UNITED STATES DISTRICT COURT ~ D
WESTERN DISTRICT OF TEXAS ocr 09 2020

UNITED STATES, et al.,

v. Case No. 20-cv-00362

INTERNAL REVENUE SERVICE, et al.

Vee vevevvnr

MOTION FOR PRELIMINARY INJUNCTION FOR TEMPORARY HALT TO
ONGOING STATE AND FEDERAL TAX PROCEEDINGS AGAINST THE PLAINTIFF-
RELATOR AS TO THE DEFENDANTS, INTERNAL REVENUE SERVICE AND
MASSACHUSETTS DEPARTMENT OF REVENUE

Pursuant to Fed. R. Civ. P. 65, the Plaintiff-Relator, Jaideep S. Chawla a/k/a John Adams,
respectfully moves this Court for a preliminary injunction as to the defendants, Internal Revenue
Service and the Massachusetts Department of Revenue, against whom this Court ought to enter a
preliminary injunction halting any state and federal tax proceedings for payments allegedly owed
by the Plaintiff-Relator.

As grounds for the relief sought, the Plaintiff-Relator states that he will suffer irreparable
harm absent a court order halting the Internal Revenue Service’s ongoing audit and collection
process and the associated, automatic tax assessment(s) from the Massachusetts Department of
Revenue. The Plaintiff-Relator, acting pro se, appears to have stated a claim for, among other
things, a conspiracy to deprive him of his civil rights. Such conspiracy has been plausibly
alleged to have involved an audit initiated by the defendant, Internal Revenue Service. In the
absence of court-ordered relief, the aforementioned state and federal tax agencies may continue

to harass the Plaintiff-Relator during the pendency of the above-captioned case in spite of the

reality that, to the extent that the Plaintiff-Relator prevails on certain claims, he is oved money


from the same state and federal tax collectors. Aside from harassment and a government-
sponsored effort to silence and/or gaslight the pro se Plaintiff-Relator during the pendency of this
complex case, there is no reason for the defendants, Internal Revenue Service and Massachusetts
Department of Revenue, to proceed with any audit, assessment, or other adverse tax action

during the pendency of the above-captioned action.

RESPECTFULLY SUBMITTED,
pp. L

JOHN ADAMS

PROSE

(formerly Jaideep S Chawla)

Mailing Address:

3 Henniker Street, #235
Hillsborough, New Hampshire 03244

Dated: October 2, 2020
RTIFICATE OF SERVICE

I hereby certify that on this day a copy of the foregoing was served on each of the
following by first class mail:

The Honorable William Barr
Attorney General of the United States
950 Pennsylvania Avenue, NW
Washington, DC 20530

The Honorable John Bash

United States Attorney, Western District of Texas
903 San Jacinto Blvd., Suite 334

Austin, Texas 78701

Dated: October 2, 2020 . Le

John Adams (formerly Jaideep S. Chawla)



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