Crichlow v. Verituity Inc. and ForgePoint Capital

Background

On August 29, 2025, the court had denied without prejudice Crichlow’s request for a discovery-related temporary restraining order. The court had nevertheless ordered all parties to preserve evidence relevant to this case and to related litigation in the District of Columbia and Virginia state court.

Crichlow then filed an emergency motion for an order to show cause, supplemental notices, a motion for a temporary restraining order, and a filing alleging abuse of process, spoliation, and improper purpose. The filings concerned a Virginia state-court lawsuit brought by Verituity Inc. In that case, Verituity had moved for default judgment against Crichlow. Crichlow asked this federal court to require the defendants to explain why they should not be sanctioned and to stop them from pursuing the Virginia case.

Court’s Analysis

The court applied the Anti-Injunction Act, a federal law that generally bars federal courts from stopping state-court proceedings. The law permits an injunction only when it is expressly authorized by Congress, necessary to protect the federal court’s jurisdiction, or necessary to protect or enforce one of the federal court’s judgments.

The court found that Crichlow had not shown that any of those three exceptions applied. It further stated that allegations about inadequate service, Verituity’s alleged misconduct, or sanctions based on conduct in the Virginia case should be presented to the Circuit Court of Fairfax County, Virginia, rather than to this federal court.

Ruling

The court denied Crichlow’s motion for an order to show cause and a temporary restraining order. It ordered Crichlow to serve the defendants with the order and his filings dated September 1 and September 4, 2025, and to file proof of service by September 15, 2025. The Clerk was directed to terminate the motion at ECF No. 18.