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UNITED STATES DISTRICT COURT

for the
DISTRICT OF MASSACHUSETTS

)
MOHAN A HARIHAR, )
)
Plaintiff )
) Docket No. TBD
v. )
)
THE UNITED STATES OF AMERICA, )
)
Defendant(s) )
)

COMPLAINT AND REQUEST FOR INJUNCTION

I. The Parties to This Complaint

A. The Plaintiff

Name Mohan A. Harihar

Street Address 7124 Avalon Drive

City and County Acton, Middlesex County

State and Zip Code MA, 01720

Telephone Number 617.921.2526 (Mobile)

E-mail Address mo.harihar@gmail.com

B. The Defendant

Name The United States of America

To the Attention of US Attorney General Jeff Sessions

Street Address 950 Pennsylvania Avenue, NW


City and County Washington, DC

Zip Code 20530-0001

Telephone Number 202.514.2000

E-mail Address Not Available

II. Basis for Jurisdiction

28 U.S. Code 1331 - Federal question. The district courts shall have original

jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the

United States.

A. Raised Issues1 (Include, but are not limited to):

1. Federal Tort Claims, pursuant to (at minimum) 28 U.S. Code 1346;

2. Judicial Fraud on the Court;

3. Failure to acknowledge evidenced acts of Treason to the Constitution,

pursuant to ARTICLE III;

4. Economic Espionage, and the misappropriation of trade secrets/ Intellectual

Property Rights of the Plaintiff;

5. Conspiracy Claims;

6. Obstruction of Justice pursuant to 18 USC Chapter 73;

7. Violations to Due Process;

8. Color of Law Violations;

9. Civil/Criminal RICO Violations;

1
Reference the filed SF-95 form, Attachment A; also, the related case dockets to Harihar v US
Bank, 15-cv-11880 (District Court), Judicial Misconduct Petition 01-16-90033, and current
10. Misprision (of Treason, and of a Felony);

11. Failure to acknowledge evidenced Securities Fraud;

12. Judicial Misconduct and evidenced acts of BAD FAITH, by officers of the

court, acting on behalf of the United States.

III. Statement of Claim

A. Where did the events giving rise to your claim(s) occur?

The events giving rise to the Plaintiffs claims occurred in the Commonwealth of

Massachusetts.

B. What date and approximate time did the events giving rise to your claim(s) occur?

Beginning September, 2, 2016, as articulated in the related case, Harihar v US Bank

et al, Docket No. 15-cv-11880 (Reference Document No. 124), and the completed SF-

95 form, filed with ALL three (3) branches of government on September 13, 2016.

C. What are the facts underlying your claim(s)?

Claims originally stem from damages suffered from the US Foreclosure Crisis, and

the Plaintiffs Illegal Foreclosure as identified by the Department of Justice (DOJ)

and the Commonwealth of Massachusetts. Claims also pertain to the Intellectual

Property Rights belonging solely to the Plaintiff, and the Economic framework

designed to deliver substantial economic repair and growth to the United States.

Due to the severity of these claims and out of fear for personal safety and security,

these evidenced claims have been necessarily brought to the attention of: The

President of the United States, US Attorney General Jeff Sessions, US Inspector

General Michael Horowitz, The House Judiciary Committee, The Judicial Council

Appeal 17-1381.
of the First Circuit, and the Federal Bureau of Investigation (FBI). These evidenced

claims have also been brought to the attention of the Public.

IV. Irreparable Injury

Irreparable injury to the Plaintiff is clearly articulated in the referenced docket(s), and in

conjunction with the filed SF-95 form.

V. Relief

As stated in the referenced SF-95 form, the Plaintiff respectfully seeks the following relief:

A. Damages resulting from the referenced ILLEGAL FORECLOSURE of the

Plaintiff;

B. Damages to the Plaintiffs Intellectual Property Rights, including (but not

limited to) the economic framework known as the HARIHAR FCS model;

C. Damages sustained to marriage, family, career, credit, future retirement, and

everyday way of living.

D. Alignment with Federal/Special Prosecutors to address criminal and

professional accountability of responsible parties.

The value of the Plaintiffs Intellectual Property Rights alone is substantial, with an

estimated value of $5T (US Dollars). The total requested relief is initially set to less

than 1% of this estimated value, or $42B (Does not account for treble damages). The

plaintiff also reserves the right to adjust the requested relief, if necessary.

VI. 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 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 Motion otherwise complies with the requirements of Rule

11.

Respectfully submitted this 14th day of June, 2017.

Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
Attachment A

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