Professional Documents
Culture Documents
MOHAN A. HARIHAR, )
)
Plaintiff/Appellant, )
) Case No. 17-1381
v. )
)
US BANK, et al )
)
Defendants/Appellees. )
The Appellant – MOHAN A. HARIHAR, acting pro se, respectfully DEMANDS that this
The most pressing issue right now pertains to the Appellant’s only available source of
associated with this litigation NOT ONLY caused: (1) an extreme financial hardship; but also
vehicle on his own. For over five (5) years, the Appellant has necessarily had to burden family
members and BORROW their vehicles in order to have transportation to/from his place of
employment and for other everyday needs. On August 25, 2018, the Appellant will be faced
Case: 17-1381 Document: 00117322315 Page: 2 Date Filed: 08/05/2018 Entry ID: 6188432
with the reality of being WITHOUT transportation, as the lease on the vehicle - he has been
1. The Plaintiff is still indigent, as recognized by this Court, and does not have the financial
means to: (a) purchase a vehicle; (b) lease a vehicle; or even (c) put a down payment on a
vehicle;
2. The Appellant has worked very hard to begin rebuilding his credit, after it was destroyed
improving, has not yet been fully restored to excellent status. Even if the Appellant were
able to qualify for an auto loan (or lease) on his own: (a) the interest rate; (b) lack of
down payment; and (c) overall monthly payment will not be affordable, based on his
3. If the Appellant is unable to secure a vehicle moving forward, there is certain risk to
current employment, and ultimately the ability to provide basic everyday needs (food,
The Appellant should NO LONGER be forced to BURDEN family members in order to satisfy
Since the recent RECUSAL of Judge Barron, both SCOTUS as well as this Court, have
VACATING the JUDGEMENT (and ALL related orders) associated with this Appeal. These
circumstances include (but are not limited to) - Refusing to address the clearly evidenced
Case: 17-1381 Document: 00117322315 Page: 3 Date Filed: 08/05/2018 Entry ID: 6188432
IMBALANCE OF HARDSHIPS. The Appellant respectfully calls for this Court to now
schedule a hearing to address these hardships without any further, unnecessary delay.
Please be advised, identical motions will be filed with the related federal litigation1, as the same
imbalance of hardships applies. Once balance is restored in one (1) case, it is anticipated to be
considered balanced in all three (3) referenced cases; and the remaining hardship motions are
For documentation purposes, after sending a copy of this MOTION to the attention of POTUS,
confirmation of its receipt is attached (See Exhibit 1) with the filed Court copy. A copy will also
be made available to the PUBLIC out of the Appellant’s continued concerns for his personal
safety and security. If there is a question regarding ANY portion of this motion, the Appellant is
Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com
1
Related Federal litigation references: (1) HARIHAR v. THE UNITED STATES, Appeal No.
17-2074 (Lower Court Docket No. 17-cv-11109); and (2) HARIHAR v. CHIEF JUDGE
JEFFREY R. HOWARD, et al, Docket No. 18-cv-11134.
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Exhibit 1
Case: 17-1381 Document: 00117322315 Page: 5 Date Filed: 08/05/2018 Entry ID: 6188432
Case: 17-1381 Document: 00117322315 Page: 6 Date Filed: 08/05/2018 Entry ID: 6188432
Case: 17-1381 Document: 00117322315 Page: 7 Date Filed: 08/05/2018 Entry ID: 6188432
CERTIFICATE OF SERVICE
I hereby certify that on August 5, 2018 I electronically filed the foregoing with the Clerk of
Court using the CM/ECF System, which will send notice of such filing to the following
registered CM/ECF users:
Jeffrey B. Loeb
David Glod
David E. Fialkow
Kevin Patrick Polansky
Matthew T. Murphy
Kurt R. McHugh
Jesse M. Boodoo
Mohan A. Harihar
Appellant
7124 Avalon Drive
Acton, MA 01720
Mo.harihar@gmail.com