NOTICE by KOLAWOLE AHMADOU, KIANA DERVIN, KRISTINA HENDERSON, NANCILEE HOLLAND, DUSTIN… — Marshall Prestamos (Dkt. 91)

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In this notice dated November 27, 2023 and filed as Document 91 in Civil Action No. 5:21-cv-04337-JMG in the Eastern District of Pennsylvania, the plaintiffs submitted supplemental authority against Chicanos Por La Causa, Inc.'s renewed motion to dismiss the second amended complaint. They attach the Pennsylvania Supreme Court's ruling in Hangey v. Husqvarna Professional Products, Inc., which found venue proper even though only 0.005% of the corporate defendant's national revenue came from the county at issue. The plaintiffs argue that the ruling bears on jurisdiction and that evidence shows CPLC employees regularly conducted loan business in Pennsylvania under Intercompany Services Agreements between the defendants. The notice was signed by Lawrence J. Lederer of Bailey & Glasser LLP.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF PENNSYLVANIA 
 
Alicia Marshall, et al., individually and on 
behalf of all others similarly situated, 
 
 
 
 
Plaintiffs, 
 
 
 
v. 
 
Prestamos CDFI, LLC and Chicanos Por La 
Causa, Inc., 
 
 
 
 
Defendants. 
 
 
 
Civil Action No. 5:21-cv-04337-JMG 
 
 
 
 
 
 
PLAINTIFFS’ NOTICE OF SUPPLEMENTAL AUTHORITY CONCERNING 
DEFENDANT CHICANOS POR LA CAUSA, INC.’S RENEWED MOTION TO 
DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT 
Plaintiffs Alicia Marshall, Daniel Pronsky, Paris Townsend, Nancilee Holland, Leona 
Owsley, Kolawole Ahmadou, Kiana Dervin, Kristina Henderson, Dustin Innis, Kelly Stalnaker 
and Jamie Jones (collectively, “Plaintiffs”), individually and on behalf of all others similarly 
situated, respectfully attach as Exhibit A the Pennsylvania Supreme Court’s recent ruling, 
Hangey v. Husqvarna Professional Products, Inc., No. 14 EAP 2022, --- A.3d ---, 2023 WL 
8102730 (Pa. Nov. 22, 2023), as supplemental authority relevant to defendant Chicanos Por La 
Causa, Inc.’s (“CPLC”) pending renewed motion to dismiss Plaintiffs’ second amended 
complaint (ECF No. 84). 
Although Hangey focuses on where a corporation “regularly conducts business” for 
purposes of Pa. R. Civ. P. 2179(a)(2)’s venue provision, the Pennsylvania Supreme Court 
additionally noted this provision “’has a dual significance: (a) it is essential to the exercise of any 
jurisdiction by the state over a foreign corporation . . . .’” Hangey, 2023 WL 8102730, at *7, 
n.11. See also id., at *17 n.18 (stating that “there may be some opportunities to borrow rationale 
Case 5:21-cv-04337-JMG     Document 91     Filed 11/27/23     Page 1 of 4

in appropriate cases” between venue and jurisdictional principles). The Court there “reaffirmed 
time and again that ‘each case must depend on its own facts’” (id. at *20), and held that venue 
was proper even though the evidence showed that only 0.005% of the corporate defendant’s total 
national revenue was derived from business in the county at issue. Here, the evidence shows, 
inter alia, that CPLC employees regularly conducted PPP business in Pennsylvania for citizens 
of Pennsylvania who sought PPP loans and actually did so pursuant to formal Intercompany 
Services Agreements (“ISAs”) between Defendants. See ECF No. 86 at 12–16 (discussing the 
ISAs and accompanying evidence regarding Defendants’ common use of employees and 
managerial and supervisory personnel). See also ECF No. 84-1 at 6 (“To the extent that CPLC 
employees worked on the PPP program, these employees were provided pursuant to the ISAs 
….”). 
Dated: November 27, 2023 
Bailey & Glasser LLP 
 
By: /s/ Lawrence J. Lederer 
 
Lawrence J. Lederer (Pa. ID 50445) 
Bart D. Cohen (Pa. ID 57606) 
1622 Locust Street 
Philadelphia, PA 19103 
T.: 202.463-2101 
F.: 202.463-2103 
llederer@baileyglasser.com 
bcohen@baileyglasser.com  
 
Bailey & Glasser LLP 
Michael L. Murphy (admitted pro hac vice)  
1055 Thomas Jefferson Street NW, Suite 540 
Washington, DC 20007 
T.: 202.463-2101 
F.: 202.463-2103 
mmurphy@baileyglasser.com  
 
and 
 
Case 5:21-cv-04337-JMG     Document 91     Filed 11/27/23     Page 2 of 4

 
Nolan Heller Kauffman LLP 
Justin A. Heller (admitted pro hac vice) 
Matthew M. Zapala (admitted pro hac vice)  
80 State Street, 11th Floor 
Albany, NY 12207 
T.: 518.449.3300 
F.: 518.432.3123 
jheller@nhkllp.com  
mzapala@nhkllp.com 
 
Attorneys for Plaintiffs and the  
Proposed Class and Subclasses 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 5:21-cv-04337-JMG     Document 91     Filed 11/27/23     Page 3 of 4

CERTIFICATE OF SERVICE 
 
I hereby certify that on November 27, 2023 I caused the foregoing to be filed on the 
Court’s CM/ECF system and for service of same on all counsel of record.  
/s/ Lawrence J. Lederer 
 
Lawrence J. Lederer  
 
Case 5:21-cv-04337-JMG     Document 91     Filed 11/27/23     Page 4 of 4

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