Exhibit 13 — Marshall v. Prestamos CDFI, LLC (Dkt. 163-15, 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. 163-15 · 2025-05-21 · Docket on CourtListener

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EX. 13 -- THE REPORT ON DAMAGES 
METHODOLOGY PROFESSOR STEVEN P. 
FEINSTEIN, PH.D., 
CFA (“FEINSTEIN”) DATED JULY 12, 2024 
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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 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REPORT ON DAMAGES METHODOLOGY 
 
PROFESSOR STEVEN P. FEINSTEIN, PH.D., CFA 
 
July12, 2024 
 
 
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TABLE OF CONTENTS 
I. 
SCOPE OF PROJECT AND REPORT ............................................................................... 1 
II. 
SUMMARY OF PLAINTIFFS’ ALLEGATIONS ............................................................. 1 
III. 
CREDENTIALS .................................................................................................................. 2 
IV. 
CONCLUSION ................................................................................................................... 4 
V. 
FACTUAL BACKGROUND ABOUT PRESTAMOS AND CPLC .................................. 5 
VI. 
ABOUT THE PPP ............................................................................................................... 7 
VII. 
DAMAGES METHODOLOGY .......................................................................................... 8 
VIII. 
ILLUSTRATION OF DAMAGE COMPUTATION USING THE COMMON 
DAMAGES METHODOLOGY ....................................................................................... 11 
IX. 
LIMITING FACTORS AND OTHER ASSUMPTIONS .................................................. 12 
 
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I. 
SCOPE OF PROJECT AND REPORT 
1. 
I was asked by Bailey & Glasser LLP, co-counsel for the Plaintiffs, to determine whether 
damages in this matter can be computed for all Class members using a common methodology 
that is consistent with the Plaintiffs’ theory of liability. Toward this end, I reviewed a wide 
variety of information and documents, including but not limited to the Third Amended Class 
Action Complaint, dated 1 May 2024 (“Complaint”), Memorandum of Law in Support of 
Defendants’ Motion to Dismiss Plaintiffs’ Second Amended Complaint, dated 3 June 2022, 
Memorandum of Law in Support of Defendant Chicanos Por La Causa’s Motion to Dismiss 
Plaintiffs’ Second Amended Complaint, dated 13 October 2023, the United States Small 
Business Administration (“SBA”) Paycheck Protection Program (“PPP”) loan database, 
regulatory filings, news articles, certain discovery produced by Defendants in this case, the 
Court’s rulings denying Defendants’ motion to strike my report and denying class certification 
in another PPP-related case, and other pertinent data and documents. 
2. 
Exhibit-1 lists the data and documents I reviewed and relied upon during this engagement. 
3. 
This report presents my analysis and conclusion. 
4. 
My work in this matter is ongoing. I reserve the right to amend, refine, or supplement my 
analyses and opinions in the event that I become aware of additional information, evidence, 
arguments, or analyses that bear on my work in this matter. 
II. 
SUMMARY OF PLAINTIFFS’ ALLEGATIONS 
5. 
Plaintiffs allege that Prestamos CDFI, LLC (“Prestamos”), a wholly-owned subsidiary of 
Chicanos Por La Causa, Inc. (“CPLC”) (collectively “Defendants”), failed to fund Plaintiffs’ 
PPP loans that had been approved by the SBA (Complaint, ¶¶13-14, 115, 405, 427). 
6. 
Plaintiffs allege that Prestamos breached its contractual undertaking by failing to fund the 
SBA-approved PPP loans and impeded Plaintiffs from accessing the funds of the PPP loan 
program (Complaint, ¶¶431, 435). 
7. 
It is further alleged that Prestamos falsely reported to the SBA that these PPP loans were 
funded, and Prestamos obtained loan processing fees for these loans from the SBA without 
having funded the loans (Complaint, ¶¶14, 131, 148, 157, 166, 180, 189, 198, 207, 216, 228, 
237, 248, 266, 279, 291, 308, 320, 333, 345, 356, 367, 376-377, 396-397, 400, 414). 
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8. 
Plaintiffs’ Complaint already identifies the number of Class members for several of the states 
who allegedly fall within the Class definition. It provides an aggregate number for ten of the 
states covered by the Class definition, and a state-by-state breakdown for those ten states. The 
ten-state total allegedly comprises 7,907 SBA-approved but unfunded PPP loan borrowers, 
which were to have received a total of $133.6 million in PPP loan proceeds, and which 
produced over $19.3 million in fees to Prestamos (Complaint, ¶¶376-377, 381-382). I 
understand that following the filing of the Complaint, additional data produced in discovery 
concerning the seven additional states added in the Marshall Third Amended Complaint – 
which are Colorado, Indiana, Mississippi, New York, Oklahoma, Texas, and Utah – add from 
those states an additional 3,748 PPP Class members, with over $60.5 million in total unfunded 
PPP loan proceeds, and over $8.9 million in loan processing fees for those allegedly unfunded 
loans. 
III. 
CREDENTIALS 
9. 
I am an Associate Professor of Finance at Babson College, and the founder and president of 
Crowninshield Financial Research, Inc., a financial economics consulting firm. 
10. 
I hold a Ph.D. in Economics from Yale University, a Master of Philosophy degree in 
Economics from Yale University, a Master of Arts degree in Economics from Yale 
University, and a Bachelor of Arts degree in Economics from Pomona College. I also hold 
the Chartered Financial Analyst (“CFA”) designation, granted by the CFA Institute. 
11. 
At Babson College, I have taught undergraduate and MBA-level courses in Capital Markets, 
Investments, Equity Analysis, Fixed Income Analysis, Financial Management, Risk 
Management, Quantitative Methods, and Security Valuation. I have also taught executive 
courses on investments and corporate financial management for numerous corporations. 
Other courses I have taught are listed in my curriculum vitae, which is attached as Exhibit-2. 
12. 
I have held the Chair in Applied Investments at Babson College and served as the Director of 
the Stephen D. Cutler Center for Investments and Finance, a research and education center 
dedicated to the study and teaching of investments and capital markets. 
13. 
Prior to my joining the faculty at Babson College, I taught at Boston University. Preceding 
my academic posts, I was an Economist at the Federal Reserve Bank of Atlanta where my 
primary responsibilities were to monitor financial markets, analyze proposed regulation, and 
advise the Bank President in preparation for his participation in meetings of the Federal Open 
2
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Market Committee – the government body responsible for monetary policy in the United 
States (“U.S.”). 
14. 
I have published in the field of finance. My finance articles have appeared in the Atlanta 
Federal Reserve Bank Economic Review, Derivatives Quarterly, Derivatives Weekly, The 
Engineering Economist, The Journal of Risk, The American Bankruptcy Institute Journal, The 
Journal of Financial Planning, The Journal of Forensic Economics, Managerial Finance, 
Risk Management, Primus, and The Review of Quantitative Finance and Accounting. I am the 
author of Finance and Accounting for Project Management, published by the American 
Management Association. I wrote two chapters in the book The Portable MBA in Finance 
and Accounting – one on corporate financial planning and the other on risk management. An 
article I recently co-authored about computing damages in class action securities cases has 
been accepted for publication in the University of Pennsylvania Journal of Business Law. 
15. 
I have presented research and analysis at the annual conventions of the American Finance 
Association, Financial Management Association, Eastern Finance Association, Midwestern 
Finance Association, the Academy of Financial Services, the Multinational Finance Society, 
the Taxpayers Against Fraud Education Fund Conference, the International Conference on 
Applied Business Research, and the National Association of Certified Valuators and Analysts 
(NACVA) Business Valuation and Financial Litigation Super Conference. 
16. 
A list of my presentations and published articles can be found in my curriculum vitae, which 
is attached as Exhibit-2. 
17. 
I have been selected to review papers for numerous finance journals and conferences, and I 
have reviewed finance textbook manuscripts for Prentice-Hall, Elsevier, Blackwell, and 
Southwestern Publishing. I have been quoted on matters relating to finance and investments 
in The Wall Street Journal, The Washington Post, The New York Times, The Financial Times, 
The Boston Globe, and Bloomberg News, and my research relating to financial analysis and 
valuation has been discussed in The Wall Street Journal, Bond Buyer, and Grant’s Municipal 
Bond Observer. 
18. 
I am a member of the American Finance Association, the Financial Management Association, 
the National Association of Forensic Economics, the CFA Institute, the CFA Society Boston, 
the North American Case Research Association, and NACVA. I have served as a member of 
the CFA Society Boston education committee and ethics subcommittee. I also served on the 
Fixed Income Specialization Examination Committee of the CFA Institute. 
3
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19. 
The CFA designation is the premier credential for financial analysts worldwide. In order to 
receive this credential, applicants must pass a series of three exams covering such topics as 
economics, equity analysis, financial valuation, business analysis, quantitative methods, 
investment analysis, portfolio management, risk management, financial accounting, and 
ethical and professional standards. For over ten years I taught in the Boston University CFA 
Review Program and the CFA Society Boston Review Program – two of the leading review 
programs that prepared candidates for the CFA exams. In both of these programs I taught 
candidates at the most advanced level. 
20. 
In addition to my teaching, research, and academic community responsibilities, I practice 
extensively as a financial consultant. My clients are primarily law firms that are prominent in 
financial services and securities litigation. Past clients also include the U.S. Securities and 
Exchange Commission, the Internal Revenue Service, the Attorney General of the State of 
Illinois, and the National Association of Securities Dealers. As an expert in financial 
economics, over the past 25 years, I have conducted analyses and presented opinions related 
to financial markets, valuation, and damages in more than 200 cases. Exhibit-3 lists my 
testimony appearances over the past four years. 
21. 
I am the sole owner of the consulting firm Crowninshield Financial Research, Inc., which 
receives compensation for the work performed by me and the staff who assist me. My firm is 
being compensated at a rate of $1,050 per hour for my work, and a range of lower rates for 
analysts and other personnel who are assisting me on this case. My compensation is not 
contingent on my findings or on the outcome of this matter. 
IV. 
CONCLUSION 
22. 
Damages in this matter can be computed in a straightforward way for all Class members using 
a common methodology that is consistent with Plaintiffs’ theory of liability. 
23. 
After considering a variety of damages methodologies, and analyzing each in the context of 
the definition of economic damages, my analysis compels the conclusion that measuring 
damages for each Class member as the difference between the SBA-approved PPP loan 
amount and the amount the Class member received, which Plaintiffs alleged is zero, plus 
prejudgment interest, is a feasible common class-wide methodology that provides a 
conservative measure of the economic damages sustained by each Class member. 
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V. 
FACTUAL BACKGROUND ABOUT PRESTAMOS AND CPLC 
24. 
Established as a wholly-owned subsidiary of CPLC in 2000, Prestamos is a financial services 
provider offering microloans, small business loans, new markets tax credit loans and 
investments, and small business development services to the Hispanic community and 
certified low-income investment tracts in Arizona and Nevada. Prestamos describes itself as 
a “certified Community Development Financial Institution (CDFI) and Community 
Development Entity (CDE) under the New Markets Tax Credit (NMTC) program” 
(https://cdfi.org/wp-content/uploads/2019/02/Prestamos-CDFI.pdf; 
https://prestamoscdfi. 
org/about-prestamos/; https://prestamoscdfi.org/business-empowerment-services/; and https: 
//prestamoscdfi.org/programs/). Certification as a Community Development Financial 
Institution is granted by the U.S. Treasury Department and provides certain tax breaks to 
lenders 
(https://www.cdfifund.gov/; 
and 
https://www.cdfifund.gov/programs-training 
/programs/new-markets-tax-credit). Prestamos was a qualified and approved SBA-supervised 
PPP lender. In 2020, Prestamos began offering PPP loan origination services and continued 
providing these services until the expiration of the PPP (“Chicanos Por La Causa, Inc. and 
Subsidiaries and Affiliates – Consolidated Financial Statements and Supplementary 
Information – Year Ended June 30, 2020,” Company report, published 11 December 2020, p. 
18; “Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2021,” Company report, 
published 21 December 2021, p. 18; and Complaint, ¶5). 
25. 
Prestamos’ parent company, CPLC, is a nonprofit community development corporation based 
in Arizona, “with operations in California, Nevada, New Mexico, and Texas” (“Chicanos Por 
La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial Statements and 
Supplementary Information – Year Ended June 30, 2021,” Company report, published 21 
December 2021, p. 15). CPLC reported in fiscal year (“FY”) 2021 that it had approximately 
50 subsidiaries, including Prestamos (“Chicanos Por La Causa, Inc. and Subsidiaries and 
Affiliates – Consolidated Financial Statements and Supplementary Information – Year Ended 
June 30, 2021,” Company report, published 21 December 2021, p. 15). 
26. 
Prestamos was an active PPP lender. Following the end of the PPP, the SBA reported the top 
PPP lenders in the U.S., and Prestamos was identified as a leading lender. Through 31 May 
2021, Prestamos had purportedly originated 494,415 PPP loans worth a total of $7.68 billion, 
ranking Prestamos third among all PPP lenders based on total number of loans approved and 
net dollars purportedly loaned. Other top PPP lenders included prominent financial 
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institutions such as Bank of America and JPMorgan Chase (“Paycheck Protection Program 
(PPP) Approvals through 5/31/2021,” U.S Small Business Association, p. 7). 
27. 
In FY 2019, prior to the PPP, CPLC reported total revenue of $81.2 million (“Chicanos Por 
La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial Statements and 
Supplementary Information – Year Ended June 30, 2019,” Company report, published 10 
December 2019, p. 5). In the following FYs, CPLC’s total revenue increased. Reported 
revenue was $108.5 million in FY 2020, $220.5 million in FY 2021, and $445.3 million in 
FY 2022 (“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated 
Financial Statements and Supplementary Information – Year Ended June 30, 2020,” 
Company report, published 11 December 2020, p. 6; “Chicanos Por La Causa, Inc. and 
Subsidiaries and Affiliates – Consolidated Financial Statements and Supplementary 
Information – Year Ended June 30, 2021,” Company report, published 21 December 2021, p. 
6; and “Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2022,” Company report, 
published 19 January 2023, p. 6). 
28. 
The fees paid by the SBA to Prestamos for originating and processing PPP loans contributed 
to the substantial increase in CPLC’s total revenues over the period from FY 2019 to FY 
2022. In FY 2020, the first year of the PPP, CPLC received $748,661 from the SBA for 
originating and processing PPP loans. The Company booked $21,343 of that revenue in that 
fiscal year, with the remainder treated as revenue deferred to later periods (“Chicanos Por La 
Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial Statements and 
Supplementary Information – Year Ended June 30, 2020,” Company report, published 11 
December 2020, p. 18). 
29. 
In FY 2021, CPLC received $314.3 million from the SBA for originating and processing PPP 
loans. The Company booked $5.09 million of PPP fees as current revenue in that period and 
treated the remainder as deferred revenue to be recognized in future periods (“Chicanos Por 
La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial Statements and 
Supplementary Information – Year Ended June 30, 2021,” Company report, published 21 
December 2021, p. 20). 
30. 
In FY 2022 CPLC again received hundreds of millions of dollars from the SBA for originating 
and processing PPP loans. That fiscal year, CPLC received $314.6 million from the SBA for 
originating and processing PPP loans. Of that amount, CPLC booked $243.4 million as 
current revenue, and treated the rest as deferred revenue to be recognized in future periods 
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(“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2022,” Company report, 
published 19 January 2023, p. 21). 
VI. 
ABOUT THE PPP 
31. 
The Paycheck Protection Program was a U.S. federal government program established by the 
Coronavirus Aid, Relief, and Economic Security (“CARES”) Act and was implemented by 
the SBA. Its purpose was to support small businesses with financial support to provide up to 
eight weeks of payroll costs, plus benefits via loans that were designed under the CARES Act 
and intended to be forgivable if the loans were made and used for permissible purposes. Funds 
were permitted to be used for payroll, utilities, rent, and mortgage interest under the PPP. 
Millions 
of 
Americans 
received 
$659 
billion 
(https://home.treasury.gov/policy-
issues/coronavirus/assistance-for-small-businesses/paycheck-protection-program). As part of 
the PPP, borrowers were permitted to apply for loan forgiveness. According to the SBA, 
“Borrowers can apply for forgiveness any time up to five years from the date that SBA issued 
the SBA loan number” (https://www.sba.gov/funding-programs/loans/covid-19-relief-
options/paycheck-protection-program/ppp-loan-forgiveness). However, those that did not 
apply for PPP loan forgiveness, “within 10 months after the last day of the covered period, 
then PPP loan payments are no longer deferred, and borrowers will begin making loan 
payments to their PPP lender” (https://www.sba.gov/funding-programs/loans/covid-19-
relief-options/paycheck-protection-program/ppp-loan-forgiveness). Of all of the loans 
distributed to Americans as part of the PPP, it is estimated that approximately 92.0% of all 
loans 
issued 
were 
granted 
in 
full 
or 
partially 
forgiven 
(https://www.npr.org/2023/01/09/1145040599/ppp-loan-forgiveness). Therefore, for all 
practical purposes, the PPP, while structured as a loan program, was in fact a grant program. 
The vast majority of PPP fund recipients had their loans forgiven. Aggrieved Class members 
were not just deprived of the use of the funds over a period of time, they were deprived of the 
quantity of funds permanently. 
32. 
To the extent that funds were intended to sustain businesses during the Coronavirus period, 
preventing business disruptions and losses, the costs of business disruptions and losses, and 
foregone profit opportunities may also be consequences of an aggrieved Class member not 
receiving PPP funds that had been approved for distribution. 
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VII. 
DAMAGES METHODOLOGY 
33. 
Counsel for Plaintiffs asked me to opine on whether damages can be measured using a 
methodology that is consistent with Plaintiffs’ theory of liability and can be commonly 
applied for all Class members with breach of contract claims. 
34. 
My understanding is that economic damages are the amount of compensation that would place 
Plaintiffs in the same economic condition that they would have been in currently if Prestamos 
had not engaged in the alleged wrongdoing (“Damages Theories and Causation Issues,” by 
Elizabeth Evans, et al., Chapter 4 of the Litigation Services Handbook: The Role of the 
Financial Expert, 6th Edition, edited by Roman Weil et al., John Wiley & Sons, Inc., 2017, p. 
4.20). 
35. 
According to Plaintiffs’ theory of liability, in the “but for” scenario where there was no 
alleged wrongdoing by Prestamos, Class members would have received a quantity of PPP 
funds that they did not receive in the actual scenario. Given the facts and circumstances of the 
instant case, and from an economics perspective, a Class member suffered damages if they 
applied for a PPP loan through Prestamos, was approved by the SBA for the PPP loan, sent 
back all completed documentation, but did not receive the PPP funds from Prestamos. 
36. 
In addition, a key part of the PPP that distinguishes a PPP loan from many other commercial 
loans is that the PPP loan was designed and intended to be forgiven if the loan was used for 
payroll and other purposes that was permissible under the PPP (Complaint, ¶¶52, 74). By 
definition, of the classes alleged in this case, all Plaintiffs and Class members never received 
their PPP loans. Thus, they could not even properly apply for forgiveness because the PPP 
loan forgiveness application required them to certify they used the loan proceeds for 
permissible purposes under the PPP, which included payroll costs to retain employees, 
business mortgage interest payments, business rent or lease payments, and business utility 
payments. See https://home.treasury.gov/system/files/136/3245-0407-SBA-Form-3508-PPP-
Forgiveness-Application.pdf. This deprivation of opportunity also damaged Plaintiffs and 
Class members because the vast bulk of all PPP loans that were actually funded were forgiven 
according to publicly available data. See https://www.pandemicoversight.gov/data-
interactive-tools/data-stories/how-many-paycheck-protection-program-loans-have-been-
forgiven. 
37. 
Therefore, assuming Plaintiffs establish liability, each Class member’s damages are at a 
minimum the respective amount of their SBA-approved PPP loan that Prestamos failed to 
fund. 
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38. 
Given the facts and circumstances of this case, and assuming Plaintiffs’ allegations and 
Prestamos’ liability are proved, the respective amount of the SBA-approved but unfunded 
PPP loan, plus prejudgment interest, is a conservative lower bound on the damages for each 
Class member particularly given PPP loan forgiveness. 
39. 
The unfunded PPP loan amount, while serving as a base for computing damages, is by itself 
a conservative measure of damages, as it excludes consequential damages, which would 
include business losses and foregone profit opportunities that no doubt were additional 
consequences of Class members not receiving their PPP loans. 
40. 
The unfunded loan amount by itself omits compensation for consequential business losses or 
foregone business profits. Prestamos’ failure to fund the SBA-approved PPP loans reasonably 
caused certain Class members financial harm as they may have lost the opportunity to 
maintain or grow their business, or even may have lost their business. As explained in the 
Complaint, Prestamos’ failure to fund the PPP loans also similarly resulted in Plaintiffs’ lost 
opportunities, for example: “Prestamos’ failure to fund Marshall’s SBA-approved PPP loan 
deprived Marshall of funds that would have directly assisted in the operation of her in-home 
healthcare business and resulted in lost opportunities and other consequential damages” 
(Complaint, ¶137). 
41. 
Similarly, damages measured as the approved but unfunded amount of the SBA-approved 
PPP loan does not consider and compensate Plaintiffs for further direct financial losses and 
harm sustained because of the failure to fund these loans to Plaintiffs. The Complaint provides 
an example of a borrower who allegedly suffered damages because of Prestamos’ failure to 
fund an SBA-approved PPP loan, who complained that “Ive previously been approved for a 
ppp loan with Prestamos CDFI LLC as my lender. This loan appears online on several sites 
as being disbursed from Prestamos CDFI LLC to myself … back in May 2021 but the issue 
is that Ive never received these funds. ... Ive recently taken out a separate business loan in the 
amount of what my ppp loan was to cover business things so I went ahead and applied for the 
Forgiveness and Prestamos accepted it and sent it to the sba. Only way to apply for forgiveness 
is by being approved and funds disbursed. I still havent received any of those funds from 
Prestamos CDFI LLC and theyre lacking important communication [sic]” (Complaint, ¶373). 
42. 
Prejudgment interest is a conservative lower bound on consequential damages that Plaintiffs 
and aggrieved Class members suffered as a result of not having their PPP loans funded. Any 
individual or business would have rationally chosen to either spend or invest PPP funds in the 
highest yielding manner permitted by the PPP as noted above that was most loss-preventing 
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or profitable. Based on generally accepted economic principles, the reasonable expected rate 
of return on an operating business into which money is invested is generally greater than the 
risk-free rate of return that can be earned on a passive investment in government notes. Thus, 
prejudgment interest should be added to the quantity of foregone PPP funding in the measure 
of damages because prejudgment interest is a conservative proxy for the business return that 
could have been earned with the PPP funds. I understand that there is also a statutory or legal 
basis for including prejudgment interest in the measure of damages. 
43. 
For each Class member, measurement of their unfunded PPP loan quantity is readily available 
from case and loan documentation. The amount of the SBA-approved PPP loan can be 
determined by the loan documentation. 
44. 
Typically, the specific prejudgment interest rate is selected to appropriately compensate the 
injured party for the delay in an awarded remedy. The specific rate for prejudgment interest 
varies depending on statutes and legal precedents. In federal jurisdictions, prejudgment 
interest “… is left to the court’s judgment based on the facts and circumstances of the case 
…” (“Prejudgment Interest,” by Jeffrey Colon and Michael Knoll, Chapter 16 of the 
Litigation Services Handbook: The Role of the Financial Expert, 6th Edition, edited by Roman 
Weil et al., John Wiley & Sons, Inc., 2017, p. 16.2; and “Discounting Lost Profits in Damage 
Measurements,” by Michael Crain, Chapter 15 of The Comprehensive Guide to Economic 
Damages, 6th Edition, edited by Nancy Fannon and Jonathan Dunitz, Business Valuation 
Resources, LLC, 2020, p. 318). 
45. 
The choice of the specific prejudgment interest rate considers various factors. The cost of 
attaining new unsecured financing at the time of the loss is one reasonable rate. That rate can 
either be the defendant’s cost of funds or the plaintiff’s, and rationales exist for either choice 
(“Prejudgment Interest,” by Jeffrey Colon and Michael Knoll, Chapter 16 of the Litigation 
Services Handbook: The Role of the Financial Expert, 6th Edition, edited by Roman Weil et 
al., John Wiley & Sons, Inc., 2017, pp. 16.3-5). 
46. 
Applying either a fixed statutory rate or the conservatively low risk-free short-term Treasury 
interest rate for the computation of prejudgment interest for all Class members provides a 
reasonable, conservative, and common damage methodology for all Class members. 
47. 
From an economics perspective, the start date for measuring prejudgment interest may be the 
date of injury or the filing date of the action, depending on governing law and economic 
considerations and how the Court may rule (“Discounting Lost Profits in Damage 
Measurements,” by Michael Crain, Chapter 15 of The Comprehensive Guide to Economic 
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Damages, 6th Edition, edited by Nancy Fannon and Jonathan Dunitz, Business Valuation 
Resources, LLC, 2020, p. 318; and “Prejudgment Interest,” by Jeffrey Colon and Michael 
Knoll, Chapter 16 of the Litigation Services Handbook: The Role of the Financial Expert, 6th 
Edition, edited by Roman Weil et al., John Wiley & Sons, Inc., 2017, p. 16.11). In the instant 
matter, the start date for computation of prejudgment interest can either be the date the initial 
Plaintiffs’ action was filed, or a certain interval of time after each respective loan application 
was entered into (based on an estimate of how long PPP loans typically took to be funded), 
or alternatively, some other date dictated by the Court. Whatever the final determination is as 
to the start date for computations of prejudgment interest, that determination will apply 
commonly to all Class members. 
48. 
I filed a report concerning the damages methodology in another PPP-related case, Greathouse 
v. Capital Plus Financial, LLC, 2023 WL 5746927 (N.D. Tex. Sept. 6, 2023). There, the 
Court denied class certification on grounds not related to the damages methodology that my 
report addressed. Defendants moved to strike my report in that case, but the Court denied 
Defendants’ motion (at footnote 2). Further, this case and proposed Class is materially 
different than that case. For example, the Court held in Capital Plus that the requirement that 
the class contain numerous class members was not satisfied because the plaintiffs there 
“fail[ed] to provide any evidence or reasonable estimate on the potential number of class 
members” (Greathouse, 2023 WL 5746927, at *4). Here, by contrast, Plaintiffs obtained 
evidence in discovery in this case in the form of two spreadsheets produced to them by 
Prestamos itself that I referred to above and which identifies the total number of Class 
members, the total number on a state-by-state basis, the total SBA-approved PPP loan 
proceeds that Prestamos failed to fund, and the total PPP loan processing fees that Prestamos 
collected anyway from the SBA for those unfunded PPP loans. 
VIII. ILLUSTRATION OF DAMAGE COMPUTATION USING THE 
COMMON DAMAGES METHODOLOGY 
49. 
I next demonstrate that the Class-wide damages methodology described can be applied to any 
Class member’s alleged economic damages. 
50. 
Given that the prejudgment interest rate potentially requires a decision from a judge or jury 
(applicable to all members of the Class), I made a working assumption for illustration 
purposes. For this example, I used the 3-year U.S. Treasury note rate prevailing at the time of 
this action’s initial filing which I believe is a reasonable and conservative measure because it 
11
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51.
53.
is a low-yield, risk-free instrument. Ifthe Court determines that a higher interest rate, such as
the yield on corporate bonds, ora risk-free instrument with a longer maturity is appropriate,
or alternatively that
a particular statutory rate is appropriate, that interest rate would be
substituted into the example below and would still be common to all Class members.
Assume a particular Class member was approved to receive an SBA-approved PPP loan for
$10,000 but this loan was never funded. Assume the prejudgment interest rate is 0.487% per
annum, which was the 3-year U.S. Treasury note semi-annually compounded simple interest
yield as of the date of the initial filing in this case,
1 October 2021 (as to certain of the
Plaintiffs; I understand other Plaintiffs were added subsequently and those subsequent dates
can be used for each such later-filed Plaintiff as applicable). For purposes ofthe illustration,
assume the ultimate date ofjudgement is 1 October 2024, three years after initial suit filing.
At a minimum, damages are the $10,000 amount ofthe unfunded loan. Prejudgment interest
would be $147, which equals semi-annually compounded interest accruing at a simple rate of
0.487% over three years. Total damages inclusive ofprejudgment interest would therefore be
$10,147.
This proposed measure of damages is conservative because it excludes the consequential
losses and harm sustained by Class members beyond the quantity of funds not received and
above the risk-free, low-yield Treasury note interest.
Further, in the event that the Court awards punitive damages to the Class, the aggregate
punitive award can be allocated to Class members on a pro-rata basis, commensurate with
their proportion oftotal economic damages.
LIMITING FACTORS AND OTHER ASSUMPTIONS
This report is furnished solely for the purpose ofcourt proceedings in the above-named matter
and may not beused or referred to for any other purpose. The analysis and opinions contained
in this report are based on information available as ofthe date ofthis report. I reserve the right
to supplement or amend this report, including in the event additional information becomes
available.
Steven P. Feinstein, Ph.D., CFA
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Exhibit-1 
Documents and Other Information Considered 
CASE DOCUMENTS 
• 
Memorandum of Law in Support of Defendants’ Motion to Dismiss Plaintiffs’ Second 
Amended Complaint, filed 3 June 2022. 
• 
Memorandum Opinion, filed 30 March 2023. 
• 
Opinion & Order, filed 6 September 2023. 
• 
Memorandum of Law in Support of Defendant Chicanos Por La Causa’s Motion to 
Dismiss Plaintiffs’ Second Amended Complaint, filed 13 October 2023. 
• 
Third Amended Class Action Complaint, filed 2 May 2024. 
COMPANY REPORTS 
• 
“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2019,” Company 
report, published 10 December 2019. 
• 
“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2020,” Company 
report, published 11 December 2020. 
• 
“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2021,” Company 
report, published 21 December 2021. 
• 
“Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates – Consolidated Financial 
Statements and Supplementary Information – Year Ended June 30, 2022,” Company 
report, published 19 January 2023. 
 
ACADEMIC AND PROFESSIONAL LITERATURE 
• 
Colon, Jeffrey, and Michael Knoll, “Prejudgment Interest,” Chapter 16 of the Litigation 
Services Handbook: The Role of the Financial Expert, 6th ed., edited by Roman Weil, 
Daniel Lentz, and Elizabeth Evans, John Wiley & Sons, Inc., 2017. 
• 
Crain, Michael, “Discounting Lost Profits in Damage Measurements,” Chapter 15 of The 
Comprehensive Guide to Economic Damages, 6th Edition, edited by Nancy J. Fannon, 
Jonathan Dunitz, Business Valuation Resources, LLC, 2020. 
• 
Evans, Elizabeth, Phil Innes, and Daniel Letz, “Damages Theories and Causation Issues,” 
Chapter 4 of the Litigation Services Handbook: The Role of the Financial Expert, 6th ed., 
edited by Roman Weil, Daniel Lentz, and Elizabeth Evans, John Wiley & Sons, Inc., 
2017. 
13
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Exhibit-1 
Documents and Other Information Considered 
DATA AND DATABASES 
• 
ProPublica 
• 
U.S. Small Business Administration Paycheck Protection Program Database 
LEGAL CASES 
• 
Greathouse v. Capital Plus Financial, LLC, 2023 WL 5746927 (N.D. Tex. Sept. 6, 2023) 
OTHER 
• 
https://www.cdfifund.gov/ 
• 
https://www.cdfifund.gov/programs-training /programs/new-markets-tax-credit 
• 
https://cdfi.org/wp-content/uploads/2019/02/Prestamos-CDFI.pdf 
• 
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-small-
businesses/paycheck-protection-program 
• 
https://home.treasury.gov/system/files/136/3245-0407-SBA-Form-3508-PPP-
Forgiveness-Application.pdf 
• 
https://www.npr.org/2023/01/09/1145040599/ppp-loan-forgiveness 
• 
https://www.pandemicoversight.gov/data-interactive-tools/data-stories/how-many-
paycheck-protection-program-loans-have-been-forgiven 
• 
https://prestamoscdfi.org/about prestamos/ 
• 
https://prestamoscdfi.org/business-empowerment-services/ 
• 
https: //prestamoscdfi.org/programs/ 
• 
https://www.sba.gov/funding-programs/loans/covid-19-relief-options/paycheck-
protection-program/ppp-loan-forgiveness 
• 
“Paycheck Protection Program (PPP) Approvals through 5/31/2021,” U.S Small Business 
Association 
• 
Any other documents cited in the report. 
14
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
Babson College 
Finance Division 
Babson Park, MA 02457 
781-239-5275 
Feinstein@Babson.edu 
 
EDUCATION 
 
1989 YALE UNIVERSITY 
 
Ph.D. in Economics (Concentration in Finance) 
 
1986 YALE UNIVERSITY 
 
M.Phil. in Economics 
 
1983 YALE UNIVERSITY 
 
M.A. in Economics 
 
1981 POMONA COLLEGE 
 
B.A. in Economics (Phi Beta Kappa, cum laude) 
 
 
TEACHING EXPERIENCE 
 
1996 - present 
BABSON COLLEGE 
 
Babson Park, MA 
 
Full-time Faculty, Finance Division 
 
Associate Professor (2000-present) 
 
Donald P. Babson Chair in Applied Investments (2002-2010) 
 
Faculty Director of the Babson College Fund (2002-2009) 
 
Director of the Stephen D. Cutler Investment Management Center (2002-
2007) 
Assistant Professor (1996-2000) 
 
1990 - 1995 
BOSTON UNIVERSITY SCHOOL OF MANAGEMENT 
 
Boston, MA 
 
Full-time Faculty, Department of Finance 
 
1993 - 1994 
WASHINGTON UNIVERSITY, OLIN SCHOOL OF BUSINESS 
 
St. Louis, MO 
 
Visiting Assistant Professor, Department of Finance 
 
 
15
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
BUSINESS EXPERIENCE 
 
2008 - present 
CROWNINSHIELD FINANCIAL RESEARCH, INC. 
 
Brookline, MA 
 
President and Senior Expert 
 
1996 - 2008 
THE MICHEL-SHAKED GROUP 
 
Boston, MA 
 
Senior Expert (2001 - 2008) 
 
Affiliated Expert (1996 - 2001) 
 
1987 - 1990 
FEDERAL RESERVE BANK OF ATLANTA 
 
Economist 
 
 
PROFESSIONAL DESIGNATIONS 
 
1998 Awarded the Chartered Financial Analyst designation by the Association for Investment 
Management and Research. 
 
 
RESEARCH AWARDS 
 
1999 Greater Boston Real Estate Board/Real Estate Finance Association – Research Grant and 
Featured Speaker at Real Estate Finance Association Meetings. 
 
 
PAPERS AND PUBLICATIONS 
 
“The Class Certification of Exchange-Listed Options in Securities Class-Action 
Litigation,” (with Don Chance and Onnig Dombalagian) forthcoming in University of 
Pennsylvania Journal of Business Law, 2024. 
 
“Securities Litigation Event Studies in the Covid Volatility Regime,” (with Miguel 
Villanueva) Journal of Forensic Economics, vol. 30, no. 1, 2022. 
 
“Stock Price Reactivity to Earnings Announcements: The Role of the Cammer/Krogman 
Factors,” (with Miguel Villanueva) Review of Quantitative Finance and Accounting, vol. 
57, no. 1, 2021. 
 
“What A Solar Eclipse Has To Do With Market Efficiency,” (with Daniel Bettencourt) 
Law360.com, 2017. 
 
 
 
16
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Case 5:21-cv-04337-JMG     Document 163-15     Filed 05/21/25     Page 19 of 31

Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“Underestimation of Securities Fraud Aggregate Damages Due to Inter-Fund Trades,” 
(with Gang Hu, Mark Marcus, and Zann Ali) Journal of Forensic Economics, September 
2013, Vol. 24, No. 2, 161-173. 
 
“Lehman Equity Research Tipping: Evidence in the Stock Price Data,” Working paper, 
March 2010. Cited in New York Times May 19, 2012, and made available on the New 
York Times website. 
 
“Distortion in Corporate Valuation: Implications of Capital Structure Changes,” (with 
Allen Michel and Jacob Oded) Managerial Finance, 2011, Vol. 37(8), 681-696. 
 
“Market Signals of Investment Unsuitability,” (with Alexander Liss and Steven Achatz) 
Law360.com, June 3, 2010. Available from http://www.law360.com/articles/170690. 
 
“Planning Capital Expenditure,” in The Portable MBA in Financing and Accounting, J. L. 
Livingstone and T. Grossman, editors, New York: Wiley, 3rd edition 2001, and 4th edition 
2009. 
 
“Financial Management of Risks,” in The Portable MBA in Financing and Accounting, J. 
L. Livingstone and T. Grossman, editors, New York: Wiley, 2nd edition 1997, 3rd edition 
2001, and 4th edition 2009. 
 
“Fraud-on-the-Market Theory: Is a Market Efficient?” (with Allen Michel and Israel 
Shaked) American Bankruptcy Institute Journal, May 2005. 
 
“Valuation of Credit Guarantees,” (with Allen J. Michel and Israel Shaked) Journal of 
Forensic Economics 17(1), pp. 17-37, 2005. 
 
“A Better Understanding of why NPV Undervalues Managerial Flexibility,” (with Diane 
Lander) in The Engineering Economist, 2002, Volume 47, Number 4. 
 
“Teaching the Strong-Form Efficient Market Hypothesis: A Classroom Experiment,” 
Journal of Financial Education, fall 2000. 
 
A Future for Real Estate Futures: Potential Applications of Derivatives in Real Estate 
Investment and Finance (with Linda Stoller). Monograph. Boston: Real Estate Finance 
Association / Greater Boston Real Estate Board, May 2000. 
 
“The Risk Budget: Using Your Human Resources,” (with John Marthinsen and John 
Edmunds) Risk Management, April 2000. 
 
“Scenario Learning: A Powerful Tool for the 21st Century Planner,” (with Jeffrey Ellis 
and Dennis Stearns) The Journal of Financial Planning, April 2000. 
 
17
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“Protecting Future Product Liability Claimants in the Case of Bankruptcy,” (with Allen 
Michel and Israel Shaked) American Bankruptcy Institute Journal, January 2000. 
 
“Measuring Risk with the Bodie Put When Stocks Exhibit Mean Reversion,” The Journal 
of Risk, Vol. 1, No. 3, 1999. 
 
“Just-in-Time Mathematics: Integrating the Teaching of Finance Theory and 
Mathematics,” (with Gordon Prichett) Primus, Vol. IX, No. 2, June 1999. 
 
Atlanta Park Medical Center v. Hamlin Asset Management. (with Natalie Taylor). 
Babson Case Collection, Harvard Business School Press, 1998. 
 
“Dealing with Delta,” Derivatives Week, VII, No. 44, November 2, 1998. 
 
“Expected Return in Option Pricing: A Non-Mathematical Explanation,” Derivatives 
Week, VII, No. 35, August 31, 1998. 
 
“When Hedges Fail: The Put Paradox and its Solution,” Derivatives Quarterly, Vol. 4, 
No. 2, Winter 1997. 
 
Finance and Accounting for Project Management. New York: American Management 
Association, 1996. 
 
“International Investing,” in Irwin’s Directory of Emerging Market Brokerages.  New 
York: Irwin, 1996. 
 
“The Hull and White Implied Volatility,” Boston University Working Paper #92-51, 
1992. 
 
“Immunizing Against Interest Rate Risk Using the Macaulay Duration Statistic: An 
Assessment,” (with Don Smith) in Financial Systems and Risk Management, the 
proceedings of the US-Japan Forum on Financial Strategy in the 1990s, sponsored by 
Osaka Foundation of International Exchange and Boston University, August 1991. 
 
“Covered Call Options: A Proposal to Ease LDC Debt,” (with Peter Abken) Federal 
Reserve Bank of Atlanta Economic Review, March/April 1990.  Reprinted in Financial 
Derivatives: New Instruments and Their Uses. Atlanta: Federal Reserve Bank. 
 
“Forecasting Stock-Market Volatility Using Options on Index Futures,” Federal Reserve 
Bank of Atlanta Economic Review, May/June 1989.  Reprinted in Financial Derivatives: 
New Instruments and Their Uses. Atlanta: Federal Reserve Bank. 
 
 
 
18
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“The Black-Scholes Formula is Nearly Linear in Sigma for At-the-Money Options; 
Therefore Implied Volatilities from At-the-Money Options are Virtually Unbiased,” 
Federal Reserve Bank of Atlanta Working Paper #88-9, December 1988. 
 
“The Effect of the ‘Triple Witching Hour’ on Stock Market Volatility,” (with William 
Goetzmann) Federal Reserve Bank of Atlanta Economic Review, September/October 
1988. Reprinted in Financial Derivatives: New Instruments and Their Uses. Atlanta: 
Federal Reserve Bank. 
 
“Stock Market Volatility,” Federal Reserve Bank of Atlanta Economic Review, 
November/December 1987. 
 
Book review of In Who’s Interest: International Banking and American Foreign Policy, 
by Benjamin J. Cohen, Yale University Press, in Federal Reserve Bank of Atlanta 
Economic Review, Summer 1987. 
 
 
PRESENTATIONS 
 
“Proving and Disproving Market Efficiency for Appraisal Hearings,” at the NACVA/CTI 
Business Valuation and Financial Litigation Super Conference, July 2023. 
 
“SPAC Public Warrant Valuation Using Iterative Monte Carlo Simulation,” (with Ayussh 
Ahuja, Achraf Krafssi, and Dukalion Tsapalas) at the Financial Management Association 
Annual Meeting, October 2021. 
 
“Stock Price Reactivity to Earnings Announcements: A Cross-Sectional Analysis of the 
Cammer/Krogman Factors,” (with Miguel Villanueva) at the Boston Area Finance 
Symposium, April 2018. 
 
“Stock Price Reactivity to Earnings Announcements: A Cross-Sectional Analysis of the 
Cammer/Krogman Factors,” (with Miguel Villanueva) at the Eastern Finance Association 
Conference, April 2018. 
 
“Determining the Defendant’s Ability to Pay,” at Taxpayers Against Fraud Education 
Fund Conference, October 2010. 
 
“The Computation of Damages in Securities Fraud Cases,” at the Grant and Eisenhofer 
Institutional Investor Conference, December 2002. 
 
“The Role of the Financial Expert in Complex Litigation,” at the Financial Management 
Association Conference, October 2000. 
 
 
 
19
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“Entrepreneurial Incentives and Resource Allocation Among Corporate Venturing 
Initiatives,” (with Joel Shulman and U. Srinivasa Rangan), Babson Entrepreneurship 
Research Conference, May 2000. 
 
“Application of Real Options in Purchasing Strategies,” (with Juan Orozco), presented at 
the International Applied Business Research Conference, March 2000. 
 
“A Future for Real Estate Futures,” (with Linda Stoller) at the Fairfield County chapter of 
the Real Estate Finance Association, November 1999, and at the Greater Boston Real 
Estate Board, November 2000. 
 
“Atlanta Park Medical Center v. Hamlin Asset Management,” (with Natalie Taylor) at the 
1999 convention of the North American Case Research Association. 
 
“Using Future Worlds in the Financial Planning Process,” (with Jeffrey Ellis) at the 
Institute of Certified Financial Planners Masters Retreat, October 1999. 
 
“Toward a Better Understanding of Real Options: A Weighted Average Discount Rate 
Approach,” at the 1999 Financial Management Association Conference, the 1999 
European Financial Management Association Conference, and the 1999 Multinational 
Finance Society Conference. 
 
“Just-In-Time Mathematics: Integrating the Teaching of Finance Theory and 
Mathematics,” (with Gordon Prichett) at the 1999 Financial Management Association 
Conference. 
 
“Alternative Dow Investments for the Individual Investor: Diamonds, Synthetics, and the 
Real Thing,” at the 1999 Academy of Financial Services Convention. 
 
“Evidence of Yield Burning in Municipal Refundings,” at Financial Management 
Association Convention, October 1997; Government Finance Officers Association, 1997; 
and Northeast Regional Convention of the National Association of State Treasurers, 
1997. 
 
“Teaching the Strong-Form Efficient Market Hypothesis,” at Conference on Classroom 
Experiments in the Teaching of Economics at University of Virginia, September 1995. 
 
“Efficient Consolidation of Implied Standard Deviations,” (with Shaikh Hamid) at 
Midwest Finance Association, March 1995. 
 
“A Test of Intertemporal Averaging of Implied Volatilities,” (with Shaikh Hamid) at 
Eastern Finance Association, April 1995. 
 
 
 
20
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“Taking Advantage of Volatility:  Non-linear Forecasting and Options Strategies,” (with 
Hassan Ahmed) at Chicago Board of Trade / Chicago Board Options Exchange 
Conference on Risk Management, February 1992. 
 
“Immunizing Against Interest Rate Risk Using the Macaulay Duration Statistic: An 
Assessment,” (with Don Smith) at Japan-U.S. Conference on Financial Strategies in the 
1990s, Osaka, Japan, August 1991. 
 
“The Hull and White Implied Volatility,” at American Finance Association Convention, 
December 1990. 
 
 
REVIEWED ARTICLES AND BOOKS FOR: 
 
Harvard Business School Publishing 
Elsevier 
Journal of Economic Education 
Journal of Forensic Economics 
Journal of Risk 
Financial Review 
North American Case Research Association 
Financial Management 
Journal of Business 
Journal of Money, Credit and Banking 
Quarterly Review of Economics and Finance 
Blackwell 
Prentice Hall 
Southwestern Publishing 
 
 
COURSES TAUGHT 
 
Advanced Derivative Securities (MBA) 
Babson College Fund (Undergraduate and MBA) 
Capital Markets (MBA) 
Continuous-Time Finance (Doctoral) 
Corporate Finance (MBA and Executive) 
Corporate Financial Strategy (MBA) 
Cross-Functional Management (Integrated curriculum, Undergraduate) Equity Markets 
(MBA) 
Derivatives: Theory and Practice (MBA) 
Financial Reporting and Corporate Finance (MBA) 
Financial Management (MBA) 
Fixed Income Analysis (Undergraduate and MBA) 
21
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
Introduction to Derivative Securities (Executive) 
International Finance (Executive) 
Integrated Management (Undergraduate) 
Investments (MBA and Executive) 
Mod B: Decision Making and Applications, Finance stream (MBA) 
Options and Futures (Undergraduate) 
Risk Management (MBA) 
Portfolio Theory / Management Information Systems (Executive) 
Quantitative Methods for Investment Management (Undergraduate and MBA) 
Security Valuation (Undergraduate and MBA) 
 
 
TEACHING AWARDS 
 
Reid Teaching Award, Washington University, Olin School of Business, 1993-94. 
 
 
SELECT LIST OF MEDIA CITATIONS 
 
“Is Insider Trading Part of the Fabric?” by Gretchen Morgenson, The New York Times, 
May 19, 2012. 
 
“Bankers Rigging Municipal Contract Bids Admit to Cover-Up Lies,” by William 
Selway and Martin Z. Braun, Bloomberg Markets Magazine, November 24, 2010. 
 
“Hospital Move Presents Buy-Out Groups with New Risks,” by Francesco Guerra, 
Christopher Bowe, and Rebecca Knight, Financial Times, July 15, 2006. 
 
“Funds of Knowledge Add Value,” by Rebecca Knight, Financial Times, March 12, 
2006. 
 
“City’s Financial Picture Worse Than Ever, Sanders Says,” by Matthew T. Hall, San 
Diego Union-Tribune, January 7, 2006. 
 
“Downer: Stock Market Takes Another Dive,” by John Chesto, Boston Herald, July 23, 
2002. 
 
“Banks, Developers, Are Main Beneficiaries,” [editorial column] by Steven Feinstein, 
The Boston Globe, March 31, 2002, p. C4. 
 
“Washington Investing: What Michael Saylor is Really Worth,” by Jerry Knight, The 
Washington Post, March 6, 2000. 
 
“IBM Retools Pensions,” by Stephanie Armour, USA Today, May 4, 1999. 
22
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Exhibit-2 
Curriculum Vitae 
Steven P. Feinstein, Ph.D., CFA 
 
“L.A. MTA’s Law Firm Says Lissack Strategy Will be a Replay,” by Andrea Figler, 
Bond Buyer, September 30, 1998. 
 
“Fed Key Player in Rescue of Floundering Hedge Fund,” by Andrew Fraser, Associated 
Press, September 25, 1998. 
 
“Top Banks Plan Bailout for Fund,” by Andrew Fraser, Associated Press, September 24, 
1998. 
 
“Clarion Call to the Small Investor,” by Jo-Ann Johnston, The Boston Globe, March 4, 
1998. 
 
“L.A. Authority Study Shows Rampant Yield Burning Abuse,” by Michael Stanton, The 
Bond Buyer, April 22, 1997. 
 
“Dispute Over Yield Burning Dominates GFOA Session,” by Michael Stanton, The Bond 
Buyer, January 29, 1997. 
 
“Men Behaving Badly (Yield Burning),” Grants Municipal Bond Observer, January 24, 
1997. 
 
“Municipal Bond Dealers Face Scrutiny,” by Peter Truell, The New York Times, 
December 17, 1996. 
 
“Iowa Market Takes Stock of Presidential Candidates,” by Stanley W. Angrist, The Wall 
Street Journal, August 28, 1995. 
 
“Looking for Clues in Options Prices,” by Sylvia Nasar, The New York Times, July 18, 
1991. 
 
“For Fed, A New Set of Tea Leaves,” by Sylvia Nasar, The New York Times, July 5, 
1991. 
 
 
MEMBERSHIP IN PROFESSIONAL SOCIETIES 
 
American Finance Association 
CFA Society Boston 
Chartered Financial Analyst Institute 
Financial Management Association 
Foundation for Advancement of Research in Financial Economics (founding member) 
National Association of Certified Valuators and Analysts 
National Association of Forensic Economics 
North American Case Research Association 
23
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Exhibit-3 
Steven P. Feinstein, Ph.D., CFA 
Testimony Provided in the Last Four Years 
 
In Re Blackberry Limited Securities Litigation 
Case No. 13-cv-07060-CM-KHP 
United States District Court 
Southern District Of New York 
Deposition Testimony 
July 2018 
Deposition Testimony 
July 2020 
 
In Re Johnson & Johnson Securities Litigation 
Civil Action No. 3:18-cv-01833-FLW-TJB 
United States District Court 
District of New Jersey 
Deposition Testimony 
October 2020 
 
In Re Envision Healthcare Corporation Securities Litigation 
Civil Action No. 3:17-cv-01112 
United States District Court 
Middle District of Tennessee 
Nashville Division 
Deposition Testimony 
January 2021 
 
In Re Novo Nordisk Securities Litigation 
Civil Action No. 3:17-cv-209-BRM-LHG 
United States District Court 
District of New Jersey 
Deposition Testimony 
February 2021 
 
In Re Jeld-Wen Holding, Inc. Securities Litigation 
Civil Action No. 3:20-cv-00112-JAG 
United States District Court 
Eastern District of Virginia 
Richmond Division 
Deposition Testimony 
January 2021 
Deposition Testimony 
February 2021 
 
 
24
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Exhibit-3 
Steven P. Feinstein, Ph.D., CFA 
Testimony Provided in the Last Four Years 
 
In Re Endo International PLC Securities Litigation 
Case No. 2:17-cv-05114-MMB 
United States District Court 
Eastern District of Pennsylvania 
Deposition Testimony 
July 2021 
 
In Re McKesson Corporation Securities Litigation 
Master File No. 3:18-cv-06525-CRB 
United States District Court 
Northern District of California 
Deposition Testimony 
August 2021 
 
In Re Perrigo Company PLC Securities Litigation 
Master File No. 2:18-cv-02074 
United States District Court 
District of New Jersey 
Deposition Testimony 
October 2021 
 
In Re Wells Fargo & Company Securities Litigation 
Master File No. 3:18-cv-03948-JD 
United States District Court 
Northern District of California 
Deposition Testimony 
November 2021 
 
In Re Microchip Technology, Inc. Securities Litigation 
Case No. 2:18-cv-02914-JJT 
United States District Court 
District of Arizona 
Deposition Testimony 
October 2020 
Deposition Testimony 
January 2022 
 
In Re Super Micro Computer, Inc. Securities Litigation 
Master File No. 4:18-cv-00838-JST 
United States District Court 
Northern District of California 
Deposition Testimony 
January 2022 
 
 
 
25
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Exhibit-3 
Steven P. Feinstein, Ph.D., CFA 
Testimony Provided in the Last Four Years 
 
In Re Cardinal Health, Inc. Securities Litigation 
Master File No. 2:19-cv-03347 
United States District Court 
Southern District of Ohio 
Eastern Division 
Deposition Testimony 
May 2022 
 
In Re Gannett Co., Inc. ERISA Litigation 
Civil Action No. 1:18-cv-00325-AJT-JFA 
United States District Court 
Eastern District of Virginia 
Alexandria Division 
Deposition Testimony 
May 2022 
 
In Re Apple Inc. Securities Litigation 
Case No. 4:19-cv-02033-YGR 
United States District Court 
Northern District of California 
Oakland Division 
Deposition Testimony 
June 2021 
Deposition Testimony 
July 2022 
 
In Re Sealed Air Co., Securities Litigation 
Case No. 1:19-cv-10161-LLS 
United States District Court 
Southern District of New York 
Deposition Testimony 
July 2022 
 
In Re Aegean Marine Petroleum Network, Inc. Securities Litigation 
Case No. 18 Civ. 4993 (NRB) 
United States District Court 
Southern District of New York 
Deposition Testimony 
November 2022 
 
 
 
26
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Case 5:21-cv-04337-JMG     Document 163-15     Filed 05/21/25     Page 29 of 31

Exhibit-3 
Steven P. Feinstein, Ph.D., CFA 
Testimony Provided in the Last Four Years 
 
In Re Synchrony Financial Securities Litigation 
Case No. 3:18-cv-01818-VAB 
United States District Court 
District of Connecticut 
Deposition Testimony 
December 2022 
 
In Re Cabot Oil & Gas Corporation Securities Litigation 
Case No. 4:21-cv-02045 
United States District Court 
Southern District of Texas 
Deposition Testimony 
June 2023 
 
In Re Mallinckrodt Public Limited Company Securities Litigation 
Civil Action No. 20-10100(AET)(TJB) 
United States District Court 
District of New Jersey 
Deposition Testimony 
July 2023 
 
In re Acadia Pharmaceuticals Inc. Securities Litigation 
Case No. 3:21-cv-00762-WQH-MSB 
United States District Court 
Southern District of California 
Deposition Testimony 
October 2023 
 
In re Kirkland Lake Gold Ltd. Securities Litigation 
Case No. 20-cv-04953 
United States District Court 
Southern District of New York 
Deposition Testimony 
March 2023 
Deposition Testimony 
October 2023 
 
In re Vale S.A. Securities Litigation 
Case No. 19-cv-526-RJD-SJB 
United States District Court 
Eastern District of New York 
Deposition Testimony 
March 2021 
Deposition Testimony 
October 2023 
27
Pla Appx 3336
Case 5:21-cv-04337-JMG     Document 163-15     Filed 05/21/25     Page 30 of 31

Exhibit-3 
Steven P. Feinstein, Ph.D., CFA 
Testimony Provided in the Last Four Years 
 
In re Alta Mesa Resources, Inc. 
Case No. 4:19-cv-00957 
United States District Court 
Southern District of Texas 
Houston Division 
Deposition Testimony 
November 2023 
 
In Re Ripple Labs Inc. Litigation 
Case No. 4:18-cv-06753-PJH 
United States District Court 
Northern District of California 
Deposition Testimony 
January 2023 
Deposition Testimony 
December 2023 
 
In Re EQT Corporation Securities Litigation 
Master File No. 2:19-cv-00754-MPK 
United States District Court 
Western District of Pennsylvania 
Deposition Testimony 
May 2021 
Deposition Testimony 
July 2021 
Deposition Testimony 
July 2023 
Deposition Testimony 
March 2024 
 
In Re Valeant Pharmaceuticals International, Inc. Securities Litigation 
Master No. 3:15-cv-07658-MAS-LHG 
United States District Court 
District of New Jersey 
Deposition Testimony 
May 2024 
 
In Re Cassava Sciences, Inc. Securities Litigation 
Master No. 1:21-cv-07751-DAE 
United States District Court 
Western District of Texas 
Austin Division 
Deposition Testimony 
June 2024 
 
28
Pla Appx 3337
Case 5:21-cv-04337-JMG     Document 163-15     Filed 05/21/25     Page 31 of 31

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