Case docket
American Video Duplicating, Inc. et al. v. Citigroup Inc. et al. — court filings
American Video Duplicating, Inc. et al. v. Citigroup Inc. et al. — 5 court filings in the archive, mostly from U.S. District Court for the Central District of California, filed between April 27, 2020 and February 2, 2021. Among them: 2 complaints, 1 order and 1 stipulation.
Case facts
| Court | U.S. District Court for the Central District of California (2 filings); UNITED STATES DISTRICT COURT (2 filings) |
|---|---|
| Filings | 5 public filings |
| Filed | 2020-04-27 – 2021-02-02 |
| Document types | complaints (2), order (1), stipulation (1) |
| Original PDFs | 5 of 5 |
Case summary
American Video Duplicating, Inc., Tush Law, Ltd. and Kenneth M. Hahn doing business as Cal State Financial, who provide consulting, legal, accounting and tax preparation services, brought this putative class action in the U.S. District Court for the Central District of California, Case No. 2:20-cv-03815-ODW (AGRx), seeking agent fees from lenders under the Paycheck Protection Program established by section 1102 of the CARES Act. They alleged that they assisted clients in securing loans from the defendant banks, that the banks received lender fees from the federal government, and that the banks refused to pay them any agent fees. On November 16, 2020 the court granted the defendants' motions to dismiss the first amended complaint with leave to amend. A second amended complaint followed, and the parties filed a joint stipulation of dismissal with prejudice on February 2, 2021.
Case at a glance
| Parties | Plaintiffs American Video Duplicating, Inc., Tush Law, Ltd. and Kenneth M. Hahn, a sole proprietor doing business as Cal State Financial, individually and on behalf of a class; defendants Citibank, N.A., U.S. Bank National Association, JPMorgan Chase Bank, N.A., Wells Fargo Bank, N.A., Bank of America, N.A., Live Oak Banking Company and Harvest Small Business Finance, LLC |
|---|---|
| Court and docket | U.S. District Court for the Central District of California, Case No. 2:20-cv-03815-ODW (AGRx), Hon. Otis D. Wright II |
| Program | Paycheck Protection Program (PPP), established by the CARES Act, Pub. L. No. 116-136, § 1102 |
| Claims | Claims for agent fees said to be owed to the plaintiffs by the lenders under the Paycheck Protection Program, brought on behalf of a putative class |
| Disposition or status | Motions to dismiss the first amended complaint granted with leave to amend on November 16, 2020; the action was dismissed with prejudice by joint stipulation under Rule 41(a)(1)(A)(ii) filed February 2, 2021 |
| Status checked | 2026-09-23 · against the court docket and DOJ press releases through 2026-09-22 |
What does the first amended complaint allege?
That the plaintiffs assisted clients in securing Paycheck Protection Program loans from the defendants, that the defendants were therefore required to pay them agent fees under the program, that the defendants received lender fees from the federal government and funded loans for borrowers the plaintiffs represented, and that the defendants failed and refused to pay any agent fees. These are the complaint's allegations.
What did the court decide?
It granted the motions to dismiss the first amended complaint with leave to amend, noting that a court need not accept conclusory allegations, unwarranted deductions of fact and unreasonable inferences.
How did the case end?
With a joint stipulation of dismissal with prejudice under Rule 41(a)(1)(A)(ii), filed February 2, 2021 by the three plaintiffs and all seven defendants, after a second amended class action complaint had been filed on December 7, 2020.
Summary written from the documents on this page; every sentence is sourced.
Filings
5 public filings from this case, in filing-date order.
- Class Action Complaint — American Video Duplicating v. Citigroup (C.D. Cal. 2020) (C.D. Cal.)Complaint · PDF
- Corrected First Amended Class Action ComplaintPDF
- Order Granting Defendants’ Motions to DismissOrder · PDF
- Second Amended Class Action ComplaintComplaint · PDF
- Joint Stipulation of Dismissal with PrejudiceStipulation · PDF
Court, dates and docket numbers are as recorded on the filings.