On June 11, 2024 a
Motion-Secondary
was filed
involving a dispute between
Chirag S Chaman,
and
Raju Mirchandani,
for Torts - Other (Witness Tampering, Defam.)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 06/11/2024 05:12 PM INDEX NO. 155362/2024
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 06/11/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Chirag S. Chaman, INDEX No. 155362/2024
Plaintiff,
AFFIRMATION IN SUPPORT OF
vs. TEMPORARY RESTRAINING
ORDER
Raju Mirchandani,
Defendant.
I, Chirag S. Chaman, affirm under penalty of perjury that the following statements are true:
1. I am the Plaintiff in this action and make this affirmation in support of my application for a
Temporary Restraining Order against Defendant Raju Mirchandani.
2. As detailed in my Verified Complaint, Defendant has engaged in a series of defamatory actions and
witness tampering that have caused significant harm to me and to Arun Mirchandani, a material
witness in my defense in a related lawsuit (Index No. 157901/2019).
3. Recently, Defendant has been requested by family members to maintain the status quo regarding the
care of Arun’s ailing and bedridden 102-year-old grandmother. Despite these requests, Defendant has
informed his family that unless Arun, his father, and sister contribute to the grandmother's weekly
care, he will terminate the overnight caregiver on June 15, 2024. This caregiver is essential for the
grandmother’s health and well-being.
4. Terminating the overnight caregiver would not only adversely affect the health of the 102-year-old
grandmother but also create the false impression that I, the Plaintiff, am somehow responsible for
these unfortunate events.
5. Additionally, Defendant is coercing Arun and his family to give him money by threatening to
terminate the essential caregiver services, which is causing significant emotional distress and
financial pressure on Arun and his family.
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1 of 2
FILED: NEW YORK COUNTY CLERK 06/11/2024 05:12 PM INDEX NO. 155362/2024
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 06/11/2024
6. It is unlikely that I will be able to convince Arun Mirchandani to present himself in court without
making him an unwilling witness, which would further fracture our business relationships.
7. Defendant’s actions are designed to coerce and intimidate Arun Mirchandani, preventing him from
participating as a witness in my defense and causing further emotional and financial harm to me.
8. Immediate relief is necessary to prevent Defendant from terminating the essential care for the
grandmother, from coercing Arun and his family to give money, and to restrain Defendant from
making any further defamatory statements, intimidating actions, and initiating any contact with Arun
Mirchandani until the disposition of Index No. 157901/2019.
9. Therefore, I respectfully request that the Court issue a Temporary Restraining Order to prevent
Defendant from terminating the overnight caregiver, coercing Arun and his family to give money,
making further defamatory statements, engaging in any actions to intimidate or coerce Arun
Mirchandani, and initiating any contact with Arun Mirchandani until the disposition of Index No.
157901/2019.
10. Attached hereto as Exhibit A is a copy of the email from Defendant where he made the statement
about terminating the caregiver.
11. I have attached the Verified Complaint and relevant exhibits as supporting documents for this
application.
I affirm the foregoing statements are true under the penalties of perjury.
Dated: June 11, 2024
___________________
Chirag S. Chaman
301 E 47th St Apt 4P
New York, NY 10017
m: 917.519.6143
e: cchaman@gmail.com
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2 of 2
Document Filed Date
June 11, 2024
Case Filing Date
June 11, 2024
Category
Torts - Other (Witness Tampering, Defam.)
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FILED: NEW YORK COUNTY CLERK 06/11/2024 05:12 PM INDEX NO. 155362/2024 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 06/11/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Chirag S. Chaman, INDEX No. 155362/2024 Plaintiff, AFFIRMATION IN SUPPORT OF vs. TEMPORARY RESTRAINING ORDER Raju Mirchandani, Defendant. I, Chirag S. Chaman, affirm under penalty of perjury that the following statements are true: 1. I am the Plaintiff in this action and make this affirmation in support of my application for a Temporary Restraining Order against Defendant Raju Mirchandani. 2. As detailed in my Verified Complaint, Defendant has engaged in a series of defamatory actions and witness tampering that have caused significant harm to me and to Arun Mirchandani, a material witness in my defense in a related lawsuit (Index No. 157901/2019). 3. Recently, Defendant has been requested by family members to maintain the status quo regarding the care of Arun’s ailing and bedridden 102-year-old grandmother. Despite these requests, Defendant has informed his family that unless Arun, his father, and sister contribute to the grandmother's weekly care, he will terminate the overnight caregiver on June 15, 2024. This caregiver is essential for the grandmother’s health and well-being. 4. Terminating the overnight caregiver would not only adversely affect the health of the 102-year-old grandmother but also create the false impression that I, the Plaintiff, am somehow responsible for these unfortunate events. 5. Additionally, Defendant is coercing Arun and his family to give him money by threatening to terminate the essential caregiver services, which is causing significant emotional distress and financial pressure on Arun and his family. Page 1 1 of 2 FILED: NEW YORK COUNTY CLERK 06/11/2024 05:12 PM INDEX NO. 155362/2024 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 06/11/2024 6. It is unlikely that I will be able to convince Arun Mirchandani to present himself in court without making him an unwilling witness, which would further fracture our business relationships. 7. Defendant’s actions are designed to coerce and intimidate Arun Mirchandani, preventing him from participating as a witness in my defense and causing further emotional and financial harm to me. 8. Immediate relief is necessary to prevent Defendant from terminating the essential care for the grandmother, from coercing Arun and his family to give money, and to restrain Defendant from making any further defamatory statements, intimidating actions, and initiating any contact with Arun Mirchandani until the disposition of Index No. 157901/2019. 9. Therefore, I respectfully request that the Court issue a Temporary Restraining Order to prevent Defendant from terminating the overnight caregiver, coercing Arun and his family to give money, making further defamatory statements, engaging in any actions to intimidate or coerce Arun Mirchandani, and initiating any contact with Arun Mirchandani until the disposition of Index No. 157901/2019. 10. Attached hereto as Exhibit A is a copy of the email from Defendant where he made the statement about terminating the caregiver. 11. I have attached the Verified Complaint and relevant exhibits as supporting documents for this application. I affirm the foregoing statements are true under the penalties of perjury. Dated: June 11, 2024 ___________________ Chirag S. Chaman 301 E 47th St Apt 4P New York, NY 10017 m: 917.519.6143 e: cchaman@gmail.com Page 2 2 of 2