Ex. E — Marshall v. Prestamos CDFI, LLC (Dkt. 150-5, 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. 150-5 · 2025-03-13 · Docket on CourtListener

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EXHIBIT E 
Case 5:21-cv-04337-JMG     Document 150-5     Filed 03/13/25     Page 1 of 3

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Burruss, Chesley
From:
Bart D. Cohen <bcohen@baileyglasser.com>
Sent:
Thursday, May 16, 2024 5:38 PM
To:
Pratt, Marcel S.
Cc:
Justin Heller; Matthew Zapala; Lawrence J. Lederer; Gabriel R. Dos Santos; Watson, Travis 
W.; Austin Marshall; daniel@ha-firm.com; roy@ha-firm.com; Rogers, Edward; Burruss, 
Chesley; Longley, Henry; Gallagher, Thomas J.; Bart D. Cohen
Subject:
Marshall v. Prestamos - Discovery meet and confer
⚠ EXTERNAL 
Marcel: 
 
This updates Prestamos on several of the outstanding discovery issues including ones we discussed in our Tuesday 
5/14 meet and confer: 
 
 
Plaintiffs agree to depose Ms. Nunez and Messrs. Martinez and Castillo either in Arizona or remotely assuming 
defendants agree to also depose plaintiffs remotely. 
 
 
We are still working on getting you dates for plaintiffs’ depositions. That said, we can offer you now the 
following all assuming the depositions will be conducted remotely – plaintiff Alyshia Johnson 1:00 pm 6/13/24 as 
Prestamos noticed; plaintiff  Enobong Etuknwa 1:00 pm 6/20/24 as Prestamos noticed; plaintiff Sharon Bradley 
Smith either 6/26/24 or 6/28/24 (Prestamos noticed her for 6/24/24 but she is unavailable that day); plaintiff 
Paris Townsend later on 5/30/24 as Prestamos noticed or earlier in May 2024 (she has health issues and 
potential surgery in June); Alicia Marshall 5/28/24 as Prestamos noticed, but 9:00 am or 10:00 am PT; Kristina 
Henderson Saturday 6/8/24 not 6/5/24 as Prestamos noticed, she works full time. 
 
 
We will agree to depose Ms. Nunez and Messrs. Martinez and Castillo once provided that the parties stipulate 
that they’ll be no objections at the depositions regarding whether the testimony sought involves class 
certification issues, merits issues or a combination of the two, and this also reciprocally applies to Prestamos’s 
sole deposition of each plaintiff. 
 
 
You have agreed to share with us in advance of the 5/23/24 hearing any documents that you’ve subpoenaed for 
that hearing and obtain from Evolve Bank and Blueacorn. 
 
 
The parties have agreed that they will promptly produce to each other all documents the parties obtain from 
non-parties, and without any need for any party to propound any further written discovery requests.  
 
Best regards, 
 
Bart 
 
___________________________ 
Bart D. Cohen 
Of Counsel
Bailey & Glasser, LLP 
1622 Locust Street 
Philadelphia,  PA  19103
T: 215.274.9420
Case 5:21-cv-04337-JMG     Document 150-5     Filed 03/13/25     Page 2 of 3

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F: 202.463.2103
 
bcohen@baileyglasser.com  
www.baileyglasser.com 
 
This message and any attached documents contain information from the law firm of Bailey & Glasser LLP that 
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Signature ForBart D. Cohen 
 
Case 5:21-cv-04337-JMG     Document 150-5     Filed 03/13/25     Page 3 of 3

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