Exhibit 1 — Marshall v. Prestamos CDFI, LLC (Dkt. 112-1, E.D. Pa. No. 5:21-cv-04337)

Record facts

U.S. District Court for the Eastern District of Pennsylvania · No. 5:21-cv-04337-JMG · Doc. 112-1 · 2024-05-10 · Docket on CourtListener

Full text

EXHIBIT 1 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 1 of 17

 
1 
 
Marshall, et al., v. Prestamos CDFI, LLC 
No. 5:21-cv-04337-JMG (E.D. Pa) 
I. 
STATUS OF DISCOVERY REQUESTS BY DEFENDANT PRESTAMOS CDFI, LLC ON PLAINTIFFS 
A. 
COMPLETED DISCOVERY 
None. 
B. 
OUTSTANDING DISCOVERY 
1. 
Prestamos’s First Requests for Production (directed to each of the eleven (11) Marshall Plaintiffs)1 
Summary of RFPs 
(39): 
 
Served: July 21, 2023 
 
Nos. 
Produced 
 
 
232 Documents (133 on Oct. 31, 
2023 and 99 on Feb. 2, 2024).  
Outstanding 
 
 
Plaintiffs produced no documents 
responsive to 28 out of 39 RFPs. 
Completed
 
 
No 
Business documents 
1 and 2 
None. 
Documents showing ownership of 
businesses identified in loan 
documents for all Plaintiffs. 
No 
Documents showing state, federal, 
or local licenses, permits, or 
certifications held by businesses of 
all Plaintiffs. 
No 
Financial documents 
17, 21, 
22, 23, 
24, 25, 
None. 
Documents showing financial 
operations of businesses, including 
profits and losses, balance sheets, 
No 
                                                          
1  On July 21, 2023, Marshall Plaintiffs included: A. Marshall, D. Pronsky, P. Townsend, N. Holland, L. Owsley, K. Ahmadou, K. 
Dervin, K. Henderson, D. Innis, K. Stalnaker, and J. Jones. See Marshall et al., v. Prestamos CDFI, LLC, No. 5:21-cv-04337, Second 
Am. Compl., ECF No. 42.  
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2 
 
26, 27, 
and 28  
bank statements, etc., for all 
Plaintiffs.  
Documents relating to business 
expenditures that served as basis of 
all Plaintiffs’ PPP loan applications.  
No 
Documents relating to any loans, 
cash advances, sales of accounts 
receivable or other financial 
products after submission of PPP 
loan applications for all Plaintiffs. 
No 
Documents relating to the impact of 
COVID-19 on the operations and 
financial condition of all Plaintiffs’ 
businesses. 
No 
Tax returns (federal and 
state) 
3, 4, and 
10 
Partial tax returns for 1 Plaintiff. 
Complete federal and state tax 
returns for all Plaintiffs. 
Partial 
Plaintiffs’ 
communications  
5, 6, 7, 8, 
9, 12, 
and 13 
Communications with Prestamos, 
SBA and other parties for 10 
Plaintiffs. 
Communications relating to PPP 
loans for all Plaintiffs, and 
confirmation by Plaintiffs all 
responsive communications have 
been produced. 
Partial 
Evidence of damages 
31 and 
34  
None. 
Documents relating to purported 
damages caused by Prestamos for all 
Plaintiffs. 
No 
Plaintiffs’ benefits  
11 
Communications for 1 Plaintiff 
regarding receipt of benefits. 
Documents showing unemployment, 
disability, retirement, or worker’s 
compensation for 10 of 11 Plaintiffs. 
Partial 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 3 of 17

 
3 
 
Allegations of failure to 
fund 
29 and 
30 
None. 
Documents relating to allegations 
that Prestamos failed to fund PPP 
loans for all 11 Plaintiffs. 
No 
Loan documents 
14, 15, 
16, 18, 
and 19 
Documents related to funding of 
PPP loan for 5 of 11 Plaintiffs. 
Documents relating to deposit of 
PPP loan funds into designated 
financial accounts for 6 of 11 
Plaintiffs. 
Partial 
Documents relating to their 
interpretation of the “Release of 
Lender Paragraph” for all Plaintiffs. 
No 
Documents showing eligibility for 
PPP loans and documents that were 
submitted as part of the applications 
for all Plaintiffs. 
No 
2. 
Prestamos’s First Interrogatories (directed to each of the eleven (11) Marshall Plaintiffs)2 
Summary of ROGs 
(19): 
 
Served: July 21, 2023 
 
Nos. 
Response 
 
 
Responses and Objections: Aug. 28, 
2023. 
Outstanding 
 
 
Plaintiffs have not verified 
Responses. 
Completed
 
 
No 
Description of businesses 
1, 2, 3, 4, 
and 9 
Description of 10 of 11 Plaintiffs’ 
businesses. 
 
Identity of trade names, addresses, 
and number of employees for 
businesses of all 11 Plaintiffs. 
Partial 
Phone numbers, email addresses, 
and social media information for 2 
of 11 Plaintiff businesses. 
Phone numbers, email addresses, 
and social media information for 9 
of 11 Plaintiff businesses.  
Partial 
Identified 3 Plaintiff businesses that 
were not required to hold licenses.  
Confirmation of the existence of 
business licenses, permits, and 
Partial 
                                                          
2 See Supra Note 1 for list of Plaintiffs. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 4 of 17

 
4 
 
 
certificates for 8 of 11 Plaintiff 
businesses.  
Plaintiffs would respond pursuant to 
Rule 33(d). 
Amounts of business expenditures 
for all 11 Plaintiffs. 
No 
Accounting of expenses, including 
amounts to which each Plaintiff 
would have applied PPP loan funds. 
No 
Identification of other 
jobs 
5 
Identified full-time occupations for 
2 Plaintiffs and would further 
respond pursuant to Rule 33(d). 
Identity of jobs held outside of 
businesses underlying PPP loan 
applications for 9 of 11 Plaintiffs. 
Partial 
Persons consulted 
regarding PPP loan and 
substance of 
communications 
6, 7, and 
8 
Plaintiffs are not aware of 
responsive information or would 
respond pursuant to Rule 33(d). 
Confirmation Plaintiffs have no 
information responsive to Requests 
for identity of Persons Plaintiffs 
communicated with regarding PPP 
loan applications, documents, or 
their interpretation of the “Release 
of Lender Paragraph.” 
No 
Identification of financial 
accounts 
10 
Plaintiffs identified bank accounts 
for 3 Plaintiffs and would further 
respond pursuant to Rule 33(d). 
Identity of financial institutions 
maintained by 8 of 11 Plaintiffs. 
Partial 
Information related to 
PPP application and 
funding (11, 12, 13, 14, 
15, 16) 
11, 12, 
13, 14, 
15, and 
16 
Identified financial institutions 
designated by 3 Plaintiffs for the 
disbursement of PPP loan funds and 
would respond pursuant to Rule 
33(d).  
Identity of financial institutions 
designated by 8 of 11 Plaintiffs for 
the disbursement of PPP loan funds. 
Partial 
Limited descriptions of discussions 
regarding PPP loans and that 
Plaintiffs are not otherwise aware of 
other responsive information. 
Confirmation that Plaintiffs have no 
information responsive to Request 
for efforts to modify method of loan 
funding, or had any 
communications regarding the 
same. 
Partial 
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5 
 
Identification of damages 
17 
Plaintiffs are not aware of 
responsive information. 
Confirmation Plaintiffs have no 
responsive information to Request 
for amount of damages each 
Plaintiff attributes to Prestamos. 
No 
Identification of funding 
efforts 
18 
Detailed 1 Plaintiff’s funding efforts 
and that 4 other Plaintiffs made no 
attempt. Plaintiffs would further 
respond pursuant to Rule 33(d). 
Confirmation Plaintiffs have no 
responsive information to Request 
for description of loans, cash 
advances, financial arrangements, 
etc., 6 of 11 Plaintiffs obtained or 
attempted to obtain.  
Partial 
Identification of benefits  
19 
Identified, generally, that 2 Plaintiffs 
received Pandemic Unemployment 
Assistance from their respective 
state.  
Identification of benefits received 
by all Plaintiffs including amounts, 
duration, and reasons.  
Partial 
 
3. 
Prestamos’s First Requests for Production (directed to each of the seven (7) Drevnak Plaintiffs)3 
Summary of 
RFPs (39): 
 
Served: Dec. 29, 2023
 
Nos. 
Produced 
 
 
Plaintiffs have produced no 
documents. 
Outstanding 
 
 
All responsive documents are 
outstanding. 
Completed
 
 
No 
Business documents 
 
None. 
Documents showing ownership of 
businesses identified in loan 
documents by all Plaintiffs.  
No 
Documents showing state, federal, 
or local, licenses, permits, or 
certifications held by businesses of 
all Plaintiffs. 
No 
                                                          
3 On December 29, 2023, Drevnak Plaintiffs included: G. Drevnak, J. Martin, K. Loyd, E. Beattie, G. Lloyd, A. Johnson, and L. 
Marvel. See Drevnak, et al. v. Prestamos CDFI, LLC, No. 5:23-cv-2777, Compl., ECF No. 1.  
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6 
 
Financial documents 
 
None. 
Documents showing financial 
operations of business, including 
profits and losses, balance sheets, 
bank statements, etc., for all 
Plaintiffs.  
No 
Documents relating to business 
expenditures that served as basis of 
all Plaintiffs’ PPP loan applications. 
No 
Documents relating to any loans, 
cash advances, sales of accounts 
receivable or other financial 
products after submission of PPP 
loan applications for all Plaintiffs. 
No 
Documents relating to the impact of 
COVID-19 on the operations and 
financial condition of all Plaintiffs’ 
businesses. 
No 
Tax returns (federal 
and state) 
 
None. 
Complete federal and state tax 
returns for all Plaintiffs. 
No 
Plaintiffs’ 
communications  
 
None. 
All Plaintiffs’ communications 
relating to PPP loans and 
confirmation by Plaintiffs all 
responsive communications have 
been produced. 
No 
Evidence of damages 
 
None. 
Documents relating to purported 
damages caused by Prestamos for 
all Plaintiffs. 
No 
Plaintiffs’ benefits  
 
None. 
Documents showing 
unemployment, disability, 
retirement, or worker’s 
compensation received for all 
Plaintiffs. 
No 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 7 of 17

 
7 
 
Allegations of failure 
to fund 
 
None. 
Documents relating to allegations 
that Prestamos failed to fund PPP 
loans for all Plaintiffs. 
No 
Loan documents 
14, 15, 16, 
18, and 19 
None. 
Documents relating to deposit of 
PPP loan funds into designated 
financial accounts for 6 of 11 
Plaintiffs. 
No 
Documents relating to their 
interpretation of the “Release of 
Lender Paragraph” for all Plaintiffs. 
No 
Documents showing eligibility for 
PPP loans and that all documents 
were submitted as part of the 
applications for all Plaintiffs 
No 
 
4. 
Prestamos’s First Interrogatories (directed to each of the seven (7) Drevnak Plaintiffs)4 
Summary of ROGs 
(19): 
 
Served: Dec 29, 2023 
 
Nos. 
Response 
 
 
Response and Objections: Feb. 8, 
2024. 
Outstanding 
 
 
Plaintiffs have not verified 
Responses. 
Completed
 
 
No 
Description of businesses 
1, 2, 3, 4, 
and 9 
Description of 6 of 6 Plaintiff 
businesses. 
 
Identity of trade names and 
addresses for 3 of 6 Plaintiff 
businesses. 
Partial 
Identified 2 Plaintiff businesses that 
were not required to hold licenses.  
 
Confirmation of the existence of 
business licenses, permits, or 
certificates for 5 of 6 Plaintiff 
businesses.  
Partial 
                                                          
4 See Supra Note 3 for list of Plaintiffs. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 8 of 17

 
8 
 
Phone numbers, email addresses, 
and social media information for 2 
of 6 Plaintiff businesses. 
Phone numbers, email addresses, 
and social media information for 4 
of 6 Plaintiff businesses. 
Partial 
Identified one expense for 1 of 6 
Plaintiffs. 
Amounts of business expenditures 
for 5 of 6 Plaintiffs. 
Partial 
Accounting of expenses, including 
amounts to which each Plaintiff 
would have applied PPP loan funds. 
No 
Identification of other 
jobs 
5 
Identified full-time occupation for 1 
Plaintiff.  
Identity of jobs held outside of 
businesses underlying PPP loan 
applications for 5 of 6 Plaintiffs. 
Partial 
Persons consulted 
regarding PPP loan and 
substance of 
communications 
6, 7, and 
8 
Identified the communications of 2 
Plaintiffs and would further respond 
pursuant to Rule 33(d). 
Communications and identities of 
Persons 4 of 6 Plaintiffs consulted 
regarding PPP loan applications, 
documents, or their interpretation of 
the “Release of Lender Paragraph.” 
Partial 
Identification of financial 
accounts 
10 
Identified financial institutions for 2 
Plaintiffs (name only). 
Identity of financial institutions and 
account information maintained by 
6 of 6 Plaintiffs. 
Partial 
Information related to 
PPP application and 
funding (11, 12, 13, 14, 
15, 16) 
11, 12, 
13, 14, 
15, and 
16 
Identified financial institutions 
designated by 3 Plaintiffs for the 
disbursement of PPP loan funds.  
Identity of financial institutions 
designated by 8 of 11 Plaintiffs for 
the disbursement of PPP loan funds. 
Partial 
Limited descriptions of discussions 
regarding PPP loans and that 
Plaintiffs are not otherwise aware of 
other responsive information. 
Confirmation that Plaintiffs have no 
information responsive to Request 
for efforts to modify method of loan 
funding, or had any 
communications regarding the 
same. 
Partial 
Identification of damages 
17 
Plaintiffs are not otherwise aware of 
responsive information. 
Identity of category and dollar 
amounts of all damages Plaintiffs 
attribute to Prestamos.  
No 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 9 of 17

 
9 
 
Identification of funding 
efforts 
18 
Detailed 2 Plaintiffs funding efforts. 
Description of loans, cash advances, 
financial arrangements, etc., for 4 of 
6 Plaintiffs obtained or attempted to 
obtain. 
Partial 
Identification of benefits 
programs 
19 
Identified 1 Plaintiff that did not 
receive benefits.  
Identification of benefits received 
by 5 of 6 Plaintiffs including 
amounts, duration, and reasons.  
Partial 
 
5. 
Prestamos’s Second Requests for Production (directed to each of the seven (18) Marshall and Drevnak 
Plaintiffs) 
Summary of RFPs 
(4): 
 
Served: Apr. 9, 2024 
 
Nos. 
Produced 
 
 
Response and Objections: May 9, 
2024. 
Outstanding 
 
 
All responsive documents are 
outstanding. 
Completed
 
 
No 
Communications with 
Government Agency 
1 
None. 
 
Documents and communications 
with any Government Agency 
regarding alleged wrongdoing by 
Prestamos for all Plaintiffs. 
No 
Meetings or Discussion 
with Government 
Agency 
2 
None. 
Documents and communications 
concerning meetings or discussions 
with any Government Agency 
relating to alleged wrongdoing by 
Prestamos for all Plaintiffs. 
No 
Document relied on in 
2nd Set of ROGs 
3 
None. 
Documents reviewed or relied upon 
in completing Second Set of 
Interrogatories for all Plaintiffs.  
No 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 10 of 17

 
10 
 
Engagement Letters 
4 
None. 
Engagement letters with Bailey & 
Glasser LLP or Nolan Heller 
Kauffman LLP by all Plaintiffs. 
No 
 
6. 
Prestamos’s Second Interrogatories (directed to each of the seven (18) Marshall and Drevnak Plaintiffs) 
Summary of ROGs 
(2): 
 
Served: Apr. 9, 2024 
 
Nos. 
Response 
 
 
Response and Objections: May 9, 
2024. 
Outstanding 
 
 
Plaintiffs have not verified 
Responses. 
Completed
 
 
No 
Government Agency 
1 
Certain Plaintiffs have 
communicated with SBA and those 
discussions have been produced. 
Description of any reports to, or 
discussions with, Government 
Agencies regarding alleged 
wrongdoing by Prestamos for all 
Plaintiffs. 
No 
Engagement 
2 
No Plaintiff has engaged legal 
counsel in connection with other 
matters that relate to Prestamos or 
PPP lending. 
None. 
Yes 
 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 11 of 17

 
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C. 
ANTICIPATED DISCOVERY 
1. 
Prestamos’s Depositions of Plaintiffs (directed to each of the 21 Marshall Plaintiffs) 
Summary of ROGs 
(2): 
 
Served: May 3, 2024 
 
Response 
 
 
Plaintiffs have not responded. 
Outstanding 
 
 
Not applicable. 
Completed
 
 
No 
Plaintiffs Noticed for 
Depositions 
None 
Plaintiffs have been noticed for depositions 
beginning on May 28, 2024 and continuing 
through June 24, 2024. 
No 
 
II. 
STATUS OF DISCOVERY REQUESTS BY DEFENDANT PRESTAMOS CDFI, LLC ON THIRD PARTIES  
Ba Fin, PPP, LLC d/b/a Blueacorn 
Evolve Bank & Trust 
Dave Inc. 
Plaintiffs’ Financial Institutions 
A. 
COMPLETED DISCOVERY 
None. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 12 of 17

 
12 
 
B. 
OUTSTANDING DISCOVERY 
1. 
Prestamos’s Third-Party Subpoena to Produce Documents (directed to BA Fin, PPP, LLC d/b/a Blueacorn) 
Summary of 
Document Requests 
(15): 
 
Served: Feb. 20, 2024 
 
Nos. 
Response 
 
 
 
Responses and Objections: Mar. 19, 
2024 
Outstanding 
 
 
 
All responsive documents are 
outstanding. 
Completed
 
 
 
No 
On Apr. 10, 2024, the parties met and conferred. Blueacorn agreed to reconsider some of its objections and to produce responsive 
documents. On May 9, 2024, Prestamos served Blueacorn with a subpoena to compel its appearance at the May 23, 2024 hearing. 
Blueacorn advised it was continuing to process responsive documents.  
PPP documents
1, 2, 3, 
and 4 
Blueacorn agreed to produce 
communications regarding loans 
Plaintiffs claim were not funded.  
Documents concerning PPP-related 
Communications with Blueacorn, 
Prestamos, the SBA, other entities, 
or Borrowers, and all Plaintiffs. 
No 
Borrower documents 
5, 6, and 
13 
Blueacorn agreed to produce 
documents and communications 
regarding loans Plaintiffs claim 
were not funded. 
Documents relating to modification 
of the PPP loan funding method. 
No 
Documents concerning PPP 
applications and any subsequent 
submissions by Plaintiffs.5 
No 
Documents relating to Blueacorn’s 
intake process and employee 
training. 
No 
Audit documents 
9 and 10 
Blueacorn stated it will not produce 
documents responsive to these 
Requests.  
Documents reflecting agreements 
with external auditors concerning 
Blueacorn’s participation in the PPP 
loan program. 
No 
                                                          
5 These Plaintiffs include: A. Marshall, D. Pronsky, P. Townsend, N. Holland, L. Owsley, K. Ahmadou, K. Dervin, K. Henderson, D. 
Innis, K. Stalnaker, J. Jones, G. Drevnak, J. Martin, K. Loyd, E. Beattie, G. Lloyd, A. Johnson, L. Marvel. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 13 of 17

 
13 
 
Reports, summaries, and findings 
from internal or external auditors 
concerning Blueacorn’s participation 
in the PPP loan program. 
No 
Organizational 
documents 
7, 8, and 
11 
Blueacorn agreed to produce 
documents regarding its corporate 
structure and marketing efforts.  
Documents relating to Blueacorn’s 
corporate structure. 
No 
Documents reflecting Blueacorn 
officers, directors or employees with 
knowledge relating to borrowers’ 
PPP loans 
No 
Documents reflecting Blueacorn’s 
marketing efforts borrowers that 
Blueacorn referred to Prestamos. 
No 
Loan documents 
12, 14, 
and 15 
Blueacorn agreed to produce 
documents reflecting its 
underwriting procedures and 
documents concerning Plaintiffs’ 
loans.  
Documents relating to Blueacorn’s 
process for reviewing borrowers’ 
qualifications for underwriting 
purposes. 
No 
Documents relating to the servicing 
of loans referred to Prestamos. 
No 
Documents relating to the 
fulfillment of loans referred to 
Prestamos. 
No 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 14 of 17

 
14 
 
2. 
Prestamos’s Third-Party Subpoena to Produce Documents (directed to Evolve Bank & Trust)  
Summary of 
Document Requests 
(2) 
 
 
Served: Feb. 20, 2024 
 
Nos. 
Response 
 
 
 
 
43 Documents (39 on Mar. 22, 2024 
and 5 on Apr. 24, 2024) 
Outstanding 
 
 
 
 
Transaction information for 13 
Plaintiffs. 
Completed
 
 
 
 
No 
Evolve Bank & Trust (“Evolve”) did not object to the production of documents responsive to Prestamos’s Requests. On May 9, 
2024, Prestamos served Evolve with a subpoena to compel its appearance at the May 23, 2024 hearing. 
ACH Return Codes 
documents 
1 
Produced 7 excel spreadsheets 
containing Prestamos ACH PPP 
loan funding transactions processed 
by Evolve and returned. 
None 
Yes 
Named-Plaintiffs 
documents6 
2 
Produced detailed PPP loan 
transaction information for 5 
Plaintiffs.7 
PPP loan transaction information 
potentially available for remaining 
Plaintiffs requires disclosure of 
highly confidential information 
(SSN). 
No 
 
                                                          
6 These Plaintiffs include: A. Marshall, D. Pronsky, P. Townsend, N. Holland, L. Owsley, K. Ahmadou, K. Dervin, K. Henderson, D. 
Innis, K. Stalnaker, J. Jones, G. Drevnak, J. Martin, K. Loyd, E. Beattie, G. Lloyd, A. Johnson, L. Marvel. 
7 These Plaintiffs include: A. Marshall, D. Innis, K. Dervin, L. Marvel, and L. Owsley. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 15 of 17

 
15 
 
3. 
Prestamos’s Third-Party Subpoena to Produce Documents (directed to Dave Inc.) 
Summary of 
Document Requests 
(4) 
 
Served: April 24, 2024 
 
Nos. 
Response 
 
 
 
134 documents produced on May 9, 
2024. 
Outstanding 
 
 
 
Complete deposit account 
agreements for Plaintiffs. 
Completed
 
 
 
No 
Dave Inc. did not object to the production of documents responsive to Prestamos’s.  
Account documents8 
1, 2, and 
3 
Produced account statements/ 
transaction histories, including ACH 
return codes; and correspondence 
(email, transcripts of phone calls). 
None 
Yes 
Policy documents 
4 
Produced account opening screens 
and account agreements. 
Policy documents relating to 
account use. 
No 
 
                                                          
8 These Plaintiffs include: A. Marshall, D. Innis, K. Dervin, L. Marvel, and L. Owsley. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 16 of 17

 
16 
 
C. 
ANTICIPATED DISCOVERY 
1. 
Prestamos’s Third-Party Subpoenas to Produce Documents (directed to Plaintiffs’ Financial Institutions)9 
Summary of 
Document Requests 
(3) 
 
Served: May 8, 2024 
 
Nos. 
Response 
 
 
 
Parties have not responded. 
 
Outstanding 
 
 
 
All responsive documents are 
outstanding. 
Completed
 
 
 
No 
Financial institution 
documents 
1 
 
Documents relating to each 
Plaintiffs’ account including bank 
statements, loan applications, etc. 
No 
Returned funds 
2 
 
Documents reflecting rejected or 
returned PPP loan funds for each 
Plaintiffs’ account.  
No 
Plaintiffs’ 
communications 
3 
 
Communications between each 
Plaintiff and their financial 
institution regarding PPP funds. 
No 
 
 
                                                          
9 The financial institutions include: JP Morgan Chase, Azlo Business, Inc., Bluebird, Wells Fargo Bank, N.A., Chime financial, Inc., 
TCF Bank National Bank, GO Bank, Public Service Credit Union, Green Dot. Corp., FirstBank, American First Federal Credit Union, 
SoFi Securities LLC, The Bancorp, Metabank National Association, Radius Bank, BMO Harris Bank NA, EECU, Capital One, Bank 
of America. 
Case 5:21-cv-04337-JMG     Document 112-1     Filed 05/10/24     Page 17 of 17

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