Chavakula v. Christian Heritage Broadcasting, Inc. et al

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Anand Kumar Chavakula,
Plaintiff,
v.
Christian 	Heritage 	Broadcasting, 	Inc. 	and
Praise Broadcasting, Inc.,
Defendants.
Civil No. 26-cv-3001 (ECT/DJF)
ORDER
This matter is before the Court on Plaintiff Anand Kumar Chavakula’s Application to
Proceed In Forma Pauperis (ECF No. 2) (“IFP Application”) and Motion for Court-Authorized
Alternative Service on Defendant DEWI11 a/k/a Pria.idaman Pursuant to Fed. R. Civ. P. 4(f)(3)
(ECF No. 28) (“Service Motion”). For the following reasons, the Court denies the IFP Application,
strikes Mr. Chavakula’s Amended Complaint (ECF No. 12), and denies the Service Motion as
moot. The Court also cautions Mr. Chavakula about his use of artificial intelligence (“AI”).
Mr. Chavakula commenced this action on June 17, 2026 by submitting various filings,
including the original Complaint (ECF No. 1) and the IFP Application. 	(See Docket.) 	The
Complaint alleges that Defendants Christian Heritage Broadcasting, Inc. (“CHBI”) and Praise
Broadcasting, Inc. (“PBI”) breached a March 2025 settlement agreement related to a previous
action by continuing to use “PraiseLive” (Mr. Chavakula’s registered trademark). The Complaint
further asserts that praiselive.org redirects visitors to an Indonesian online gambling platform
called DEWI11. (See ECF No. 1 ¶¶ 1, 7–14, 18.) Mr. Chavakula filed the Amended Complaint a
week later, adding DEWI11 as a Defendant and asserting new claims, including cybersquatting,
conspiracy, and racketeering. (See ECF No. 12 at 2–3, 10–13.)
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In this action’s first three weeks, Mr. Chavakula’s filings filled about 30 docket entries and
(with exhibits) exceeded 500 pages. (See generally Docket.) The filings included three motions
for a temporary restraining order. 	(See ECF Nos. 7, 13, 21.) 	Chief U.S. District Judge Eric C.
Tostrud denied the first two motions as superseded and explained that briefing would follow
service of process. (See ECF Nos. 10, 18, 31.) The third motion remains pending.
The docket raises many issues. The Court starts with the IFP Application. “The central
question [when assessing an application to proceed in forma pauperis (‘IFP’)] is whether the
movant can afford the costs of proceeding without undue hardship or deprivation of the necessities
of life.” Ayers v. Tex. Dep’t of Crim. Just., No. 95-10615, 1995 WL 696702, at *1 (5th Cir. Oct.
19, 1995) (per curiam) (citing Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339–40
(1948)); see also, e.g., Lukobi-Johnson v. Pester, No. 26-cv-1801 (DWF/DJF), 2026 WL 1083794,
at *1 (D. Minn. Apr. 17, 2026) (quoting Ayers). “The opportunity to proceed [IFP] is a privilege,
not a right.” 	Weaver v. Pung, 925 F.2d 1097, 1099 n.4 (8th Cir. 1991) (citing Williams v.
McKenzie, 834 F.2d 152, 154 (8th Cir. 1987)).
Mr. Chavakula’s IFP Application indicates that is unemployed. 	He reports $8,000 in
retirement income over the previous 12 months (against $8,050 in monthly expenses)1, and he says
he is “borrowing to pay [his] bills and the mortgage is delinquent.” (ECF No. 2 at 2, 4.) But he
also reports having $2,000 in cash, $2,950 in bank accounts, and $65,000 in a brokerage account.
(See id. at 3.) The cash and bank balances alone are several times this action’s $405.00 filing fee.
1 At $8,000 per month, Mr. Chavakula has an annual income of $96,000 per year. His IFP
application identifies no dependents. (See ECF No. 2 at 3.) Though he claims significant expenses,
including $300 per month in alimony or other support payments (id. at 4), the Court takes judicial
notice that his annual income far exceeds the federal poverty guidelines for a household of one or
two 	(if 	he 	is 	married). 	See 	https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-
guidelines.
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Mr. Chavakula claims that the “[b]rokerage is actually about minus $180,000.00, so I can’t
withdraw” (id.), but he does not reconcile that with the $65,000 he reports. And according to his
own public filings, he received $100,000 in the March 2025 settlement (see ECF No. 1 ¶¶ 8–9;
ECF No. 8 at 9–10). His IFP Application does not reveal what became of it.
Mr. Chavakula’s finances might be strained, but the Court cannot conclude that paying this
action’s filing fee would cause him undue hardship or deprive him of life’s necessities. It is his
burden to show that he qualifies for IFP status, see 28 U.S.C. § 1915(a)(1), and he has not done
so. The Court therefore denies the IFP Application. For this action to proceed, Mr. Chavakula
must pay the $405.00 filing fee by November 9, 2026. If he does not, the Court will recommend
dismissing this action without prejudice for failure to prosecute it. See Fed. R. Civ. P. 41(b).
The Amended Complaint also presents issues that need to be addressed. 	It is well
established that an amended complaint “‘supersedes’” the original, such that “[t]he ‘original
pleading no longer performs any function in the case.’” Royal Canin U.S.A., Inc. v. Wullschleger,
604 U.S. 22, 35 (2025) (quoting civil-procedure treatise); see also, e.g., In re Atlas Van Lines, Inc.,
209 F.3d 1064, 1067 (8th Cir. 2000) (citing Washer v. Bullitt Cnty., 110 U.S. 558, 562 (1884)).
Thus, under this District’s Local Rules, an amended pleading generally “must be complete in itself
and must not incorporate by reference any prior pleading.” D. Minn. LR 15.1(a).
On its face, the Amended Complaint is not “complete in itself.” 	By its own account, it
purports to “supplement[] and expand[] Plaintiff’s original Complaint.” (ECF No. 12 at 3.) For
example, it drops the original Complaint’s detailed allegations of improper continued use of the
PraiseLive name. (See ECF No. 1 ¶ 13(c)–(h).) But it still asserts a failure “to cease all use of the
PRAISELIVE mark.” (ECF No. 12 at 8–9.) The new pleading also omits the original pleading’s
specific-performance claim without explaining whether Mr. Chavakula means to abandon it.
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(Compare ECF No. 1 ¶¶ 20–22 with ECF No. 12 at 8–13.) It further relies on an “Exhibit O” that
is not attached to it (and was filed with the original Complaint instead). (See ECF No. 12 ¶ 11;
ECF No. 1-3 at 21–23.) And it ends with a “Supplemental Evidence Update” that Mr. Chavakula
suggests is “Incorporated by Reference.” (ECF No. 12 at 15–16.)
Making matters worse, Mr. Chavakula has tried to revise his pleadings further with
“notices.” One such notice purports to correct the original Complaint (see ECF No. 8 at 9); another
adds numbered findings and asks the Court to “[a]uthorize the Amended Complaint” (ECF No. 15
at 7–16, 19). 	As a result, the Court cannot tell (nor could any Defendant) exactly what Mr.
Chavakula’s operative allegations and claims are. 	That makes it all but impossible for any
Defendant to fairly “admit or deny the allegations asserted against it.” Fed. R. Civ. P. 8(b)(1)(B).
In any event, under the Federal Rules of Civil Procedure, notices are not pleadings, see Fed. R.
Civ. P. 7(a), and they cannot amend or supplement the Complaint. See Fed. R. Civ. P. 15(a), (d).
The Court recognizes that Mr. Chavakula’s pro se filings are “‘to be liberally construed.’”
Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97,
106 (1976)); see also, e.g., Olsen as Tr. for Xurex, Inc. v. Di Mase, 24 F.4th 1197, 1202 (8th Cir.
2022) (quoting Erickson). Nevertheless, “pro se litigants are not excused from failing to comply
with substantive and procedural law.” 	Burgs v. Sissel, 745 F.2d 526, 528 (8th Cir. 1984) (per
curiam) (citing Faretta v. California, 422 U.S. 806, 834–35 n.46 (1975)); Morrison v. Rose, No.
26-cv-1553 (ECT/DJF), 2026 WL 2687270, at *2 (D. Minn. Sept. 14, 2026) (quoting Burgs). The
Court will not assemble a pleading from pieces of various filings.
The Court therefore strikes the Amended Complaint under Local Rule 1.3 and the Court’s
inherent authority to manage its docket. See, e.g., D. Minn. LR 1.3; Dietz v. Bouldin, 579 U.S. 40,
47 (2016) (citing cases). 	The original Complaint remains the operative pleading. 	And because
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the original Complaint names only CHBI and PBI as defendants, DEWI11 is not currently a party
to this action.2
However, the Court will provide Mr. Chavakula an opportunity to correct the deficiencies
in his pleading: Mr. Chavakula may file an amended complaint by November 9, 2026. If he does
not do so, then this action will proceed on the original Complaint alone. Any amended complaint
that Mr. Chavakula submits must be complete in itself. 	It should name every defendant, allege
every fact, and assert every claim on which Mr. Chavakula means to proceed, in plain terms and
numbered paragraphs, without relying on any other filing. See, e.g., D. Minn. LR 15.1(a); Fed. R.
Civ. P. 8(a)(2), 10(a)–(b). 	It should also identify which claims are asserted against which
Defendants and omit motions, legal argument, and lengthy evidentiary submissions.
This leads to three points about service. First, because DEWI11 is not currently a party,
the Service Motion, which seeks leave to serve DEWI11 through WhatsApp, Telegram, and other
electronic means (see ECF No. 28 at 5–6), is moot. The Court therefore denies the Service Motion
without prejudice to Mr. Chavakula renewing the request if he files a proper amended complaint
naming DEWI11.3
Second, because Mr. Chavakula is not proceeding IFP, he is responsible for service on
CHBI and PBI. See Fed. R. Civ. P. 4(c)(1), (3); D. Minn. LR 4.1. After he pays this action’s filing
fee, he can present summonses to the Clerk of Court for issuance. 	Unless service is waived, a
nonparty who is at least 18 years old must serve each Defendant with a summons and the operative
2 Given these rulings, the Court does not now consider whether any of Mr. Chavakula’s
claims are adequately pleaded, see 28 U.S.C. § 1915(e)(2)(B), or whether the Court could exercise
personal jurisdiction over DEWI11.
3 Because the Court denies Mr. Chavakula’s IFP Application, he will be responsible for
serving DEWI11 if DEWI11 is properly added in an amended pleading.
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complaint, and Mr. Chavakula will need to file proof of service. See Fed. R. Civ. P. 4(b), (c)(1)–
(2), (d), (l)(1).
Third, the 90-day service deadline set by Federal Rule of Civil Procedure 4(m) expired on
September 15, 2026. However, the Court finds good cause exists to extend it, because the Clerk’s
Office did not issue any summonses while Mr. Chavakula’s IFP Application was pending. (See,
e.g., ECF Nos. 29 at 1, 4; ECF No. 30 at 1; ECF No. 41 at 1.) The Court thus extends the deadline
for Mr. Chavakula to serve CHBI and PBI to January 7, 2027. 	The Court may recommend
dismissing any Defendant who is not served by the new deadline. See Fed. R. Civ. P. 4(m).
Finally, the Court is compelled to address Mr. Chavakula’s prolific use of artificial
intelligence. Mr. Chavakula acknowledges using “AI-assisted drafting tools” to prepare filings.
(ECF No. 26 at 1.) This is permissible. Under this District’s guidance, however, litigants who use
such tools remain “ultimately responsible for the accuracy and sufficiency of the resulting work
product.” 	U.S. Dist. Ct., D. Minn., GenAI FAQ (Oct. 1, 2025), available at https://www.
mnd.uscourts.gov/sites/mnd/files/GenAI_FAQ.pdf. 	In addition, under Federal Rule of Civil
Procedure 11, even the signature of an “unrepresented party” certifies that, after a reasonable
inquiry, a filing’s legal contentions are “warranted” and its factual contentions “have evidentiary
support.” Fed. R. Civ. P. 11(b)(2)–(3); see also, e.g., Turnage v. Associated Bank, N.A., No. 25-
cv-3004 (ECT/DTS), 2025 WL 3052638, at *3 (D. Minn. Sept. 12, 2025) (“There is no pro se
exception to Rule 11(b).”), aff’d, No. 25-3092, 2025 WL 4694563, at *1 (8th Cir. Nov. 25, 2025).
“[A]ll litigants—represented and unrepresented—must read their filings and take reasonable care
to avoid misrepresentations, factual and legal.” Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th
967, 970 (7th Cir. 2026). Using artificial intelligence does not excuse these requirements.
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Mr. Chavakula’s filings indicate that he is relying too heavily on AI tools. For instance,
the Amended Complaint alleges “nine separate rotating destinations” but then only lists eight.
(ECF No. 12 ¶ 12.) It also asserts that DEWI11 is “to be served pursuant to the Hague Service
Convention” (id. at 2), but then the Service Motion calls that very process “inapplicable” (ECF
No. 28 at 3). 	The Service Motion argues for “email service,” yet does not identify any email
address for DEWI11. (ECF No. 28 at 1, 4–7.) And Mr. Chavakula has already conceded that his
filings “incorrectly cited” a Supreme Court decision for a proposition it does not support. (ECF
No. 26 at 3.) 	Problems like these make filings hard to follow and unacceptably consume the
Court’s limited resources.
The Court has already cautioned Mr. Chavakula, both about citing “hallucinated”
authorities and supplementing motions without leave. (See ECF Nos. 11, 31.) It now warns him
that he (not any AI tool) is ultimately responsible for any document he files. 	Before filing a
document, Mr. Chavakula must read it and make sure that its factual statements are accurate and
that its authorities exist and support his contentions. Citing hallucinated authorities may result in
an order striking the filing without leave to amend it. 	In addition, Mr. Chavakula may not file
“notices,” “supplements,” or similar documents that purport to add to or revise earlier filings
without prior permission from the Court to do so. And generally speaking, he should file fewer
documents that are themselves shorter and clearer than those filed to date. 	The Court does not
suggest Mr. Chavakula has acted in bad faith. 	But it may strike or disregard future filings that
violate the Federal Rules of Civil Procedure, this District’s Local Rules, or the Court’s orders—
and if necessary, it may impose other sanctions, including filing restrictions in this action. 	See
Fed. R. Civ. P. 11(c); D. Minn. LR 1.3.
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ORDER
Based on the foregoing, and on all the files, records, and proceedings herein, IT IS
HEREBY ORDERED THAT:
1. 	Plaintiff Anand Kumar Chavakula’s Application to Proceed In Forma Pauperis
(ECF No. 2) is DENIED.
2. 	Mr. Chavakula must pay this action’s $405.00 filing fee by November 9, 2026,
failing which the Court will recommend dismissing this action without prejudice
for failure to prosecute.
3. 	Mr. Chavakula’s Amended Complaint (ECF No. 12) is STRICKEN, and the
complaint filed at ECF No. 1 remains this action’s operative pleading. The Clerk
of Court is directed to terminate DEWI11 a/k/a Pria.idaman as a party.
4. 	Mr. Chavakula may file an amended complaint that is complete in itself and
otherwise compliant with this Order by November 9, 2026. If he does not do so,
the original Complaint (ECF No. 1) shall serve as the operative complaint.
5. 	Mr. Chavakula’s Motion for Court-Authorized Alternative Service on Defendant
DEWI11 a/k/a Pria.idaman Pursuant to Fed. R. Civ. P. 4(f)(3) (ECF No. 28) is
DENIED AS MOOT and WITHOUT PREJUDICE.
6. 	Mr. Chavakula is responsible for serving process under Federal Rule of Civil
Procedure 4. His deadline to serve CHBI and PBI is extended to January 7, 2027.
7. 	Mr. Chavakula is WARNED, as explained above, that he is responsible for the
accuracy of every document he files, including any documents prepared with AI
tools, and that noncompliant filings may be stricken and may result in sanctions,
including filing restrictions in this action.
Dated: October 9, 2026 	s/ Dulce J. Foster
DULCE J. FOSTER
United States Magistrate Judge
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