FOR IMMEDIATE RELEASE

Harihar Offers Settlement Opportunity to Defendants in

Federal RICO/Foreclosure Case.
nd

Boston, MA, January 25, 2016 The US District Court in Boston, MA has recently accepted the 2
amended complaint to Docket No: 15cv11880, Harihar vs. US Bank et al, and summonses have
1
been issued to 14 Defendants: US Bank NA, Wells Fargo NA, RMBS CMLTI 2006-AR1 , The
Commonwealth of Massachusetts, Attorney General (former) Martha Coakley, Nelson Mullins LLP,
Harmon Law offices PC, David E. Fialkow (Esq.), Jeffrey S. Patterson (Esq.), Peter Haley (Esq.), Real
Estate Brokers Ken & Mary Daher (Daher Companies, Methuen, MA), Jeffrey & Isabelle Perkins
(Residents of the illegal foreclosure located at 168 Parkview Avenue, Lowell, MA 01852).
Prior to having the summonses delivered via US Marshall Service, the Plaintiff Mohan A. Harihar, is
providing an opportunity to ALL Defendants to seek a mutual agreement prior to moving forward in the
legal process. In the meantime, the Department of Justice/Office of the Inspector General (DOJ/OIG)
has been in contact with Harihar, who is awaiting alignment with Federal Prosecutors, and/or the
assignment of a Special Prosecutor, if deemed necessary.
The two primary issues in this litigation involve fraudulent foreclosure, and secondly the Plaintiffs
Intellectual Property known as the FCS Model an economic framework designed to assist the United
States with economic recovery and growth.

Scroll down to view a copy of the DEMAND Letter, in its entirety.

For Further Media Information Contact: Mohan A. Harihar

Email: mh.foreclosure1@gmail.com
Phone: 617.921.2526 (Mobile)
Follow on Twitter:
Mohan Harihar@MH_Foreclosur1

RMBS Residential Mortgage-Backed Security.

---------- Forwarded message ---------From: Mohan Harihar <moharihar@gmail.com>

Date: Tue, Jan 26, 2016 at 10:11 AM
Subject: RE: Demand Letter - HARIHAR vs. US BANK et al, Docket No: 15cv11880
To: david.fialkow@klgates.com, "Constituent.services@state.ma.us" <constituent.services@state.ma.us>, jeffrey.patterson@klgates.com,
"peter.haley@nelsonmullins.com" <peter.haley@nelsonmullins.com>, mcoakley@foleyhoag.com, "kendaher@dahercompanies.com"
<kendaher@dahercompanies.com>, "maryekoontz@dahercompanies.com" <maryekoontz@dahercompanies.com>, Jim Gray
<jim.gray@nelsonmullins.com>
Cc: jarrettpublic@who.eop.gov, kbranch@who.eop.gov, newyorkcomplaints@usdoj.gov, "christina.sterling@usdoj.gov"
<christina.sterling@usdoj.gov>, press@usdoj.gov, washington.field@ic.fbi.gov, boston@ic.fbi.gov, "elizabeth_warren@warren.senate.gov"
<elizabeth_warren@warren.senate.gov>, "mark_bayer@markey.senate.gov" <mark_bayer@markey.senate.gov>,
mark_gallagher@markey.senate.gov, ma-igo-general-mail@massmail.state.ma.us, maura.healey@state.ma.us, "june.black@mail.house.gov"
<june.black@mail.house.gov>, "chris.mullin@mail.house.gov" <chris.mullin@mail.house.gov>, "eileen.donoghue@masenate.gov"
<eileen.donoghue@masenate.gov>, "timothy.sheehan@cfpb.gov" <timothy.sheehan@cfpb.gov>, bryan.olson@klgates.com

January 26, 2016

FOR DOCUMENTATION, NEGOTIATION & SETTLEMENT PURPOSES ONLY

VIA US MAIL and EMAIL

To ALL Recipients:

You have been named as a Defendant in a civil/criminal complaint, filed in the United States District Court
(Boston, MA), HARIHAR vs. US BANK, et al, Docket No: 15cv11880. The CURRENT list of Defendants is as
follows:
1.

US Bank, NA

2. Wells Fargo, NA
3. Residential Mortgage-Backed Security (RMBS) - CMLTI 2006-AR1
4. The Commonwealth of Massachusetts
5. Nelson Mullins, LLP
6. Harmon Law offices, PC
7. David E. Fialkow, esq.
8. Jeffrey S. Patterson, esq.
9. Peter Haley, esq.
10. Martha Coakley, MA Attorney General (Former)
11. Ken Daher (Weichert Realtors/Daher Companies, Methuen, MA)
12. Mary Daher (Weichert Realtors/Daher Companies, Methuen, MA)
13. Jeffrey Perkins, (Resident 168 Parkview Avenue, Lowell, MA 01852)
14. Isabelle Perkins, (Resident 168 Parkview Avenue, Lowell, MA 01852)
As representing counsel in active litigation against Plaintiff - Mohan A. Harihar, the Defendant David E.
Fialkow is instructed to forward a copy of this Demand Letter to his respective clients Defendants US Bank
NA, Wells Fargo NA and RMBS CMLTI 2006-AR1.

Please be advised of the following:

1.

A second amended civil/criminal complaint for the referenced Docket No: 15cv11880, has been
accepted by the United States District Court in Boston, MA; Summonses for all Defendants have
been issued. The allegations listed in the referenced complaint are considered both civil and criminal in
nature, and ALL are fully supported. A copy of the complaint has been made available to the public, and
can be viewed by clicking on the attached link: Harihar Files Request for Special Prosecutor in
Federal Foreclosure/RICO Complaint https://www.scribd.com/doc/289241306

2.

The United States Department of Justice (USDOJ) and Massachusetts Office of the Attorney General,
have already identified violations of Federal and State law associated with the referenced foreclosure.

3.

Separately, the Federal Reserve, along with Federal Bank Regulators, has identified similar misconduct
involving Defendants - Wells Fargo NA and US Bank NA, regarding the referenced foreclosure through
an Independent Foreclosure Review.

4.

Confirmation of the referenced misconduct is additionally supported by the sworn testimony of FRAUD
EXPERT Lynn Syzmoniak; involves the Residential Mortgage Backed Security (RMBS) Trust
CMLTI 2006-AR1; and includes multiple case references.

5.

Civil/Criminal allegations stated in the referenced complaint include (but are not limited to) the following:

a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
6.

Violations of the RICO Act

14th Amendment Constitutional Violations to Due Process and Equal Protection Rights
Color of Law violations
Tampering Violations
Abuses of Judicial Discretion
Fraudulent Misrepresentation
Fraudulent Concealment
Fraud, Including Deceptive Practices
Fraudulent Assignments
Aiding and Abetting Fraud
Perjury violations
SEC violations
FCA (False Claims Act) claims

In addition to the direct harm and damages suffered by the Plaintiff Mohan A. Harihar, referenced
allegations threaten the Plaintiffs Intellectual Property that includes the FCS Model [1] an economic
framework designed to assist the United States with economic recovery and growth.

7.

The referenced allegations additionally expose multiple levels of corruption, warranting communication to
the Office of the Inspector General (DOJ/OIG).

8.

Summonses have been issued for all listed Defendants, and are being prepared for delivery via US
Marshalls Service.

9.

Plaintiff Mohan A. Harihar is now in contact with the Executive Office of the Department of Justice, and
the Office of the Inspector General (OIG), regarding alignment of civil/criminal complaints, and the
assignment of a special prosecutor, if necessary.

10. Before moving forward with these civil and criminal legal actions, referenced Defendants are being
offered in good faith, an opportunity to voluntarily enter into settlement negotiations, for the purpose of
reaching a mutual agreement, as it pertains to damages resulting from the alleged misconduct.

11. Should an acceptable agreement between parties be reached, the Plaintiff Mohan A. Harihar MAY
consider the withdrawal of criminal complaints filed.

12. Choosing to decline or ignore this opportunity will result in civil/criminal complaints moving forward
against ALL responsible parties as planned. Maximum penalties allowed by law will be sought for ALL
civil and criminal infractions, and will be addressed with the appropriate Law and Real Estate
Professional authorities.

13. The Plaintiff is committed to seeing this matter to its legal conclusion, regardless of timeline.
14. This is a very serious matter that requires your immediate attention. This letter is your final opportunity to
resolve this matter amicably.

15. A copy of this letter is being filed with the United States District Court (Boston, MA), Docket No: 15-cv11880, to inform the Court of a proposed settlement opportunity, and for documentation purposes.

16. A copy of this letter is being delivered (via email correspondence) to State and Federal authorities
including:

a.
b.
c.
d.
e.

The United States Department of Justice (DOJ), and the Office of the Inspector General (OIG).
The Federal Bureau of Investigation (FBI).
The US Attorneys Office (MA).
The Massachusetts Office of the Inspector General.
The Massachusetts Office of the Attorney General.

17. A copy of this letter is being delivered (via email correspondence) to the following government officials:
a. President Barack Obama (via Senior Advisor, Valerie Jarrett)
b. United States Senator Elizabeth Warren (MA).
c. United States Senator Ed Markey (MA).
d. Governor Charles Baker (MA).
e. Congresswoman Nikki Tsongas (MA).
f. Massachusetts State Senator Eileen Donoghue (MA).
18. A copy of this letter is being delivered (via email correspondence) to the Consumer Financial Protection
Bureau (CFPB).

19. A copy of this letter is being delivered (via email correspondence) to the Senior Management of K&L
Gates LLP.

20. A copy of this letter is being made available to the Public and to the media.
21. Finally, by extending this opportunity to ALL listed Defendants, the Plaintiff Mohan A. Harihar has
shown in good faith, a sincere effort to reach a mutual agreement, prior to moving forward with the
referenced legal proceedings associated with this Docket.

For documentation purposes, please provide a written response on or by Friday, February 5, 2016, so that it may
be filed with the United States District Court, and the associated docket. Thank you for your attention to this
matter.

Sincerely,

Mohan A. Harihar

[1] FCS Foreclosure Crisis Solution