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Verified First Amended Complaint for Declaratory and Injunctive Relief

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Verified First Amended Complaint filed October 10, 2024 as Document 18 in Case No. 3:24-cv-04241-LJC, United States District Court for the Northern District of California, by Gold Club - SF, LLC and other plaintiffs against the United States Small Business Administration, Isabel Casillas Guzman, the United States of America, the SBA Office of Hearings and Appeals and Kimberly McLeod. The plaintiffs, described as licensed bars, restaurants, taverns and nightclubs, allege that the SBA denied forgiveness of their PPP loans or began Post-Payment Reviews, relying on 13 C.F.R. § 120.110(p) or the Affiliation Rules. They contend they are NAICS code 72 businesses exempt from those rules and that OHA proceedings lacked due process. They seek declaratory and injunctive relief and fees under the Equal Access to Justice Act.

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“Verified First Amended Complaint for Declaratory and Injunctive Relief.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/18-amended-complaint-with-jury-demand-against-all-defendants-fi-38af64f579/, SHA-256 612c5eb8313cd8d7a574033a994a1b9cfb8ef17738cd7e9b663d88ee43e2984f.

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     Case 3:24-cv-04241-LJC        Document 18       Filed 10/10/24    Page 1 of 169



 1   DOUGLAS J. MELTON, Bar No. 161353
     SHANE M. CAHILL, Bar No. 227972
 2   LONG & LEVIT LLP
     465 California Street, Suite 500
 3   San Francisco, California 94104
     Telephone:     (415) 397-2222
 4   Facsimile:     (415) 397-6392
     Email:         dmelton@longlevit.com
 5                  scahill@longlevit.com

 6   BRADLEY J. SHAFER (MI P36604)*
     ZACHARY M. YOUNGSMA (MI P84148)*
 7   SHAFER & ASSOCIATES, P.C.
     3800 Capital City Blvd., Suite 2
 8   Lansing, MI 48906
     Telephone:    (517) 886-6560
 9   Facsimile:    (517) 886-6565
     Email:        Brad@BradShaferLaw.com
10                 Zack@BradShaferLaw.com

11   *Admitted Pro Hac Vice

12   Attorneys for Plaintiffs

13                               UNITED STATES DISTRICT COURT

14                          FOR THE NORTHERN DISTRICT OF CALIFORNIA

15
     GOLD CLUB - SF, LLC; DALLAS FOOD AND              Case No.: 3:24-cv-04241-LJC
16   BEVERAGE, LLC; 2345 MEACHAM, LLC;
     11000    REEDER,        LLC;     S.A.W.           VERIFIED FIRST AMENDED
17   ENTERTAINMENT LIMITED; SMITHVILLE                 COMPLAINT FOR DECLARATORY AND
     BISTRO, LLC; DEJA VU SHOWGIRLS OF                 INJUNCTIVE RELIEF, ATTORNEY’S
18   LAS VEGAS, LLC; OFFICE MINNEAPOLIS,               FEES AND COSTS UNDER THE EQUAL
     LLC; CATS MEOW OF VEGAS, LLC; CATS                ACCESS TO JUSTICE ACT, AND FOR
19   701 BOURBON, LLC; POLE POSITION AT                JUDICIAL REVIEW OF FINAL AGENCY
     TACOMA, LLC; JAMME HOLDINGS, LLC;                 ACTION
20   90’S MINNEAPOLIS, LLC; LAS VEGAS
     BISTRO,    LLC;      and     STOCKTON             [REQUEST FOR JURY TRIAL]
21   ENTERPRISES, LLC,

22            Plaintiffs,

23            v.

24   UNITED STATES SMALL BUSINESS
     ADMINISTRATION; ISABEL CASILLAS
25   GUZMAN, in her official capacity as
     Administrator   of  the Small   Business
26   Administration; THE UNITED STATES OF
     AMERICA;       THE   SMALL    BUSINESS
27   ADMINISTRATION OFFICE OF HEARINGS
     AND APPEALS; and KIMBERLY MCLEOD, in
28
                                                 1                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24      Page 2 of 169



 1   her official capacities as the Assistant
     Administrator and Chief Hearing Officer of the
 2   Office of Hearings and Appeals.

 3            Defendants.

 4
              NOW COME Plaintiffs, by and through counsel, and for their verified first amended
 5
     complaint against the Defendants allege as follows:
 6

 7                                    INTRODUCTION AND SUMMARY
 8            1.       The Plaintiffs to this action are non-public businesses that are specifically identified
 9   and defined below, and the Defendants are governmental actors, also defined below, that are tasked
10   with administering the Paycheck Protection Program (“PPP”) enacted to address the national
11   financial fallout of the COVID-19 pandemic (the “Pandemic”). The current disputes among these
12   parties arise under the loan programs set up by the PPP.
13            2.       Congress initially created the PPP as part of the Coronavirus, Aid, Relief, and
14   Economic Security Act, Pub. L. 116-136 (2020) (the “CARES Act”). Through the CARES Act and
15   the subsequent Consolidated Appropriations Act, 2021, Pub. L. 116-260, § 311 (2020), which
16   Congress referred to as the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act
17   (the “Appropriations Act” or “EAA”), the PPP ultimately set up two series of loan programs (now
18   referred to as “first draw” and “second draw” loans). These programs authorized certain banks,
19   specifically approved by the United States Small Business Administration (“SBA”), to issue loans
20   under the PPP that would be guaranteed by the SBA. The first and second draw loan programs were
21   then further amended via the American Rescue Plan Act of 2021 (“ARPA”), Pub. L. 117-2, § 5001
22   (Mar. 11, 2021). The authorized banks that issued PPP loans to these Plaintiffs are referred to
23   hereinafter as the “Lending Banks.”
24            3.       In this action, Plaintiffs seek, among other things, both declaratory and injunctive
25   relief to bring to an end the Defendants’ continued and persistent mistreatment as delineated in
26   exhaustive detail below and documented through voluminous attached exhibits—of the Plaintiffs and
27   others that the SBA perceives to be “affiliated” with them; most but not all of which engage in,
28
                                                 2                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24       Page 3 of 169



 1   present, and/or permit, one or more forms of lawful entertainment protected under the First

 2   Amendment to the United States Constitution (including such noncontroversial forms of

 3   entertainment as karaoke bars).

 4            4.       The actions of the Defendants have caused, continue to cause, and/or will cause, as

 5   applicable, these Plaintiffs and certain businesses associated with them to: A) needlessly incur

 6   exorbitant sums of money in the form of attorneys’ fees, accountants’ fees, and other professional

 7   fees in responding to the actions of the Defendants; B) needlessly devote countless hours of their

 8   staffs’ time in attempting to respond to voluminous and ever-changing requests and positions of the

 9   Defendants as they exhaustingly seek out a viable course of conduct to financially ruin these

10   Plaintiffs in a manner that could be legally defended (where the SBA often demands documents that

11   a particular Plaintiff simply does not possess and does not have the legal authority to acquire); and

12   C) pay back loans that, according to the law, should be forgiven since they were fully approved,

13   lawfully obtained, and the proceeds thereof were used in strict accordance with statutory

14   requirements. In addition, as detailed shortly below, the Defendants have threatened a number of the

15   Plaintiffs, as well as their Lending Banks, with both civil and criminal investigation if the Plaintiffs

16   don’t fully bend to every demand--as unreasonable, outrageous, and legally deficient as it may be--

17   of the Defendants.

18            5.       Pursuant to 15 U.S.C. § 636(a)(36)(F)(i)(I) – (XI) and 15 U.S.C. § 636(a)(37)(J)(iii)(I)

19   – (VIII) of the PPP, loans were to be used for, and forgiveness of such loans was to be granted by the

20   Lending Bank and/or SBA if the loaned funds were specifically expended upon, among other things,

21   payroll costs, certain group health care benefits, rent, mortgage interest, utility bills, interest on other

22   pre-Pandemic debt, personal protective equipment, and covered supplier costs (collectively, the

23   “Permitted Uses”). If the loan is forgiven, the SBA then makes the Lending Bank whole.

24            6.       All of the Plaintiffs had their PPP loans approved by their Lending Banks and/or the

25   SBA (the “Loans”); received the full funds under those Loans (the “Loan Proceeds”); and used the

26   amount requested via their loan forgiveness applications for the purposes specified in the PPP and in

27   their loan documents (although a number of the Plaintiffs have actually returned a portion of their

28
                                                 3                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18       Filed 10/10/24      Page 4 of 169



 1   Loan Proceeds because they were unable, as a result of governmentally ordered business shutdowns

 2   arising from the Pandemic, to fully utilize such funds for the Permitted Uses).

 3            7.       Now, however, the SBA has, for some of the Plaintiffs, denied forgiveness of the

 4   Loans through the issuance of what is known as a Final Loan Review Decision (hereinafter “FLRD,”

 5   or “Denial Letter”); for other Plaintiffs, the SBA has denied forgiveness of the Loans but has, at least

 6   temporarily, suspended such a determination pending “further investigation” after those Plaintiffs

 7   filed formal administrative appeals in the SBA’s Office of Hearings and Appeals (“OHA”) of the

 8   FLRDs issued to those Plaintiffs and needlessly expended tens of thousands of dollars in professional

 9   fees in doing so; for other Plaintiffs the SBA has done the same thing and has now issued “new and

10   improved” Denial Letters triggering the requirement of those Plaintiffs to file yet a second

11   administrative appeal in the OHA; and for yet other Plaintiffs that have not only received PPP Loans

12   but have also obtained forgiveness of such Loans, the SBA has recently initiated audits, or what the

13   SBA refers to as “Post-Payment Reviews,” of such Plaintiffs purportedly to “re-examine” the

14   question of whether they were eligible for the Loans in the first place.

15            8.       The OHA proceedings, in which many of these Plaintiffs have been compelled to

16   participate, have been bereft of due process. It is no exaggeration to state that, with the exception of

17   motions to extend deadlines, all contested motions filed by the Plaintiffs in the OHA have been

18   denied, and all contested motions filed by the SBA have been granted. But the OHA normally does

19   not even wait until receipt of the SBA’s response to a Plaintiff’s motion before ruling; rather, such

20   Plaintiff motions are usually denied within hours of filing. And, contested motions filed by the SBA

21   in the OHA have been granted within one minute of the filing of the motion by the SBA.

22            9.       In regard to the audits, or Post-Payment Reviews, some Plaintiffs have been informed

23   by their Lending Bank that the SBA is “considering a full denial” of such Loans.

24            10.      If Loan forgiveness is denied, the Plaintiff is then required to pay the Loan Proceeds

25   back to its Lending Bank. However, and simply put, having used the Loan Proceeds in strict

26   accordance with the PPP (only for the Permitted Uses for the amounts requested to be forgiven),

27   Plaintiffs are no longer in possession of the Loans Proceeds and have no lawful way to recover them

28
                                                 4                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 5 of 169



 1   in order to be able to pay them back—as demanded by the SBA—to their Lending Banks. The Loan

 2   Proceeds are, quite literally, in the hands of the Plaintiffs’ employees, utility providers, landlords,

 3   and the like.

 4            11.      In addition to denying or threatening to deny Loan Forgiveness, some Plaintiffs have

 5   been told through communication from the SBA to the Plaintiffs’ Lending Banks that the failure to

 6   provide each and every item of the voluminous materials requested by the SBA (unnecessary for the

 7   reasons set forth herein), “may include referral to the Office of Credit Management and/or transfer

 8   of this matter (borrower and lender) to the Office of Inspector General.” [Exhibit A (exemplar post

 9   payment review letter received by Plaintiff Office Minneapolis, LLC; clarification in original);

10   Exhibit B (exemplar request for production of documents received by Plaintiff Dallas Food &

11   Beverage, LLC: “. . . may include . . . referral to the Office of Credit Risk Management, and/or

12   transfer of this matter (borrower and lender) to the Inspector General”)]. As such, the SBA is now

13   not just threatening the Plaintiffs, but it is also threatening the Plaintiffs’ Lending Banks as well and

14   in doing so, in certain circumstances, is also compromising the ongoing business relationship that a

15   number of the Plaintiffs have with their Lending Banks and associated financial institutions.

16            12.      In addition, as further evidence of the vindictive, harassing, discriminatory, and

17   retaliatory nature of the SBA’s treatment of these Plaintiffs and those that the Defendants believe to

18   be “affiliated” with them, the SBA initiated, shortly before the filing of this suit, an investigation of

19   a number of these Plaintiffs and certain others that the Defendants believe to be “affiliated” with

20   them in regard to funds that such businesses received, as part of a federal court settlement following

21   the initiation of litigation against some of these same Defendants for similar types of misconduct,

22   under another Pandemic-related funding program administered by the SBA (the Restaurant

23   Revitalization Fund; “RRF”). These latest actions will likely be the subject of a separate proceeding

24   in that federal court.

25            13.      The SBA’s actions in denying Loan forgiveness of the Plaintiffs or, where forgiveness

26   has already been granted, in commencing audits to “re-examine” the question of Loan eligibility, are

27   purportedly based upon, directly or indirectly, either or both of what Plaintiffs will refer to herein as

28
                                                 5                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24      Page 6 of 169



 1   the Regulation” found at 13 C.F.R. § 120.110(p), or the “Affiliation Rules” found at 13 C.F.R. §

 2   121.101, 13 C.F.R. § 121.103; 13 C.F.R. § 121.201, 13 C.F.R. § 121.301.

 3            14.      The dispute concerning the Prurience Regulation involves the question of whether

 4   certain of the Plaintiffs present forms of entertainment, or sell products, of a “prurient sexual nature.”

 5   The SBA contends that such businesses are not eligible for PPP loans under 13 C.F.R. § 121.110(p).

 6            15.      The dispute regarding the Affiliation Rules revolves around the question of whether

 7   the Plaintiffs are what the PPP refers to as “NAICS code 72” businesses (including food and alcoholic

 8   beverage establishments, such as bars, taverns, restaurants, nightclubs, and discotheques). Such

 9   companies or “business concerns” are exempt, under the PPP pursuant to 15 U.S.C. §

10   636(a)(36)(D)(iii)(I) and 15 U.S.C. § 636(a)(36)(D)(iv)(I) for first draw loans and 15 U.S.C. §

11   636(a)(37)(D) and (E) for second draw loans (collectively, the “Affiliation Exception Provisions”),

12   from the “normal” Affiliation Rules used by the SBA to determine whether a business, together with

13   entities that the SBA contends are “related” to it, is “too big” to receive funding under certain of its

14   loan and grant programs.

15            16.      “NAICS” stands for the North American Industry Classification System, which was

16   jointly developed by the Office of Management and Budget, the U.S. Economic Classification Policy

17   Committee, Statistics Canada, and Mexico’s Instituto Nacional de Estadistica y Geografia. The

18   NAICS is currently maintained by the United States Census Bureau, with its website providing the

19   latest information, (https://www.census.gov/naics/?99967 (last visited October 7, 2024)).

20            17.      The NAICS is used for various statistical purposes by certain agencies of the federal

21   government. The Census Bureau is one such agency. The Internal Revenue Service (“IRS”) also

22   indirectly, and as is relevant to the circumstances of a number of the Plaintiffs here for the reasons

23   discussed below, references them (albeit, also discussed hereinafter, with some differences).

24            18.      All Plaintiffs are licensed bars, and/or restaurants, and/or taverns, and/or nightclubs,

25   and are therefore, for PPP purposes, NAICS code 72 businesses.

26            19.      In addition to the Prurience Regulation and the Affiliation Rules, the SBA has, in a

27   number of their “audits” and as a purely pretextual matter in an effort to run up the Plaintiffs’ costs

28
                                                 6                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24     Page 7 of 169



 1   and to have them needlessly expend staff time and effort on unnecessary and extraneous matters,

 2   demanded that certain Plaintiffs immediately produce documentation to: A) verify that it indeed

 3   suffered a specified 25% reduction in aggregated gross receipts (that being an eligibility prerequisite

 4   for second draw PPP loans; see generally 5 U.S.C. § 636(a)(37)(A)(iv)(I)); and B) to permit the SBA

 5   to be able to calculate the original loan amount or forgiveness amount (the SBA claiming that for the

 6   latter Plaintiffs, “sufficient documentation” had not been previously produced even those such Loans

 7   had been approved and forgiven).

 8            20.      All Plaintiffs applying for and receiving second draw PPP loans suffered the statutory

 9   requisite 25% reduction in aggregated gross receipts in order to qualify for such second draw PPP

10   loans.

11            21.      All Plaintiffs have sufficient and proper documentation to document the original

12   amount of their requested PPP Loans and the amounts thereof sought to be forgiven.

13            22.      As a result of the above and as further described in detail below, Plaintiffs challenge

14   here as being unconstitutional under the First and Fifth Amendments to the United States

15   Constitution: A) both facially and as applied by the Defendants to these Plaintiffs, the Prurience

16   Regulation (already enjoined by, among other courts, the Eastern District of Michigan); B) the

17   manner in which the Defendants are applying the Affiliation Exception Provisions to these Plaintiffs;

18   C) both facially and as applied by the Defendants to these Plaintiffs, the Affiliation Rules; and D)

19   both facially and as applied by the Defendants to these Plaintiffs, the rules of the OHA, as discussed

20   and defined, infra, that apply specifically and exclusively to appeals emanating from PPP matters, 1

21   which lack due process by, among other things, denying any and all forms of discovery whatsoever

22   (13 C.F.R. § 134.1209(b)), while permitting SBA to “supplement” the administrative record at any

23   time; requiring the appellant to file its appeal brief before it has even had an opportunity to view the

24   “administrative record” that the SBA purports to have relied on in issuing the FLRD that is the subject

25   of the appeal so that the appellant may respond accordingly (but which it is not even entitled to do

26
     1
      Plaintiffs do not challenge the “normal” appellate rules of the OHA that apply to all other appeals
27   except for PPP matters. Those, in contrast to the rules challenged here that pertain only to PPP
     decisions, actually provide some semblance of due process.
28
                                                      7                          Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 8 of 169



 1   as a matter of right) (13 C.F.R. §§ 134.1202, 134.1207); precluding any form of hearing or oral

 2   argument whatsoever to occur on the appeal (13 C.F.R. § 134.1209(b)); precluding the award of

 3   attorneys’ fees and costs under the Equal Access to Justice Act (5 U.S.C. § 504 & 28 U.S.C. § 2412)

 4   to appellants if otherwise eligible under that Act (13 C.F.R. § 134.1213); and permitting the SBA to

 5   “submit” administrative records to the OHA for its consideration of the appeal that have been so

 6   heavily redacted that the appellant cannot in the OHA proceeding fully understand and respond (even

 7   if permitted, in the complete and absolute discretion of the OHA) to the supposed reasoning of the

 8   SBA in denying loan or forgiveness eligibility—and thereby significantly limiting the Plaintiffs’

 9   ability to later adjudicate such claims in a court of law. Plaintiffs also challenge the legality of the

10   SBA having enacted the various challenged regulations and, based upon the extremely egregious

11   conduct by the Defendants as detailed herein, the anti-injunction provisions of 15 U.S.C. § 634(b)(1).

12            23.      The consequences of Defendants’ unlawful and unconstitutional actions have now

13   reached the point where a number of these Plaintiffs are—and more will be if the Defendants are not

14   stopped—on the precipice of financial ruin, which could result in the closure of such Plaintiffs’

15   businesses and, for a number of the Plaintiffs, the cessation of the presentation of, and the ability of

16   the adult public to view and participate in, constitutionally protected entertainment.

17            24.      The matters set forth in the paragraph immediately above, together with the threats

18   by the SBA to the Plaintiffs and to the Lending Banks to forward these disputes to the Office of

19   Credit Management and/or the Office of Inspector General for “further handling,” and particularly

20   in context of the sovereign immunity from claims for damages enjoyed by the Defendants,

21   undeniably constitutes immediate and irreparable harm being suffered by these Plaintiffs. This

22   harassment, targeting, and retaliation, resulting from the admitted disdain (detailed herein) that a

23   certain senior representative of the SBA has for the nature of the entertainment presented by some of

24   the Plaintiffs, continues up to the date of the filing of this action and must be stopped. Given the

25   egregious conduct of the Defendants as detailed herein, Defendants and their agents, as public

26   officials, cannot be presumed to be properly discharging or to have been properly discharging their

27   official duties. United States v. Mezzanatto, 513 U.S. 196, 210 (1995).

28
                                                 8                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24      Page 9 of 169



 1            25.      Plaintiffs have contacted, through the undersigned attorneys, legal counsel from the

 2   Department of Justice (“DOJ”) who had previously represented the SBA in numerous other lawsuits

 3   and disputes between the clients of the undersigned firm and the SBA informing him of the actions

 4   summarized above and as described in exhaustive detail below, but the unlawful and unconstitutional

 5   actions of the SBA continue unabated. 2

 6            26.      In fact, following the transmission of correspondence from the undersigned attorneys

 7   to (at least previous) legal counsel for the SBA as discussed in the paragraph immediately above, not

 8   only did the SBA commence the “review” of the settlement proceeds paid by the SBA under the RRF

 9   program discussed in paragraph 12above, but its actions in initiating “audits” of the clients of the

10   undersigned firm in order to “re-examine” loan eligibility or the use of Loan Proceeds increased

11   precipitously. As the undersigned attorneys had been drafting the original complaint in this action,

12   scores of new “audits” of their clients, as well as other businesses that the SBA apparently contends

13   are somehow related to or tainted by them, had been initiated by the SBA.

14            27.      As a result of the matters set forth in the paragraph immediately above, the current

15   list of Plaintiffs identified in this action is merely representative of those businesses affected by

16   unconstitutional and illegal actions of the Defendants detailed herein, with the Plaintiff list to

17   increase as time permits amendments to these pleadings. Nevertheless, given the cascading actions

18   of the Defendants, the filing of this lawsuit at this time is necessary in order to permit Plaintiffs the

19   opportunity to seek and obtain preliminary injunctive relief and/or accelerated declaratory judgment.

20                                       JURISDICTION AND VENUE

21            28.      Jurisdiction is conferred on this Court for the resolution of the substantial
22   constitutional questions presented herein by virtue of 28 U.S.C. § 1331; 28 U.S.C. § 1343(a)(1), (3),
23   and (4); 28 U.S.C. § 1346(a)(2); 28 U.S.C. § 1361; and 28 U.S.C. § 2201.
24            29.      Jurisdiction is conferred on this Court for resolution of all relevant questions of law,
25
     2
       Plaintiffs do not attribute, in any way, the failure of SBA to conform its actions with the law and/or
26   the U.S. Constitution to the actions or inactions of the aforementioned DOJ attorney; rather, as
     repeated herein, Plaintiffs attribute it exclusively and directly to the SBA and, in particular, to one
27   of its senior officials with a stated animus towards the form of the constitutionally protected
     entertainment some of the Plaintiffs present.
28
                                                          9                           Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24       Page 10 of 169



 1   the interpretation of constitutional and statutory provisions, the determination of the meaning or

 2   applicability of the terms of the SBA’s actions as discussed herein, and over Plaintiffs’ facial and as

 3   applied challenges to the SBA’s regulations, by virtue of 5 U.S.C. §§ 702 and 706.

 4            30.      Jurisdiction is conferred on this Court for Plaintiffs’ claim(s) for attorneys fees and

 5   costs by virtue of 5 U.S.C. § 504 and 28 U.S.C. § 2412.

 6            31.      Jurisdiction is also proper under 15 U.S.C. § 634(b)(1).

 7            32.      No other action, civil or criminal, is pending in any state court involving the Plaintiffs

 8   regarding the activities and events discussed herein.

 9            33.      Plaintiff Gold Club – S.F., LLC, and any other Plaintiff that receives a final decision

10   from the OHA regarding their PPP loan forgiveness application, is entitled to judicial review of SBA

11   and the OHA’s decision. 13 C.F.R. § 134.1201(d); 13 C.F.R. § 134.1211(g).

12            34.      This suit is authorized by law to redress deprivations of rights, privileges, and

13   immunities secured by the First and Fifth Amendments to the United States Constitution.

14            35.      Pursuant to 28 U.S.C. § 1391(e), venue in this Court is appropriate because Plaintiffs

15   Gold Club -S.F., LLC and S.A.W. Entertainment Limited are located in the Northern District of

16   California; the Small Business Administration operates in the Northern District of California;

17   Defendants have consented to venue in the Northern District of California; and the injury complained

18   of and acts causing the injury have occurred and will continue to occur in the Northern District of

19   California.

20            36.      Venue in this Court is appropriate for all Plaintiffs because Plaintiffs Gold Club – S.F.,

21   LLC and S.A.W. Entertainment Limited are located in the Northern District of California. E.g., Raju

22   v. Cuccinelli, No. 20-CV-01386-AGT, 2020 WL 4915773, at *3 (N.D. Cal. Aug. 14, 2020) (“There

23   is no dispute that venue is proper in this district; the two California-based plaintiffs live within the

24   district, which is sufficient.”); Californians for Renewable Energy v. United States Env't Prot.

25   Agency, No. C 15-3292 SBA, 2018 WL 1586211, at *5 (N.D. Cal. Mar. 30, 2018) (“For purposes of

26   § 1391(e)(1)(C), the clear weight of federal authority holds that venue is proper in a multi-plaintiff

27   case if any plaintiff resides in the District.”); F.L.B. v. Lynch, 180 F. Supp. 3d 811, 815 (W.D. Wash.

28
                                                10                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 11 of 169



 1   2016) (quoting Ry. Labor Execs.’ Ass’n v. Interstate Commerce Comm’n, 958 F.2d 252, 256 (9th

 2   Cir. 1991) (noting the Ninth Circuit has cited, “with approval,” cases from other jurisdictions

 3   “holding that, ‘in order to avoid a multiplicity of similar suits in different courts, venue need be

 4   proper for only one plaintiff under 28 U.S.C. § 1391(e).”); E. Texas Baptist Univ. v. Sebelius, No.

 5   CIV.A. H-12-3009, 2013 WL 4678016, at *7 (S.D. Tex. Aug. 30, 2013) (noting that the “only view

 6   adopted by the federal courts since 1971” is that “§ 1391(e)(1) [] provide[s] venue to all plaintiffs as

 7   long as one plaintiff resides in the district”); Exxon Corp. v. F.T.C., 588 F.2d 895, 899 (3d Cir. 1978)

 8   (“There is no requirement that all plaintiffs reside in the forum district.”).

 9            37.      In addition, the claims of all Plaintiffs should be heard in this single action because:

10   A) as a result of the financial hardships caused by the Pandemic and the actions of the Defendants

11   detailed herein, a number of the Plaintiffs would not be able to financially afford to fund separate

12   litigation predicated upon its individual circumstances; and B) individual lawsuits, which would be

13   based upon the same facts, circumstances and law, and in particular the SBA’s contention that many

14   of these Plaintiffs are part of the same “affiliation group” as discussed herein, could result in

15   inconsistent decisions that would compound the violations of Plaintiffs’ constitutional rights.

16                                                THE PARTIES

17   Plaintiffs

18            38.      Plaintiff Gold Club SF, LLC (“Gold Club”) is a Limited Liability Company duly

19   organized under the laws of the State of Nevada and authorized to conduct business in the State of

20   California. Gold Club does business as Gold Club at 650 Howard Street, San Francisco, California

21   94105. This address will be referred to below as Gold Club’s “physical location.”

22            39.      Plaintiff Dallas Food and Beverage, LLC (“Dallas Food and Beverage”), is a Texas

23   Limited Liability Company duly organized and authorized to conduct business in the State of Texas.

24   Dallas Food and Beverage does business as Bucks Cabaret at 2150 California Crossing Rd. in Dallas,

25   Texas. These addresses will be referred to below as Dallas Food and Beverage’s “physical location.”

26            40.      Plaintiff 2345 Meacham, LLC (“Meacham”) is a Limited Liability Company duly

27   organized and licensed to do business in the State of Texas. Meacham does business as Buck’s

28
                                                11                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18      Filed 10/10/24     Page 12 of 169



 1   Cabaret at 2345 Meacham Blvd, Fort Worth, Texas 76106. This address will be referred to below as

 2   Meacham’s “physical location.”

 3            41.      Plaintiff 1100 Reeder, LLC (“Reeder”) is a Texas Limited Liability Company duly

 4   organized and authorized to conduct business in the State of Texas. Reeder does business as Bucks

 5   Wild at 11327 Reeder Road in Dallas, Texas 75229. This address will be referred to below as

 6   Reeder’s “physical location.”

 7            42.      Plaintiff S.A.W. Entertainment Limited (“SAW”), is a California Corporation duly

 8   organized and authorized to conduct business in the State of California. SAW does business as Larry

 9   Flynt’s Hustler Club at 1031 Kearny Street and Condor Club at 560 Broadway Street in San

10   Francisco, California. These addresses will be referred to below as SAW’s “physical location.”

11            43.      Plaintiff Smithville Bistro, LLC (“Smithville”), is a Tennessee Limited Liability

12   Company duly organized and authorized to conduct business in the State of Tennessee. Smithville

13   does business as Midnight Express - Smithville at 33847 Sparta Way in Smithville, Tennessee. These

14   addresses will be referred to below as Smithville’s “physical location.”

15            44.      Plaintiff Deja Vu Showgirls of Las Vegas, LLC (“DVSG of LV”), is a Nevada Limited

16   Liability Company duly organized and authorized to conduct business in the State of Nevada. DVSG

17   of LV does business as Deja Vu Showgirls Las Vegas at 3247 Sammy Davis Jr. Drive, in Las Vegas,

18   Nevada. These addresses will be referred to below as DVSG of LV’s “physical location.”

19            45.      Plaintiff Office Minneapolis, LLC (“Office”), is a Minnesota Limited Liability

20   Company duly organized and authorized to conduct business in the State of Minnesota. Office does

21   business as The Office Pub & Grill at 307 N. Washington Ave., in Minneapolis, MN. These addresses

22   will be referred to below as Office’s “physical location.”

23            46.      Plaintiff Cats Meow of Vegas, LLC (“Cats”), is a Nevada Limited Liability Company

24   duly organized and authorized to conduct business in the State of Nevada. Cats does business as

25   Cat’s Meow at 450 Fremont Street, Suite 201, in Las Vegas, Nevada. This address will be referred to

26   below as Cats’ “physical location.”

27            47.      Plaintiff Cats 701 Bourbon, LLC (“Cats NOLA”), is a Nevada Limited Liability

28
                                                12                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18      Filed 10/10/24     Page 13 of 169



 1   Company authorized to conduct and does conduct business in the State of Louisiana. Cats NOLA

 2   does business as Cat’s Meow at 701 Bourbon Street in New Orleans, LA. This address will be

 3   referred to below as Cats NOLA’s “physical location.”

 4            48.      Plaintiff Pole Position at Tacoma, LLC (“Pole Position”), is a Washington Limited

 5   Liability Company duly organized and authorized to conduct business in the State of Washington.

 6   Pole Position does business as Pole Position Sports Bar at 10707 Pacific Ave. S., Ste. F, in Tacoma,

 7   WA. This address will be referred to below as Pole Position’s “physical location.”

 8            49.      Plaintiff Jamme Holdings, LLC (“Jamme”), is a Pennsylvania Limited Liability

 9   Company duly organized and authorized to conduct business in the State of Pennsylvania. Jamme

10   does business as Dream Girls Wilkes-Barre at 205 Mundy Street in Wilkes-Barre, Pennsylvania.

11   These addresses will be referred to below as Jamme’s “physical location.”

12            50.      Plaintiff 90’s Minneapolis, LLC (“90s”), is a Minnesota Limited Liability Company

13   duly organized and authorized to conduct business in the State of Minnesota. 90s does business as

14   Gay 90’s Minneapolis at 408 Hennepin Ave. in Minneapolis, MN. These addresses will be referred

15   to below as 90’s “physical location.”

16            51.      Plaintiff Las Vegas Bistro, LLC (“LVB”), is a Nevada Limited Liability Company

17   duly organized and authorized to conduct business in the State of Nevada. LVB does business as

18   Larry Flynt’s Hustler Club – Las Vegas at 6007 Dean Martin Dr. in Las Vegas, NV. These addresses

19   will be referred to below as LVB’s “physical location.”

20            52.      Plaintiff Stockton Enterprises, LLC (“Stockton Enterprises”), is a Nevada Limited

21   Liability Company authorized to conduct and does conduct business in the State of California.

22   Stockton Enterprises does business as Showgirls of Stockton at 64206 N. West Ln., in Stockton, CA.

23   These addresses will be referred to below as Stockton Enterprises’ “physical location.”

24   Defendants

25            53.      Defendant Small Business Administration (again, “SBA”) is an independent federal

26   agency created and authorized pursuant to 15 U.S.C. § 633, et seq. The SBA maintains a branch

27   office at 455 Market Street, Ste. 600 in San Francisco, California, which is within the Northern

28
                                                13                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 14 of 169



 1   District of California.

 2            54.      Defendant Isabel Casillas Guzman (“Guzman,” or the “Administrator”) is the

 3   Administrator of the SBA, a Cabinet-level position, and is sued in her official capacity only as the

 4   Administrator of the SBA.

 5            55.      Authority to sue the Administrator is granted by 15 U.S.C. § 634(b), which states, in

 6   part:

 7            In the performance of, and with respect to, the functions, powers, and duties vested
              in him by this chapter the Administrator may—(1) sue and be sued in any court of
 8            record of a State having general jurisdiction, or in any United States district court, and
              jurisdiction is conferred upon such district court to determine such controversies
 9            without regard to the amount in controversy . . . .

10            56.      Defendant Office of Hearings and Appeals (again, “OHA”) is an independent office

11   of the United States Small Business Administration in 1983 and which has an office in Washington,

12   D.C., but maintains an email address for any internet user to email from anywhere in the world where

13   there is access to the world wide web.

14            57.      Defendant Kimberly McLeod (“McLeod”) is the Assistant Administrator for the OHA

15   and is the Chief Hearing Officer for the OHA.

16            58.      Defendant United States of America is a sovereign nation dedicated to the protection

17   of life, liberty, and property as set forth in the Bill of Rights and other provisions of and amendments

18   to the Constitution of the United States.

19            59.      The SBA, the Administrator, the OHA, McLeod, and the United States of America

20   are referred to collectively hereinafter as the “Defendants.”

21            60.      Plaintiffs do not seek, at this time, damages and currently pray only for declaratory

22   and injunctive relief under 5 U.S.C. § 701, et seq., in order to restrain the actions of the SBA, the

23   Administrator, and McLeod in each of their official capacities. Plaintiffs do, however, make a claim

24   for attorneys’ fees and costs under the Equal Access to Justice Act and applicable law, 5 U.S.C. §

25   504 and 28 U.S.C. § 2412, as set forth herein. See Count XV.

26                          FACTS RELATED TO THE SPECIFIC PLAINTIFFS

27   Gold Club – S.F., LLC (“Gold Club”)

28
                                                14                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 15 of 169



 1            61.      Gold Club is a licensed food and alcohol serving restaurant/nightclub open to the

 2   consenting adult public, which presents on its premises a variety of non-obscene, constitutionally

 3   protected, female performance dance entertainment.

 4            62.      Gold Club has never been charged with, let alone convicted of, any crimes of

 5   obscenity. Similarly, none of the entertainers who have performed on Gold Club’s premises have

 6   ever been charged with, let alone convicted of, any crimes of obscenity related to their performances

 7   at the facility owned and operated by Gold Club.

 8            63.      Gold Club does not present any live performances, depictions or displays, or sell any

 9   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

10   prurient, or unhealthy interest in sex.

11            64.      Gold Club operates it nightclub pursuant to, and in accordance with, the following

12   licenses/permits, which it maintains:

13                     a.     Alcoholic Beverage License issued by the State of California’s Department of

14            Alcoholic Beverage Control agency; and

15                     b.     A Class/Permit Number H26/32781 License Certificate issued by the City of

16            San Francisco that describes Gold Club as an H26 Restaurant Over 2,000 SQ issued to

17            Alternative Entertainment, Inc., a wholly owned subsidiary of Gold Club.

18            65.      As a consequence of the Pandemic, Gold Club was subject to various governmental

19   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

20   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

21   related thereto, Gold Club suffered, as did a large percentage of businesses throughout the United

22   States, devastating and catastrophic financial losses.

23            66.      In order to mitigate the financial impact caused to Gold Club by the Pandemic and

24   the consequences thereof, including but not limited to its ability to retain and pay its employees, Gold

25   Club submitted an application to its Lending Bank for a first draw PPP loan on or about April 14,

26   2020, and for a second draw PPP loan in March of 2021. At all times relevant hereto, Gold Club’s

27   Lending Bank operated as a delegate of the SBA in processing and approving/disapproving of the

28
                                                15                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 16 of 169



 1   first and second draw PPP loans sought by Gold Club.

 2            67.      Because Gold Club operates a licensed food and alcohol-serving nightclub under the

 3   licenses/permits identified in paragraph 64, it is, for purposes of the PPP and the Affiliation Rules, a

 4   NAICS code 72 business. Since at least 2016, Gold Club has claimed NAICS code 722410 as its

 5   “business code number” on its federal income tax returns, and claimed NAICS code 722410 on its

 6   second draw PPP loan application, its second draw PPP loan forgiveness application, and its SBA

 7   Form 3511.

 8            68.      At all times related to the relevant period for its first draw PPP loan, Gold Club had

 9   no more than 176 persons employed at its physical location.

10            69.      At all times related to the relevant period for its second draw PPP loan, Gold Club

11   had no more than 155 persons employed at its physical location.

12            70.      Under the PPP, Gold Club was eligible to obtain its first draw Loan and it received its

13   first draw Loan.

14            71.      Under the PPP, Gold Club was eligible to obtain its second draw Loan and it received

15   its second draw Loan.

16            72.      The Loan Proceeds amount that Gold Club applied for forgiveness of for both its first

17   and second draw Loans, were used by Gold Club exclusively for the Permitted Uses in full

18   accordance with the PPP and its Loan Agreement. Consequently, it no longer possesses any of the

19   Loan Proceeds from its first and second draw Loan.

20   Gold Club’s Appeal to the OHA of SBA’s FLRD Denying Forgiveness of its First Draw PPP Loan

21            73.      While Gold Club was eligible for forgiveness of its first draw Loan, the SBA

22   conducted a review of Gold Club’s Loan and, on or about October 31, 2023, issued Gold Club an

23   FLRD denying Gold Club’s forgiveness application for its first draw Loan because SBA had

24   conclude that Gold Club was ineligible for that Loan for two reasons: 1) Gold Club was allegedly an

25   ineligible business concern providing prurient sexual material (and therefore precluded from

26   eligibility by application of the Prurience Regulation) and 2) Gold Club, together with the businesses

27   SBA claims it is affiliated with, exceeded the maximum allowable number of employees and the

28
                                                16                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 17 of 169



 1   SBA’s small business size standards.

 2             74.     On or about November 30, 2021, Gold Club timely applied for forgiveness of its first

 3   draw PPP Loan. At all times during that forgiveness application process, Gold Club’s Lending Bank

 4   operated as a delegate of the SBA in processing and approving/disapproving of forgiveness of Gold

 5   Club’s first draw PPP Loan, and issued a forgiveness decision to SBA approving Gold Club’s loan

 6   forgiveness application in the amount of $262,664.96.

 7             75.     On December 11, 2023, the OHA served a scheduling order for the aforementioned

 8   appeal.

 9             76.     The next day, on December 12, 2023, Gold Club filed a motion for discovery seeking

10   necessary discovery in the form of document requests; a Fed. R. Civ. P. 30(b)(6) deposition of the

11   SBA; a deposition of Eric Benderson, SBA’s Associate General Counsel for Litigation who had, in

12   previous litigation, provided a declaration regarding how determinations are made under the

13   Prurience Regulation; and the depositions of that person or those persons who made, or participated

14   in any fashion in making, the decision to deny Plaintiff’s loan forgiveness application. This motion

15   and other similar motions filed by other Plaintiffs in the OHA are discussed and attached to this First

16   Amended Complaint, infra.

17             77.     At that time, no attorney for the SBA had yet filed an appearance.

18             78.     The following day, December 13, 2023, without a response from SBA, the OHA, sua

19   sponte, denied the aforementioned discovery motion stating that “OHA’s authority is limited to

20   reviewing whether a loan forgiveness decision is based on clear error.”

21             79.     On January 2, 2024, SBA filed the 5,967-page administrative record in that appeal.

22             80.     Gold Club and its staff, as well as its attorneys and accountants, began reviewing the

23   5,967-page administrative record to determine whether objections were necessary and to prepare the

24   same if necessary, which, pursuant to 13 C.F.R. § 134.1207 and the scheduling order in the appeal,

25   were due within 10 calendar days of SBA filing the administrative record.

26             81.     Gold Club requested and was granted three unopposed extensions to file its objections

27   to the administrative record.

28
                                                17                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24     Page 18 of 169



 1            82.      On February 27, 2024, the day before Gold Club’s objections to the administrative

 2   record were due, SBA filed a motion to dismiss the appeal. Its stated basis for the motion was that it

 3   had, apparently, on February 20, 2024, withdrawn the FLRD that was the subject of the appeal

 4   because SBA determined that it was necessary to complete a further review of the loan.

 5            83.      That same day, without a response from Gold Club, OHA granted SBA’s motion and

 6   dismissed the appeal.

 7   Gold Club’s First Appeal to the OHA of SBA’s First FLRD Denying Forgiveness of its Second Draw

 8   PPP Loan

 9            84.      On or about April 22, 2022, Gold Club applied for forgiveness of its second draw

10   Loan. At all times during that forgiveness application process, Gold Club’s Lending Bank operated

11   as a delegate of the SBA in processing and approving/disapproving of forgiveness of Gold Club’s

12   second draw PPP Loan, and issued a forgiveness decision to SBA approving Gold Club’s loan

13   forgiveness application in the amount of $0.00. Gold Club, however, had applied for and qualified

14   for forgiveness in the amount of $1,993,233.75.

15            85.      While Gold Club was eligible for forgiveness of its second draw Loan, the SBA

16   conducted a review of Gold Club’s Loan and, on or about October 31, 2023, issued Gold Club an

17   FLRD denying Gold Club’s forgiveness application for its second draw PPP Loan because, despite

18   Gold Club’s obvious qualification for the Affiliation Exception Provisions, SBA concluded that Gold

19   Club was ineligible for the Loan for two reasons: 1) Gold Club was allegedly an ineligible business

20   concern providing prurient sexual material (and therefore precluded from eligibility by application

21   of the Prurience Regulation) and 2) Gold Club, together with the businesses SBA claims it is affiliated

22   with, exceeded the maximum allowable number of employees and the SBA’s small business size

23   standards.

24            86.      Gold Club timely appealed this FLRD.

25            87.      On December 12, 2023, Gold Club filed a motion for discovery seeking necessary

26   discovery in the form of document requests; a Fed. R. Civ. P. 30(b)(6) deposition of the SBA; a

27   deposition of Eric Benderson, SBA’s Associate General Counsel for Litigation who had, in previous

28
                                                18                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 19 of 169



 1   litigation, provided a declaration regarding how determinations are made under the Prurience

 2   Regulation; and the depositions of that person or those persons who made, or participated in any

 3   fashion in making, the decision to deny Plaintiff’s loan forgiveness application. This motion and

 4   other similar motions filed by other Plaintiffs in the OHA are discussed and attached to this First

 5   Amended Complaint, infra.

 6            88.      The next day, on December 13, 2023, OHA, sua sponte, denied that discovery motion,

 7   again, without any briefing from SBA.

 8            89.      On January 2, 2024, SBA filed the 920-page administrative record in that appeal. Gold

 9   Club and its staff, as well as its attorneys and accountants, began reviewing the 920-page

10   administrative record to determine whether objections were necessary and to prepare the same, if

11   necessary, which, pursuant to 13 C.F.R. § 134.1207 and the scheduling order in the appeal, were due

12   within 10 calendar days of SBA filing the administrative record.

13            90.      On January 8, 2024, Gold Club filed an unopposed motion for an extension of time

14   to January 24, 2024, to file its objections to the administrative record.

15            91.      The next day, on January 9, 2024, SBA filed a motion to dismiss the appeal. Its stated

16   basis for that motion was that it had, apparently, on January 3, 2024, withdrawn the FLRD that was

17   the subject of that appeal because SBA determined that it was necessary to complete a further review

18   of the Loan.

19            92.      That same day, without a response or an opportunity for a response from Gold Club,

20   OHA granted SBA’s motion and dismissed the appeal.

21   Gold Club’s Second Appeal to the OHA of SBA Denying Forgiveness of its Second Draw PPP Loan

22            93.      While Gold Club was eligible for forgiveness of its second draw Loan, the SBA
23   conducted a further review of Gold Club’s Loan and, on or about January 30, 2024, SBA issued a
24   second FLRD (the “Second FLRD”) regarding Gold Club’s second draw Loan. This FLRD denied
25   Gold Club’s forgiveness application for its second draw PPP Loan, this time denying forgiveness
26   based solely on SBA’s conclusion that Gold Club was an ineligible business providing prurient sexual
27   material. A true and accurate copy of this FLRD is attached hereto as Exhibit C.
28
                                                19                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 20 of 169



 1            94.      On or about February 29, 2024, Gold Club timely appealed the Second FLRD denying

 2   forgiveness of its second draw Loan seeking reversal of this FLRD (the “Appeal”).

 3            95.      In the Appeal petition of its second denial of forgiveness on its second draw Loan,

 4   Gold Club argued, among other things, that SBA’s decision was arbitrary and capricious for various

 5   reason including that it was not adequately explained, was not the product of reasoned decision

 6   making because it conflicts with the decision to award Gold Club’s second draw Loan in the first

 7   place, and it treats Gold Club differently than similarly situated businesses; that SBA revisiting the

 8   eligibility issue at the loan forgiveness stage conflicts with the PPP statute and is otherwise in excess

 9   of SBA’s jurisdiction/authority; that SBA lacks authority to provide a forgiveness amount different

10   from the sum of specific costs incurred and expenditures made during the Loan’s covered period; an

11   estoppel theory; and that SBA’s decision is violative of Gold Club’s constitutional rights.

12   Additionally, Gold Club argued that it should be entitled to its costs and fees, including attorneys’

13   fees, pursuant to the Administrative Procedures Act and the Equal Access to Justice Act. A true and

14   accurate copy of Gold Club’s second appeal petition of its second draw Loan is attached hereto as

15   Exhibit D.

16            96.      On or about March 25, 2024, SBA filed the 951-page administrative record in the

17   Appeal. Attached hereto as Exhibit E is a true and accurate copy of relevant excerpts from the

18   administrative record SBA filed in Gold Club’s second OHA appeal.

19            97.      Gold Club and its staff, as well as its attorneys and accountants, began reviewing the

20   951-page administrative record to determine whether objections thereto were necessary and, if so, to

21   prepare the same. Pursuant to 13 C.F.R. § 134.1207 and the scheduling order in the Appeal,

22   objections to the administrative record were due within 10 calendar days of SBA filing the

23   administrative record.

24            98.      After an extension of time, on April 23, 2024, Gold Club filed various objections to

25   the administration of record via a 17-page filing. Primarily, Gold Club objected to the redactions

26   contained in the admirative record as well as the absence of certain documents, notes, and research

27   referenced by SBA decision-makers in the administrative record that were not provided in the

28
                                                20                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 21 of 169



 1   administrative record. A true and accurate copy of Gold Club’s objections to the administrative record

 2   in the Appeal is attached hereto as Exhibit F.

 3            99.      Simultaneously, on April 23, 2024, Gold Club filed a 23-page motion for discovery

 4   with 1,685 pages of exhibits seeking necessary discovery in the form of document requests; a Fed.

 5   R. Civ. P. 30(b)(6) deposition of the SBA; a deposition of Eric Benderson, SBA’s Associate General

 6   Counsel for Litigation who had, in previous litigation, provided a declaration regarding how

 7   determinations are made under the Prurience Regulation; and the depositions of that person or those

 8   persons who made, or participated in any fashion in making, the decision to deny Plaintiff’s loan

 9   forgiveness application. A true and accurate copy of this discovery motion along with its exhibits are

10   attached hereto as Exhibit G. Gold Club also included the lack of documents responsive to these

11   discovery requests and the absence of a transcript of the Fed. R. Civ. P. 30(b)(6) deposition in its

12   objections to the administrative record in the Appeal.

13            100.     That same day, on April 23, 2024, OHA, sua sponte and without any response from

14   SBA, denied Gold Club’s discovery request stating that discovery is not permitted in appeals from

15   SBA final loan review decisions regarding PPP loans. A true and accurate copy of OHA’s order

16   denying Gold Club’s discovery motion in the Appeal is attached hereto as Exhibit H.

17            101.     On May 8, 2024, SBA responded to Gold Club’s Appeal.

18            102.     Included in its response was a Declaration from Sigmund Pannu (the “Pannu

19   Declaration” with Sigmund Pannu being “Pannu”), a Supervisory Loan Specialist in the Office of

20   Capital Access at SBA. The Pannu Declaration included numerous exhibits that were not included

21   in the administrative record in the Appeal, which Pannu declared were “the same as or consistent

22   with what I [he] reviewed during my [his] initial review of this loan prior to issuance of the final loan

23   review decision.” A true and accurate copy of SBA’s response to Gold Club’s Appeal, including the

24   Pannu Declaration with all exhibits and attachments thereto, is attached hereto as Exhibit I.

25            103.     In its response to Plaintiff’s Appeal, SBA relied on the “evidence” included in the

26   Pannu Declaration, which was not included in the administrative record. SBA argued, among other

27   things, that 1) Gold Club failed to state or argue that it does not present live performances of a

28
                                                21                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 22 of 169



 1   prurient sexual nature or that Gold Club does not derive more than de minimus revenue from services

 2   of a prurient sexual nature, 2) SBA cannot be bound by lender decisions, 3) SBA cannot be estopped

 3   from enforcing the law by an earlier decision, 4) SBA’s loan review of Gold Club’s eligibility for the

 4   Loan was consistent with the CARES Act and that SBA may review loans at any time, 5) SBA cannot

 5   be restricted under a promissory estoppel theory from denying loan forgiveness, 6) Gold Club cannot

 6   recover costs and fees before the OHA, and 7) OHA cannot adjudicate challenges to the

 7   constitutionality of SBA’s implementation of the CARES Act and EAA.

 8            104.     On May 10, 2024, Gold Club filed a Motion to Strike the Pannu Declaration and its

 9   exhibits and attachments in SBA’s response to Gold Club’s Appeal on, among other bases, the basis

10   that these items were not included in the administrative record and should have been and SBA cannot

11   add new evidence mid-appeal. See 13 C.F.R. § 134.1209. A true and accurate copy of Gold Club’s

12   Motion to Strike in the Appeal is attached hereto as Exhibit J.

13            105.     Four days later, on May 14, 2024, OHA issued an order affirming SBA’s FLRD in the

14   Appeal and denying as moot Gold Club’s motion to strike (the “May 14 Order,” which is attached

15   hereto as Exhibit K).

16            106.     The May 14 Order addressed Gold Club’s objections to the administrative record and

17   overruled each and every one of them. The May 14 Order also denied Gold Club’s Motion to Strike

18   the Pannu Declaration as moot. The May 14 Order also affirmed the Second FLRD issued regarding

19   Gold Club’s second draw Loan and concluded that Gold Club was eligible for the final forgiveness

20   amount of $0 and that the Second FLRD issued regarding Gold Club’s second draw Loan was not

21   based on clear error of fact or law.

22            107.     As to Gold Club’s constitutional claims and claims for costs and fees under the EAJA

23   raised in the Appeal, the May 14 Order stated that OHA “lack[s] authority to decide the[se] issues

24   raised by” Gold Club.

25            108.     The required 30 days for the May 14 Order to become final has lapsed and, therefore,

26   the OHA’s May 14 Order and SBA’s Second FLRD issued regarding Gold Club’s second draw Loan

27   is ripe for judicial review and this petition for the same is timely. 13 C.F.R. § 134.1211.

28
                                                22                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 23 of 169



 1             109.    Gold Club has exhausted its administrative remedies prior to filing this First Amended

 2   Complaint and petition for judicial review.

 3             110.    In light of OHA’s orders and regulations regarding the PPP, Gold Club has resumed

 4   making repayments on its second draw Loan.

 5             111.    If forced to repay its first and second draw PPP Loans, and because of the precarious

 6   financial condition in which it finds itself still as a result of the lingering impact of the Pandemic and

 7   the consequences thereof, Gold Club may be forced to file for reorganization through bankruptcy,

 8   which may preclude the Gold Club from presenting First Amendment protected entertainment in the

 9   future.

10   Dallas Food & Beverage, LLC (“Dallas Food and Beverage”)

11             112.    Dallas Food and Beverage is a licensed food and alcohol serving, nightclub open to
12   the consenting adult public, which presents on its premises a variety of non-obscene, constitutionally
13   protected, female performance dance entertainment.
14             113.    Dallas Food and Beverage has never been charged with, let alone convicted of, any
15   crimes of obscenity. Similarly, none of the entertainers who have performed on Dallas Food and
16   Beverage’s premises have ever been charged with, let alone convicted of, any crimes of obscenity
17   related to their performances at the facility owned and operated by Dallas Food and Beverage.
18             114.    Dallas Food and Beverage does not present any live performances, depictions or
19   displays, or sell any products or services, of a prurient sexual nature or that otherwise appeal to a
20   shameful, morbid, prurient, or unhealthy interest in sex.
21             115.    Dallas Food and Beverage operates it nightclub pursuant to, and in accordance with,
22   the following licenses/permits, which it maintains:
23                     a.     Dance Hall License issued by the City of Dallas;
24                     b.     A Liquor License issued by the State of Texas;
25                     c.     An Alcohol Permit issued by Dallas County
26                     d.     An Alcohol Permit issued by the City of Dallas; and
27                     e.     An Adult Cabaret License issued by the City of Dallas.
28
                                                23                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 24 of 169



 1            116.     As a consequence of the Pandemic, Dallas Food and Beverage was subject to various

 2   governmental closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As

 3   a direct and proximate result thereof, the lingering effects of the Pandemic, and the supply chain

 4   disruptions related thereto, Dallas Food and Beverage suffered, as did a large percentage of

 5   businesses throughout the United States, devastating and catastrophic financial losses.

 6            117.     In order to mitigate the financial impact caused to Dallas Food and Beverage by the

 7   Pandemic and the consequences thereof, including but not limited to its ability to retain and pay its

 8   employees, Dallas Food and Beverage submitted an application to its Lending Bank for a first draw

 9   PPP loan on or about April 7, 2020. At all times relevant hereto, Dallas Food and Beverage’s Lending

10   Bank operated as a delegate of the SBA in processing and approving/disapproving of the first draw

11   PPP loan sought by Dallas Food and Beverage.

12            118.     Under the PPP, Dallas Food and Beverage was eligible to obtain, and did obtain, a

13   first draw Loan.

14            119.     On or about July 8, 2021, Dallas Food and Beverage applied for loan forgiveness of

15   its first draw PPP loan. The Loan Proceeds amount that Dallas Food and Beverage applied for

16   forgiveness of for its first draw Loan, Dallas Food and Beverage used exclusively for the Permitted

17   Uses in full accordance with the PPP and its Loan Agreement. Consequently, it no longer possesses

18   any of the Loan Proceeds from its first draw Loan.

19            120.     On April 15, 2022, Dallas Food and Beverage received forgiveness of the full amount

20   of forgiveness requested on its first draw PPP Loan.

21            121.     On or about January 30, 2024, via letter, SBA notified Dallas Food and Beverage that

22   it was initiating a Post-Payment Review of Dallas Food and Beverage’s first draw PPP Loan and

23   requested that Dallas Food and Beverage provide a number of documents. The stated purpose for

24   SBA’s requests via the Post-Payment Review was to review whether Dallas Food and Beverage was

25   eligible for the PPP Loan under, among other factors, the Prurience Regulation and Affiliation Rules

26            122.     Because Dallas Food and Beverage operates an alcohol serving nightclub under the

27   licenses/permits identified in paragraph 115, it is, for purposes of the PPP and the Affiliation Rules,

28
                                                24                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 25 of 169



 1   a NAICS code 72 business.

 2            123.     Dallas Food and Beverage claimed NAICS Code 722410 on its first draw PPP loan

 3   forgiveness application, the SBA Form 3511, its second draw PPP loan application, and its second

 4   draw PPP loan forgiveness application.

 5            124.     At all times related to the relevant period for its first and second draw PPP Loans,

 6   Dallas Food and Beverage had no more than 113 persons employed at its physical location.

 7            125.     Under the PPP, Dallas Food and Beverage was eligible to obtain and did obtain a

 8   second draw PPP Loan.

 9            126.     The Loan Proceeds amount that Dallas Food and Beverage applied for forgiveness of

10   for its second draw Loan, Dallas Food and Beverage used exclusively for the Permitted Uses in full

11   accordance with the PPP and its Loan Agreement. Consequently, it no longer possesses any of the

12   Loan Proceeds from its second draw Loan.

13            127.     On or about May 24, 2022, Dallas Food and Beverage applied for forgiveness of its

14   second draw PPP Loan. At all times during that forgiveness application process, Dallas Food and

15   Beverage’s Lending Bank operated as a delegate of the SBA in processing and

16   approving/disapproving of forgiveness of Dallas Food and Beverage’s second draw PPP Loan, and

17   issued a forgiveness decision to SBA approving Dallas Food and Beverage’s loan forgiveness

18   application in the amount of $889,157.00.

19            128.     While Dallas Food and Beverage was eligible for forgiveness of its second draw PPP

20   Loan, the SBA conducted a review of Dallas Food and Beverage’s Loan and denied forgiveness in

21   an FLRD dated December 14, 2023. The claimed bases for the denial were due to alleged “size

22   issues” based on SBA’s application of the Affiliation Rules despite Dallas Food and Beverage’s

23   obvious qualification for the Affiliation Exception Provisions and alleged ineligibility due to SBA’s

24   application of the Prurience Regulation. Dallas Food and Beverage timely appealed that FLRD, but

25   SBA filed a motion to dismiss on February 29, 2024, that was granted by the OHA the same day.

26            129.     If forced to repay its second draw PPP Loan, and because of the precarious financial

27   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

28
                                                25                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24     Page 26 of 169



 1   consequences thereof, Dallas Food and Beverage may be forced to close its business and file for

 2   bankruptcy, which would result in the cessation of both the presentation of and the ability to view

 3   entertainment that is presumptively protected under the First Amendment to the United States

 4   Constitution, as well as the wholesale termination of its employees jobs; which the PPP was in fact

 5   designed to preclude from happening.

 6   2345 Meacham, LLC (“Meacham”)

 7            130.     Meacham is a licensed food and alcohol serving, nightclub open to the consenting
 8   adult public, which presents on its premises a variety of non-obscene, constitutionally protected,
 9   female performance dance entertainment.
10            131.     Meacham has never been charged with, let alone convicted of, any crimes of
11   obscenity. Similarly, none of the entertainers who have performed on Meacham’s premises have ever
12   been charged with, let alone convicted of, any crimes of obscenity related to their performances at
13   the facility owned and operated by Meacham.
14            132.     Meacham does not present any live performances, depictions or displays, or sell any
15   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,
16   prurient, or unhealthy interest in sex.
17            133.     Meacham operates it nightclub pursuant to, and in accordance with, the following
18   licenses/permits, which it maintains:
19                     a.     A Specialized Certificate of Occupancy;
20                     b.     A Liquor Permit issued by Tarrant County;
21                     c.     A Liquor Permit issued by the City of Forth Worth;
22                     d.     A health permit issued by the City of Forth Worth; and
23                     e.     Alcoholic Beverage Permit issued by the Texas Alcoholic Beverage
24            Commission.
25            134.     As a consequence of the Pandemic, Meacham was subject to various governmental
26   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and
27   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions
28
                                                26                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 27 of 169



 1   related thereto, Meacham suffered, as did a large percentage of businesses throughout the United

 2   States, devastating and catastrophic financial losses.

 3            135.     In order to mitigate the financial impact caused to Meacham by the Pandemic and the

 4   consequences thereof, including but not limited to its ability to retain and pay its employees,

 5   Meacham applied for, obtained, and obtained forgiveness of, a first draw PPP loan. Meacham also

 6   submitted an application its Lending Bank for a second draw PPP loan on or about March 9, 2021.

 7   At all times relevant hereto, Meacham’s Lending Bank operated as a delegate of the SBA in

 8   processing and approving/disapproving of the second draw PPP loan sought by Meacham.

 9            136.     Because Meacham operates a licensed food and alcohol-serving nightclub under the

10   licenses and permits identified in paragraph 133, it is, for purposes of the PPP and the Affiliation

11   Rules, a NAICS code 72 business. Since at least 2013, Meacham has claimed NAICS code 722410

12   as its “business activity code number” on its federal income tax returns, and claimed NAICS code

13   722410.

14            137.     At all times related to the relevant period for its second draw PPP loan, Meacham had

15   no more than 118 persons employed at its physical location.

16            138.     Under the PPP, Meacham was eligible to obtain its second draw Loan and received

17   its second draw Loan.

18            139.     The Loan Proceeds amount that Meacham applied for forgiveness of for its second

19   draw Loan, Meacham used exclusively for the Permitted Uses in full accordance with the PPP and

20   its Loan Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its second

21   draw Loan.

22            140.     On or about April 15, 2022, Meacham applied for forgiveness of its second draw PPP

23   Loan. At all times during that forgiveness application process, Meacham’s Lending Bank operated

24   as a delegate of the SBA in processing and approving/disapproving of forgiveness of Meacham’s

25   second draw PPP Loan, and issued a forgiveness decision to SBA approving Meacham’s loan

26   forgiveness application in the amount of $760,910.00.

27   Meacham’s Second Appeal to the OHA of SBA’s FLRD Denying Forgiveness of its Second Draw PPP

28
                                                27                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 28 of 169



 1   Loan

 2            141.     While Meacham was eligible for forgiveness of its second draw PPP Loan, the SBA

 3   conducted a review of Meacham’s Loan, on or about June 21, 2023, issued Meacham an FLRD

 4   denying Meacham’s forgiveness application for its second draw PPP Loan because SBA had

 5   concluded that Meacham did not meet the size standards for the PPP or that SBA could not otherwise

 6   determine whether Meacham met the size standards despite Meacham’s obvious qualification for the

 7   Affiliation Exception Provisions.

 8            142.     Meacham timely appealed that FLRD.

 9            143.     Shortly thereafter, Meacham and SBA filed a stipulated request to stay the appeal,

10   which the OHA granted a few days later.

11            144.     On September 13, 2023, SBA filed a motion to dismiss. Its stated basis for the motion

12   was that it had, apparently that same day, withdrawn the FLRD that was the subject of that appeal

13   because SBA determined that it was necessary to complete a further review of the loan.

14            145.     That same day, without a response from Meacham, OHA granted SBA’s motion and

15   dismissed the appeal.

16   Meacham’s Second Appeal to the OHA of SBA’s FLRD Denying Forgiveness of its Second Draw PPP

17   Loan

18            146.     While Meacham was eligible for forgiveness of its second draw PPP Loan, the SBA

19   conducted a review of Meacham’s Loan, on or about December 28, 2023, issued Meacham an FLRD

20   this time denying Meacham’s forgiveness application for its second draw PPP Loan based on alleged

21   ineligibility due to SBA’s application of the Prurience Regulation as its sole basis for the denial.

22            147.     Meacham timely appealed that FLRD to the OHA.

23            148.     On or about February 20, 2024, SBA filed a 458-page administrative record in that

24   appeal, relevant excerpts of that administrative record are attached hereto as Exhibit L.

25            149.     Meacham and its staff, as well as its attorneys, began reviewing the 458-page

26   administrative record to determine whether objections were necessary and to prepare the same if

27   necessary, which, pursuant to 13 C.F.R. § 134.1207 and the scheduling order in the appeal, were due

28
                                                28                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 29 of 169



 1   within 10 calendar days of SBA filing the administrative record.

 2            150.     On page 17 of Meacham’s administrative record, the second entry on the “SBA

 3   Internal Notes” record was made by Sara Renn on June 24, 2022, states that, based on “internet

 4   presence as viewed on www.bucksclubs.com/bucks-cabaret/fort-worth,” Meacham “operates as a

 5   ‘Gentlemen’s Club,” which is confirmed through open-source searches of the borrower’s business,”

 6   which is then followed by a redaction. [Id. at p. 19]. Later, on April 24, 2023, Sharon Drake stated

 7   that Meacham was an “ineligible business” based on “[a] visual search of Google (Addendum B)

 8   determined these businesses to be adult entertainment clubs, or of a prurient nature.” [Id. at p. 18].

 9            151.     On or about February 27, 2024, Meacham filed a 25-page motion for discovery

10   accompanied by 1,669 pages of exhibits seeking necessary discovery in the form of document

11   requests; a Fed. R. Civ. P. 30(b)(6) deposition of the SBA; a deposition of Eric Benderson, SBA’s

12   Associate General Counsel for Litigation who had, in previous litigation, provided a declaration

13   regarding how determinations are made under the Prurience Regulation; and the depositions of that

14   person or those persons who made, or participated in any fashion in making, the decision to deny

15   Plaintiff’s loan forgiveness application. This motion and other similar motions filed by other

16   Plaintiffs in the OHA are discussed and attached to this First Amended Complaint, infra.

17            152.     On March 7, 2024, Meacham filed various objections to the administrative record,

18   including an objection to the presence of redactions in the administrative record. On March 12, 2024,

19   SBA responded to Meacham’s objections. On March 18, 2024, the OHA judge ruled on those

20   objections and ordered SBA to state the privilege asserted for the redactions. A true and accurate

21   copy of the OHA’s order referenced earlier is attached hereto as Exhibit M.

22            153.     On March 20, 2024, SBA filed a Motion to Reconsider the OHA’s order on the

23   objections to the administrative record. Therein, SBA asserted that the redacted materials were

24   irrelevant and were privileged pursuant to 5 U.S.C. § 552(b)(7). A true and accurate copy of SBA’s

25   reconsideration motion is attached hereto as Exhibit N. On April 19, 2024, Meacham responded to

26   SBA’s reconsideration motion.

27            154.     On April 26, 2024, SBA filed its response to Meacham’s appeal, complete with a

28
                                                29                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 30 of 169



 1   declaration from Sigmund Pannu which attached additional “evidence” SBA claims it relied upon

 2   but which was not included in the administrative record. A true and accurate copy of that response is

 3   attached hereto as Exhibit O. Therein, SBA argues that the open-source searches referenced above

 4   was “SBA’s effort to describe by polite means the nature of Appellant’s business and more

 5   specifically the nature of its performances[.]”

 6            155.     Based on SBA’s response, on April 27, 2024, the OHA ordered the parties to meet and

 7   confer and submit a joint status report no later than May 10, 2024. One of the items the OHA ordered

 8   the parties to discuss was whether “the parties agree that the documents in the affiant’s exhibits are

 9   the same as or consistent with what SBA reviewed prior to December 28, 2023?” A true and accurate

10   copy of this order is attached hereto as Exhibit P.

11            156.     On May 6, 2024, OHA counsel for Meacham met and conferred with SBA’s OHA

12   counsel. SBA’s OHA counsel stated that the exhibits found in Sigmund Pannu’s declaration would

13   be added to the administrative record either through stipulation as the OHA judge requested in order

14   to allow the appeal to proceed or the SBA would withdraw the FLRD, include the exhibits from

15   Pannu’s declaration into the AR, and reissue the FLRD on the same basis as the one under appeal.

16            157.     On or about May 10, 2024, SBA and Meacham filed a joint status report, which is

17   attached hereto as Exhibit Q.

18            158.     On May 14, 2024, OHA issued an order granting Meacham’s appeal and remanding

19   the FLRD. OHA concluded that Meacham was correct that the materials attached to Sigmund

20   Pannu’s declaration were not found in the administrative record and was without a firm conviction

21   that SBA’s FLRD is free from clear error. A true and accurate copy of this OHA order is attached

22   hereto as Exhibit R.

23            159.     If forced to repay its second draw PPP Loans, and because of the precarious financial

24   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

25   consequences thereof, Meacham may be forced to close its business and file for bankruptcy, which

26   would result in the cessation of both the presentation of and the ability to view entertainment that is

27   presumptively protected under the First Amendment to the United States Constitution, as well as the

28
                                                30                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18           Filed 10/10/24    Page 31 of 169



 1   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

 2   happening.

 3   11000 Reeder, LLC (“Reeder”)

 4            160.     Reeder is a licensed food serving and BYOB, nightclub open to the consenting adult
 5   public, which presents on its premises a variety of non-obscene, constitutionally protected, female
 6   performance dance entertainment.
 7            161.     Reeder has never been charged with, let alone convicted of, any crimes of obscenity.
 8   Similarly, none of the entertainers who have performed on Reeder’s premises have ever been charged
 9   with, let alone convicted of, any crimes of obscenity related to their performances at the facility
10   owned and operated by Reeder.
11            162.     Reeder does not present any live performances, depictions or displays, or sell any
12   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,
13   prurient, or unhealthy interest in sex.
14            163.     Reeder operates it nightclub pursuant to, and in accordance with, the following
15   licenses/permits, which it maintains:
16                     a.     A Sexually Oriented Business License;
17                     b.     A Health Permit issued by the City of Dallas;
18                     c.     A Dance Hall license; and
19                     d.     A certificate of occupancy.
20            164.     As a consequence of the Pandemic, Reeder was subject to various governmental
21   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and
22   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions
23   related thereto, Reeder suffered, as did a large percentage of businesses throughout the United States,
24   devastating and catastrophic financial losses.
25            165.     In order to mitigate the financial impact caused to Reeder by the Pandemic and the
26   consequences thereof, including but not limited to its ability to retain and pay its employees, Reeder
27   submitted an application to its Lending Bank for a first draw PPP loan on or about April 3, 2020. At
28
                                                31                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 32 of 169



 1   all times relevant hereto, Reeder’s Lending Bank operated as a delegate of the SBA in processing

 2   and approving/disapproving of the first draw PPP loan sought by Reeder.

 3            166.     In order to further mitigate the financial impact caused to Reeder by the Pandemic

 4   and the consequences thereof, including but not limited to its ability to retain and pay its employees,

 5   Reeder submitted an application to its Lending Bank for a second draw PPP loan on or about January

 6   14, 2021. At all times relevant hereto, Reeder’s Lending Bank operated as a delegate of the SBA in

 7   processing and approving/disapproving of the second draw PPP loan sought by Reeder.

 8            167.     Because Reeder operates a licensed food serving nightclub under the licenses/permits

 9   identified in paragraph 163, it is, and was at all times relevant to the PPP, for purposes of the PPP

10   and the Affiliation Rules, a NAICS code 72 business.

11            168.     Reeder claimed NAICS code 722410 on its first draw PPP loan forgiveness

12   application, the SBA Form 3511, its second draw PPP Loan application, and its second draw PPP

13   loan forgiveness application.

14            169.     On or about December 28, 2020, Reeder applied for loan forgiveness of its first draw

15   PPP loan. The Loan Proceeds amount that Reeder applied for forgiveness of for its first draw Loan,

16   Reeder used exclusively for the Permitted Uses in full accordance with the PPP and its Loan

17   Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

18            170.     On or about February 18, 2021, Reeder received forgiveness of the full amount of

19   forgiveness requested on its first draw PPP Loan.

20            171.     On or about November 17, 2021, Reeder applied for loan forgiveness of its second

21   draw PPP Loan. The Loan Proceeds amount that Reeder applied for forgiveness of for its second

22   draw Loan, Reeder used exclusively for the Permitted Uses in full accordance with the PPP and its

23   Loan Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its second

24   draw Loan.

25            172.     On or about November 24, 2021, Reeder received forgiveness of the full amount of

26   forgiveness requested on its second draw PPP Loan.

27            173.     On or about January 29, 2023, via separate letters, SBA notified Reeder that it was

28
                                                32                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 33 of 169



 1   initiating a Post-Payment Review of Reeder’s first and second draw PPP Loans and requested that

 2   Reeder provide a number of documents. The stated purpose for SBA’s requests via the Post-Payment

 3   Review was to review whether Reeder was eligible for the PPP Loan under, among other factors, the

 4   Prurience Regulation and Affiliation Rules.

 5            174.     At all times related to the relevant period for its first and second draw PPP Loans,

 6   Reeder had no more than 57 persons employed at its physical location.

 7            175.     If forced to repay its first and second draw PPP Loans, and because of the precarious

 8   financial condition in which it finds itself still as a result of the lingering impact of the Pandemic and

 9   the consequences thereof, Reeder may be forced to close its business and file for bankruptcy, which

10   would result in the cessation of both the presentation of and the ability to view entertainment that is

11   presumptively protected under the First Amendment to the United States Constitution, as well as the

12   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

13   happening.

14   S.A.W. Entertainment, Ltd. (“SAW”)

15            176.     SAW is a licensed food and alcohol serving, bar/restaurant/nightclub open to the

16   consenting adult public, which presents on its premises a variety of non-obscene, constitutionally

17   protected, female performance dance entertainment.

18            177.     SAW has never been charged with, let alone convicted of, any crimes of obscenity.

19   Similarly, none of the entertainers who have performed on SAW’s premises have ever been charged

20   with, let alone convicted of, any crimes of obscenity related to their performances at the facility

21   owned and operated by SAW.

22            178.     SAW does not present any live performances, depictions or displays, or sell any

23   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

24   prurient, or unhealthy interest in sex.

25            179.     SAW operates it nightclub pursuant to, and in accordance with, the following

26   licenses/permits, which it maintains:

27                     a.     H26/11579 License Certificate issued by the City of San Francisco that

28
                                                33                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 34 of 169



 1            describes SAW as an H26 Restaurant over 2,000 SQ;

 2                     b.     Alcoholic Beverage License issued by the State of California Department of

 3            Alcoholic Beverage Control;

 4                     c.     Live entertainment permit; and

 5                     d.     Extended hours permit.

 6            180.     As a consequence of the Pandemic, SAW was subject to various governmental

 7   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

 8   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

 9   related thereto, SAW suffered, as did a large percentage of businesses throughout the United States,

10   devastating and catastrophic financial losses.

11            181.     In order to mitigate the financial impact caused to SAW by the Pandemic and the

12   consequences thereof, including but not limited to its ability to retain and pay its employees, SAW

13   submitted an application to its Lending Bank for a first draw PPP loan on or about April 14, 2020.

14   At all times relevant hereto, SAW’s Lending Bank operated as a delegate of the SBA in processing

15   and approving/disapproving of the first draw PPP loan sought by SAW.

16            182.     Because SAW operates a licensed food and alcohol-serving nightclub under the

17   licenses/permits identified in paragraph 179, it is, for purposes of the PPP and the Affiliation Rules,

18   a NAICS code 72 business. Since at least 2016, SAW has claimed NAICS code 722410 as its

19   “business activity code number” on its federal income tax returns, and claimed NAICS code 722410

20   its SBA Form 3511.

21            183.     At all times related to the relevant period for its first draw PPP Loan, SAW had no

22   more than 163 persons employed at its physical location.

23            184.     Under the PPP, SAW was eligible to obtain its first draw Loan and it received its first

24   draw Loan.

25            185.     The Loan Proceeds amount that SAW applied for forgiveness of for its first draw

26   Loan, SAW used exclusively for the Permitted Uses in full accordance with the PPP and its Loan

27   Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

28
                                                34                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24    Page 35 of 169



 1   SAW’s First Appeal to the OHA of SBA’s First FLRD Denying Forgiveness of its First Draw PPP

 2   Loan

 3            186.     On or about November 12, 2021, SAW applied for forgiveness of its first draw PPP

 4   Loan. At all times during that forgiveness application process, SAW’s Lending Bank operated as a

 5   delegate of the SBA in processing and approving/disapproving of forgiveness of SAW’s first draw

 6   PPP Loan, and issued a forgiveness decision to SBA approving SAW’s loan forgiveness application

 7   in the amount of $222,800.19.

 8            187.     While SAW was eligible for forgiveness of its first draw Loan, the SBA conducted a

 9   review of SAW’s Loan, and on or about October 31, 2023, issued SAW an FLRD denying SAW’s

10   forgiveness application of its first draw PPP Loan because, despite SAW’s obvious qualification for

11   the Affiliation Exception Provisions, SBA concluded that SAW was ineligible for the Loan on the

12   sole basis that SAW, together with the businesses SBA claims it is affiliated with, exceeded the

13   maximum number of employees of 500 for PPP first draw Loans. A true and accurate copy of this

14   FLRD is attached hereto as Exhibit S.

15            188.     SAW timely appealed this FLRD

16            189.     On December 13, 2023, SAW filed a 13-page discovery motion accompanied by 27-

17   pages of exhibits seeking necessary discovery in the form of document requests; a Fed. R. Civ. P.

18   30(b)(6) deposition of the SBA; a deposition of Eric Benderson, SBA’s Associate General Counsel

19   for Litigation who had, in previous litigation, provided a declaration regarding how determinations

20   are made under the Prurience Regulation; and the depositions of that person or those persons who

21   made, or participated in any fashion in making, the decision to deny Plaintiff’s loan forgiveness

22   application. This motion and other similar motions filed by other Plaintiffs in the OHA are discussed

23   and attached to this First Amended Complaint, infra.

24            190.     That same day, December 13, 2023, OHA, sua sponte, denied that discovery motion

25   without any briefing from SBA.

26            191.     On January 2, 2024, SBA filed a 6,206-page administrative record in that appeal.

27   SAW and its staff, as well as its attorneys and accountants, began reviewing the 6,206-page

28
                                                35                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24     Page 36 of 169



 1   administrative record to determine whether objections were necessary and to prepare the same, if

 2   necessary, which, pursuant 13 C.F.R. § 134.1207 and the scheduling order in the appeal, were due

 3   within 10 calendar days of SBA filing the administrative record. True and accurate excerpts (pages

 4   3542, 3547, 3550, and 3553-55) from this administrative record are attached hereto as Exhibit T.

 5            192.     On January 8, 2024, SAW filed an unopposed motion for an extension of time to

 6   January 24, 2024, to file its objections to the administrative record, which was granted the same day.

 7            193.     On January 10, 2024, SBA filed a motion to dismiss the appeal. Its stated basis for

 8   that motion was that it had, apparently, that same day (January 10, 2024), withdrawn the FLRD that

 9   was the subject of that appeal because SBA determined that it was necessary to complete a further

10   review of the Loan.

11            194.     That same day, without a response or an opportunity for a response from SAW, Judge

12   Richard Ambrow granted SBA’s motion and dismissed the appeal.

13   SAW’s Second Appeal to the OHA of SBA Denying SAW Forgiveness of its First Draw PPP Loan

14            195.     While SAW was eligible for its first draw PPP Loan, SBA conducted a further review

15   of SA’'s Loan and, on or about January 30, 2024, SBA issued a second FLRD denying SAW’s first

16   draw Loan. This FLRD denied SAW’s forgiveness application for its first draw PPP Loan, this time

17   denying forgiveness based solely on SBA’s conclusion that SAW was an ineligible business

18   providing prurient sexual material.

19            196.     SAW timely appealed this second FLRD denying forgiveness of its first draw PPP

20   Loan.

21            197.     In the Appeal petition of its second denial of forgiveness on its second draw Loan,

22   SAW argued, among other things, that SBA’s decision was arbitrary and capricious for various reason

23   including that it was not adequately explained, was not the product of reasoned decision making

24   because it conflicts with the decision to award SAW’s first draw Loan in the first place, and it treats

25   SAW differently than similarly situated businesses; that SBA revisiting the eligibility issue at the

26   loan forgiveness stage conflicts with the PPP statute and is otherwise in excess of SBA’s

27   jurisdiction/authority; that SBA lacks authority to provide a forgiveness amount different from the

28
                                                36                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 37 of 169



 1   sum of specific costs incurred and expenditures made during the Loan’s covered period; an estoppel

 2   theory; and that SBA’s decision is violative of SAW’s constitutional rights. Additionally, SAW argued

 3   that it should be entitled to its costs and fees, including attorneys’ fees, pursuant to the Administrative

 4   Procedures Act and the Equal Access to Justice Act.

 5            198.     On or about May 20, 2024, SBA filed a motion to dismiss the appeal. Its stated basis

 6   for that motion was that it had, apparently, on May 17, 2024, withdrawn the FLRD that was the

 7   subject of that appeal because SBA determined that it was necessary to complete a further review of

 8   the Loan.

 9            199.     That same day, OHA ordered SAW to respond to the motion to dismiss no later than

10   June 4, 2024, which SAW did.

11            200.     On June 21, 2024, OHA dismissed SAW’s OHA appeal.

12            201.     On June 28, 2024, SAW timely filed for reconsideration of that decision. SBA

13   responded on July 11, 2024, and OHA denied reconsideration the next day on July 12, 2024. A true

14   and accurate copy of the OHA’s order denying reconsideration is attached hereto as Exhibit U.

15            202.     If forced to repay its first draw PPP Loan, and because of the precarious financial

16   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

17   consequences thereof, SAW may be forced to file for reorganization through bankruptcy , which may

18   preclude the SAW from presenting First Amendment protected entertainment in the future.

19   Smithville Bistro, LLC (“Smithville”)

20            203.     Smithville is a licensed alcohol serving nightclub open to the consenting adult public,

21   which presents on its premises a variety of non-obscene, constitutionally protected, female

22   performance dance entertainment.

23            204.     Smithville has never been charged with, let alone convicted of, any crimes of

24   obscenity. Similarly, none of the entertainers who have performed on Smithville’s premises have

25   ever been charged with, let alone convicted of, any crimes of obscenity related to their performances

26   at the facility owned and operated by Smithville.

27            205.     Smithville does not present any live performances, depictions or displays, or sell any

28
                                                37                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 38 of 169



 1   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

 2   prurient, or unhealthy interest in sex.

 3            206.     Smithville operates it nightclub pursuant to, and in accordance with, the following

 4   licenses/permits, which it maintains: Beer Permit issued by the County of DeKalb, Tennessee;

 5            207.     As a consequence of the Pandemic, Smithville was subject to various governmental

 6   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

 7   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

 8   related thereto, Smithville suffered, as did a large percentage of businesses throughout the United

 9   States, devastating and catastrophic financial losses.

10            208.     In order to mitigate the financial impact caused to Smithville by the Pandemic and

11   the consequences thereof, including but not limited to its ability to retain and pay its employees,

12   Smithville submitted an application to its Lending Bank for a second draw PPP loan on or about

13   February 14, 2021. At all times relevant hereto, Smithville’s Lending Bank operated as a delegate of

14   the SBA in processing and approving/disapproving of the second draw PPP loan sought by

15   Smithville.

16            209.     Because Smithville operates a licensed alcohol-serving nightclub under the

17   license/permit identified in paragraph 206, it is, for purposes of the PPP and the Affiliation Rules, a

18   NAICS code 72 business. Smithville has also claimed NAICS code 722410 on its first draw PPP

19   loan forgiveness application, the SBA Form 3511, its second draw PPP Loan application, and its

20   second draw PPP loan forgiveness application.

21            210.     Smithville applied for and obtained a first draw PPP loan. Smithville obtained partial

22   loan forgiveness of its first draw PPP loan pursuant to a settlement agreement it entered into with the

23   SBA.

24            211.     At all times related to the relevant period for its second draw PPP Loan, Smithville

25   had no more than 11 persons employed at its physical location.

26            212.     Under the PPP, Smithville was eligible to obtain its second draw Loan and it received

27   its second draw Loan.

28
                                                38                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 39 of 169



 1            213.     The Loan Proceeds amount that Smithville applied for forgiveness of for its second

 2   draw Loan, Smithville used exclusively for the Permitted Uses in full accordance with the PPP and

 3   its Loan Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its second

 4   draw Loan.

 5            214.     On or about May 16, 2022, Smithville applied for forgiveness of its second draw PPP

 6   Loan. At all times during that forgiveness application process, Smithville’s Lending Bank operated

 7   as a delegate of the SBA in processing and approving/disapproving of forgiveness of Smithville’s

 8   second draw PPP Loan, and issued a forgiveness decision to SBA approving Smithville’s loan

 9   forgiveness application in the amount of $38,871.00.

10            215.     While Smithville was eligible for forgiveness of its second draw PPP Loan, the SBA

11   conducted a review of Smithville’s Loan and denied forgiveness in an FLRD dated December 14,

12   2023. The claimed basis for the denial was due to alleged “size issues” based on SBA’s application

13   of the Affiliation Rules despite Smithville’s obvious qualification for the Affiliation Exception

14   Provisions, and alleged ineligibility due to SBA’s application of the Prurience Regulation. Smithville

15   timely appealed that FLRD to the OHA and that appeal remains pending.

16            216.     If forced to repay its second draw PPP Loan, and because of the precarious financial

17   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

18   consequences thereof, Smithville may be forced to close its business and file for bankruptcy, which

19   would result in the cessation of both the presentation of and the ability to view entertainment that is

20   presumptively protected under the First Amendment to the United States Constitution, as well as the

21   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

22   happening.

23   Deja Vu Showgirls of Las Vegas, LLC (“DVSG of LV”)

24            217.     DVSG of LV is a licensed alcohol serving nightclub and service bar open to the

25   consenting adult public, which presents on its premises a variety of non-obscene, constitutionally

26   protected, female performance dance entertainment.

27            218.     DVSG of LV has never been charged with, let alone convicted of, any crimes of

28
                                                39                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24     Page 40 of 169



 1   obscenity. Similarly, none of the entertainers who have performed on DVSG of LV’s premises have

 2   ever been charged with, let alone convicted of, any crimes of obscenity related to their performances

 3   at the facility owned and operated by DVSG of LV.

 4            219.     DVSG of LV does not present any live performances, depictions or displays, or sell

 5   any products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

 6   prurient, or unhealthy interest in sex.

 7            220.     DVSG of LV operates it nightclub pursuant to, and in accordance with, the following

 8   licenses/permits, which it maintains:

 9                     a.     Business License Adult Book / Video Sales Rental issued by Clark County,

10            Nevada;

11                     b.     Business License Adult Entertainment Cabaret issued by Clark County,

12            Nevada;

13                     c.     Business License Adult Novelty issued by Clark County, Nevada;

14                     d.     Business License Amusement Machines issued by Clark County, Nevada;

15                     e.     Business License Book Sales issued by Clark County, Nevada;

16                     f.     Business License Erotic Dance Establishment issued by Clark County,

17            Nevada; and

18                     g.     Quarterly Liquor License issued by Clark County, Nevada.

19            221.     As a consequence of the Pandemic, DVSG of LV was subject to various governmental

20   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

21   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

22   related thereto, DVSG of LV suffered, as did a large percentage of businesses throughout the United

23   States, devastating and catastrophic financial losses.

24            222.     In order to mitigate the financial impact caused to DVSG of LV by the Pandemic and

25   the consequences thereof, including but not limited to its ability to retain and pay its employees,

26   DVSG of LV submitted an application to its Lending Bank for a second draw PPP loan on or about

27   February 5, 2021. At all times relevant hereto, DVSG of LV’s Lending Bank operated as a delegate

28
                                                40                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 41 of 169



 1   of the SBA in processing and approving/disapproving of the second draw PPP loan sought by DVSG

 2   of LV.

 3            223.     Because DVSG of LV operates a licensed alcohol-serving nightclub under the

 4   licenses/permits identified in paragraph 220, it is, for purposes of the PPP and the Affiliation Rules,

 5   a NAICS code 72 business. DVSG of LV has also claimed NAICS code 722410 on its first draw PPP

 6   loan forgiveness application, the SBA Form 3511, and its second draw PPP Loan application.

 7            224.     DVSG of LV applied for and obtained a first draw PPP loan. DVSG of LV obtained

 8   partial loan forgiveness of its first draw PPP loan pursuant to a settlement agreement it entered into

 9   with the SBA.

10            225.     At all times related to the relevant period for its second draw PPP Loan, DVSG of LV

11   had no more than 72 persons employed at its physical location.

12            226.     Under the PPP, DVSG of LV was eligible to obtain its second draw Loan and it

13   received its second draw Loan.

14            227.     The Loan Proceeds amount that DVSG of LV applied for forgiveness of for its second

15   draw Loan, DVSG of LV used exclusively for the Permitted Uses in full accordance with the PPP

16   and its Loan Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its

17   second draw Loan.

18            228.     On or about July 6, 2022, DVSG of LV applied for forgiveness of its second draw

19   PPP Loan. At all times during that forgiveness application process, DVSG of LV’s Lending Bank

20   operated as a delegate of the SBA in processing and approving/disapproving of forgiveness of DVSG

21   of LV’s second draw PPP Loan, and issued a forgiveness decision to SBA approving DVSG of LV’s

22   loan forgiveness application in the amount of $313,605.98.

23            229.     While DVSG of LV was eligible for forgiveness of its second draw PPP Loan, the

24   SBA conducted a review of DVSG of LV’s Loan and denied forgiveness in an FLRD dated December

25   14, 2023. The claimed basis for the denial was due to alleged “size issues” based on SBA’s

26   application of the Affiliation Rules despite DVSG of LV’s obvious qualification for the Affiliation

27   Exception Provisions, and alleged ineligibility due to SBA’s application of the Prurience Regulation.

28
                                                41                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 42 of 169



 1   DVSG of LV timely appealed that FLRD to the OHA and that appeal remains pending.

 2            230.     If forced to repay its second draw PPP Loan, and because of the precarious financial

 3   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

 4   consequences thereof, DVSG of LV may be forced to close its business and file for bankruptcy, which

 5   would result in the cessation of both the presentation of and the ability to view entertainment that is

 6   presumptively protected under the First Amendment to the United States Constitution, as well as the

 7   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

 8   happening.

 9   Office Minneapolis, LLC (“Office”)

10            231.     Office is a licensed alcohol serving bar and grill open to the consenting adult public.

11            232.     Office does not present any live performances, depictions or displays, or sell any

12   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

13   prurient, or unhealthy interest in sex

14            233.     Office operates its bar and grill pursuant to, and in accordance with, the following

15   licenses/permits, which it maintains:

16                     a.     Two Liquor Permits issued by the City of Minneapolis;

17                     b.     A Liquor Permit allowing Office to close at 2 am; and

18                     c.     A retail buyer’s card for liquor.
19            234.     As a consequence of the Pandemic, Office was subject to various governmental

20   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

21   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

22   related thereto, Office suffered, as did a large percentage of businesses throughout the United States,

23   devastating and catastrophic financial losses.

24            235.     In order to mitigate the financial impact caused to Office by the Pandemic and the

25   consequences thereof, including but not limited to its ability to retain and pay its employees, Office

26   submitted an application to its Lending Bank for a first draw PPP loan on or about April 7, 2020. At

27   all times relevant hereto, Office’s Lending Bank operated as a delegate of the SBA in processing and

28
                                                42                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 43 of 169



 1   approving/disapproving of the first draw PPP loan sought by Office.

 2            236.     Because Office operates a licensed alcohol-serving bar and grill under the

 3   licenses/permits identified in paragraph 233, it is, and was at all times relevant to the PPP, for

 4   purposes of the PPP and the Affiliation Rules, a NAICS code 72 business.

 5            237.     Office claimed NAICS code 722410 on its first draw PPP loan forgiveness application

 6   and the SBA Form 3511.

 7            238.     On or about June 1, 2021, Office applied for loan forgiveness of its first draw PPP

 8   loan. The Loan Proceeds amount that Office applied for forgiveness of for its first draw Loan, Office

 9   used exclusively for the Permitted Uses in full accordance with the PPP and its Loan Agreement.

10   Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

11            239.     On or about June 25, 2021, Office received forgiveness of the full amount of

12   forgiveness requested on its first draw PPP Loan.

13            240.     On or about January 30, 2024, via letter, SBA notified Office that it was initiating a

14   Post-Payment Review of Office’s first draw PPP Loan and requested that Office provide a number

15   of documents. The stated purpose for SBA’s requests via the Post-Payment Review was to review

16   whether Office was eligible for the PPP Loan under, among other factors, the Prurience Regulation

17   and Affiliation Rules.

18            241.     At all times related to the relevant period for its first draw PPP Loan, Office had no

19   more than 13 persons employed at its physical location.

20   Cats Meow of Vegas, LLC (“Cats”)

21            242.     Cats is a licensed alcohol serving, karaoke bar and nightclub open to the consenting

22   adult public, which presents on its premises a variety of constitutionally protected live karaoke

23   production entertainment as well as other live performance entertainment including singing and

24   dancing.

25            243.     Cats does not present any live performances, depictions or displays, or sell any

26   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

27   prurient, or unhealthy interest in sex.

28
                                                43                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24      Page 44 of 169



 1            244.     Cats operates it nightclub pursuant to, and in accordance with, the following

 2   licenses/permits, which it maintains:

 3                     a.     A L38 Tavern – Limited License, issued by the City of Las Vegas, Nevada;

 4            and

 5                     b.     A D19-Karaoke Business Licenses, issued by the City of Las Vegas, Nevada.

 6            245.     As a consequence of the Pandemic, Cats was subject to various governmental closures

 7   orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and proximate

 8   result thereof, the lingering effects of the Pandemic, and the supply chain disruptions related thereto,

 9   Cats suffered, as did a large percentage of businesses throughout the United States, devastating and

10   catastrophic financial losses. In fact, Cats sued the state of Nevada in order to reopen. See Cats Meow

11   of Vegas, LLC v. Nevada, No.: 2:20-cv-02055 (D. Nev. 2020).

12            246.     In order to mitigate the financial impact caused to Cats by the Pandemic and the

13   consequences thereof, including but not limited to its ability to retain and pay its employees, Cats

14   submitted an application to its Lending Bank for a first draw PPP loan on or about April 22, 2020,

15   and a second draw PPP loan on or about April 1, 2021. At all times relevant hereto, Cats’ Lending

16   Bank operated as a delegate of the SBA in processing and approving/disapproving of the first and

17   second draw PPP loan sought by Cats.

18            247.     Because Cats operates a licensed alcohol-serving karaoke bar and nightclub under the

19   licenses and permits identified in paragraph 244, it is, for purposes of the PPP and the Affiliation

20   Rules, a NAICS code 72 business. Cats claimed NAICS code 722410 as its “business code number”

21   on its 2019 federal income tax returns, and claimed NAICS code 722410 on both of its PPP loan

22   applications and PPP loan forgiveness applications.

23            248.     At all times related to the relevant period for its first draw PPP loan, Cats had no more

24   than 35 persons employed at its physical location.

25            249.     At all times related to the relevant period for its second draw PPP loan, Cats had no

26   more than 57 persons employed at its physical location.

27            250.     Under the PPP, Cats was eligible to obtain its first draw Loan and it received its first

28
                                                44                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 45 of 169



 1   draw Loan.

 2            251.     Under the PPP, Cats was eligible to obtain its second draw Loan and it received its

 3   second draw Loan.

 4            252.     The Loan Proceeds amounts that Cats applied for forgiveness of for both its first and

 5   second draw Loans, Cats used exclusively for the Permitted Uses in full accordance with the PPP

 6   and its Loan Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its first

 7   or second draw Loan.

 8            253.     On or about July 13, 2021, Cats applied for forgiveness of its first draw PPP Loan. At

 9   all times during that forgiveness application process, Cats’ Lending Bank operated as a delegate of

10   the SBA in processing and approving/disapproving of forgiveness of Cats’ first draw PPP Loan, and

11   issued a forgiveness decision to SBA approving Cats’ loan forgiveness application in the amount of

12   $171,851.69.

13            254.     On or about November 30, 2021, Cats applied for forgiveness of its second draw PPP

14   Loan. At all times during that forgiveness application process, Cats’ Lending Bank operated as a

15   delegate of the SBA in processing and approving/disapproving of forgiveness of Cats’ second draw

16   PPP Loan, and issued a forgiveness decision to SBA approving Cats’ loan forgiveness application in

17   the amount of $128,866.00.

18            255.     Cats received forgiveness on both its first and second draw PPP Loans.

19            256.     Despite Cats being eligible for forgiveness of its first and second draw PPP Loans,

20   and receiving forgiveness on the same, the SBA conducted a review of both of Cats’ first and second

21   draw PPP loans due to alleged “size issues,” despite its obvious qualification for the Affiliation

22   Exception Provisions, based on SBA’s application of the Affiliation Rules, an allegation that the 25%

23   reduction in aggregated gross receipts for its second draw PPP Loan may not have been met, and

24   alleged “insufficient documentation” to enable SBA to calculate the Loan amounts and forgiveness

25   amounts.

26            257.     If forced to repay its first and second draw PPP Loan, and because of the precarious

27   financial condition in which it finds itself still as a result of the lingering impact of the Pandemic and

28
                                                45                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 46 of 169



 1   the consequences thereof, Cats may be forced to close its business and file for bankruptcy, which

 2   would result in the cessation of both the presentation of and the ability to view entertainment that is

 3   presumptively protected under the First Amendment to the United States Constitution, as well as the

 4   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

 5   happening.

 6   Cats 701 Bourbon, LLC (“Cats NOLA”)

 7            258.     Cats NOLA is a licensed alcohol serving, karaoke bar and nightclub open to the

 8   consenting adult public, which presents on its premises a variety of constitutionally protected live

 9   karaoke production entertainment as well as other live performance entertainment including singing

10   and dancing.

11            259.     Cats NOLA does not present any live performances, depictions or displays, or sell

12   any products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

13   prurient, or unhealthy interest in sex.

14            260.     Cats NOLA operates its nightclub pursuant to, and in accordance with, the following

15   licenses/permits, which it maintains:

16                     a.     A Liquor License issued by the City of New Orleans; and

17                     b.     A Liquor License issued by the State of Louisiana with a Restaurant

18            endorsement.

19            261.     As a consequence of the Pandemic, Cats NOLA was subject to various governmental

20   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

21   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

22   related thereto, Cats NOLA suffered, as did a large percentage of businesses throughout the United

23   States, devastating and catastrophic financial losses.

24            262.     In order to mitigate the financial impact caused to Cats NOLA by the Pandemic and

25   the consequences thereof, including but not limited to its ability to retain and pay its employees, Cats

26   NOLA submitted an application to its Lending Bank for a first draw PPP loan on or about April 7,

27   2020. At all times relevant hereto, Cats NOLA’s Lending Bank operated as a delegate of the SBA in

28
                                                46                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 47 of 169



 1   processing and approving/disapproving of the first draw PPP Loan sought by Cats NOLA.

 2            263.     Because Cats NOLA operates a licensed alcohol-serving karaoke bar and nightclub

 3   under the licenses and permits identified in paragraph 260, it is, for purposes of the PPP and the

 4   Affiliation Rules, a NAICS code 72 business.

 5            264.     Cats NOLA claimed NAICS code 722410 as its “business code number” on its 2019

 6   federal income tax returns, and claimed NAICS code 722410 on its PPP loan forgiveness application.

 7            265.     At all times related to the relevant period for its first draw PPP loan, Cats NOLA had

 8   no more than 65 persons employed at its physical location.

 9            266.     Under the PPP, Cats NOLA was eligible to obtain its first draw Loan and it received

10   its first draw Loan.

11            267.     On or about July 8, 2021, Cats NOLA applied for forgiveness of its first draw PPP

12   Loan. The Loan Proceeds amount that Cats NOLA applied for forgiveness of for its first draw Loan,

13   Cats NOLA used exclusively for the Permitted Uses in full accordance with the PPP and its Loan

14   Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

15            268.     On or about September 20, 2021, Cats NOLA received forgiveness of the fully

16   amount of forgiveness requested on its first draw PPP Loan.

17            269.     On or about January 30, 2024, via email, SBA notified Cats NOLA that it was

18   initiating a Post-Payment Review of Cats NOLA’s first draw PPP Loan and requested that Cats

19   NOLA provide a number of documents.

20            270.     There was no stated purpose for the Post-Payment Review stated in the email

21   informing Cats NOLA of the Post-Payment Review.

22            271.     If forced to repay its first draw PPP Loan, and because of the precarious financial

23   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

24   consequences thereof, Cats NOLA may be forced to close its business and file for bankruptcy, which

25   would result in the cessation of both the presentation of and the ability to view entertainment that is

26   presumptively protected under the First Amendment to the United States Constitution, as well as the

27   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

28
                                                47                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 48 of 169



 1   happening.

 2   Pole Position at Tacoma, LLC (“Pole Position”)

 3            272.     Pole Position was a licensed alcohol and food serving sports bar open to the

 4   consenting adult public. Pole Position permanently closed its doors in March of 2023 as a result of

 5   the economic downturn due to COVID restrictions.

 6            273.     Pole Position does not present any live performances, depictions or displays, or sell

 7   any products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

 8   prurient, or unhealthy interest in sex.

 9            274.     Pole Position operates its sports bar pursuant to, and in accordance with, the following

10   licenses/permits, which it maintains:

11                     a.     A business license issued by the State of Washington endorsed as a

12            spirits/beer/wine restaurant lounge; and

13                     b.     A food establishment and cocktail lounge permit issued by Pierce County.

14            275.     As a consequence of the Pandemic, Pole Position was subject to various governmental

15   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

16   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

17   related thereto, Pole Position suffered, as did a large percentage of businesses throughout the United

18   States, devastating and catastrophic financial losses.

19            276.     In order to mitigate the financial impact caused to Pole Position by the Pandemic and

20   the consequences thereof, including but not limited to its ability to retain and pay its employees, Pole

21   Position submitted an application to its Lending Bank for a second draw PPP loan and received the

22   second draw PPP loan on or about May 3, 2021. At all times relevant hereto, Pole Position’s Lending

23   Bank operated as a delegate of the SBA in processing and approving/disapproving of the second

24   draw PPP Loan sought by Pole Position.

25            277.     Because Pole Position operated a licensed alcohol-serving sports bar under the

26   licenses and permits identified in paragraph 274, it is, for purposes of the PPP and the Affiliation

27   Rules, a NAICS code 72 business.

28
                                                48                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 49 of 169



 1            278.     Pole Position claimed NAICS code 722410 on its second draw PPP loan and loan

 2   forgiveness applications.

 3            279.     At all times related to the relevant period for its second draw PPP loan, Pole Position

 4   had no more than 31 persons employed at its physical location.

 5            280.     Under the PPP, Pole Position was eligible to obtain its second draw Loan and it

 6   received its second draw Loan.

 7            281.     Pole Position applied for forgiveness of its second draw PPP Loan. The Loan Proceeds

 8   amount that Pole Position applied for forgiveness of for its second draw Loan, Pole Position used

 9   exclusively for the Permitted Uses in full accordance with the PPP and its Loan Agreement.

10   Consequently, it no longer possesses any of the Loan Proceeds from its second draw Loan.

11            282.     On or about March 26, 2022, Pole Position received forgiveness of the fully amount

12   of forgiveness requested on its second draw PPP Loan.

13            283.     On or about December 21, 2023, via email, SBA notified Pole Position that it was

14   conducting a “review” of the loan and informed Pole Position that it may “request more information

15   on any PPP loan of any size at any time.” The “review” requested that Pole Position provide a number

16   of documents.

17            284.     There was no stated purpose for the “review” stated in the email informing Pole

18   Position of the “review.”

19            285.     Pole Position is closed, and, if forced to repay its second draw PPP Loan, Pole

20   Position would be unable to do so.

21   Jamme Holdings, LLC (“Jamme”)

22            286.     Jamme is a licensed alcohol serving nightclub open to the consenting adult public,

23   which presents on its premises a variety of non-obscene, constitutionally protected, female

24   performance dance entertainment.

25            287.     Jamme has never been charged with, let alone convicted of, any crimes of obscenity.

26   Similarly, none of the entertainers who have performed on Jamme’s premises have ever been charged

27   with, let alone convicted of, any crimes of obscenity related to their performances at the facility

28
                                                49                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 50 of 169



 1   owned and operated by Jamme.

 2            288.     Jamme does not present any live performances, depictions or displays, or sell any

 3   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

 4   prurient, or unhealthy interest in sex.

 5            289.     Jamme operates it nightclub pursuant to, and in accordance with, the following

 6   licenses/permits, which it maintains:

 7                     a.     A Liquor License issued by the State of Pennsylvania that includes Sunday

 8            sales, extended food hours, and an amusement permit;

 9                     b.     A Certificate of Occupancy that includes an adult entertainment nightclub use

10            permission; and

11                     c.     A Health Permit for a Food Facility.

12            290.     As a consequence of the Pandemic, Jamme was subject to various governmental

13   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

14   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

15   related thereto, Jamme suffered, as did a large percentage of businesses throughout the United States,

16   devastating and catastrophic financial losses.

17            291.     In order to mitigate the financial impact caused to Jamme by the Pandemic and the

18   consequences thereof, including but not limited to its ability to retain and pay its employees, Jamme

19   submitted an application to its Lending Bank for a first draw PPP loan on or about April 7, 2020. At

20   all times relevant hereto, Jamme’s Lending Bank operated as a delegate of the SBA in processing

21   and approving/disapproving of the first draw PPP loan sought by Jamme.

22            292.     In order to further mitigate the financial impact caused to Jamme by the Pandemic

23   and the consequences thereof, including but not limited to its ability to retain and pay its employees,

24   Jamme submitted an application to its Lending Bank for a second draw PPP loan on or about April

25   1, 2021. At all times relevant hereto, Jamme’s Lending Bank operated as a delegate of the SBA in

26   processing and approving/disapproving of the second draw PPP loan sought by Jamme.

27            293.     Because Jamme operates a licensed alcohol-serving nightclub under the

28
                                                50                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 51 of 169



 1   licenses/permits identified in paragraph 289, it is, and was at all times relevant to the PPP, for

 2   purposes of the PPP and the Affiliation Rules, a NAICS code 72 business.

 3            294.     Jamme claimed NAICS code 722410 on its first draw PPP loan forgiveness

 4   application, the SBA Form 3511, its second draw PPP Loan application, and its second draw PPP

 5   loan forgiveness application.

 6            295.     On or about July 1, 2021, Jamme applied for loan forgiveness of its first draw PPP

 7   loan. The Loan Proceeds amount that Jamme applied for forgiveness of for its first draw Loan,

 8   Jamme used exclusively for the Permitted Uses in full accordance with the PPP and its Loan

 9   Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

10            296.     On or about July 30, 2021, Jamme received forgiveness of the full amount of

11   forgiveness requested on its first draw PPP Loan.

12            297.     On or about January 30, 2024, via letter, SBA notified Jamme that it was initiating a

13   Post-Payment Review of Jamme’s first draw PPP Loan and requested that Jamme provide a number

14   of documents. The stated purpose for SBA’s requests via the Post-Payment Review was to review

15   whether Jamme was eligible for the PPP Loan under, among other factors, the Prurience Regulation

16   and Affiliation Rules.

17            298.     On or about May 23, 2022, Jamme applied for loan forgiveness of its second draw

18   PPP Loan. The Loan Proceeds amount that Jamme applied for forgiveness of for its second draw

19   Loan, Jamme used exclusively for the Permitted Uses in full accordance with the PPP and its Loan

20   Agreement. Consequently, it no longer possesses any of the Loan Proceeds from its second draw

21   Loan.

22            299.     As of the date of this filing, Jamme has not received a final forgiveness decision from

23   SBA regarding Jamme’s second draw PPP Loan.

24            300.     At all times related to the relevant period for its first and second draw PPP Loans,

25   Jamme had no more than 38 persons employed at its physical location.

26            301.     If forced to repay its first draw PPP Loan, and because of the precarious financial

27   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

28
                                                51                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 52 of 169



 1   consequences thereof, Jamme may be forced to close its business and file for bankruptcy, which

 2   would result in the cessation of both the presentation of and the ability to view entertainment that is

 3   presumptively protected under the First Amendment to the United States Constitution, as well as the

 4   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

 5   happening.

 6   90’s Minneapolis, LLC (“90s”)

 7            302.     90s is a licensed alcohol serving nightclub open to the consenting adult public, which

 8   presents on its premises a variety of non-obscene, constitutionally protected, male and female

 9   performance dance entertainment.

10            303.     90s has never been charged with, let alone convicted of, any crimes of obscenity.

11   Similarly, none of the entertainers who have performed on 90s’s premises have ever been charged

12   with, let alone convicted of, any crimes of obscenity related to their performances at the facility

13   owned and operated by 90s.

14            304.     90s does not present any live performances, depictions or displays, or sell any

15   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

16   prurient, or unhealthy interest in sex.

17            305.     90s operates it nightclub pursuant to, and in accordance with, the following

18   licenses/permits, which it maintains:

19                     a.     A Liquor License;

20                     b.     A Food License-Sidewalk Café; and

21                     c.     A Liquor Permit allowing 90s to close at 2 am.

22            306.     As a consequence of the Pandemic, 90s was subject to various governmental closures

23   orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and proximate

24   result thereof, the lingering effects of the Pandemic, and the supply chain disruptions related thereto,

25   90s suffered, as did a large percentage of businesses throughout the United States, devastating and

26   catastrophic financial losses.

27            307.     In order to mitigate the financial impact caused to 90s by the Pandemic and the

28
                                                52                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24      Page 53 of 169



 1   consequences thereof, including but not limited to its ability to retain and pay its employees, 90s

 2   submitted an application to its Lending Bank for a first draw PPP loan on or about April 7, 2020. At

 3   all times relevant hereto, 90s’s Lending Bank operated as a delegate of the SBA in processing and

 4   approving/disapproving of the first draw PPP loan sought by 90s.

 5            308.     In order to further mitigate the financial impact caused to 90s by the Pandemic and

 6   the consequences thereof, including but not limited to its ability to retain and pay its employees, 90s

 7   submitted an application to its Lending Bank for a second draw PPP loan on or about April 27, 2021.

 8   At all times relevant hereto, 90s’s Lending Bank operated as a delegate of the SBA in processing and

 9   approving/disapproving of the second draw PPP loan sought by 90s.

10            309.     Because 90s operates a licensed alcohol-serving nightclub under the licenses/permits

11   identified in paragraph 305, it is, and was at all times relevant to the PPP, for purposes of the PPP

12   and the Affiliation Rules, a NAICS code 72 business.

13            310.     90s claimed NAICS code 722410 on its first draw PPP loan forgiveness application,

14   the SBA Form 3511, its second draw PPP Loan application, and its second draw PPP loan forgiveness

15   application.

16            311.     On or about July 8, 2021, 90s applied for loan forgiveness of its first draw PPP loan.

17   The Loan Proceeds amount that 90s applied for forgiveness of for its first draw Loan, 90s used

18   exclusively for the Permitted Uses in full accordance with the PPP and its Loan Agreement.

19   Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

20            312.     On or about July 22, 2021, 90s received forgiveness of the full amount of forgiveness

21   requested on its first draw PPP Loan.

22            313.     On or about January 30, 2024, via letter, SBA notified 90s that it was initiating a Post-

23   Payment Review of 90s’s first draw PPP Loan and requested that 90s provide a number of documents.

24   The stated purpose for SBA’s requests via the Post-Payment Review was to review whether 90s was

25   eligible for the PPP Loan under, among other factors, the Prurience Regulation and Affiliation Rules.

26            314.     On or about May 13, 2022, 90s applied for loan forgiveness of its second draw PPP

27   Loan. The Loan Proceeds amount that 90s applied for forgiveness of for its second draw Loan, 90s

28
                                                53                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 54 of 169



 1   used exclusively for the Permitted Uses in full accordance with the PPP and its Loan Agreement.

 2   Consequently, it no longer possesses any of the Loan Proceeds from its second draw Loan.

 3            315.     On or about May 23, 2023, 90s received forgiveness of the full amount of forgiveness

 4   requested on its second draw PPP Loan.

 5            316.     At all times related to the relevant period for its first and second draw PPP Loans, 90s

 6   had no more than 49 persons employed at its physical location.

 7            317.     If forced to repay its first draw PPP Loan, and because of the precarious financial

 8   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

 9   consequences thereof, 90s may be forced to close its business and file for bankruptcy, which would

10   result in the cessation of both the presentation of and the ability to view entertainment that is

11   presumptively protected under the First Amendment to the United States Constitution, as well as the

12   wholesale termination of its employees jobs; which the PPP was in fact designed to preclude from

13   happening.

14   Las Vegas Bistro, LLC (“LVB”)

15            318.     LVB is a licensed alcohol serving nightclub open to the consenting adult public, which

16   presents on its premises a variety of non-obscene, constitutionally protected, male and female

17   performance dance entertainment.

18            319.     LVB has never been charged with, let alone convicted of, any crimes of obscenity.

19   Similarly, none of the entertainers who have performed on LVB’s premises have ever been charged

20   with, let alone convicted of, any crimes of obscenity related to their performances at the facility

21   owned and operated by LVB.

22            320.     LVB does not present any live performances, depictions or displays, or sell any

23   products or services, of a prurient sexual nature or that otherwise appeal to a shameful, morbid,

24   prurient, or unhealthy interest in sex.

25            321.     LVB operates it nightclub pursuant to, and in accordance with, the following

26   licenses/permits, which it maintains:

27                     a.     An Adult Entertainment Cabaret License issued by Clark County

28
                                                54                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18      Filed 10/10/24      Page 55 of 169



 1                     b.     A Liquor License issued by Clark County; and

 2                     c.     A Food (Restaurant) License issued by Clark County
 3            322.     As a consequence of the Pandemic, LVB was subject to various governmental

 4   closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As a direct and

 5   proximate result thereof, the lingering effects of the Pandemic, and the supply chain disruptions

 6   related thereto, LVB suffered, as did a large percentage of businesses throughout the United States,

 7   devastating and catastrophic financial losses.

 8            323.     In order to mitigate the financial impact caused to LVB by the Pandemic and the

 9   consequences thereof, including but not limited to its ability to retain and pay its employees, LVB

10   submitted an application to its Lending Bank for a first draw PPP loan on or about April 7, 2020. It

11   submitted a revised application on May 21, 2020. At all times relevant hereto, LVB’s Lending Bank

12   operated as a delegate of the SBA in processing and approving/disapproving of the first draw PPP

13   loan sought by LVB.

14            324.     Because    LVB    operates   a   licensed   alcohol-serving   nightclub   under   the

15   licenses/permits identified in paragraph 321, it is, and was at all times relevant to the PPP, for

16   purposes of the PPP and the Affiliation Rules, a NAICS code 72 business.

17            325.     LVB claimed NAICS code 722410 on its first draw PPP loan forgiveness application

18   and the SBA Form 3511.

19            326.     On or about July 1, 2021, LVB applied for loan forgiveness of its first draw PPP loan.

20   The Loan Proceeds amount that LVB applied for forgiveness of for its first draw Loan, LVB used

21   exclusively for the Permitted Uses in full accordance with the PPP and its Loan Agreement.

22   Consequently, it no longer possesses any of the Loan Proceeds from its first draw Loan.

23            327.     On or about July 27, 2021, LVB received forgiveness of the full amount of forgiveness

24   requested on its first draw PPP Loan.

25            328.     On or about January 30, 2024, via letter, SBA notified LVB that it was initiating a

26   Post-Payment Review of LVB’s first draw PPP Loan and requested that LVB provide a number of

27   documents. The stated purpose for SBA’s requests via the Post-Payment Review was to review

28
                                                55                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 56 of 169



 1   whether LVB was eligible for the PPP Loan under, among other factors, the Prurience Regulation

 2   and Affiliation Rules.

 3            329.     At all times related to the relevant period for its first draw PPP Loan, LVB had no

 4   more than 120 persons employed at its physical location.

 5   Stockton Enterprises, LLC (“Stockton Enterprises”)

 6            330.     Stockton Enterprises is a licensed alcohol serving nightclub open to the consenting

 7   adult public, which presents on its premises a variety of non-obscene, constitutionally protected,

 8   female performance dance entertainment.

 9            331.     Stockton Enterprises has never been charged with, let alone convicted of, any crimes

10   of obscenity. Similarly, none of the entertainers who have performed on Stockton Enterprises’

11   premises have ever been charged with, let alone convicted of, any crimes of obscenity related to their

12   performances at the facility owned and operated by Stockton Enterprises.

13            332.     Stockton Enterprises does not present any live performances, depictions or displays,

14   or sell any products or services, of a prurient sexual nature or that otherwise appeal to a shameful,

15   morbid, prurient, or unhealthy interest in sex.

16            333.     Stockton Enterprises operates it nightclub pursuant to, and in accordance with, the

17   following licenses/permits, which it maintains:

18                     a.     Business License issued by San Joaquin County;

19                     b.     Liquor License #364893 issued by the State of California; and

20                     c.     A Health Permit for a Restaurant / Bar (#PT0002172).

21            334.     As a consequence of the Pandemic, Stockton Enterprises was subject to various

22   governmental closures orders imposed to mitigate the effects and spread of the COVID-19 virus. As

23   a direct and proximate result thereof, the lingering effects of the Pandemic, and the supply chain

24   disruptions related thereto, Stockton Enterprises suffered, as did a large percentage of businesses

25   throughout the United States, devastating and catastrophic financial losses.

26            335.     In order to mitigate the financial impact caused to Stockton Enterprises by the

27   Pandemic and the consequences thereof, including but not limited to its ability to retain and pay its

28
                                                56                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 57 of 169



 1   employees, Stockton Enterprises submitted an application to its Lending Bank for a first draw PPP

 2   loan on or about April 7, 2020. At all times relevant hereto, Stockton Enterprises’ Lending Bank

 3   operated as a delegate of the SBA in processing and approving/disapproving of the first draw PPP

 4   loan sought by Stockton Enterprises.

 5            336.     Because Stockton Enterprises operates a licensed alcohol-serving nightclub under the

 6   licenses/permits identified in paragraph 333, it is, and was at all times relevant to the PPP, for

 7   purposes of the PPP and the Affiliation Rules, a NAICS code 72 business.

 8            337.     Stockton Enterprises claimed NAICS code 722410 on its first draw PPP loan

 9   forgiveness application and the SBA Form 3511.

10            338.     On or about July 15, 2021, Stockton Enterprises applied for loan forgiveness of its

11   first draw PPP loan. The Loan Proceeds amount that Stockton Enterprises applied for forgiveness of

12   for its first draw Loan, Stockton Enterprises used exclusively for the Permitted Uses in full

13   accordance with the PPP and its Loan Agreement. Consequently, it no longer possesses any of the

14   Loan Proceeds from its first draw Loan.

15            339.     On or about July 23, 2021, Stockton Enterprises received forgiveness of the full

16   amount of forgiveness requested on its first draw PPP Loan.

17            340.     On or about January 30, 2024, via letter, SBA notified Stockton Enterprises that it

18   was initiating a Post-Payment Review of Stockton Enterprises’ first draw PPP Loan and requested

19   that Stockton Enterprises provide a number of documents. The stated purpose for SBA’s requests via

20   the Post-Payment Review was to review whether Stockton Enterprises was eligible for the PPP Loan

21   under, among other factors, the Prurience Regulation and Affiliation Rules.

22            341.     At all times related to the relevant period for its first draw PPP Loan, Stockton

23   Enterprises had no more than 115 persons employed at its physical location.

24            342.     If forced to repay its first draw PPP Loan, and because of the precarious financial

25   condition in which it finds itself still as a result of the lingering impact of the Pandemic and the

26   consequences thereof, Stockton Enterprises may be forced to close its business and file for

27   bankruptcy, which would result in the cessation of both the presentation of and the ability to view

28
                                                57                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24       Page 58 of 169



 1   entertainment that is presumptively protected under the First Amendment to the United States

 2   Constitution, as well as the wholesale termination of its employees jobs; which the PPP was in fact

 3   designed to preclude from happening.

 4                                         GENERAL ALLEGATIONS

 5            343.     The causes of action contained herein all revolve around the actions of the SBA in

 6   administering the Loans under the PPP.

 7            344.     As a result of the issuance of its PPP Loan at issue, each Plaintiff was required to enter

 8   into a loan agreement, normally by way of executing a Promissory Note (the “Loan Agreements”),

 9   with its Lending Bank. The Loan Agreements of the Plaintiffs are collectively attached hereto as

10   Exhibit V.

11            345.     Procedurally, Plaintiffs fall into five categories (although, as demonstrated, some

12   Plaintiffs actually fall into more than one category because of multiple PPP Loans obtained by them).

13   First, Plaintiffs Gold Club (first draw), DV SG of LV, and Smithville have had their Loans granted

14   but forgiveness thereof denied by the SBA through the issuance of an FLRD. Second, Plaintiffs

15   Meacham, SAW, Dallas Food and Beverage, and Gold Club (second draw) have had their Loans

16   granted but forgiveness denied by the SBA through the issuance of FLRDs, with the SBA then,

17   following those Plaintiffs having appealed to the OHA, withdrawing the applicable FLRD and

18   indicating that the SBA would be undertaking further investigation, and, upon motion by the SBA,

19   the OHA subsequently dismissing such appeal. Third, Plaintiffs Gold Club (second draw) and

20   Meacham have had their Loans granted but forgiveness denied by the SBA through the issuance of

21   FLRDs, with the SBA then, following those Plaintiffs having appealed to the OHA, withdrawing the

22   applicable FLRD and indicating that the SBA would be undertaking further investigation, and, upon

23   motion by the SBA, the OHA subsequently dismissing such appeal, and with the SBA then issuing a

24   second “new and improved” FLRD. Third, Plaintiff Gold Club (second draw) has had its Loan

25   granted but forgiveness denied by the SBA through issuance of multiple FLRDs, which were

26   appealed, with the OHA having affirmed SBA’s “new and improved” FLRD such that Gold Club

27   seeks judicial review of those orders by way of this lawsuit. Fourth, Plaintiff Meacham has had its

28
                                                58                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24     Page 59 of 169



 1   Loan granted but forgiveness denied by the SBA through issuance of multiple FLRDs, which

 2   Meacham timely appealed, with the OHA having granted Meacham’s appeal of SBA’s “new and

 3   improved” FLRD and remanded the same back to SBA and SBA has not issued a new FLRD or

 4   otherwise issued forgiveness on that Loan. Fifth, Plaintiffs Cats of Vegas, the Office, Pole Position,

 5   Jamme, 90’s, Las Vegas Bistro, Stockton, Reeder, and Cat’s NOLA, have had both their Loans and

 6   forgiveness thereof granted, yet the SBA has recently informed those Plaintiffs that it was

 7   reconsidering the Plaintiffs’ eligibility for such Loans and requested from them voluminous

 8   documentary materials. This has required the staffs and professionals of such Plaintiffs to devote

 9   substantial resources, and the Plaintiffs to expend substantial sums, to comply with such requests.

10            346.     Under the PPP and Bank Fraud Enforcement Harmonization Act of 2022, Pub. L. 117-

11   166, 136 Stat. 1365 (Jan. 3, 2022), now codified at 15 U.S.C. § 636(a)(36)(W) and (a)(37)(P),

12   criminal charges or civil enforcement actions alleging that a borrower engaged in fraud with respect

13   to a PPP Loan may be brought not later than 10 years after the alleged offense was committed.

14            347.     Under and/or pursuant to 15 U.S.C. § 636m(l); 15 U.S.C. § 636m(E); 13 C.F.R. §

15   120.461(d); and/or SBA 7(a) Loan Servicing and Liquidation, SOP 50 57 3, § 3.D.5 (Aug. 1, 2023),

16   the SBA has six years after a PPP loan is forgiven to audit and reconsider the decision. At the pace

17   that the undersigned firm has seen the SBA recently issue such audit notices, it is expected that a

18   large number of the clients of the undersigned firm will be audited in the near future.

19            348.     For those Plaintiffs that have had forgiveness of their Loans denied through the

20   issuance by the SBA of an un-withdrawn FLRD, since the SBA is—under the terms of the PPP—the

21   guarantor of such Loans, the Lending Banks have demanded, are demanding, and/or will be

22   demanding, repayment of such Loans.

23            349.     As reported by NPR based on SBA data, 92% of all PPP loans have been forgiven.

24            350.     All attached Exhibits are incorporated by reference as though fully set forth herein.

25      THE SBA’S AND CONGRESS’ GERRYMANDERING OF EMERGENCY PANDEMIC
         FUNDING TO ASSIST PREVIOUSLY EXCLUDED BUSINESS ACTIVITIES AND
26                       TO DAMAGE “DISFAVORED” SPEECH
27

28
                                                59                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC              Document 18     Filed 10/10/24      Page 60 of 169



 1            351.     Congress created the SBA on July 30, 1953, through the Small Business Act of 1953,

 2   Pub. L. 83-163, tit. II, 67 Stat. 232, et seq., (1953); see also https://www.sba.gov/about-

 3   sba/organization#:~:text=Congress%20created%20SBA%20with%20the,is%20periodically%20am

 4   ended%20by%20Congress (last visited Oct. 7, 2024). The Small Business Act referenced in the

 5   previous sentence and all subsequent amendments thereto are collectively referred to hereinafter as

 6   the “SBA Act.”

 7            352.     On March 28, 2020, the President signed the CARES Act into law which, among other

 8   things, created the PPP.

 9            353.     The PPP is part of the SBA Act.

10            354.     The PPP instructs the SBA to promulgate rules as follows:

11            SEC. 1114. EMERGENCY RULEMAKING AUTHORITY.

12            Not later than 15 days after the date of the enactment of this Act, the Administrator
              shall issue regulations to carry out this title and the amendments made by this title
13            without regard to the notice requirements under section 553(b) of title 5, United States
              Code.
14
     CARES Act, Pub. L. 116-136 § 1114; codified as 15 U.S.C. § 9012.
15
              355.     The CARES Act specifically tasked the SBA with administering the PPP. The PPP
16
     further provides:
17
              (I) In general
18

19            For purposes of making covered loans for the purposes described in clause (i), a lender
              approved to make loans under this subsection shall be deemed to have been delegated
20            authority by the Administrator to make and approve covered loans, subject to the
              provisions of this paragraph.
21
              (II) Considerations
22
              In evaluating the eligibility of a borrower for a covered loan with the terms described
23            in this paragraph, a lender shall consider whether the borrower—
24
              (aa) was in operation on February 15, 2020; and
25
              (bb)(AA) had employees for whom the borrower paid salaries and payroll taxes; or
26
              (BB) paid independent contractors, as reported on a Form 1099-MISC.
27

28            (iii) Additional lenders
                                                60                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18          Filed 10/10/24       Page 61 of 169



 1
              The authority to make loans under this paragraph shall be extended to additional
 2            lenders determined by the Administrator and the Secretary of the Treasury to have the
              necessary qualifications to process, close, disburse and service loans made with the
 3            guarantee of the Administration.
 4   15 U.S.C. § 636(a)(36)(F)(ii).
 5            356.     Nowhere in the CARES Act did Congress authorize the SBA to make value judgments
 6   in determining which small businesses should survive the Pandemic through the issuance of
 7   emergency funding and which businesses should be allowed to fail without such funding.
 8            357.     Pursuant to the PPP, and in particular 15 U.S.C. § 636(a)(36)(F)(ii), the SBA did, in
 9   fact, promulgate numerous regulations.
10            358.     On April 15, 2020, the SBA published, in the Federal Register, 85 Fed. Reg. 20811-
11   17 (Interim Final Rule, Apr. 15, 2020), an Interim Final Rule titled “Business Loan Program
12   Temporary Changes; Paycheck Protection Program,” which reads, in relevant part:
13            Businesses that are not eligible for PPP loans are identified in 13 CFR 120.110 and
              described further in SBA’s Standard Operating Procedure (SOP) 50 10, Subpart B,
14            Chapter 2, except that nonprofit organizations authorized under the Act are eligible.
              (SOP 50 10 can be found at https://www.sba.gov/ document/sop-50-10-5-
15            lenderdevelopment- company-loan-programs.).
16   85 Fed. Reg. 20812 (Apr. 15, 2020).
17            359.     On April 15, 2020, the SBA published, in the Federal Register, 85 Fed. Reg. 20817-
18   21 (Interim Final Rule, Apr. 15, 2020), an Interim Final Rule titled “Business Loan Program
19   Temporary Changes; Paycheck Protection Program,” which reads, in relevant part:
20            This rule exempts otherwise qualified faith-based organizations from the SBA’s
              affiliation rules, including those set forth in 13 CFR part 121, where the application
21            of the affiliation rules would substantially burden those organizations’ religious
              exercise.
22
                                                   *       *        *
23
              The Administrator has also concluded that she does not have a compelling interest in
24            denying emergency assistance to faith-based organizations that are facing the same
              economic hardship to which the CARES Act responded and who would be eligible
25            for PPP but for their faith-based organizational and associational decisions.
26                                                 *       *        *
27
              In light of these exemptions, it is difficult to maintain that denying relief to these faith-
28            based organizations is necessary to further a compelling government interest, let alone
                                                            61                            Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 62 of 169



 1            the least restrictive means of doing so.

 2   85 Fed. Reg. 20819.

 3            360.     In its April 15, 2020, Interim Final Rule (85 Fed. Reg. 20817-21) the SBA classified

 4   the PPP as a benefit program:

 5            The affiliation rules would deny an important benefit (participation in a program for
              which they would otherwise be eligible under the CARES Act) because of the exercise
 6            of sincere religious belief (affiliation with other religious entities).

 7   85 Fed. Reg. 20819 (emphasis added; all clarifications in original).
 8            361.     On April 20, 2020, the SBA published, in the Federal Register, 85 Fed. Reg. 21747-
 9   52 (Interim Final Rule, Apr. 20, 2020), an Interim Final Rule titled “Business Loan Program
10   Temporary Changes; Paycheck Protection Program—Additional Eligibility Criteria and
11   Requirements for Certain Pledges of Loans,” which reads, in relevant part:
12            b. Are businesses that receive revenue from legal gaming eligible for a PPP Loan?
13            A business that is otherwise eligible for a PPP Loan is not rendered ineligible due to
              its receipt of legal gaming revenues if the existing standard in 13 CFR 120.110(g) is
14            met or the following two conditions are satisfied: (a) The business’s legal gaming
              revenue (net of payouts but not other expenses) did not exceed $1 million in 2019;
15            and (b) legal gaming revenue (net of payouts but not other expenses) comprised less
              than 50 percent of the business’s total revenue in 2019. Businesses that received
16            illegal gaming revenue are categorically ineligible. The Administrator, in consultation
              with the Secretary, believes this test appropriately balances the longstanding policy
17            reasons for limiting lending to businesses primarily and substantially engaged in
              gaming activity with the policy aim of making the PPP Loan available to a broad
18            segment of U.S. businesses and their employees.
19            85 Fed. Reg. 21751 (all clarifications in original).
20            362.     A few days later, on April 28, 2020, the SBA published, in the Federal Register, 85
21   Fed. Reg. 23450 (Interim Final Rule, Apr. 28, 2020), an Interim Final Rule titled “Business Loan
22   Program Temporary Changes; Paycheck Protection Program—Requirements—Promissory Notes,
23   Authorizations, Affiliation, and Eligibility,” which expanded gambling establishments’ eligibility
24   and reads, in relevant part:
25            d. Part III.2.b. of the Third PPP Interim Final Rule (85 FR 21747, 21751) is revised
              to read as follows:
26

27            Are businesses that receive revenue from legal gaming eligible for a PPP Loan?

28
                                                62                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 63 of 169



 1            A business that is otherwise eligible for a PPP Loan is not rendered ineligible due to
              its receipt of legal gaming revenues, and 13 CFR 120.110(g) is inapplicable to PPP
 2            loans. Businesses that received illegal gaming revenue remain categorically
              ineligible. On further consideration, the Administrator, in consultation with the
 3            Secretary, believes this approach is more consistent with the policy aim of making
              PPP loans available to a broad segment of U.S. businesses.
 4

 5   85 Fed. Reg. at 23451.

 6            363.     That same Interim Final Rule also “determined that this exception to the general

 7   ineligibility of government-owned entities, 13 CFR 120.110(j), is inappropriate to effectuate the

 8   purpose of the CARES Act,” thereby allowing government-owned hospitals to receive PPP loans. Id.

 9   Such entities would otherwise have been ineligible for PPP loans under 13 C.F.R. § 120.110(j)

10            364.     On June 26, 2020, the SBA published, in the Federal Register, 85 Fed. Reg. 38301

11   (Interim Final Rule, Jun. 26, 2020), an Interim Final Rule titled “Business Loan Temporary Changes;

12   Paycheck Protection Program—Additional Eligibility Revisions to First Interim Final Rule.”

13            365.     Via 85 Fed. Reg. at 38302, the SBA relaxed its rule in the first interim final rule (85

14   Fed. Reg. 20811) that provided that “an applicant is ineligible for a PPP loan if an owner of 20 percent

15   or more . . . is presently subject to an indictment, criminal information, arraignment, or other means

16   by which formal criminal charges are brought in any jurisdiction” by determining that “should be

17   limited to pending criminal charges for felony offenses, which aligns with the Administrator’s prior

18   determination that only felony convictions . . . will limit an applicant’s eligibility for the PPP.” Prior

19   to these two interim final rules, such entities would have been categorically excluded from SBA’s

20   7(a) loans via 13 C.F.R. § 120.110(n).

21            366.     On June 30, 2020, the SBA published, in the Federal Register, 85 Fed. Reg. 39066

22   (Interim Final Rule, Jun. 30, 2020), an Interim Final Rule titled “Business Loan Program Temporary

23   Changes; Paycheck Protection Program—Certain Eligible Payroll Costs.”

24            367.     Prior to the June 30, 2020, Interim Final Rule (85 Fed. Reg. 39066, et seq.),

25   crewmembers of commercial fishing boats were “treated as independent contractors or otherwise

26   self-employed” and “because independent contractors have the ability to apply for a PPP loan on

27   their own, they [the crewmembers] do not count for purposes of another applicant’s PPP loan

28
                                                63                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18         Filed 10/10/24      Page 64 of 169



 1   calculation.” 85 Fed. Reg. 39066 (clarification added). In other words, prior to this Interim Final

 2   Rule, boat owners could not count the payments made to their crewmembers as payroll costs for the

 3   PPP because the crewmembers were themselves eligible for a PPP. The SBA’s June 30, 2020, Interim

 4   Final Rule negated that limitation:

 5            The Administrator, in consultation with the Secretary, has determined that the
              relationship of a fishing boat owner and a crewmember described in Section
 6            3121(b)(20) of the Code is analogous to a joint venture or partnership.

 7                                               *       *       *

 8            Accordingly, as described below, this interim final rule (1) provides that a fishing boat
              owner may include compensation reported on Box 5 of Form 1099–MISC and paid
 9            to a crewmember described in Section 3121(b)(20) as a payroll cost in its PPP loan
              application, and (2) addresses a fishing boat owner’s eligibility to obtain loan
10            forgiveness of payroll costs paid to a crewmember who has obtained his or her own
              PPP loan.
11

12   85 Fed. Reg. at 39066-67.
13            368.     On January 27, 2021, the President signed the Appropriations Act into law, which,
14   among other things, created the second draw loans under the PPP, and which is largely codified at 15
15   U.S.C. § 636(a)(37).
16            369.     The second draw PPP provisions of the Appropriation Act states:
17            Except as otherwise provided in this paragraph, the Administrator may guarantee
              covered loans to eligible entities under the same terms, conditions, and processes as
18            a loan made under paragraph [15 U.S.C. § 636(a)](36).
19   15 U.S.C. § 636(a)(37)(B) (clarification added).
20
              370.     The Appropriation Act provides, in regard to Second Draw PPP eligibility:
21
              (iv) the term “eligible entity”—
22
              (III) does not include—
23
              (aa) any entity that is a type of business concern (or would be, if such entity were a
24            business concern) described in section 120.110 of title 13, Code of Federal
              Regulations (or in any successor regulation or other related guidance or rule that may
25            be issued by the Administrator) other than a business concern described in subsection
              (a) or (k) of such section; or
26
              (bb) any business concern or entity primarily engaged in political or lobbying
27            activities, which shall include any entity that is organized for research or for engaging
              in advocacy in areas such as public policy or political strategy or otherwise describes
28
                                                64                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 65 of 169



 1            itself as a think tank in any public documents;

 2            (cc) any business concern or entity—

 3            (AA) for which an entity created in or organized under the laws of the People's
              Republic of China or the Special Administrative Region of Hong Kong, or that has
 4            significant operations in the People's Republic of China or the Special Administrative
              Region of Hong Kong, owns or holds, directly or indirectly, not less than 20 percent
 5            of the economic interest of the business concern or entity, including as equity shares
              or a capital or profit interest in a limited liability company or partnership; or
 6
              (BB) that retains, as a member of the board of directors of the business concern, a
 7            person who is a resident of the People's Republic of China;
 8            (dd) any person required to submit a registration statement under section 612 of Title
              22; or
 9
              (ee) an eligible person or entity (as defined under section 24 of the Economic Aid to
10            Hard-Hit Small Businesses, Nonprofits, and Venues Act) that receives a grant under
              such section 24;
11
     15 U.S.C. § 636(a)(37)(A)(iv)(III). Hereafter, 15 U.S.C. § 636(37)(A)(iv)(III)(aa) shall be referred
12
     to as the “Incorporating Statute.”
13
              371.     The Appropriation Act expanded eligibility for the second draw PPP loans to include,
14
     as eligible businesses, churches and religious organizations:
15
              (c) ELIGIBLE CHURCHES AND RELIGIOUS ORGANIZATIONS.—
16

17            (1) SENSE OF CONGRESS.—It is the sense of Congress that the interim final rule
                  of the Administration entitled ‘‘Business Loan Program Temporary Changes;
18                Paycheck Protection Program’’ (85 Fed. Reg. 20817 (April 15, 2020)) properly
                  clarified the eligibility of churches and religious organizations for loans made
19                under paragraph (36) of section 7(a) of the Small Business Act (15 U.S.C. 636(a)).
20   Appropriations Act, § 311(c). Such entities would otherwise have been ineligible for PPP loans under
21   13 C.F.R. § 120.110(k).
22            372.     The Appropriation Act expanded eligibility for the Second Draw PPP, by amending
23   the PPP to include, as eligible businesses, among other entities:
24                     a.     “housing cooperatives” and “small agricultural cooperatives,” see EAA §
25            311(a) (adding 15 U.S.C. § 636(a)(37)(A)(i)), which, until 2017, may have been ineligible
26            pursuant to 13 C.F.R. § 120.110(l) (see 82 Fed. Reg. 39491, 39492 (Final, Aug. 21, 2017);
27                     b.     a wider range of religious entities, by waiving SBA’s rule prohibiting loans to
28
                                                65                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC              Document 18       Filed 10/10/24    Page 66 of 169



 1            certain faith-based entities, see EAA § 311(a) (adding 15 U.S.C. § 636(a)(37)(A)(iv)(III)(aa);

 2            EAA § 311(c)(ii), which were previously ineligible pursuant to 13 C.F.R. § 120.110(k); and

 3                     c.        non-profit businesses, by waiving SBA’s rule prohibiting loans to the same,

 4            see EAA § 311(a) (adding 15 U.S.C. § 636(a)(37)(A)(iv)(III)(aa).

 5            373.     The Appropriation Act further expanded eligibility for the Second Draw PPP, by

 6   amending the PPP to include, as eligible businesses, certain news businesses:

 7            (II) Eligibility of news organizations

 8            (aa) Definition
 9
              In this subclause, the term “included business concern” means a business concern,
10            including any station which broadcasts pursuant to a license granted by the Federal
              Communications Commission under title III of the Communications Act of 1934 (47
11            U.S.C. 301 et seq.) without regard for whether such a station is a concern as defined
              in section 121.105 of title 13, Code of Federal Regulations, or any successor thereto—
12
              (AA) that employs not more than 500 employees, or the size standard established by
13            the Administrator for the North American Industry Classification System code
              applicable to the business concern, per physical location of such business concern; or
14
              (BB) any nonprofit organization or any organization otherwise subject to section
15            511(a)(2)(B) of the Internal Revenue Code of 1986 that is a public broadcasting entity
              (as defined in section 397(11) of the Communications Act of 1934 (47 U.S.C.
16            397(11))).

17            (bb) Eligibility

18            During the covered period, an included business concern shall be eligible to receive
              a covered loan if—
19
              (AA) the included business concern is majority owned or controlled by a business
20            concern that is assigned a North American Industry Classification System code
              beginning with 511110 or 5151 or, with respect to a public broadcasting entity (as
21            defined in section 397(11) of the Communications Act of 1934 (47 U.S.C. 397(11))),
              has a trade or business that falls under such a code; and
22
              (BB) the included business concern makes a good faith certification that proceeds of
23            the loan will be used to support expenses at the component of the included business
              concern that produces or distributes locally focused or emergency information.
24

25   15 U.S.C. § 636(a)(36)(D)(iii)(II) (previously, Appropriations Act, § 317 (a)(2)). Such entities’
26   eligibility under the CARES Act would have otherwise been uncertain pursuant to 13 C.F.R. §
27   120.110(r).
28
                                                66                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24    Page 67 of 169



 1            374.     Via 87 Fed. Reg. 38900 (June 30, 2022), SBA fully eliminated that prohibition against

 2   providing loans, including PPP loans, to “businesses principally engaged in teaching, instructing,

 3   counseling or indoctrinating religion or religious beliefs, whether in a religious or secular setting,”

 4   found at 13 C.F.R. § 120.110(k), specifically stating that “SBA has determined that . . . paragraph (k)

 5   of section 120.110 should be removed from the Agency’s regulations, and reserved[.]” 87 Fed. Reg.

 6   38900, 38901. Via the proposed rule:

 7
              SBA explained that this provision, which was promulgated in 1996, could be
 8            interpreted as impermissible exposing a special disability on organizations based on
              their religious status. Thus, the regulation may have caused uncertainty for Lenders
 9            and Borrowers determining the eligibility of an applicant for an SBA loan. . . .
10            The removal of section 120.110(k) will eliminate uncertainty for Lenders and
              Borrowers and . . . SBA will continue to apply relevant Supreme Court caselaw to
11            ensure that the proceeds of SBA business loans are used in a manner consistent with
              the First Amendment to the U.S. Constitution. Although this change is beneficial to
12            increase clarity and uncertainty, it will not result in any specific way SBA implements
              this provision. SBA is currently following the Supreme Court precedent when
13            analyzing eligibility for SBA financial assistance as it believes that any regulation
              which may be inconsistent with that precedent cannot be given effect.
14

15   Id. at 38906-07 (emphasis added).
16            375.     The Appropriations Act also expanded eligibility for the second draw PPP loans by
17   amending the PPP to include, as eligible businesses, certain lobbying and destination marketing
18   businesses:
19            (vii) Eligibility for certain 501(c)(6) organizations
20
              (I) In general
21
              Any organization that is described in section 501(c)(6) of the Internal Revenue
22            Code and that is exempt from taxation under section 501(a) of such Code (excluding
              professional sports leagues and organizations with the purpose of promoting or
23            participating in a political campaign or other activity) shall be eligible to receive a
              covered loan if—
24
              (aa) the organization does not receive more than 15 percent of its receipts from
25            lobbying activities;
26            (bb) the lobbying activities of the organization do not comprise more than 15 percent
              of the total activities of the organization;
27
              (cc) the cost of the lobbying activities of the organization did not exceed $1,000,000
28
                                                67                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 68 of 169



 1            during the most recent tax year of the organization that ended prior to February 15,
              2020; and
 2
              (dd) the organization employs not more than 300 employees.
 3
              (II) Destination marketing organizations
 4

 5            Any destination marketing organization shall be eligible to receive a covered loan
              if—
 6
              (aa) the destination marketing organization does not receive more than 15 percent of
 7            its receipts from lobbying activities;

 8            (bb) the lobbying activities of the destination marketing organization do not comprise
              more than 15 percent of the total activities of the organization;
 9
              (cc) the cost of the lobbying activities of the destination marketing organization did
10            not exceed $1,000,000 during the most recent tax year of the destination marketing
              organization that ended prior to February 15, 2020; and
11
              (dd) the destination marketing organization employs not more than 300 employees;
12            and

13            (ee) the destination marketing organization—

14            (AA) is described in section 501(c) of the Internal Revenue Code and is exempt from
              taxation under section 501(a) of such Code; or
15
              (BB) is a quasi-governmental entity or is a political subdivision of a State or local
16            government, including any instrumentality of those entities.

17   15 U.S.C. § 636(a)(36)(D)(vii) (previously, Appropriations Act, § 318(2)(C). Such entities would

18   otherwise have been ineligible for PPP loans under 13 C.F.R. § 120.110(j) and (r); see also 86 Fed.

19   Reg. 3692, 3697 n.26 (Interim Final Rule Jan. 14, 2021)

20            376.     The Appropriations Act also expanded eligibility for the second draw PPP loans by

21   amending 11 U.S.C. § 364 to include, as eligible businesses, businesses in bankruptcy:

22            ‘(g)(1) The court, after notice and a hearing, may authorize a debtor in possession or
              a trustee that is authorized to operate the business of the debtor under section 1183,
23            1184, 1203, 1204, or 1304 of this title to obtain a loan under paragraph (36) or (37)
              of section 7(a) of the Small Business Act (15 U.S.C. 636(a)), and such loan shall be
24            treated as a debt to the extent the loan is not forgiven in accordance with section 7A
              of the Small Business Act or subparagraph (J) of such paragraph (37), as applicable,
25            with priority equal to a claim of the kind specified in subsection (c)(1) of this section.

26            ‘(2) The trustee may incur debt described in paragraph (1) notwithstanding any
              provision in a contract, prior order authorizing the trustee to incur debt under this
27            section, prior order authorizing the trustee to use cash collateral under section 363, or
              applicable law that prohibits the debtor from incurring additional debt.
28
                                                68                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 69 of 169



 1
              ‘(3) The court shall hold a hearing within 7 days after the filing and service of the
 2            motion to obtain a loan described in paragraph (1). Notwithstanding the Federal Rules
              of Bankruptcy Procedure, at such hearing, the court may grant relief on a final basis.’
 3

 4   Appropriations Act, § 320(a). SBA had previously determined that such entities were ineligible for

 5   PPP loans. 85 Fed. Reg. 23450, 23451(Interim Final Rule, Apr 28, 2020) (“Will I be approved for a

 6   PPP loan if my business is in bankruptcy? No.”).

 7            377.     The provisions of the Appropriation Act regarding second draw PPP loans instruct the

 8   SBA to promulgate rules as follows:

 9            (M) Publication of guidance

10            Not later than 10 days after December 27, 2020, the Administrator shall issue
              guidance addressing barriers to accessing capital for minority, underserved, veteran,
11            and women-owned business concerns for the purpose of ensuring equitable access to
              covered loans.
12

13   15 U.S.C. § 636(a)(37)(M).
14            378.     Title III, Section 303 of the Appropriations Act (also known by the “Economic Aid to
15   Hard-Hit Small Businesses, Nonprofits, and Venues Act”), instructs the SBA to promulgate rules as
16   follows:
17            Not later than 10 days after the date of enactment of this Act, the Administrator shall
              issue regulations to carry out this Act and the amendments made by this Act without
18            regard to the notice requirements under section 553(b) of title 5, United States Code.
19   Appropriations Act, § 303 (now codified as 15 U.S.C. § 9012).
20            379.     Pursuant to the provisions of the Appropriations Act that apply to second draw PPP
21   loans, the SBA did, in fact, promulgate numerous regulations.
22            380.     On March 8, 2021, the SBA published, in the Federal Register, 86 Fed. Reg. 13149-
23   56 (Interim Final Rule, Mar. 8, 2021), an Interim Final Rule titled “Business Loan Program
24   Temporary Changes; Paycheck Protection Program—Revisions to Loan Amount Calculation and
25   Eligibility,” which:
26            remove[s] the eligibility restriction that prevents businesses with owners who have non-
              financial fraud felony convictions in the last year from obtaining PPP loans and remove[s]
27            the eligibility restriction that prevents businesses with owners who are delinquent or in
              default on their Federal student loans from obtaining PPP loans. The changes apply to both
28
                                                69                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 70 of 169



 1            First Draw PPP Loans and Second Draw PPP Loans.

 2   86 Fed. Reg. 13149 (clarification added). The SBA reasoned that removing these eligibility
 3   restrictions were:
 4            appropriate to ensure consistency with Congressional intent to provide relief to small
              businesses and their employees, expand access to the PPP, and remove barriers people
 5            with prior convictions face when working to restart their lives and contribute to our
              economy. SBA has determined that the one-year lookback restriction related to non-
 6            financial fraud felonies should be removed and only the five-year lookback restriction
              for those felonies involving fraud, bribery, embezzlement, or a false statement in a
 7            loan application or an application for federal financial assistance will limit an
              applicant’s eligibility for the PPP. Removing the one-year lookback restriction related
 8            to non-financial fraud felonies is consistent with Congressional support for reducing
              criminal background checks in the PPP and the important policies underlying recent
 9            criminal justice reforms in Congress, such as last year’s Fair Chance to Compete for
              Jobs Act of 2019 (Pub. L. 116–92, Div. A, Tit. XI, Subtit. B,) and the First Step Act
10            of 2018 (Pub. L. 115–391).
11                                               *      *       *
12            By removing barriers for applicants with non-financial fraud felonies, this interim
              final rule balances the need to increase access to the PPP and remove barriers for
13            people with prior convictions while still ensuring basic guardrails against fraud exist
              for this emergency program. Preserving the five-year lookback for financial fraud-
14            related felonies is one of these guardrails.
15                                               *      *       *
16            SBA has determined that eliminating consideration of delinquent or defaulted Federal
              student loans is appropriate to ensure consistency with Congressional intent to
17            provide relief to small businesses and their employees and expand access to the PPP.
              This change will make PPP loans available to more borrowers with financial need and
18            is consistent with Congress’s intent that PPP loans be prioritized for small business
              concerns owned and controlled by socially and economically disadvantaged
19            individuals as defined in section 8(d)(3)(c) of the Small Business Act.13 According
              to the Department of Eduction [sic], ‘‘Black and Brown students rely more heavily
20            on student loan debt than their peers and experience delinquency at disproportionately
              high rates. As a result prohibiting delinquent student loan borrowers from obtaining
21            PPP loans is more likely to exclude business owners of color from access to the loans
              they need.’’ In addition, this change is consistent with the policy set in section 3513
22            of the CARES Act and the Department of Education’s ongoing actions to provide
              economic relief to student loan borrowers whose loans are held by the agency by
23            suspending Federal student loan payments and collections during the pandemic and
              keeping the interest rate at 0 percent.
24
              At the request of the Department of Education by letter dated February 27, 2021,
25            Treasury also has granted an exemption from the bar in 31 U.S.C. 3720B and 31 CFR
              285.13, with respect to PPP borrowers with Federal student loans in delinquent status.
26
              The change in PPP regulations relating to Federal student loans and the Treasury
27            exemption apply to new PPP applicants as well as those borrowers who have already
              received a PPP loan. In this way, PPP borrowers with delinquent or defaulted student
28
                                                70                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24     Page 71 of 169



 1            loan debts are treated equally, without regard to when they submitted their PPP
              application.
 2
     86 Fed. Reg. 13154-55.
 3
              381.     On March 11, 2021, the President signed ARPA into law, which, among other things,
 4
     modified both first and second draw PPP loan provisions via Section 5001 thereof.
 5
              382.     On March 22, 2021, the SBA published, in the Federal Register, an Interim Final Rule
 6
     titled “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by
 7
     American Rescue Plan Act,” 86 Fed. Reg. 15083 (Interim Final Rule, Mar 22, 2021), which provides
 8
     that “[t]he intent of the CARES Act, the Economic Aid Act, and the American Rescue Plan Act is
 9
     that SBA provide relief to America’s small businesses and nonprofit organizations expeditiously.”
10
     Id. at 15084.
11
              383.     Generally, Section 5001 of ARPA amended the PPP to increase eligibility for certain
12
     non-profit organizations, including non-profit organizations that conduct lobbying activities and
13
     internet publishing organizations.
14
              384.     Specifically, ARPA added the following to 15 U.S.C. § 36(a):
15
              ‘‘(xvii) the term ‘additional covered nonprofit entity’—
16
              ‘‘(I) means an organization described in any paragraph of section 501(c) of the
17            Internal Revenue Code of 1986, other than paragraph (3), (4), (6), or (19), and exempt
              from tax under section 501(a) of such Code; and
18
              ‘‘(II) does not include any entity that, if the entity were a business concern, would be
19            described in section 120.110 of title 13, Code of Federal Regulations (or in any
              successor regulation or other related guidance or rule that may be issued by the
20            Administrator) other than a business concern described in paragraph (a) or (k) of such
              section.’’; and
21
              (B) in subparagraph (D)—
22
              (i) in clause (iii), by adding at the end the following:
23
              ‘‘(III) ELIGIBILITY OF CERTAIN ORGANIZATIONS.—
24            Subject to the provisions in this subparagraph, during the covered period—
25            ‘‘(aa) a nonprofit organization shall be eligible to receive a covered loan if the
              nonprofit organization employs not more than 500 employees per physical location
26            of the organization; and
27            ‘‘(bb) an additional covered nonprofit entity and an organization that, but for
              subclauses (I)(dd) and (II)(dd) of clause (vii), would be eligible for a covered loan
28
                                                71                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24      Page 72 of 169



 1            under clause (vii) shall be eligible to receive a covered loan if the entity or
              organization employs not more than 300 employees per physical location of the entity
 2            or organization.’’; and

 3            (ii) by adding at the end the following:

 4            ‘‘(ix) ELIGIBILITY OF ADDITIONAL COVERED NONPROFIT
              ENTITIES.—An additional covered nonprofit entity shall be eligible to receive a
 5            covered loan if—

 6            ‘‘(I) the additional covered nonprofit entity does not receive more than 15 percent of
              its receipts from lobbying activities;
 7
              ‘‘(II) the lobbying activities of the additional covered nonprofit entity do not comprise
 8            more than 15 percent of the total activities of the organization;

 9            ‘‘(III) the cost of the lobbying activities of the additional covered nonprofit entity did
              not exceed $1,000,000 during the most recent tax year of the additional covered
10            nonprofit entity that ended prior to February 15, 2020; and

11            ‘‘(IV) the additional covered nonprofit entity employs not more than 300
              employees.’’.
12
              (2) ELIGIBILITY FOR SECOND DRAW LOANS.—Paragraph (37)(A)(i) of section
13            7(a) of the Small Business Act (15 U.S.C. 636(a)), as added by the Economic Aid to
              Hard-Hit Small Businesses, Nonprofits, and Venues Act (title III of division N of
14            Public Law 116–260), is amended by inserting ‘‘ ‘additional covered nonprofit
              entity’,’’ after ‘‘the terms’’.
15
     ARPA, § 5001(a)(1)(A)-(B) & (a)(2).
16
                 FACTS RELATING TO PLAINTIFFS’ ESTOPPEL CAUSE OF ACTION
17
              385.     In reliance upon the terms of the Loan Agreements and the provisions of the PPP, the
18
     Plaintiffs used the portions of the Loan Proceeds that they seek forgiveness of only for the Permitted
19
     Uses and no other uses whatsoever. More specifically, as a result of receiving the Loan Proceeds,
20
     Plaintiffs kept as many of their employees as possible employed during the various Pandemic
21
     governmental shutdowns so that those employees would not be required to seek and obtain
22
     unemployment compensation or other forms of governmental assistance.
23
              386.     At all times, each Plaintiff has fully abided by all of its obligations under the Loan
24
     Agreement or Loan Agreements to which it is bound.
25
              387.     But for receipt of the Loans Proceeds, the Plaintiffs would not have been able, during
26
     governmental shutdowns and the immediate time periods thereafter because of the significant drop
27

28
                                                72                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 73 of 169



 1   of business resulting from the Pandemic, to continue the employment of many of their employees.

 2   Through and with the Loan Proceeds, the Plaintiffs paid wages to the retained employees and paid

 3   and/or remitted all withholding taxes due on such wages or related thereto to the applicable federal

 4   and state authorities.

 5            388.     But for the receipt of the Loan Proceeds, the Plaintiffs, during the governmental

 6   shutdowns and the immediate time periods thereafter, may not have continued the employment of

 7   many of their employees during that time period. In other words, but for the receipt of the Loan

 8   Proceeds permitted Plaintiffs to keep a number of their employees on payroll such that, without the

 9   Loan Proceeds, these employees would have either a) not been paid or b) have applied for other

10   governmental assistance programs such as unemployment.

11            389.     Nevertheless, due to the extent of certain governmentally mandated Pandemic

12   shutdowns and/or closure orders, a number of the Plaintiffs were not able to use all of their Loan

13   Proceeds for the Permitted Uses; primarily as a result of the inability to have numerous employees

14   actually undertake work-related activities for which compensation in the form of wages would then

15   be due and payable.

16            390.     As a result of the circumstances set forth in the paragraph immediately above,

17   Plaintiffs Deja Vu Showgirls of Las Vegas, LLC; Office Minneapolis, LLC; Cats 701 Bourbon, LLC;

18   90’s Minneapolis, LLC; Las Vegas Bistro, LLC; Stockton Enterprises, LLC returned to their Lending

19   Banks those portions of their Loan Proceeds that they were unable to use for the Permitted Uses, to

20   wit: Plaintiff Deja Vu Showgirls of Las Vegas, LLC returned $7,207.02; Plaintiff Office Minneapolis,

21   LLC returned $55,966.51; Plaintiff Cats 701 Bourbon, LLC returned $70,350.77; Plaintiff 90’s

22   Minneapolis, LLC returned $25,486.74; Plaintiff Las Vegas Bistro, LLC returned $303,039.48; and

23   Plaintiff Stockton Enterprises, LLC returned $96,738.94.

24            391.     For all other Loan Proceeds, the Plaintiffs used them, as stated above, in accordance

25   with the Loan Agreements and the PPP, and therefore no longer have possession of any of such Loan

26   Proceeds.

27            392.     In addition, because Plaintiffs’ employees provided the work for which they had been

28
                                                73                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 74 of 169



 1   retained, Plaintiffs have no legal remedy to recoup such Loan Proceeds from their employees and

 2   ex-employees in the event that the SBA is successful in negating the Loans.

 3            393.     Further, because Plaintiffs paid, among other things, various utility bills as they

 4   became due, rent, and mortgages, during the Pandemic, all of which are Permitted Uses, Plaintiffs

 5   have no legal remedy to recoup such Loan Proceeds from, for example, their trash service provider,

 6   internet service provider, landlord, etc., in the event that the SBA is successful in negating the Loans.

 7            394.     Through the distribution of the Loan Proceeds pursuant to the Loan Agreements and

 8   the PPP, a substantial portion of the Loan Proceeds have already been returned to the Treasury in the

 9   form of income and payroll taxes paid by or on behalf of the ultimate recipients of the Loan Proceeds;

10   most of whom were the employees of the Plaintiffs, service providers of the Plaintiffs, or landlords

11   of the Plaintiffs.

12            395.     For Loan Proceeds that have already been returned to the Treasury in the form of

13   payroll taxes paid on behalf of Plaintiffs’ employees, the Plaintiffs themselves remitted such taxes to

14   the Treasury.

15            396.     In addition to the Loan Proceeds discussed in the paragraph immediately above, other

16   Loan Proceeds have also already been returned to the Treasury in the form of income and other taxes

17   due on or related to the purchase of goods and services by Plaintiffs’ employees out of the wages

18   they received from the Plaintiffs through the Loan Proceeds.

19            397.     In addition to the Loan Proceeds discussed in two paragraphs immediately above,

20   other Loan Proceeds have also already been returned to the Treasury in the form of, for example,

21   income taxes from Plaintiffs’ landlords, income taxes for personal protective equipment (i.e.,

22   “worker protection expenditures,” see 15 U.S.C. § 636(a)(36)(F)(i)(XI)), purchased by Plaintiffs and

23   paid by the vendors that sold such equipment, and income taxes on utilities such as trash and internet

24   services paid by Plaintiffs’ vendors of these services.

25            398.     As a result of the facts and circumstances set forth in the seven paragraphs

26   immediately above, if Plaintiffs are required to pay back the Loan Proceeds (which they no longer

27   themselves possess), the federal government will realize a substantial, inequitable, and “double

28
                                                74                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 75 of 169



 1   dipping” of compensation in the form of the Loan Proceeds.

 2                          FACTS RELATING TO PRIOR OHA PROCEEDINGS

 3            399.     Prior to the matters involved in this action, the undersigned firm had initiated
 4   approximately16 appeals in the OHA.
 5            400.     Of the prior administrative appeals that the undersigned firm has filed, not a single
 6   one resulted in a final ruling by the OHA. One was dismissed on procedural grounds. In all of the
 7   others, the SBA withdrew its final determination in order to permit it to come up with a “new” reason
 8   to justify denial of eligibility; with all such matters subsequently being resolved by formal
 9   settlements between the undersigned firm’s clients and the SBA.
10            401.     In the previous OHA appeals where the SBA had withdrawn its final determination,
11   it either stayed the appeal pending issuance of the “new and improved” FLRD or moved for dismissal
12   of the OHA appeal (one such motion having been granted by the OHA the same day as the filing of
13   the SBA’s motion for dismissal, without the appellant there even being permitted the opportunity to
14   respond, despite 13 C.F.R. § 134.211(c) permitting the non-moving party fifteen days to respond to
15   a motion).
16            402.     In one particular instance, the undersigned firm filed an appeal with the OHA; the
17   SBA then withdrew that FLRD; the OHA appeal was then dismissed; the SBA then came up with a
18   second reason to deny forgiveness and issued a second FLRD; the undersigned firm then filed a
19   second appeal in the OHA on behalf of that client; and the SBA then withdrew that second FLRD as
20   well (litigation thereafter being avoided by the SBA subsequently resolving its dispute with that
21   entity as part of a “group” settlement).
22            403.     In several of the instances where the SBA has withdrawn the FLRD, it has done so
23   not at the early stages of the appeal; but rather, after reviewing the appeal brief, filing the
24   administrative record, and reviewing the appellant’s objections to the administrative record. Such
25   instances increased the cost of these appeals, in terms of professional fees (both attorney and
26   accountant), exponentially.
27                  FACTS AND LAW RELATING TO THE OHA PROCEEDINGS
                 UNDERLYING THIS LAWSUIT, AND PLEADINGS IN AVOIDANCE OF
28
                                           75                  Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 76 of 169



 1                             ADMINISTRATIVE REMEDIES EXHAUSTION

 2            404.     13 C.F.R., Ch. I, Pt. 134, Subpart L, titled “Borrower Appeals of Final Sba Loan
 3   Review Decisions,” 13 C.F.R. §§ 134.1201 – 1217, provides “rules of practice” that apply only “to
 4   appeals to OHA from certain final SBA loan review decisions under the Paycheck Protection
 5   Program[.]” 13 C.F.R. § 134.1201(a). These regulations will be collectively referred to hereinafter
 6   as the “Special OHA Rules.” Plaintiffs only challenge these Special OHA Rules that apply solely to
 7   PPP loans, i.e., 13 C.F.R., Ch. I, Pt. 134, Subpart L; they do not challenge the “normal” OHA
 8   appellate rules that apply to appeals related to all other SBA-related funding decisions generally
 9   found at 13 C.F.R., Ch. I, Pt. 134, Subparts A – M, excluding Subpart L.
10            405.     The OHA was never designed to handle the number of appeals emanating from the
11   PPP and other Pandemic funding programs. As a result, in order to administer and decide such
12   appeals, the OHA uses “administrative law judges” or “administrative judges” from other federal
13   agencies and does not even require, for PPP related appeals, administrative law judges to adjudicate
14   appeals. Rather, the Special OHA Rules permit outside attorneys hired by the SBA, and referred
15   herein to as “OHA Attorneys,” to sit in consideration of, and to decide, appeals in the OHA. See 13
16   C.F.R. § 134.1206. The screenshot attached hereto as Exhibit W demonstrates that OHA Attorney
17   Loreen McCloskey submitted the order signed by the Administrative Judge dismissing the appeal the
18   same day that SBA filed a motion to dismiss and, upon information and belief, Constance T. O’Bryant
19   is a retired administrative law judge. See https://www.linkedin.com/in/constance-obryant-
20   109b0385/.
21            406.     13 C.F.R. § 134.1209(c) provides that all appeals in the OHA are to be “decided solely
22   on a review of the administrative record, the appeal petition, any response, any reply or supplemental
23   pleading, and filings related to objection to the administrative record.” There is no right for the
24   appellant to obtain any form of hearing in the OHA for PPP loans. Id.
25            407.     13 C.F.R. § 134.1209(a) provides that “[g]enerally, the Judge may not admit evidence
26   beyond the administrative record.”
27            408.     Under the general rules of the OHA, a party may obtain discovery “upon motion, and
28
                                                76                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24      Page 77 of 169



 1   for good cause shown.” 13 C.F.R. § 134.213(a). Permissible discovery includes requests for

 2   admissions, requests for production of documents, interrogatories, and depositions. See 13 C.F.R. §

 3   134.213(b).

 4            409.     However, the SBA has promulgated a rule, initially without public notice or comment,

 5   specifically precluding discovery “in appeals from final SBA loan review decisions” under the PPP.

 6   13 C.F.R. § 134.1209(b); see also 13 C.F.R. § 134.1201(h) (enumerating select provisions of 13

 7   C.F.R., Ch. I, Pt. 134, Subpart B for incorporation into Subpart L, and expressly stating that “[o]ther

 8   provisions from subpart B of this part that are not specifically referenced in this subpart do not apply

 9   to this subpart.”).

10            410.     As a result of the provisions of 13 C.F.R. § 134.1209(b), all of these Plaintiffs are, by

11   adopted regulation, precluded from obtaining any discovery whatsoever in the OHA before their

12   matters can proceed to court. Further, as discussed, infra, several of these Plaintiffs have filed

13   motions in the OHA seeking discovery; all of which were denied. [See Ex. H].

14            411.     Upon information and belief, the SBA will contend in this litigation or any litigation

15   resulting from an OHA appeal that the Court is limited to the factual record “developed” in the OHA

16   (and see further discussion below in this regard).

17            412.     In various OHA appeals, SBA has attempted to add “evidence” to support its FLRD

18   after issuance of the FLRD and which is not contained in the administrative record; including in the

19   OHA appeals of Meacham and Gold Club.

20            413.     On or about May 14, 2024, Meacham “won” its OHA appeal by, among other things,

21   demonstrating a lack of evidence in the administrative record to support SBA’s conclusions set forth

22   in the FLRD and that OHA judge’s refusal to accept SBA’s late “evidence” proffered by declaration

23   accompanying SBA’s response in that appeal.

24            414.     To support the FLRDs that SBA issued Meacham and SAW, SBA included the same

25   type of evidence, namely, google maps photographs of the street view of these Plaintiffs’ buildings,

26   in both of those Plaintiff’s administrative records.

27            415.     Upon information and belief, SBA, fearing SAW’s second appeal of SBA’s denial of

28
                                                77                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 78 of 169



 1   forgiveness on its first draw PPP Loan would be meritorious for the same reasons as Meacham’s was,

 2   withdrew the FLRD that SAW was appealing—thereby needlessly increasing SAW’s costs in this

 3   process of achieving Loan forgiveness

 4            416.     SBA’s tactics as described in the previous paragraph could forever prohibit these

 5   plaintiffs from obtaining review by an Article III judge.

 6            417.     This action asks this Court to resolve numerous constitutional matters; including both

 7   facial challenges and challenges to the SBA’s application of the various regulations and statutes

 8   challenged herein, as well as to conduct a judicial review of the second FLRD issued by SBA on

 9   Gold Club’s second draw PPP Loan and the May 14 Order affirming the same (summarized above

10   and specifically delineated below).

11            418.     As consistently stated by the Supreme Court, constitutional questions are beyond the

12   jurisdiction of administrative agencies, and therefore beyond the jurisdiction of the OHA. See, e.g.,

13   Carr v. Saul, 593 U.S. 83, 92 (2021) (numerous citations omitted) (“. . . this Court has often observed

14   that agency adjudications are generally ill suited to address structural constitutional challenges,

15   which usually fall outside the adjudicators’ area of technical expertise”); Califano v. Sanders, 430

16   U.S. 99, 109 (1977) (“Constitutional questions are obviously unsuited to resolution in administrative

17   hearing procedures and, therefore, access to the court is essential to the decision of such questions.”);

18   Johnson v. Robison, 415 U.S. 361, 368 (1974) (“Adjudication of the constitutionality of

19   congressional enactments has generally been thought beyond the jurisdiction of administrative

20   agencies.”); Mobility Workx, LLC v. Unified Pats., LLC, 15 F.4th 1146, 1150 (Fed. Cir. 2021)

21   (cleaned up; collecting cases) (“Under Supreme Court and circuit precedent, agencies generally do

22   not have authority to declare a statute unconstitutional. It follows that constitutional challenges to

23   the statute under which the agency operates need not be raised before the agency.”); see also 5 U.S.C.

24   § 706 (“. . . the reviewing court shall decide all relevant questions of law, interpret constitutional and

25   statutory provisions . . . .”); Crowell v. Benson, 285 U.S. 22, 60 (1932) (“In cases brought to enforce

26   constitutional rights, the judicial power of the United States necessarily extends to the independent

27   determination of all questions, both of fact and law, necessary to the performance of that supreme

28
                                                78                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 79 of 169



 1   function.”); [see also Ex. I , at p. 17 (SBA explaining, in its response to Gold Club’s appeal, that

 2   OHA does not have the authority “to consider the validity of an SBA regulation”)]. 3

 3            419.     In addition, administrative agencies do not have the jurisdiction to decide the

 4   constitutionality of their own regulations. See, e.g., Gilbert v. Nat'l Transp. Safety Bd., 80 F.3d 364,

 5   366 (9th Cir. 1996) (collecting cases) (“Generally, challenges to the constitutionality of a statue or

 6   regulation promulgated by an agency are beyond the power or the jurisdiction of an agency.”); Motor

 7   & Equip. Mfrs. Ass'n, Inc. v. E.P.A., 627 F.2d 1095, 1114-15 (D.C. Cir. 1979), cert denied 446 U.S.

 8   952; Thunder Basin Coal Co. v. Reich, 510 U.S. 200, 215 (1994); Gonzalez v. Metro. Transp. Auth.,

 9   174 F.3d 1016, 1018 (9th Cir. 1999) (noting that “[t]he constitutionality of agency drug testing

10   regulations is reviewed de novo.”).

11            420.     In particular, the OHA does not have the ability to consider the validity of an SBA

12   regulation. [See, e.g., Exhibit X (SBA Response to Plaintiff Meacham’s Motion for Discovery in the

13   OHA, arguing that OHA does not have the “ability to consider the validity of an SBA regulation”

14   and that Administrative Law Judges “do not have constitutionally-backed judicial power” and

15   therefore cannot entertain constitutional challenges); Exhibit Y (the Administrative Law Judge in

16   Plaintiff Gold Club’s first draw OHA appeal specifically stating “[n]othing in the Administrative

17   Procedures Act, the Small Business Act, or SBA regulations gives OHA the ability to consider the

18   validity of an SBA regulation”); Ex. K (OHA Order in Gold Club’s second appeal of the denials of

19   forgiveness regarding its second draw PPP Loan, the OHA judge, at page 10 of the order, stating, in

20   regards to Gold Club’s constitutional and EAJA claims, “I lack authority to decide the issues raised

21   by Appellant”); Ex. I (discussed, supra, paragraph 418]; 13 C.F.R. § 134.102.

22            421.     Nevertheless, the SBA’s administration of the PPP purports to require Plaintiffs to

23   first seek review by the OHA before moving to federal court. See 134 C.F.R. § 134.1201(d).

24

25   3
       Plaintiffs acknowledge that citation to case law is not normally encouraged in formal federal
     complaints. However, since Plaintiffs have the burden to plead in avoidance of the requirement that
26   they first exhaust their administrative remedies before repairing to this Court, Plaintiffs include
     citations to establish just that point and to carry that burden. Other case citations are included to
27   accurately describe the legal standards applicable to a number of the Plaintiffs’ constitutional
     challenges contained herein.
28
                                                       79                          Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 80 of 169



 1            422.     The Supreme Court has acknowledged “a futility exception to exhaustion

 2   requirements.” Carr, 593 U.S. at 93. As stated by the Supreme Court, “[i]t makes little sense to require

 3   litigants to present claims to adjudicators who are powerless to grant the relief requested.” Id.

 4            423.     Pursuant to the Special OHA Rules, each Plaintiff that has been denied Loan

 5   forgiveness has filed an appeal of each denial with the OHA as discussed herein, supra.

 6            424.     Unlike normal “court” appeals, the actual appeal brief in the OHA—where the

 7   appellant argues the factual and legal merits of its appellate claims—must be filed as part of the

 8   appellant’s initial submissions and before the appellant has received the administrative record from

 9   the SBA which documents (or purports to document) the SBA’s reasoning for its decision. See 13

10   C.F.R. §§ 134.1202(a) (noting the 30-day timeline from receipt of the FLRD to file an appeal

11   petition); 134.1204(a) (noting the content requirements for an appeal petition, which specifically

12   includes “[a] full and specific statement as to why the [FLRD] is alleged to be erroneous, together

13   with all factual information and legal arguments supporting the allegations”); 134.1204(b) (noting

14   an appeal may be dismissed if it does not contain the required information); 134.1206 (requiring the

15   OHA judge to issue a Notice and Order to “establish[] a deadline for production of the administrative

16   record and specify[] a date by which SBA may respond to the appeal,” after the appeal has been

17   filed); 134.1207(a) (noting that the “administrative record will be due 20 calendar days after issuance

18   of the Notice and Order”); 134.1207(b) (discussing the required contents of the administrative record,

19   which, apparently, does not include “all documents pertaining to the appellant,” only those the SBA

20   deems “relevant” to its consideration when making the FLRD “or that were before SBA at the time

21   of the” FLRD); 134.1208(b) (noting SBA has 45 calendar days to respond to the appeal petition after

22   issuance of the Notice and Order); see also Notice and Order (Scheduling Order) for Dallas Food

23   and Beverage’s OHA Appeal [Exhibit Z].

24            425.     The administrative records involving the Plaintiffs, filed by the SBA in the OHA after

25   the appellant has submitted its brief on the merits, can comprise thousands of pages of documents.

26   For example, the administrative record for the OHA appeal of Plaintiff SAW comprised 6,206 pages.

27            426.     Regardless of the length of the administrative record, absent relief from the OHA, the

28
                                                80                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 81 of 169



 1   appellant is only provided 10 days to review the entire administrative record and to then file with the

 2   OHA any objections to the contents thereof. 13 C.F.R. §§ 1207(a) (noting that the administrative

 3   record is due “20 calendar days after issuance of the Notice and Order”); 1207(e) (noting that

 4   objections “to the administrative record must be filed with OHA and served on SBA no later than 30

 5   days after the issuance of the Notice and Order,” and allowing for an additional 10 calendar day

 6   extension “from the date SBA is required to file the administrative record” “[i]f additional time to

 7   file the administrative record was requested”).

 8            427.     After receipt of the administrative record, an OHA appellant has no unconditional

 9   right to submit further briefing in support of its position and to place the contents, or lack thereof, of

10   the administrative record in context to the appellate arguments that had previously been made by the

11   appellant. 13 C.F.R. § 134.1208(e) (“Generally, a reply to a response is not permitted unless the Judge

12   directs otherwise.”).

13            428.     Although an OHA appeal is purportedly to be based upon the administrative record

14   applicable to that particular appeal, some of the Plaintiffs have actually received administrative

15   records from the SBA that contain numerous redactions (through simply “blacked out” text) without

16   any further explanation and SBA has been permitted to supply “evidence” with its response to OHA

17   appellants’ appeals via declaration.

18            429.     As a result of the redactions to the administrative records as stated in the paragraph

19   immediately above, a number of the Plaintiffs (including Gold Club) have not even been provided

20   with a full record of the documentation pertaining to their administrative appeals; they do not know

21   the full contents of the administrative record being used against them to justify denial of their loan

22   forgiveness applications; and it is simply impossible for them to file full and substantive objections

23   to those portions of the administrative record that they simply have not seen.

24            430.     In most of Plaintiffs’ OHA appeals, the particular Plaintiff filed, contemporaneously

25   with the submission of the appeal or shortly thereafter, a motion for discovery seeking leave to obtain

26   certain discovery that the appellants (Plaintiffs here) felt was essential for the proper consideration

27   of its OHA appeal and for the proper adjudication of any such ruling by a federal court. The motions

28
                                                81                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 82 of 169



 1   also requested that the responses to the discovery sought be included in the administrative record for

 2   such appeal.

 3            431.     In order to demonstrate the unconstitutional nature of the Special OHA Rules,

 4   Plaintiffs attach only three examples of the discovery motions filed by the Plaintiffs. Exhibit AA is

 5   the motion (including exhibits A-H thereto), filed on December 12, 2023, pertaining to the appeal of

 6   the denial of the application for forgiveness on Plaintiff Gold Club’s first draw PPP Loan; Exhibit

 7   BB is the motion (including exhibits A-D thereto), filed on December 13, 2023, pertaining to the

 8   appeal of the denial of the application for forgiveness on Plaintiff SAW’s first draw PPP Loan;

 9   Exhibit CC is the motion (including exhibits A-F thereto, filed on February 27, 2024, pertaining to

10   the appeal of the denial of the application for forgiveness on Plaintiff Meacham’s second draw PPP

11   Loan.

12            432.     The Gold Club (first and second draw loan appeals) and SAW matters were assigned

13   to Richard Ambrow, who is an administrative law judge from the Department of Health and Human

14   Services and who normally handles appeals dealing with Medicare claims.

15            433.     Each of the four discovery motions attached laid out in elaborate detail the discovery

16   being sought and the legal and factual reasons why that discovery was essential to the full

17   adjudication of appellants’ legal and factual claims. In addition, each motion contained a document

18   production request that specifically identified the documents requested, as well as a deposition notice

19   of the SBA that listed each area of inquiry. To the extent possible, the discovery requests followed

20   the format of the Federal Rules of Civil Procedure (the Special OHA Rules not including any

21   discovery format rules), and in particular the deposition notice provisions of FRCP 30(b)(6).

22            434.     The discovery motions filed in Plaintiffs’ OHA appeals specifically asserted that the

23   denial of such a motion would be a flagrant denial of the appellant’s fundamental due process rights.

24   [See, e.g., Ex. AA, at ¶ 77]. Each motion also stated appellant’s concern that the SBA would argue

25   in court that the court’s consideration of the appellant’s claims would be limited to the administrative

26   record contained in the OHA (hence the need for the discovery sought), and that the response of the

27   SBA to such motion would permit counsel for the SBA to address the appellant’s concern. [Id., ¶ 14].

28
                                                82                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18         Filed 10/10/24   Page 83 of 169



 1            435.     Mr. Ambrow denied Gold Club’s discovery motion on December 13, 2023, within 20

 2   hours of its submission [Order Denying Motion for Discovery, Ex. Y]. For SAW, Mr. Ambrow denied

 3   SAW’s discovery motion the same day, within three hours of its submission [Order Denying Motion

 4   for Discovery, Exhibit DD]. Both motions were denied before counsel for the SBA filed any

 5   response and, in the case of the SAW motion, before any counsel for the SBA had even been assigned.

 6            436.     The Gold Club and SAW motions were denied on the basis that no discovery was

 7   permitted in the OHA on appeals relating to PPP loans. Neither of these two OHA orders denying

 8   discovery addressed the impact upon the appellant’s due process rights as a result of the lack of such

 9   discovery other than containing a comment regarding the lack of authority of the OHA to “consider

10   the validity of an SBA regulation.” [E.g., Ex. Y].

11            437.     As a result of such expedited denials, Plaintiffs’ Gold Club and SAW and the OHA

12   were deprived of a response by the SBA as to whether the SBA will contend that subsequent court

13   review of an OHA decision is limited to the facts contained in the formal administrative record

14   prepared by the SBA.

15            438.     Further demonstrating the unconstitutional nature of the Special OHA Rules is the

16   fact that in Meacham and Gold Club’s appeals, SBA is seeking to or sought to, as applicable, add

17   evidence to support its FLRD that is not contained in the administrative record and to do so, SBA

18   contends that it has the authority to withdraw an FLRD at any point in time and reissue after updating

19   the administrative record. In other words, SBA can amend the administrative record at whim, while

20   the appellant cannot and also cannot take discovery.

21            439.     As evidenced by the OHA’s decision in SAW’s reconsideration petition, OHA,

22   apparently, agrees that SBA may withdraw an FLRD at any point in time. See Ex. U.

23            440.     Pursuant to scheduling orders that had been entered in the OHA appeals related to

24   Plaintiff Gold Club’s second and first draw PPP Loan and Plaintiff SAW’s second draw PPP Loan,

25   the administrative records were produced (951 pages for Gold Club’s second draw PPP Loan appeal,

26   5,967 pages for Gold Club’s first draw PPP Loan appeal, and 6,206 pages for SAW’s first draw PPP

27   Loan appeal).

28
                                                83                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24       Page 84 of 169



 1            441.     Following the production of the administrative records as described in the paragraph

 2   immediately above and the administrative records relating to the Plaintiffs’ other OHA appeals, the

 3   attorneys and accountants of the Plaintiffs began reviewing the administrative records in order to be

 4   able to submit to the OHA any necessary objections thereto in the timeframes as established by the

 5   Special OHA Rules and the scheduling orders issued by the OHA adjudicator. This required each

 6   appellant to incur thousands of dollars, and in some circumstances tens of thousands of dollars, in

 7   professional fees in furtherance of undertaking steps that are purported to be necessary in order for

 8   those Plaintiffs to be able to comply with the Special OHA Rules.

 9            442.     As those reviews of the administrative records were occurring, and as legal counsel

10   was preparing the filings of the actual OHA appeals for a number of the other Plaintiffs, the

11   undersigned law firm received, on January 9, 2024, a motion to dismiss the OHA appeal related to

12   the forgiveness denial of Plaintiff Gold Club’s second draw PPP loan. That motion, with an

13   accompanying declaration, is attached as Exhibit EE.

14            443.     The motion to dismiss the OHA appeal of Plaintiff Gold Club’s second draw PPP loan

15   forgiveness request was based upon the fact that the SBA had withdrawn, on January 3, 2024, the

16   FLRD on appeal. In the motion, the SBA contended that it had done so:

17            . . . because it determined that it is necessary to complete a further review of the Loan.
              This review will include, but is not limited to, additional requested information
18            submitted with the Appeal.

19   [Ex. EE, at p. 2 (citations omitted)].

20            444.     Under the Special OHA Rules, a party to an appeal is given 15 days to respond to a

21   motion. 13 C.F.R. § 134.211(c), which is expressly incorporated into the Special OHA Rules via 13

22   C.F.R. § 134.1201(h). Irrespective of that regulation and without permitting Plaintiff Gold Club to

23   respond to the motion to dismiss, Mr. Ambrow granted the motion the same day it was filed.

24   [Compare Order of Dismissal, Plaintiff Gold Club’s second draw PPP appeal, Exhibit FF (issued on

25   January 9, 2024, with SBA’s Motion to Dismiss Plaintiff Gold Club’s second draw PPP appeal, Ex.

26   EE (filed on January 9, 2024)].

27            445.     As a direct and proximate result of the withdrawal by the SBA of its FLRD and the

28
                                                84                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24    Page 85 of 169



 1   OHA’s subsequent dismissal of the appeal based thereon, Plaintiff Gold Club has needlessly

 2   expended significant sums of money in attorney fees and accountant fees in preparing and filing its

 3   initial OHA appeal documents, in preparing and filing its discovery motion, and in reviewing the

 4   administrative record in furtherance of filing objections thereto.

 5            446.     As noted, supra, SBA, the day after the filing of the motion to dismiss the appeal and

 6   the entry of the dismissal order in Plaintiff Gold Club’s second draw appeal, filed an almost identical

 7   motion in Plaintiff SAW’s first draw appeal, with the same thing happening. Without allowing

 8   Plaintiff SAW to file a response to the motion and to be heard, Mr. Ambrose granted that motion the

 9   same day that it was filed as well. [Exhibits GG and HH respectively].

10            447.      As a direct and proximate result of the withdrawal by the SBA of its FLRD and the

11   OHA’s subsequent dismissal of the appeal based thereon, Plaintiff SAW has needlessly expended

12   significant sums of money in attorney fees and accountant fees in preparing and filing its initial OHA

13   appeal documents, in preparing and filing its discovery motion, and in reviewing the administrative

14   record in furtherance of filing objections thereto.

15            448.      Because Plaintiff Gold Club’s first and second draw OHA appeals and Plaintiff

16   SAW’s first draw OHA appeal were filed as a group and contained similar issues (denials based on

17   the Prurience Regulation and/or the Affiliation Rules), and because the attorneys and accountants for

18   Plaintiff Gold Club were also reviewing the administrative record on Plaintiff Gold Club’s first draw

19   PPP loan appeal for objection purposes, attorney Zachary Youngsma, representing Plaintiff Gold

20   Club in the OHA, emailed SBA’s counsel, Lane Siems, to inquire whether the SBA intended to do

21   the same thing in Plaintiff Gold Club’s first draw PPP loan appeal; that being withdrawing the FLRD

22   and seeking dismissal of the appeal.

23            449.     The OHA portal for Gold Club’s second draw appeal states that the “OHA Attorney”

24   is Christopher Hicks.

25            450.     In response to the email of Mr. Youngsma, attorney Siems stated, in an email of

26   January 11, 2024, that “[a]t this time there are no plans to withdraw the remaining Gold Club’s

27

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 86 of 169



 1   FLRD.” [See email string attached as Exhibit II]. 4 As a result, Plaintiff Gold Club’s attorneys and

 2   accountant are required to continue and complete their review of the SBA’s claimed administrative

 3   record for the purposes of filing objections thereto, and Plaintiff Gold Club is required to pay their

 4   fees for such work.

 5            451.     There are no material legal or factual differences between the Gold Club second draw

 6   appeal and SAW’s first draw appeal on the one hand, and the Gold Club first draw appeal on the

 7   other hand, that could justify the disparate handling by the SBA of the OHA appeals of these Plaintiffs

 8   as demonstrated in Mr. Siems’ email quoted in the paragraph immediately above.

 9            452.     SBA, however, changed its mind because on February 6, 2024, attorney Siems

10   emailed Mr. Youngsma informing him that SBA was “currently taking another look at this loan and

11   there is a good likelihood that the FLRD gets pulled.” Attorney Siems and Mr. Youngsma obtained

12   an additional extension for Gold Club to file its objections to the administrative record.

13            453.     On February 27, 2024, at 12:54 p.m., in response to an email from Mr. Youngsma

14   inquiring as to whether the SBA had made a decision on whether it would withdraw Gold Club’s

15   FLRD or not, attorney Siems emailed Mr. Youngsma a copy of a three (3) page motion to dismiss

16   Gold Club’s second draw appeal based on SBA’s decision to withdraw the FLRD, which was

17   accompanied by a three (3) page declaration in support thereof. Attorney Siems email stated that he

18   would “file [the Motion] here shortly.” A true and accurate copy of that email exchange is attached

19   hereto as Exhibit JJ.

20            454.     Seven minutes later, at 1:01 pm on February 27, 2024, Mr. Youngsma received an

21   email from the OHA stating that a new filing had been added to Gold Club’s second draw appeal,

22   which was the motion to dismiss that attorney Siems had sent to Mr. Youngsma seven minutes earlier.

23   Roughly four hours later, at 5:25 pm, Mr. Youngsma received two emails from the OHA; one stating

24   that a filing had been added to the appeal and one stating that a decision had been rendered in the

25

26   4
       On February 6, 2024, Mr. Siems emailed Mr. Youngsma informing him that SBA is “currently
     taking another look at this loan and there is a good likelihood the FLRD gets pulled[.]” That
27   prediction came true on February 27, 2024, when SBA filed a motion to dismiss the appeal stating
     that it had withdrawn the FLRD under appeal.
28
                                                   86                         Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 87 of 169



 1   appeal. True and accurate copies of these three emails from the OHA with the corresponding

 2   documents associated with those emails, along with screenshots of their appearance in Mr.

 3   Youngsma’s email inbox and in the OHA portal, as well as the order dismissing the appeal, are

 4   attached hereto as Exhibit KK.

 5            455.     The order granting SBA’s motion to dismiss Gold Club’s second draw appeal is two

 6   pages long, is signed by Mr. Ambrow, and is accompanied by a one-page Notice of Appeal Rights

 7   and Procedures.

 8            456.     The disparate handling by the SBA of the OHA appeals of Plaintiff Gold Club’s first

 9   and second draw loans runs counter to the statements of SBA’s lead representative as noted, infra;

10   primarily, that SBA would not negotiate regarding second draw loans.

11            457.     Plaintiff Meacham filed a motion for discovery similar to those filed in Gold Club

12   and SAW’s OHA appeals. [Ex. CC]. Plaintiff Meacham’s aforementioned discovery motion was

13   denied similar to those of Plaintiffs Gold Club and SAW.

14            458.     Plaintiff Dallas Food & Beverage anticipated filing a motion for discovery similar to

15   Gold Club, SAW, and Meacham, however SBA filed a motion to dismiss on February 29, 2024,

16   stating that it had withdrawn the FLRD the day prior, and OHA granted that motion and dismissed

17   the appeal the same day.

18            459.     Gold Club timely appealed the second FLRD SBA issued regarding Gold Club’s

19   second draw PPP Loan and, in the OHA, the matter was assigned to Mr. Ambrow assigned as the

20   judge and Christopher Hicks assigned as the “OHA Attorney.”

21            460.     The SBA did a very similar routine with Plaintiff Meacham’s OHA appeal as it did

22   with Gold Club’s second draw PPP Loan appeal described above.

23            461.     The disparate actions of the SBA as reflected in its conduct regarding the OHA

24   appeals of Plaintiff Gold Club’s second draw PPP Loan, Plaintiff SAW’s first draw PPP Loan,

25   Plaintiff Gold Club’s first draw PPP Loan, and Plaintiff Meacham’s second draw PPP Loan,

26   demonstrate the lack of reasoned decision making and completely arbitrary and capricious way, and

27   indeed the vindictive and retaliatory nature, that the SBA is treating these Plaintiffs.

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1            462.     Given the history of the clients of the undersigned law firm with the SBA as detailed

 2   above, the constitutional claims of those Plaintiffs that have had their FLRD’s withdrawn, and their

 3   OHA appeals dismissed, are nevertheless capable of repetition yet evading review (exemplified by

 4   the recent events concerning Plaintiffs Gold Club and Meacham’s second draw Loans ). Moreover,

 5   the claims of all Plaintiffs under the Equal access to Justice Act, see Count IV, dictate that dismissal

 6   of some of the Plaintiffs’ OHA appeals does not moot out their claims. And, given the history of the

 7   SBA regarding PPP loans as set forth above, those Plaintiffs that have had their OHA appeals

 8   dismissed can certainly be subject to FLRD denials in the future and therefore further OHA

 9   proceedings (again, as is specifically exemplified by the SBA’s actions in regard to Plaintiffs Gold

10   Club and Meacham’s second draw Loans).

11            463.     In addition, as demonstrated above, the Special OHA Rules are a flagrant denial of

12   fundamental due process, and further administrative appeals by these Plaintiffs in the OHA would

13   be expensively futile. Plaintiffs should not, therefore, be required to exhaust any administrative

14   remedies before being able to have their claims heard by this Court.

15                 FACTS AND LAW RELATING TO THE PRURIENCE REGULATION

16            464.     The actual text of the Prurience Regulation, adopted by the SBA via 61 Fed. Reg.
17   3226, and which is now lodged at 13 C.F.R. § 120.110(p) states:
18            The following types of businesses are ineligible [for SBA business loans]:
19                                                      ***
20            (p) Businesses which:
21                 (1) Present live performances of a prurient sexual nature; or
22                 (2) Derive directly or indirectly more than de minimis gross revenue through the
                       sale of products or services, or the presentation of any depictions or displays,
23                     of a prurient sexual nature[.]
24   (Clarification added).
25            465.     28 U.S.C. § 2401 is inapplicable to Plaintiffs’ facial attack on the Prurience
26   Regulation because, as described herein, Defendants persist in enforcing this unlawful regulation in
27   a manner that affects Plaintiffs; namely, to deny the grant of or forgiveness of PPP Loans. Flynt v.
28
                                                88                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24      Page 89 of 169



 1   Shimazu, 940 F.3d 457, 462 (9th Cir. 2019) (“When the continued enforcement of a statue inflicts

 2   continuing or repeated harm, a new claim arises (and the limitations period commences) with each

 3   new injury.”); Deanda v. Becerra, 645 F. Supp. 3d 600, 615 (N.D. Tex. 2022) (collecting cases)

 4   (“Plaintiffs claims accrue continually as Defendants persist in enforcing unlawful statutes or agency

 5   rules in a manner that affects Plaintiff” such that “Section 2401(a) is inapplicable to [the plaintiff’s]

 6   claims.”).

 7            466.     The Prurience Regulation defines neither the term “prurient” nor the phrase “prurient

 8   sexual nature.”

 9            467.     Prior to the Pandemic, the term “prurient” had, in the published case law of this nation,

10   one singular legal definition and that was under the legal standards for “obscenity.”

11            468.     The constitutional criteria for legal obscenity—meaning expression that falls outside

12   of the protections of the First Amendment—require determinations by the trier of fact of whether:

13            The average person, applying contemporary community standards, would find that
              the work, taken as a whole, appeals to the prurient interest;
14
              Applying contemporary community standards, the work depicts or describes, in a
15            patently offensive way, sexual conduct specifically defined by applicable state law;
              and
16
              A reasonable person would find that the work lacks serious literary, artistic, political,
17            or scientific value.

18   These standards derive from three Supreme Court cases: Miller v. California, 413 U.S. 15, 24 (1973);

19   Smith v. United States, 431 U.S. 291, 300 n.6 (1977); and Pope v. Illinois, 481 U.S. 497, 500-01 &
20
     n.3 (1987).
21
              469.     The Supreme Court has held that each element of the three-part test of obscenity set
22
     forth in the paragraph immediately above must be satisfied before expression can be found to be
23
     obscene and therefore beyond the protections of the First Amendment. See Reno v. ACLU, 521 U.S.
24
     844, 872 (1997).
25
              470.     The phrase “prurient appeal” under the obscenity standards has been defined, through
26
     other Supreme Court precedents, to mean a shameful, morbid, or unhealthy interest in sex. The
27

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                                                89                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   “shameful or morbid” standard was first articulated in Roth v. United States, 354 U.S. 476, 487 n.20

 2   (1957), and the “unhealthy” aspect was added in Brockett v. Spokane Arcades, 472 U.S. 491, 498-

 3   99 (1985).

 4             471.     These constitutional standards of obscenity, as articulated in Miller, Smith, Pope,

 5   Roth, and Brockett, and in particular that of prurient appeal, are collectively referred to hereinafter

 6   simply as the “Miller Test.”

 7             472.     In Brockett, the Court was clear to point out what would not be considered to be

 8   “prurient.” In noting that the Roth standard should not be construed to extend obscenity to expression

 9   that invoked merely “lustful thoughts,” or that appealed to “normal, healthy sexual desires,” the

10   Court observed that the government may not outlaw expression which, “taken as a whole, does no

11   more than arouse, ‘good, old fashioned, healthy’ interest in sex.” Brockett, 472 U.S. at 498-99

12   (quoting the opinion being reversed there; J-R Distributors, Inc. v. Eikenberry, 725 F.2d 482, 492

13   (9th Cir. 1984)).

14             473.     Most importantly for the legal matters here, the DOJ, which is representing all of the

15   Defendants in this action, [Doc. 13], filed an amicus brief in the Supreme Court in the Brockett case

16   where it recommended to the Supreme Court the concepts that it, the DOJ, contended would satisfy

17   expressive materials being “prurient.” Specifically, the DOJ argued that the Washington State

18   statutory definition of “prurient” as meaning “that which incites lasciviousness or lust” was “plainly

19   authorized by the decisions of this [the Supreme] Court.” [Brief for the United States as Amicus

20   Curiae,          Brockett     v.     Eikenberry,      No.      84-28,      No.       84-148      (1984),

21   https://www.justice.gov/sites/default/files/osg/briefs/1984/01/01/sg840109.txt#:~:text=The%20cou

22   rt%20stated%20that%20the,69a). (last visited Oct. 7, 2024; clarification added)]. 5 Again, the

23   Supreme Court specifically rejected, in its Brockett decision, this argument of the DOJ.

24             474.     For reasons that will become abundantly clear to this Court in the later summary

25   judgment motion practice in this action, and irrespective of the Supreme Court’s rejection of the

26   DOJ’s concept of “prurience” as set forth in the Brockett decision, the SBA wants to define, and has

27
     5
         The online amicus brief of the DOJ contains no page numbering for specific citation purposes.
28
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          VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
          FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                            AGENCY ACTION
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 1   attempted to define in Pandemic funding litigation (as discussed below), “prurient” under the

 2   Prurience Regulation as being anything but the constitutional standard set forth in the Miller Test.

 3            475.     Shortly after the enactment of the SBA Act, the SBA adopted, through regulation,

 4   what became known as the “opinion molder rule,” which precluded funding through the SBA for any

 5   businesses involved in the “creation, origination, expression, dissemination, propagation or

 6   distribution of ideas, values, thoughts, opinions or similar intellectual property.” Business Loan

 7   Policy—Media Policy Rule, 59 Fed. Reg. 15872 (Proposed, Apr. 5, 1994) (quoting 13 C.F.R. §

 8   120.101-2(b) (1993)).

 9            476.     In Mission Trace Investments, Ltd. V. SBA, 622 F. Supp. 687 (D. Colo. 1985), the

10   opinion molder rule was declared to be unconstitutional under the First Amendment to the United

11   States Constitution, and the SBA was enjoined from enforcing it.

12            477.     The SBA appealed only the district court’s award of damages in the Mission Trace

13   case, which the appellate court vacated on the basis of sovereign immunity in a ruling under the name

14   of Ascot Dinner Theatre, Ltd v. SBA, 887 F.2d 1024 (10th Cir. 1989); with that ruling

15   acknowledging, however, that the holding of the district court finding the opinion molder rule

16   unconstitutional was not being disturbed. Id. at 1026.

17            478.     Then, on July 15, in 1994, the SBA formally repealed, through the Media Policy Rule,

18   59 Fed. Reg. 36042 (Jul. 15, 1994), the opinion molder rule.

19            479.     In response thereto, Congress undertook actions to permit the SBA to decline the

20   funding of businesses engaged in certain expressive activities.

21            480.     In particular, through and from the enactment of the Small Business Reauthorization

22   and Amendments Act of 1994, Pub. L. 103-403 (1994), which was signed into law on October 22,

23   1994, the SBA Act itself (and irrespective of any promulgated regulations) has precluded loans to

24   businesses that have been involved in the sale or distribution of legal obscenity.

25            481.     Specifically, Congress, through the Small Business Reauthorization and Amendments

26   Act of 1994, Pub. L. 103-403, § 611 (1994), enacted what is now codified at 15 U.S.C. § 633(e)

27   (hereinafter simply “§ 633(e)”), which applies to any type of SBA assistance—grant, loan, or

28
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                                          AGENCY ACTION
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 1   otherwise—provides in relevant part:

 2            (e) Prohibition on provision of assistance

 3            Notwithstanding any other provision of law, the Administration is prohibited from
              providing any financial or other assistance to any business concern or other person
 4            engaged in the production or distribution of any product or service that has been
              determined to be obscene by a court of competent jurisdiction.
 5
     (emphasis added).
 6
              482.     When first proposed by the House of Representatives, this provision contained no
 7
     requirement of a determination by a court of legal obscenity. The Senate included such a requirement,
 8
     and the legislative history of the conciliation conference provides as follows:
 9
              The conferees adopted the Senate provision with the clarification that any materials
10            in question must have been judicially determined, in either a civil or criminal action,
              to be legally obscene under the prevailing constitutional standards in order for the ban
11            to apply.
12   H.R. CONF. REP. 103-824, 54, 1994 U.S.C.C.A.N. 3436, 3455 [Exhibit LL].
13            483.     The related Senate Report explains why this Bill was changed before adoption:
14            During Committee markup of the bill, Senator Pressler offered an amendment, that
              was unanimously accepted by the Committee, to prohibit the Administration from
15            providing assistance to businesses engaged in the production and distribution of
              obscene products or services. The amendment was offered in response to the
16            Administration's recent repeal of its “opinion molder rule” promulgated in 1953.
              Under that rule, the Administration, with few exceptions, could not provide assistance
17            to small businesses engaged in the “creation, origination, expression, dissemination,
              propagation or distribution of ideas, values, thought, opinions or similar
18            intellectual property, regardless of medium, form, or content” (13 CFR 120.101–
              2(b)). With the repeal of the rule, businesses such as newspapers, movie theaters, radio
19            stations and bookstores now are eligible for Administration assistance. However,
              members of the Committee were concerned a blanket repeal of the rule would allow
20            businesses involved in the production and distribution of obscene products and
              services to seek Administration support and that the agency would have no means by
21            which to deny such loans or other assistance. Senator Pressler's amendment makes it
              clear the Administration is not authorized to provide any assistance to those engaged
22            in “obscene” businesses (and thus not entitled to First Amendment protection) as
              defined by the U.S. Supreme Court.
23
     S. Rep. No. 103-332 § 612, at 3430-31 (1994).
24

25            484.     Accordingly, as of October 1994, SBA funding to businesses that engage in the sale

26   of expressive materials or entertainment could only be precluded, through § 633(e), upon an actual

27   adjudication of legal obscenity under the “prevailing constitutional standards”; those being the

28
                                                92                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   criteria articulated through the Miller Test.

 2            485.     Consequently, prior to the enactment of the PPP, the SBA Act had, through § 633(e),

 3   conceptualized the term “prurient” in accordance with Roth and Brockett; that being a shameful,

 4   morbid, and/or unhealthy interest in sex.

 5            486.     Shortly following adoption of the CARES Act and during the evening of the day

 6   before the PPP loan application portals were to open, the SBA issued two “Final Interim Rules,” one

 7   of which claimed to incorporate into the newly created PPP the laundry list of regulatory eligibility

 8   exclusions for “normal” Section 7(a) SBA loans found at 13 C.F.R. § 120.110. 85 Fed. Reg. 20811,

 9   20812 (Interim Final Rule, Apr. 15, 2020). This included the Prurience Regulation. The publication

10   of this Interim Final Rule resulted in a number of businesses across the country filing federal lawsuits

11   seeking to enjoin the SBA from applying the Prurience Regulation to Pandemic funding programs.

12            487.     One such action was filed by the undersigned firm, which, in fact, resulted in the

13   issuance of an injunction prohibiting the use of the Prurience Regulation when evaluating the PPP

14   applications of those plaintiffs. See DV Diamond Club of Flint v. SBA, 459 F. Supp.3d 943, 954-962

15   (E.D. Mich. 2020) (the “DV Diamond Club” action).

16            488.     In another such action, filed in the Southern District of Texas, the DOJ (representing

17   the SBA) admitted in open court that the Prurience Regulation was vague. At a preliminary injunction

18   hearing, the following colloquy occurred:

19            THE COURT:              Who's to determine what's a prurient interest? You know,
                                      there's the famous, what is it, Potter Stewart opinion, you
20                                    know, the pornography opinion that came out, what, in the
                                      '50s? I think Stewart was on the Court at that time. He said he
21
                                      can't define it but he knows it when he sees it? Are we in an
22                                    area like that?

23            MR. KINCHELOE           [Assistant United States Attorney; Attorney for the SBA]: It's
                                      vague, your Honor.
24
     Transcript of Preliminary Injunction Hearing, D. Houston, Inc. v. SBA, 4:20-cv-02308 (S.D. Tex.
25
     Sept. 11, 2020), ECF 27, at p. 29:23-25 – 30:1-4 (clarification added) [Exhibit MM].
26
              489.     The concession set forth in the paragraph immediately above caused the court to then
27

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                                                93                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
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 1   note, prior to enjoining the Prurience Regulation: “Okay. But that’s one of their complaints is that

 2   it’s vague.” [Ex. MM, at p. 30:5-6 (cleaned up)].

 3            490.     In other pandemic-related lawsuits, the SBA’s conflicting and ever-changing

 4   explanations as to the meaning of the term “prurient” approached the comical.

 5            491.     For example, at an April 30, 2020, hearing in the DV Diamond Club action in

 6   Michigan, the SBA took the position that “prurient” meant “tending to arouse a ‘lustful’ or, you know

 7   ‘lascivious’ interest in sex.” “The SBA’s interpretation of ‘prurient,’ simply refers to, you know,

 8   invoking an avert [sic] strong sexual interest.” Transcript of Apr. 30, 2020, Hearing on Motion for

 9   TRO and/or Preliminary Injunction, DV Diamond Club, 20-cv-10899 (E.D. Mich. Jun 12, 2020),

10   ECF 54, at 8:18-19; 58:5-6, excerpts attached as Exhibit NN.

11            492.     However, in the Camelot Banquet Case in Wisconsin, the SBA took the position that:

12            Businesses that feature live dancing explicitly intended to be “erotic” undoubtedly
              falls within the plain language of the regulation.
13
                                                 *       *      *
14
              The SBA has restricted government-backed small-business loans to businesses
15            engaged in live erotic performances for nearly twenty-five years.

16   Government Motion for Emergency Stay, Camelot Banquet, 2:20-cv-00601 (E.D. Wis. May 4, 2020),

17   ECF 30, at pp. 4, 8, excerpts attached as Exhibit OO.
18
              493.     In fact, the SBA continued to maintain, in its pleadings on appeal from the District
19
     Court’s ruling in the Camelot Banquet case (which ultimately resulted in the injunction ruling found
20
     at Camelot Banquet Rooms, Inc. v. SBA, 458 F.Supp.3d 1044, 1055-1057 (E.D. Wisc. 2020)) that
21
     the term “prurient” simply meant “erotic.” Specifically, this is what the SBA stated in its emergency
22
     motion for stay to the Seventh Circuit:
23
              The SBA’s restriction on providing Section 7(a) loans to businesses that present live
24            erotic performances dates back to 1996. See 61 Fed. Reg. 3226, 3240 (Jan. 31, 1996)
              (final rule); 60 Fed. Reg. 64356, 64360 (Dec. 15, 1995) (proposed rule).
25
                                                 *       *      *
26
              Businesses that feature live dancing explicitly intended to be “erotic” undoubtedly
27            fall within the plain language of the regulation.

28                                               *       *      *
                                                        94                 Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
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                                          AGENCY ACTION
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     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 95 of 169



 1
              The SBA has restricted government-backed small-business loans to businesses
 2            engaged in live erotic performances for nearly twenty-five years.

 3   Government’s Emergency Motion for Stay Pending Appeal, Camelot Banquet Rooms, Inc. v. U.S.

 4   Small Business Admin., 20-1729 (7th Cir. May 4, 2020), Doc 4, at p. 4, 13, 17, excerpts attached as
 5
     Exhibit PP.
 6
              494.     And in its reply brief on that motion to the Seventh Circuit, the SBA again asserted,
 7
     in regard to the Prurience Regulation:
 8
              Plaintiffs’ businesses— “Gentlemen’s Clubs” which present live nude and semi-nude
 9            dance performances that are explicitly intended to be erotic—thus fall within the heart
              of the regulation’s scope.
10
                                                 *       *      *
11
              And although Congress explicitly lifted some of those restrictions in creating the
12            Paycheck Protection Program, Congress did not lift or alter the SBA’s longstanding
              restriction on loans to businesses that present live erotic performances.
13
                                                 *       *      *
14
              The SBA could reasonably determine that, since Congress has expressly barred it
15            from providing financial assistance to businesses that provide “obscene” products and
              services, the agency’s limited resources are best directed to subsidizing businesses
16            other than those that, although not “obscene” in the legal sense, are nonetheless
              “sexually oriented” and explicitly intended to be erotic.
17
     Government’s Reply In Support of Its Motion for Stay Pending Appeal, Camelot Banquet Rooms,
18
     Inc. v. U.S. Small Business Admin., 20-1729 (7th Cir. May 11, 2020), Doc. 14, at pp. 5, 7, 8, excerpts
19
     attached as Exhibit QQ.
20
              495.     However, after then being confronted in the Michigan DV Diamond Club action that
21
     it—the SBA—had articulated a different standard for the term “prurient” in the Camelot Banquet
22
     Wisconsin case (i.e., “erotic”), and after the federal judge in the DV Diamond Club matter pointed
23
     out that such a standard (erotic) would render the Prurience Regulation to be unconstitutionally
24
     overbroad, the SBA retreated to its previous position that “prurient” meant “lascivious or lustful.”
25
     Transcript of May 5, 2020 Continued Hearing for Motion for TRO and/or Preliminary Injunction,
26
     DV Diamond Club, 20-cv-10899 (E.D. Mich. Jun. 12, 2020), ECF 55, at 41:18 – 43:7, excerpts
27

28
                                                95                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24     Page 96 of 169



 1   attached as Exhibit RR.

 2            496.     In a second action involving Camelot Banquet, the SBA’s Associate General Counsel

 3   for Litigation, Eric Benderson (“Benderson”), submitted a declaration. Declaration of Eric S.

 4   Benderson, Camelot Banquet Rooms, Inc. v. United States Small Bus. Admin., No.: 2:21-cv-00447

 5   (E.D. Wis. 2021), Doc. 21-7 [Exhibit SS, hereafter, the “Benderson Declaration”].

 6            497.     In the Benderson Declaration, Benderson declared that “[s]ince September 23, 1982,

 7   [he] [] served as the Associate General Counsel for Litigation in the Office of General Counsel at the

 8   U.S. Small Business Administration[.]” [Ex. SS at ¶ 1].

 9            498.     In the Benderson Declaration, Benderson stated that the term “prurient” was used “in

10   its colloquial sense, simply to mean, for example, lustful, lascivious, or arousing of sexual interest

11   or desire, which is equated in many dictionaries with the term ‘erotic.’” [Ex. SS at ¶ 10].

12            499.     Neither Benderson nor the Benderson Declaration were subjected to cross-

13   examination.

14            500.     Under the SBA’s interpretation of the word “prurient,” it means absolutely nothing in

15   context of the Prurience Regulation.

16            501.     While the Prurience Regulation uses the phrase “prurient sexual nature,” given how

17   the SBA in litigation, and in particular through the Benderson Declaration, has construed the meaning

18   of the word “prurient,” the SBA is literally and completely reading the word “prurient” out of the

19   Prurience Regulation and asserting that the Prurient Regulation applies, rather, to entertainment that

20   is merely of a “sexual nature.”

21            502.     Nothing issued by the SBA for the notice and comment period related to the adoption

22   of the Prurience Regulation would have alerted a person of ordinary intelligence that the Prurience

23   Regulation would be construed and applied by the SBA in the manner as set forth in the paragraph

24   immediately above.

25            503.     Under the SBA’s interpretation of the word “prurient” in the Prurience Regulation as

26   set forth above, and because of the Regulation’s incorporation into the PPP via the Incorporating

27   Statute, § 633(e) of the SBA Act, in incorporating all three prongs of the Miller Test and the

28
                                                96                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   definitions of the words and phrases contained therein as dictated by the Supreme Court, including

 2   but not limited to the term “prurient,” is rendered superfluous.

 3            504.     To date, in all of the litigation with the SBA in which the undersigned firm has been

 4   involved, the SBA has not produced a single document, created either before the beginning of the

 5   Pandemic or after, that establishes that the SBA had or has some type of uniform, objective,

 6   established, and articulated standard for defining and applying the word “prurient,” or the phrase

 7   “prurient sexual nature,” under the Prurience Regulation.

 8            505.     Nevertheless, this is what Associate General Counsel Benderson stated under penalty

 9   of perjury in the Benderson Declaration filed in the second Camelot Banquet case:

10            SBA has never interpreted 13 C.F.R. § 120.110(p)’s “prurient sexual nature” standard
              as equivalent to prurience as that term is specifically defined for purposes of the
11            obscenity test established under Miller v. California, 413 U. S. 15 (1973).
12
     [Ex. SS, ¶ 10 (emphasis added)].
13
              506.     Benderson’s statement in the Benderson Declaration, as quoted in the paragraph
14
     immediately above, is not true.
15
              507.     Benderson’s statement in the Benderson Declaration, as quoted in paragraph 505,
16
     was not true when made.
17
              508.     Upon information and belief, Benderson’s statement in the Benderson Declaration,
18
     as quoted in paragraph 505, was known by Benderson to be untrue when made.
19
              509.     The SBA issues, from time-to-time, what are known as “Standard Operating
20
     Procedures” (“SOP’s”) to provide guidance to lending banks in administering the SBA’s various
21
     loan and grant programs.
22
              510.     Those SOPs that address the Prurience Regulation seem to be constantly and ever-
23
     changing, as discussed immediately below.
24
              511.     A limited number of the SOP’s can be found on the SBA’s website.
25
              512.     Those online SOP’s only go back, however, to 2008. SBA Website,
26
     https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs                  (last
27
     visited Oct. 7, 2024).
28
                                                97                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            513.     That earliest applicable SOP available on the SBA’s website is SOP 50 10 (5) (the

 2   numbering itself acknowledging that earlier SOP’s exist), which is listed on SBA’s website as

 3   “Version 5.” SBA Website, https://www.sba.gov/document/sop-50-10-lender-development-

 4   company-loan-programs (last visited Oct. 7, 2024).

 5            514.     In SOP 50 10 (5), the SBA states that:

 6            The lender must consider whether the nature and extent of the sexual component
              causes it, in view of community standards, to be prurient.
 7

 8   SOP 50 10 (5), § B, Ch. 2(3)(d)(3)(xvi) (effective August 1, 2008) (emphasis added) [Exhibit TT].
 9            515.     By using the phrase “community standards” in SOP 50 10(5), the SBA publicly
10   represented that it was in fact directly borrowing at least the concept of “prurient appeal” from the
11   Miller Test (the first element of which, again, requiring an evaluation of “whether the ‘average
12   person, applying contemporary community standards,’ would find that the work, taken as a whole,
13   appeals to the prurient interest”). 6
14            516.     By using the phrase “extent” in SOP 50 10(5), it also appears that the SBA was
15   applying the concept of “taken as a whole” (i.e., “the “extent”); which is also a component of the
16   “prurient appeal” prong of the Miller Test.
17            517.     By using the word “nature” in SOP 50 10(5), it further appears that the SBA was
18   applying the “patent offensiveness” prong of the Miller Test, (the second element of which, again,
19   requires evaluating whether “[a]pplying contemporary community standards, the work depicts or
20   describes, in a patently offensive way, the sexual conduct specifically defined by applicable state
21   law”), 7 as well for use under the Prurience Regulation.
22            518.     While lending banks had been advised under previous SOP’s to review the “nature
23   and extent” of the “sexual component,” the SBA has produced nothing to date in litigation, or
24   otherwise, explaining what such banks were/are to look for, and thus what the SBA would look for,
25

26   6
       Miller, 413 U.S. at 24 (emphasis added) (quoting Kois v. Wisconsin, 408 U.S. 229, 230 (1972),
27   quoting Roth, 354 U.S. at 489).
     7
       Miller, 413 U.S. at 24.
28
                                                    98                        Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
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 1   that would render expression to be “prurient” and therefore the business at issue then not subject,

 2   arguably (in the SBA’s view), to funding.

 3            519.     Regardless of the fact that the SBA used from at least 2008 the concept of

 4   “community standards” by which to judge the potential prurient nature of expression, Plaintiffs are

 5   unaware of any documents from the SBA identifying which community standards the “nature and

 6   extent” of the sexual component of the expression is or was to be measured by (obscenity

 7   jurisprudence allowing, among other things, a state or local standard and, at least prior to the

 8   invention of the Internet, rejecting a national standard).

 9            520.     Just prior to the beginning of the Pandemic, the SBA issued another SOP which, while

10   omitting specific reference to the community standards, still stated:

11            The Lender must consider whether the nature and extent of the sexual component
              causes the business activity to be prurient.
12

13   SOP 50 10 5(K) § B, Ch. 2(III)(A)(15)(b) (effective April 1, 2019) (emphasis added) [Exhibit UU].

14            521.     SOP 50 10 5(K) further stated that if the lender found that an applicant may have a

15   business aspect of a prurient sexual nature, then, prior to submitting an application or requesting a

16   loan number, the lender was to “document and submit the analysis and supporting documentation to

17   the Associate General Counsel for Litigation” (i.e., Mr. Benderson) “for a final agency decision on

18   eligibility.” SOP 50 10 5(K) §B, Ch. 2(III)(A)(15)(c) [Id. at p. 114].

19            522.     SOP 50 10 5(K) also provided an email address that lenders were to use to send

20   “supporting documentation the Associate General Counsel for Litigation.” That email address is

21   PSMReview@sba.gov, which, upon information and belief, is an abbreviation for “prurient sexual

22   material review.” SOP 50 10 5(K) §B, Ch. 2(III)(A)(15)(c) [Id.].

23            523.     From the very language of SOP 50 10 5(K) quoted in the two paragraphs immediately

24   above, from entries in various administrative records that members of the undersigned law firm have

25   reviewed as part of numerous OHA appeals, and from further investigations undertaken by the

26   undersigned attorneys, including but not limited to discussions with members of local SBA loan

27   boards, Plaintiffs understand and believe that Benderson is the person at the SBA who makes final

28
                                                99                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 100 of 169



 1   loan and forgiveness determinations when application of the Prurience Regulation is involved, and

 2   is the person behind the denials at issue in this lawsuit.

 3              524.   Effective just last August 1, 2023, the SBA promulgated yet another SOP, SOP 50 10

 4   7, that notes the Prurience Regulation as being relevant to loan ineligibility but deletes any reference

 5   to the “nature and extent of the sexual component” of the expression. See SOP 50 10 7 § A, Ch.

 6   1(F)(14) (effective August 1, 2023) [Exhibit VV]. That SOP, however, still provided the

 7   PSMReview@sba.gov email discussed, supra, for the submission by the lender of an “analysis and

 8   supporting documentation for an applicant that may have a business aspect of a prurient sexual

 9   nature.” Id. at Appendix 12.

10              525.   SOP 50 10 7 did not, however, last unchanged for very long. On November 15, 2023,

11   the SBA promulgated yet another SOP, SOP 50 10 7.1, that completely deleted any reference to a

12   lending bank having to send to the SBA an analysis and documentation of a business that may have

13   an aspect of a prurient sexual nature. See SOP 50 10 7.1 [Exhibit WW].

14              526.   Regardless of all of the above, the SBA continues, as reflected by its actions leading

15   to this suit, to impose whatever definitions and understandings it so chooses at any given time in

16   order to utilize the Prurience Regulation to deny loan forgiveness or to “reevaluate” granted and even

17   forgiven PPP loans and to then deny eligibility.

18              527.   The SBA is doing those things listed in the previous paragraph even though recent

19   case law demonstrates the unconstitutionality of the SBA’s interpretation of the word “prurient.”

20              528.   For example, various courts have recently addressed Florida’s anti-“drag show”

21   statute, which uses some of the same words or their equivalents that the SBA has contended apply to

22   language used in the Prurience Regulation.

23              529.   Specifically, in HM Florida-ORL, LLC v. Griffin, 2023 WL 4157542, at *6-9 (M.D.

24   Fla. June 23, 2023), the United States District Court in Florida found that because the statute did not

25   define the phrases “lewd conduct” and “lewd exposure of prosthetic or imitation genitals or breasts,”

26   it was most likely unconstitutionally vague and overbroad, and enjoined Florida from enforcing the

27   statute.

28
                                               100                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            530.     Florida requested a partial stay of the district court’s injunction, which the Eleventh

 2   Circuit denied. 2023 WL 678-5071, No. 23-12160 (11th Cir. October 11, 2023).

 3            531.     This should be compared to the comments of the federal judge in the DV Diamond

 4   Club case referenced above who had pointed out that virtually all dictionaries equate lewdness to

 5   lasciviousness; a term that the SBA and the DOJ have specifically claimed in litigation to describe

 6   how they define the term “prurient” in the Prurience Regulation.

 7            532.     In addition, in enjoining the Florida anti-drag show statute, the district court pointed

 8   out that the failure to define certain terms rendered the law unconstitutional. “These ambiguities,

 9   especially those pertaining to ‘lewd’ conduct and exposure of prosthetics, represent a material

10   departure from the established obscenity outline set forth in Miller.” 2023 WL 4157542, at * 7.

11            533.     This is the exact same argument that the undersigned firm has repeatedly made in

12   litigation across the country involving the Prurience Regulation.

13            534.     Yet, irrespective of these rulings by the Florida district court and the Eleventh Circuit,

14   and regardless of the fact that the Supreme Court recently denied an application for stay of the district

15   court ruling (144 S. Ct. 1, No. 23A366 (November 16, 2023)), the SBA continues to apply the

16   Prurience Regulation in a manner that has the exact same constitutional failings.

17         FACTS RELATED TO HOW THE SBA IS ACTUALLY DETERMINING
       WHETHER A BUSINESS SHOULD BE DENIED A LOAN, OR LOAN FORGIVENESS,
18                    UNDER THE PRURIENCE REGULATION
19
              535.     The Prurience Regulation purports to make businesses ineligible for certain SBA
20
     loans if those businesses “present live performances of a prurient sexual nature,” or “[d]erive directly
21
     or indirectly more than de minimis gross revenue through the sale of products or services, or the
22
     presentation of any depictions or displays, of a prurient sexual nature[.]” 13 C.F.R. § 120.110(p).
23
              536.     A rational person might then believe that before declaring a business ineligible for a
24
     PPP loan under the Prurience Regulation, representatives of the SBA would actually view the “live
25
     performances,” or the “products or services,” or the “presentation of depictions or displays,” in order
26
     to determine whether they are of a prurient sexual nature.
27
              537.     A rational person as described in paragraph 536, however, would be wrong. The SBA
28
                                               101                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   does not actually view the live performances it deems to be prurient.

 2            538.     A review of the administrative records in certain OHA appeals that the undersigned

 3   firm has handled document SBA investigators making eligibility determinations just as Benderson

 4   stated in his declaration. [Ex. SS, at ¶ 9 (“SBA will review the potential borrower’s website . . . .”)].

 5            539.     Denial Letters received by a number of the Plaintiffs further indicate that eligibility

 6   determinations under the Prurience Regulation were made through “open source research” (i.e.,

 7   online searches). This is further discussed below.

 8            540.     Similarly, in an Affiliate Narrative Worksheet Mohney et al #127 made for a number

 9   of the Plaintiffs, the SBA determined in a conclusory and circular fashion, though Kevin Clay as the

10   “Reviewer” and Sharon K. Drake as the “Approver” of the Affiliate Narrative Worksheet Mohney et

11   al #127, that businesses were ineligible for loans under the Prurience Regulation based upon Google

12   Earth photographs because they were “adult entertainment clubs, an ineligible business of prurient

13   nature.” Excerpts of Plaintiff Gold Club’s first draw PPP Appeal Administrative Record attached

14   here to as Exhibit XX.

15            541.     Here are just a few examples of the photos contained in that Affiliate Narrative

16   Worksheet Mohney et al #127, taken from Plaintiff Gold Club’s first draw PPP OHA appeal

17   Administrative Record, but which also appeared in a number of administrative records reviewed by

18   the undersigned firm, that are claimed by the SBA to justify ineligibility determinations:

19

20
21

22

23

24

25

26

27

28            Ln# 4961037708 Rouge Portland LLC, Per Google Address 403 SW Harvey Milk St,
                                                  102                      Case No. 3:24-cv-04241-LJC
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                                          AGENCY ACTION
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 1            Portland, OR 97204

 2

 3

 4

 5

 6

 7

 8

 9
10
              Ln# 1723727301 Ypsilanti Art Theatre Corp. 26 S WASHINGTON ST YPSILANTI
11            MI 48197

12

13

14

15

16

17

18

19

20
              Ln# 1522057305 Gold Club SF LLC 650 Howard St, San Francisco, CA 94105
21

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                                               103                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
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 1            Ln# 7560437005 Paradise Bar of Tampa, LLC 6087 E State Rd 60 Tampa FL

 2   [Ex. XX].
 3
              542.     The SBA engaged in similar conclusory and circular reasoning to conclude that
 4
     Plaintiff Meacham was ineligible for loans under the Prurience Regulation. For example, on
 5
     Meacham’s administrative record, the “Acceptor,” Sharon Drake, on April 24, 2023, stated that “[a]
 6
     visual search of Google (Addendum B) determined these businesses [Meacham] to be adult
 7
     entertainment clubs, or of a prurient nature.” The referenced Addendum B is found on AR pages 266-
 8
     268 (exhibit pages 8-10) and includes these photos:
 9
10

11

12

13

14

15

16

17

18

19

20
21

22

23

24

25

26

27

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                                               104                         Case No. 3:24-cv-04241-LJC
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                                               105                         Case No. 3:24-cv-04241-LJC
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26   [Ex. L, at AR pp. 16, 266-68; exhibit pages 5, 8-10].
27            543.     Those photos are literally the basis—and the only basis—that the SBA states that it
28
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                                          AGENCY ACTION
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 1   used to determine loan and forgiveness ineligibility under the Prurience Regulation for a number of

 2   the Plaintiffs.

 3            544.     Upon information and belief, at no time did any representatives of the SBA ever view

 4   any of the “live performances,” or “products or services,” or “presentations of depictions or

 5   displays,” at the Plaintiffs’ businesses, as applicable, in order to determine whether they themselves

 6   (the performances, products, services, and/or presentations) were of a prurient sexual nature

 7   (whatever that may mean) prior to deciding to deny loan forgiveness of the Plaintiffs’ PPP loans at

 8   issue here.

 9            545.     Upon information and belief, when applying the Prurience Regulation to Plaintiffs’

10   PPP Loans, no representative of the SBA actually viewed the “live performances,” or the “products

11   or services,” or the “presentation of depictions or displays” at Plaintiffs’ businesses, as applicable.

12                      FACTS RELATED TO THE SBA’S “SIZE” DETERMINATION
                                    OF LOAN INELIGIBILITY
13
              546.     The SBA was established to assist “small” businesses. The SBA Act and the
14
     regulations promulgated thereto restrict funding to certain “size” businesses and “business
15
     concerns.”
16
              547.     One of the reasons that the SBA purports to have denied forgiveness of a number of
17
     the Plaintiffs’ Loans is because the SBA asserts that the particular Plaintiff, when including its
18
     “affiliates,” is “too big” from an employee-count standpoint to be eligible for PPP loans.
19
              548.     Similarly, one of the reasons that the SBA has recently opened audits of other
20
     Plaintiffs that have had their Loans forgiven is to examine whether that Plaintiff, when including its
21
     “affiliates,” was “too big” from an employee-count standpoint to have qualified for PPP loans in the
22
     first place.
23
              549.     For first draw PPP loans, the normal employee count limit was 500, 15 U.S.C. §
24
     636(a)(36)(D)(i)(I), and for second draw PPP loans it was 300 employees. 15 U.S.C. §
25
     636(a)(37)(A)(iv)(I)(aa).
26
              550.     For pre-pandemic loans, the SBA had (and still has “affiliation” regulations in order
27

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   to determine whether a business, together with its “related” entities, is under the “size” threshold for

 2   financial assistance to small businesses. The Affiliation Rules that Plaintiffs challenge herein are,

 3   again, collectively found in 13 C.F.R. § 121.101, 13 C.F.R. § 121.103; 13 C.F.R. § 121.201, 13 C.F.R.

 4   § 121.301.

 5            551.     Under SBA’s rules, Affiliation between two businesses can be determined by, for

 6   example, stock ownership, stock options, common management, “identity of interest,” the “newly

 7   organized concern rule,” joint ventures, and franchise and license agreements. See 13 C.F.R. §

 8   121.103(c - i).

 9            552.     Nevertheless, 13 C.F.R. § 121.103(a)(5) actually states:

10            In determining whether affiliation exists, SBA will consider the totality of the
              circumstances, and may find affiliation even though no single factor is sufficient to
11            constitute affiliation.
12
              553.     The provisions of 13 C.F.R. §121.103(a)(5) set forth in the paragraph immediately
13
     above establish that the Affiliation Rules are completely subjective.
14
              554.     The provisions of 13 C.F.R. §121.103(a)(5) set forth in paragraph 552 establish that
15
     they lack any form of constraints upon governmental officials.
16
              555.      The provisions of 13 C.F.R. §121.103(a)(5) set forth in paragraph 552 establish they
17
     permit SBA personnel to render arbitrary and capricious decisions in regard to “affiliation.”
18
              556.     Simply put, the Affiliation Rules provide no standards or guidance to govern
19
     representatives of the SBA in determining whether affiliation under the Affiliation Rules in fact exists
20
     and permits SBA personnel to make ad hoc, arbitrary, and discriminatory determinations based upon
21
     their own predilections and biases.
22
              557.     Because of the national financial emergency brought on by the Pandemic, the PPP
23
     contains a specific waiver of the Affiliation Rules for NAICS code 72 businesses (which constitute,
24
     among other things, establishments that serve food and beverages). See 15 U.S.C. §
25
     636(a)(36)(D)(iii)(I) and 15 U.S.C. § 636(a)(36)(D)(iv)(I) (for first draw loans); and 15 U.S.C. §
26
     636(a)(37)(D) & (E) (for second draw loans) (again, collectively the “Affiliation Exception
27
     Provisions”).
28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            558.     Under the Affiliation Exception Provisions, business concerns with a NAICS code

 2   beginning with 72 are eligible for PPP loans so long as the employee count of each “physical

 3   location” of the business concern is not more than the numerical employee threshold (again, 500

 4   employees for first draw loans, and 300 employees for second draw loans).

 5            559.     The determination of which NAICS code applies to a particular business for PPP loan

 6   purposes has not been self-apparent given the ever-changing loan application forms, instructions,

 7   and rules issued by the SBA since the beginning of the Pandemic.

 8            560.     The Affiliation Exception Provisions actually state that the PPP exceptions to the

 9   normal SBA Affiliation Rules apply to businesses “assigned” a NAICS “code beginning with 72.”

10   That language is actually a non sequitur.

11            561.     Except for certain governmental contractors (not applicable to these Plaintiffs),

12   NAICS codes are not actually “assigned” in the normal understanding of that term. They are, in fact,

13   self-selected by the business itself.

14            NAICS is a Self-Assigned System; no one assigns you a NAICS Code. What this
              means is that a company selects the code that best depicts the primary business
15            activity and then uses it when asked for their code. If your Business Activities include
              more than one Unique Line of Business, you may want to use more than one NAICS
16            Code.

17   https://www.naics.com/what-is-a-naics-code-why-do-i-need-one, dated January 18, 2017 (last
18   visited Oct. 7, 2024); see also New York Department of Taxation and Finance, Jun. 26, 2018,
19   https://www.tax.ny.gov/pubs_and_bulls/tg_bulletins/st/naics.htm#:~:text=NAICS%20is%20a%20s
20   elf%2Dassigned,North%20American%20Industry%20Classification%20System (last visited Oct. 7,
21   2024) (“NAICS is a self-assigned system. You pick the code that best describes your business or
22   organization.”).
23            562.     SBA’s own instructions as to finding a NAICS code states that “[t]o find your NAICS
24   code, view the NAICS code list at U.S. Census Bureau.” https://www.sba.gov/federal-
25   contracting/contracting-guide/basic-requirements (last visited Oct. 7, 2024).
26            563.     SBA’s website also states that “[a] business will generally have a primary NAICS
27   code, but it can also have multiple NAICS codes if it sells multiple products and services.”
28
                                               109                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   https://www.sba.gov/federal-contracting/contracting-guide/basic-requirements (last visited Oct. 7,

 2   2024).

 3            564.      Even prior to the enactment of the PPP through the CARES Act, the Affiliation Rules

 4   addressed NAICS codes.

 5            565.     13 C.F.R. § 121.101(a) states:

 6            SBA’s size standards define whether a business entity is small and, thus, eligible for
              Government programs and preferences reserved for “small business” concerns. Size
 7            standards have been established for types of economic activity, or industry, generally
              under the North American Industry Classification System (NAICS). (Clarification in
 8            original).

 9            566.     13 C.F.R. § 121.101(b) states, in part:

10            NAICS is described in the North American Industry Classification Manual-United
              States, which is available from the National Technical Information Service, 5285 Port
11            Royal Road, Springfield, VA 22161; by calling 1(800) 553-6847 or 1(703) 605-6000;
              or via the Internet at http://www.ntis.gov/products/naics.aspx.
12
              567.     The website link provided in 13 C.F.R. § 121.101(b), however, is broken, it does not
13
     lead to a website; rather, an error is returned when entering that link into a (Google Chrome) web-
14
     browser.
15
              568.     The website link provided in 13 C.F.R. § 121.101(b) has in it “ntis,” or the National
16
     Technical Information Service (“NTIS”). A search of NTIS’s website, https://www.ntis.gov/ (last
17
     visited Feb. 14, 2024), for “NAICS” brings back zero results. 8
18
              569.     13 C.F.R. § 121.101(b) also states:
19
              NAICS assigns codes to all economic activity within twenty broad sectors. Section
20            121.201 provides a full table of small business size standards matched to the U.S.
              NAICS industry codes. A full table matching a size standard with each NAICS
21            Industry or U.S. Industry code is also published annually by SBA in the Federal
              Register. (emphasis added).
22
              570.     The “full table” of NAICS codes contained in 13 C.F.R. § 121.201, as referenced in
23
     13 C.F.R. § 121.101(b), does not match, and is far less comprehensive than, the NAICS code list
24
     contained in the North American Industry Classification System list on the U. S. Census Bureau
25

26
     8
       There appears to be an issue with the website www.ntis.gov because when the undersigned’s staff
27   attempted to view the website on October 7, 2024, an error page appeared indicating the
     www.ntis.gov hosting server encountered an error.
28
                                                     110                       Case No. 3:24-cv-04241-LJC
         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
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 1   website, both the 2017 and 2022 found thereat.

 2            571.     In addition, irrespective of the statement found in 13 C.F.R. § 121.101(b) quoted in

 3   paragraph 569 above, the SBA does not, in fact, annually publish a “full table matching a size

 4   standard with each NAICS Industry or U.S. code” in the Federal Register. Rather, the SBA annually

 5   publishes updates of this list. From Plaintiffs’ review of the Federal Register, the SBA has not

 6   updated any information in regard to any of the NAICS codes that could even potentially be

 7   applicable to the Plaintiffs since before the Pandemic.

 8            572.     NAICS codes appear to be somewhat tangentially related to the “business code

 9   number” or “business activity code” on business tax returns.

10            573.     All Plaintiffs are either corporations or limited liability companies.

11            574.     Corporations file an IRS Form 1120 tax return, and limited liability companies file an

12   IRS Form 1065 tax return as partnership income.

13            575.     The IRS Form 1065 (2021 version attached hereto as Exhibit YY) requires, as the

14   very first entry on the document, inclusion of the “Principal business activity” of the taxpayer.

15            576.     The IRS’s Instructions for Form 1065 (excerpts from the 2021 version being attached

16   hereto as Exhibit ZZ) explain that the code for the principal business activity is to be taken from a

17   list of principal business activity and principal product or service codes near the end of the

18   instructions. [Id., at p. 18]. That chart of the business activity codes states: “These Principal Business

19   Activity Codes are based on the North American Industry Classification System.” [ Id., at p. 56].

20            577.     The IRS Form 1120 (2021 version attached hereto as Exhibit AAA) and Instructions

21   for Form 1120 (excerpts from the 2021 version being attached hereto as Exhibit BBB) are similar.

22            578.     The IRS Form 1120 requires entry, at Schedule K, line 2a, of the “Business activity

23   code no.” [Ex. AAA]. The Instructions for Form 1120 also refer to a chart of codes, which in turn

24   similarly states that “[t]hese principal business activity codes are based on the North American

25   Industry Classification System.” [Ex. BBB, at p. 28].

26            579.     The list of the business activity codes contained in the instructions to the IRS Forms

27   1120 and 1065, which specifically state that they are based on the North American Industry

28
                                               111                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24     Page 112 of 169



 1   Classification System, do not correlate verbatim to, and are not as comprehensive as, the list of

 2   NAICS codes contained in 13 C.F.R. § 121.201.

 3            580.     The list of the business activity codes contained in the instructions to the IRS Forms

 4   1120 and 1065, which specifically state that they are based on the North American Industry

 5   Classification System, do not correlate verbatim to, and are not as comprehensive as, the NAICS

 6   code list contained in either the 2017 or 2022 version of the NAICS Manual found on the U.S. Census

 7   Bureau’s website, https://www.census.gov/naics/ (last visited Oct. 7, 2024).

 8            581.     The initial PPP loan applications and instructions contained no information or

 9   directions regarding how an applicant, or an accounting professional assisting in the preparation of

10   an application, was to determine whether the applicant was a NAICS code 72 for purposes under the

11   PPP so as to be exempted from the Affiliation Rules.

12            582.     First draw PPP loan application forms, SBA Form 2483, are found on SBA’s website

13   and contain versions 1, effective April 2, 2020, through version 10, effective March 18, 2021.

14   https://www.sba.gov/document/sba-form-2483-ppp-first-draw-borrower-application-form                (last

15   visited Oct. 7, 2024).

16            583.     The first draw PPP loan application forms promulgated by SBA did not reference a

17   NAICS code, or in any way require an applicant to list a NAICS code on the application form, until

18   version 7, which was effective as of January 8, 2021. [Exhibit CCC]. Thereon, for the first time,

19   SBA’s instructions to Form 2483, stated: “[f]or purposes of reporting NAICS Code, applicants must

20   match the business activity code provided on their IRS income tax filings, if applicable.” [Id. at p.3].

21            584.     Second draw PPP loan application forms, SBA Form 2483-SD, are found on SBA’s

22   website and contain versions 1, effective January 8, 2021, through version 4, effective March 18,

23   2021.      https://www.sba.gov/document/sba-form-2483-sd-ppp-second-draw-borrower-application-

24   form (last visited Oct. 7, 2024).

25            585.     All of the second draw PPP loan application forms promulgated by SBA state that

26   “[f]or purposes of reporting NAICS Code, applicants must match the business activity code provided

27   on their IRS tax income filings, if applicable.” [Exhibit DDD].

28
                                               112                         Case No. 3:24-cv-04241-LJC
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        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
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 1            586.     SBA used the same form, SBA Form 3508, for both first and second draw PPP loan

 2   forgiveness applications.

 3            587.     For loans of $150,000.00 and below, borrowers were to use the SBA Form 3508S.

 4            588.     For loans of over $150,000.00, borrowers could use SBA Form 3508 or Form 3508EZ

 5   to apply for forgiveness.

 6            589.     SBA Form 3508 is found on SBA’s website, which contains versions 1, effective May

 7   15, 2020, through 10, effective July 30, 2021. https://www.sba.gov/document/sba-form-3508-ppp-

 8   loan-forgiveness-application-instructions (last visited Oct. 7, 2024).

 9            590.     The SBA Form 3508 did not require an applicant to list a NAICS code on the

10   application form until version 8, which was effective as of January 19, 2021. [Exhibit EEE].

11   Thereon, for the first time, SBA’s instructions to Form 3508, stated: “[e]nter the same information as

12   on your Borrower Application Form, unless there has been a change in address or contact

13   information. If NAICS code was not on the Borrower Application Form, match the business activity

14   code provided on IRS income tax filings, if applicable.” [Id.].

15            591.     As discussed above, all of the Plaintiffs are licensed bars or taverns, serve alcohol,

16   and some provide live entertainment. Some also have specific “nightclub” licenses in addition to

17   their liquor licenses.

18            592.     The 2017 NAICS Manual, found at https://www.census.gov/naics/?48967 (last

19   visited, Oct. 7, 2024), states, in regard to NAICS code 722410, that “[t]his industry comprises

20   establishments known as bars, taverns, nightclubs, or drinking places,” and specifically lists, among

21   other things, “nightclubs, alcoholic beverage” as an appropriate entity under this code.

22   https://www.census.gov/naics/?input=722410&year=2017&details=722410 (last visited Oct. 7,

23   2024; and which represents the electronic version of the aforementioned 2017 NAICS Manual)

24   (emphasis added).

25            593.     The 2022 NAICS Manual, found at https://www.census.gov/naics/?48967 (last

26   visited, Oct. 7, 2024), contains identical language to that quoted for the 2017 Manual in the preceding

27   paragraph.

28
                                               113                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1             594.    The 2017 NAICS Manual, in regard to NAICS code 722410, also states, in its “Cross-

 2   References” section, that “[o]perating discotheques or dance clubs without selling alcoholic

 3   beverages—are classified in Industry 713990, All Other Amusement and Recreation Industries.”

 4   https://www.census.gov/naics/?input=722410&year=2017&details=722410 (last visited Oct. 7,

 5   2024; and which represents the electronic version of the aforementioned 2017 NAICS Manual).

 6             595.    The 2022 NAICS Manual, in regard to NAICS code 722410’ “Cross-Reference”

 7   section, states essentially the same thing as the 2017 NAICS Manual as quoted in the preceding

 8   paragraph, however, changes it ever so slightly: “[o]perating nightclubs or dance clubs without

 9   selling          alcoholic     beverages—are          classified      in        Industry      713990[.]”

10   https://www.census.gov/naics/?input=722410&year=2022&details=722410 (last visited Oct. 7,

11   2024) (emphasis added).

12             596.    Based upon the statements found in the official NAICS Manuals and website as

13   quoted in the preceding paragraphs, the Plaintiffs and their accounting professionals who assisted in

14   the various Loan and forgiveness applications believed at the time, and still believe, that each of the

15   Plaintiffs is appropriately a NAICS 722410 entity; that as a consequence thereof the Plaintiffs are

16   exempt under the PPP from the Affiliation Rules; and that the Plaintiffs are therefore entitled to the

17   Loans and to the forgiveness thereof as applied for.

18             597.    Plaintiffs are NAICS code 722410 entities.

19             598.    NAICS code 722410 entities are exempt under the PPP from the Affiliation Rules.

20             599.    As NAICS code 722410 entities, Plaintiffs are exempt under the PPP from the

21   Affiliation Rules.

22             600.    In addition, and regardless of the above, subsequent developments in the PPP loan

23   and forgiveness application process, as discussed above, further support Plaintiffs’ exclusion from

24   the Affiliation Rules.

25             601.    In regard to the belated instructions set forth in the forms discussed in paragraphs 584

26   and 589, Plaintiffs Gold Club, SAW, and Meacham had, for years prior to the Pandemic, identified

27   themselves on their federal tax returns with a business activity code beginning with the number 72

28
                                               114                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   (specifically 722410; equivalent to NAICS code 722410). For these Plaintiffs, at least, the decision

 2   of the SBA to deny forgiveness, or at least initially deny forgiveness, based upon the Affiliation Rules

 3   is actually directly contrary to the SBA’s own revised application forms and the instructions relating

 4   thereto.

 5            602.     In addition, the applications and instructions set forth in the forms discussed in

 6   paragraphs 582, 584, and 589, are in numerous instances, misleading and internally incorrect. For

 7   example, a number of the Plaintiffs used a business activity code on their tax returns of 713900

 8   (“Other Amusement & Recreation”), although neither the Affiliation Regulations nor the NAICS

 9   Manual (either 2017 or 2022) contain a NAICS code of 713900. So, in applying for a PPP loan or

10   forgiveness it would literally be impossible for the applicant to identify a specific NAICS code that

11   simply does not exist.

12            603.     Regardless of all of above in this subsection of facts, for those Plaintiffs that had Loan

13   forgiveness denied by the SBA, most of them (Plaintiffs Meacham and Reeder being the exceptions)

14   were belatedly determined by the SBA to be ineligible for loans, and therefore for loan forgiveness,

15   based upon the claim by the SBA that the particular Plaintiff, together with Mohneys (as that term is

16   defined below) being alleged “affiliated” entities (Plaintiffs again, Meacham and Reeder being the

17   exceptions), are “too large” of a “business concern” under the Affiliation Rules to be entitled to loans

18   guaranteed by the SBA. More specifically, the SBA does not accept that such Plaintiffs are NAICS

19   code 72 businesses under the Affiliation Exception Provisions.

20            604.     More specifically, the SBA is lumping all of these Plaintiff businesses together

21   (Plaintiff Meacham excepted) based upon their association, or perceived (by the SBA) association,

22   with businessmen by the name of Harry Mohney (“H.Mohney”) and Jason Mohney (“J.Mohney,”

23   when combined with H.Mohney, the “Mohneys”). Through its action as described herein, the SBA

24   seeks to assert that because of their “affiliation” with either, H.Mohney, J.Mohney, or both, each

25   Plaintiff (again, except Meacham), together with its “Mohney affiliates,” renders this “business

26   concern” too large for SBA funding.

27            605.     As it relates to Plaintiffs Reeder and Meacham, however, SBA has since initiated Post

28
                                               115                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   Payment Review audits of these Plaintiffs and one of the asserted reasons therefor is that, SBA

 2   asserts, these Plaintiffs, together with their alleged “affiliated” entities are too large of a business

 3   concern under the Affiliation Rules to be entitled to loans guaranteed by the SBA. More specifically,

 4   the SBA does not accept that such Plaintiffs are NAICS code 72 businesses under the Affiliation

 5   Exception Provisions.

 6            606.     The Plaintiffs that received both Loans and forgiveness thereof, but which are now

 7   under audit from the SBA, are—based upon the documents and information requested—being

 8   audited for the same reason (too large of a business concern under the Affiliation Rules); the SBA

 9   not accepting those Plaintiffs’ identification as being a NAICS code 72 business on their PPP Loan

10   and forgiveness applications.

11            607.     Benderson has a particular and admitted disdain (as discussed later herein) for the

12   type of “adult” businesses with which H. Mohney, J. Mohney, or both, are associated to the extent

13   that the SBA is now going after businesses associated with Mohneys that have nothing whatsoever

14   to do with perceived (by the SBA) “adult” entertainment, exemplified by Plaintiffs Cats Vegas and

15   Cats NOLA which are simply karaoke bars, or Plaintiffs Office and Pole Position which are just

16   licensed bars that do not regularly present any form of entertainment whatsoever.

17            608.     From the document requests and Denial Letters that numerous Plaintiffs have

18   received from the SBA and/or the Lending Banks, it seems clear that the SBA contends that it has

19   the authority to “reassign” the Plaintiffs’ self-designated NAICS code, or to rely solely on what SBA

20   may perceive to be the primary NAICS code, despite admitting that a business may have more than

21   one NAICS code, based upon what the SBA contends was the main income source of the business.

22   And, in doing so, the SBA also believes that it has absolute discretion to assign various income

23   streams to certain aspects of a business in order to justify its desired “conclusion” that the Plaintiffs’

24   self-designated NAICS 72 code designation was not correct.

25            609.     The SBA has no basis in fact or law to “assign” NAICS codes for PPP purposes based

26   on sources of income.

27            610.     The SBA has not published any guidance, legislative rule, general statement of policy,

28
                                               116                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   or otherwise, that provides authority to assign, or guidance for assigning, NAICS codes for PPP

 2   purposes based on sources of income.

 3            611.     Even though it has no basis in fact or law for doing so, the SBA’s focus on sources of

 4   income as discussed in the preceding few paragraphs immediately breaks down when viewed in the

 5   context of Plaintiffs Cats Vegas, Cats NOLA, and the Office, which either do not regularly present

 6   live entertainment or that have simple karaoke entertainment which itself does not have its own

 7   NAICS code. Yet, the SBA’s examinations of these businesses aptly demonstrate the vindictive,

 8   harassing, targeted, discriminatory, and retaliatory nature of the SBA’s treatment of these Plaintiffs

 9   and others SBA claims are related to Mohneys.

10            612.     The SBA’s focus on income sources for its affiliation analysis of a number of these

11   Plaintiffs also breaks down when viewed in context of the most recent events concerning Plaintiffs

12   Gold Clubs’ second draw Loan and Meacham’s second draw Loan where the SBA, in its “new and

13   improved” Denial Letters, abandoned affiliation as a basis for forgiveness denial even though those

14   Plaintiffs have numerous sources of income, including that from entertainment.

15            613.     Upon information and belief, the actions of the SBA in regard to these “size” issues

16   are not being taken in good faith and are being taken, rather, to financially bleed the Plaintiffs through

17   the professional fees that have to be incurred in responding to the SBA’s never-ending requests that

18   are themselves the direct and proximate result of Benderson’s aversion to any forms of “adult”

19   entertainment or to those associated in any regard or degree with the same.

20            614.     During a settlement conference conducted via Zoom that occurred on March 24, 2023,

21   with attorneys of the undersign firm and SBA attorneys Erica Hoppes, Arlene Embrey, and

22   Benderson. During the conference, Benderson commented that clients of the undersigned firm should

23   not be receiving SBA monies because they are, he stated, merely “fronts for prostitution.” Benderson

24   further stated that with regard to second draw loans, the SBA would not even negotiate with clients

25   of the undersigned firm that present “adult” entertainment. Regardless of the fact that each Plaintiff

26   is a licensed bar and is under constant governmental supervision as a result of such licenses, and the

27   fact that none of the Plaintiffs have ever been charged with prostitution or prostitution-related crimes,

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   the comments of Benderson at this settlement conference clearly demonstrate his bias against these

 2   Plaintiffs. And, given Benderson’s position of authority—as discussed herein—in making ultimate

 3   eligibility determinations affecting these Plaintiffs, these comments of Benderson explain the

 4   vindictive, harassing, discriminatory, and retaliatory nature of the SBA’s treatment of these Plaintiffs

 5   as described in elaborate detail herein. 9

 6            615.     As a further example of the vindictive, harassing, discriminatory, and retaliatory

 7   nature of the SBA’s treatment of these Plaintiffs, while the SBA has not technically denied Loan

 8   forgiveness for Plaintiff Meacham based upon “affiliation” with Mohneys, the treatment of Meacham

 9   by the SBA in denying Loan forgiveness is still nevertheless related to Benderson’s disdain for

10   Mohneys in that Meacham is owned by an individual who is a member in Plaintiff Dallas Food &

11   Beverage, which is in part indirectly owned by J.Mohney. And, because of all of the “affiliation”

12   information these Plaintiffs have been required to submit to the SBA as part of their Loan and

13   forgiveness applications, the SBA and Benderson know that.

14            616.     On the other hand, the SBA has forgiven PPP loans for numerous “adult” businesses

15   located all throughout the country that have no association with Mohney.

16            617.     In addition, as part of its continued vindictive, harassing, discriminatory, and

17   retaliatory treatment of these particular Plaintiffs, the SBA has not been above actually lying in its

18   Denial Letters.

19            618.     For example, in the Denial Letter for Plaintiff Dallas Food & Beverage’s second draw

20   PPP Loan [Exhibit FFF], the SBA states, in denying Loan forgiveness both under the Prurience

21   Regulation and the Affiliation Rules, that:

22            It is noted borrower claimed NAICS code 722515 on 2483 however Tax returns List
              NAICS Code 71390, Adult Entertainment, which is in line with SBA guidelines
23            classification based on the business primary industry type and limited revenue figure
              from Tax Returns.
24

25   9
       Under Fed. R. Evid. 408, settlement negotiations are normally privileged and cannot be admitted
     into evidence, at least not in the proceeding that was the subject of the settlement negotiations. There
26   are, however, exceptions to Fed. R. Evid. 408’s prohibition on admittance of evidence related to
     compromise/settlement negotiations. One of the exceptions to Fed. R. Evid. 408’s prohibition on
27   admittance of evidence related to compromise/settlement negotiations includes proving a witness’s
     bias or prejudice. Fed. R. Evid. 408(b).
28
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         VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
         FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                           AGENCY ACTION
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 1   [Id. (emphasis added)].

 2            619.     Plaintiff Dallas Food & Beverage never listed a business activity code on its tax
 3   returns (based on NAICS codes, as discussed above) of “71390.”
 4            620.     There is no 71390 NAICS code.
 5            621.     There is no NAICS code for “Adult Entertainment” nor does “Adult Entertainment”
 6   or the content of entertainment operate to exclude a business from any applicable NAICS code.
 7            622.     Nothing contained in the PPP, any regulations promulgated thereto, or in the
 8   Affiliation Regulations, permits the SBA to “reassign” a NAICS code number to a loan applicant
 9   that is a licensed bar, let alone to a loan grantee.
10            623.     As such, there is no basis for the SBA to have denied Loan eligibility and therefore
11   forgiveness in regard to, for example, Plaintiffs Dallas Food and Beverage and Meacham because of
12   the fact that they had not provided, as the SBA contends, sufficient “documentation” on their various
13   streams of income (SBA’s FLRDs request “an itemized breakdown of the Business Revenue/Sales”).
14   Such information is completely irrelevant to the question of whether the business is as a licensed bar
15   or tavern, or a liquor-serving nightclub.
16            624.     In all of the FLRDs, SBA has failed to identify which NAICS code it believes the
17   particular Plaintiff should be.
18            625.     Since each Plaintiff is properly a NAICS code 72 business for PPP purposes, and
19   because each had, in regard to first draw PPP Loans fewer than 500 employees at its physical location
20   and in regard to second draw PPP Loans fewer than 300 employees at its physical location, all
21   Plaintiffs are exempt from the Affiliation Rules. As such, there is no factual or legal basis to have
22   denied, for some of the Plaintiffs, forgiveness of their Loans based upon the Affiliation Rules and,
23   for other Plaintiffs, to have now commenced audits of their forgiven Loans in order to target and
24   reexamine Loan eligibility based upon the Affiliation Rules.
25            626.     It is beyond the scope of Defendants’ authority to create unconstitutional regulations,
26   policies, and procedures; to enforce unconstitutional regulations, policies, procedures and statutory
27   provisions including but not limited to the Prurient Regulation, Incorporating Statute, the Affiliation
28
                                               119                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   Exception Provisions, the Affiliation Rules, the Special OHA Rules, and the Injunction Provision

 2   (defined, infra); to interpret statutes, regulations, policies, and procedures in an unconstitutional

 3   manner including but not limited to the Prurient Regulation, Incorporating Statute, the Affiliation

 4   Exception Provisions, the Affiliation Rules, the Special OHA Rules, and the Injunction Provision;

 5   and to apply unconstitutional regulations, policies, procedures, and statutory provisions including

 6   but not limited to the Prurient Regulation, Incorporating Statute, the Affiliation Exception Provisions,

 7   the Affiliation Rules, the Special OHA Rules, and the Injunction Provision.

 8                                                  COUNT I

 9        THE PRURIENCE REGULATION AND INCORPORATING STATUTE VIOLATE
                             THE FIRST AMENDMENT
10

11            627.     Plaintiffs incorporate herein by reference each and every paragraph above as though

12   fully set forth herein.

13            628.     In raising their First Amendment challenges to the Prurience Regulation and the

14   Incorporating Statute here, those Plaintiffs affected assert not only their own rights but also the rights

15   of their owners and employees; the entertainers who perform on their premises; the customers who

16   have in the past frequented, and intend in the future to frequent, those Plaintiffs’ premises in order to

17   be able to observe First Amendment protected entertainment and otherwise engage in First

18   Amendment-protected activities; as well as the rights of other businesses that the SBA asserts,

19   believes, or claims to be “affiliated” with any of the Plaintiffs and have suffered from the same type

20   of vindictive, retaliatory, harassing and discriminatory conduct by the SBA as detailed herein.

21            629.     The Prurience Regulation and the Incorporating Statute violate, and are contrary to,

22   the First Amendment to the United States Constitution, both on their face and in particular as applied

23   by the SBA to Plaintiffs, for numerous and various reasons, including but not limited to:

24                     a.      They are impermissible viewpoint-based restrictions on speech and

25            expression that are not necessary to any compelling governmental interest and are not

26            sufficiently narrowly tailored;

27                     b.      They are impermissible content-based restrictions on speech and expression

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
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                                          AGENCY ACTION
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 1            that are not necessary to any compelling governmental interest and are not sufficiently

 2            narrowly tailored;

 3                     c.    As agreed by the SBA in D. Houston Inc. v. United States Small Bus. Admin.,

 4            579 F. Supp. 3d 959, 968, ¶ 34 and also n.10 (S.D. Tex. 2020), the Prurience Regulation is a

 5            content-based restriction of speech and expression;

 6                     d.    As admitted by the SBA, they invidiously and impermissibly discriminate

 7            against disfavored speech and expression and are being applied by the SBA particularly

 8            against speech and expression that its personnel find to be disagreeable;

 9                     e.    They are being applied by SBA personnel in a discriminatory fashion in

10            retaliation for the nature of the speech and expression engaged in by some of these Plaintiffs

11            and for some of them and/or their principals having participated in other litigation against the

12            SBA arising out of Pandemic funding programs;

13                     f.    The SBA is applying them in an unconstitutional fashion in that SBA

14            personnel do not even review the expression at issue and are reaching eligibility

15            determinations in a conclusory fashion;

16                     g.    They violate, as applied to the First Amendment, the doctrine of

17            unconstitutional conditions by conditioning the receipt of PPP loans upon the Plaintiffs not

18            engaging in entertainment that the SBA opines, determines, or assumes without any analysis

19            whatsoever, to be of a “prurient sexual nature” (whatever that may mean);

20                     h.    They effectuate, in order to obtain PPP loans, an impermissible prior restraint

21            on speech and expression;

22                     i.    Even if deemed to be content-neutral (which they cannot under any existing

23            precedent), they do not further any permissible and important governmental interest;

24                     j.    They fail to conform to the constitutional standards regarding obscenity;

25                     k.    As applied by the SBA, they are in conflict with § 633(e) of the SBA Act and

26            render that provision to be meaningless and a nullity; thereby depriving speech and

27            expression-related businesses of the First Amendment protections that Congress imposed by

28
                                               121                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            enacting § 633(e);

 2                     l.      They deprive fundamental First Amendment protections to speech and

 3            expression-related businesses in SBA funding decisions imposed by Congress through §

 4            633(e) of the SBA Act and, in clear violation of fundamental canons of statutory construction,

 5            render § 633(e) to be meaningless and a nullity;

 6                     m.      They impermissibly single out, and are being applied to single out, First

 7            Amendment-protected businesses for denial of PPP benefits without justification;

 8                     n.      The exceptions of loan eligibility under the PPP have been legislatively and

 9            administratively gerrymandered so that such exceptions now, under the modified PPP, apply

10            to disfavored speech and expression and to little else, in other words, the exceptions swallow

11            the rule;

12                     o.      They are unconstitutionally vague on their face and as applied by the SBA,

13            particularly under the enhanced vagueness standards that are imposed upon laws that impact

14            upon speech and expression-related activities, because: 1) they do not provide standards that

15            can be readily understood by persons of common intelligence; 2) they do not provide clear

16            guidance to governmental officials so that no ad hoc, arbitrary, or discriminatory enforcement

17            decisions are made; and 3) they do not contain the full three standards of obscenity as

18            established under the Miller Test which the Supreme Court has acknowledged in Reno v.

19            ACLU, 521 U.S. 844, 865, 871, 873-74 (1997) are necessary in order for the individual

20            components of the Miller Test not to be impermissibly vague;

21                     p.      They are impermissibly and substantially overbroad in relation to their plain

22            legitimate sweep; and

23                     q.      They, as applied by the SBA, have been impermissibly manipulated beyond

24            defining the contours of the PPP funding program to impermissibly defining its recipients

25            (i.e., not Plaintiffs).

26            630.     As a direct and proximate result of the unconstitutional aspects of the Prurience

27   Regulation and the Incorporating Statute, as well as the Defendants’, and their delegates’, application

28
                                               122                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   and enforcement of them against the affected Plaintiffs and their interests, all as referenced above,

 2   the affected Plaintiffs, as well as their owners and employees, the entertainers who perform on their

 3   premises and the customers who frequent their establishments, have suffered, and/or will suffer,

 4   and/or will continue to suffer irreparable injuries including but not limited to financial collapse,

 5   business ruination, and/or the inability to present, view, and/or engage in First Amendment-protected

 6   speech, expression, and entertainment.

 7            631.     Because of the First Amendment rights being infringed upon by Defendants’

 8   application and enforcement of the Prurience Regulation and the Incorporating Statute, all as

 9   referenced in detail above, this Court has the authority to declare the rights and the legality of actions

10   of the various parties and should do so here. It should also permanently enjoin enforcement by the

11   SBA of the Prurience Regulation and the Incorporating Statute.

12            632.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

13   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

14   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

15   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

16   enforcement of the Prurience Regulation and the Incorporating Statute, because the Defendants will

17   not suffer any harm whatsoever by the entry of a preliminary injunction, and because the balance of

18   harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter a preliminary

19   injunction in order to protect Plaintiffs’ fundamental rights at issue here.

20            633.     For the reasons set forth above, Plaintiffs are entitled to judicial review in regard to

21   the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

22                                                   COUNT II

23        THE PRURIENCE REGULATION AND INCORPORATING STATUTE VIOLATE
                             THE FIFTH AMENDMENT
24

25            634.     Plaintiffs incorporate herein by reference each and every paragraph above as though

26   fully set forth herein.

27            635.     The Regulation and the Incorporating Statute violate, and are contrary to, the Fifth

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1   Amendment to the United States Constitution, both on their face and particularly as applied by the

 2   SBA to Plaintiffs, for numerous and various reasons, including but not limited to:

 3                     a.    They treat establishments presenting certain forms of live performance dance

 4            entertainment, such as some of these Plaintiffs, differently from establishments presenting

 5            other forms of entertainment or no entertainment at all, for no compelling, important, or

 6            rational reason;

 7                     b.    They treat, under the PPP, businesses that employee persons who work at

 8            establishments presenting certain forms of entertainment, as demonstrated by some of the

 9            Plaintiffs here, unequally and differently from businesses that employ workers at

10            establishments presenting other forms of entertainment or no entertainment at all, for no

11            compelling, important, or rational reason;

12                     c.    They violate the occupational liberty rights of the affected Plaintiffs, their

13            employees, and the entertainers who perform on their premises;

14                     d.    They violate the substantive and procedural Due Process rights of the affected

15            Plaintiffs, their employees, and the entertainers who perform on their premises;

16                     e.    They treat, have been used to treat, and could continue to treat in the future,

17            similarly situated persons and businesses differently without justification;

18                     f.    They deny, for the reasons set forth in detail above, the affected Plaintiffs of

19            equal protection under the laws of the United States of America;

20                     g.    They treat First Amendment-protected businesses differently by waiving other

21            prior statutory and administrative expression-related exclusions to PPP eligibility under the

22            SBA Act that applied to certain expressive businesses and business concerns, while denying

23            the affected Plaintiffs access to PPP benefits via denial of loan forgiveness;

24                     h.    They treat First Amendment-protected businesses differently from non-

25            constitutionally protected businesses by waiving, for PPP purposes, other prior statutory and

26            administrative exclusions to PPP eligibility under the SBA Act that applied to certain non-

27            constitutionally protected businesses, while continuing to deny the affected Plaintiffs access

28
                                               124                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1            to PPP benefits;

 2                     i.     They are being arbitrarily and capriciously applied by the Defendants; and

 3                     j.     They are impermissibly vague on their face and as applied to these Plaintiffs

 4            for the reasons discussed above.

 5            636.     As a direct and proximate result of the unconstitutional aspects of the Prurience

 6   Regulation and the Incorporating Statute, as well as the Defendants’, and their delegates’, application

 7   and enforcement of them against the affected Plaintiffs and their interests, all as referenced above,

 8   the affected Plaintiffs, as well as their owners and employees, the entertainers who perform on their

 9   premises and the customers who frequent their establishments, have suffered, and/or will suffer,

10   and/or will continue to suffer irreparable injuries including but not limited to financial collapse,

11   business ruination, and/or the inability to present, view, and/or engage in First Amendment-protected

12   speech, expression, and entertainment.

13            637.     Because of the Fifth Amendment rights being infringed upon by Defendants’

14   application and enforcement of the Prurience Regulation and the Incorporating Statute, all as

15   referenced above, this Court has the authority to declare the rights and the legality of actions of the

16   various parties and should do so here.

17            638.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

18   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

19   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

20   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

21   enforcement of the Prurience Regulation and the Incorporating Statute, because the Defendants will

22   not suffer any harm whatsoever by the entry of a preliminary injunction, and because the balance of

23   harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter a preliminary

24   injunction in order to protect Plaintiffs’ fundamental rights at issue here.

25            639.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

26   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

27

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1                                                  COUNT III

 2      THE SBA’S INTERPRETATION(S) OF THE PRURIENCE REGULATION AND THE
                       INCORPORATING STATUTE ARE INVALID
 3

 4            640.     Plaintiffs incorporate herein by reference each and every paragraph above as though

 5   fully set forth herein.

 6            641.     The SBA and/or the Administrator’s defining of “prurient” as “lustful,” “lascivious,”

 7   an “overt strong sexual interest,” “erotic,” and/or “arousing of strong sexual interest or desire” under

 8   the Prurience Regulation is not a legitimate or lawful exercise of the SBA’s or its Administrator’s

 9   authority, and is otherwise invalid under the Administrative Procedures Act, 5 U.S.C. § 551 et seq.

10   and applicable law because, among other reasons:

11                     a.      Such construction of the term “prurient” is inconsistent with the SBA Act,

12            particularly § 633(e) thereof, the SOP’s that the SBA has issued, and the legal definition of

13            the term “prurient” as articulated by the United States Supreme Court;

14                     b.      Such construction of the term “prurient” is not a reasonable interpretation of

15            the term;

16                     c.      Such construction of the term “prurient” renders that very term of the

17            Prurience Regulation irrelevant, superfluous, and of no effect since the term “erotic,” which

18            the SBA has asserted in litigation to be what the term “prurient” is meant to convey, is

19            generally understood to mean a tendency to arouse sexual desire or excitement, which is

20            already included in the Prurience Regulation through the phrase “prurient sexual nature”;

21                     d.      Such construction, for the reasons set forth in the subsection immediately

22            above, demonstrates that the SBA deceived the general public in the notice and comment

23            process by not conveying just what the SBA was attempting to exclude from funding by way

24            of the Prurience Regulation;

25                     e.      Such construction of the term “prurient” is arbitrary, capricious, an abuse of

26            discretion in light of, and is directly contrary to, the SBA Act, and in particular § 633(e)

27            thereof;

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
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                                          AGENCY ACTION
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 1                     f.     Such construction of the term “prurient” is arbitrary, capricious, and an abuse

 2            of discretion in light of, as a result of, and as exemplified by, the ever-changing SOP’s issued

 3            by the SBA that discuss, and that purport to provide guidance to Lending Banks in regard to,

 4            the Prurience Regulation;

 5                     g.     Such construction of the term “prurient” would render § 633(e) of the SBA

 6            Act meaningless, void, a nullity, and of no effect;

 7                     h.     Such construction of the term “prurient” is not supported by the Prurience

 8            Regulation’s findings because in promulgating the Prurience Regulation the SBA specifically

 9            acknowledged the Miller v. California, 413 U.S. 15 (1983) test of obscenity, with which the

10            Prurience Regulation does not comply, see Business Loan Programs, 60 Fed. Reg. 64356,

11            64360 (Proposed, Dec. 15, 1995);

12                     i.     Such construction of the term “prurient” is not supported by current

13            constitutional standards of obscenity which, as articulated by the United States Supreme

14            Court, defines and operationalizes the term “prurient” to mean a “shameful or morbid” and

15            “unhealthy” interest in sex, as opposed to “normal, healthy sexual desires”;

16                     j.     Such construction of the term “prurient” is not supported by current

17            constitutional standards of obscenity which, as articulated by the United States Supreme

18            Court, reject “lustful” as satisfying the constitutional standard for prurient appeal; and

19                     k.     Such construction of the term “prurient” is inconsistent with Congress’s goals

20            under the CARES Act and the Appropriations Act.

21            642.     Because, as applied by the SBA and/or the Administrator, the Prurience Regulation

22   and the Incorporating Statute are inconsistent with the SBA Act, as well as the broad form of relief

23   provided by the CARES Act and the Appropriations Act, all as referenced above, this Court has the

24   authority to declare the rights and the legality of actions of the various parties and should do so here.

25            643.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

26   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

27   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

 2   enforcement of the Prurience Regulation and the Incorporating Statute, because the Defendants will

 3   not suffer any harm whatsoever by the entry of a preliminary injunction, and because the balance of

 4   harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter a preliminary

 5   injunction in order to protect Plaintiffs’ fundamental rights at issue here.

 6            644.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

 7   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

 8                                                   COUNT IV

 9                          OTHER INVALIDITY OF THE PRURIENCE REGULATION
10            645.     Plaintiffs incorporate herein by reference each and every paragraph above as though
11   fully set forth herein.
12            646.     The Prurience Regulation is not a legitimate or lawful exercise of the SBA’s or the
13   Administrator’s authority as applied to first and second draw PPP loans, and is otherwise invalid
14   under the Administrative Procedure, 5 U.S.C. § 551 et seq. and applicable law because, among other
15   reasons:
16                     a.       It fails to serve any lawful or legitimate regulatory purpose for the SBA or the
17            Administrator as to first and second Draw PPP loans or otherwise;
18                     b.       The SBA and/or the Administrator failed to make a sufficient record, or to
19            otherwise articulate a satisfactory explanation, as to why the Prurience Regulation is a
20            rational or reasonable response to a problem that the agency was charged with solving under
21            the CARES Act or the Appropriations Act, and in particular the first and second Draw PPP
22            loans;
23                     c.       As applied to Plaintiffs by the SBA and/or the Administrator, the Prurience
24            Regulation conflicts with the decision to award first and/or second draw PPP Loans to
25            Plaintiffs in the first place because, among other reasons, only eligible entities were to receive
26            PPP loans;
27                     d.       As applied to Plaintiffs by the SBA and/or the Administrator, Defendants have
28
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                                          AGENCY ACTION
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 1            used the Prurience Regulation to engage in unreasoned decision making by utterly failing to

 2            explain how Defendants allegedly violated the Prurience Regulation in the FLRDs; and

 3                     e.      Applying the Prurience Regulation at the PPP loan forgiveness stage is in

 4            excess of SBA’s jurisdiction because, pursuant to the loan forgiveness statute, 15 U.S.C. §

 5            633m, only eligible recipients are entitled to loan forgiveness and eligible recipient is defined

 6            as simply “the recipient of a covered loan,” 15 U.S.C. § 636(a)(10), and Plaintiffs received

 7            covered loans.

 8            647.      Because the Prurience Regulation and the Incorporating Statute, as applied by the

 9   SBA and/or the Administrator, are inconsistent with the SBA Act, as well as the broad form of relief

10   provided by the CARES Act and the Appropriations Act, all as referenced above, and because they

11   do not, again as applied and enforced by the SBA and/or the Administrator, represent a rational and

12   reasonable response to a problem that the agency was charged with solving, this Court has the

13   authority to declare the rights and the legality of actions of the various parties and should do so here.

14            648.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

15   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

16   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

17   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

18   enforcement of the Prurience Regulation and the Incorporating Statute, because the Defendants will

19   not suffer any harm whatsoever by the entry of a preliminary injunction, and because the balance of

20   harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter a preliminary

21   injunction in order to protect Plaintiffs’ fundamental rights at issue here.

22            649.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

23   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

24                                                  COUNT V

25         THE SBA’S APPLICATION OF THE AFFILIATION EXCEPTION PROVISIONS
                           VIOLATES THE FIRST AMENDMENT
26
                                                (RETALIATION)
27

28
                                               129                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24    Page 130 of 169



 1            650.     Plaintiffs incorporate herein by reference each and every paragraph above as though

 2   fully set forth herein.

 3            651.     The SBA has stated and/or claimed that Plaintiffs (except Plaintiffs Meacham and

 4   Reeder) are affiliated with, among other entities related to Mohneys, DV Diamond Club of Flint,

 5   LLC. [See Ex. XX at AR p. 5851, exhibit p. 2 (noting that the Affiliation Narrative Worksheet

 6   Mohney et al #127 lists, among others, these Plaintiffs as alleged “affiliates” of DV Diamond Club

 7   of Flint)].

 8            652.     In the DV Diamond Club action against the SBA to gain access to PPP funds, the PPP

 9   funds were being withheld based on the SBA’s apparent disgust at the constitutionally protected

10   entertainment presented by these Plaintiffs and the SBA’s erroneous application of the Prurience

11   Regulation.

12            653.     By filing the DV Diamond Club action against the SBA, those Plaintiffs were engaged

13   in conduct protected by the First Amendment.

14            654.     Plaintiffs have presented, currently present, and desire to continue to present

15   entertainment that is protected by the First Amendment.

16            655.     Since the DV Diamond Club action, the SBA, and in particular Benderson, has

17   selected any business the SBA alleges to be an adult entertainment business or to be affiliated with

18   the Mohneys for additional scrutiny on any pandemic related funding program, including the PPP,

19   and has been looking for ways to deny Plaintiffs, and any business SBA alleges to be affiliated with

20   the Mohneys, pandemic aid funding, including to the PPP, to claw back any pandemic aid funding

21   the Plaintiffs received, or to simply run up the entities costs associated with obtaining loan

22   forgiveness. Examples and other indicia of the retaliatory actions by the SBA include:
23                     a.      The fact that Plaintiffs Gold Club and SAW were initially denied access to

24            RRF grants based on SBA’s extra-statutory incorporation of the Prurience Regulation into its

25            defective legislative rule couched as a general statement of policy or general statement of

26            policy that did not carry the force of law, Restaurant Revitalization Funding Program Guide.

27            It was only after these Plaintiffs sued in a case captioned as MAG Enterprises, Inc. v. U.S.

28
                                               130                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            Small Bus. Admin., No. 2:21-cv-02213 (E.D. Pa. 2021) that these Plaintiffs were granted

 2            access to these funds;

 3                     b.    The fact that SBA has concluded that Plaintiffs were not entitled to PPP loan

 4            forgiveness based on SBA’s failure to apply the Affiliation Exception Provisions to these

 5            Plaintiffs despite, as noted herein, the fact that they are clearly a NAICS 72 entity, serve

 6            alcohol/beverages and/or food and are licensed bars and taverns;

 7                     c.    The statements made by Benderson in the Zoom settlement meeting that

 8            occurred on March 24, 2023, as discussed herein;

 9                     d.    The targeting of businesses owned by the Mohneys, or either one of them, and

10            any businesses SBA alleges are affiliated with them, for incessant audits, requests for

11            documentation, and additional scrutiny of any business SBA claims that they are affiliated

12            with;

13                     e.    The fact that Benderson, via the Benderson Declaration, submitted untrue

14            statements to a court in support of advocacy against, among others, various businesses alleged

15            by the SBA via the Affiliation Narrative Worksheet Mohney # 127 to be affiliated with some

16            of the Plaintiffs and which presented similar constitutionally protected entertainment as

17            several of the Plaintiffs here, receiving second draw PPP loans;

18                     f.    The fact that Benderson stated the SBA refuses to even negotiate over various

19            Plaintiffs’ second draw loans as it did with regard to first draw loans, presumably, on the basis

20            that with the second draw, the Regulation is incorporated into the PPP via the Incorporating

21            Statute;

22                     g.    The fact that, on or about February 1, 2024, the SBA initiated an internal

23            review of the RRF award to Plaintiff SAW—which came by way of a settlement agreement

24            with the SBA, which specifically stated that SBA would not apply the Prurience Regulation

25            or the definitions and instructions concerning “Affiliates” and “Affiliated Businesses” as

26            found on page 19 of SBA’s April 28, 2021, Restaurant Revitalization Funding Program

27            Guide—demanding, among other documents, a list of all businesses that the principal owners

28
                                               131                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1             of SAW hold at least a 20% interest ownership in and their physical locations so as to make

 2             a determination under page 19 of SBA’s April 28, 2021, Restaurant Revitalization Funding

 3             Program Guide as to whether Plaintiff SAW was eligible for the RRF grant in the first place.

 4             In other words, SBA is acting in direct contravention to the settlement agreement under which

 5             Plaintiff SAW received its RRF grant in order to claw back the RRF grant;

 6                     h.      The fact that, for Plaintiff Meacham, SBA identified Meacham as allegedly

 7             being ineligible for the PPP under the Prurience Regulation back on April 24, 2023, at the

 8             latest, [Ex. L at AR p. 16, exhibit p. 5], (really, back on June 24, 2022, [id. at AR p. 17, exhibit

 9             p. 6], yet issued Meacham its first FLRD which does not reference this alleged ineligibly

10             reason. It was only after Meacham appealed that FLRD in the OHA and SBA withdrew that

11             FLRD did SBA issue the second FLRD, which raised, for the first time, Meacham’s alleged

12             ineligibility based on the Prurience Regulation. This scheme was designed to cause Meacham

13             to unnecessarily incur significant professional fees when SBA knew the present reason for its

14             denial of Meacham’s forgiveness request all along; and

15                     i.      The fact that, for Plaintiff SAW, SBA identified SAW as allegedly being

16             ineligible for the PPP under the Prurience Regulation back on September 9, 2022, at the latest,

17             [Excerpts of Administrative Record in SAW’s first OHA appeal of its first draw PPP Loan

18             initiated on or about November 30, 2023, at pp. 3542, 3547, 3550, and 3553-55]; 10 (Ex. T,

19             excerpts of the “Affiliate Narrative Worksheet Mohney et al #127 prepared and/or

20             reviewed/approved by Kevin Clay and Sharon K. Drake on or about September 19, 2022,

21             states: “There are NO entities that qualify for PPP Waivers since . . . AND Google Search

22             identify the business establishments as either gentlemen’s club [sic] or a business providing

23             Prurient Sexual Material. See Appendix B,” (Ex. T p. 3547), with Appendix B thereto stating,

24             “Business Address located in Google Search/Maps identifies ineligible businesses of prurient

25             nature,”) and providing the following:

26

27
     10
          Citations are to the page numbers stamped on the bottom of the pages, not the PDF page number.
28
                                                      132                           Case No. 3:24-cv-04241-LJC
          VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
          FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                            AGENCY ACTION
     4862-2357-8321, v. 1
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 1

 2

 3

 4

 5

 6

 7

 8

 9
10

11

12

13

14

15            Id. at p. 3554)], yet issued SAW its first FLRD, which does not reference this alleged

16            ineligibility reason. [Ex. S]. This was also included in the administrative record in Gold

17            Club’s appeal of SBA’s denial of its first draw Loan forgiveness application. [Ex. XX]. It was

18            only after SAW appealed that FLRD in the OHA and SBA withdrew that FLRD dis SBA

19            issue the second FLRD, which raised, for the first time, SAW’s alleged ineligibility based on

20            the Prurience Regulation. This scheme was designed to cause SAW to unnecessarily incur

21            significant professional fees when SBA knew the present reason for its denial of SAW’s

22            forgiveness request all a long; and

23                     j.    The fact that, after losing the Meacham appeal based on, among other things,

24            a lack of evidence to support the FLRD’s conclusion in the administrative record, SBA,

25            having included the same type of evidence in the administrative record of SAW that it had

26            included and was forced to rely upon in Meacham’s OHA appeal, withdrew the FLRD that

27            SAW was appealing because it could not support the conclusions in SAWs FLRD. This

28
                                               133                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC          Document 18        Filed 10/10/24     Page 134 of 169



 1            scheme, combined with the fact that multiple courts have enjoined the use of the Prurience

 2            Regulation as eligibility criteria for first draw PPP Loans, was designed to cause SAW to

 3            unnecessarily incur significant professional fees.

 4            656.     The causal link between these Plaintiffs’ protected First Amendment conduct, as

 5   described herein, is evidenced by, among other things detailed herein, the scope of the Affiliation

 6   Narrative Worksheet Mohney et al #127 appearing in nearly every administrative record the

 7   undersigned firm has reviewed, the actions of the SBA to claw back various RRF grants by applying

 8   standards it waived via a settlement agreement, and Benderson’s comments in the aforementioned

 9   Zoom call directed at any of the undersigned firm’s clients that present constitutionally protected live

10   female performance dance entertainment such as these Plaintiffs.

11            657.     As a direct and proximate result of the retaliatory actions of Defendants based on

12   these Plaintiffs’ First Amendment protected activities, as well as Defendants’, and their delegates’,

13   application and enforcement of the Prurience Regulation, the Incorporating Statute, and the

14   Affiliation Rules against the affected Plaintiffs and their interests, all as referenced above, the

15   affected Plaintiffs, as well as their owners and employees, the entertainers who perform on their

16   premises and the customers who frequent their establishments, have suffered, and/or will suffer,

17   and/or will continue to suffer irreparable injuries including but not limited to financial collapse,

18   business ruination, and/or the inability to present, view, and/or engage in First Amendment-protected

19   speech, expression, and entertainment.

20            658.     Because of the First Amendment rights being infringed upon by Defendants

21   retaliatory actions as discussed herein, this Court has the authority to declare the rights and legality

22   of the actions of the various parties and should do so here. It should also permanently enjoin

23   enforcement by the SBA of the Prurience Regulation, the Incorporating Statute, and the Affiliation

24   Rules as they apply to the PPP, against the affected Plaintiffs.

25            659.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

26   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

27   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

28
                                               134                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18         Filed 10/10/24      Page 135 of 169



 1   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

 2   enforcement of the Prurience Regulation, the Incorporating Statute, and the Affiliation Rules,

 3   because the Defendants will not suffer any harm whatsoever by the entry of a preliminary injunction,

 4   and because the balance of harms tilts in favor of the Plaintiffs and against the Defendants, this Court

 5   should enter a preliminary injunction in order to protect Plaintiffs’ fundamental rights at issue here.

 6            660.      For the reasons set forth above, Plaintiffs are entitled to judicial review in regard to

 7   the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

 8                                                   COUNT VI

 9         THE SBA’S APPLICATION OF THE AFFILIATION EXCEPTION PROVISIONS
                           VIOLATES THE FIFTH AMENDMENT
10

11            661.      Plaintiffs incorporate herein by reference each and every paragraph above as though

12   fully set forth herein.

13            662.      The way that the SBA is applying and enforcing the Affiliation Exception Provisions,

14   and in particular in regard to businesses engaged in expression protected by the First Amendment,

15   violates, and is contrary to, the Fifth Amendment to the United States Constitution for numerous and

16   various reasons, including but not limited to:

17                      a.     It is an arbitrary and capricious construction and application of the Affiliation

18            Exception Provisions;

19                      b.     It is directly contrary to the plain text of the Affiliation Exception Provisions;

20                      c.     It is being applied in such a manner for vindictive, retaliatory, harassing and

21            discriminatory purposes;

22                      d.     The SBA has no lawful authority to reject, or to change, a self-assigned

23            NAICS code of a PPP loan applicant or recipient that otherwise lawfully applies to such

24            entity;

25                      e.     There is no basis in law for the SBA to challenge a legally licensed bar, tavern,

26            and/or nightclub as a NAICS code 72 business based upon an undefined and unarticulated

27            standard of differing income streams;

28
                                               135                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1                     f.     It permits the SBA to demand—as a condition for Loan forgiveness—that an

 2            applicant produce information held by others that it has no lawful way of obtaining;

 3                     g.     It violates the occupational liberty rights of the affected Plaintiffs, their

 4            employees, and the entertainers who perform on their premises;

 5                     h.     It violates the substantive and procedural Due Process rights of the affected

 6            Plaintiffs, their employees, and the entertainers who perform on their premises;

 7                     i.     It denies, for the reasons set forth in detail above, the affected Plaintiffs of

 8            equal protection under the laws of the United States of America, particularly with regard to

 9            other NAICS code 72 businesses that do not provide or present forms of entertainment that

10            are disagreeable to the SBA or to its officials;

11                     j.     Upon information and belief, the SBA is not applying or interpreting the

12            Affiliation Exception Provisions in such a manner or fashion except for businesses that

13            present entertainment that the SBA or its officials find to be disagreeable, or are businesses

14            that the SBA asserts, believes, or claims to be “affiliated” with any of the Plaintiffs;

15                     k.     It has been used to deny Plaintiffs forgiveness of PPP loans to which they are

16            entitled and is thereby being used to take Plaintiff’s protected property interest in loan

17            forgiveness;

18                     l.     It treats, has been used to treat, and could continue to treat in the future,

19            similarly situated persons and businesses differently without justification.

20            663.     As a direct and proximate result of the unconstitutional aspects of the SBA’s

21   application of the Affiliation Exception Provisions, all as referenced above, the affected Plaintiffs, as

22   well as their owners and employees, the entertainers who perform on their premises and the

23   customers who frequent their establishments, have suffered, and/or will suffer, and/or will continue

24   to suffer irreparable injuries including but not limited to financial collapse, business ruination, and/or

25   the inability to present, view, and/or engage in First Amendment-protected speech, expression, and

26   entertainment.

27            664.     Because Plaintiffs’ Fifth Amendment rights have been infringed upon by Defendants’

28
                                               136                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24       Page 137 of 169



 1   application of the Affiliation Exception Provisions, all as referenced above, this Court has the

 2   authority to declare the rights and the legality of actions of the various parties and should do so here.

 3            665.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

 4   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

 5   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

 6   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin the

 7   Defendants’ application of the Affiliation Exception Provisions, because the Defendants will not

 8   suffer any harm whatsoever by the entry of a preliminary injunction, and because the balance of

 9   harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter a preliminary

10   injunction in order to protect Plaintiffs’ fundamental rights at issue here.

11            666.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

12   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

13                                                  COUNT VII

14        THE SBA’S INTERPRETATION(S) AND APPLICATIONS OF THE AFFILIATION
                         EXCEPTION PROVISIONS ARE INVALID
15

16            667.     Plaintiffs incorporate herein by reference each and every paragraph above as though

17   fully set forth herein.

18            668.     The SBA and/or the Administrator’s application and enforcement of the Affiliation

19   Exception Provisions is not a legitimate or lawful exercise of the SBA’s or its Administrator’s

20   authority, and is otherwise invalid under the Administrative Procedures Act, 5 U.S.C. § 551 et seq.

21   and applicable law because, among other reasons:

22                     a.      Such construction is inconsistent with the plain text of the Affiliation

23            Exception Provisions;

24                     b.      Such construction is not a reasonable interpretation of the Affiliation

25            Exception Provisions;

26                     c.      Such construction is arbitrary, capricious, an abuse of discretion in light of,

27            and is directly contrary to, the PPP and in particular the plain text of the Affiliation Exception

28
                                               137                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 138 of 169



 1            Provisions;

 2                     d.      Such construction is inconsistent with Congress’s goals under the CARES Act

 3            and the Appropriations Act; and

 4                     e.      Such construction and application to Plaintiffs runs contrary to the evidence

 5            before the SBA, namely, that Plaintiffs are NAICS 72 businesses such that they qualify for

 6            Affiliation exception Provisions.

 7            669.     Because the SBA’s and/or the Administrator’s application of the Affiliation Exception

 8   Provisions is inconsistent with the SBA Act, as well as the broad form of relief provided by the

 9   CARES Act and the Appropriations Act, all as referenced above, this Court has the authority to

10   declare the rights and the legality of actions of the various parties and should do so here.

11            670.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

12   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

13   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

14   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

15   enforcement of the SBA’s application of the Affiliation Exception Provisions, because the

16   Defendants will not suffer any harm whatsoever by the entry of a preliminary injunction, and because

17   the balance of harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter

18   a preliminary injunction in order to protect Plaintiffs’ fundamental rights at issue here.

19            671.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

20   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

21                                                 COUNT VIII

22        OTHER INVALIDITY OF THE WAY THE SBA IS APPLYING THE AFFILIATION
                              EXCEPTION PROVISIONS
23

24            672.     Plaintiffs incorporate herein by reference each and every paragraph above as though

25   fully set forth herein.

26            673.     The SBA’s and the Administrator’s application and enforcement of the Affiliation

27   Exception Provisions are not legitimate or lawful exercises of the SBA’s or the Administrator’s

28
                                               138                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   authority as applied to first and second draw PPP loans, and are otherwise invalid under the

 2   Administrative Procedure, 5 U.S.C. § 551 et seq. and applicable law because, among other reasons:

 3                     a.     There has been no formal ruling making whatsoever that would permit the

 4            SBA and the Administrator to create their own construct of the Affiliation Exception

 5            Provisions, especially one that runs counter to the clear text of the statute, and these matters

 6            are not left to SBA discretion;

 7                     b.     They fail to serve any lawful or legitimate regulatory purpose for the SBA or

 8            the Administrator as to first and second Draw PPP loans or otherwise;

 9                     c.     The SBA and/or the Administrator failed to make a sufficient record, or to

10            otherwise articulate a satisfactory explanation, as to why their application and enforcement

11            of the Affiliation Exception Provisions are rational or reasonable responses to a problem that

12            the agency was charged with solving under the CARES Act or the Appropriations Act, and in

13            particular the first and second Draw PPP loans; and

14                     d.     The SBA and/or the Administrator failed to make a sufficient record or

15            examine relevant evidence before it at the time it made its decision to deny Plaintiffs PPP

16            Loan forgiveness requests such that SBA’s FLRDs are not the product of reasoned decision-

17            making.

18            674.     Because the SBA’s and the Administrator’s application and enforcement of the

19   Affiliation Exception Provisions are inconsistent with the SBA Act, as well as the broad form of

20   relief provided by the CARES Act and the Appropriations Act, all as referenced above, because they

21   do not, again as applied by the SBA and/or the Administrator, represent a rational and reasonable

22   response to a problem that the agency was charged with solving, and because the SBA’s decisions

23   with regard to Plaintiffs’ PPP Loan forgiveness requests failed to examine relevant evidence and

24   otherwise fails to explain its decision, this Court has the authority to declare the rights and the legality

25   of actions of the various parties and should do so here.

26            675.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

27   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

28
                                               139                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 140 of 169



 1   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

 2   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

 3   enforcement of the SBA’s application of the Affiliation Exception Provisions, because the

 4   Defendants will not suffer any harm whatsoever by the entry of a preliminary injunction, and because

 5   the balance of harms tilts in favor of the Plaintiffs and against the Defendants, this Court should enter

 6   a preliminary injunction in order to protect Plaintiffs’ fundamental rights at issue here.

 7            676.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

 8   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

 9                                                  COUNT IX

10                    IN THE ALTERNATIVE, THE AFFILIATION RULES VIOLATE
                                    THE FIFTH AMENDMENT
11

12            677.     Plaintiffs incorporate herein by reference each and every paragraph above as though

13   fully set forth herein.

14            678.     In the alternative to invalidating the manner and way that the SBA is interpreting and

15   applying the Affiliation Exception Provisions, Plaintiffs assert this Count IX and Counts X - XI

16   immediately below.

17            679.     The Affiliation Rules violate, and are contrary to, the Fifth Amendment to the United

18   States Constitution, both on their face and particularly as applied by the SBA to Plaintiffs, for

19   numerous and various reasons, including but not limited to:

20                     a.      They are unconstitutionally vague on their face and as applied by the SBA,

21            particularly when applied to First Amendment protected businesses as a result of the

22            enhanced vagueness standards that are imposed upon laws that impact upon speech and

23            expression-related activities, because: 1) they do not provide standards that can be readily

24            understood by persons of common intelligence; 2) as exemplified by the circumstances here

25            and in particular light of the provisions of 13 C.F.R. § 121.103(a)(5), they do not provide

26            clear guidance to governmental officials so that no ad hoc, arbitrary, or discriminatory

27            enforcement decisions are made;

28
                                               140                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1                     b.     They treat similar businesses differently for no compelling, important, or

 2            rational reason;

 3                     c.     They permit the SBA to demand—as a condition for Loan forgiveness—that

 4            an applicant produce information held by others that it has no lawful way of obtaining;

 5                     d.     They violate the occupational liberty rights of the affected Plaintiffs, their

 6            employees, and the entertainers who perform on their premises;

 7                     e.     They violate the substantive and procedural Due Process rights of the affected

 8            Plaintiffs, their employees, and the entertainers who perform on their premises;

 9                     f.     They treat, have been used to treat, and could continue to treat in the future,

10            similarly situated persons and businesses differently without justification;

11                     g.     They deny, for the reasons set forth in detail above, the affected Plaintiffs of

12            equal protection under the laws of the United States of America; and

13                     h.     They are being arbitrarily and capriciously applied by the Defendants.

14            680.     As a direct and proximate result of the unconstitutional aspects of the Affiliation

15   Rules, as well as the Defendants’, and their delegates’, application of them against the affected

16   Plaintiffs and their interests, all as referenced above, the affected Plaintiffs, as well as their owners

17   and employees, the entertainers who perform on their premises and the customers who frequent their

18   establishments, have suffered, and/or will suffer, and/or will continue to suffer irreparable injuries

19   including but not limited to financial collapse, business ruination, and/or the inability to present,

20   view, and/or engage in First Amendment-protected speech, expression, and entertainment.

21            681.     Because of the Fifth Amendment rights being infringed upon by Defendants’

22   application of the Affiliation Rules, all as referenced above, this Court has the authority to declare

23   the rights and the legality of actions of the various parties and should do so here.

24            682.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

25   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

26   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

27   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

28
                                               141                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC            Document 18       Filed 10/10/24      Page 142 of 169



 1   enforcement of the Affiliation Rules, because the Defendants will not suffer any harm whatsoever

 2   by the entry of a preliminary injunction, and because the balance of harms tilts in favor of the

 3   Plaintiffs and against the Defendants, this Court should enter a preliminary injunction in order to

 4   protect Plaintiffs’ fundamental rights at issue here.

 5            683.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

 6   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

 7                                                   COUNT X

 8        THE SBA’S INTERPRETATION(S) OF THE AFFILIATION RULES ARE INVALID
 9
              684.     Plaintiffs incorporate herein by reference each and every paragraph above as though
10
     fully set forth herein.
11
              685.     The SBA and/or the Administrator’s interpretation and/or application of the
12
     Affiliation Rules is not a legitimate or lawful exercise of the SBA’s or its Administrator’s authority,
13
     and is otherwise invalid under the Administrative Procedures Act, 5 U.S.C. § 551 et seq. and
14
     applicable law because, among other reasons:
15
                       a.      Such interpretation and/or application is inconsistent with the SBA Act and its
16
              purposes;
17
                       b.      Such interpretation and/or application is not a reasonable in light of the
18
              purpose and intent of the SBA Act;
19
                       c.      Such interpretation and/or application is arbitrary, capricious, an abuse of
20
              discretion in light of, and is directly contrary to, the SBA Act; and
21
                       d.      Such interpretation and/or application is inconsistent with Congress’s goals
22
              under the CARES Act and the Appropriations Act.
23
              686.     Because, as applied by the SBA and/or the Administrator, the Affiliation Rules are
24
     inconsistent with the SBA Act, as well as the broad form of relief provided by the CARES Act and
25
     the Appropriations Act, all as referenced above, this Court has the authority to declare the rights and
26
     the legality of actions of the various parties and should do so here.
27
              687.     Plaintiffs do not have adequate remedies at law because, among other reasons, they
28
                                               142                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

 2   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

 3   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

 4   enforcement of the Affiliation Rules, because the Defendants will not suffer any harm whatsoever

 5   by the entry of a preliminary injunction, and because the balance of harms tilts in favor of the

 6   Plaintiffs and against the Defendants, this Court should enter a preliminary injunction in order to

 7   protect Plaintiffs’ fundamental rights at issue here.

 8            688.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

 9   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

10                                                  COUNT XI

11                          OTHER INVALIDITY OF THE AFFILIATION RULES
12
              689.     Plaintiffs incorporate herein by reference each and every paragraph above as though
13
     fully set forth herein.
14
              690.     The Affiliation Rules are not a legitimate or lawful exercise of the SBA’s or the
15
     Administrator’s authority under the SBA Act because, among other reasons:
16
                       a.      They are contrary to the very purpose and intent of the SBA Act;
17
                       b.      They fail to serve any lawful or legitimate regulatory purpose for the SBA or
18
              the Administrator under the SBA Act;
19
                       c.      They fail to acknowledge and give respect to corporate formalities otherwise
20
              legally enforceable;
21
                       d.      The SBA and/or the Administrator failed to make a sufficient record, or to
22
              otherwise articulate a satisfactory explanation, as to why the Affiliation Rules are a rational
23
              or reasonable response to a problem that the agency was charged with solving under the SBA
24
              Act; and
25
                       e.      The SBA and/or the Administrator failed to make a sufficient record or
26
              otherwise examine relevant data to establish that the Affiliation rules are a rational or
27
              reasonable response to a problem that the agency was charged with solving.
28
                                               143                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1            691.      Because the Affiliation Rules, as applied by the SBA and/or the Administrator, are

 2   inconsistent with the SBA Act, as well as the broad form of relief provided by the CARES Act and

 3   the Appropriations Act, all as referenced above, and because they do not, again as applied by the

 4   SBA and/or the Administrator, represent a rational and reasonable response to a problem that the

 5   agency was charged with solving, this Court has the authority to declare the rights and the legality

 6   of actions of the various parties and should do so here.

 7            692.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

 8   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

 9   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

10   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

11   enforcement of the Affiliation Rules, because the Defendants will not suffer any harm whatsoever

12   by the entry of a preliminary injunction, and because the balance of harms tilts in favor of the

13   Plaintiffs and against the Defendants, this Court should enter a preliminary injunction in order to

14   protect Plaintiffs’ fundamental rights at issue here.

15            693.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

16   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

17                                                 COUNT XII

18                   THE SPECIAL OHA RULES VIOLATE THE FIFTH AMENDMENT
19
              694.     Plaintiffs incorporate herein by reference each and every paragraph above as though
20
     fully set forth herein.
21
              695.     The Special OHA Rules violate, and are contrary to, the Fifth Amendment to the
22
     United States Constitution, both on their face and particularly as applied by the SBA to Plaintiffs, for
23
     numerous and various reasons, including but not limited to:
24
                       a.      They deny both substantive and procedural due process in that, among other
25
              ways, they:
26
                               i.     Provide for no form of hearing whatsoever;
27
                               ii.    Preclude any form of discovery whatsoever, including discovery that
28
                                               144                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1                     may be essential to the later adjudication of the appellant’s claims in court following

 2                     conclusion of the administrative appeal proceedings;

 3                             iii.    Preclude the submission by the appellant of any documents, material,

 4                     or information that is not included in the formal “administrative record” created solely

 5                     by the SBA, while, seemingly, permitting SBA to submit documents, material, or

 6                     information that is not included in the formal “administrative record,” as evidenced

 7                     by SBA’s responses to the OHA appeals of Meacham and Gold Club;

 8                             iv.     Do not permit the appellant to meaningfully participate in the creation

 9                     of the formal “administrative record” upon which the administrative appeal is to be

10                     solely based;

11                             v.      Do not provide sufficient time frames as a matter of right for the

12                     appellant to respond to and filed objections concerning the formal “administrative

13                     record” created solely by the SBA;

14                             vi.     Do not permit the appellant any ability whatsoever to confront or

15                     challenge the evidence that the SBA purports to possess against it;

16                             vii.    Require the appellant to file its substantive “appeal brief” before it has

17                     been provided with the “administrative record” purportedly created by the SBA as the

18                     basis of rendering its adverse decision against the appellant;

19                             viii.   Permit the SBA to produce such heavily redacted “administrative

20                     records” that it is virtually impossible for the appellant to understand the full basis for

21                     the SBA’s decision or, more importantly, to either file adequate objections to such

22                     “record” or to be able to seek leave to be able to respond to the contentions as

23                     contained in the purported “administrative record”;

24                             ix.     Permit SBA to broadly assert claims of privilege without an avenue

25                     for appellant to challenge such claims and without explanation of the claim of

26                     privilege, see Ex. N, at p. 4 (SBA claiming the redactions in the administrative record

27                     “are not relevant and require no explanation or claims of privilege”);

28
                                               145                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1                            x.      Provide no right of the appellant to file a “merits” or “reply” brief once

 2                     it has been provided with the “administrative record” purportedly created by the SBA

 3                     as the basis of rendering its adverse decision against the appellant;

 4                            xi.     Permit SBA to, apparently, withdraw an FLRD for any reason or no

 5                     reason at all, thereby needlessly increasing the costs of an OHA appeal, which is

 6                     contrary to the purposes of the PPP;

 7                            xii.    Are not applied consistently by the OHA and the personnel who act as

 8                     adjudicators; and

 9                            xiii.   As applied by the OHA, provide no substantive protections for the

10                     appellant whatsoever, including even requiring that the OHA follow its own Special

11                     OHA Rules when to do so might be to the advantage of the appellant;

12                     b.     They violate the occupational liberty rights of the affected Plaintiffs, their

13            employees, and the entertainers who perform on their premises;

14                     c.     In contrast to the OHA appellate rules that apply to all other forms of appeals

15            from SBA decisions, they treat, have been used to treat, and could continue to treat in the

16            future, similarly situated persons and businesses differently without justification;

17                     d.     They deny, for the reasons set forth in detail above, the affected Plaintiffs of

18            equal protection under the laws of the United States of America;

19                     e.     They are being arbitrarily and capriciously applied by the Defendants; and

20                     f.     They are impermissibly vague on their face and as applied to these Plaintiffs

21            for the reasons discussed above.

22            696.     As a direct and proximate result of the unconstitutional aspects of the Special OHA

23   Rules, as well as the Defendants’, and their delegates’, application of them against the affected

24   Plaintiffs and their interests, all as referenced above, the affected Plaintiffs, as well as their owners

25   and employees, the entertainers who perform on their premises and the customers who frequent their

26   establishments, have suffered, and/or will suffer, and/or will continue to suffer irreparable injuries

27   including but not limited to financial collapse, business ruination, the inability to present, view,

28
                                               146                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   and/or engage in First Amendment-protected speech, expression, and entertainment, and the denial

 2   of their due process rights.

 3            697.     Because of the Fifth Amendment rights being infringed upon by Defendants’

 4   application and enforcement of the Special OHA Rules, all as referenced above, this Court has the

 5   authority to declare the rights and the legality of actions of the various parties and should do so here.

 6            698.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

 7   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

 8   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to their claims

 9   asserted herein, because Plaintiffs will be suffer irreparable injury if this Court does not enjoin

10   enforcement of the Special OHA Rules, because the Defendants will not suffer any harm whatsoever

11   by the entry of a preliminary injunction, and because the balance of harms tilts in favor of the

12   Plaintiffs and against the Defendants, this Court should enter a preliminary injunction in order to

13   protect Plaintiffs’ fundamental rights at issue here.

14            699.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

15   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

16                                                 COUNT XIII

17                          OTHER INVALIDITY OF THE SPECIAL OHA RULES
18
              700.     Plaintiffs incorporate herein by reference each and every paragraph above as though
19
     fully set forth herein.
20
              701.     The Special OHA Rules are not a legitimate or lawful exercise of the SBA’s or the
21
     Administrator’s authority as applied to first and second draw PPP loans, and are otherwise invalid
22
     under the Administrative Procedure, 5 U.S.C. § 551 et seq. and applicable law because, among other
23
     reasons:
24
                       a.      They fail to serve any lawful or legitimate regulatory purpose for the SBA or
25
              the Administrator as to first and second Draw PPP loans or otherwise;
26
                       b.      For the reasons set forth in the previous Count, they are contrary to
27
              constitutional rights and privileges;
28
                                               147                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1                     c.      For the reasons set forth in the previous Count, they fail to provide adequate

 2            procedure; and

 3                     d.      The SBA and/or the Administrator failed to make a sufficient record, or to

 4            otherwise articulate a satisfactory explanation, as to why the Special OHA Rules are a rational

 5            or reasonable response to a problem that the agency was charged with solving under the

 6            CARES Act or the Appropriations Act, and in particular the first and second Draw PPP loans.

 7            702.     Because Special OHA Rules are inconsistent with the SBA Act, as well as the broad

 8   form of relief provided by the CARES Act and the Appropriations Act, all as referenced above, and

 9   because they do not represent a rational and reasonable response to a problem that the agency was

10   charged with solving, this Court has the authority to declare the rights and the legality of actions of

11   the various parties and should do so here.

12            703.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

13   cannot recover damages against the Defendants as a result of sovereign immunity and because

14   resolution of their claims in court may be constrained by the OHA proceedings undertaken pursuant

15   to and informed by the Special OHA Rules. Because of the same, because Plaintiffs have a reasonable

16   likelihood of success on the merits in regard to their claims asserted herein, because Plaintiffs will

17   be suffer irreparable injury if this Court does not enjoin enforcement of Special OHA Rules, because

18   the Defendants will not suffer any harm whatsoever by the entry of a preliminary injunction, and

19   because the balance of harms tilts in favor of the Plaintiffs and against the Defendants, this Court

20   should enter a preliminary injunction in order to protect Plaintiffs’ fundamental rights at issue here.

21            704.     For the reasons set forth above, Plaintiffs are entitled to judicial review with regard

22   to the actions and inactions of the Defendants pursuant to 5 U.S.C. § 702.

23                                                   COUNT XIV

24                                                    ESTOPPEL
25
              705.     Plaintiffs incorporate herein by reference each and every paragraph above as though
26
     fully set forth herein.
27
              706.     Through the PPP, the regulations promulgated thereto, other documents issued and/or
28
                                               148                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   distributed by the SBA, and the loan Documents, the SBA itself and through its Lending Banks

 2   created a system of representations and promises to borrowers establishing that if borrowers

 3   (including each one of these Plaintiffs), during certain critical periods of the Pandemic, retained their

 4   employees so that they would not be required to avail themselves of other governmental assistance

 5   programs such as welfare and unemployment compensation and otherwise used Loan Proceeds only

 6   for the Permitted Uses, their Loans would be forgiven (collectively the “Promises”).

 7            707.     The Promises are definite and of definite terms, which the SBA would expect the

 8   Plaintiffs to rely on.

 9            708.     The Promises reasonably induced reliance thereon by the Plaintiffs.

10            709.     The Plaintiffs relied on the Promises of Loan forgiveness to their detriment, and no

11   longer possess any of the Loan Proceeds; having used the amounts sought via Plaintiffs’ PPP Loan

12   forgiveness applications exclusively for the Permitted Uses.

13            710.     For each of the Plaintiffs, the Defendants had actual, or at least constructive

14   knowledge, of the facts relating to the eligibility or ineligibility of the Plaintiffs for their Loans at the

15   time of the granting of such Loans and the disbursement of the Loan Proceeds, and, for those

16   Plaintiffs that received forgiveness of their Loans, actual, or at least constructive knowledge, of the

17   eligibility of such Plaintiffs for Loan forgiveness at the time their Loans were forgiven.

18            711.     Regardless of the matters set forth in the paragraph immediately above, the

19   Defendants, at no time prior to the issuance of the Loans and, for those Plaintiffs that received Loan

20   forgiveness, prior to the forgiving of such Loans, disclosed, and in fact concealed, the material fact

21   that the SBA would contend that the Plaintiffs were ineligible for such Loans and/or for forgiveness

22   thereof.

23            712.     The concealment by the Defendants of the material facts as referenced in the two

24   paragraphs immediately above was done with the intention that the Plaintiffs would nevertheless

25   utilize the Loan Proceeds for the Permitted Uses, retain their staffs thereby, ensure, as a result thereof,

26   that the Plaintiffs’ employees would not be required to seek other forms of governmental financial

27   assistance as a result of Pandemic-related closures, and otherwise abide by the requirements of the

28
                                               149                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1   PPP.

 2            713.     At no time prior to the developments leading to the filing of this action did the

 3   Plaintiffs know, or have had the means of knowing, that the Defendants would seek to deny Loan

 4   forgiveness and for those Plaintiffs that obtained forgiveness of their Loans reverse such decisions

 5   and seek repayment of such Loan Proceeds.

 6            714.     As a result of the above, Plaintiffs detrimentally relied upon the actions, inactions,

 7   representations, and concealments of the Defendants by obtaining the Loan Proceeds, using the

 8   portions to which they seek forgiveness of exclusively for the Permitted Uses, and otherwise abiding

 9   by the terms of the PPP.

10            715.     For the reasons set forth above, Defendants should be estopped from denying Loan

11   eligibility and Loan forgiveness of the Plaintiffs’ PPP Loans at issue.

12                                                   COUNT XV

13                                       ATTORNEYS’ FEES AND COSTS
14
              716.     Plaintiffs incorporate herein by reference each and every paragraph above as though
15
     fully set forth herein.
16
              717.     For all of the reasons set forth above, the positions of the SBA in taking the actions
17
     as detailed herein were not substantially justified.
18
              718.     There are no special circumstances that make an award of fees and other expenses in
19
     favor of the Plaintiffs and against the Defendants unjust.
20
              719.     For the reasons set forth above, Plaintiffs are entitled to an award of attorneys’ fees
21
     and costs against the Defendants pursuant to the Equal Access to Justice Act, 28 U.S.C. § 2412, to 5
22
     U.S.C.§ 504, and as otherwise permitted by law.
23
                                                     COUNT XVI
24
                             15 U.S.C. § 634(b)(1) VIOLATES THE CONSTITUTION
25
              720.     Plaintiffs incorporate herein by reference each and every paragraph above as though
26
     fully set forth herein.
27

28
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        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
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 1            721.     15 U.S.C. § 634(b)(1) states that

 2            In the performance of, and with respect to, the functions, powers, and duties vested
              in him by this chapter, the Administrator may—(1) sue and be sued in any court of
 3            record of a State having general jurisdiction, or in any United States district court, and
              jurisdiction is conferred upon such district court to determine such controversies
 4            without regard to the amount in controversy; but no attachment, injunction,
              garnishment, or other similar process, mesne or final, shall be issued against the
 5            Administrator or his property[.]

 6   (emphasis added—the italicized portion is hereafter referred to as the “Injunction Provision”).

 7            722.     While Plaintiffs do not know how this Court will interpret the Injunction Provision or

 8   whether it will be called upon to do so in this case, some courts, for example, In re Hidalgo Cnty.

 9   Emergency Serv. Found., 962 F.3d 838 (5th Cir. 2020), have held that this Injunction Provision

10   operates as an absolute bar to the issuance of any injunction against the SBA, while the majority of

11   courts have held that the Injunction Provision does not operate as an absolute bar to the issuance of

12   injunctive relief against the SBA.

13            723.     As applied by the courts that have held this provision to be an absolute bar to the

14   issuance of any injunction against the SBA, the Injunction Provision is violative of the First and Fifth

15   Amendment for numerous and various reasons including but not limited to:

16                     a.     Courts have not been applying this evenhandedly; indeed, the Southern

17            District of Texas issued an injunction against the SBA in D. Houston v. SBA, 579 F. Supp.

18            3d 959, 970-71 (S.D. Tex. 2020), as did the Eastern District of Michigan in DV Diamond,

19            and the Eastern District of Wisconsin in Camelot Banquet Rooms, Inc. v. U.S. Small Bus.

20            Admin., 458 F. Supp. 3d 1044 (E.D. Wis. 2020), and the District of Alaska in Alaska

21            Urological Inst., P.C. v. U.S. Small Bus. Admin., 619 B.R. 689 (D. Alaska 2020). In response

22            to the government’s argument that the Injunction Provision operates as an absolute bar, the

23            Central District of California disagreed and stated that “when the Administrator acts beyond

24            the scope of his authority, 15 U.S.C. § 634(b) does not preclude injunctive action,” Dubrow

25            v. Small Bus. Admin., 345 F. Supp. 4, 7 (C.D. Cal. 1972);

26                     b.     As noted by District Court Judges Adelman and Leitman in Camelot Banquet

27            Rooms, Inc. v. SBA, 458 F. Supp. 3d 1044, 1052 (E.D. Wis. 2020) and DV Diamond Club of

28
                                               151                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
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 1            Flint, LLC, 459 F. Supp. 3d 943, 952-54 (E.D. Mich. 2020), as interpreted by the those courts

 2            holding that 15 U.S.C. § 634(b)(1) is an absolute bar to injunctive relief against SBA, SBA

 3            could adopt unconstitutional policies and continue to follow them even after a court declared

 4            them unconstitutional;

 5                     c.     It permits the SBA to act unconstitutionally and renders the courts powerless

 6            to stop the SBA;

 7                     d.     It permits the SBA to continue to engage in the unconstitutional and illegal

 8            conduct described herein indefinitely; and

 9                     e.     It prevents recourse against the SBA for the SBA’s infringement of Plaintiff’s

10            First and Fifth Amendment rights as outlined herein because it prevents courts from enjoining

11            SBA’s actions and Plaintiffs are prevented under Sovereign Immunity from obtaining

12            damages from the SBA.

13            724.     As a direct and proximate result of the unconstitutional nature of the Injunction

14   Provision, as referenced herein, Plaintiffs, as well as their owners and employees, the entertainers

15   who perform on their premises and the customers who frequent their establishments, have suffered,

16   and/or will suffer, and/or will continue to suffer irreparable injuries including but not limited to

17   financial collapse, business ruination, and/or the inability to present, view, and/or engage in First

18   Amendment-protected speech, expression, and entertainment.

19            725.     Because of the fundamental rights being infringed upon by Defendants as referenced

20   herein, this Court has the authority to declare the rights and legal actions of the various parties and

21   should do so here.

22            726.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

23   cannot recover damages against the Defendants as a result of sovereign immunity. Because of the

24   same, because Plaintiffs have a reasonable likelihood of success on the merits in regard to the claims

25   asserted herein, because Plaintiffs will suffer irreparable injury if the Court does not enjoin

26   enforcement of the regulations and statutes as noted herein, particularly the Prurience Regulation and

27   Incorporating Statute, because Defendants will not suffer any harm whatsoever by the entry of a

28
                                               152                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 153 of 169



 1   preliminary injunction as requested herein, particularly because Plaintiffs do not seek to attach the

 2   SBA’s assets or otherwise interfere with its internal operations, and because the balance of harms

 3   tilts in favor of Plaintiffs and against Defendants, this Court should enter a preliminary injunction

 4   enjoining the use of the Injunction Provision as an absolute bar to injunctions against the SBA, in

 5   order to protect Plaintiffs’ fundamental rights at issue here.

 6                                                  COUNT XVII

 7         JUDICIAL REVIEW OF THE MAY 14 ORDER AND UNDERLYING FLRD / OTHER
                  INVALIDITY OF THE MAY 14 ORDER AND UNDERLYING FLRD
 8

 9            727.     Plaintiffs incorporate herein by reference each and every paragraph above as though

10   fully set forth herein.

11            728.     Under 5 U.S.C. § 706, this Court must hold unlawful and set aside agency action

12   found not to be in accordance with the law.

13            729.     For the reasons set forth herein, including but not limited to, the invalidity of the

14   Prurience Regulation and the lack of due process caused by the Special OHA Rules and SBA’s

15   Decision, the May 14 Order is not in accordance with the law.

16            730.     Under 5 U.S.C. § 706, this Court must compel agency action unlawfully withheld.

17            731.     In denying forgiveness of Gold Club’s second draw PPP Loan on the bases provided

18   by SBA and affirmed by the May 14 Order, in addition to the reasons set forth in Gold Club’s

19   underlying OHA Appeal of the Second FLRD, all of which are incorporated by reference as though

20   fully set forth herein, SBA has unlawfully withheld agency action—forgiveness of the portions of

21   Gold Club’s second draw PPP Loan that it applied for forgiveness of—required by law, including 15

22   U.S.C. § 636m(b); 15 U.S.C. § 636(a)(37)(j)(ii-iii); 85 Fed. Reg. 20811, 20814-15; and 86 Fed. Reg.

23   3712, 3722.

24            732.     The May 14 Order is arbitrary and capricious, in excess of statutory jurisdiction and

25   authority, unwarranted by the facts upon which it is based, and contrary to Gold Club’s constitutional

26   rights for numerous and various reasons set forth herein and in the preceding Counts as well as those

27   reasons set forth in Gold Club’s OHA Appeal of the Second FLRD, which are incorporated by

28
                                               153                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24     Page 154 of 169



 1   reference as though fully set forth herein.

 2            733.     Gold Club seeks judicial review pursuant to the Administrative Procedures Act, 5

 3   U.S.C. § 701, et seq., of any and all decisions, including the May 14 Order and the Second FLRD,

 4   issued by SBA and OHA so reviewable on issues so reviewable.

 5            734.     As a result of the Second FLRD issued by SBA and OHA’s May 14 Order affirming

 6   the same, Gold Club risks legal consequences including, but not limited to, accusations of making

 7   false statements on its PPP loan application and forgiveness application paperwork.

 8            735.     For these reasons and those set forth elsewhere herein, Gold Club is entitled to a

 9   reversal of SBA’s Second FLRD regarding Gold Club’s second draw PPP Loan and OHA’s May 14

10   Order affirming that FLRD, and in their place, an order granting forgiveness of Gold Club’s second

11   draw PPP Loan in the amount of $1,993,233.75.

12                                                 COUNT XVIII

13                                            INJUNCTIVE RELIEF

14            736.     Plaintiffs incorporate herein by reference each and every paragraph above as though

15   fully set forth herein.

16            737.     A PPP Loan recipient’s obligation to make payments on the Loan is deferred during

17   OHA proceedings.

18            738.     “Borrowers can apply for forgiveness at any time up to five years form the date that

19   SBA issued the SBA loan number,” and “[i]f [PPP] borrowers do not apply for forgiveness within 10

20   months after the last day of the covered period, then PPP loan payments are no longer deferred, and

21   borrowers will begin making loan repayments to their PPP lender.” https://www.sba.gov/funding-

22   programs/loans/covid-19-relief-options/paycheck-protection-program/ppp-loan-forgiveness          (last

23   visited Oct. 9, 2024).

24            739.     Because Gold Club no longer has a pending OHA appeal regarding its second draw

25   PPP Loan, it is obligated to make and has begun making payments on this Loan to its Lending Bank.

26            740.     Because, in some Plaintiffs’ case, SBA has issued FLRDs and then withdrawn them

27   after that Plaintiff timely appealed to that FLRD to the OHA, for example, Plaintiff SAW, and

28
                                               154                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 155 of 169



 1   because those Plaintiffs did not apply for forgiveness of those PPP Loans within 10 months after the

 2   last day of the covered period of their loans, for example, Plaintiff SAW, those Plaintiffs, SAW

 3   included, are required to make and have been making repayments on their PPP Loans to their Lending

 4   Banks.

 5            741.     Plaintiffs in the situation described in paragraph 740 are unaware of any mechanism

 6   to recoup the monies already repaid on those Loans to their Lending Banks if they are ultimately

 7   successful in this action and thereby entitled to forgiveness of the Loans at issue.

 8            742.     If ultimately successful in this action, Gold Club will be entitled to forgiveness of

 9   $1,993,233.75 of its second draw PPP Loan; however, Gold Club is unaware of any mechanism to

10   recoup the monies already repaid on this Loan to its Lending Bank.

11            743.     Gold Club and the Plaintiffs in the situation described in paragraph 740, therefore, do

12   not have adequate remedies at law because, among other things, they cannot, so far as they are aware,

13   recover those monies already repaid to their Lending Banks.

14            744.     Plaintiffs do not have adequate remedies at law because, among other reasons, they

15   cannot recover damages against the Defendants as a result of sovereign immunity and because, so

16   far as they are aware, there is no mechanism to recoup the amount of monies paid back to the Lending

17   Banks on a PPP Loan, which a court has subsequently determined should have been forgiven.

18   Because of the unconstitutionality of the Prurience Regulation and its application to Gold Club and

19   those Plaintiffs in the situation described in paragraph 740 by Defendants, all as outlined herein;

20   because Gold Club and these Plaintiffs will suffer irreparable injury if this Court does not enjoin

21   Gold Club’s and these Plaintiffs’ obligation(s) to make payments on the PPP Loans at issue during

22   the pendency of this matter; because Defendants will not suffer any harm whatsoever by the entry of

23   the preliminary injunction requested herein; this Court should enter a preliminary injunction staying

24   Gold Club’s and the Plaintiffs in the situation described in paragraph 740’s obligation(s) to make

25   payments on the PPP Loans at issue during the pendency of this matter.

26            745.     Alternatively, the Court should order that Defendants set aside funding in the of Gold

27   Club’s and those Plaintiffs in the situation described in paragraph 740’s requested PPP Loan

28
                                               155                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 156 of 169



 1   forgiveness amount, which, for Gold Club is $1,993,233.75, during the pendency of this litigation so

 2   that, if Plaintiffs are ultimately successful, SBA may remit the difference between the amounts

 3   forgiven and what these Plaintiffs have already paid back on their Loans to their Lending Banks

 4   thereby making the Lending Banks whole and remit the remainder, representing the amounts these

 5   Plaintiffs have already paid back on their Loans, to the individual Plaintiffs affected, thereby making

 6   these Plaintiffs whole.

 7                                          PRAYER FOR RELIEF

 8            For the reasons set forth herein, this Honorable Court should enter the following relief:

 9            A.       Declare that the Defendants are applying the Prurience Regulation (13 C.F.R. §

10   120.110(p)) and Incorporating Statute (15 U.S.C. § 636(37)(A)(iv)(III)(aa)) in an unconstitutional

11   and/or unlawful manner;

12            B.       Declare that the Prurience Regulation and Incorporating Statute are facially

13   unconstitutional, and/or that the SBA’s application of them here under the PPP is not a legitimate or

14   lawful exercise of the SBA’s or its Administrator’s authority, and are otherwise invalid under the

15   Administrative Procedures Act, 5 U.S.C. § 551 et seq. and applicable law;

16            C.       Declare that 15 U.S.C. § 634(b)(1) does not bar the injunctive relief against SBA as

17   requested herein and that interpretations concluding that 15 U.S.C. § 634(b)(1) is an absolute bar to

18   injunctive relief against SBA are unconstitutional;

19            D.       Enter both a preliminary and permanent injunction precluding 15 U.S.C. § 634(b)(1)

20   from operating as a complete bar to injunctions against the SBA;

21            E.       Enter a preliminary injunction precluding the Defendants, as well as their employees,

22   agents, and representatives, including the Lending Banks, from requiring Plaintiffs to make payments

23   on the PPP Loans until such a time as this Court is able to adjudicate the merits of these claims;

24            F.       As an alternative to the preceding paragraph, Order Defendants to set aside

25   guaranteed funding in the amount to be demonstrated at the preliminary injunction hearing, but which

26   shall not be less than $1,993,233.75, during the pendency of this litigation;

27            G.       Enter both a preliminary and permanent injunction precluding the Defendants, as well

28
                                               156                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 157 of 169



 1   as their employees, agents, and representatives, including the Lending Banks, from using or applying

 2   the Prurience Regulation and/or the Incorporating Statute as a means of denying eligibility and/or

 3   forgiveness of the Plaintiffs’ PPP Loans at issue, or to the PPP loans of any businesses that the SBA

 4   asserts, believes, or claims to be “affiliated” with any of the Plaintiffs;

 5            H.       Declare that the Defendants are applying the Affiliation Exception Provisions (15

 6   U.S.C. § 636(a)(36)(D)(iii)(I), 15 U.S.C. § 636(a)(36)(D)(iv)(I), and 15 U.S.C. § 636(a)(37)(D) and

 7   (E)) in an unconstitutional and/or unlawful manner;

 8            I.       Declare that all Plaintiffs are NAICS code 72 businesses for all purposes under the

 9   PPP and that, as a result thereof, Plaintiffs are therefore exempt from the Affiliation Rules under the

10   PPP;

11            J.       Enter both a preliminary and permanent injunction precluding the Defendants, as well

12   as their employees, agents, and representatives, including the Lending Banks, from determining that

13   the Plaintiffs, or any other businesses that the SBA asserts, believes, or claims to be “affiliated” with

14   any of the Plaintiffs that are licensed bars, taverns, and/or nightclubs, are anything other than NAICS

15   code 72 businesses for PPP loan purposes and for application of the Affiliation Exception Provisions

16   to the Affiliation Rules;

17            K.       Declare that the Defendants are applying the Affiliation Rules (13 C.F.R. § 121.101,

18   13 C.F.R. § 121.103; 13 C.F.R. § 121.201, 13 C.F.R. § 121.301) in an unconstitutional and/or

19   unlawful manner;

20            L.       Declare that the Affiliation Rules are facially unconstitutional, and/or that the SBA’s

21   application of them here under the PPP is not a legitimate or lawful exercise of the SBA’s or its

22   Administrator’s authority, and are otherwise invalid under the Administrative Procedures Act, 5

23   U.S.C. § 551 et seq. and applicable law;

24            M.       Enter both a preliminary and permanent injunction precluding the Defendants, as well

25   as their employees, agents, and representatives, including the Lending Banks, from using or applying

26   the Affiliation Rules to Plaintiffs’ PPP Loans as a means of denying eligibility and/or forgiveness of

27   the Plaintiffs’ PPP Loans at issue, or to the PPP loans of any businesses that the SBA asserts, believes,

28
                                               157                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18       Filed 10/10/24      Page 158 of 169



 1   or claims to be “affiliated” with any of the Plaintiffs;

 2            N.       Order the Defendants, as well as their employees, agents, and representatives,

 3   including the Lending Banks, to grant Loan forgiveness to those Plaintiffs, or to those businesses

 4   that the SBA asserts, believes, or claims to be “affiliated” with any of the Plaintiffs, that have been

 5   denied forgiveness of any of their PPP Loans at issue, or that have been denied Loan forgiveness,

 6   that have filed appeals in the OHA, and that have then had the SBA withdraw the FLRD upon which

 7   the administrative appeal was based for further consideration of the affected Plaintiffs’ Loan

 8   forgiveness application;

 9            O.       Declare that OHA appeals for these Plaintiffs would be futile given the text of the

10   Special OHA Rules and the claims being asserted by these Plaintiffs;

11            P.       Enter both a preliminary and permanent injunction precluding the Defendants, as well

12   as their employees, agents, and representatives, including the Lending Banks, from requiring the

13   Plaintiffs, or any businesses that the SBA asserts, believes, or claims to be “affiliated” with any of

14   the Plaintiffs, to have to undergo OHA appeals as a procedural prerequisite to being able to appear

15   before this Honorable Court in order to have their constitutional and other legal claims set forth

16   herein fully adjudicated;

17            Q.       Declare that the Special OHA Rules (13 C.F.R., Ch. I, Pt. 134, Subpart L), as applied

18   to PPP loans, denies due process and therefore violates the First and Fifth Amendments to the United

19   States Constitution, and/or that the SBA’s application of them here under the PPP is not a legitimate

20   or lawful exercise of the SBA’s or its Administrator’s authority, and/or are otherwise invalid under

21   the Administrative Procedures Act, 5 U.S.C. § 551 et seq. and applicable law;

22            R.       Enter both a preliminary and permanent injunction precluding the Defendants, as well

23   as their employees, agents, and representatives, from applying the Special OHA Rules against the

24   Plaintiffs, or against any businesses that the SBA asserts, believes, or claims to be “affiliated” with

25   any of the Plaintiffs, in regard to any of their legal challenges to the SBA’s actions concerning their

26   PPP Loans;

27            S.       Declare that the Defendants should be estopped from denying loan eligibility and

28
                                               158                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC           Document 18        Filed 10/10/24      Page 159 of 169



 1   forgiveness of the Plaintiffs’ PPP Loans at issue, and of the PPP loans of any businesses that the SBA

 2   asserts, believes, or claims to be “affiliated” with any of the Plaintiffs;

 3            T.       Enter both a preliminary and permanent injunction estopping the Defendants, as well

 4   as their employees, agents, and representatives, including the Lending Banks, from denying Plaintiffs

 5   eligibility and forgiveness of their PPP Loans at issue, or to the PPP loans of any businesses that the

 6   SBA asserts, believes, or claims to be “affiliated” with any of the Plaintiffs;

 7            U.       Order Defendants, as well as their employees, agents, and representatives, to notify,

 8   as expeditiously as possible, all SBA lending banks to immediately discontinue using or applying the

 9   Prurience Regulation and the Incorporating Statute for any matters concerning PPP loans;

10            V.       Order Defendants, as well as their employees, agents, and representatives, to notify,

11   as expeditiously as possible, the OHA to immediately discontinue using or applying the Special OHA

12   Rules in regarding appeals concerning PPP loans;

13            W.       Order the Defendants, as well as their employees, agents, and representatives,

14   including the Lending Banks, to immediately desist from conducting any, or from initiating any

15   further, audits, “Post Payment Reviews,” or other similar investigations of any of the Plaintiffs’ PPP

16   Loans at issue or any PPP Loans obtained by any businesses that the SBA asserts, believes, or claims

17   to be “affiliated” with any of the Plaintiffs;

18            X.       Order the Defendants to immediately issue to the Lending Banks correspondence

19   withdrawing all threats issued to such banks related to the Loans issued to the Plaintiffs, or issued to

20   any businesses that the SBA asserts, believes, or claims to be “affiliated” with any of the Plaintiffs,

21   including but not limited to the threat to refer such Lending Banks to the Office of Credit

22   Management and/or to transfer the matter to the office of Inspector General;

23            Y.       Enter an award of attorneys’ fees and costs against the Defendants and in favor of the

24   Plaintiffs pursuant to the Equal Access to Justice Act, 28 U.S.C. § 2412, to 5 U.S.C.§ 504, and as

25   otherwise permitted; and

26            Z.       Enter such other and further relief as this Court may deem to be just and proper in

27   these circumstances.

28
                                               159                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC       Document 18      Filed 10/10/24      Page 160 of 169



 1

 2   Dated: October 10, 2024                           Respectfully Submitted,
 3
                                                       SHAFER & ASSOCIATES, P.C.
 4

 5                                                     /s/    Bradley J. Shafer
                                                       Bradley J. Shafer (MI P36604)*
 6                                                     Zachary M. Youngsma (MI P84148)*
                                                       SHAFER & ASSOCIATES, P.C.
 7                                                     3800 Capital City Blvd., Ste. 2
                                                       Lansing, Michigan 48906
 8                                                     T: 517-886-6560
                                                       F: 517-886-6565
 9                                                     E: Brad@BradShaferLaw.com
                                                       E: Zack@BradShaferLaw.com
10

11                                                     LONG & LEVIT LLP
12
                                                       DOUGLAS J. MELTON, Bar No. 161353
13                                                     SHANE M. CAHILL, Bar No. 227972
                                                       LONG & LEVIT LLP
14                                                     465 California Street, Suite 500
                                                       San Francisco, California 94104
15                                                     Telephone:     (415) 397-2222
                                                       Facsimile:     (415) 397-6392
16                                                     Email: dmelton@longlevit.com
                                                              scahill@longlevit.com
17
                                                       *Admitted Pro Hac Vice
18
                                                       Attorneys for All Plaintiffs
19

20
21

22

23

24

25

26

27

28
                                               160                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC          Document 18        Filed 10/10/24      Page 161 of 169



 1                                      DEMAND FOR JURY TRIAL

 2            Plaintiffs, by counsel and pursuant to Fed. R. Civ. P. 38, hereby demand a trial by jury of any

 3   issues so triable.

 4   Dated: October 10, 2024                                Respectfully Submitted,

 5
                                                            SHAFER & ASSOCIATES, P.C.
 6

 7                                                          /s/    Bradley J. Shafer
                                                            Bradley J. Shafer (MI P36604)*
 8                                                          Zachary M. Youngsma (MI P84148)*
                                                            SHAFER & ASSOCIATES, P.C.
 9                                                          3800 Capital City Blvd., Ste. 2
                                                            Lansing, Michigan 48906
10                                                          T: 517-886-6560
                                                            F: 517-886-6565
11                                                          E: Brad@BradShaferLaw.com
                                                            E: Zack@BradShaferLaw.com
12

13                                                          LONG & LEVIT LLP
14
                                                            DOUGLAS J. MELTON, Bar No. 161353
15                                                          SHANE M. CAHILL, Bar No. 227972
                                                            LONG & LEVIT LLP
16                                                          465 California Street, Suite 500
                                                            San Francisco, California 94104
17                                                          Telephone:     (415) 397-2222
                                                            Facsimile:     (415) 397-6392
18                                                          Email: dmelton@longlevit.com
                                                                   scahill@longlevit.com
19
                                                            *Admitted Pro Hac Vice
20
                                                            Attorneys for All Plaintiffs
21

22

23

24

25

26

27

28
                                               161                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
     Case 3:24-cv-04241-LJC          Document 18        Filed 10/10/24      Page 162 of 169



 1                                        FILER’S ATTESTATION

 2            I hereby attest that I have on file all holographic signatures corresponding to any signatures

 3   indicated by a conformed signature (/s/) within this e-filed document.

 4

 5

 6

 7
                                                            ____________________________________
 8                                                          BRADLEY J. SHAFER

 9
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                                               162                         Case No. 3:24-cv-04241-LJC
        VERIFIED FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S
        FEES AND COSTS UNDER THE EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL
                                          AGENCY ACTION
     4862-2357-8321, v. 1
Docusign Envelope ID: EC0EC6EB-7E9F-46CB-BC81-8BE919937360
                  Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24   Page 163 of 169



              1                            VERIFICATION OF COMPLAINT AS TO:
                           Dallas Food and Beverage, LLC; 2345 Meacham, LLC; and 11000 Reeder, LLC
              2

              3            1.       I, Curtis Wise, am the Managing Member of Dallas Food and Beverage, LLC; 2345

              4    Meacham, LLC; and 11000 Reeder, LLC.

              5            2.       I make this verification upon my personal knowledge, unless specifically stated to the

              6    contrary.

              7            3.       I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR

              8    DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE

              9    EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION

            10     (the “FAC”) in its entirety.

            11             4.       The factual statements in the FAC, as they pertain to Dallas Food and Beverage, LLC;

            12     2345 Meacham, LLC; and 11000 Reeder, LLC, are true and accurate to the best of my information,

            13     knowledge and belief.

            14             5.       Except, any matters stated to be upon “information and belief,” I verily believe to be

            15     true.

            16

            17     I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
                   CORRECT.
            18
                                  10/9/2024
            19     Executed on:
                                                                  By:      Curtis Wise
            20

            21

            22

            23

            24

            25

            26
            27

            28

            30                                                 1                        Case No. 3:24-cv-04241-LJC
                     VERIFICATION OF COMPLAINT AS TO DALLAS FOOD AND BEVERAGE, LLC; 2345 MEACHAM, LLC; AND
                                                       11000 REEDER, LLC
            31
Case 3:24-cv-04241-LJC   Document 18   Filed 10/10/24   Page 164 of 169
Docusign Envelope ID: 0D9DBA5D-AD1C-4285-92C2-0758CEA246D1
                  Case 3:24-cv-04241-LJC            Document 18        Filed 10/10/24   Page 165 of 169



              1                                VERIFICATION OF COMPLAINT AS TO:
                                                    Pole Position at Tacoma, LLC
              2
                           1.      I, Eric Forbes, am the Managing Member of Pole Position at Tacoma, LLC.
              3
                           2.      I make this verification upon my personal knowledge, unless specifically stated to the
              4
                   contrary.
              5
                           3.      I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR
              6
                   DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE
              7
                   EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION
              8
                   (the “FAC”) in its entirety.
              9
                           4.      The factual statements in the FAC, as they pertain to Pole Position at Tacoma, LLC,
            10
                   are true and accurate to the best of my information, knowledge and belief.
            11
                           5.      Except, any matters stated to be upon “information and belief,” I verily believe to be
            12
                   true.
            13

            14
                   I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
            15     CORRECT.

            16                    10/9/2024
                   Executed on:
            17                                                   By:      Eric Forbes

            18

            19

            20

            21

            22

            23

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                                                                  1                        Case No. 3:24-cv-04241-LJC
                                     VERIFICATION OF COMPLAINT AS TO POLE POSITION AT TACOMA, LLC
            31
Docusign Envelope ID: 08F01E3D-5B9A-45C9-9E43-5CE062D221DD
                  Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24    Page 166 of 169



              1                               VERIFICATION OF COMPLAINT AS TO:
                                          Smithville Bistro, LLC and Cats Meow of Vegas, LLC
              2

              3            1.       I, Harry Mohney, am the Managing Member of Smithville Bistro, LLC and Cats

              4    Meow of Vegas, LLC.

              5            2.       I make this verification upon my personal knowledge, unless specifically stated to the

              6    contrary.

              7            3.       I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR

              8    DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE

              9    EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION

            10     (the “FAC”) in its entirety.

            11             4.       The factual statements in the FAC, as they pertain to Smithville Bistro, LLC and Cats

            12     Meow of Vegas, LLC, are true and accurate to the best of my information, knowledge and belief.

            13             5.       Except, any matters stated to be upon “information and belief,” I verily believe to be

            14     true.

            15

            16     I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
                   CORRECT.
            17
                                  10/9/2024
            18     Executed on:
                                                                  By:      Harry Mohney
            19

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                                                                1                        Case No. 3:24-cv-04241-LJC
                        VERIFICATION OF COMPLAINT AS TO SMITHVILLE BISTRO, LLC AND CATS MEOW OF VEGAS, LLC
            31
Docusign Envelope ID: BF5C6100-08CE-473D-97B8-6B3AD428A567
                  Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24    Page 167 of 169



              1                            VERIFICATION OF COMPLAINT AS TO:
                             Cats 701 Bourbon, LLC; Jamme Holdings, LLC; and Las Vegas Bistro, LLC
              2

              3             1.      I, Jason Mohney, am the Managing Member of Cats 701 Bourbon, LLC; Jamme

              4    Holdings, LLC; and Las Vegas Bistro, LLC.

              5             2.      I make this verification upon my personal knowledge, unless specifically stated to the

              6    contrary.

              7             3.      I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR

              8    DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE

              9    EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION

            10     (the “FAC”) in its entirety.

            11              4.      The factual statements in the FAC, as they pertain to Cats 701 Bourbon, LLC; Jamme

            12     Holdings, LLC; and Las Vegas Bistro, LLC, are true and accurate to the best of my information,

            13     knowledge and belief.

            14              5.      Except, any matters stated to be upon “information and belief,” I verily believe to be

            15     true.

            16

            17     I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
                   CORRECT.
            18
                                   10/10/2024
            19     Executed on:
                                                                  By:      Jason Mohney
            20

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            30                                                   1                       Case No. 3:24-cv-04241-LJC
                        VERIFICATION OF COMPLAINT AS TO CATS 701 BOURBON, LLC; JAMME HOLDINGS, LLC; AND LAS
                                                         VEGAS BISTRO, LLC
            31
Docusign Envelope ID: 8C4AAC14-4896-4875-92F9-D139D52E94C9
                  Case 3:24-cv-04241-LJC              Document 18       Filed 10/10/24   Page 168 of 169



              1                               VERIFICATION OF COMPLAINT AS TO:
                                        Gold Club – S.F., LLC and S.A.W. Entertainment Limited
              2

              3              1.     I, Joseph Carouba, am the Managing Member of Gold Club – S.F., LLC and President

              4    of S.A.W. Entertainment Limited.

              5              2.     I make this verification upon my personal knowledge, unless specifically stated to the

              6    contrary.

              7              3.     I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR

              8    DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE

              9    EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION

            10     (the “FAC”) in its entirety.

            11               4.     The factual statements in the FAC, as they pertain to Gold Club – S.F., LLC and

            12     S.A.W. Entertainment Limited, are true and accurate to the best of my information, knowledge and

            13     belief.

            14               5.     Except, any matters stated to be upon “information and belief,” I verily believe to be

            15     true.

            16

            17     I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
                   CORRECT.
            18
                                  10/9/2024
            19     Executed on:
                                                                  By:      Joseph Carouba
            20

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                                                               1                            Case No. 3:24-cv-04241-LJC
                       VERIFICATION OF COMPLAINT AS TO GOLD CLUB – S.F., LLC AND S.A.W. ENTERTAINMENT LIMITED
            31
Docusign Envelope ID: 28AC6219-FFA8-4AA4-841A-F1A035CA24BE
                  Case 3:24-cv-04241-LJC             Document 18        Filed 10/10/24   Page 169 of 169



              1                                VERIFICATION OF COMPLAINT AS TO:
                                           Office Minneapolis, LLC and 90’s Minneapolis, LLC
              2

              3             1.      I, Peter Hafiz, am the Managing Member of Office Minneapolis, LLC and 90’s

              4    Minneapolis, LLC.

              5             2.      I make this verification upon my personal knowledge, unless specifically stated to the

              6    contrary.

              7             3.      I have reviewed the foregoing VERIFIED FIRST AMENDED COMPLAINT FOR

              8    DECLARATORY AND INJUNCTIVE RELIEF, ATTORNEY’S FEES AND COSTS UNDER THE

              9    EQUAL ACCESS TO JUSTICE ACT, AND FOR JUDICIAL REVIEW OF FINAL AGENCY ACTION

            10     (the “FAC”) in its entirety.

            11              4.      The factual statements in the FAC, as they pertain to Office Minneapolis, LLC and

            12     90’s Minneapolis, LLC, are true and accurate to the best of my information, knowledge and belief.

            13              5.      Except, any matters stated to be upon “information and belief,” I verily believe to be

            14     true.

            15

            16     I VERIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND
                   CORRECT.
            17
                                  10/9/2024
            18     Executed on:
                                                                  By:      Peter Hafiz
            19

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            30                                                    1                         Case No. 3:24-cv-04241-LJC
                           VERIFICATION OF COMPLAINT AS TO OFFICE MINNEAPOLIS, LLC AND 90’S MINNEAPOLIS, LLC
            31


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