Professional Documents
Culture Documents
The Plaintiff – MOHAN A. HARIHAR, a pro se litigant, respectfully calls for the Court to
issue an order compelling the Defendants – Jeffrey and Isabelle Perkins to appear in person
for the approaching Rule 16 conference scheduled for Tuesday, May 14, 2019. As grounds
Isabelle Perkins. Unless the sole purpose for requesting this conference is to enter into a
The Plaintiff’s evidenced arguments of record clearly support not only jurisdiction issues,
but also include an UNOPPOSED – Fraud on the Court Claim under Mass. R. Civ.
2. The Court is respectfully reminded that there are evidenced state and federal criminal
complaints associated with this litigation. The Plaintiff has made clear that he intends to
enjoin the evidenced civil complaints with state/federal prosecutors for the specific
purpose of bringing criminal indictments against named Defendants. This Court has been
to the US Attorney’s Office and the MA AGO - and the request for their attendance at the
3. The Court is respectfully reminded that BOTH the Massachusetts Office of the
Attorney General (MA AGO) AND the US Department of Justice (DOJ) have
evidenced arguments align with these findings, indicating at minimum, that the
Defendants (both named and still to be named) KNEW that they had NO LEGAL
STANDING to the Plaintiff’s Property and still CONSPIRED to DEFRAUD him of his
for this Rule 16 Conference should include co-conspirators, Jeffrey and Isabelle
Perkins.1
4. Aside from evidenced criminal claims that include (but are not limited to) FRAUD, the
1
Moving forward, there is an expectation for the remaining Defendants – US BANK, WELLS FARGO and
MERS (also additional parties still to be named) to also be in attendance, once it is determined which corporate
officers/employees bear civil/criminal accountability.
INSTRUCTOR in the multiple states including the Commonwealth of Massachusetts.
The Plaintiff has made clear that he also seeks professional accountability against the
Defendants and their counsel for these evidenced crimes. ANY OBJECTIVE
OBSERVER should find it alarming (and unacceptable) to find any LICENSED REAL
claims that include (but are not limited to) FRAUD. As a matter of record, this Court is
reminded that a professional complaint has long been filed with the Northeast
For these reasons, the Plaintiff respectfully calls for an order mandating the personal appearance
Conference on 05/14/19. If your Honor has ANY questions regarding ANY portion of this
Motion, or requires additional information, the Plaintiff is happy to provide upon request.
Respectfully submitted,
Mohan a. Harihar
Plaintiff – Pro Se
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com
2
Professional complaints are similarly filed with Board of BAR Overseers against retained counsel in this case -
Jeffrey B. Loeb, Esq. (Rich May, PC) and David E. Fialkow, Esq (K&L Gates, LLP).
CERTIFICATE OF SERVICE
I hereby certify that on May 7, 2019, I filed the foregoing Opposition with the Clerk of the
Court and counsel for the Defendants (listed below) via US Mail and Email Communication:
David E. Fialkow
K&L Gates, LLP
State Street Financial Center
One Lincoln Street
Boston, MA 02111
david.fialkow@klgates.com
Mohan A. Harihar
Plaintiff
7124 Avalon Drive
Acton, MA 01720
617.921.2526 (Mobile)
Mo.harihar@gmail.com