeds and to also

10
A copy of the filed Motion requesting Validation/
Affirmation will be provided upon request.
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protect potential homebuyers and other real estate
professionals from potential future legal risk; and that
this Court correct the wrongful displacement of the
Appellant, Mohan A. Harihar, who is still homeless, and
should not be. The Appellant requests that ALL costs
associated with this wrongful displacement be reimbursed by
the Appellees.
If the Court has additional questions, needs additional
information to be provided, or requires separate motions to
be filed for the requests stated within, please advise.
Due to the growing complexity of this matter, copies of
this FAR Application are additionally sent to the following
parties: Vice President Joe Biden, the Office of the MA
Inspector General, US Senator Elizabeth Warren (MA), US
Senator Ed Markey (MA), Governor Deval Patrick (MA), US
Congresswoman Niki Tsongas (MA), MA Attorney General Martha
Coakley, the US Attorneys Office, the Consumer Financial
Protection Bureau (CFPB), and the American Civil Liberties
Union (ACLU).


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Respectfully Submitted,
Mohan A. Harihar
Pro Se
168 Parkview Avenue
Lowell, MA 01852














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Judgment on Appeal

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