Chaturvedi v. Jaiswal et al

1
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
____________________________________
)
Rahul Chaturvedi, )
)
Plaintiff, )
)
) Civil Action No. 25-CV-13632-AK
v. )
)
Arvind Kumar Jaiswal, Siddharth Siddharth, )
Manuel Garabal, John Does 1-20, )
Jane Does 1-20 )
)
Defendants. )
)
MEMORANDUM AND ORDER ON
PETITIONER’S APPLICATION UNDER THE ALL WRITS ACT
A. KELLEY, D.J.
Before this Court is Petitioner Rahul Chaturvedi’s Emergency Application Under the All
Writs Act. [See Dkts. 1, 12]. Although somewhat difficult to determine, it appears Mr.
Chaturvedi is requesting some type of intervention in a supplementary process proceeding in the
Falmouth District Court for fear that it is requiring certain disclosures in violation of the “Defend
Trade Secrets Act, the Lanham Act, and 42 U.S.C. § 1983, and [other] federal rights.” [Dkt. 1 at
2]. Important to the below analysis, a supplementary process is “a lawsuit to collect a judgment
that the court already awarded.” Court Forms for Supplementary Process,
https://www.mass.gov/lists/court-forms-for-supplementary-process (last visited December 5,
2025).
Federal courts possess inherent authority to “manage their own affairs so as to achieve
the orderly and expeditious disposition of cases.” Goodyear Tire & Rubber Co. v. Haeger, 581
U.S. 101, 107 (2017) (quoting Link v. Wabash R.R. Co., 370 U.S. 626, 630-31 (1962)). This
Case 1:25-cv-13632-AK Document 16 Filed 12/09/25 Page 1 of 4

2
includes the power to dismiss actions that are frivolous or malicious. See Mallard v. United
States Dist. Ct., 490 U.S. 296, 307-08 (1989); Brockton Sav. Bank v. Peat, Marwick, Mitchell &
Co., 771 F.2d 5, 11 n.5 (1st Cir. 1985). A claim is legally frivolous if it “lacks an arguable basis
either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). Importantly, pro se
actions are construed liberally. Haines v. Kerner, 404 U.S. 519, 520-21 (1972). Even under this
generous standard, dismissal is warranted because the request lacks any plausible basis in law.
See Thomas v. Rhode Island, 542 F.3d 944, 948 (1st Cir. 2008) (stating that a complaint must
allege a plausible entitlement to relief).
To the extent Plaintiff challenges either the underlying action in which a finding was
made against Mr. Chaturvedi or the currently active supplementary process proceeding, such
action is barred by two related jurisdictional doctrines: Rooker-Feldman and Younger abstention.
Under the Rooker-Feldman doctrine, federal district courts lack authority to review or overturn
final state-court judgments.1 See Geiger v. Foley Hoag LLP Retirement Plan, 521 F.3d 60, 65
(1st Cir. 2008). As a result, the Court lacks jurisdiction to address the underlying judgment
against Mr. Chaturvedi.
The Younger abstention doctrine arises from Younger v. Harris, 401 U.S. 37 (1971) and
bars the exercise of federal jurisdiction in certain circumstances. In Sirva Relocation, LLC v.
Richie, 794 F.3d 185 (1st Cir. 2015), the First Circuit devised a three-step approach to determine
the applicability of Younger abstention. “To begin, a federal court must ascertain whether a
particular state proceeding falls within the Younger taxonomy. If so, the court must then take the
second step and consider whether the Middlesex factors support abstention. And if these two
steps leave the case on track for abstention, the court must take the third step and determine
1 The doctrine is named after the Supreme Court decisions in District of Columbia Court of Appeals v. Feldman, 460
U.S. 462 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923).
Case 1:25-cv-13632-AK Document 16 Filed 12/09/25 Page 2 of 4

3
whether any of the isthmian exceptions to the Younger doctrine apply.” Id. at 192-93. As to the
first step, three types of cases fall within the Younger taxonomy: “(i) criminal prosecutions, (ii)
‘civil proceedings that are akin to criminal prosecutions,’ and (iii) proceedings ‘that implicate a
State’s interest in enforcing the orders and judgments of its courts.’” Id. at 192 (quoting Sprint
Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 72-73 (2013). Turning to the second step, the Middlesex
factors advise abstention if the exercise of federal jurisdiction “would interfere (1) with an
ongoing state judicial proceeding; (2) that implicates an important state interest; and (3) that
provides an adequate opportunity for the federal plaintiff to advance his federal constitutional
challenge.” Rossi v. Gemma, 489 F.3d 26, 34-35 (1st Cir. 2007). Finally, exceptions to the
Younger abstention doctrine include: (1) “when a state proceeding is brought in bad faith, that is,
for the purpose of harassment,” (2) “if the state forum provides inadequate protection of federal
rights,” and (3) “when a state statute is ‘flagrantly and patently violative of express constitutional
prohibitions.’” Sirva Relocation, LLC, 794 F.3d at 192 (quoting Younger, 401 U.S. at 53)
(citations omitted).
Here, Plaintiff seemingly seeks intervention in the supplementary process proceeding,
which he claims is requiring the disclosure of protected secrets. Looking to the first step, the
supplementary process proceeding, a lawsuit to allow the collection of a judgment that the court
has already awarded, is a civil proceeding that obviously implicates the State’s interest in
enforcing the judgments of its courts. Turning to the Middlesex factors: (1) the supplementary
process proceeding is ongoing, (2) it is an important state interest to enforce final court
judgments, and (3) Mr. Chaturvedi has offered no evidence that the Falmouth District Court does
not provide an adequate forum to advance his federal challenges. Finally, none of the recognized
Case 1:25-cv-13632-AK Document 16 Filed 12/09/25 Page 3 of 4

4
exceptions to abstention are applicable in the instant case. Thus, this Court lacks subject matter
jurisdiction under the Younger abstention doctrine.
I. CONCLUSION
For the foregoing reasons, Petitioner Rahul Chaturvedi’s Emergency Application Under
the All Writs Act [see Dkts. 1, 12] is DISMISSED. The Emergency Motion for Temporary
Restraining Order [Dkt. 2] and Motion for Administrative Clarification of Initiating Document
and Case Scheduling [Dkt. 12] are DENIED AS MOOT. Nothing in this ORDER prevents Mr.
Chaturvedi from filing a future federal complaint to rectify a violation of the Defend Trade
Secrets Act, the Lanham Act, or 42 U.S.C. § 1983.
SO ORDERED.
Dated: December 9, 2025 /s/ Angel Kelley
Hon. Angel Kelley
United States District Judge
Case 1:25-cv-13632-AK Document 16 Filed 12/09/25 Page 4 of 4