BYJUs Alpha, Inc. v. Raveendran

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The Plaintiffs have filed an Omnibus Objection to the First Motion to Strike and the Second Motion to Strike (Adv. Docket No. 198) and an Objection to the Motion for Discovery (Adv. Docket No. 201). Defendant Raveendran filed Reply Briefs to the Plaintiffs' Objections (Adv. Docket Nos. 200 and 202).

After refusing to participate meaningfully in this adversary for months, now, after entry of a default, Mr. Raveendran is filing various motions demanding extensive discovery and seeking to strike documents that were part of the Plaintiffs' sanctions motion and brief on damages. The Court has reviewed the Motions and related responses and, for the reasons set forth below, will deny all of the Motions.

BACKGROUND

The Plaintiffs filed this adversary proceeding as part of the Debtor's ongoing efforts in the Chapter 11 case to unravel a series of fraudulent transfers that stripped the Debtor of its assets (including the $533 million Alpha Funds and the proceeds thereof) by placing those assets beyond the reach of the Debtor and its creditors and concealing their whereabouts.²The Debtor commenced this adversary proceeding against Defendants Byju Raveendran, Divya Gokulnath and Anita Kishore on April 9, 2025, asserting claims for breach of fiduciary duties, aiding and abetting breach of fiduciary duties, accounting, conversion and civil conspiracy.

2 See Byju's Alpha, Inc. v. Camshaft Cap. Fund L.P. (In re Byju's Alpha, Inc.), Adv. Pro. No.

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On November 20, 2025, this Court issued an Opinion granting the Plaintiffs' Motion for Default against Byju Raveendran for his failure to comply with the Court's expedited discovery orders in this adversary proceeding.³That Opinion included an award of damages. Shortly thereafter, Byju Raveendran filed his Motion to Correct Opinion Pursuant to Federal Rule of Civil Procedure 60(a) noting that, at a hearing on September 9, 2025, the parties had agreed to defer the damages portion of the Motion for Default to a later date to be determined.⁴As a result, the Court issued an Amended Opinion Granting Plaintiffs' Motion for Default, which thus excluded an award of damages, and entered a Scheduling Order⁵requiring the parties to submit simultaneous briefing (with proposed forms of judgment order) on the issue of damages. The parties submitted their briefs on January 21, 2026.⁶

Since the Court issued the Scheduling Order for briefing on damages, Mr. Raveendran has filed five separate motions⁷seeking discovery from the Plaintiffs or seeking to strike declarations or documents relied upon by the Plaintiffs for the damage calculations. Mr. Raveendran argues that this adversary proceeding has been bifurcated into a separate "damages phase" which should begin with full discovery and include an evidentiary hearing on causation and entitlement to remedies. Mr. Raveendran argues that the Plaintiffs have the burden of proof on

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the issue of damages, and that their refusal to engage in discovery in this new phase is inherently unfair and prejudicial to him.

In response, the Plaintiffs assert that Mr. Raveendran's position ignores the procedural context of this litigation and results in a remarkable turn of events in which: "(1) [Mr. Raveendran] would be free to withhold all relevant discovery from Plaintiffs after having all but acknowledged that his prior sworn discovery answers were materially incomplete and false, (2) Plaintiffs would be barred from presenting the (undisputed in their authenticity) evidence they possess in spite of Raveendran's obstruction, and (3) Mr. Raveendran would be free to demand one- sided discovery from Plaintiffs in exchange for nothing at all."⁸Thus, the Plaintiffs argue that Mr. Raveendran's motions are intended only to delay and cause further substantial prejudice to them.

DISCUSSION

The Plaintiffs sought a default judgment in this adversary proceeding under Fed.R.Civ.P. 37(b)(2)(A)(vi) as a sanction against Defendant Raveendran for his failure to comply with the Court's discovery orders. As directed by Third Circuit's decision in Poulis v. State Farm Fire and Casualty Company,⁹this Court carefully examined six factors to consider whether imposing a default judgment as a discovery sanction was warranted in this proceeding and determined that all six factors were met.¹⁰

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"While a default judgment constitutes an admission of liability, the quantum of damages remains to be established by proof unless the amount is liquidated or susceptible of mathematical computation."¹¹A court "has considerable latitude in determining the amount of damages."¹²The court may conduct a hearing, but is not required to do so "as long as it ensure[s] that there [is] a basis for the damages specified in the default judgment."¹³The Plaintiffs argue that the quantum of damages is straightforward in this case and may be easily ascertainable from and inextricably linked with the Complaint's allegations that pertain to liability, which the Court has accepted as true as a consequence of Mr. Raveendran's default.¹⁴The Complaint alleges that, at Mr. Raveendran's direction, Riju Ravindran breached his fiduciary duties to the Debtor by transferring $533 million to a sham hedge fund (Camshaft Capital Fund, L.P.) which deprived the Debtor of $533 million.¹⁵Then, Mr. Raveendran participated in the Debtor's unauthorized transfer of the Camshaft LP Interest, valued by Camshaft Fund's fund administrator at $540,647,109.29, for $0 in return.¹⁶

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A court must ensure that there is a basis for the damage amount awarded.¹⁷ To do so, some courts have relied upon detailed affidavits and documentary evidence, supplemented by the judge's personal knowledge of the record.¹⁸Here, the Plaintiffs rely, in part, upon the following evidence of damages:

• For damages on Count I (aiding and abetting breach of fiduciary duty):

Declaration of Timothy Pohl, attaching (among other things) the Debtor's bank statements showing six wire transfers that total $533 million (attached as Exhibit B to the Default Motion);

• For damages on Counts II (breach of fiduciary duties), V (conversion), and VI (civil conspiracy): Declaration of Benjamin Finestone filed in support of the Default Motion (Adv. Docket No. 98), Ex. 8 - statement issued to Inspilearn on investment details for the period from December 31, 2022 to March 31, 2023.¹⁹

However, Defendant Raveendran now demands discovery on the issue of damages, moves to strike declarations, and seeks to challenge documents, "new arguments" and "new concessions" he claims are found throughout the Plaintiffs' damages brief. As noted previously, a defendant cannot "credibly argue that the

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assessment of damages was not based on more accurate data, given that its wrongdoing rendered such data unavailable."²⁰

First, Mr. Raveendran seeks to strike the Pohl Declaration as hearsay.²¹The Plaintiffs, however, assert that Pohl Declaration attaches the Debtor's uncontroverted bank records, which are not hearsay, but are admissible under Federal Rules of Evidence 803(6) (business records exception) and 807 (residual exception). The Court agrees that the residual exception is particularly applicable here. Federal Rule of Evidence 807 provides:

(a) In General. Under the following conditions, a hearsay statement is not excluded by the rule against hearsay even if the statement is not admissible under a hearing exception in Rule 803 or 804:

(1) The statement is supported by sufficient guarantees of trustworthiness—after considering the totality of the circumstances under which it was made and evidence, if any, corroborating the statement;

(2) It is more probative on the point for which it is offered than any other evidence that the proponent can obtain through reasonable efforts.

(b) Notice. The statement is admissible only if the proponent gives an adverse party reasonable notice of the intent to offer the statement — including its substance and the declarant's name, so that the party has a fair opportunity to meet it. The notice must be provided in writing before the trial or hearing or in any form during the trial or hearing if the court, for good cause, excuses a lack of earlier notice.

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The Plaintiffs gave Mr. Raveendran notice of their reliance on the Pohl Declaration with the attached bank statements as required by Rule 807(b) by attaching them to the Plaintiffs' Default Motion. The trustworthiness of the bank statements is not seriously in dispute since the Declaration of J. Michael McNutt, filed by Mr. Raveendran, relies in part on the same bank statements.²²The Plaintiffs were denied the opportunity to obtain evidence to corroborate the bank records when Mr. Raveendran failed to participate in discovery. Under Evidence Rule 807, the Pohl Declaration will not be stricken as hearsay because the Declaration is highly material, trustworthy, and the only documentary evidence before the Court concerning the activity of the Debtor's accounts due, at least in part, to Mr. Raveendran's refusal to meaningfully comply with the Plaintiffs' discovery requests.²³

Mr. Raveendran also argues that the Pohl Declaration was withdrawn at the September 9, 2025 hearing, but a review of the transcript does not support this claim. The Plaintiffs did not introduce the Pohl Declaration into evidence at the

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non-evidentiary oral argument, but this does not prevent the court from relying on it.²⁴The Pohl Declaration will not be stricken.

Mr. Raveendran's next arguments for requiring discovery seek to reopen liability issues, rather than explore the Plaintiffs' quantification of damages. He argues that discovery is needed to permit him to reply to various "concessions"

made in the Plaintiffs' Damages Brief, including:

(i) that the Plaintiffs' recovery should come from guarantors and the security under the Credit Agreement, rather than the Defendant;

(ii) that the Plaintiffs' "evidence" of relief under Count I²⁵rests on the erroneous assumption that Think and Learn Private Limited ("TLPL") had only three board members, when there were six;

(iii) that the Plaintiffs must off-set the OCI Settlement Amount;

(iv) that the Alpha Funds were legitimately invested TLPL;

(v) that Tim Pohl was the sole officer of the Debtor at that time the transfers were made;

(vi) Counts V and VI²⁶must fail because Plaintiffs concede the Alpha Funds were transferred to TLPL.

Mr. Raveendran also argues that he must respond to new claims asserted against him in the Plaintiff's Damages Brief based upon these alleged "concessions."

The Court finds that Mr. Raveendran's arguments for discovery on these new issues or so-called "concessions" are groundless. The Complaint has not changed.

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There is no basis to reconsider Mr. Raveendran's liability for the claims in the Complaint. Whether the Plaintiffs — in particular, GLAS and the Lenders -— may also seek remedies against guarantors of the $1.2 billion borrowed under the Credit Agreement is irrelevant to the damage claims before the Court.²⁷Whether there were three or six directors at TLPL does not affect the damages calculation. The fact that Tim Pohl was the only legitimate officer of the Debtor when the Defendant and Riju Ravindran transferred the Debtor's assets has been known since the filing of the Complaint and changes nothing.²⁸Whether some part of the wrongfully transferred Alpha Funds later were traced to a related corporate entity is not a defense to the claims in this adversary. The arguments conflate the damages owed to GLAS/Lenders under the Credit Agreement on the defaulted loans with the Debtor's own, separate injuries suffered on account of Mr. Raveendran's wrongful conduct.²⁹

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Finally, Mr. Raveendran's request to schedule a Fed.R.Civ.P. 26(f) discovery conference is also denied. For the reasons set forth above, Mr. Raveendran has not provided any basis to permit discovery regarding the amount of damages. The Court also concludes that the issues and arguments raised in the Defendant's Motions effectively serve as a Reply to the Plaintiffs' damages brief. No further briefing is necessary. The Scheduling Order for briefing on damages provided: "Following receipt of those submissions, the Court will determine whether argument on the dispute will be of assistance or whether the matter can be decided on the papers."³⁰Federal Rule of Civil Procedure 55(b)(2) grants the Court discretion to determine whether an evidentiary hearing is necessary to determine the appropriate amount of damages for a default judgment.³¹As discussed above, the Defendant has not asserted valid reasons for allowing discovery on the issue of damages or the need for an evidentiary hearing. The Court has determined that an evidentiary hearing on damages would not be helpful or appropriate in this matter. The Court will decide the damage issue on the papers.

reconcile [this] latest defense with [TLPL's] false financial statements and his repeated falsehoods and misrepresentations under oath, all of which hid the movement of the Alpha Funds." Pl.'s Reply in Support of Motion to Quash, Adv. Docket No. 191, ¶ 12.

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AND NOW, upon consideration of the First Motion to Strike, Second Motion to Strike, and the Discovery Motion filed by Mr. Raveendran, and the objections and

replies thereto, and for the reasons stated above, it is hereby ORDERED that the First Motion to Strike, Second Motion to Strike, and the Discovery Motion are

DENIED.

FOR THE COURT:

BRENDAN LINEHAN SHANNON

UNITED STATES BANKRUPTCY JUDGE

Dated: March 19, 2026