FOR IMMEDIATE RELEASE

Plaintiff in Harihar vs. US Banks files $10M Demand for

costs/fees and Judicial BAD FAITH Acts
Boston, MA, January 7, 2017 If the incoming TRUMP Presidential administration wishes to Drain
the Swamp, the facts surrounding Harihar vs. US Bank, et al will certainly need to be added to the
list for review, and investigation.
The Plaintiff is Mohan A. Harihar - who has acted as a pro se litigant for nearly 6 years. The
litigation, which began in 2011 in Lowell District Court over an ILLEGAL FORECLOSURE, made its
way to Federal Court in 2015 (Harihar vs. US Bank, et al, Docket No. 2015-cv-11880, US District
Court, Boston, MA).
Harihars civil complaint addresses a number of well-supported allegations beyond the illegal
foreclosure (alleged) including infractions involving (but not limited to): Intellectual Property rights,
RICO violations, Fraud, Conspiracy claims, and most recently the Judicial Misconduct of a US
District Court Judge. Right now, Harihar is seeking reimbursement from the United States for a portion
of the irrefutable BAD FAITH acts committed against him by the presiding judge Allison D.
Burroughs. The reimbursement sought here pertains to Balance of Hardships and Legal Fees, and
has been calculated to include TREBLE damages for acts made in bad faith.
In his filed DEMAND, Harihar also re-states his everyday concerns for safety and well-being. The
allegations within his civil complaint continues to expose government corruption at state and federal
levels. Both the Department of Justice (DOJ) and the Massachusetts Office of the Attorney
General are on record as stating that they WILL NOT PROSECUTE the evidenced criminal
misconduct committed against Mr. Harihar, an American-born citizen. Now, on top of that, Harihar
necessarily addresses multiple acts of judicial misconduct (alleged) in order to move litigation forward
that will certainly impact this Nations Economy in historic fashion.
Mr. Wahlberg, Mr. Affleck, Mr. Damon if any of you are looking for your next film project, its right
here in your backyard of Boston.
(Scroll down to view a copy of Harihars filed Motion, in its entirety.)
For Further Media Information Contact: Mohan A. Harihar
Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR

CIVIL ACTION NO: 15-cv-11880

Plaintiff
vs.
US BANK NA, et al.
Defendants

PLAINTIFF DEMAND FOR PAYMENT PURSUANT TO 45 CFR 30.11

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

files this DEMAND for PAYMENT from the UNITED STATES, for COSTS
and FEES, as described in Document No. 128, and pursuant to
Code of Federal Regulations 45 CFR 30.11. The Plaintiff has
already brought to the attention of the Court, the supported
allegations of JUDICIAL MISCONDUCT and BAD FAITH ACTS believed
to have been committed with malicious intent against him by an
officer of the Court.1 In addition, the Plaintiff respectfully
reminds the Court of the following:

Pattern of Corrupt Conduct Since filing the initial

complaint with the Court on May 21, 2015, the Plaintiff has
necessarily brought a number of judicial misconduct allegations
against the presiding Judge Allison D. Burroughs. These
fully-supported allegations are all on record with this US
1

1. The Plaintiffs interpretation of the Law is that the

(still) presiding Judge Allison D. Burroughs no longer
has jurisdiction and has been disqualified to rule in this
litigation. Therefore, ALL related orders issued by Judge
Burroughs are considered VOID.
2. In nearly five (5) months since raising allegations of
judicial misconduct against Judge Allison D. Burroughs,
not a single one of the fourteen Defendants have
challenged or opposed these well-supported allegations.
That includes the Bank Defendants, the Defendant - Law
firms and attorneys, the Defendant - RMBS Trust, Defendant
Real Estate Brokers and Defendant Purchasers of the
referenced illegal foreclosure. Even the Commonwealth of
Massachusetts and its former Attorney General have not
made a single effort to challenge or oppose the evidenced
allegations of judicial misconduct and BAD FAITH ACTS
disqualifying Judge Burroughs.
3. Judge Burroughs herself has yet to address, deny, or
defend these allegations of judicial misconduct which now
includes three (3) allegations of Treason to the
Constitution. Any attempt to rule on (for or against) this
Demand for Payment by Judge Burroughs will similarly be

District Court, and are also before the Judicial Council of the
First Circuit.
3

interpreted as an incremental FOURTH act of TREASON, and a

VOID/NULL order.
4. Since the order associated with Document No. 129 is
considered VOID, and there is NO OPPOSITION FILED by a
single Defendant OR the United States, the Plaintiff
interprets that the referenced motion filed with the Court
stands as UNOPPOSED. Therefore, the Court SHOULD grant
payment to the Plaintiff for referenced costs and fees,
payable by the United States. Furthermore, the malicious
intent of Bad Faith acts against this Plaintiff warrants
TREBLE damages, and is considered tax-exempt. Efforts made
by ANY party to prevent the Plaintiff from rightfully
receiving this reimbursement will be interpreted as an
attempt to cause further harm and damage(s) to the
Plaintiff.
5. The relief sought here by the Plaintiff is considered
separate from the damages sought with the initial
complaint. It additionally represents only a portion of
the alleged bad faith acts committed against him.2 The
Plaintiff reserves the right to amend the existing
complaint as needed, so that ALL related and evidenced
infractions can also be addressed.
This Demand for Payment address alleged bad faith acts
committed by the United States against Plaintiff Mohan A.
Harihar, as it relates to Balance of Hardships and Legal Fees.
2

6. The Court has already been informed that the Plaintiffs

legal fees will continue to accrue until either:
a. The Plaintiff is successful in retaining legal
counsel on his own;
b. The Plaintiff is successful in retaining counsel with
the assistance of the Court; or
c. A mutual settlement agreement is reached between ALL
parties, INCLUDING the United States.3
7. For the purpose of this PAYMENT DEMAND, the updated costs
and fees total is accrued through week ending January 7,
2017. A breakdown of the updated total is as follows:
a. Housing - Total interim housing reimbursement costs,
as described in Document No. 128 remains unchanged,
at $29,114.86. Factoring in treble damages brings the
total housing payment portion of this demand to
$87,344.58.
b. Transportation - Total transportation reimbursement
costs due to the Plaintiff thus far, previously
reported in Document No. 128 as $97,624.76, is
adjusted to $100,692.00, adding $3,067.24 in end-oflease fees for the Plaintiffs 2015 Nissan Altima
Mutual Agreement Opportunity with the United States In
addition to bad faith acts, the Plaintiff still awaits an
ANSWER regarding the respectfully proposed Mutual Agreement
Opportunity, offered to the United States by the Plaintiff.
3

lease. Factoring in treble damages brings the total

transportation payment portion of this demand to
$302,076.00.
c. Legal Fees Legal fees previously reported in
Document No. 128 are adjusted to reflect accrual
through week ending January 7, 2017. The hourly rate
remains unchanged, at $1000 per hour, as does the
weekly cap of 40 hours per week (Calculated for 85
weeks). The total legal fees (adjusted) thus far due
to the Plaintiff is $3,400,000.00.

Factoring in

treble damages brings the total Legal Fees payment

portion of this demand to $10,200,000.00.
d. Demand for Payment (Total) After factoring in
referenced adjustments and treble damages, the TOTAL
DEMAND sought with this filing is $10,589,420.
8. The Plaintiff additionally plans to file a copy of this
DEMAND with the Department of the Treasury, and with the
Massachusetts Department of Revenue for their records. The
Plaintiff respectfully requests that this Court provide
the Treasury Department with appropriate documentation
approving the referenced payment, for the reasons
described within.
9. Outstanding Debts owed to the United States and to the
Commonwealth Once payment approval has been confirmed by

the Court and the Treasury Department, the Plaintiff

respectfully requests that the Treasury Department deduct
the past due Federal Income taxes which are rightfully due
to the United States.4
Similarly, once payment has been received from the
Treasury Department, the Plaintiff will timely coordinate
a payment arrangement with the Massachusetts Department of
Revenue for past due State income taxes which are
rightfully due to the Commonwealth.
10.

PLAINTIFF FEARS FOR HIS PERSONAL SAFETY AND WELL-

BEING

Both

the

Department

of

Justice

(DOJ)

and

the

Massachusetts Office of the Attorney General are both ON

RECORD as stating that they WILL NOT protect this American
born citizen from the related acts of criminal misconduct
committed against him. In addition, this Plaintiff, as a
pro

se

litigant,

has

had

to

deal

with

the

judicial

misconduct (alleged) of a Federal District Court Judge,

that includes (but is not limited to) multiple acts of
TREASON.

These

collective,

and

documented

acts

by

the

United States and the Commonwealth add to the Plaintiffs

allegations pertaining to (at minimum) Color of Law
violations and Conspiracy Claims.

Total estimated past due Federal taxes are estimated at $15k.

7

This gives the Plaintiff every reason to FEAR for his

personal

safety

and

well-being

EVERY

SINGLE

DAY.

It

clearly appears (at least on its surface), that both the

Executive and Judicial branches of government (Federal and
State) have chosen not protect the Plaintiff, and have
taken extreme measures in a coordinated fashion to ensure
that his litigation efforts fail. Therefore, the Plaintiff
will

continue

bringing

awareness

to

the

publics

attention, in part, for safety and security reasons.

11.

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 Motion: (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

specifically
support

so

after

investigation or

have

identified,
a

evidentiary
will

reasonable

discovery;

likely

support
have

opportunity

or,

if

evidentiary
for

further

and (4) the Motion otherwise

complies with the requirements of Rule 11.

Finally, the Plaintiff respectfully requests the following:

1. That the approval for this payment demand be made by an

officer of the Court, who has the legal jurisdiction to
make such a decision. The Plaintiff additionally requests
that the Department of the Treasury issue payment no later
than January 14, 2017;
2. That the Court finally move this litigation to the
Discovery phase, as it has now exceeded six (6) months to
survive the filed motions to dismiss; and
3. For the United States to provide the Plaintiff with an
answer regarding the Plaintiffs Mutual Agreement
Opportunity.

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