Motion for Leave to File Excess Pages filed by Chicanos Por la Causa, Inc. — Marshall v. Prestamos CDFI, LLC (Dkt. 45, E.D. Pa. No. 5:21-cv-04337)

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A motion by defendants Prestamos CDFI, LLC and Chicanos Por La Causa, Inc. to exceed page limits for their motion to dismiss briefing, filed 06/03/22 as Document 45 in Marshall v. Prestamos CDFI, LLC, Case No. 5:21-cv-04337-JMG, Eastern District of Pennsylvania. They say the second amended complaint, filed May 20, 2022, added Chicanos Por La Causa as a defendant, a new claim and more pages to nationwide and state-specific class allegations over a complex loan program enacted in response to the COVID-19 pandemic. They ask to file a memorandum not to exceed 45 pages and a reply not to exceed 30 pages, noting the court granted an earlier page extension on February 15, 2022. Advocacy document; claims are the defendants'.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF PENNSYLVANIA 
 
ALICIA MARSHALL, DANIEL PRONSKY, 
PARIS TOWNSEND, NANCILEE HOLLAND, 
LEONA OWSLEY, KOLAWOLE AHMADOU, 
KIANA DERVIN, KRISTINA HENDERSON, 
DUSTIN INNIS, KELLY STALNAKER and 
JAMIE JONES, individually and on behalf of all 
others similarly situated, 
 
 
 
Plaintiffs, 
 
 
 
v. 
 
PRESTAMOS CDFI, LLC and CHICANOS 
POR LA CAUSA, INC., 
 
 
 
 
Defendants. 
 
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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, Defendants Prestamos 
CDFI, LLC (“Prestamos”) and Chicanos Por La Causa, Inc. (“CPLC”) hereby move the Court for 
leave to exceed the Court’s 20-page limit in connection with Prestamos and CPLC’s Memorandum 
of Law in Support of Defendants’ Motion to Dismiss Plaintiffs’ Second Amended 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. Plaintiffs filed their Amended Complaint on January 14, 2022, ECF 
No. 18, which added to the original pleadings eight named plaintiffs, two statutory claims, and 
nearly double the number of pages. It includes both nationwide and state-specific class allegations 
involving a complex, heavily regulated loan scheme only recently enacted by Congress in response 
to the COVID-19 pandemic. Plaintiffs filed a Second Amended Complaint on May 20, 2022, ECF 
No. 42, which added an additional defendant, CPLC, a new claim, and another fifteen pages, 
Case 5:21-cv-04337-JMG     Document 45     Filed 06/03/22     Page 1 of 3

 
 
 
 
 
exclusive of attachments. Defendants believe they have strong justifications for resolving these 
claims at the pleadings stage. But doing so will require Defendants to address, in a single 
memorandum, the legislative and regulatory background of the loan program; the terms of relevant 
loan documents; and complex issues of federal and state statutory interpretation, standing and 
causes of action, personal jurisdiction and alter ego liability, contractual construction, and 
substantive analysis under the common and statutory laws of multiple states.  
Simply put, Defendants will not, despite their best efforts, have sufficient space to address 
all of the Second Amended Complaint’s deficiencies and legal issues within the 20-page limit. 
Defendants have strived to be as economical as possible with its arguments.  
Defendants therefore request permission to file a Memorandum of Law in support of the 
Motion not to exceed 45 pages, and a reply brief not to exceed 30 pages, exclusive of attachments.  
Prestamos’s previous Motion to Exceed Page Limits for Motion to Dismiss Briefing, ECF 
No. 23, was granted by this Court on February 15, 2022, ECF No. 25. Defendants now request an 
additional extension of the page limit to account for the addition of claims, parties, and allegations 
to the Second Amended Complaint. 
Defendants respectfully request that the Court grant this motion and enter the attached 
proposed order. 
 
 
Case 5:21-cv-04337-JMG     Document 45     Filed 06/03/22     Page 2 of 3

 
 
 
 
 
Dated: June 3, 2022  
 
 
Respectfully, 
 
By: /s/ Marcel S. Pratt 
 
 
 
Marcel S. Pratt (Pa. ID 307483) 
 
 
Michael R. McDonald (Pa. ID 326873) 
 
 
Alexa L. Levy (Pa. ID 327973) 
 
 
1735 Market Street, 51st Floor 
 
 
Philadelphia, PA 19103 
 
 
T: 215-665-8500 / F: 215-864-8999 
 
 
PrattM@ballardspahr.com 
 
 
McDonaldM@ballardspahr.com 
 
 
LevyA@ballardspahr.com 
 
 
 
Roy Herrera* 
 
 
Daniel A. Arellano* 
 
 
Jillian Andrews* 
 
 
530 East McDowell Road 
 
 
Suite 107-150 
 
 
Phoenix, AZ 85004 
 
 
T: 602-567-482 
 
 
roy@ha-firm.com 
 
 
daniel@ha-firm.com 
 
 
jillian@ha-firm.com 
 
 
 
*pro hac vice admission to be sought 
 
 
 
Attorneys for Defendants 
 
 
 
 
 
 
Case 5:21-cv-04337-JMG     Document 45     Filed 06/03/22     Page 3 of 3

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