Stipulation Requesting Order Changing Time — Gold Club SF, LLC v. Small Business Administration (Dkt. 51, N.D. Cal.)

Summary

This filing is a Stipulation Requesting Order Changing Time under Civil L.R. 6-2(a) in Gold Club SF, LLC, et al. v. Small Business Administration, et al., No. 3:24-cv-04241-LJC (Document 51, N.D. Cal.), dated and filed March 24, 2026. It is signed by Senior Trial Counsel David M. Glass for Defendants and by Zachary M. Youngsma of Shafer & Associates, P.C. for Plaintiffs, whose signature blocks also list Bradley J. Shafer and Douglas J. Melton and Shane M. Cahill of Long & Levitt LLP. The stipulation notes that Plaintiffs moved on March 19, 2026 (ECF No. 50) to preliminarily enjoin enforcement of 13 C.F.R. Ch. 1, Pt. 134, Subpart L governing PPP loan forgiveness appeals before the SBA Office of Hearings and Appeals. Noting no prior extension since ECF No. 45, the parties ask to extend Defendants' opposition deadline from 14 days under Civil L.R. 7-3(a) to 30 days, through April 18, 2026.

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Case 3:24-cv-04241-LJC          Document 51        Filed 03/24/26   Page 1 of 3




     BRETT A. SHUMATE
 1
     Assistant Attorney General
 2   JOSEPH E. BORSON
     Assistant Branch Director
 3   DAVID M. GLASS, DC Bar 544549
     Senior Trial Counsel
 4
     Department of Justice, Civil Division
 5   Federal Programs Branch
     1100 L Street, N.W., Room 12020
 6   Washington, D.C. 20530
 7   Tel: (202) 514-4469
     Email: david.glass@usdoj.gov
 8   Attorneys for Defendants
 9                                UNITED STATES DISTRICT COURT
10                              NOTRHERN DISTRICT OF CALIFORNIA
                                     SAN FRANCISCO DIVISION
11
                                               )               No. 3:24-cv-04241-LJC
12   GOLD CLUB SF, LLC, et al.,                )
13                                             )               STIPULATION REQUESTING
                                   Plaintiffs, )               ORDER CHANGING TIME
14                                             )
                 v.                            )
15                                             )
16   SMALL BUSINESS ADMINISTRATION,            )
     et al.,                                   )
17                                             )
                                   Defendants. )
18
     ____________________________________      )
19
             The parties stipulate as follows pursuant to Civil L.R. 6-2(a):
20
             1. Plaintiffs moved on March 19, 2026, for an order “preliminarily enjoining Defendants
21
22   from enforcing 13 C.F.R. Ch. 1, Pt. 134, Subpart L . . . which govern[s] appeals before the Small

23   Business Administration (‘SBA’) Office of Hearings and Appeals (‘OHA’) relating to Paycheck
24
     Protection Program (‘PPP’) loan forgiveness determinations.” ECF No. 50 at 1.
25
             2. During discussions among counsel that preceded the filing of the above motion,
26
27   defendants’ counsel asked plaintiffs’ counsel: “Would you stipulate to our having 30 days to

28


     No. 3:24-cv-04241-LJC
     Stip. Req. Order Changing Time                                                          1

             Case 3:24-cv-04241-LJC          Document 51         Filed 03/24/26      Page 2 of 3




     respond to any motion for PI you might file.” Declaration of David M. Glass ¶ 5 (quoting email
 1
 2   from Glass to Youngsma (Mar. 17, 2026)).

 3           3. Plaintiffs’ counsel responded: “[Y]es, we’ll agree to 30 days to respond to our motion
 4
     for preliminary injunction.” Id. ¶ 6 (quoting email from Shafer to Glass (Mar. 18, 2026)).
 5
             4. Defendants foresee that they will not have sufficient time to prepare an opposition to
 6
 7   plaintiffs’ motion for preliminary injunction with the care and thoroughness that the opposition

 8   merits if they are required to file the opposition within the 14 days that Civil L.R. 7-3(a)
 9   prescribes for oppositions to motions. Id. ¶ 7.
10
             5. Defendants do not foresee that the resolution of this action will be delayed unduly if
11
     they are given 30 days to file their opposition to plaintiffs’ motion for preliminary injunction
12
13   because no other extension of time has been sought or approved in this action since the Court

14   granted in part and denied in part defendants’ motion to dismiss. Id. ¶ 8 (citing Order (Sept. 30,
15   2025), ECF No. 45, at 1).
16
             6. The parties ask in view of the foregoing that the Court approve the proposed order,
17
     submitted herewith, which provides: “Upon the stipulation requesting an order changing time
18
19   dated on or about March 24, 2026, and good cause having been shown, it is ordered that

20   defendants’ time to file their opposition to plaintiffs’ motion for preliminary injunction, ECF No.
21
     50, be extended through April 18, 2026.”
22
     Dated: March 24, 2026                         BRETT A. SHUMATE
23                                                 Assistant Attorney General
24
                                                   JOSEPH E. BORSON
25                                                 Assistant Branch Director
26
27
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     No. 3:24-cv-04241-LJC
     Stip. Req. Order Changing Time                                                                 2

             Case 3:24-cv-04241-LJC   Document 51      Filed 03/24/26    Page 3 of 3




                                          s/ David M. Glass
 1
                                          DAVID M. GLASS, DC Bar 544549
 2                                        Senior Trial Counsel
                                          Department of Justice, Civil Division
 3                                        Federal Programs Branch
                                          1100 L Street, N.W., Room 12020
 4
                                          Washington, D.C. 20530
 5                                        Tel: (202) 514-4469
                                          Email: david.glass@usdoj.gov
 6                                        Attorneys for Defendants
 7
                                          SHAFER & ASSOCIATES, P.C.
 8
                                          s/ Zachary M. Youngsma
 9                                        Bradley J. Shafer (MI P36604)*
10                                        Zachary M. Youngsma (MI P84148)*
                                          SHAFER & ASSOCIATES, P.C.
11                                        3800 Capital City Blvd., Ste. 2
                                          Lansing, Michigan 48906
12                                        T: 517-886-6560
13                                        F: 517-886-6565
                                          E: Brad@BradShaferLaw.com
14                                        E: Zack@BradShaferLaw.com
15                                        LONG & LEVITT LLP
16
                                          DOUGLAS J. MELTON, Bar No. 161353
17                                        SHANE M. CAHILL, Bar No. 227972
                                          LONG & LEVITT LLP
18
                                          465 California Street, Suite 500
19                                        San Francisco, California 94104
                                          Telephone: (415) 397-2222
20                                        Facsimile:     (415) 397-6392
                                          Email: dmelton@longlevit.com
21
                                                 scahill@longlevit.com
22
                                          Admitted Pro Hac Vice
23
24                                        Attorneys for All Plaintiffs

25
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     No. 3:24-cv-04241-LJC
     Stip. Req. Order Changing Time                                                3

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