Court filing
Exhibit Exhibit A — Agent Fee Litigation (Dkt. 180.1)
Summary
Exhibit A, filed June 17, 2020 as Document 180-1 in MDL No. 2950, consists of a cover sheet and an email. The email, sent Tuesday, June 16, 2020 by an associate at Manatt, Phelps & Phillips, LLP to counsel for the plaintiff, is titled Brunner v. Square: Arbitration Demand. It demands arbitration of the plaintiff's claims, citing an arbitration provision in the promissory note governing the PPP loan at issue. It asks whether the plaintiff would stipulate by Friday, June 19, 2020 to dismissal of the claims against Square pending arbitration, and states that Square made no loans under the Paycheck Protection Program. It also points to the SBA's list of lenders participating in PPP as of June 1, 2020, attached as a PDF, stating that Square is not on the list.
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Full text
Case MDL No. 2950 Document 180-1 Filed 06/17/20 Page 1 of 2
EXHIBIT A
Case MDL No. 2950 Document 180-1 Filed 06/17/20 Page 2 of 2
Fitz-Patrick, Kay
From: Fitz-Patrick, Kay
Sent: Tuesday, June 16, 2020 20:47
To: 'Michael Adler'; Ben Meiselas; harmeet@dhillonlaw.com
Cc: Richard E. Gottlieb (RGottlieb@manatt.com)
Subject: Brunner v. Square: Arbitration Demand
Attachments: PPP_Lender_List_200601-508.pdf
Michael, Ben, and Harmeet:
By this note, we hereby demand arbitration of plaintiff’s claims in the above matter.
We are in receipt of the promissory note entered into between Sweet Laurel and Celtic Bank, and which governs all
disputes arising out of the PPP loan at issue here.
In the complaint, you allege that plaintiff acted as Sweet Laurel’s agent with respect to the loan, and the arbitration
provision requires the arbitration of all disputes arising under or in connection with the Promissory Note, including
claims by agents and/or beneficiaries of the PPP Program. Please let us know by Friday, June 19, 2020 whether your
client would be willing to stipulate to the dismissal of the claims against Square pending arbitration.
We have already advised you that Square made no loans under the Paycheck Protection Program and that, on that basis
alone, it should be dismissed. Further to our early resolution efforts, we call your attention to the SBA’s list of lenders
participating in PPP as of June 1, 2020. Square is not on the list. I’ve attached a searchable PDF, and refer you to the
official link, which is found at: https://www.sba.gov/sites/default/files/2020-06/PPP_Lender_List_200601-508.pdf
We are available to discuss at your convenience.
Sincerely,
Kay
Kay Fitz-Patrick
Associate
__________________________
Manatt, Phelps & Phillips, LLP
2049 Century Park East
Suite 1700
Los Angeles, CA 90067
D (310) 312-4257 F (310) 312-4224
KFitz-Patrick@manatt.com
manatt.com
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File and source
- File
- gov.uscourts.jpml.1161172.180.1.pdf
- Size
- 181,612 bytes
- SHA-256
- 88d1d3076b7455e95cc91c8709655ee3f5806e05a9b09519cee34b17334e8745
- Original
- No public link identified.