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Home Court filings Greathouse v. Capital Plus Financial, LLC Brief in Support of Motion for Class Certification — Greathouse v. Capital Plus (TXND) (N.D. Tex., 2023-01-12)

Court filing

Brief in Support of Motion for Class Certification — Greathouse v. Capital Plus (TXND) (N.D. Tex., 2023-01-12)

Filed January 12, 2023 in Greathouse v. Capital Plus; one of 8 filings from this case.

Record facts

CourtU.S. District Court for the Northern District of Texas, Fort Worth Division
Filed2023-01-12

U.S. District Court for the Northern District of Texas, Fort Worth Division · No. 4:22-cv-00686-P · Doc. 68 · 2023-01-12 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF TEXAS 
FORT WORTH DIVISION 
 
Eric Greathouse, Ernesto Covarrubias, 
Tiffany Sumrall, Barbara Myles, Cori 
Pericho, John Pinkney, Joshua Smith and 
Alicia Mena, individually and on behalf of 
all others similarly situated, 
 
Plaintiffs, 
 
 
v. 
Capital Plus Financial, LLC, Crossroads 
Impact Corp., Eric A. Donnelly and Robert 
H. Alpert,  
Defendants. 
 
 
Case No. 4:22-cv-686-P  
 
 
 
 
 
 
 
 
BRIEF IN SUPPORT OF PLAINTIFFS’  
MOTION FOR CLASS CERTIFICATION 
 
 
Case 4:22-cv-00686-P   Document 68   Filed 01/12/23    Page 1 of 33   PageID 1260
FILED
KAREN MITCHELL
CLERK, U.S. DISTRICT COURT
January 12, 2023

i 
 
Table of Contents 
 
Table of Contents ............................................................................................................................. i 
Table of Authorities ........................................................................................................................ ii 
Table of Abbreviations .................................................................................................................. vi 
Introduction ..................................................................................................................................... 1 
Factual Background ........................................................................................................................ 3 
Legal Standard ................................................................................................................................ 6 
Argument ........................................................................................................................................ 7 
I. 
The Proposed Class and Subclasses are Ascertainable ........................................... 7 
II. 
Plaintiffs Satisfy the Requirements of Rule 23(a) .................................................. 8 
III. 
Plaintiffs Satisfy the Requirements of Rule 23(b)(3) ........................................... 12 
IV. 
Plaintiffs’ Counsel Meet the Requirements of Rule 23(g) .................................... 21 
V. 
Plaintiffs Satisfy the Additional Requirements of Local Rule 23.2. ..................... 22 
Conclusion .................................................................................................................................... 25 
  
 
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Table of Authorities 
 
Page(s) 
Cases 
Advance Trust & Life Escrow Services, LTA v. Security Life of Denver Ins. Co., 
2020 WL 8186476 (D. Colo. Apr. 13, 2020) ...........................................................................18 
Ahmad v. Old Republic Nat’l Title Ins. Co., 
690 F.3d 698 (5th Cir. 2012) .................................................................................................6, 9 
Allapattah Servs., Inc. v. Exxon Corp., 
333 F.3d 1248 (11th Cir. 2003) ...............................................................................................15 
AM International Inc. v. Graphic Management Associates, Inc., 
44 F.3d 572 (7th Cir. 1995) .....................................................................................................17 
Amchem Prods., Inc. v. Windsor, 
521 U.S. 591 (1997) .................................................................................................................12 
Amgen Inc. v. Conn. Ret. Plans & Trust Funds, 
568 U.S. 455 (2013) .............................................................................................................6, 12 
Castano v. Am. Tobacco Co., 
84 F.3d 734 (5th Cir. 1996) .....................................................................................................20 
Cathedral of Hope v. v. FedEx Corp. Servs., Inc., 
2008 WL 2242546 (N.D. Tex. May 30, 2008) ..................................................................15, 16 
Cel-Tech Commc’ns, Inc. v. Los Angeles Cellular Tel. Co., 
973 P.2d 527 (Cal. 1999) .........................................................................................................18 
In re Checking Account Overdraft Litig., 
307 F.R.D. 630 (S.D. Fla. 2015) ..............................................................................................17 
Cleven v. Mid-America Apartment Communities, Inc., 
328 F.R.D. 452 (W.D. Tex. 2018) .............................................................................................7 
Conrad v. Gen. Motors Acceptance Corp., 
283 F.R.D. 326 (N.D. Tex. 2012) ..............................................................................................7 
Cox v. Spirit Airlines, Inc., 
2022 WL 939732 (E.D.N.Y. Mar. 3, 2022) .......................................................................15, 16 
Cruson v. Jackson Nat’l Life Ins. Co., 
954 F.3d 240 (5th Cir. 2020) .............................................................................................14, 15 
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Crutchfield v. Sewerage & Water Bd. of New Orleans, 
829 F.3d 370 (5th Cir. 2016) ...............................................................................................7, 13 
In re Deepwater Horizon, 
732 F.3d 326 (5th Cir. 2013) ...................................................................................................16 
In re Deepwater Horizon, 
739 F.3d 790 (5th Cir. 2014) .....................................................................................................9 
In re Deepwater Horizon, 
785 F.3d 1003 (5th Cir. 2015) .................................................................................................12 
Deposit Guar. Nat. Bank, Jackson, Miss. v. Roper, 
445 U.S. 326 (1980) .................................................................................................................21 
Durrett v. John Deere Co., 
150 F.R.D. 555 (N.D. Tex. 1993) ............................................................................................14 
Ellsworth v. U.S. Bank, N.A., 
2014 WL 2734953 (N.D. Cal. June 13, 2014) .............................................................15, 18, 19 
Feder v. Elec. Data Sys. Corp., 
429 F.3d 125 (5th Cir. 2005) ...................................................................................................11 
In re FirstPlus Fin. Grp., Inc., Sec. Litig., 
2002 WL 31415951 (N.D. Tex. Oct. 28, 2002) .......................................................................13 
Frey v. First Nat’l Bank Sw., 
602 F. App’x 164 (5th Cir. 2015) ............................................................................................12 
In re Heartland Payment Sys., Inc. v. Customer Data Sec. Breach Litig., 
851 F. Supp. 2d 1040 (S.D. Tex. 2012) ...................................................................................11 
James v. City of Dallas, 
254 F.3d 551 (5th Cir. 2001) ...................................................................................................10 
John v. Nat’l Sec. Fire & Cas. Co., 
501 F.3d 443 (5th Cir. 2007) .....................................................................................................6 
King v. Baylor Univ., 
46 F.4th 344 (5th Cir. 2022) ....................................................................................................16 
Longest v. Green Tree Servicing LLC, 
308 F.R.D. 310 (C.D. Cal. 2015) .............................................................................................18 
Lyn-Lea Travel Corp. v. American Airlines, Inc., 
283 F.3d 282 (5th Cir. 2002) .............................................................................................14, 16 
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M.D. v. Perry, 
294 F.R.D. 7 (S.D. Tex. 2013) .................................................................................................10 
M.D. ex rel. Stukenberg v. Perry 
675 F.3d 832 (5th Cir. 2012)  ....................................................................................................9 
Mitchell v. State Farm Fire & Cas. Co., 
954 F.3d 700 (5th Cir. 2020) ...................................................................................................12 
Mullen v. Treasure Chest Casino LLC, 
186 F.3d 620 (5th Cir. 1999) .........................................................................................8, 10, 11 
Overka v. Am. Airlines, Inc., 
265 F.R.D. 14 (D. Mass. 2010) ................................................................................................18 
Page v. State Farm Life Insurance Company, 
584 F. Supp. 3d 200 (W.D. Tex. 2022) ....................................................................................14 
Rikos v. Procter & Gamble Co., 
799 F.3d 497 (6th Cir. 2015) ...................................................................................................19 
Scherer v. Coney, 
2002 WL 31412757, 114 Wash. App. 1014 (Oct. 28, 2002) ...................................................17 
Schwartz v. TXU Corp., 
2005 WL 3148350 (N.D. Tex. Nov. 8, 2005) ..........................................................................13 
Seeligson v. Devon Energy Prod. Co., 
753 F. App’x 225 (5th Cir. 2018) ..............................................................................................7 
Steinberg v. Nationwide Mutual Insurance Co., 
224 F.R.D. 67 (E.D.N.Y. 2004) ...............................................................................................15 
In re TWL Corp., 
712 F.3d 886 (5th Cir. 2013) ...................................................................................................20 
Tyson Foods, Inc. v. Bouaphakeo, 
577 U.S. 442 (2016) .................................................................................................................12 
In re U.S. Foodservice Inc. Pricing Litigation, 
729 F.3d 108 (2d Cir. 2013).....................................................................................................15 
Union Asset Mgmt. Holding A.G. v. Dell, Inc., 
669 F.3d 632 (5th Cir. 2012) .....................................................................................................6 
Vine v. PLS Fin. Servs., Inc., 
807 F. App’x 320 (5th Cir. 2020) ............................................................................................19 
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Wal-Mart Stores, Inc. v. Dukes, 
564 U.S. 338 (2011) ...................................................................................................................6 
Zehentbauer Family Land, LP v. Chesapeake Exploration, L.L.C., 
935 F.3d 496 (6th Cir. 2019) ...................................................................................................15 
Zeidman v. J. Ray McDermott & Co., 
651 F.2d 1030 (5th Cir. Unit A July 1981) ................................................................................8 
Statutes 
28 U.S.C. § 1332(d)(2) ..................................................................................................................23 
CARES Act ..................................................................................................................................1, 3 
Class Action Fairness Act, 28 U.S.C. § 1332(d)(2)(A) .................................................................23 
Other Authorities 
Fed. R. Civ. P. 23 ................................................................................................................... passim 
Fed. R. Civ. P. 26(f) ...................................................................................................................8, 24 
3 L. Cunningham and A. Jacobson, Corbin On Contracts § 542 (1998 Supp.) .............................16 
Local Civil Rule 23.2 ............................................................................................................. passim 
 
 
 
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Table of Abbreviations  
CARES Act:  Coronavirus Aid, Relief and Economic Security Act 
Defendants:  Capital Plus Financial, LLC (“CPF”), Crossroads Impact Corp. 
(“Crossroads”), Eric A. Donnelly (“Donnelly”) and Robert H. Alpert (“Alpert”) 
Loan Documents:  the Note, Additional and Correction Documents Agreement (Errors 
and Omissions Agreement), Business Purpose Statement, Notice - No Oral Agreements, Written 
Consent of Governing Body, IRS W-9 Request for Taxpayer Identification Number and 
Certification, and Information and Bank Account Certification and Authorization form (ECF 
No. 4) 
NCUDTPA:  North Carolina Unfair and Deceptive Trade Practices Act (N.C. Gen. Stat. 
Ann. §§ 75-1.1, et seq.) 
PPP:  Paycheck Protection Program 
PPPLF:  Paycheck Protection Program Liquidity Facility 
Plaintiffs:  Eric Greathouse, Ernesto Covarrubias (“Covarrubias”), Tiffany Sumrall, 
Barbara Myles (“Myles”), Cori Pericho, John Pinkney, Joshua Smith (“Smith”), and Alicia Mena 
SBA:  U.S. Small Business Administration 
SEC:  U.S. Securities and Exchange Commission 
UCC:  Uniform Commercial Code 
UCL:  California Unfair Competition Law (Cal. Bus. & Prof. Code § 17200, et seq.) 
 
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Plaintiffs1 respectfully submit this brief in support of their motion for class certification.  
Introduction 
Following the worldwide outbreak of COVID-19, Congress passed the CARES Act to, 
among other things, provide relief to America’s small businesses and sole proprietors through the 
creation of the PPP. Administered by the SBA, the PPP was established to provide forgivable 
loans to businesses and sole proprietors in a quick and efficient manner using standard form loan 
agreement documents such as the Loan Documents that Plaintiffs and other PPP borrowers 
entered into with CPF. To ensure that businesses and sole proprietors received PPP loan 
proceeds quickly, the applicable provisions of the PPP required lenders to fund PPP loans within 
ten days of SBA approval. Lenders that participated in the Program were entitled to be paid fees 
by the SBA for each PPP loan they actually funded. Defendant CPF was one of the SBA’s 
authorized PPP lenders, and reportedly committed to fund 472,036 PPP loans in 2021 totaling 
over $7.5 billion, all or the bulk of which CPF obtained from the Federal Reserve’s PPPLF to 
fund those loans. 
In disregard of its obligations to Plaintiffs and the other class member borrowers, 
however, CPF failed to fund those borrowers’ SBA-approved PPP loans. Although the parties 
dispute whether the Loan Documents are binding contracts (see ECF No. 37 at 20-21; ECF 43 at 
21-22), it is indisputable both that the Loan Documents are standardized and indeed identical in 
substance across the class, and that resolution of Defendants’ enforceability defense raises 
factual and legal issues that by definition turn on common evidence. Defendants also cannot 
reasonably dispute that governing PPP regulations required PPP loan funding, CPF’s obligation 
 
1  
Unless otherwise noted, all paragraph citations are to Plaintiffs’ Class Action Complaint 
(ECF No. 1); all emphasis is added; all page cites to ECF filings are to the ECF, rather than 
native, page number; and all internal quotations and citations are omitted. 
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to use advances it obtained from the PPPLF to actually fund PPP loans, CPF’s obligation to be 
paid loan processing fees by the SBA only on funded loans, and CPF’s duty to report accurately 
to the SBA regarding PPP loan funding and lending.  
Because the claims of Plaintiffs and other SBA-approved but unfunded PPP borrowers 
share the same core factual and legal issues and a class action is the only practical way for 
Plaintiffs and the class to have any opportunity to obtain relief given the relative size of their 
individual claims, this case is ideal for class certification. Accordingly, Plaintiffs seek 
certification of the following national class and two subclasses (collectively, the “Classes”) 
pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3):  
National Class: All persons and entities in the United States and its 
territories Guam, Northern Mariana Islands, Puerto Rico and U.S. Virgin 
Islands who, in 2021, applied for PPP loans with defendant CPF as the 
lender for whom the SBA provided an SBA loan number, and who 
executed and submitted their Loan Documents but did not receive the PPP 
loan proceeds. 
 
Plaintiffs Covarrubias and Smith seek certification of the following California Subclass: 
California Subclass: All persons and entities in California who, in 2021, 
applied for PPP loans with defendant CPF as the lender for whom the 
SBA provided an SBA loan number, and who executed and submitted 
their Loan Documents but did not receive the PPP loan proceeds. 
 
Plaintiff Myles seeks certification of the following North Carolina Subclass:  
North Carolina Subclass: All persons and entities in North Carolina 
who, in 2021, applied for PPP loans with defendant CPF as the lender for 
whom the SBA provided an SBA loan number, and who executed and 
submitted their Loan Documents but did not receive the PPP loan 
proceeds. 
 
In further support of Plaintiffs’ motion for class certification, Plaintiffs are also 
contemporaneously filing and incorporate here an Appendix containing the parties’ standard 
form Loan Documents (Tab 1; accord ECF No. 4); the experts reports of Jason D. Koontz, CRC 
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(Tab 2) (the “Koontz Report”), William Manger (Tab 3) (the “Manger Report”), Steven P. 
Feinstein, Ph.D., CFA (Tab 4) (the “Feinstein Report”), and William Briggs (Tab 5) (the “Briggs 
Report”); Plaintiffs’ proposed trial plan (Tab 6) (the “Proposed Trial Plan”); the declaration of 
Lawrence J. Lederer (Tab 7) (the “Lederer Decl.”); declarations of Plaintiffs (Tab 8); firm 
resumes of Kendall Law Group, PLLC (Tab 9), Bailey & Glasser, LLP (Tab 10), Nolan Heller 
Kauffman LLP (Tab 11), and Friday, Eldredge & Clark, LLP (Tab 12); and charts identifying 
and comparing the elements of Plaintiffs’ contract claims (Tab 13) and unjust enrichment claims 
(Tab 14) in all jurisdictions encompassed within the proposed National Class. 
Factual Background 
As proprietors of insurance, auto repair, landscape, art, delivery, cable and housecleaning 
businesses (¶¶ 17-24), Plaintiffs are among those that a widely bipartisan Congress intended the 
CARES Act and the PPP to assist. ¶ 40. Defendant Crossroads is a publicly traded company; its 
wholly owned subsidiary CPF is a CDFI which is supposed “to serve low-income people and 
underserved communities lacking adequate access to affordable financial products and services” 
(https://home.treasury.gov/news/press-releases/jy0359) (last visited Dec. 18, 2022); and 
Donnelly and Alpert were at all times their two direct or indirect controlling shareholders.  
Plaintiffs were approved by the SBA for PPP loans ranging from $3,750 (¶ 203) to 
$20,832 (¶¶ 167, 181); entered into and are bound by the standard form Loan Documents (see 
App’x Tab 1 (attaching the Loan Documents)) with CPF (¶¶ 117, 131, 146, 157, 169, 181, 193, 
205); never received any PPP loans (¶ 12); and remain bound to pay back to CPF those loans 
with interest and unable to obtain or even properly apply for forgiveness. ¶¶ 55, 60-61, 232; 
App’x Tab 1 at 3. Plaintiffs failed to receive their PPP loans despite Defendants’ knowledge that 
CPF failed to fund SBA-approved PPP loans (¶ 106), and numerous additional follow-up 
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attempts by several Plaintiffs to actually get funded. See, e.g., ¶¶ 119-21, 133-37, 147-48, 158-
59, 207-08. 
For their respective roles, CPF as the SBA-authorized PPP lender obtained over $6.4 
billion or $7.5 billion in cash from the Federal Reserve’s PPPLF secured by, and to be used to 
fund, Plaintiffs’ eight and 472,028 other PPP loans (¶¶ 9, 87, 98-99, 104-05); falsely reported to 
the SBA it had funded them (¶ 100); was paid by the SBA $930 million in PPP loan fees and 
expects $1.1 billion in such fees (¶¶ 77-78); upstreamed to Crossroads all those fees; Crossroads 
reported in SEC filings that it obtained the $930 million “windfall” from PPP lending which 
increased its revenues 2,446% to $932.7 million in FY 2021 compared to $36.6 million in FY 
2020 (¶¶ 76, 82, 89); and Crossroads in turn, just weeks after the new applicant PPP lending 
window closed on May 31, 2021, declared and in July 2021 paid a special dividend to its 
shareholders in which it paid over $149.9 million in cash to Donnelly and Alpert personally. 
¶¶ 11, 14-15, 76, 81-84. See App’x Tab 4 Feinstein Report ¶ 21 (discussing special dividend). 
At the time the special dividend was declared and paid, Donnelly (at 37.8%) and Alpert 
(at 25%) owned a controlling equity stake in Crossroads. ¶ 80. In addition at all relevant times, 
Donnelly was also the dual CEO of both Crossroads and CPF; CPF was wholly owned by 
Crossroads (¶¶ 7, 80-81); and Donnelly, Alpert and other corporate insiders, including Farzana 
Giga (“Giga”), who simultaneously serves as CPF’s and Crossroads’s dual CFO, signed the Loan 
Documents for CPF, and also as a Crossroads shareholder participated in the special dividend, 
owned approximately 66% of Crossroads’s equity. ¶¶ 7, 80, 84, 91, 93. In addition to the over 
$149.9 million in cash that Donnelly and Alpert were paid by the special dividend, including off 
the backs of Plaintiffs’ and other unfunded borrowers’ PPP loans, Donnelly and Giga also 
received over $8.8 million each in cash bonuses in 2021. ¶ 15.   
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Crossroads recently disclosed that its “outstanding advances on the PPPLF at July 31, 
2022 was $1,260,012,462” and that CPF’s PPP lending is the subject of government 
investigations. See https://crossroads.com/wp-content/uploads/2022/09/Q3-2022-OTC-
Disclosure-Statement-FINAL_091222.pdf Item 5 at p. 10 and note 12 at p.27 (last visited 
Dec. 29, 2022); see also 2022_Q4 OTC Financial Statement Workbook - Release 
(crossroads.com) at 1 (PPPLF advance was $1,108,965,758 at Oct. 31, 2022) (last visited 
Dec. 19, 2022).   
More recently, the U.S. Congressional House Select Subcommittee on the Coronavirus 
Crisis issued on December 1, 2022 its staff report “How Fintechs Facilitated Fraud in the 
Paycheck Protection Program” which contains findings regarding CPF’s and Crossroads’s PPP 
lending activities. See 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2022.12.01%20How%
20Fintechs%20Facilitated%20Fraud%20in%20the%20Paycheck%20Protection%20Program_0.p
df (link to Congressional report) (last visited Dec. 9, 2022).  
Similarly, on December 8, 2022, the SBA issued a press release stating that the House 
Select Subcommittee report “details serious problems of fraud and self-dealing by lenders” and 
that the SBA has “launched a full investigation of the lenders” including defendant “Capital 
Plus” to “ensure that federal financial regulators have a coordinated response to wrongdoing by 
lenders.” See https://www.sba.gov/article/2022/dec/08/us-small-business-administration-
statement-house-select-subcommittee-coronavirus-crisis-report (link to SBA press release) (last 
visited Dec. 9, 2022).  
These facts are based largely on indisputable, publicly available information and 
Crossroads’s own SEC filings and Donnelly’s and Alpert’s other public statements. Based on 
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CPF’s false reporting, SBA data identifies Plaintiffs’ loans as “disbursed” even though the loans 
were not, and Plaintiffs nevertheless remain bound to pay back to CPF those loan proceeds with 
interest. ¶¶ 12, 122-23, 138-39, 149-50, 160-61, 172-73, 184-85, 196-97, 210-11.   
Legal Standard 
“[T]o maintain a class action, the class sought to be represented must be adequately 
defined and clearly ascertainable.” Union Asset Mgmt. Holding A.G. v. Dell, Inc., 669 F.3d 632, 
638 (5th Cir. 2012). This requirement is an “implied prerequisite” of Rule 23. John v. Nat’l Sec. 
Fire & Cas. Co., 501 F.3d 443, 445 (5th Cir. 2007).  
Where as here class members are ascertainable, Plaintiffs must also demonstrate that the 
proposed Classes comply with Federal Rule of Civil Procedure 23(a)’s requirements of 
numerosity, commonality, typicality, and adequacy of representation and, as applicable here, 
Rule 23(b)(3), “which requires that questions of law or fact common to the class predominate 
over questions affecting only individual members, and that a class action is superior to other 
available methods for the fair and efficient adjudication of the controversy.” Ahmad v. Old 
Republic Nat’l Title Ins. Co., 690 F.3d 698, 702 (5th Cir. 2012) (citing Fed. R. Civ. P. 23(b)).   
The trial court must conduct a “rigorous analysis” of the Rule 23 requirements before 
certifying a class. Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350-51 (2011). That analysis 
may “overlap” with analysis of the merits of a plaintiff’s claims, id. at 351, but “Rule 23 grants 
courts no license to engage in free-ranging merits inquiries at the certification stage.” Amgen Inc. 
v. Conn. Ret. Plans & Trust Funds, 568 U.S. 455, 466 (2013). Merits questions may be 
considered only to the extent that they are relevant to certification. Id. 
“At bottom, the [predominance] inquiry requires the trial court to weigh common issues 
against individual ones and determine which category is likely to be the focus of a trial.” 
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Crutchfield v. Sewerage & Water Bd. of New Orleans, 829 F.3d 370, 376 (5th Cir. 2016). See 
also App’x Tab 6 (attaching Plaintiffs’ Proposed Trial Plan and identifying classwide evidence).  
Argument 
I. 
The Proposed Class and Subclasses are Ascertainable 
 
“An identifiable class exists if its members can be ascertained by reference to objective 
criteria.” Manual for Complex Litigation (Fourth) § 21.222 (2004); see also Cleven v. Mid-
America Apartment Communities, Inc., 328 F.R.D. 452, 467 (W.D. Tex. 2018); Conrad v. Gen. 
Motors Acceptance Corp., 283 F.R.D. 326, 328 (N.D. Tex. 2012). “[T]he court need not know 
the identity of each class member before certification; ascertainability requires only that the court 
be able to identify class members at some stage of the proceeding.” Seeligson v. Devon Energy 
Prod. Co., 753 F. App’x 225, 230 (5th Cir. 2018) (quoting Frey v. First Nat’l Bank Sw., 602 F. 
App’x 164, 168 (5th Cir. 2015) (citing William B. Rubenstein, Newberg on Class Actions § 3:3 
(5th ed. 2011)). 
Class members will be readily ascertainable upon Defendants’ production of discovery. 
CPF’s record-keeping responsibilities as a PPP lender are clear and likewise indisputable and 
detailed in part in an SBA Procedural Notice dated July 15, 2021. See 
https://www.sba.gov/sites/default/files/2021-07/Procedural%20Notice%20 5000-
812316%20PPP%20Guaranty%20Purchase%20%26%20 Charge%20Off%20Servicing%20 
7.15.21-508.pdf (last visited Dec. 12, 2022). That Notice states that PPP lenders are required to 
“[k]eep an accurate record under its direct control of each loan” and “submit separate monthly 
SBA Form 1502 reports that include loan status information for their PPP loans … until the loan 
is paid in full [or] fully forgiven.” Id., at 1-2. Accord App’x Tab 3 Manger Report ¶ 19. Those 
records will identify any CPF PPP loans that were approved by the SBA but not disbursed. 
Accordingly, the members of the Classes are ascertainable. 
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II. 
Plaintiffs Satisfy the Requirements of Rule 23(a) 
 
Numerosity: Rule 23(a)(1) requires that a class be “so numerous that joinder of all 
members is impracticable.” The Fifth Circuit has stated “that any class consisting of more than 
forty members ‘should raise a presumption that joinder is impracticable.’” Mullen v. Treasure 
Chest Casino LLC, 186 F.3d 620, 624 (5th Cir. 1999) (quoting 1 Newberg on Class Actions § 
3.05, at 3–25 (3d ed.1992)). The key question is “whether joinder of all members is practicable 
in view of the numerosity of the class and all other relevant factors.” Zeidman v. J. Ray 
McDermott & Co., 651 F.2d 1030, 1038 (5th Cir. Unit A July 1981). Those other factors may 
include the class’s “geographical dispersion,” the “ease with which class members may be 
identified,” and the “the nature of the action.” Id. 
Plaintiffs are mindful of Local Civil Rule 23.2(b)(1)’s requirement that they identify the 
approximate number of class members. Following the Court’s denial of Defendants’ motion to 
stay discovery on December 13, 2022 (ECF No. 47), Plaintiffs have already sought to confer 
under Fed. R. Civ. P. 26(f) and served Defendants with discovery, including discovery directed 
specifically at numerosity. Given the timeframe in which Defendants have effectively stalled any 
discovery to date, however, Plaintiffs have been unable thus far to obtain any information from 
Defendants regarding the size of the Classes or the status of the PPPLF advances CPF obtained 
on class members’ unfunded loans, among other things. Accordingly, Plaintiffs intend to file 
supplemental submissions concerning numerosity or an amended motion for class certification 
following discovery as the Court may direct or permit. Accord App’x Tab 7 Lederer Decl. ¶ 3.  
Despite Defendants’ refusal to date to produce any discovery, Plaintiffs already number 
eight; others similarly situated continue to contact Plaintiffs’ counsel and seek to be added; and 
publicly available information already indicates the existence of several other putative class 
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members. See ¶ 214(a)-(h). Plaintiffs submit that discovery will likely add many additional class 
member borrowers for each of the three Classes and exceed the relatively low figure that suffices 
to establish numerosity. And, as CPF contracted with PPP borrowers nationwide and in four U.S. 
territories, the members of the National Class are geographically dispersed. 
Commonality: Rule 23(a)(2) requires that “there are questions of law or fact common to 
the class.” That requirement entails “merely a single common contention that enables the class 
action ‘to generate common answers apt to drive the resolution of the litigation.’” In re 
Deepwater Horizon, 739 F.3d 790, 811 (5th Cir. 2014) (quoting M.D. ex rel. Stukenberg v. 
Perry, 675 F.3d 832, 840 (5th Cir. 2012)) (emphasis in original). Plaintiffs’ claims “‘must 
depend on a common contention,’ and the common contention ‘must be of such a nature that it is 
capable of classwide resolution — which means that the determination of its truth or falsity will 
resolve an issue that is central to the validity of each one of the claims in one stroke.”’ Ahmad, 
690 F.3d at 702 (quoting Dukes, 564 U.S. at 350)). 
Plaintiffs’ claim that CPF breached all class members’ standard form Loan Documents 
itself suffices to establish commonality. Here, however, the claims raise additional common 
questions that all class members share including, among others: whether CPF and Crossroads 
procured fees and PPPLF funds for PPP loans that CPF did not make; whether Crossroads 
controlled CPF; whether Crossroads and CPF were, in the alternative in view of Defendants’ 
position that Loan Documents are not enforceable, unjustly enriched by virtue of procuring the 
fees and funds that resulted from their false submissions to the SBA regarding class member 
loans; and whether Donnelly and Alpert were likewise and independently unjustly enriched by 
directing and controlling CPF’s PPP lending and also allocating to themselves substantial 
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10 
portions of those fees. See App’x Tab 5 Briggs Report (discussing PPP context); App’x Tab 3 
Manger Report ¶¶ 12-13 (same). 
Typicality: Rule 23(a)(3) requires that “the claims or defenses of the representative 
parties are typical of the claims or defenses of the class.” “[T]he test for typicality is not 
demanding.” Mullen, 186 F.3d at 625. “Typicality does not require a complete identity of 
claims.” James v. City of Dallas, 254 F.3d 551, 571 (5th Cir. 2001), abrogated on other grounds 
by Stukenberg, 675 F.3d at 839-41. In analyzing typicality, “the critical inquiry is whether the 
class representative’s claims have the same essential characteristics of those of the putative class. 
If the claims arise from a similar course of conduct and share the same legal theory, factual 
differences will not defeat typicality.” Id. (quoting Moore’s Federal Practice § 23.24[4] (3d ed. 
2000)). Often, once a party satisfies the commonality requirement, satisfying typicality “will 
follow as a matter of course.” M.D. v. Perry, 294 F.R.D. 7, 29 (S.D. Tex. 2013). 
Plaintiffs’ claims in this case are not only typical of the claims of the Classes -- they are 
in substance identical to those claims. Every class member signed and is governed by an 
identical package of Loan Documents and subject to identical PPP regulations. Virtually all 
relevant issues regarding the claims and defenses turn on Defendants’ conduct that is largely 
identical as to all class members. Plaintiffs’ typicality cannot credibly be disputed. 
Adequacy: Rule 23(a)(4) requires that “the representative parties will fairly and 
adequately protect the interests of the class.” In determining adequacy of representation, the 
Court considers (1) the willingness and ability of the representatives to take an active role in the 
litigation and to protect the interests of class members they seek to represent and (2) the 
enthusiasm and competence of the proposed class counsel. See Feder v. Elec. Data Sys. Corp., 
429 F.3d 125, 130 (5th Cir. 2005).  
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The first inquiry turns principally on whether there exist any “intraclass conflicts” 
between the class representatives and others in the class. In re Heartland Payment Sys., Inc. v. 
Customer Data Sec. Breach Litig., 851 F. Supp. 2d 1040, 1056 (S.D. Tex. 2012). “Differences 
between named plaintiffs and class members render the named plaintiffs inadequate 
representatives only if those differences create conflicts between the named plaintiffs’ interests 
and the class members’ interests.” Mullen, 186 F.3d at 625–26. Although courts evaluating 
adequacy should consider class representatives’ “willingness and ability ... to take an active role 
in and control the litigation,” the representatives “need not be legal scholars and are entitled to 
rely on [class] counsel.” Feder, 429 F.3d at 130-132 n.4.   
Plaintiffs are adequate class representatives because their interests in prosecuting their 
claims are wholly aligned with the interests of the members of the Classes. Plaintiffs have all 
sought to obtain PPP loans and are well-versed as to their obligations in prosecuting this case and 
protecting the interests of the Classes in conjunction with counsel. See App’x Tab 8 (attaching 
Plaintiffs’ declarations). Each proposed representative entered into the parties’ Loan Documents 
(App’x Tab 1), many made additional follow-up attempts to obtain funding (¶¶ 119-21, 133-37, 
147-48, 158-59, 207-08), and all will be prepared to testify at depositions and at trial as their 
accompanying declarations attest. See App’x Tab 8 ¶ 5; accord App’x Tab 6.   
Plaintiffs’ counsel from Kendall Law Group, PLLC, Bailey & Glasser LLP, Nolan Heller 
Kauffman LLP, and Friday, Eldredge & Clark, LLP combine to have extensive experience 
litigating complex and class action cases and cases involving financial institutions. See App’x. 
Tabs 9-12 (attaching Plaintiffs’ counsels’ resumes). As reflected in their resumes and discussed 
in greater detail in § IV below, Plaintiffs’ counsel are knowledgeable and practiced attorneys 
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with a history of zealous advocacy on behalf of their clients. Plaintiffs satisfy Rule 23(a)(4)’s 
adequacy requirement. 
III. 
Plaintiffs Satisfy the Requirements of Rule 23(b)(3) 
Common Questions Predominate:  Rule 23(b)(3) requires that “questions of law or fact 
common to class members predominate over any questions affecting only individual members.” 
The standard requires that the proposed class be “sufficiently cohesive to warrant adjudication by 
representation.” Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 623 (1997). “In order to 
‘predominate,’ common issues must constitute a significant part of the individual cases.” Frey, 
602 F. App’x at 170. “When ‘one or more of the central issues in the action are common to the 
class and can be said to predominate, the action may be considered proper under Rule 23(b)(3) 
even though other important matters will have to be tried separately, such as damages or some 
affirmative defenses peculiar to some individual class members.’” Tyson Foods, Inc. v. 
Bouaphakeo, 577 U.S. 442, 453–54 (2016) (quoting 7AA C. Wright, A. Miller, & M. Kane, 
Federal Practice and Procedure § 1778, pp. 123–124 (3d ed. 2005)). 
Plaintiffs need not show they will prevail on predominantly common issues, but only that 
they can offer common evidence to prove their claims. Amgen, 568 U.S. at 459 (2013). It is 
enough if common issues predominate in the case as a whole; proof of each element need not be 
predominantly common. Id. at 469 (“Rule 23(b)(3) … does not require a plaintiff seeking class 
certification to prove that each element of her claim is susceptible to classwide proof.” (emphasis 
in original)). Likewise, the necessity of individualized damages calculations are not a bar to class 
certification where, as in this case, common questions overwhelmingly predominate as to fact 
and liability issues. Mitchell v. State Farm Fire & Cas. Co., 954 F.3d 700, 710–11 (5th Cir. 
2020); In re Deepwater Horizon, 785 F.3d 1003, 1017 (5th Cir. 2015). 
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Common issues predominate in cases, including this case, where defendants’ 
“misconduct affected the members of the Class in the same manner.” Schwartz v. TXU Corp., 
2005 WL 3148350, at *15 (N.D. Tex. Nov. 8, 2005). See also In re FirstPlus Fin. Grp., Inc., 
Sec. Litig., 2002 WL 31415951, at *4 (N.D. Tex. Oct. 28, 2002). Common issues arising from 
Defendants’ alleged misconduct will overwhelmingly “be the focus” at trial, Crutchfield, 829 
F.3d at 376, and include at least the following: 
• 
whether CFP had and breached its duty under the Loan Documents to fund 
Plaintiffs’ and class members’ SBA-approved loans; 
 
• 
whether CPF’s failure to fund these PPP loans also violated the SBA’s funding 
rule and CPF’s obligations to obtain and use advances it obtained from the PPPLF 
to fund PPP loans, be paid SBA fees only on funded loans, and report accurately 
to the SBA regarding PPP loan funding and PPP lending;  
 
• 
whether each Defendant procured fees for PPP loans that CPF did not make; 
 
• 
whether Crossroads controlled CPF; 
 
• 
whether Donnelly and Alpert controlled Crossroads and CPF;  
 
• 
whether and, if so, how Plaintiffs and class members suffered damages as a result 
of Defendants’ alleged misconduct and the proper measure of relief;  
 
• 
whether Crossroads and CPF were in the alternative, to the extent that Plaintiffs’ 
breach of contract claims fail to provide adequate relief given Defendants’ 
argument there is no enforceable contract (see ¶ 252), unjustly enriched from PPP 
loan fees and other income on class members’ PPP loans;  
 
• 
whether Donnelly and Alpert were likewise unjustly enriched by allocating to 
themselves substantial portions of those fees and other income; 
 
• 
as to the California Subclass, whether Defendants’ misconduct violated the UCL 
again only in the alternative, to the extent that Plaintiffs’ contract claims fail to 
provide adequate relief to the members of the California Subclass (see ¶ 288); and  
 
• 
as to the North Carolina Subclass, whether Defendants’ misconduct violated the 
NCUDTPA. 
 
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Further, and as discussed more fully in Plaintiffs’ Proposed Trial Plan, the evidence 
Plaintiffs intend to use to prove their claims at trial will also apply classwide, including 
predominantly the Loan Documents and governing PPP regulations themselves. Common issues 
likewise predominate with respect to even class members’ damages. As Professor Feinstein 
concludes, “[d]amages in this matter can be computed in a straightforward manner for all Class 
members using a common methodology consistent with Plaintiffs’ theory of liability.” App’x 
Tab 4 Feinstein Report ¶ 16. 
The fact that all class members signed identical Loan Document contracts (App’x Tab 1) 
and otherwise had little contact with CPF prior to CPF’s breaching those contracts establishes 
predominant issues central to the case. Accord App’x Tab 2 Koontz Report § 5 (discussing the 
Loan Documents); App’x Tab 5 Briggs Report (discussing PPP context); App’x Tab 3 Manger 
Report ¶¶ 16-22 (accord).  
Breach of contract cases “often lend themselves to class treatment.” Cruson v. Jackson 
Nat’l Life Ins. Co., 954 F.3d 240, 255 (5th Cir. 2020) (citing Sacred Heart Health Sys., Inc. v. 
Humana Military Healthcare Servs., Inc., 601 F.3d 1159, 1171 (11th Cir. 2010) (“It is the form 
contract, executed under like conditions by all class members, that best facilitates class 
treatment.”)). See also Page v. State Farm Life Insurance Company, 584 F. Supp. 3d 200, 221 
(W.D. Tex. 2022) (finding predominance where members signed “standardized form contract, 
not subject to individual negotiation”); Durrett v. John Deere Co., 150 F.R.D. 555, 560 (N.D. 
Tex. 1993) (finding predominance where claims arose from “similar if not identical contracts.”). 
The fact that National Class members reside in fifty states and four U.S. territories is no 
impediment to class certification because the alleged misconduct here is actionable under the 
laws of all such jurisdictions. As the Fifth Circuit stated in Lyn-Lea Travel Corp. v. American 
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Airlines, Inc., 283 F.3d 282, 290 (5th Cir. 2002), “[t]he [Supreme] Court reasoned in [American 
Airlines, Inc. v.] Wolens[, 513 U.S. 219, 233 n.8 (1995),] that because contract law is, at its 
‘core,’ uniform and non-diverse, there is little risk of inconsistent state adjudication of 
contractual obligations.” See also Cathedral of Hope v. v. FedEx Corp. Servs., Inc., 2008 WL 
2242546, at * 5 (N.D. Tex. May 30, 2008) (citing Lyn-Lea, Wolens). Courts have repeatedly 
certified nationwide contract classes on that basis. See, e.g., Zehentbauer Family Land, LP v. 
Chesapeake Exploration, L.L.C., 935 F.3d 496, 506 (6th Cir. 2019) (citing Smilow v. Sw. Bell 
Mobile Sys., 323 F.3d 32, 42 (1st Cir. 2003)); In re U.S. Foodservice Inc. Pricing Litigation, 729 
F.3d 108, 127 (2d Cir. 2013) (citing Wolens); Allapattah Servs., Inc. v. Exxon Corp., 333 F.3d 
1248, 1261 (11th Cir. 2003); Ellsworth v. U.S. Bank, N.A., 2014 WL 2734953, at *22 (N.D. Cal. 
June 13, 2014); Cox v. Spirit Airlines, Inc., 2022 WL 939732, at *17 (E.D.N.Y. Mar. 3, 2022) 
(“The Second Circuit has also explained, in the context of breach-of-contract claims, that ‘state 
contract law defines breach consistently such that the question will usually be the same in all 
jurisdictions.’”). 
That said, Plaintiffs are also aware that, as the Fifth Circuit held in Cruson, “[t]he party 
seeking certification of a nationwide class must therefore provide an extensive analysis of state 
law variations to reveal whether these pose insuperable obstacles. And the district court must 
then consider how variations in state law affect predominance.” Id., 954 F.3d at 254-55 (cleaned 
up). The Fifth Circuit in Cruson also held that Steinberg v. Nationwide Mutual Insurance Co., 
224 F.R.D. 67, 76 (E.D.N.Y. 2004), reflected a sufficiently “rigorous predominance analysis.” 
Cruson, 954 F.3d at 255-56.  
Accordingly, and in view of Cruson, Plaintiffs’ counsel have prepared charts reflecting 
that, if proven as alleged, Defendants’ underlying misconduct would similarly violate the 
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contract law of all jurisdictions encompassed within the National Class, and that any variations 
in those laws would not come close to defeating Plaintiffs’ showing that common issues of proof 
will overwhelmingly predominate at trial. See App’x Tab 13. Accord App’x Tab 6. In sum, and 
as in Lyn-Lea, Cathedral of Hope, Cox and other cases, the contract claims here are consistent 
across all jurisdictions within the National Class.    
To determine whether CPF has breached its form contracts, the Court should consider 
whether the Loan Documents and applicable PPP regulations are unambiguous and, if so, 
interpret the unambiguous language. See, e.g., King v. Baylor Univ., 46 F.4th 344, 362 (5th Cir. 
2022) (“Whether a contract is ambiguous is a question of law.”); In re Deepwater Horizon, 732 
F.3d 326, 345 (5th Cir. 2013) (“Contract interpretation … is a question of law.”). For this 
purpose, the vast majority of states, including Texas, follow what is known as the “Four 
Corners” or “Plain Meaning” rule, whereby the Court must determine whether the contract is 
unambiguous based on the “four corners” of the contract and, if it is, then the language of the 
contract should be applied as written, as the best representation of the parties’ intent. See App’x 
Tab 13 (identifying 44 states and the District of Columbia which have adopted this standard of 
interpretation). Thus, for these jurisdictions, the Court should evaluate the “four corners” of the 
parties’ Loan Documents and the applicable PPP regulations incorporated therein to determine 
whether CPF was bound to actually fund class members’ SBA-approved PPP loans. 
In contrast, the six remaining states allow for the admission of narrowly limited extrinsic 
evidence to interpret a contract to determine whether an ambiguity exists, following an exception 
recognized by Professor Corbin. See App’x Tab 13. Professor Corbin explained that “[t]he 
emphasis on discovery of the intentions of the parties through an examination of the objective 
indicia of those intentions is the approach endorsed by this treatise.” 3 L. Cunningham and A. 
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Jacobson, Corbin On Contracts § 542 at 98 (1998 Supp.). In reaching this conclusion, Corbin 
cited with approval Judge Posner’s analysis in AM International Inc. v. Graphic Management 
Associates, Inc., 44 F.3d 572 (7th Cir. 1995), drawing a sharp distinction between “objective” 
and “subjective” extrinsic evidence in this context. Judge Posner explained that when extrinsic 
evidence might be admissible for purposes of determining the meaning of a contract, such 
evidence was limited as to type and scope: 
By “objective” evidence we mean evidence of ambiguity that can be 
supplied by disinterested third parties: evidence that there was more than 
one ship called Peerless, or that a particular trade uses “cotton” in a 
nonstandard sense. The ability of one of the contracting parties to “fake” 
such evidence, and fool a judge or a jury, is limited. By “subjective” 
evidence we mean the testimony of the parties themselves as to what they 
believe the contract means. Such testimony is invariably self-serving, 
being made by a party to the lawsuit, and is inherently difficult to verify. 
“Objective” evidence is admissible to demonstrate that apparently clear 
contract language means something different from what it seems to mean; 
“subjective” evidence is inadmissible for this purpose. 
 
Id. at 575. See also Scherer v. Coney, 2002 WL 31412757, at *4, 114 Wash. App. 1014 (Oct. 28, 
2002) (“When considering the circumstances leading up to and surrounding a writing, a court 
examines the parties’ objective manifestations, but not their ‘unilateral or subjective purposes 
and intentions about the meanings of what is written.’”). Accordingly, even in the unlikely event 
that admissible (i.e., objective) evidence could have any bearing on the Court’s ambiguity 
analysis regarding whether, taken together, the Loan Documents and PPP regulations required 
CPF to actually fund the class member SBA-approved loans, that evidence also would be 
common as to those class members. 
 
The same applies with respect to Plaintiffs’ unjust enrichment claims. “There is general 
agreement among courts that the ‘minor variations in the elements of unjust enrichment under 
the laws of the various states ... are not material and do not create an actual conflict.’” In re 
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Checking Account Overdraft Litig., 307 F.R.D. 630, 647 (S.D. Fla. 2015). See also Overka v. 
Am. Airlines, Inc., 265 F.R.D. 14, 21 (D. Mass. 2010) (“there are only a few differences in the 
description of unjust enrichment claims as between states”). Accord App’x Tab 14 (analyzing 
unjust enrichment laws of National Class); App’x Tab 6 (identifying evidence Plaintiffs intend to 
use to prove their unjust enrichment claims classwide).  
 
That said, if the Court determines that it requires additional analyses of variations among 
the laws of applicable jurisdictions for the National Class under the applicable Fifth Circuit 
standards, Plaintiffs respectfully request leave to file supplemental submissions or an amended 
motion for class certification to allow for that additional analysis. See Advance Trust & Life 
Escrow Services, LTA v. Security Life of Denver Ins. Co., 2020 WL 8186476, at *7 (D. Colo. 
Apr. 13, 2020). 
 
Plaintiffs’ two subclasses present no such issues, as they are limited to residents of single 
states. Specifically, Defendants’ violation of the UCL’s “unlawful” prong is premised on CPF’s 
violations of the SBA’s funding rule, to use advances from the PPPLF to fund PPP loans, to be 
paid loan processing fees only on funded loans, and to report accurately to the SBA regarding 
PPP lending. Defendants’ acts were also “unfair” under the UCL for violating the “legislatively 
declared policy” embodied in the PPP. See Cel-Tech Commc’ns, Inc. v. Los Angeles Cellular Tel. 
Co., 973 P.2d 527, 544 (Cal. 1999). See also Longest v. Green Tree Servicing LLC, 308 F.R.D. 
310, 331 (C.D. Cal. 2015) (“The Court agrees with other courts to confront this issue that 
whether a practice is unfair in the context of legislative policy [is a] question[] capable of 
classwide resolution.”); Ellsworth v. U.S. Bank, N.A., 2014 WL 2734953, at *28 (N.D. Cal. 
June 13, 2014) (accord). 
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Plaintiff Myles’s NCUDTPA claim -- which is grounded in CPF’s inducing the North 
Carolina Subclass to sign the Loan Documents without intending to perform (¶ 296) -- is 
likewise governed by the same in-state law. Nor does reliance on CPF’s inducement to enter into 
the loans raise individual issues. “As the en banc court in Torres [v. SGE Management, LLC, 838 
F. 3d 629 (5th Cir. 2016),] explained, common issues … predominate if common evidence of 
fraudulent misrepresentation ‘gives rise to a reasonable inference that that misrepresentation 
induced [the class members’ actions] and caused their losses.’ 838 F.3d at 641. Other circuits 
have likewise ‘permitted inferences of reliance when [they] follow[ ] logically from the nature of 
the scheme, and there is common, circumstantial evidence that class members relied on the 
fraud.’ Id.” Vine v. PLS Fin. Servs., Inc., 807 F. App’x 320, 329–30 (5th Cir. 2020). “In cases 
involving fraudulent overbilling, payment may constitute circumstantial proof of reliance based 
on the reasonable inference that customers who pay the amount specified in an inflated invoice 
would not have done so absent reliance upon the invoice’s implicit representation that the 
invoiced amount was honestly owed.” Vine, 807 F. App’x at 330 (quoting U.S. Foodservice, 729 
F.3d at 120).   
Here, the “circumstantial proof of reliance [is] based on the reasonable inference that” 
subclass members would not have applied to CPF -- and thereby forfeited their ability to apply to 
other PPP lenders -- had they known that CPF would not disburse the proceeds of their SBA-
approved loans. See also Rikos v. Procter & Gamble Co., 799 F.3d 497, 518 (6th Cir. 2015) 
(affirming certification of NCUDTPA class, reasoning that “[i]t does not strain credulity to 
conclude that each plaintiff, in entering into contracts with the defendants, relied upon the 
defendants’ representations and assumed they would be paid the amounts they were due because 
the promise to [pay] was a central reason [class members] would sign the agreements.”). 
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Superiority: Rule 23(b)(3) further requires that a class action be “superior to other 
available methods for fairly and efficiently adjudicating the controversy,” and that courts 
consider: (1) the class members’ interest in individually controlling their separate actions, (2) the 
extent and nature of existing litigation by class members concerning the same claims, (3) the 
desirability of concentrating the litigation in the particular forum, and (4) the likely difficulties of 
managing a class action. As to the first factor, where, as here, the costs of litigating an individual 
action would exceed the expected recovery of each individual class member, this presents what 
are commonly referred to as “negative value suits.” See In re TWL Corp., 712 F.3d 886, 903 n.5 
(5th Cir. 2013) (Graves, J., concurring) (“A negative value suit is a case in which the costs of 
enforcement in an individual action would exceed the expected individual recovery.”). “The 
most compelling rationale for finding superiority in a class action” is “the existence of a negative 
value suit[.]” Castano v. Am. Tobacco Co., 84 F.3d 734, 748 (5th Cir. 1996). Second, Plaintiffs 
are not aware of any other litigation by class members concerning the same claims. Third, this is 
a clearly proper forum for litigation focused on CPF and its controlling parent company and 
controlling shareholders, and given that CPF committed to fund hundreds of millions of dollars 
in PPP loans to some 37,800 Texas borrowers many of whom may be similarly situated SBA-
approved but unfunded class members. See ¶ 9 (citing SBA PPP loan data).  
Finally, the likely difficulties of managing this case as a class action pale in comparison 
to doing otherwise. Each Defendant’s liability is a common question that would be inefficient to 
litigate piecemeal. Plaintiffs’ counsel have spent and will if permitted by the Court continue to 
spend significant time litigating the liability and damage issues. Doing this work for an 
individual case alone would be cost-prohibitive and inefficient, particularly considering many of 
the same documents, experts and fact witnesses bear on the liability and damage issues 
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classwide. Absent a class action, the overwhelming majority of affected borrowers, whose loans 
are generally for less than $25,000, would likely not even pursue relief, much less succeed in 
securing it. The cost to them of proceeding on an individual basis would be impractical and 
uneconomical. Through the class action procedure, these common claims can be brought in one 
proceeding, preserving limited judicial resources and eliminating unnecessary duplication and 
potentially inconsistent adjudication. It would also “vindicat[e] the rights of individuals who 
otherwise might not consider it worth the candle to embark on litigation in which the optimum 
result might be more than consumed by the cost.” Deposit Guar. Nat. Bank, Jackson, Miss. v. 
Roper, 445 U.S. 326, 338 (1980).  
IV. 
Plaintiffs’ Counsel Meet the Requirements of Rule 23(g) 
Fed. R. of Civ. P. 23(g)(1) requires courts to appoint class counsel for any certified class. 
In appointing class counsel, courts must consider: (1) “the work counsel has done in identifying 
or investigating potential claims in the action”; (2) “counsel’s experience in handling class 
actions, other complex litigation, and the types of claims asserted in the action”; (3) “counsel’s 
knowledge of the applicable law”; and (4) “the resources that counsel will commit to 
representing the class.” Fed. R. Civ. P. 23(g)(1)(A). Class counsel has a duty to “fairly and 
adequately represent the interests of the class.” Fed. R. Civ. P. 23(g)(4). 
Plaintiffs’ counsel meet the requirements of Rule 23(g). Plaintiffs are represented by 
attorneys who have extensive experience litigating complex financial and class action lawsuits in 
federal courts. See App’x Tabs 9-12. Plaintiffs’ attorneys have a deep understanding of the facts 
and issues, and a clear roadmap to pursue discovery based on having spent months investigating 
Plaintiffs’ claims. Plaintiffs’ attorneys have demonstrated their steadfast commitment to the case 
over nearly a year, refiling it promptly after the Arkansas court dismissed the prior version of 
this case without prejudice. Plaintiffs’ counsel have furthered their investigation, repeatedly 
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pressed Defendants to commence discovery and have now started discovery following the 
Court’s December 13, 2022 Order (ECF No. 47), and filed numerous briefs and accompanying 
documents including in opposition to Defendants’ three separate motions to dismiss. They have 
built strong relationships with the Plaintiffs, been retained by others seeking to be added, and 
fielded wide-ranging inquiries from class members. They have undertaken a wide-ranging search 
and retained highly-qualified experts including two former senior SBA officials who helped 
oversee the PPP (see App’x Tabs 3, 5), an expert in commercial loans (App’x Tab 2), and an 
expert in capital markets (App’x Tab 4), and worked closely with those experts. Lederer Decl. 
¶ 5. And Plaintiffs’ counsel have already expended substantial time and costs including expert 
costs and have the necessary financial and human resources to litigate this matter through trial 
and on appeal. Id. Plaintiffs’ attorneys are experienced advocates with the zeal, skill, and means 
to go toe to toe with likewise skilled defense counsel throughout, and accordingly satisfy the 
qualifications for appointment as class counsel pursuant to Rule 23(g).   
V. 
Plaintiffs Satisfy the Additional Requirements of Local Rule 23.2. 
Local Rule 23.2(a): As discussed above in Sections II and III, this suit is properly 
maintainable as a class action pursuant to Federal Rules of Civil Procedure 23(a) and (b)(3).   
Local Rule 23.2(b): Plaintiffs address the requirements referenced in Local Rule 23.2(b) 
in the Introduction, and Sections III and IV above, and intend to supplement or amend their 
motion for class certification to provide estimates regarding the approximate number of class and 
subclass members per Local Rule 23.2(b)(1) as the Court may direct or permit following a 
reasonable opportunity for discovery, as Defendants perhaps alone have that data. 
Local Rule 23.2(c): The basis of Plaintiffs’ claims to be adequate representatives of the 
class is detailed in Section III above. Proposed class counsel have undertaken to fund this action 
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on behalf of the Classes on a contingent basis, have paid all the costs of litigation incurred, and 
commit to continuing to prosecute and fund the action through its resolution. Lederer Decl. ¶ 5.  
Local Rule 23.2(d): This Court has jurisdiction over this matter under the Class Action 
Fairness Act, 28 U.S.C. § 1332(d)(2)(A). Plaintiffs allege that Defendants improperly failed to 
disburse loans in the thousands of dollars, and in many instances, tens of thousands of dollars, to 
each of a large number of class members. Based upon what Plaintiffs believe that number to be, 
Plaintiffs easily meet the jurisdictional threshold amount of $5,000,000 as required by 28 U.S.C. 
§ 1332(d)(2). Discovery is necessary as to this factor which Plaintiffs have now commenced. 
Local Rule 23.2(e): Notice will be provided by mail and/or electronic mail, based on 
Defendants’ records. Plaintiffs’ counsel will pay the cost of notice if ordered by the Court.  
Local Rule 23.2(f): As also set forth in Plaintiffs’ opposition to Defendants’ motions to 
dismiss (ECF No. 46 at Tab A (Lederer Decl. ¶ 6)), Plaintiffs require the following information 
to properly prepare for a class certification hearing: 
a. 
the total number of SBA-approved but unfunded PPP loans at issue in this 
case for the putative members of the National Class;  
 
b. 
the total number of SBA-approved but unfunded PPP loans for the 
proposed California Subclass;  
 
c. 
the total number of SBA-approved but unfunded PPP loans for the 
proposed North Carolina Subclass;  
 
d. 
the total principal amount of all such SBA-approved but unfunded PPP 
loans for the proposed National Class, California Subclass and North 
Carolina Subclass;  
 
e. 
the amount, status and whereabouts of the PPPLF advances CPF obtained 
for the SBA-approved but unfunded PPP loans for the proposed National 
Class, California Subclass and North Carolina Subclass, including without 
limitation the representations in Crossroads’s financial reports regarding 
those advances;   
 
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f. 
whether CPF transferred or otherwise paid any PPPLF advances it 
obtained to Crossroads or any other person or entity who or which was not 
an SBA-approved PPP borrower and, if so, to whom, when, how much, 
and why;  
 
g. 
the amount, status and whereabouts of the loan processing fees CPF was 
paid by the SBA for the SBA-approved but unfunded PPP loans of the 
proposed National Class, California Subclass and North Carolina 
Subclass; and  
 
h. 
the total number and principal amounts of the SBA-approved PPP loans 
CPF funded after December 29, 2021, when the prior version of this 
litigation was filed in the U.S. District Court for the Eastern District of 
Arkansas. 
Defendants acknowledge that “CPF is required to keep under various estaregulations” 
[sic] PPP records but have also already asserted that producing them “would require detailed 
review for confidential personal and financial information” and “may be subject to the federal 
banking examiner’s privilege, which is held by the regulator and requires financial institutions to 
provide notice to and obtain permission from the regulator before disclosing affected 
documents.” ECF No. 42 at 5. Accordingly, while it is indisputable that CPF is required to 
maintain and readily access and produce PPP loan data (see, e.g., ECF No. 41 at 10-11 (citing 
record keeping provisions)), Plaintiffs are unable presently to estimate the time necessary for 
such discovery with a high degree of confidence. Plaintiffs have already earlier this week served 
each Defendant with opening document requests and interrogatories along with a request for a 
Rule 26(f) meeting and a draft confidentiality order. Assuming Defendants produce the data 
Plaintiffs have requested regarding the Classes’ unfunded loans within 30 days, Plaintiffs believe 
the parties can hold depositions within 45 days after that production, assuming no dispute arises 
between the parties that delays discovery. Plaintiffs will require additional discovery addressed 
to the merits, and do not by complying with Local Rule 23.2(f) waive any rights to pursue further 
discovery. 
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25 
Local Rule 23.2(g): Plaintiffs will seek an award of attorneys’ fees as may be approved 
by the Court in the event of certification and judgment in favor of Plaintiffs and the Classes. 
Plaintiffs’ counsel have entered into contingency fee contracts with Plaintiffs which allow for 
such an application.   
Conclusion 
For the forgoing reasons, Plaintiffs respectfully request that the Court certify the National 
Class, the California Subclass and the North Carolina Subclass; appoint Plaintiffs as 
representatives of the National Class; appoint plaintiffs Covarrubias and Smith as representatives 
of the California Subclass; appoint plaintiff Myles as representative of the North Carolina 
Subclass; and appoint Plaintiffs’ counsel as counsel to the Classes. 
Dated: January 11, 2023 
Respectfully submitted,  
 
Kendall Law Group, PLLC 
 
By: /s/ Joe Kendall 
 
 
 
 
Joe Kendall 
Texas Bar No. 11260700 
3811 Turtle Creek Blvd., Suite 1450 
Dallas, TX  75219 
T:  (214) 744-3000   
F:  (214) 744-3015  
jkendall@kendalllawgroup.com 
 
 
Bailey & Glasser LLP 
Lawrence J. Lederer (pro hac vice) 
Bart D. Cohen (pro hac vice) 
1622 Locust Street 
Philadelphia, PA  19103 
T:  (215) 274-9420 
F:  (202) 463-2103 
llederer@baileyglasser.com  
bcohen@baileyglasser.com  
Case 4:22-cv-00686-P   Document 68   Filed 01/12/23    Page 32 of 33   PageID 1291

26 
 
 
Bailey & Glasser LLP 
Michael L. Murphy (pro hac vice) 
1055 Thomas Jefferson St., NW, Suite 540 
Washington, DC 20007 
T:  (202) 463-2101 
F:  (202) 463-2103 
mmurphy@baileyglasser.com 
 
 
Nolan Heller Kauffman LLP 
Justin A. Heller (pro hac vice) 
Matthew M. Zapala (pro hac vice) 
80 State Street, 11th Floor 
Albany, NY 12207 
T:  (518) 449-3300 
F:  (518) 432-3123 
jheller@nhkllp.com 
mzapala@nhkllp.com  
 
and 
 
 
Friday, Eldredge & Clark, LLP 
Katherine C. Campbell (pro hac vice) 
3350 S. Pinnacle Hills Pkwy, Suite 301 
Rogers, AR  72758 
T:  (479) 695-6049 
F:  (501) 244-5389 
kcampbell@fridayfirm.com 
 
Attorneys for Plaintiffs and the  
Proposed Class and Subclasses 
 
 
Certificate of Service 
 
I hereby certify that a copy of the foregoing document was served on all counsel of 
record on January 11, 2023 via CM/ECF, in accordance with the Federal Rules of Civil 
Procedure. 
 
 
 
 
 
 
 
/s/ Joe Kendall 
 
 
 
 
 
 
 
 
Joe Kendall 
Case 4:22-cv-00686-P   Document 68   Filed 01/12/23    Page 33 of 33   PageID 1292

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