Motion for Leave to File Excess Pages // Motion — Marshall v. Prestamos CDFI, LLC (Dkt. 14, E.D. Pa. No. 5:21-cv-04337)

Summary

Prestamos CDFI, LLC's motion to exceed page limits for its motion to dismiss briefing, filed 12/10/21 as Document 14 in Alicia Marshall, Daniel Pronsky and Paris Townsend v. Prestamos CDFI, LLC, Case No. 5:21-cv-04337-JMG in the U.S. District Court for the Eastern District of Pennsylvania. The lender says the class action complaint raises nationwide and state-specific claims about a complex, highly regulated loan program recently enacted amid the COVID-19 pandemic. It says its memorandum must cover the program's legislative and regulatory background, standing, statutory interpretation, breach of contract and California consumer protection law, and must attach the loan agreements. It asks leave to file a longer memorandum and reply than the court's standard limit allows.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF PENNSYLVANIA 
ALICIA MARSHALL, DANIEL PRONSKY, 
and PARIS TOWNSEND, individually and on 
behalf of all others similarly situated, 
Plaintiffs, 
v. 
PRESTAMOS CDFI, LLC, 
Defendant. 
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Case No. 5:21-cv-04337-JMG 
MOTION TO EXCEED PAGE LIMITS 
FOR MOTION TO DISMISS BRIEFING 
Pursuant to Section II(B)(4) of the Court’s Policies and Procedures, Defendant Prestamos 
CDFI, LLC hereby moves the Court for leave to exceed the Court’s 20-page limit in connection 
with the Memorandum of Law in Support of Defendant’s Motion to Dismiss Plaintiffs’ Complaint 
(the “Motion”), which is filed concurrently herewith.   
Exceeding the Court’s standard page limitation is necessary to adequately address the legal 
issues involved in the Motion.  The Class Action Complaint, ECF No. 1, includes both nationwide 
and state-specific class allegations involving a complex, highly regulated loan scheme only 
recently enacted by Congress amid the COVID-19 pandemic.  Resolving these claims at the 
pleadings stage requires Defendant to address, in a single memorandum, the legislative and 
regulatory background of the program and the terms of Plaintiff’s loan agreements.  Defendant 
must also brief complex issues of federal statutory interpretation and intent, standing, and 
substantive analysis under common law breach-of-contract principles and California’s consumer 
protection statutes.  Finally, because the Complaint did not include the loan agreements cited in 
Case 5:21-cv-04337-JMG     Document 14     Filed 12/10/21     Page 1 of 3

2 
the Complaint and upon which resolution of the case turns, Defendant must attach them to the 
Motion, further adding to the page length.   
Simply put, Defendant will not, despite its best efforts, have enough space to address all 
legal issues within the 20-page limit.  Defendant has strived to be as economical as possible with 
its arguments.   
Defendant therefore requests permission to file a Memorandum of Law in support of the 
Motion not to exceed 30 pages and a reply brief not to exceed 20 pages, exclusive of attachments.  
Defendant respectfully requests that the Court grant this motion and enter the attached proposed 
order. 
Dated: December 10, 2021 
 
Respectfully, 
By: /s/ Marcel S. Pratt
 
Marcel S. Pratt (Pa. ID 307483) 
 
Michael R. McDonald (Pa. ID 326873) 
 
1735 Market Street, 51st Floor 
 
Philadelphia, PA 19103 
 
T: 215-665-8500 / F: 215-864-8999 
 
PrattM@ballardspahr.com 
 
McDonaldM@ballardspahr.com 
 
Roy Herrera*  
 
Daniel A. Arellano* 
 
1 East Washington Street, Suite 2300 
 
Phoenix, AZ 85004 
 
T: 602-798-5400 / F: 602-798-5595 
 
HerreraR@ballardspahr.com 
 
ArellanoD@ballardspahr.com 
*pro hac vice admission to be sought
 
Attorneys for Defendant  
Case 5:21-cv-04337-JMG     Document 14     Filed 12/10/21     Page 2 of 3

CERTIFICATE OF SERVICE 
I hereby certify that, on December 10, 2021, I caused this Motion To Exceed Page Limits 
For Motion to Dismiss Briefing, along with the attached proposed order, to be filed on the 
Court’s CM/ECF system, which served copies of same on all counsel of record via electronic 
mail.  
/s/ Marcel S. Pratt  
 
Marcel S. Pratt  
Case 5:21-cv-04337-JMG     Document 14     Filed 12/10/21     Page 3 of 3

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