Report Of Rule 26(f) Conference by Prestamos CDFI, LLC — Marshall v. Prestamos CDFI, LLC (Dkt. 97, E.D. Pa. No. 5:21-cv-04337)

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U.S. District Court for the Eastern District of Pennsylvania · No. 5:21-cv-04337-JMG · Doc. 97 · 2024-02-21 · Docket on CourtListener

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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,  
 
Defendant. 
 
 
 
 
 
 
 
 
 
 
 
 
Case No. 5:21-cv-04337-JMG 
 
JOINT RULE 26(f) REPORT 
In accordance with Fed. R. Civ. P. 26(f) and the Court’s instruction dated February 21, 
2024, counsel for the parties conferred on February 29, 2024, and submit the following report of 
their meeting for the Court’s consideration: 
VII. 
Anticipated Scope of Discovery 
Plaintiffs 
A. Summarize with specificity those issues on which the Parties will need to conduct 
discovery. Identify categories of information each Party needs in discovery and 
why.  
Plaintiffs generally anticipate that the scope of discovery will be coincident with 
the existing scope of discovery, which has been the subject of substantial and 
ongoing discussions among the parties, the primary exceptions being discovery 
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regarding the PPP loans of Plaintiffs in this action, and issues related to class 
members in the states in which Plaintiffs reside. 
B. Anticipated number of interrogatories per Party: 
20. 
C. Anticipated number of depositions per Party: 
40. 
D. To the extent either Party proposes to exceed the presumptive limits in the Federal 
Rules of Civil Procedure for discovery, explain the basis for that proposal.  
This case involves what Plaintiffs believe may be hundreds or thousands of 
proposed class members, and many millions of dollars or more in disputed and 
unfunded PPP loan proceeds as Prestamos committed to funding more PPP loans 
in 2021 than any other lender according to the SBA. Plaintiffs will therefore need 
to pursue substantial discovery commensurate with the scope of this case as is 
common under the Federal Rules of Civil Procedure for complex litigation 
including this case. 
E. Do the Parties anticipate the need for any third-party discovery? If so, identify the 
likely third-parties and the discovery to be sought. 
Yes. Plaintiffs anticipate seeking non-party discovery from Blueacorn and the 
SBA regarding their communications and dealings with Defendants concerning 
Plaintiffs’ and class members’ PPP loans, as well as other third-parties including 
any third-parties to whom Defendants may have transferred any applicable PPP 
loan proceeds or fees that Plaintiffs contend should be paid to Plaintiffs and the 
class. 
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F. Do the Parties anticipate the need for experts? If so, identify the subjects on which 
the expert(s) may opine.  
Yes. Plaintiffs presently anticipate needing experts. For example, Plaintiffs 
anticipate needing one or more experts to opine as to the alleged damages 
incurred by the members of the class and any subclasses. Plaintiffs also anticipate 
needing one or more experts in forensic accounting and related areas depending 
on Defendants’ disposition of PPP loan proceeds Plaintiffs contend should be paid 
to Plaintiffs and the class. 
Defendant 
A. Summarize with specificity those issues on which the Parties will need to conduct 
discovery. Identify categories of information each Party needs in discovery and why. 
i. Information about each of Named Plaintiff’s business, including history, 
financial and revenue information, tax returns, and the impact on their 
business caused by the Covid-19 pandemic to assess the Plaintiff’s 
eligibility for a second-draw PPP loan. 
ii. Information verifying the representations each Named Plaintiff made to 
SBA, Blueacorn, Prestamos, or others during the application process for a 
second-draw PPP loan to assess the veracity of information provided in 
the application process and the Plaintiff’s eligibility for a second-draw 
PPP loan. 
iii. All communications each Named Plaintiff had with SBA, Blueacorn, their 
bank, and others about their application for a second-draw PPP loan to 
assess the veracity of information provided in the application process, the 
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Plaintiff’s eligibility for a second-draw PPP loan, and the Plaintiff’s 
knowledge with respect to the status of their application for a second-draw 
PPP loan. 
iv. Information regarding each Named Plaintiff’s efforts to secure 
disbursement of loan proceeds from Prestamos or another entity, and 
efforts to apply for a second-draw PPP loan from any other lender to 
assess the veracity of the Plaintiff’s allegation that they regularly inquired 
about the status of their loan and were unable to secure a second-draw PPP 
loan from another source.  
v. Information about the bank accounts into which each Named Plaintiff 
sought to have their second-draw PPP loan deposited to assess the 
Plaintiff’s eligibility for a second-draw PPP loan and to investigate 
reasons why the Plaintiff’s loan disbursement may have been rejected or 
otherwise delayed. 
vi. Information detailing and verifying any harm each Named Plaintiff 
allegedly suffered as a result of any delay in receiving a second-draw PPP 
loan. 
B. Anticipated number of interrogatories per Party:  
 
 
 
  35      . 
C. Anticipated number of depositions per Party:1 
 
 
 
 
  40  .2 
                                                          
1 Were the Court to consolidate this matter with Drevnak v. Prestamos CDFI, LLC, No. 2:23-cv-
2777-JMG, as requested by the parties, see infra § XVI, Prestamos would need to depose the 
eleven Named Plaintiffs in Marshall and the seven Named Plaintiffs in Drevnak.  Any 
consolidation, however, would not require any additional deposition of the single Defendant in 
this matter, Prestamos. 
 
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D. To the extent either Party proposes to exceed the presumptive limits in the Federal 
Rules of Civil Procedure for discovery, explain the basis for that proposal. 
 
Defendant believes this case will be resolved with evidence from Named 
Plaintiffs, which will establish that they do not have claims for relief. In any event, 
Defendant also intends to oppose certification of the plaintiff class and, accordingly, 
does not believe class-wide discovery is appropriate at this juncture.  There is also 
substantial third-party discovery.  Prestamos recently served subpoenas upon 
Blueacorn, its lender service provider, as well as Evolve Bank & Trust which was 
involved in the attempts to fund plaintiffs’ loan transactions. 
E. Do the Parties anticipate the need for any third-party discovery? If so, identify the likely 
third-parties and the discovery to be sought. 
 
Yes. Defendant anticipates seeking non-party discovery from Blueacorn, 
SBA, Evolve, and Plaintiffs’ financial institutions regarding their communications 
and dealings with Plaintiffs. 
F. Do the Parties anticipate the need for experts? If so, identify the subjects on which the 
expert(s) may opine.  
 
Yes. At a minimum, and without waiving the right to retain additional experts, 
Defendant anticipates retaining of several experts relating to both Class Certification 
and Plaintiffs claims on the merits and to refute Plaintiffs’ claimed damages.  
VIII. Status of Discovery 
The parties exchanged initial disclosures on January 14, 2022.  Plaintiffs served 
interrogatories and requests for production on November 16, 2021. Defendant served its 
responses and objections on January 19, 2022.  Plaintiffs served their first set of requests for 
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admission on April 5, 2023, and Defendant responded on May 10, 2023.  Plaintiffs served a  
second set of requests for production on November 27, 2023, and a second set of interrogatories 
on November 30, 2023.  Defendant served its responses and objections on January 19, 2024.   
Defendant served its first interrogatories and first requests for production on July 21, 
2023.  Plaintiffs responded to the requests for production on August 21, 2023, and to the 
interrogatories on August 28, 2023.  Plaintiffs served a supplemental response to the 
interrogatories on February 2, 2024.   
IX. 
Proposed Case Management Deadlines:   
The parties have agreed to detailed proposed case management plan governing both 
actions to address the class certification discovery and class certification which is attached as 
Exhibit A.  The dates requested by the Court are set forth below. 
A. 
Deadline to serve initial disclosures under Rule 
26(a)(1) (*must be exchanged at least one (1) 
business day before Rule 16 conference): ................... exchanged January 14, 2022 
B. 
Deadline to amend pleadings to add claims or 
Parties (*must be as early as practicable to avoid 
prejudice or unnecessary delays): ..................................................... See Exhibit A.. 
C. 
Deadline for affirmative expert reports (if any) and 
disclosure of lay witness opinion testimony with 
related information and documents (if any):  ...................................... See Exhibit A 
D. 
Deadline for rebuttal expert reports (if any): ...................................... See Exhibit A 
E. 
Deadline to complete discovery: ......................................................... See Exhibit A 
F. 
If any Party seeks more than 120 days for fact discovery, explain why. 
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Defendant has produced hundreds of thousands of pages of documents and 
complex financial data. In addition, the large number of named Plaintiffs require 
more depositions than the average civil case. The parties agree that discovery is 
and will continue to be voluminous and will require more than 120 days to 
complete.  
G. 
Deadline to file motion for summary judgment:................................ See Exhibit A. 
H. 
Estimated trial ready date: ................................................................. See Exhibit A. 
I. 
Estimated Number of Days for Trial: ...................................................................15. 
X. 
Deposition Scheduling 
The Court expects the Parties to meet and confer as soon as practicable to set aside dates 
to hold open for depositions before the close of discovery. If the Parties have not already done 
so, the Court will order the Parties to do so within two weeks of the Rule 16 conference. 
 
Have the Parties set aside dates for deposition? ___ Yes   x   No 
 
If yes, what are those dates? ________________________________________________ 
 
If no, when do the parties intend to confer, and how many dates do they intend to set 
aside? 
This is a complex class action and the parties will confer with respect to depositions and 
complete depositions prior to the close of proposed fact discovery set forth in the Case 
Management Plan.  
XI. 
Electronic Discovery 
The parties entered into a stipulated order governing electronically stored information, 
which the Court entered on July 21, 2023. ECF 80.  
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XII. 
Protective Orders and Confidentiality Agreements 
The parties filed a Joint Motion for Protective Order on January 14, 2022, ECF 19, which 
the Court granted on January 18, 2022, ECF 20. 
XIII. Alternative Dispute Resolution 
A. Have the Parties engaged in any settlement discussions? If so, set forth the status of 
those negotiations. If not, explain why not. 
The parties have discussed the possibility of mediation. 
B. Have the Parties explored or considered other forms of alternative dispute resolution? 
If so, summarize those efforts. If not, state the Parties’ positions with respect to ADR, 
as required under Local Rule of Civil Procedure 53.3. 
The parties are receptive to considering ADR at an appropriate stage of the 
proceedings. 
C. Identify the individual who will attend the Rule 16 conference who will have 
authority to discuss settlement. 
For Plaintiffs: 
Lawrence J. Lederer 
Bart D. Cohen 
BAILEY & GLASSER LLP 
 
 
For Defendant: 
Marcel S. Pratt 
 
 
Timothy D. Katsiff 
 
 
BALLARD SPAHR LLP 
 
 
 
Daniel A. Arellano 
 
 
HERRERA ARELLANO LLP 
 
XIV. Consent to Send Case to a Magistrate Judge 
Both Parties consent to Magistrate Judge Carlos maintaining responsibility for resolving 
discovery disputes. 
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XV. 
Policies and Procedures 
Judge Gallagher’s Policies and Procedures are available for the Parties to review on the 
Court’s website. By signing below, counsel for each Party and/or each pro se Party represents 
that he or she has reviewed the Judge’s Policies and Procedures and acknowledges the 
requirements contained therein. The Parties and their counsel further acknowledge by signing 
below that Judge Gallagher will strike pleadings and other submissions that do not comply with 
his Policies and Procedures.  
XVI. Other Matters 
The factual and legal issues in this matter substantially overlap with those in Drevnak v. 
Prestamos CDFI, LLC, No. 2:23-cv-2777-JMG, which is also before this Court.  Moreover, the 
respective parties in Drevnak and Marshall are represented by the same counsel.  Prior to the 
November 16, 2023 Rule 16 Pretrial Scheduling Conference in Drevnak (“Rule 16 Conference”), 
the parties filed a Joint Rule 26(f) Report (the “Report”).  The Report, including the Proposed 
Case Management Schedule (attached to the Report), is appended here as Exhibit B.  The Report 
notes that the parties anticipate seeking consolidation of the two cases and that, if the Court 
agrees, the Plaintiffs in Marshall and Drevnak will seek to file a consolidated amended 
complaint.  Further, at the Rule 16 Conference, the parties and the Court discussed consolidation 
of these matters and issuance of a single scheduling order. 
The parties continue to support consolidating Marshall and Drevnak and moving forward 
with these matters as a single action.  The parties therefore request that the Court enter the 
attached Proposed Case Management Schedule, appended here as Exhibit A, which updates the 
proposed schedule previously filed with the Report in Drevnak.   
 
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ACKNOWLEDGEMENT OF RULE 26(F) MEETING AND THE ABOVE SUBMISSION 
TO THE COURT: 
 
Dated: March 1, 2024 
 
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: 215-274-9420 
F: 202-463-2103 
llederer@baileyglasser.com 
bcohen@baileyglasser.com 
 
Michael L. Murphy (admitted pro hac vice) 
1055 Thomas Jefferson Street NW 
Suite 540 
Washington, DC 20007 
T: 202-548-7789 
F: 202-463-2103 
mmurphy@baileyglasser.com 
 
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 
 
Counsel for Plaintiffs and Proposed Class 
BALLARD SPAHR LLP 
 
By: /s/ Timothy D. Katsiff 
Timothy D. Katsiff (Pa. ID 75490) 
Marcel S. Pratt (Pa. ID 307483) 
J. Chesley Burruss (Pa. ID 331521) 
Henry W. Longley (Pa. ID 328847) 
1735 Market Street, 51st Floor 
Philadelphia, PA 19103 
T: 215-665-8500 
F: 215-864-8999 
prattm@ballardspahr.com 
katsifft@ballardspahr.com 
burrussc@ballardspahr.com 
longleyh@ballardspahr.com 
 
HERRERA ARELLANO LLP 
Roy Herrera (admitted pro hac vice) 
Daniel A. Arellano (admitted pro hac vice) 
Jillian Andrews (admitted pro hac vice) 
Austin T. Marshall (admitted pro hac vice) 
1001 North Central Avenue, Suite 404 
Phoenix, AZ 85004 
T: 602-567-4820 
Roy@ha-firm.com 
Daniel@ha-firm.com 
Jillian@ha-firm.com 
Austin@ha-firm.com 
 
Counsel for Defendant 
 
 
 
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EXHIBIT A 
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EXHIBIT A 
 
PROPOSED CASE MANAGEMENT SCHEDULE  
FOR CONSOLIDATED ACTION 
 
 
Event 
Proposed Deadline 
Consolidated Amended 
Complaint 
4/19/2024 
Prestamos’ response to SAC  
5/20/2024 
Substantial completion of Class 
Certification discovery 
3/3/2025 
Plaintiffs’ identification of Class 
Certification Experts and Rule 26 
disclosures and summary 
3/3/2025 
Plaintiffs’ Class Certification 
Expert Reports 
4/14/2025 
Plaintiffs’ production of materials 
relied upon by experts in their 
Class Certification Expert Reports 
4/21/2025 
Defendant’s Class Certification 
Expert Reports 
7/9/2025 
Defendant’s production of 
materials relied upon by experts 
in their Class Certification Expert 
Reports 
7/16/2025 
Plaintiffs’ Rebuttal Class 
Certification Expert Reports 
8/15/2025 
Plaintiffs’ Motion for Class 
Certification Combined for Both 
Cases (40 pages, not including 
exhibits) 
8/15/2025 
Plaintiffs’ production of materials 
relied upon by experts in their 
Rebuttal Class Certification 
Expert Reports 
8/22/2025 
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Event 
Proposed Deadline 
Deadline for expert discovery 
with respect to class certification 
issues 
9/19/2025 
Defendant’s Opposition to 
Plaintiffs’ Motion for Class 
Certification (not to exceed 40 
pages, without exhibits) 
10/17/2025 
Plaintiffs’ and Defendant’s 
Daubert Motions on Class 
Certification Experts 
10/24/25 
Plaintiffs’ Reply in Support of 
Motion for Class Certification 
(not to exceed 20 pages, without 
exhibits) 
11/24/2025 
Plaintiffs’ and Defendant’s 
Oppositions to Daubert Motions 
on Class Certification 
01/12/2026 
Plaintiffs’ and Defendant’s 
Replies to Daubert Motions on 
Class Certification 
1/26/2026 
Class Certification Hearing 
02/06/2026 
Fact discovery deadline 
6/13/2026 
 
Plaintiffs’ and Defendant’s Merits 
Expert Reports 
8/26/2026 
Plaintiffs’ and Defendant’s 
production of materials relied 
upon by experts in their Merits 
Expert Reports 
8/31/2026 
Plaintiffs’ and Defendant’s 
Rebuttal Merits Expert Reports 
11/12/2026 
Plaintiffs and Defendant’s 
production of materials relied 
upon by experts in their Rebuttal 
Merits Expert Reports 
11/16/2026 
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Event 
Proposed Deadline 
Deadline for expert discovery 
with respect to merits issues 
12/10/2026 
Plaintiffs’ and Defendant’s 
Daubert Motions 
1/17/2027 
Plaintiffs’ and Defendant’s 
Oppositions to Daubert Motions 
2/15/2027 
Plaintiffs’ and Defendant’s 
Replies in Support of Daubert 
Motions 
3/1/2027 
Plaintiffs’ and Defendant’s 
Motions for Summary Judgment 
4/26/2027 
Plaintiffs’ and Defendant’s 
Oppositions to Motions for 
Summary Judgment 
5/24/2027 
Plaintiffs’ and Defendant’s 
Replies in Support of Motions for 
Summary Judgment  
6/14/2027 
Estimated trial ready date 
TBD 
Estimated Number of Days for 
Trial 
15 
 
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EXHIBIT B 
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IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF PENNSYLVANIA 
GEORGINA DREVNAK, JOHN MARTIN, 
KATHERINE LOYD, EZRA BEATTIE, 
GREGORY LLOYD, ALYSHIA JOHNSON 
and LAMETRIA MARVEL, individually and 
on behalf of all others similarly situated, 
 
 
 
 
 
Plaintiffs, 
 
 
 
v. 
 
PRESTAMOS CDFI, LLC and CHICANOS 
POR LA CAUSA, INC., 
 
 
 
 
 
Defendants. 
 
 
 
Civil Action No. 2:23-cv-2777-JMG 
 
 
 
 
 
JOINT RULE 26(f) REPORT 
In accordance with Fed. R. Civ. P. 26(f), counsel for the parties conferred on October 23, 
2023, and submit the following report of their meeting for the Court’s consideration: 
I. 
Counsel 
A. 
Lead counsel for Plaintiff(s): 
Lawrence J. Lederer 
Michael L. Murphy 
Bart D. Cohen 
BAILEY & GLASSER LLP 
 
 
Lead counsel for Defendant(s): 
Timothy D. Katsiff 
Marcel S. Pratt  
BALLARD SPAHR LLP 
 
Daniel A. Arellano 
HERRERA ARELLANO LLP 
 
B. 
Counsel who participated in Rule 26(f) conference on behalf of Plaintiff(s): 
Lawrence J. Lederer 
Bart D. Cohen 
Bailey & Glasser LLP 
 
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C. 
Counsel who participated in Rule 26(f) conference on behalf of Defendant(s): 
Timothy Katsiff 
Marcel S. Pratt 
BALLARD SPAHR LLP 
 
 
Daniel A. Arellano 
HERRERA ARELLANO LLP 
 
II. 
Description of Claims and Defenses  
Plaintiffs 
Plaintiffs’ claims arise from the same course of conduct by Defendants as plaintiffs’ 
claims in Marshall v. Prestamos CDFI, LLC, No. 5:21-cv-04337-JMG (“Marshall”), which is 
also pending before this Court. After the United States Small Business Administration (“SBA”) 
raised the fees payable to lenders for processing Paycheck Protection Program (“PPP”) loans, 
Defendant Prestamos CDFI, LLC (“Prestamos”) processed nearly 500,000 loans over the course 
of only five months. As a result, Prestamos received nearly $1.2 billion in loan processing fees. 
Despite its contractual obligations under the same standard form promissory note and 
accompanying loan documents to which Prestamos and all class member borrowers were parties, 
however, Prestamos failed to fund the loans of borrowers whose loans had been approved by the 
SBA. Further, Prestamos failed to fund these SBA-approved loans despite the fact that the PPP 
loan proceeds had actually been paid to Prestamos and funded by the Paycheck Protection 
Program Liquidity Facility (“PPPLF”) or otherwise. In fact, Prestamos continued to receive 
funds from the PPPLF through September 2021, even though the loan application period closed 
in May 2021. Prestamos has at all relevant times been wholly-owned by defendant Chicanos Por 
La Causa, Inc. (“CPLC”). Plaintiffs allege that CPLC controlled and directed Prestamos’s PPP 
lending and was the alter ego of Prestamos. The Court’s personal jurisdiction over CPLC is the 
subject of a pending motion in Marshall. Id., ECF 84. 
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Plaintiffs are small business owners whose loans were approved by the SBA but were 
never funded by Prestamos. SBA records reflect that those loans were in fact disbursed. Internet 
sites including Reddit, the website of the Better Business Bureau and other websites are replete 
with complaints by other borrowers throughout the country alleging similar misconduct by 
Prestamos. Plaintiffs allege breach of contract claims on behalf of statewide classes for 
Prestamos’s failure to fund the SBA-approved PPP loans in compliance with the parties’ loan 
agreements. PPP lenders including Defendant were also subject to compliance with applicable 
rules regarding PPP loans including, among other things, a requirement to fund PPP loans within 
10 days after their approval by the SBA.  
In Marshall, the Court held that plaintiffs maintain standing to represent state-wide 
classes, denied Defendants’ motion to dismiss plaintiffs’ breach of contract claims, and ordered 
further proceedings as to the Court’s personal jurisdiction over CPLC, in an Opinion and Order 
dated March 30, 2023. Marshall, ECF 56-57. Plaintiffs’ Complaint in this action accounts for 
that Order and Opinion. 
In light of the substantial overlap of both factual and legal issues in this action and 
Marshall, the parties anticipate seeking consolidation of the two cases. If the Court agrees to 
that, Plaintiffs will seek to file a consolidated amended complaint encompassing the claims of 
plaintiffs in both cases. 
Defendants 
Defendant Prestamos CDFI, LLC (“Prestamos”), is a certified Community Development 
Financial Institution who, like other lending institutions across the United States, participated in 
the Paycheck Protection Program, a program enacted by Congress and administered by the SBA 
to facilitate the distribution of financial aid—in the form of federally-backed, forgivable loans—
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to small businesses affected by the Covid-19 pandemic.   Defendant Chicanos Por La Causa, Inc. 
(“CPLC”) is an Arizona non-profit corporation organized under Section 501(c)(3) of the Internal 
Revenue Code, and is the sole member of Prestamos. CPLC is not a lender, and it does not 
appear on any of Plaintiffs’ loan documents. Defendants deny Plaintiffs’ allegations of 
wrongdoing, and Plaintiffs’ claims fail for the same reason as those in the Marshall action. 
Specifically, none of the documents that purportedly governed Plaintiffs’ applications for 
PPP loans incorporated any requirements under the CARES Act or related rules and guidelines, 
or obligated Prestamos to disburse money to Plaintiffs within a certain time period, or at all. 
Whatever agreements Prestamos may have had with SBA cannot be enforced by non-parties like 
Plaintiffs. And the Promissory Note each Plaintiff signed contains a broad release provision that 
bars Plaintiffs’ lawsuit.  Finally, Plaintiffs cannot prove any damage on any of their claims. 
In light of the substantial overlap of both factual and legal issues in this action and 
Marshall, Defendants do not oppose the consolidation of the two cases for the purpose of 
discovery.  
Stipulated Facts 
1. 
Defendant Prestamos is a limited liability company organized under the laws of 
the state of Arizona, having its principal place of business at 1024 E. Buckeye Road, Suite 270, 
Phoenix, Arizona 85034, with additional offices in Tucson, Arizona, Las Vegas and Reno, 
Nevada, and Santa Fe, New Mexico. 
2. 
Prestamos is a Community Development Financial Institution certified by the 
United States Treasury as a Loan Fund.  
3. 
On March 11, 2020, the World Health Organization declared the COVID-19 
outbreak a “pandemic.” 
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4. 
On March 13, 2020, the United States declared a national emergency due to the 
COVID-19 pandemic.  
5. 
Congress enacted the Coronavirus Aid, Relief, and Economic Security Act 
(“CARES Act”) at least in part to provide assistance for individuals, families, and businesses 
affected by the pandemic.  
6. 
Prestamos participated in the Paycheck Protection Program, implemented 
pursuant to the CARES Act, as a lender of federally-guaranteed, forgivable loans. 
7. 
Prestamos entered into an agreement with Blueacorn PPP, LLC, a lender service 
provider, whereby Prestamos compensated Blueacorn for its assistance with, inter alia, 
facilitating the PPP loan application paperwork, collection, and approval process.  
8. 
Prestamos, like other lenders participating in the PPP, received fees from SBA in 
connection with processing PPP loan applications. 
III. 
Jurisdiction 
Plaintiffs 
This Court has subject matter jurisdiction pursuant to the Class Action Fairness Act 
because at least one member of the proposed class is a citizen of a different state than defendant 
Prestamos; there are more than 100 members of the proposed class; and the aggregate amount in 
controversy exceeds $5,000,000.00 exclusive of interest and costs. See 28 U.S.C. 
§ 1332(d)(2)(A).  
Defendants 
Defendants contend that this Court lacks subject matter jurisdiction because Plaintiffs 
lack Article III standing to bring this suit. Specifically, Plaintiffs did not suffer a cognizable 
injury-in-fat from any delay in disbursement of loan funds because they cannot demonstrate that 
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they were entitled to receive those funds; and Plaintiffs cannot demonstrate that any injury 
caused by an alleged delay in receiving loan funds is traceable to any action taken by 
Defendants. 
Further, Defendants maintain that the Court lacks personal jurisdiction over CPLC, 
because CPLC has not directed any activities toward this jurisdiction, is not a party to any 
Plaintiff’s loan documents, and is not the alter ego of Prestamos. 
Insurance Coverage and Deductibles 
Defendants do not, under the information presently available to them, intend to rely on 
any insurance coverage related to potential liability in this action. Nonetheless, and without 
waiving their right to argue that insurance coverage is unavailable as to any potential liability in 
this litigation, Defendants will identify relevant insurance agreements in its initial disclosures. 
IV. 
Dispositive Motions 
Defendant CPLC intends to file a motion to dismiss Plaintiffs’ complaint under Fed. R. 
Civ. P. 12(b)(2) and 12(b)(6) pending this Court’s ruling on Defendant CPLC’s Motion to 
Dismiss in Marshall.  Defendant Prestamos and, if its motion to dismiss is denied, Defendant 
CPLC, intend to file a motion for summary judgment under Fed. R. Civ. P. 56.  In addition both 
CPLC and Prestamos intend to oppose class certification of this matter. 
V. 
Anticipated Scope of Discovery 
Plaintiffs 
A. 
Summarize with specificity those issues on which the Parties will need to conduct 
discovery. Identify categories of information each Party needs in discovery and why.  
Plaintiffs generally anticipate that the scope of discovery will be coincident with 
the scope of discovery in Marshall, which has been the subject of substantial and 
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ongoing discussions among the parties, the primary exceptions being discovery 
regarding the PPP loans of Plaintiffs in this action, and issues related to class 
members in the states in which Plaintiffs reside. If the Court agrees to consolidate 
this case with the Marshall case, discovery in the Marshall case would comprise a 
portion of the record in this case. 
B. 
Anticipated number of interrogatories per Party: .................................................20. 
C. 
Anticipated number of depositions per Party: ......................................................40. 
D. 
To the extent either Party proposes to exceed the presumptive limits in the Federal 
Rules of Civil Procedure for discovery, explain the basis for that proposal.  
This case involves what Plaintiffs believe may be hundreds or thousands of 
proposed class members, and many millions of dollars or more in disputed and 
unfunded PPP loan proceeds as Prestamos committed to funding more PPP loans 
in 2021 than any other lender according to the SBA. Plaintiffs will therefore need 
to pursue substantial discovery commensurate with the scope of this case as is 
common under the Federal Rules of Civil Procedure for complex litigation 
including this case. 
E. 
Do the Parties anticipate the need for any third-party discovery? If so, identify the 
likely third-parties and the discovery to be sought. 
Yes. Plaintiffs anticipate seeking non-party discovery from Blueacorn and the 
SBA regarding their communications and dealings with Defendants concerning 
Plaintiffs’ and class members’ PPP loans, as well as other third-parties including 
any third-parties to whom Defendants may have transferred any applicable PPP 
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loan proceeds or fees that Plaintiffs contend should be paid to Plaintiffs and the 
class. 
F. 
Do the Parties anticipate the need for experts? If so, identify the subjects on which 
the expert(s) may opine.  
Yes. Plaintiffs presently anticipate needing experts. For example, Plaintiffs 
anticipate needing one or more experts to opine as to the alleged damages 
incurred by the members of the class and any subclasses. Plaintiffs also anticipate 
needing one or more experts in forensic accounting and related areas depending 
on Defendants’ disposition of PPP loan proceeds Plaintiffs contend should be paid 
to Plaintiffs and the class. 
Defendant 
A. 
Summarize with specificity those issues on which the Parties will need to conduct 
discovery. Identify categories of information each Party needs in discovery and why. 
i. 
Information about each of Named Plaintiff’s business, including history, 
financial and revenue information, tax returns, and the impact on their 
business caused by the Covid-19 pandemic to assess the Plaintiff’s 
eligibility for a second-draw PPP loan. 
ii. 
Information verifying the representations each Named Plaintiff made to 
SBA, Blueacorn, Prestamos, or others during the application process for a 
second-draw PPP loan to assess the veracity of information provided in 
the application process and the Plaintiff’s eligibility for a second-draw 
PPP loan. 
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iii. 
All communications each Named Plaintiff had with SBA, Blueacorn, their 
bank, and others about their application for a second-draw PPP loan to 
assess the veracity of information provided in the application process, the 
Plaintiff’s eligibility for a second-draw PPP loan, and the Plaintiff’s 
knowledge with respect to the status of their application for a second-draw 
PPP loan. Information regarding each Named Plaintiff’s efforts to secure 
disbursement of loan proceeds from Prestamos or another entity, and 
efforts to apply for a second-draw PPP loan from any other lender to 
assess the veracity of the Plaintiff’s allegation that they regularly inquired 
about the status of their loan and were unable to secure a second-draw PPP 
loan from another source.  
iv. 
Information about the bank accounts into which each Named Plaintiff 
sought to have their second-draw PPP loan deposited to assess the 
Plaintiff’s eligibility for a second-draw PPP loan and to investigate 
reasons why the Plaintiff’s loan disbursement may have been rejected or 
otherwise delayed. 
v. 
Information detailing and verifying any harm each Named Plaintiff 
allegedly suffered as a result of any delay in receiving a second-draw PPP 
loan. 
B. 
Anticipated number of interrogatories per Party: .................................................35. 
C. 
Anticipated number of depositions per Party: ......................................................40. 
D. 
To the extent either Party proposes to exceed the presumptive limits in the Federal 
Rules of Civil Procedure for discovery, explain the basis for that proposal. 
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Defendants believe this case will be resolved with evidence from Named 
Plaintiffs, which will establish that they do not have claims for relief. In any 
event, Defendants also intend to oppose certification of the plaintiff class.  
E. 
Do the Parties anticipate the need for any third-party discovery? If so, identify the 
likely third-parties and the discovery to be sought. 
Yes. Defendants anticipate seeking non-party discovery from Blueacorn, SBA, 
and Plaintiffs’ financial institutions, regarding their communications and dealings 
with Plaintiffs. 
F. 
Do the Parties anticipate the need for experts? If so, identify the subjects on which 
the expert(s) may opine.  
Yes. At a minimum, and without waiving the right to retain additional experts, 
Defendant anticipates retaining of several experts relating to both Class 
Certification and Plaintiffs claims on the merits and to refute Plaintiffs’ claimed 
damages.  
VI. 
Status of Discovery 
Plaintiffs served requests for production on October 18, 2023 which are identical to the 
discovery served in Marshall case. The parties have also agreed to exchange initial disclosures 
no later than November 15, 2023. Defendants believe that discovery should be consolidated in 
both cases so as to avoid duplicating discovery efforts.  The parties have not addressed informal 
disclosures, as formal discovery has progressed in the Marshall case. 
VII. 
Proposed Case Management Deadlines:   
The parties have agreed to detailed proposed case management plan governing both 
actions to address the class certification discovery and class certification which is attached as 
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Exhibit A.  The dates requested by the Court are set forth below. 
A. 
Deadline to serve initial disclosures under Rule 
26(a)(1) (*must be exchanged at least one (1) 
business day before Rule 16 conference): ................................. November 15, 2023 
B. 
Deadline to amend pleadings to add claims or 
Parties (*must be as early as practicable to avoid 
prejudice or unnecessary delays): .............................................. December 1, 2023.. 
C. 
Deadline for affirmative expert reports (if any) and 
disclosure of lay witness opinion testimony with 
related information and documents (if any):  ...................................... See Exhibit A 
D. 
Deadline for rebuttal expert reports (if any): ...................................... See Exhibit A 
E. 
Deadline to complete discovery: ......................................................... See Exhibit A 
F. 
If any Party seeks more than 120 days for fact discovery, explain why. 
Defendants have produced hundreds of thousands of pages of documents and 
complex financial data. In addition, the large number of named Plaintiffs between 
this action and Marshall require more depositions than the average civil case. The 
parties agree that discovery is and will continue to be voluminous and will require 
more than 120 days to complete.  
G. 
Deadline to file motion for summary judgment:................................ See Exhibit A. 
H. 
Estimated trial ready date: ................................................................. See Exhibit A. 
I. 
Estimated Number of Days for Trial: ...................................................................15. 
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VIII. Deposition Scheduling 
The Court expects the Parties to meet and confer as soon as practicable to set aside dates 
to hold open for depositions before the close of discovery. If the Parties have not already done 
so, the Court will order the Parties to do so within two weeks of the Rule 16 conference. 
 
Have the Parties set aside dates for deposition? ___ Yes   x   No 
 
If yes, what are those dates? ________________________________________________ 
 
If no, when do the parties intend to confer, and how many dates do they intend to set 
aside? 
This is a complex class action and the parties will confer with respect to depositions and 
complete depositions prior to the close of proposed fact discovery set forth in the Case 
Management Plan.  
IX. 
Electronic Discovery 
The parties in Marshall entered into a stipulated order governing electronically stored 
information, which the Court entered on July 21, 2023. Marshall, ECF 80. The parties propose to 
use the same stipulated order in this action. 
X. 
Protective Orders and Confidentiality Agreements 
The parties in Marshall agreed to the terms of proposed protective order, which the Court 
entered on January 14, 2022. Marshall, ECF 19. The parties propose to use the same order in this 
action. 
XI. 
Alternative Dispute Resolution 
A. 
Have the Parties engaged in any settlement discussions? If so, set forth the status 
of those negotiations. If not, explain why not. 
The parties have discussed the possibility of mediation. 
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B. 
Have the Parties explored or considered other forms of alternative dispute 
resolution? If so, summarize those efforts. If not, state the Parties’ positions with respect to 
ADR, as required under Local Rule of Civil Procedure 53.3. 
The parties are receptive to considering ADR at an appropriate stage of the 
proceedings. 
C. 
Identify the individual who will attend the Rule 16 conference who will have 
authority to discuss settlement. 
For Plaintiffs: 
Lawrence J. Lederer 
Michael L. Murphy 
Bart D. Cohen 
BAILEY & GLASSER LLP 
 
 
For Defendants: 
Timothy D. Katsiff 
Marcel S. Pratt  
BALLARD SPAHR LLP 
 
Daniel A. Arellano 
HERRERA ARELLANO LLP 
 
XII. 
Consent to Send Case to a Magistrate Judge 
Both Parties consent to Magistrate Judge Carlos maintaining responsibility for resolving 
discovery disputes. 
XIII. Policies and Procedures 
Judge Gallagher’s Policies and Procedures are available for the Parties to review on the 
Court’s website. By signing below, counsel for each Party and/or each pro se Party represents 
that he or she has reviewed the Judge’s Policies and Procedures and acknowledges the 
requirements contained therein. The Parties and their counsel further acknowledge by signing 
below that Judge Gallagher will strike pleadings and other submissions that do not comply with 
his Policies and Procedures.  
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II. 
Other Matters 
As is set forth above, the Parties would like to discuss the possibility of combining this 
action and the Marshall action for the purposes of consideration of Plaintiffs’ anticipated motion 
for class certification and discovery. 
ACKNOWLEDGEMENT OF RULE 26(F) MEETING AND THE ABOVE SUBMISSION 
TO THE COURT: 
 
Date: November 6, 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.: 215.274-9420 
F.: 202.463-2103 
llederer@baileyglasser.com 
bcohen@baileyglasser.com 
 
BAILEY & GLASSER LLP 
Michael L. Murphy (pro hac vice to be filed) 
1055 Thomas Jefferson Street, NW #540 
Washington, DC 20007 
T.: 202.463-2101 
F.: 202.463-2103 
mmurphy@baileyglasser.com 
 
NOLAN HELLER KAUFFMAN LLP 
Justin A. Heller (pro hac vice to be filed)  
Matthew M. Zapala (pro hac vice to be filed) 
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 
BALLARD SPAHR LLP 
 
By:             /s/ Timothy D. Katsiff                  . 
Timothy D. Katsiff (Pa. ID 75490) 
Marcel S. Pratt (Pa. ID 307483) 
Thomas J. Gallagher IV (Pa. ID 316269) 
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 
KatsiffT@ballardspahr.com 
GallagherT@ballardspahr.com 
LevyA@ballardspahr.com 
 
HERRERA ARELLANO LLOP 
Roy Herrera (admitted pro hac vice) 
Daniel A. Arellano (admitted pro hac vice) 
Jillian Andrews (admitted pro hac vice) 
Austin T. Marshall (admitted pro hac vice) 
1001 North Central Avenue, Suite 404 
Phoenix, AZ 85004 
T: 602-567-4820 
Roy@ha-firm.com 
Daniel@ha-firm.com 
Jillian@ha-firm.com 
Austin@ha-firm.com 
 
Counsel for Defendants 
 
 
 
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EXHIBIT A 
 
PROPOSED CASE MANAGEMENT SCHEDULES  
FOR CONSOLIDATED ACTION 
 
 
Event 
Plaintiffs’ Proposed 
Deadline 
Defendant’s Proposed 
Deadline 
Consolidated Amended Complaint 
November 22, 2023 
 
Prestamos’ response to SAC  
December 22, 2023 
30 days after filing 
Substantial completion of Class 
certification discovery  
June 7, 2024 
 October 4, 2024 
Plaintiffs’ identification of Class 
Certification Experts and Rule 26 
disclosures and summary  
June 28, 2024 
October 4, 2024 
Plaintiffs’ Class Certification 
Expert Reports 
July 19, 2024 
November 15, 2024 
Plaintiffs’ production of materials 
relied upon by experts in their Class 
Certification Expert Reports 
July 26, 2024 
November 22, 2024 
Fact discovery deadline 
September 13, 2024 
January 13, 2025 
Defendants’ Class Certification 
Expert Reports 
September 13, 2024 
February 10, 2025 
Defendants’ production of materials 
relied upon by experts in their Class 
Certification Expert Reports 
September 20, 2024 
February 17, 2024 
Plaintiffs’ Rebuttal Class 
Certification Expert Reports 
November 1, 2024 
March 17, 2024 
Plaintiffs’ Motion for Class 
Certification Combined for Both 
Cases (40 pages, not including 
exhibits) 
July 19, 2024 
March 17, 2024 
Plaintiffs’ production of materials 
relied upon by experts in their 
Rebuttal Class Certification Expert 
Reports 
November 8, 2024 
March 24, 2024 
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Event 
Plaintiffs’ Proposed 
Deadline 
Defendant’s Proposed 
Deadline 
Deadline for expert discovery with 
respect to class certification issues 
December 6, 2024 
April 21, 2024 
Defendants’ Opposition to 
Plaintiffs’ Motion for Class 
Certification (not to exceed 40 
pages, without exhibits) 
September 13, 2024 
May 19, 2024 
Plaintiffs’ and Defendants’ Daubert 
Motions on Class Certification 
Experts 
January 10, 2025 
May 26, 2024 
Plaintiffs’ Reply in Support of 
Motion for Class Certification (not 
to exceed 20 pages, without 
exhibits) 
November 1, 2024 
June 26, 2024 
Plaintiffs’ and Defendants’ 
Oppositions to Daubert Motions on 
Class Certification 
February 7, 2025 
August 14, 2024 
Plaintiffs’ and Defendants’ Replies 
to Daubert Motions on Class 
Certification 
February 21, 2025 
August 28, 2024 
Class Certification Hearing 
March 21, 2025 
September 8. 2024 
Plaintiffs’ and Defendants’ Merits 
Expert Reports 
April 18, 2025 
March 28, 2025 
Plaintiffs’ and Defendants’ 
production of materials relied upon 
by experts in their Merits Expert 
Reports 
April 25, 2025 
April 1, 2025 
Plaintiffs’ and Defendants’ Rebuttal 
Merits Expert Reports 
June 7, 2025 
June 13, 2025 
Plaintiffs and Defendants’ 
production of materials relied upon 
by experts in their Rebuttal Merits 
Expert Reports 
June 14, 2025 
June 17, 2025 
Deadline for expert discovery with 
respect to merits issues 
July 12, 2025 
July 11, 2025 
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3 
Event 
Plaintiffs’ Proposed 
Deadline 
Defendant’s Proposed 
Deadline 
Plaintiffs’ and Defendants’ Daubert 
Motions 
August 1, 2025 
August 16, 2025 
Plaintiffs’ and Defendants’ 
Oppositions to Daubert Motions 
September 19, 2025 
September 12, 2025 
Plaintiffs’ and Defendants’ Replies 
in Support of Daubert Motions 
October 17, 2025 
September 26, 2025 
Plaintiffs’ and Defendants’ Motions 
for Summary Judgment 
August 1, 2025 
November 21, 2025 
Plaintiffs’ and Defendants’ 
Oppositions to Motions for 
Summary Judgment 
September 19, 2025 
December 19, 2025 
Plaintiffs’ and Defendants’ Replies 
in Support of Motions for Summary 
Judgment  
October 17, 2025 
January 9, 2026 
Estimated trial ready date 
December 1, 2025 
 
Estimated Number of Days for Trial 
15 
 
 
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