Joint Status Report (October 1, 2025) — ALJ Grants Reconsideration, Remands Case — PayServices v. FRBSF

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A joint status report filed October 1, 2025 in PayServices Bank v. Federal Reserve Bank of San Francisco, No. 24-2355, in the U.S. Court of Appeals for the Ninth Circuit, on appeal from the District of Idaho, No. 1:23-cv-00305-REP (DktEntry: 63.1). It is filed under the court's January 24, 2025 order directing status reports every 30 days until the administrative appeal is resolved. The report states that on September 8, 2025 the ALJ granted PayServices' Motion for Reconsideration, denied the Idaho Department of Finance's motion without prejudice, and remanded the matter to the Department. It adds that PayServices filed a Motion for Clarification on September 30, 2025, that the Department has not issued a final order, and that FRBSF has no independent information on the administrative appeal. The four-page report is signed by counsel for both parties.

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No. 24-2355 
__________________________________________________________________ 
 
IN THE UNITED STATES COURT OF APPEALS 
FOR THE NINTH CIRCUIT 
 
 
PAYSERVICES BANK, 
 
Plaintiff-Appellant, 
 
v. 
 
FEDERAL RESERVE BANK OF SAN FRANCISCO, 
 
Defendant-Appellee. 
 
On Appeal from the United States District Court 
for the District of Idaho 
No. 1:23-cv-00305-REP 
Hon. Raymond E. Patricco, Jr. 
 
 
JOINT STATUS REPORT 
 
 
Jade A. Craig, Esq. 
Jade A. Craig, P.A. 
1048 S. Clearview Avenue, #3 
Tampa, Florida 33629 
Telephone: (813) 459-1309 
jade@jadeacraigpa.com 
 
Attorney for Appellant  
PayServices Bank 
Jonathan K. Youngwood   
Simpson Thacher & Bartlett LLP   
425 Lexington Avenue   
New York, NY 10017  
Telephone: (415) 455-3539 
jyoungwood@stblaw.com  
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco 
 
Case: 24-2355, 10/01/2025, DktEntry: 63.1, Page 1 of 4

INTRODUCTION 
In the Court’s Order entered on January 24, 2025 (Docket Entry No. 52.1), 
the Court directed the parties to “file a status report as to the status of the appeal by 
February 27, 2025 and every 30 days thereafter until the resolution of the 
administrative appeal.” In compliance with this directive, the parties state the 
following: 
1. 
Appellee Federal Reserve Bank of San Francisco (“FRBSF”) does not 
have access to the Administrative Law Judge (“ALJ”)’s September 8, 2025 Orders 
or PayServices’ September 30, 2025 Motion for Clarification briefing with the ALJ 
and the Idaho Office of Administrative Hearings referenced below and has no 
updates or information regarding the status of PayServices’ administrative appeal. 
FRBSF is only aware of the below events through PayServices’ updates herein. 
2. 
On September 8, 2025, the ALJ issued an Order granting PayServices’ 
Motion for Reconsideration and denying without prejudice the Idaho Department of 
Finance’s (the “Department”) Motion for Reconsideration. The ALJ remanded the 
matter to the Department to allow for the parties to further develop the record. 
Counsel for the Department sent a communication regarding remand to PayServices 
on September 16, 2025. After some written communications, it became clear to 
PayServices that PayServices and the Department had reached an impasse regarding 
Case: 24-2355, 10/01/2025, DktEntry: 63.1, Page 2 of 4

2 
 
the legal and practical implications of the ALJ’s Order granting PayServices’ Motion 
for Reconsideration.  
3. 
On September 30, 2025, PayServices filed a Motion for Clarification 
with the ALJ and the Idaho Office of Administrative Hearings. PayServices is 
awaiting a response to the Motion for Clarification from the Department and 
additional direction from the ALJ. The Idaho Department of Finance has still not 
issued a final order or taken final agency action. Thus, the matter remains pending. 
4. 
Any further updates in this matter will be provided via a status report 
which will be filed 30 days from today’s date. 
Date: October 1, 2025  
 
 
Jade A. Craig, P.A. 
 
s/ Jade A. Craig_______ 
Jade A. Craig 
 
Attorney for Appellant PayServices 
Bank 
 
 
Simpson Thacher & Bartlett LLP 
 
s/ Jonathan K. Youngwood_____ 
Jonathan K. Youngwood 
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco  
 
 
 
 
 
 
Case: 24-2355, 10/01/2025, DktEntry: 63.1, Page 3 of 4

3 
 
CERTIFICATE OF FILING AND SERVICE 
 
 
I hereby certify that on this 1st day of October, 2025, I electronically filed the 
foregoing with the Clerk of Court for the United States Court of Appeals for the 
Ninth Circuit by using the appellate CM/ECF system. 
 
 
 
/s/ Jonathan K. Youngwood_____ 
Jonathan K. Youngwood 
Simpson Thacher & Bartlett LLP 
425 Lexington Avenue   
New York, NY 10017  
Telephone: (212) 455-2000 
jyoungwood@stblaw.com 
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco 
 
 
 
 
 
 
 
 
 
Case: 24-2355, 10/01/2025, DktEntry: 63.1, Page 4 of 4

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