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Home Court filings Blueacorn Beringer Nced 187990 Exhibit J - AZ Attorney General Consumer Complaints — Blueacorn Beringer (Dkt. 36.11)

Court filing

Exhibit J - AZ Attorney General Consumer Complaints — Blueacorn Beringer (Dkt. 36.11)

No. 5:21-cv-00251-BO · Doc. 36-11 · Docket on CourtListener

Summary

Exhibit J in No. 5:21-cv-00251-BO, filed July 6, 2021 as Doc. 36-11, is a 17-page set of notices from the Office of the Arizona Attorney General, Consumer Information and Complaints. The notices are dated June 28, 2021, addressed to Blue Acorn in Raleigh, and each asks for a written response within ten (10) days. Each notice attaches a consumer complaint form, including complaints 21-003731 and 21-004978, naming Blue Acorn at a Scottsdale, AZ address. The complainants describe applying for PPP loans through Blue Acorn, one approved for $18,025.00 and another for $2,852.00, and state that the funds were never deposited, or that personal information was submitted after a YouTube ad.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

EXHIBIT J

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 1of17
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PHOENIX, AZ 85004-1592

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Page 2 of 17

Filed 07/06/21

-00251-BO Document 36-11

21-cv

Case 5
OFFICE OF THE ARIZONA ATTORNEY GENERAL CONSUMER INFORMATION &
Mark BRNovicH ComPLaINTSs

ATTORNEY GENERAL Civic Limcation Division (602) 542-5763
ConsumER PROTECTION & ADVOCACY SECTION (In-State Oxy) (800) 352-8434

June 28, 2021
BLUE ACORN
4000 Westchester BLVD

Suite 280
Raleigh, NC 27607

RE: CIC 21-003731 , 0S (FIFTH NOTICE)
Dear Sir or Madam:
Our Office recently asked you to respond to the attached complaint. We have not yet received your response.

It is important that we receive your written response fully addressing the matter raised in the consumer complaint no
later than ten (10) days from the date of this letter.

Thank you for your immediate attention to this matter.
Sincerely,

Consumer Information and Complaints

CPA:SpF (07/15)

2005 NortH CENTRAL Avenue, PHoenm, AZ 85004 + PHone 602.542.5763 * Fax 602.542.4579 »* www.azac.cov « ConsuMERINFO@azAG.cov

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 3of17
CONSUMER COMPLAIN!

OFFICE OF THE ARIZONA ATTORNEY GENERAL
ATTORNEY GENERAL MARK BRNOVICH
WwWwW.azag.gov Complaint/Confirmation #: 21-003731

Section 1: YOUR INFORMATION

YOUR NAME YOUR STREET ADDRESS

Te :

BEST NUMBER TO CALL DURING THE DAY EMAIL ADDRESS CITY STATE ZIP CODE
PO errrr—(‘i‘ial

Section 2: WHO YOU ARE COMPLAINING AGAINST
NAME OF BUSINESS YOU ARE COMPLAINING AGAINST STREET ADDRESS OF BUSINESS

Blue Acorn 7014 E Camelback Rd , suite 1452
PHONE NUMBER OF BUSINESS EMAIL ADDRESS CITY STATE ZIP CODE
Scottsdale AZ 85251

Section 3: AUTHORIZATIONS

May we send a copy of this to the person or firm you are complaining against? Yes Tl ves [NO

(By selecting the answer, “Yes,” to the question, “May we send a copy of this to the person or business you are complaining against,” | hereby authorize the Office of the
Arizona Attorney General to communicate with the party(ies) against whom | have filed this complaint, | also authorize the party(ies) against whom | have filed this
complaint to communicate with and provide information related to my complaint, including disclosure of non-public personal information, to the Office of the Arizona
Attorney General in connection with this complaint. If your response is “No,” we may be prevented from taking any action on your complaint.)

May we provide your name and telephone number to the media in the event of an inquiry about this matter? No rT yes PF NO

May we send a copy of your complaint to another government agency for its review or investigation? Yes l- yes F' No

Section 4: STATISTICAL INFORMATION (Optional)
For statistical purposes, please indicate:

Your Age: Between 31-59 Military/Veteran:
I~ Under the age of 30 I” Between the age of 60-79 I~ Currently in military service
I~ Between the age of 31-59 T” Over the age of 80 I Aveteran
How did you hear about our complaint form (please choose only one): Media: Newspaper/Radio/TV
I~ Called Phoenix AG Office I~ Visited an AG Satellite Office f Another Arizona State Agency/State Legislator
I~ Called Tucson AG Office I~ An Out Of State Agency [~ Attended AG Presentation/Event
I~ Went onto AG Website I~ Media: Newspaper/Radio/TV [~ Other

Section 5: TELEMARKETING | ROBOCALL COMPLAINTS (if your complaint is not against a telemarketer, skip .to Section 6)
Is your complaint about a telemarketer or robocall? No ves [NO
Are you on the National Do Not Call Registry? 7 YES [I NO

Date of phone call List the phone number that called you List the phone number that received the phone call

Was the caller offering a product or service? M™ ves [No

What was the call about?

You do not need to fill out Section 6 unless applicable to your complaint. Please make sure to review your complaint for accuracy and then sign
and date your complaint (located at Section 7 at the end of this form).

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page4of17
Was an oral or written warranty given? No [~ YES [7 NO

Did you sign any documents? No [7 YES [I~ NO ff yes, please attach a copy if possible.

Date of transaction: 04/07/2021 Place of transaction: home
Witness to transaction: Salesperson's name:
Total amount of damages (list actual loss only): $0

Have you complained to the business? No T YES [I~ No

What was the response?

Was the product or service advertised? Yes I~ YES [~ NO
If yes, indicate the date and how it was advertised: 04/07/2021 Youtube ad

Do you have an attorney? No I~ YES [7 NO

If yes, please provide the attorney's name and address:

Is any legal action pending? I~ YES [™ No

List any other consumer agencies contacted:

PLEASE EXPLAIN THE ENTIRE CIRCUMSTANCES SURROUNDING YOUR COMPLAINT (attach additional pages if necessary)

| was reviewing a youtube video and an ad came up from Blue Acorn(listed on their web page Scottsdale, AZ)offering to file a PPP loan with the
SBA. | submitted private information including my email address, a picture of my driver's license, and two pages from my tax form. | also entered
my user name and password on my checking account( | changed the p.w. withing minutes of realizing something was not right). This is not a real
business after doing some research. | thought a youtube ad would be real,

Section 7: DECLARATION

| declare, under penalty of perjury, that the facts and statements contained in this declaration, including any attached Statements, are true, correct,
and based upon my personal knowledge.

Signature: in Date: 04/07/2021

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page5of17
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Page 6 of 17

Filed 07/06/21:

21-cv-00251-BO Document 36-11

Case 5
CONSUMER INFORMATION &
Mark BRNovicH OFFICE OF THE ARIZONA ATTORNEY GENERAL

CowmPLainTs
ATTORNEY GENERAL Civit Limication Division (602) 542-5763
CONSUMER PROTECTION & Apvocacy SECTION (In-Stare Ory) (800) 352-8431
June 28, 2021
BLUE ACORN
4000 Westchester BLVD
Suite 280

Raleigh, NC 27607

RE: CIC 21-004978 / po (FOURTH NOTICE)

Dear Sir or Madam:

Our Office recently asked you to respond to the attached complaint. We have not yet received your response.

It is important that we receive your written response fully addressing the matter raised in the consumer complaint no
later than ten (10) days from the date of this letter.

Thank you for your immediate attention to this matter.
Sincerely,

Consumer Information and Complaints

CPA:SpF (07/15)

2005 NortH Central Avenue, PHoenix, AZ 85004 * PHone 602.542.5763 » Fax 602.542.4579 « WWW AZAG.GOY * CONSUMERIWFO@AzAG.GOV

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page /7of17
CONSUMER COMPLAINT

OFFICE OF THE ARIZONA ATTORNEY GENERAL

ATTORNEY GENERAL MARK BRNOVICH
WWW.aZag.gov Complaint/Confirmation #: 21-004978

Section 1: YOUR INFORMATION

YOUR NAME YOUR STREET ADDRESS
BEST NUMBER TO CALL DURING THE DAY EMAIL ADDRESS CITY STATE ZIP CODE
a eee

Section 2: WHO YOU ARE COMPLAINING AGAINST

NAME OF BUSINESS YOU ARE COMPLAINING AGAINST STREET ADDRESS OF BUSINESS

Blue Acorn / 7014 East camelback road

PHONE NUMBER OF BUSINESS EMAIL ADDRESS CITY STATE ZIP CODE
Support@blue.co 85251 AZ Scottsdale

Section 3: AUTHORIZATIONS

May we send a copy of this to the person or firm you are complaining against? Yes T yes [NO

(By selecting the answer, "Yes," to the question, “May we send a copy of this to the person or business you are complaining against,” | hereby authorize the Office of the
Arizona Attorney General to communicate with the party(ies) against whom | have filed this complaint. | also authorize the party(ies) against whom | have filed this
complaint to communicate with and provide information related to my complaint, including disclosure of non-public personal information, to the Office of the Arizona
Attorney General in connection with this complaint. If your response is “No,” we may be prevented from taking any action on your complaint.)

May we provide your name and telephone number to the media in the event of an inquiry about this matter? Yes I~ YES IT No

May we send a copy of your complaint to another government agency for its review or investigation? Yes yes F NO

Section 4: STATISTICAL INFORMATION (Optional) -
For statistical purposes, please indicate:

Your Age: Between 60-79 Military/Veteran:
I” Under the age of 30 I Between the age of 60-79 I~ Currently in military service
I~ Between the age of 31-59 I~ Over the age of 80 I~ Aveteran
How did you hear about our complaint form (please choose only one): Went onto AG Website
I Called Phoenix AG Office I~ Visited an AG Satellite Office I Another Arizona State Agency/State Legislator
I~ Called Tucson AG Office I~ An Out Of State Agency I~ Attended AG Presentation/Event
I Went onto AG Website I~ Media: Newspaper/Radio/TV I~ Other

(If your complaint is not against a telemarketer, skip to Section 6)

Section 5: TELEMARKETING / ROBOCALL COMPLAINTS
ls your complaint about a telemarketer or robocall? No I~ YES [~ NO

Are you on the National Do Not Call Registry? ITT YES TF NO
Date of phone call List the phone number that called you List the phone number that received the phone call

Was the caller offering a product or service? Pr yes fFNo

What was the call about?

You do not need to fill out Section 6 unless applicable to your complaint. Please make sure to review your complaint for accuracy and then sign
and date your complaint (located at Section 7 at the end of this form).

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 8of17
, V

Was an oral or written warranty given? No [ YES [7 No

Did you sign any documents? Yes I~ YES [NO __ Ifyes, please attach a copy if possible.

Date of transaction: 04/18/2021 Place of transaction: Online
Witness to transaction: Salesperson's name:
Total amount of damages (list actual loss only): $ 18025

Have you complained to the business? Yes I~ YES [7 NO

They are receiving a high number of Of applications but rest assured we are working through every single one
What was the response? ;
of them and you were already SBA approved so please be patient

Was the product or service advertised? Yes I” YES rT No
If yes, indicate the date and how it was advertised: 03/01/2021 Facebook /TV

Do you have an attomey? No I~ YES [7 No

If yes, please provide the attorney's name and address:

Is any legal action pending? [” YES [~ NO
List any other consumer agencies contacted:

PLEASE EXPLAIN THE ENTIRE CIRCUMSTANCES SURROUNDING YOUR COMPLAINT (attach additional pages if necessary)

| went through blue acorn hoping to get my SBA loan for my small business. | started my application on March 8th 2021 and was finally approved a
month later with a loan amount of $18,025.00 I've been paiently waiting for my funds and they have never reached my account. | started reading
the reviews on blue acorn an it seems to be a scam | signed my DocuSign documents on 4/18/2021 and it said | would be funded into my account
in 3-business days !! Here we are May 10th and nothing yet!! I've been approved over 2-months and nothing

Section 7: DECLARATION

| declare, under penalty of perjury, that the facts and statements contained in this declaration, including any attached statements, are true, correct,
and based upon my personal knowledge.

Signature: Date: 05/08/2021

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page9of17
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Page 10 of 17

Filed 07/06/21

21-cv-00251-BO Document 36-11

Case 5
Consumer INFORMATION &
Basic Brncvicil OFFICE OF THE ARIZONA ATTORNEY GENERAL

CompLaints
ATTORNEY GENERAL Civil Litigation Division (602) 542-5763
CONSUMER PROTECTION & ADvocacy SECTION (In-Stave Onty) (800) 352-8431

June 28, 2021
BLUE ACORN
4000 Westchester BLVD

Suite 280
Raleigh, NC 27607

RE; CIC 21-005074 —r (FOURTH NOTICE)
Dear Sir or Madam:
Our Office recently asked you to respond to the attached complaint. We have not yet received your response.

It is important that we receive your written response fully addressing the matter raised in the consumer complaint no
later than ten (10) days from the date of this letter.

Thank you for your immediate attention to this matter.
Sincerely,

Consumer Information and Complaints

CPA:SpF (07/15)

2005 My RED AY EOD FT AB CF DECENT SE-1 VRAD TIBI” * PAGE TT OPT?
CONSUMER COMPLAINT

OFFICE OF THE ARIZONA ATTORNEY GENERAL
ATTORNEY GENERAL MARK BRNOVICH
WWW.aZag.gov Complaint/Confirmation #: 21-005074

Section 1: YOUR INFORMATION
YOUR NAME YOUR STREET ADDRESS

BEST NUMBER TO CALL DURING THE DAY EMAIL ADDRESS CITY STATE ZIP CODE

Section 2: WHO YOU ARE COMPLAINING AGAINST

NAME OF BUSINESS YOU ARE COMPLAINING AGAINST STREET ADDRESS OF BUSINESS

Blue Acorn 7014 E Camelback Rd Ste, Ste 1452

PHONE NUMBER OF BUSINESS EMAIL ADDRESS CITY STATE ZIP CODE
Scottsdale AZ 85251

Section 3: AUTHORIZATIONS

May we send a copy of this to the person or firm you are complaining against? Yes ves TNO

(By selecting the answer, “Yes,” to the question, “May we send a copy of this to the person or business you are complaining against,” | hereby authorize the Office of the
Arizona Attorney General to communicate with the party(ies) against whom | have filed this complaint. | also authorize the party(ies) against whom | have filed this
complaint to communicate with and provide information related to my complaint, including disclosure of non-public personal information, to the Office of the Arizona
Attorney General in connection with this complaint. If your response is “No,” we may be prevented from taking any action on your complaint.)

May we provide your name and telephone number to the media in the event of an inquiry about this matter? Yes yes [NO

May we send a copy of your complaint to another government agency for its review or investigation? Yes I~ YES l™ No

Section 4: STATISTICAL INFORMATION (Optional)

For statistical purposes, please indicate:
Your Age: Between 31-59 Military/Veteran:
I Under the age of 30 I~ Between the age of 60-79 I Currently in military service
I~ Between the age of 31-59 I~ Over the age of 80 T~ A veteran
How did you hear about our complaint form (please choose only one): Went onto AG Website
I~ Called Phoenix AG Office I~ Visited an AG Satellite Office I~ Another Arizona State Agency/State Legislator
I~ Called Tucson AG Office I~ An Out Of State Agency I~ Attended AG Presentation/Event
I~ Went onto AG Website I~ Media: Newspaper/Radio/TV T~ Other

Section 5: TELEMARKETING / ROBOCALL COMPLAINTS (If your complaint is not against a telemarketer, skip to Section 6)

Is your complaint about a telemarketer or robocall? No [ YES [ NO
Are you on the National Do Not Call Registry? I~ ves [I NO

Date of phone call List the phone number that called you List the phone number that received the phone call

Was the caller offering a product or service? IT YES [ NO

What was the call about?

You do not need to fill out Section 6 unless applicable to your complaint. Please make sure to review your complaint for accuracy and then sign
and date your complaint (located at Section 7 at the end of this form).

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 12 of 17
Section 6: COMPLAINT DETAILS

Was an oral or written warranty given? No [ YES [ NO
Did you sign any documents? I~ YES [I~ NO _Ifyes, please attach a copy if possible.

Date of transaction: 04/02/2021 Place of transaction: Internet
Witness to transaction: Salesperson's name: Blue Acorn
Total amount of damages (list actual loss only): $ 20832

Have you complained to the business? I” YES [7 NO

What was the response?

Was the product or service advertised? No [T YES [I NO

If yes, indicate the date and how it was advertised:

Do you have an attorney? No T YES [7 NO

lf yes, please provide the attorney's name and address:

Is any legal action pending? T YES [7 NO
List any other consumer agencies contacted: BBB

PLEASE EXPLAIN THE ENTIRE CIRCUMSTANCES SURROUNDING YOUR COMPLAINT (attach additional pages if necessary)

| applied for a PPP loan on April 2nd, 2021. | was fully approved and signed my loan documents committing to the loan on April 9th, 2021. | was to
be funded $20,832.00 to my Wells Fargo checking account. | was told this process would take 7-10 days from being approved. It is now May 11th.
2021 and Blue Acorn is nowhere to be found, wont respond to their online chat, wont take phone calls, and | am in debt to the SBA almost $21,000
dollars. The worst part is | have to prove | used the money on business expenses 8-24 weeks from getting the loan, | am not burning up that time
period and Blue Acorn and their lenders are holding my funds. | believe their lender is Capital Plus Financial (also do not take or return calls). |
have provided my very personal identifying information and believe at this point | have been defrauded out of almost $21,000. | will work with you ,
and the DOJ is necessary to prosecute these thieves to the fullest extent of the law. My business needed that money in the worst way. PLEASE
HELP.

Section 7: DECLARATION

| declare, under penalty of perjury, that the facts and statements contained in this declaration, including any attached statements, are true, correct,
and based upon my personal knowledge.

Signature iin Date: 05/11/2021

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 13 of 17
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Page 14 of 17

Filed 07/06/21

21-cv-00251-BO Document 36-11

Case 5
Mark Brnovic OFFICE OF THE Aacean ATTORNEY GENERAL CoNsUMER INFORMATION &

ComPLaINTs
ATTORNEY GENERAL Civic LimicaTion Division (602) 542-5763
CoNsUMER PROTECTION & Apvocacy SECTION (In-State Onvy) (800) 352-8431
June 28, 2021
BLUE ACORN
4000 Westchester BLVD
Suite 280
Raleigh, NC 27607

RE: CIC 21-004931 / a (FOURTH NOTICE)

Dear Sir or Madam:
Our Office recently asked you to respond to the attached complaint. We have not yet received your response.

It is important that we receive your written response fully addressing the matter raised in the consumer complaint no
later than ten (10) days from the date of this letter.

Thank you for your immediate attention to this matter,
Sincerely,

Consumer Information and Complaints

CPA:SpF (07/15)

2005 North Centra. Avenue, PHoeNix, AZ 85004 * PHone 602.542.5763 * Fax 602.542.4579 » www.azss.cov * CONSUMERINFO@AzZAG.GOV

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 15 of 17
CONSUMER COMPLAINT

OFFICE OF THE ARIZONA ATTORNEY GENERAL
ATTORNEY GENERAL MARK BRNOVICH

WWW.aZag.gov Complaint/Confirmation #: 21-004931
Section 1: YOUR INFORMATION
YOUR NAME YOUR STREET ADDRESS
a
BEST NUMBER TO CALL DURING THE DAY EMAIL ADDRESS CITY STATE ZIP CODE
S| «Se

Section 2: WHO YOU ARE COMPLAINING AGAINST

NAME OF BUSINESS YOU ARE COMPLAINING AGAINST STREET ADDRESS OF BUSINESS

Blueacorn 7014 E, Camelback Rd , ste 1452

PHONE NUMBER OF BUSINESS EMAIL ADDRESS CITY STATE ZIP CODE
000-000-0000 support@blueacornppp.com Scottsdale AZ 85251

“Section 3: AUTHORIZATIONS

May we send a copy of this to the person or firm you are complaining against? Yes ~ yes [NO

(By selecting the answer, “Yes,” to the question, “May we send a copy of this to the person or business you are complaining against,” | hereby authorize the Office of the
Arizona Attorney General to communicate with the party(ies) against whom | have filed this complaint, | also authorize the party{ies) against whom | have filed this
complaint to communicate with and provide information related to my complaint, including disclosure of non-public personal information, to the Office of the Arizona
Attorney General in connection with this complaint. If your response is “No,” we may be prevented from taking any action on your complaint.)

May we provide your name and telephone number to the media in the event of an inquiry about this matter? Yes TT ves [NO

May we send a copy of your complaint to another government agency for its review or investigation? Yes Tr yes F NO

Section 4: STATISTICAL INFORMATION (Optional)
For statistical purposes, please indicate:

Your Age: Between 31-59 Military/Veteran: Veteran
I~ Under the age of 30 I~ Between the age of 60-79 I~ Currently in military service
I~ Between the age of 31-59 I~ Over the age of 80 I~ A veteran
How did you hear about our complaint form (please choose only one): Called Phoenix AG Office
I Called Phoenix AG Office I~ Visited an AG Satellite Office I~ Another Arizona State Agency/State Legislator
I~ Called Tucson AG Office I~ An Out Of State Agency I~ Attended AG Presentation/Event
I~ Went onto AG Website I~ Media: Newspaper/Radio/TV I~ Other

Section 5: TELEMARKETING / ROBOCALL COMPLAINTS (If your.complaint is not.against a telemarketer, skip to Section 6)

Is your complaint about a telemarketer or robocall? No I~ YES [7 NO
Are you on the National Do Not Call Registry? I~ Yes I NO
Date of phone call List the phone number that called you List the phone number that received the phone call

Was the caller offering a product or service? IT ves F' No

What was the call about?

You do not need to fill out Section 6 unless applicable to your complaint. Please make sure to review your complaint for accuracy and then sign
and date your complaint (located at Section 7 at the end of this form).

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 16 of 17
Was an oral or written warranty given? Yes I~ YES Tl no

Did you sign any documents? Yes 7” YES [I~ NO {If yes, please attach a copy if possible.

Date of transaction: 04/18/2021 Place of transaction: Internet
Witness to transaction: Salesperson's name: unknown
Total amount of damages (list actual loss only): $ 2852

Have you complained to the business? Yes I~ YES [~ NO

What was the response? The same robo response of 7-10 business days.

Was the product or service advertised? Yes I~ YES [7 NO
If yes, indicate the date and how it was advertised: 03/01/2020 | believe online and YouTube

Do you have an attorney? No I YES [~ No

If yes, please provide the attorney's name and address:

Is any legal action pending? I~ YES [~ No
List any other consumer agencies contacted: Texas Att Gen.

PLEASE EXPLAIN THE ENTIRE CIRCUMSTANCES SURROUNDING YOUR COMPLAINT (attach additional pages if necessary)

On or about April 6th, 2021,! applied for a PPP Loan (Payroll Protection Program) thru a company called Blueacorn, supposedly based in
Scottsdale, AZ. Specifically addressed at the fashion square mall. On 04/08/2021,1 was approved by the SBA for a loan of $2,852.00, and was
given my lender number, and told 7-10 business days to sign my papers via Docusign. All this communication was done via emails, which | do
still have. On 04/18/21, | signed my papers for my loan and was told 7-10 business days and the money would be deposited into my account. As
of 05/06/21, | still have received no deposit. | have filed numerous Support requests and am being a robo response of 7-10 business days. And in
one email told only 2-4 more days for deposit to be made. Starting on or about 05/04/21, | started making contact with the SBA, along with a FB
group called ppp funding group and discovered there are many of us in the same situation having the same issues, On 05/06/21, | discovered
that the address for Blueacorn for the fashion Square mall was non existent. These people cannot be reached. But there is a Blueacorn based in
Charlotte, S.C. that says they are not the same as the ones doing this. | believe myself and numerous others are victims of fraud.

Section 7: DECLARATION

| declare, under penalty of perjury, that the facts and statements contained in this declaration, including any attached statements, are true, correct,
and based upon my personal knowledge.

Signature: Date: 05/06/2021

Case 5:21-cv-00251-BO Document 36-11 Filed 07/06/21 Page 17 of 17

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