Case: 21-1953 Document: 00117843041 Page: 1 Date Filed: 02/16/2022 Entry ID: 6477363

IN THE UNITED STATES COURT OF APPEALS

FOR THE FIRST CIRCUIT

)
MOHAN A. HARIHAR, )
)
Appellant )
) Appeal No. 21-1953
v. )
)
JEANNE D’ARC CREDIT UNION, et al )
)
Appellees )

APPELLANT RESPONSE AND EMERGENCY MOTION RE: (1) JURISDICTION

VIOLATIONS EVIDENCED IN 01-26-2022 ORDER ISSUED BY RECUSED CIRCUIT
JUDGE – HON. WILLIAM J. KAYATTA JR.; (2) NEWLY DISCOVERED CONFLICTS
OF INTEREST/ PRIOR JUDICIAL MISCONDUCT VIOLATIONS OF RECORD; AND
(3) REQUEST FOR ASSISTANCE WITH THE APPOINTMENT OF COUNSEL

BACKGROUND

The Appellant – Mohan A. Harihar, a pro se litigant with no legal experience, respectfully files

this Emergency Motion to address documented judicial failures and patterns of corrupt conduct

that continue to be evidenced (and thus far blatantly ignored) in the First Circuit: (1) most

recently discovered in this appeal; (2) in the lower court docket; (3) and in all related litigation,

impacting jurisdiction and again showing cause to question the integrity of both the US District

and this US Court of Appeals. It’s important to note that in recent months, evidenced judicial

misconduct/criminal violations – believed (at least in part) to include First Circuit Judges, has

appeared in national headline news, referencing the September 2021 Wall Street Journal

(WSJ) Investigative Report that identified 131 Federal Judges who failed to disclose
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Conflicts of Interest in cases they were presiding over.1 The WSJ report was then addressed

by: (1) The Administrative Office of US Courts - October 2021 Memorandum addressing

Judicial Code of Conduct, Conflict of Interest Screening, Ethics Training, etc.2; (2) US Senator

Elizabeth Warren (D-MA)/ US Congresswoman Pramila Jayapal (D-WA) in a letter to US

Supreme Court Chief Justice – Hon. John G. Roberts, Jr.3; and (3) US Supreme Court

Chief Justice – Hon. John G. Roberts, Jr. in his 2021 End of Year Report on the Federal

Judiciary.4

The Appellant respectfully reminds the Court that this Appeal is related to other litigation that

remains ongoing in the US District Court and includes a considerable list of evidenced judicial/

administrative failures that remain uncorrected, dating as far back as 2015. Reference is made to

the following related Civil Complaints of record:

1. HARIHAR v US BANK et al, Docket No. 15-cv-11880 – includes the sua sponte recusal

of US District Court Judge – Hon. Allison Dale Burroughs on June 19, 2017, which

came only after judicial misconduct had been evidenced for the record.5 Nearly five (5)

1
The referenced WSJ Investigative report can be viewed online in its entirety on the WSJ website at the following
location: https://www.wsj.com/articles/131-federal-judges-broke-the-law-by-hearing-cases-where-they-had-a-
financial-interest-11632834421?fbclid=IwAR17veisSou0tQJdrn4VM9Ssvk_JYFqCY-
Foselbnkb1SsNx2ia1Fji1GAQ
2
See Exhibit 1, or click on the following link to view the October 13, 2021 Memorandum (Additional Guidance
on Conflict Screening – IMPORTANT INFORMATION) from Judge Roslynn R. Mauskopf – Director,
Administrative Office of United States Courts: 10132021judiciary_conflicts.pdf (thomsonreuters.com)
3
See Exhibit 2, or click on the following link to view the October 14, 2021 letter delivered from US Senator
Elizabeth Warren (D-MA)/ US Congresswoman Pramila Jayapal (D-WA) to US Supreme Court Chief Justice
– Hon. John G. Roberts, Jr. on Judicial Ethics 2021.10.14 Letter to Chief Justice on Judicial Ethics.pdf
(senate.gov)
4
Click on the following link to view the 2021 End of Year Report on the Federal Judiciary, delivered by US
Supreme Court Chief Justice – Hon. John G. Roberts, Jr. 2021year-endreport.pdf (supremecourt.gov)
5
See Exhibit 3, to view the sua sponte recusal order from US District Court Judge – Hon. Allison Dale Burroughs
issued on June 19, 2017.
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years later, the US District Court has yet to void/vacate all orders/judgements related

Judge Burroughs’ recusal and jurisdiction has yet to be restored. Even more disturbing is

that Judge Burroughs has continued to issue orders after her recusal and without

jurisdiction, constituting (at minimum) violations to ARTICLE III and 18 U.S. Code §

2381 – Judicial Treason, for “Warring against the Constitution of the United States”.

US District Court clerks stand accused of Misprision of Treason under 18 U.S. Code §

2382, after witnessing an act of Treason and failed (or refused) to report this serious

crime, as required under Federal law. Instead, clerks are continuing to follow void orders

issued by a recused judge – which includes (but is not limited to) refusing to docket the

Plaintiff’s filed documents. In the past year, it was also discovered that Judge

Burroughs failed to disclose a Conflict of Interest that shows - she holds a mortgage

with Bank Defendant – US BANK.

2. HARIHAR v THE UNITED STATES, Docket No. 18-cv-11109 – is directly related to

HARIHAR v US BANK et al, but is necessarily brought as a separate complaint as

required by Federal law, since the Federal government cannot be included with other

Defendants. As a matter of record, the presiding US District Court Judge – Hon.

Denise J. Casper, exemplified the same egregious judicial abuses of power as judge

Burroughs – However, despite evidence of judicial disqualification, Judge Casper

refused to recuse and continued to issue orders without jurisdiction. The Court has yet to

initiate corrective action, beginning with restoring jurisdiction; and

3. HARIHAR v HOWARD, et al, Docket No. 18-cv-11134 – This civil complaint was filed

against recused/disqualified judges, court clerks/administrative personnel and named

Defense attorneys to recoup civil damages for the evidenced judicial/administrative

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failures that are well documented in the above-referenced litigation. As previously stated,

all Sovereign Immunity, Judicial Immunity and Litigation Privilege is considered

waived under Fed. R. Civ. P. 60(b)(3) – Fraud on the Court (UNOPPOSED claims of

record). As a general rule, judges cannot be held liable for money damages for acts done

in the exercise of his judicial function, within the limits of his jurisdiction, no matter

how erroneous, illegal or malicious his acts may be (48A Corpus Juris Secundum §86).

HOWEVER, if an INFERIOR judge – (for example, resulting from Recusal/

Disqualification) acts maliciously or corruptly he may incur liability - as is the case here

(Kalb v. Luce, 291 N.W. 841, 234, WISC 509). In the referenced litigation, the record

conclusively shows what can only be described as egregious patterns of corrupt conduct,

where presiding judges have all blatantly refused to uphold Federal laws, brushing aside

all Plaintiff/Appellant claims in order to reach a corrupt and pre-determined outcome.

Examples of this misconduct include (but are not limited to) the following:

a. Failure/Refusal to uphold 28 U.S.C. § 1915 – Assistance with the Appointment of

Counsel;
b. Failure/Refusal to uphold Fed. R. Civ. P. 60(b)(3) – Fraud on the Court;
c. JUDICIAL Fraud on the Court;
d. Failure/Refusal to uphold 18 U.S. Code § 1832 – Misappropriation of Trade
Secrets/Economic Espionage Act, and resulting impact to National Security;
e. Refusing to CLARIFY decisions;
f. Ignoring or failing to address Plaintiff/Appellant’s repeated concerns for personal
safety and security;
g. Failure/Refusal to uphold 18 U.S. Code § 2382; Misprision of Treason;
h. Failure/Refusal to uphold 18 U.S. Code § 4; Misprision of a Felony;
i. Failure/Refusal to address evidenced Acts of TREASON, under Article III and 18
U.S. Code § 2381;
j. Ignoring evidenced claims believed to impact matters of National Security;
k. Federal Tort Claims, pursuant to (at minimum): 28 USC § 2671, 28 USC § 2674 and
28 USC § 1346;
l. Color of Law/Due Process violations, (at minimum) pursuant to 18 U.S. Code § 242;
m. Civil RICO Claims pursuant to 18 U.S. Code § 1964
n. Ignoring the sua sponte RECUSAL of Judge Allison Dale Burroughs from Docket
No. 17-cv-11109, HARIHAR v. THE UNITED STATES and its impact to related
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dockets;
o. Unnecessary Judicial Delay;
p. Refusing to RECUSE;
q. Demonstrated INTENT to cause increased hardship to Plaintiff/Appellant, Mohan
A. Harihar by unjustly tipping the Scales of Justice heavily in favor of the Defendants;
r. False Statements; and others.

As evidenced by the Plaintiff, the presiding judge in HARIHAR v HOWARD et al – Hon.

William G. Young, also exemplified identical patterns of misconduct, by brushing aside all

evidenced claims and denying assistance with the appointment of legal counsel - in order to

arrive at the same corrupt and pre-determined outcome. As with the related cases, the

Plaintiff has clearly shown cause for the COURT, to void/vacate all orders/judgements tied

to recusal/disqualification and to re-establish jurisdiction, without any further unnecessary

delay.

Unfortunately, the lower court docket for this appeal – HARIHAR v JEANNE D’ARC CREDIT

UNION et al, Docket No. 20-cv-12293 has been no different, where despite clear evidence of

disqualification – and considering the severity of legal issues, the presiding US District Court –

Hon. Indira Talwani has (at minimum):

1. Failed to disclose conflicts of interests with Bank Defendants in the related litigation;
2. Refused to clarify jurisdiction;
3. Refused to recuse;
4. Refused to assist the Plaintiff with the appointment of legal counsel under 28 U.S. Code
§ 1915;
5. Refused the Plaintiff’s right to Discovery;
6. Brushed aside the Plaintiff’s evidenced arguments and request for a trial by jury;
7. Refused to recognize the related recusals/disqualifications of record, including (at
minimum) evidenced violations to ARTICLE III and 18 U.S. Code § 2381 – Judicial
Treason and its impact to jurisdiction, which has yet to be restored (Ex. HARIHAR v US
BANK et al);
8. Continued to issue orders – including a Dismissal order, after judicial disqualification
was clearly evidenced, in the same identical manner evidenced in HARIHAR v US BANK
et al.
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On Monday, December 20, 2021, the Plaintiff filed a motion – respectfully reminding this

Appeals Court that there remain unresolved issues in the lower court, which was originally

stated stated on the Appellant’s filed Civil Cover sheet. However, the cover sheet has

apparently been altered by the Clerk of the US District Court – Robert M. Farrell.6 The

Appellant’s original Civil Cover Sheet informed this Court that: (1) motions were still pending

in the lower court; (2) there were NO sealed documents; and (3) SHOULD HAVE included the

entire transcript from the lower court. Any objective observer that reviews the Appellant’s filed

Notice of Appeal (Attached) or the lower court transcript in its entirety will clearly conclude that

that are multiple issues that remain unresolved in the lower court. By altering the Appellant’s

filed cover sheet, Clerk Farrell and Deputy Clerk – Matthew A. Paine have (at minimum)

evidenced incremental acts of Bad Faith and Federal Tampering violations under 18 U.S.

Code § 1512(c)(1), (2) – showing cause to amend the original complaint against the Federal

Government (Ref. HARIHAR v THE UNITED STATES) and warrants the attention of the

Department of Justice (DOJ). Additionally, please be advised that a criminal complaint was

previously filed with the FBI (and separately, with the DOJ) against Clerk Farrell and other

Clerks of the lower court for evidenced Federal Tampering and Mail Fraud violations – that

STILL remain unaddressed.7

6
See Exhibit 4, to view the Appellant’s ALTERED Civil Cover Sheet (Highlighted), followed by the Appellant’s
filed Notice of Appeal.
7
Click on the following link to view the FBI Criminal Complaint filed with the FBI on June 4, 2020 against: US
District Court Clerks: (1) Robert M. Farrell; (2) Karen Folan; (3) Christina McDonagh; (4) Christine Bono; and (5)
Taylor Halley.
https://drive.google.com/file/d/1fRFdZYmqhMTL0RtDgtCr0AWY0wyznumP/view?usp=sharing
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On Wednesday, January 26, 2022, an order was issued without jurisdiction on the Appellant’s

motion by Circuit Judge – Hon. William Kayatta, Jr.8, who as a matter of record, previously

RECUSED himself from BOTH related appeals: (1) HARIHAR v US BANK et al, Appeal No.

17-1381 on July 17, 20189; and (2) HARIHAR v THE UNITED STATES, Appeal No. 17-2074

on September 7, 2018.10 Based on this pro se litigant’s interpretation of the law, by consciously

deciding to issue an order without jurisdiction, Judge Kayatta has (again, at minimum)

committed a violation to ARTICLE III and 18 U.S. Code § 2381 – Judicial Treason. The 01-

26-2022 VOID order by Circuit Judge Kayatta is the latest example of egregious and systemic

judicial abuses that continue to be evidenced in the First Circuit.

Moving forward, the Appellant respectfully states that - forcing a pro se litigant, with no legal

experience to deal with ALL of these judicial failures – on top the complexity of legal issues in

the complaint(s) itself, is completely unrealistic and shows the intention to unfairly tip the scales

of justice, heavily in favor of the Defendants/Appellees. Not only are there too many serious

legal issues that remain unresolved, but it should be abundantly clear to any objective observer

that neither this Appeals Court, nor the lower District Court have any intention of correcting

these egregious and certainly abusive judicial failures of record. Any objective observer who has

8
See Exhibit 5, to view the General Docket of this Appeal, which shows the 01-26-2022 VOID order, issued
without jurisdiction by recused Circuit Judge – William J Kayatta, Jr.
9
See Exhibit 6, to view the July 17, 2018 recusal order of Circuit Judges Torruella and Kayatta from HARIHAR
v US BANK et al (Ref. Appeal No. 17-1381), which came after the recusal of Circuit Judge – Hon. David J.
Barron, who acknowledged having a Conflict of Interest with Bank Defendant – WELLS FARGO. Judge
Barron’s recusal also came after judicial misconduct claims were brought against the entire panel. It’s recently been
discovered that Judge Kayatta also had Conflicts of Interest with Bank Defendants – WELLS FARGO and
CITIBANK. HOWEVER, these Conflicts of Interest were never disclosed by either Circuit Judge.
10
See Exhibit 7, to view the September 7, 2018 order, regarding the recusal of Circuit Judges Kayatta and Barron
(Ref. Appeal No. 17-2074).
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thoroughly reviewed the decade-long history of this litigation would agree (Federal and MA

State).

The Appellant also shows cause to fear for his safety and security, since the record shows his

Civil/Due Process rights as an America-born Citizen appear to be irrelevant - at least in the

eyes of this First Circuit. The Appellant restates that he has repeatedly shown cause for

assistance with the appointment of counsel, only to be denied – over and over again by

recused/disqualified Judges. With all due respect to the Court itself, these legal proceedings

have increasingly become a complete legal mess - and is being recognized nationwide as, “the

most egregious abuse of judicial power ever recorded in US history.”

THEREFORE, the Appellant respectfully requests the following:

1. That this Court should clarify its jurisdiction, considering the legal issues that have yet to

be resolved in the lower court;

2. That this Court should clarify how Circuit Judge - Hon. William Kayatta, Jr. could

possibly have been allowed to issue an order after recusal, without jurisdiction and

undisclosed conflicts of interest.11 To be clear, the Appellant has now evidenced for the

record that out of the NINE (9) First Circuit Judges - the following SEVEN (7) Circuit

Judges have either recused (after judicial misconduct was evidenced) or shown

cause for disqualification – refusing to recuse and continuing to issue orders without

jurisdiction:

a. Chief Judge – Hon. Jeffrey R. Howard;

11
See Exhibit 8, to view Judge Kayatta’s 2011 Financial Disclosure, which shows a Financial Investment with
Bank Defendant – WELLS FARGO on page 5 (Highlighted). Judge Kayatta’s 2013 Financial Disclosure shows
a Financial Investment with Bank Defendant – CITIBANK.
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b. Circuit Judge – Hon. Norman H. Stahl;

c. Circuit Judge – Hon. Sandra L. Lynch;
d. Circuit Judge – Hon. Kermit V. Lipez;
e. Circuit Judge – Hon. O. Rogeriee Thompson;
f. Circuit Judge – Hon. William J. Kayatta, Jr.; and
g. Circuit Judge – Hon. David J. Barron

Based on the Appellants interpretation of the law, the only two (2) remaining Circuit

judges who are believed to still have jurisdiction are:

a. Circuit Judge - Hon. Bruce M. Selya; and

b. Circuit Judge - Hon. Gustavo A. Gelpi (who replaced recused Circuit Judge
– Hon. Juan R. Torruella, who passed away on October 26, 2020).

3. Void/Vacate the 01-26-2022 order issued without jurisdiction by Judge Kayatta;

4. Vacate the Appellant’s Briefing Schedule that was delivered on 01-28-2022 and is

curretly set for 03-09-2022, since unresolved issues remain in the lower court and it is

unclear if an appeal will be necessary once these legal issues are justly resolved;

5. Assist the Appellant with the appointment of counsel under 28 U.S. Code § 1915 since

clearly, all requirements warranting the Court’s assistance (both here and in the lower

Court) have long been satisfied. Unless the Appellant is somehow able to secure legal

counsel on his own – which thus far has not been an option, the Court’s continued refusal

to properly exercise its discretion under 28 U.S. Code § 1915 – at minimum, shows cause

to amend the related civil complaint against The United States;

6. Remand this case back to the lower District Court to resolve the existing legal issues,

beginning with jurisdiction.

Please be advised, due to the severity and totality of unresolved legal issues – including matters

perceived to impact national security and evidenced judicial failures that have gone uncorrected
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since 2015, the Appellant has little confidence in this First Circuit’s willingness to initiate

corrective (and just) legal action. Upon filing this motion with the Court, copies of this

Emergency Motion will be delivered via email communication to the following government

offices/agencies including (but not limited to):

1. The United States Supreme Court Chief Justice – Hon. John G. Roberts, Jr. (via
Clerk of the US Supreme Court – Scott S. Harris);
2. The Administrative Office of United States Courts – specifically, Deputy Director -
Dan Jackson;
3. US Senator – Elizabeth Warren (D-MA);
4. US Congresswoman – Lori Trahan (D-MA);
5. US Congresswoman – Pramila Jayapal (D-WA);
6. The Office of Governor Charlie Baker (D-MA);
7. The White House – specifically, the Executive Office of the President (EOP) via
www.whitehouse.gov;
8. The US Department of Justice (DOJ) – specifically Assistant AG – Kristen Clarke
(Civil Rights Division);
9. The US Attorney’s Office (MA); and
10. First Circuit Executive – Susan Goldberg

The Public and Media sources nationwide will also receive copies of this motion for

documentation purposes and out of continued concerns for the Appellant’s personal safety and

security. If the Court has any questions or needs additional information, the Appellant is happy

to provide upon request. The Appellant is grateful for the Court’s consideration.

Respectfully submitted this 16th day of February, 2022.

Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
[email protected]
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Exhibit 1
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Exhibit 2
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Exhibit 3
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Exhibit 4
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UNITED STATES DISTRICT COURT

for the
DISTRICT OF MASSACHUSETTS

)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. 20-cv-12293
v. )
)
JEANNE D’ARC CREDIT UNION, et al )
)
Defendants )

PLAINTIFF NOTICE OF APPEAL AND CONTINUED ACTS OF BAD FAITH

EVIDENCED BY THE UNITED STATES DISTRICT COURT SHOWS CAUSE FOR
AMENDMENT TO RELATED DOCKETS: (1) HARIHAR v THE UNITED STATES;
AND (2) HARIHAR v HOWARD ET AL, UNDER FED. R. CIV. P. 60(b)(2)(3) & (6)

Notice is hereby given by Mohan A. Harihar, Plaintiff in the above-named matter and also a

pro se litigant with no legal experience, who appeals to the United States Court of Appeals for

the First Circuit, after a VOID judicial order was issued by disqualified US District Court Judge

– Hon. Indira Talwani, who consciously brushed aside all of the Plaintiff’s evidenced

arguments impacting jurisdiction and the Judicial Code of Conduct - and entered a VOID

action on Tuesday, November 2, 2021 [Ref. ECF No. 25]. As required by Federal law, the

Plaintiff filed a RESPONSE to the void judicial action on Tuesday, November 9, 2021,

informing the Court that Judge Talwani had (at minimum) violated ARTICLE III and 18 U.S.

CODE § 2381 – judicial treason, for continuing to rule on the Docket without jurisdiction after

disqualification was clearly evidenced [Ref. ECF No. 26]. The White House and

Massachusetts Governor Charlie Baker’s Office were also notified as required under

ARTICLE III - when an act of Treason against the US Constitution has been witnessed.
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Since this is a very serious criminal violation by a judicial officer, the US Department of

Justice (DOJ) was copied on the legal communication to Governor Baker. Multiple

Congressional leaders were also copied on the legal communication, since the severity of the

evidenced crime(s) warrants removal from the Bench.

As of this morning – Sunday, November 21, 2021, there has been no corrective action by the

US District Court. This is yet again another very serious legal issue that evidences systemic

failures within this judiciary and the blatant abuse of judicial power. The Nation is already aware

of what is considered the most egregious example of these judicial failures. Reference is made to

the related civil complaint – HARIHAR v US BANK et al, Docket No. 15-cv-11880 and

RECUSED US District Court Judge – Hon. Allison Dale Burroughs; the first of an

unprecedented ELEVEN (11) judges to recuse from the Plaintiff’s litigation (9 Federal, 2 MA

State), who consciously has continued to issue orders without jurisdiction - and without any

legal accountability thus far. Collectively – and based on the Plaintiff’s interpretation of the

law, the systemic failures that continue to be evidenced by this judiciary has severely damaged

this Court’s integrity. The decade-long history of this litigation is becoming recognized

Nationwide as “the most egregious abuse of judicial power ever recorded in US history.”

Based on the Plaintiff’s interpretation of the law, the plethora of evidenced judicial failures

exemplifies continued acts of BAD FAITH by the Federal Government and at minimum,

shows cause to amend the following civil complaints under Fed. R. Civ. P. 60(b)(2), (3), and

(6):

1. HARIHAR v THE UNITED STATES, Docket No. 17-cv-11109;

2. HARIHAR v HOWARD, Docket No. 18-cv-11134

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Finally, the Plaintiff makes clear that he is in GOOD FAITH – and in the interest of judicial

economy, willing to have/resume legal settlement discussions with all named Defendants on this

Docket and in all related Dockets, including the Federal Government and the Commonwealth of

Massachusetts. It remains my sincere hope that all parties will come together to justly resolve

the existing legal issues; and that this Court will finally address these egregious abuses of

judicial power and initiate corrective action. The Plaintiff respectfully thanks the Court for its

attention to this very serious and sensitive legal matter.

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 Plaintiff 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 Notice otherwise complies with the requirements

of Rule 11.

Respectfully submitted this 21st Day of November, 2021.

Mohan A. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
[email protected]
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Exhibit 5
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Exhibit 6
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Exhibit 7
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Exhibit 8
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