FOR IMMEDIATE RELEASE $42B Lawsuit Filed Against Wells Fargo, US Bank & the Commonwealth of Massachusetts Boston, MA, May 21, 2015 – A Federal complaint has been filed at the United States District Courthouse in Boston, by foreclosed homeowner – Mohan A. Harihar. Defendants in the civil complaint include: Wells Fargo NA, US Bank NA, the Commonwealth of Massachusetts, associated law firms, attorneys, real estate brokers, and parties who knowingly purchased an illegal foreclosure.

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For those who have been following this 4-year storyline, an overwhelming amount of evidence has steadily come forth to support Mr. Harihar’s consistent claims of civil and criminal misconduct. Multiple allegations of evidenced corruption have come forth as well. The most recent allegations reveal criminal tampering with a MA Superior Court case file, and evidenced Collusion involving the Massachusetts Attorney General’s Office, the US Attorney’s Office, the Boston BAR Association, and retained counsel (former) for Wells Fargo & US Bank – Nelson Mullins Riley & Scarborough LLP. While the individual damages are certainly significant, the big picture focuses on the intellectual property belonging to Mr. Harihar, and three (3) specific projects designed to bring considerable economic growth to the US – and repairing damages suffered from the US Foreclosure/Financial Crisis. Scroll down to view a copy of the filed Federal Complaint in its entirety. Mr. Harihar is now seeking to retain a qualified/experienced legal team to assist with this action. Interested firms are encouraged to reference the contact information listed below. 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

1 Associated Law Firms include: Nelson Mullins Riley & Scarborough LLP and Harmon Law Offices

PC; Associated attorneys include: David E. Fialkow, Jeffrey S. Patterson, and Peter Haley; Associated Real Estate Brokers include: Daher Companies – Weichert Realtors (Methuen, MA); Jeffrey & Isabelle Perkins are parties who knowingly moved forward with purchasing an illegal foreclosure.

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UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MOHAN A. HARIHAR CIVIL ACTION NO: TBD

Lower Court: 11-04499

Plaintiff

v.

WELLS FARGO NA,

US BANK NA,

RMBS CMLTI 2006 AR-1,

COMMONWEALTH OF MASSACHUSETTS,

HARMON LAW OFFICES PC,

NELSON MULLINS RILEY AND SCARBOROUGH LLP,

DAVID E. FIALKOW – ESQ,

JEFFREY PATTERSON – ESQ,

PETER HALEY – ESQ,

MARY AND KEN DAHER - DAHER COMPANIES,

JEFFREY AND ISABELLE PERKINS

Defendants

CIVIL COMPLAINT FOR PLAINTIFF DAMAGES AND DEMAND FOR JURY TRIAL

UNDER FED. R. CIV. P. 38(B)

I. INTRODUCTION

1. The Plaintiff, MOHAN A. HARIHAR, acting pro se, brings this

enforcement action to hold multiple parties accountable –

from their violations of both Massachusetts and Federal law,

stemming from the US Foreclosure Crisis that has gripped

Massachusetts and this Nation since 2007. The resulting

damages to this Plaintiff are considerable. Accordingly,

pursuant to (at minimum) the Massachusetts Consumer

Protection Act, G.L.c. 93A, the Plaintiff seeks to require

Defendants Wells Faro NA, US Bank NA, Harmon Law Offices PC,

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Nelson Mullins LLP, David E. Fialkow – Esq., Jeffrey

Patterson – Esq., Peter Haley – Esq., Mary and Kenneth Daher

– Daher Companies, Jeffrey and Isabelle Perkins, and the

Commonwealth of Massachusetts, to pay civil penalties,

restitution, and other compensation for harms caused by

their unfair and deceptive conduct (at minimum), in

Massachusetts, and additionally the infringement and damage

to the Plaintiff’s Intellectual property.

2. The Plaintiff also seeks injunctive relief in order to

remedy, address and prevent additional harm from arising out

of the Defendants’ conduct. The request for Injunctive

relief has been initially filed with the Middlesex Superior

Court.2 However, nearly fourteen (14) weeks later, still no

decision has been made, and it was revealed that the

referenced case file “went missing” for a period of

approximately three(3) weeks. On Thursday, May 13, 2015,

Plaintiff – Mohan A. Harihar requested to review the “newly

found” file. Upon review, clear signs of tampering were

evident, ranging from (at minimum) the dis-assembly of the

Plaintiff’s submitted 9A package, mislabeling, items out of

order, missing documents, and unidentified notations made to

a separate and “re-assembled” set of Court documents – which

appear as the first items to be reviewed by the Court. The

2 Reference Docket No: 2011-04499, Harihar vs. US Bank NA, Wells

Fargo NA, Harmon Law Offices PC, et al.

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Plaintiff immediately notified the Clerk – Michael Brennan

of these findings, and the Clerk’s office is currently

reviewing the file.

3. The clearly evidenced discovery of improper relationships

including Collusion and Conflict, involving Nelson Mullins

Riley and Scarborough LLP, the MA Attorney General’s Office,

the US Attorney’s Office, and the Boston Bar Association has

necessitated the involvement of the Massachusetts Inspector

General’s Office, the requested call for (at minimum)

multiple internal investigations, and the assignment of a

special prosecutor to address the numerous criminal

allegations associated with this complaint, including (but

not limited to) Corruption.3

4. The announcement just released by the former Attorney

General - Martha Coakley on January 16, 2015 addresses the

consent judgment from the amended 2011 complaint filed by

the Commonwealth against four banks including the Defendant,

Wells Fargo N.A. The complaint details the Defendant’s

unlawful conduct resulting in void/illegal foreclosures. The

Attorney General states, “Wells Fargo Bank violated

Massachusetts foreclosure law and the Massachusetts Consumer

Protection Act by illegally foreclosing upon Massachusetts

residents when the banks lacked the legal authority to do

so.” This declaration by the Massachusetts Attorney General

3 See Attachment A

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reaffirms the consistent claims by this Plaintiff, through

nearly four (4) years of litigation.4

5. The historical record associated with this matter

collectively reflects an overwhelming (and still growing)

amount of evidence and information which has steadily come

forth, in full support of this Plaintiff’s consistent claims

– thus clearly warranting new trial and a move to Federal

Court.

6. The scope of both civil and criminal misconduct alleged is

significant, involves complex facts, will (at minimum)

require voluminous discovery, subpoenaed testimony by

multiple parties, and the likely need for substantial case

management.

7. Plaintiff reserves the right to expand the list of

Defendants, as the depth of related misconduct is revealed.

This includes any party, agency, employer, etc… who so

chooses to support any portion of the referenced misconduct.

Defendant’s newly retained counsel - K & L Gates, LLP, has

been given notice, that any alignment or show of support to

any portion of the referenced misconduct will show cause to

add their firm as a Defendant in this matter. This includes

(but is not limited to) the recent decisions to newly employ

Defendants – Attorney David E. Fialkow and Attorney Jeffrey

4 Reference Suffolk County Superior Court Docket No: 11-4363,

filed by the Commonwealth of Massachusetts, and includes

Defendant – Wells Fargo NA; See Attachment B.

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S. Patterson. Both Defendants – Fialkow and Patterson have

recently separated from Defendant - Nelson Mullins Riley and

Scarborough LLP for reasons unknown.5

8. Defendant – Harmon Law Offices, PC has been in Default,

since this matter was brought before the Massachusetts

Appeals Court, again as injunctive relief is sought in the

Middlesex Superior Court, and since coming under

investigation by the MA Attorney General’s Office for

wrongful foreclosure and eviction practices.6

9. There has been NO ATTEMPT MADE, by the Commonwealth or

Nelson Mullins, to deny, defend, or even address the

evidenced allegations of COLLUSION made against them.7

10. While the Plaintiff has historically acted as a pro se

litigant (out of financial necessity), a significant effort

is now made to retain counsel with the filing of this

action. If attempts to secure counsel are unsuccessful, the

Plaintiff intends to file with the Court a separate “Motion

for the Appointment of Counsel” per Title 28 U.S.C. § 1915.8

5 K & L Gates, LLP is the 3rd law firm to appear as retained

counsel to Defendant’s US Bank NA, Wells Fargo NA, and CMLTI

2006-AR1 (Replacing Defendant - Nelson Mullins Riley and

Scarborough LLP, and Defendant - Harmon Law Offices PC). See

Notice, Attachment C. 6 The Massachusetts Attorney General’s office is believed to be

still conducting this ongoing investigation. 7 Similarly, there has been no effort made by the US Attorney’s

Office or the Boston BAR Association, to deny, defend or

address these allegations. 8 See – Motion for Appointment of Counsel and/or Special

Prosecutor (filed separately).

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II. JURISDICTION AND VENUE

11. While the Plaintiff has been granted leave to file for new

trial by the Massachusetts Appeals Court9, the facts

surrounding this matter satisfy (at minimum) the Federal

requirements of diversity (28 U.S. Code § 1332), damages

exceeding a threshold of $75,000; violations to Federal

Antitrust laws; Constitutional Violations of the 14th

Amendment to Due Process and Equal Protection Rights;

Evidenced Collusion and Conflict, in which the Commonwealth

thus far has failed to address and take corrective action.

12. The growing complexity of this matter warrants the

Plaintiff to actively seek and retain qualified and

experienced counsel to assist with this action. The severity

of evidenced allegations involving the Commonwealth of

Massachusetts additionally warrants the assistance of a

special prosecutor.

13. The parties are joined in a single lawsuit pursuant to

Mass R. Civ. P.20, and with meeting the Federal requirements

of Diversity, due to a significant number of common issues

of fact and law raised by the claims detailed within and

because these claims originate out of the same series of

9 See MA Appeals Court Docket Sheet for No: 2013-P-1829,

Harihar v. US Bank NA, Wells Fargo NA, et al.; Reference #19.

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transactions or occurrences, namely, foreclosures that

failed to comply with Massachusetts law.

14. Trial by jury is hereby respectfully demanded under Civil

Procedure Rule 38 § (a), taking into consideration the

historical abuses of judicial discretion throughout multiple

state courts, irrefutable negligence by the Northeast

Housing Court, 14th Amendment infractions to Due Process and

Equal Protection Rights, and the Commonwealth’s

failure/refusal to address and prosecute Defendants’ (and

counsel’s) evidenced criminal misconduct, or to take ANY

corrective action.

III. THE PARTIES

15. The Plaintiff is Mohan A. Harihar, a wrongfully foreclosed

and wrongfully displaced homeowner, who brings this action

to recover damages suffered, and also in the public

interest. Mr. Harihar is also the originator/owner of three

(3) separate projects specifically designed to assist this

Nation’s and overall Global economic recovery from damages

suffered from the US Foreclosure/Financial Crisis. These

projects include the FCS model10.

16. Defendant Wells Fargo Bank, N.A. ("Wells Fargo") is a

national bank with a principal place of business in Sioux

10 The FCS Model ©, is the Intellectual Property belonging to

the Plaintiff – Mohan A. Harihar. See Attachment D for

completed form AO 121.

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Falls, South Dakota. As described below, Wells Fargo either

directly and/or indirectly through its agents, employees,

subsidiaries and/or related companies, including without

limitation Wells Fargo Home Mortgage, Inc., held, serviced

and/or engaged in transactions related to, mortgages of real

property within the Commonwealth, including the Plaintiff’s

foreclosed property.11

17. Defendant US Bank, N.A. (“US Bank”), is a national bank

with a principal place of business in Saint Paul, MN. As

described below, US Bank either directly and/or indirectly

through its agents, employees, subsidiaries and/or related

companies, including without limitation Wells Fargo Home

Mortgage, Inc., held, serviced and/or engaged in

transactions related to, mortgages of real property within

the Commonwealth, including the Plaintiff’s foreclosed

property.

18. Defendant CMLTI 2006-AR1 is the residential mortgage-

backed security (RMBS) trust associated with the Plaintiff’s

wrongful foreclosure.

19. Defendant Harmon Law Offices PC is a law firm with a

principal office in Newton, MA. Harmon is the originally

retained counsel by US Bank in this matter, who withdrew

from this case shortly after the MA Attorney General’s

11 The referenced illegal foreclosure is located at 168

Parkview Avenue, Lowell, MA 01852.

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Office began its investigation of Harmon’s involvement with

unlawful foreclosures. Harmon has been labeled the

“Foreclosure Mill” of Massachusetts, tied to over 50,000

foreclosures throughout the Commonwealth. Harmon has also

been directly linked to disbarred Florida foreclosure

kingpin – David Stern.

20. Defendant Nelson Mullins Riley and Scarborough LLP is a

law firm with multiple locations primarily along the east

coast of the United States, including a Boston Office

located at One Post Office Square, 30th floor, Boston, MA

02109. Nelson Mullins Riley and Scarborough LLP served as

prior counsel to both Defendants - Wells Fargo and US Bank

(Nelson Mullins Riley & Scarborough LLP).

21. Defendant David E. Fialkow is a newly employed attorney

for K & L Gates, LLP in Boston, MA (formerly with Nelson

Mullins Riley and Scarborough LLP, located in Boston).

22. Defendant Jeffrey Patterson is a newly employed attorney

for K & L Gates, LLP in Boston, MA (formerly with Nelson

Mullins Riley and Scarborough LLP, located in Boston).

23. Defendant Peter Haley is the Managing Partner for Nelson

Mullins Riley and Scarborough LLP, located in Boston, MA.

24. Defendants Mary and Ken Daher are Real Estate Brokers

associated with Weichert Realtors – Daher Companies located

in Methuen, MA.

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25. Defendants Jeffrey and Isabelle Perkins, who are believed

to have moved to the Commonwealth from the state of New

Jersey, are parties who have moved forward in purchasing the

referenced wrongful foreclosure. Isabelle Perkins is also

believed to be a licensed Real Estate Broker, associated

with Weichert Realtors in the State of New Jersey.

26. The Commonwealth of Massachusetts now becomes a Defendant

in this matter.

IV. STATEMENT OF FACTS

27. This matter originates from direct and irrefutable

association with the US Foreclosure/Financial Crisis –

considered by many to be the largest case of FRAUD in the

history of these United States. Misconduct associated with

the Plaintiffs’ foreclosure has been identified by both the

Massachusetts Attorney General’s Office, and separately by

Federal Bank Regulators.

28. A historical review of the complete record will reveal

related complaints against referenced Defendants - filed

with multiple agencies, organizations, etc…, including:

1. The Federal Bureau of Investigation (Fraud Investigations

Unit).

2. The Massachusetts Office of the Attorney General (Criminal

Complaints).

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3. The Massachusetts Board of BAR Overseers/BAR Counsel.

4. The Northeast Association of Realtors (NEAR).

5. The Securities and Exchange Commission (SEC).

6. The Federal Trade Commission (FTC).

7. The American Civil Liberties Union (ACLU).

29. Defendant misconduct associated with the Plaintiff’s

referenced foreclosure is supported by the sworn testimony

of Fraud expert – Lynn Syzmoniak.

30. Defendant misconduct including (but not limited to)

deceptive practices is supported in the recorded

conversations during the attempted 22-month loan

modification process, between Plaintiff and Defendant

(Mortgage servicer), Wells Fargo NA. The Plaintiff

respectfully insists that this Court issue an order for the

production of these recordings in the Discovery phase. The

historical record will show that Defendants – Wells Fargo NA

and US Bank NA have repeatedly refused to produce this

evidence, and Massachusetts State Courts have repeatedly

failed to order Defendants to provide this critical

Discovery.

31. A thorough review AND VALIDATION of the historical record

from ALL related Massachusetts Courts will reveal a

substantial amount documented evidence and support (already

on file) for the Plaintiff’s consistent claims of misconduct

against referenced parties.

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V. ALLEGATIONS

32. The Harihar case, which began nearly four years ago, has

steadily gained the attention of many - both nationally and

globally, as supporting evidence continues still, to come

forth. The list of evidenced misconduct against referenced

Defendant’s includes (at minimum):

1. Fraud

2. Deceptive Practices

3. Anti-trust Violations

4. Fraudulent Misrepresentation

5. Fraudulent Assignments

6. Perjury

7. Aiding and Abetting Fraud

8. 14th Amendment Constitutional infraction to Due Process

and Equal Protection Rights.

9. Improper relationships revealing evidenced Collusion –

involving the MA Attorney General’s Office, the MA US

Attorney’s Office, the Boston BAR association, and

Defendant’s counsel (prior) – Nelson Mullins Riley &

Scarborough LLP.

10. Abuses of Judicial discretion

11. Infractions/Infringement to the Intellectual property

belonging to Mohan A. Harihar, including projects designed

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to assist with this Nation’s (and Global) economic

recovery from the US Foreclosure/Financial Crisis.

33. The Appellant respectfully brings to this Court’s

attention, that upon review of the supporting cases

submitted by Defendants over the past four (4) years, there

does not appear to be one (1) case example provided, which

reflects the depth of circumstances equivalent to this

matter. Specifically, no case example has been provided to

the Court(s) which includes the magnitude of documented

civil and criminal misconduct as does this matter. In fact,

the Appellant does not believe there to be a single case

decision, in this Commonwealth, or any state in the Nation,

which articulates and provides justification in lieu of

documented civil and criminal misconduct provided.

Therefore, all such related arguments by these Defendants,

and their impact to ALL related decisions, respectfully,

must be considered VOID. Any continued argument by opposing

parties based on the same premise, should be disallowed.

VI. RELIEF SOUGHT

34. The Plaintiff’s collective injuries are divided into six

(6) sections:

1. Injunctive Relief – Decisions are currently pending in the

Middlesex Superior Court and the Northeast Housing

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Court12, as it relates to the Plaintiff’s request for

injunctive relief and corrective action by the

Commonwealth of Massachusetts. The Plaintiff respectfully

calls for the Court to recognize any injunctive relief

and/or corrective action taken by the Commonwealth (or

their failure to do so). The Plaintiff calls for a formal

Federal investigation as it pertains to the referenced

tampering allegations stated within. The Plaintiff

additionally reserves the right to revisit the requests

for injunctive relief with this Court, pending the

decisions made by the Middlesex Superior Court and the

Northeast Housing Court.

2. Personal damages to marriage, family, career, credit,

future retirement and everyday living. Personal damages

include loss of Plaintiff’s home, to which the Plaintiff

is still HOMELESS. A review of the historical record will

additionally reveal Slander/Defamation of the Plaintiffs’

character for the past four (4) years. Collective damages

easily meet the Federal minimum requirement of $75,000 and

are considered greater than $1M.

3. Damage to Plaintiff’s Intellectual Property involving a

project designed to assist this Nation’s and overall

economic recovery from damages suffered during the US

12 Reference Middlesex Superior Court Docket No: 2011-04499;

Reference Northeast Housing Court Docket No: 11-SP-3032.

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Foreclosure/Financial Crisis. The documented MERITS of

this project are significant, having successfully reached

the Executive Offices of the President of these United

States (EOP) – at the specific request of Vice President

Joe Biden, the Deputy Chief Counsel of the House Finance

Committee, Senior Economic adviser to US Senator Elizabeth

Warren (MA), Congresswoman Niki Tsongas’ Office (MA), the

Chairman of a nationally ranked Strategic Communications

firm, the Attorney General Offices of Massachusetts and

New Hampshire, and two (2) Massachusetts State Senators.

Effectively implemented, this project is expected to have

a positive economic impact estimated in the trillions of

dollars. The collective actions of the Defendants are

considered to have negatively impacted and caused damage

to this project. Economic experts will be called to

articulate the measure of all variables, in a successfully

implemented FCS model. The “value” of the FCS model is

equated to the total positive economic impact of a

successfully implemented model (measured in US dollars).

4. Damage to Plaintiff’s Intellectual Property involving a

template designed to assist (at minimum) the 4.2 million

FORECLOSED parties, identified in the US Foreclosure

Crisis, with filing a civil action against the responsible

Lender/party. Any party, agency, court, employer, etc…

whose actions negatively impact or cause damage to any

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portion of this project are expected to be included as

Defendants in this civil/criminal action(s).

An expanded overview of this Project is described as

follows:

i) As a pro se litigant, the Plaintiff has clearly

demonstrated the ability to properly construct (and

argue) a civil complaint as it relates to this matter.

ii) The final product of the proposed template can be

described as a “cleaned up” version of what already

exists on record. This version will be simplified in a

“step by step” manual, modified by state, as needed.

iii) Accessibility to this template is expected to come

(at minimum) with incorporating a website. Numerous

media sources including social media will be used to

communicate, educate, and inform the public, and ALL

affected parties of this new available tool.

To put into context a value for this template, the

following formula is used:

i) A baseline of 4.2M affected parties with similar

damages averaging an estimated $1M each.

ii) Multiply 4.2M (affected parties) by $1M (average

damages per) to estimate total damages; equating the

value of this template at 100% to an estimated $4.2T.

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e. Damage to Plaintiff’s Intellectual Property involving a

template designed to assist (at minimum) the 4.2 million

parties, identified in the US Foreclosure Crisis, with

filing a criminal action against the responsible

Lender/party. Any party, agency, court, employer, etc… whose

actions negatively impact or cause damage to any portion of

this project are expected to be included as Defendants in

this civil action. Accessibility and communication of this

template, once complete, will be released in conjunction

with the civil complaint model. The Plaintiff elects to

refrain at this time, from assigning an estimated value to

this criminal complaint template, until counsel has been

retained, and/or a special prosecutor has been assigned.

f. The reimbursement of All associated legal fees/costs

affecting this Plaintiff.

g. While the Plaintiff has every right to seek 100% of the

damages/infringement as described within, the Plaintiff

will initially set the total relief sought – equivalent to

1 percent (1%) of the template defined in 34(d), or $42B.

Should an agreement between parties be reached based on

this fraction of damages, Plaintiff MAY consider various

options of payment to lessen the burden of payment.

However, if it is instead the Defendant’s decision not to

seek agreement based on this very minimal percentage, the

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Plaintiff reserves the right to adjust damages up to and

including 100 percent (100%) of ALL six (6) sections of

damages as described within, and without consideration for

various options of payment.

h. The Plaintiff will look to the recommendations of counsel

(once retained) and the Court to assist with a breakdown

of relief due to the Plaintiff by each of the Defendants,

along with their ability to pay.

i. The Plaintiff makes very clear before this Court; the

formula used to calculate damages here, ONLY takes into

consideration the measured timeline of the US Foreclosure/

Financial crisis (estimated 2006 – 2010). The 4.2M

affected parties identified are similarly from this

estimated timeline only. It is NOT to say that similar

misconduct has not occurred before this timeline, or

since. Additionally, the formula is ONLY applied to

impacted FORECLOSURES within this estimated timeline.

THE PLAINTIFF MAKES VERY CLEAR, THAT ASSOCIATED MISCONDUCT

IS NOT LIMITED TO FORECLOSURES ALONE.

Should an agreement here between parties be unsuccessful,

the plaintiff will reserve the right to address this

expanded misconduct in a separate action(s).

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35. Restating that a Trial by jury is hereby respectfully

demanded under Civil Procedure Rule 38 § (a), taking into

consideration the historical abuses of judicial discretion

throughout multiple state courts, irrefutable negligence by

the Northeast Housing Court, 14th Amendment infractions to

Due Process and Equal Protection Rights, and the

Commonwealth’s failure/refusal to address and prosecute

Defendants’ (and counsel’s) evidenced criminal misconduct,

or to take ANY corrective action.

It is through sheer arrogance and the apparent belief of

being “ABOVE THE LAW” that these Defendants now find

themselves in this position of increased legal risk. This

Plaintiff has followed the rules of the Court; has clearly

conducted himself in an ethical manner; exemplified complete

transparency, and shown beyond ANY doubt, evidenced

misconduct by Defendants and their retained counsel. It is

understandable to suspect, that a degree of embarrassment

exists – knowing that this pro se litigant has historically

exemplified the ability to successfully argue this matter in

a Court of law. Regardless, their position now comes by

their own hand. As this pro se Plaintiff has abided by the

rules of the Court, so too, must these Defendants and

counsel be held accountable when they violate and abuse the

law.

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The Plaintiff - Mohan A. Harihar, has clearly gone over and

above, perhaps more so than any individual in this

Commonwealth or Country, not only to irrefutably prove this

case, but to also provide a solution which aids in this

Nation’s economic recovery, and ALL parties affected.

It remains my sincere hope, that a mutual agreement will be

reached here, while paving the way for an economic framework

that brings historic economic growth to these United States.

Respectfully Submitted,

Mohan A. Harihar

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Attachment A

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Attachment B

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Attachment C

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May 20, 2015

VIA EMAIL CORRESPONDENCE K&L Gates, LLP Attn: Brian L. Olson, Chief Human Resources Officer State Street Financial Center One Lincoln Street Boston, MA 02111-2950 RE: Attorneys David E. Fialkow and Jeffrey S. Patterson.

Mr. Olson:

It is my understanding that K&L Gates LLP has made the decision to recently employ, as

Partner’s in the Boston Office, Attorneys – David E. Fialkow and Jeffrey S. Patterson

(Previously with Nelson Mullins Reilly & Scarborough, LLP). It is also my understanding that

K&L Gates has made the decision to replace Nelson Mullins as retained counsel to both US

Bank NA and Wells Fargo NA, in litigation against Mohan A. Harihar.

Please be advised of the following:

1. The evidenced civil and criminal misconduct associated with the historical record of

this matter is included as part of a new complaint being filed in Federal Court. The

evidenced misconduct includes (at minimum):

a. Fraud

b. Deceptive Practices

c. Anti-trust Violations

d. Fraudulent Misrepresentation

e. Fraudulent Assignments

f. Perjury

g. Aiding and Abetting Fraud

h. 14th Amendment Constitutional infraction to Due Process and Equal

Protection Rights.

i. Improper relationships revealing evidenced Collusion – involving the MA

Attorney General’s Office, the MA US Attorney’s Office, the Boston BAR

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association, and Defendant’s counsel (prior) – Nelson Mullins Riley &

Scarborough LLP.

j. Abuses of Judicial discretion

k. Infractions/Infringement to the Intellectual property belonging to Mohan A.

Harihar, including projects designed to assist with this Nation’s (and Global)

economic recovery from the US Foreclosure/Financial Crisis.

2. David E. Fialkow, Jeffrey S. Patterson, and their former employer – Nelson Mullins

Riley and Scarborough LLP will now be included Defendants in this Federal

complaint(s). Nelson Mullins is on record as supporting the documented misconduct

of retained counsel. Senior management has remained silent for nearly two (2) years

since having been implicated by the managing partner of the Boston Office, Peter

Haley.

3. Clear evidence of improper relationships including Collusion is on record.

Furthermore, there has been no denial by ANY party – the Massachusetts Attorney

General’s Office, the US Attorney’s Office, the Boston BAR Association, or Nelson

Mullins Riley and Scarborough LLP, of these very serious, and clearly evidenced

allegations.

4. Any party, agency, employer, etc… who so chooses to align themselves in support of

this referenced misconduct, is expected to be added as a Defendant in the forthcoming

Federal action(s).

5. A copy of this correspondence will be included in the referenced Federal complaint.

6. While K&L Gates has yet to been listed as a Defendant, Plaintiff – Mohan A. Harihar

has reserved the right to expand the list of Defendants as the depth of misconduct

continues to be revealed/exposed.

You are now respectfully requested to articulate for the record, your intentions as they pertain

to this matter. Please note, a failure to do so will be interpreted as a decision to support the

evidenced misconduct of referenced clients and new employees/partners of K&L Gates, LLP.

Thank you for your attention to this matter.

Sincerely,

Mohan A. Harihar

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Attachment D

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