Whether federal trade secret protections under the Defend Trade Secrets Act preempt state court adjudications that fail to provide mandatory confidentiality safeguards

No question identified. : Pursuant to Supreme Court Rules 13.5 and 22, Petitioner Rahul Chaturvedi, proceeding pro se, while diligently seeking counsel experienced in Supreme Court practice, respectfully requests a 60-day extension of time to file his petition for a writ of certiorari. The petition is currently due on December 3, 2025, following the Supreme Judicial Court of Massachusetts’s final order entered on September 4, 2025, in Bridge Over Corporation, et al. v. Chaturvedi, FAR-30465. A 60-day extension would move the deadline to February 2, 2026. See S. Ct. R. 30.1. This Court has jurisdiction under 28 U.S.C. § 1257. Petitioner respectfully submits that good cause exists for the requested extension for the following reasons. As reflected in Petitioner’s contemporaneously submitted petition for a writ of certiorari due on November 23 in FAR-29818B, for which an extension was granted in Application No. 25A307, escalating extraordinary circumstances necessitate the requested extension. The respondents in the matters are Petitioner’s former licensees, and both petitions arise from the same commercial and technical relationships. On November 20, 2025, the Supreme Judicial Court docketed a petition for supervisory relief filed by Petitioner under Mass. G. L. c. 211, § 3 (SJ-250624). That proceeding is now the vehicle for addressing specific record-integrity issues, and it requests an emergency stay to prevent irreparable harm from the loss of DTSA-protected information. The requested extension will allow Petitioner to exhaust state court remedies before seeking a stay from this Court. This case involves multiple related state proceedings in which overlapping issues have been adjudicated. Several of those matters have recently advanced on accelerated schedules, including discovery and trial dates that coincide with the existing certiorari deadline. The extension sought here concerns federal rights under the Defend Trade Secrets Act (DTSA), 18 U.S.C. § 1836 et seq., including trade secrets and information that are federally protected and presumptively export-controlled. These rights are embedded in licensing, loan, and security agreements, and the conflict preemption that arises in state court adjudications without the mandatory confidentiality safeguards of 18 U.S.C. § 1835(b). The developing record over multiple dockets is extensive and complex. Petitioner is actively engaged in retaining counsel. The requested extension will allow Counsel to complete the remaining state-court filings and finalize any petitions that may become ripe so they may, if appropriate, be consolidated under a single writ consistent with S. Ct. R. 12.4 and prepared in compliance with 8. Ct. R. 14 and 33.1. For these reasons, Petitioner respectfully submits that good cause exists for the requested extension. Respectfully submitted, /s/ Rahul Chaturvedi Pro se Rahul Chaturvedi 867 Boylston St. 5th Floor Boston, MA 02116 rahul@dhruv.legal Dated: November 22, 2025 dhruv.legal email address is used solely by Petitioner for secure personal and custodian communications for evidentiary digests. It does not indicate a law firm, legal practice, or legal representation in any jurisdiction.