First Amended Complaint — Creation Entertainment, Inc. v. Small Business Administration (No. 22-684, 2022-08-19)

Summary

First Amended Complaint filed August 19, 2022 by Creation Entertainment, Inc. against the Small Business Administration and its Administrator in the United States District Court for the District of Columbia, Civil Action No. 22-684 (ABJ). It is an action under the Administrative Procedure Act and the Declaratory Judgment Act seeking Shuttered Venue Operators Grant funds that Creation alleges were unlawfully withheld. It alleges that Creation applied on April 28, 2021 for an SVOG award of $9,699,500.00, that the SBA denied the application and the appeal, and that the denial was arbitrary, capricious, an abuse of discretion and otherwise unlawful. The prayer for relief asks the Court to declare the denial unlawful and set it aside.

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Issuer: UNITED STATES DISTRICT COURT
Document type: Complaint
Date: 2022-08-19
Case: Plaintiff, v. SMALL BUSINESS ADMINISTRATION, et al.,
Case number: 22-684

Cite this document

“First Amended Complaint — Creation Entertainment, Inc. v. Small Business Administration (No. 22-684, 2022-08-19).” UNITED STATES DISTRICT COURT, No. 22-684, dated 2022-08-19. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-08-19-plaintiff-v-small-business-administration-et-al/, SHA-256 8c881fbfff861fbcd4b2e2f8cd87f4e41d2f2b5173696a0a33b30f4995cd1060.

Full text

Case 1:22-cv-00684-ABJ Document 14 Filed 08/19/22 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CREATION ENTERTAINMENT, INC.

Plaintiff,
v.
Civil Action No. 22-684 (ABJ)
SMALL BUSINESS ADMINISTRATION, et al.,

Defendants.

FIRST AMENDED COMPLAINT

Plaintiff Creation Entertainment, Inc. (“Creation”), by and through counsel, alleges and

states as follows:

INTRODUCTION

1. This is an action under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706,

and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, seeking emergency federal

financial assistance unlawfully withheld by Defendants Small Business Administration (“SBA”)

and its Administrator, Isabella Casillas Guzman.

2. The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, as

amended, 15 U.S.C. § 9009a, established the Shuttered Venue Operators Grant (“SVOG”) Program

to provide emergency financial assistance to eligible live entertainment businesses impacted by

the global COVID-19 pandemic. The SVOG Program is administered by the SBA and

Administrator Casillas Guzman.

3. Plaintiff Creation demonstrated its eligibility for a SVOG award in its application

to the SBA and, following an initial denial, its appeal to the SBA. The SBA denied Creation’s

application and its appeal. Since that time Creation has provided the SBA with overwhelming

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evidence that it qualifies for an SVOG award, evidence that the SBA is now choosing deliberately

and wrongfully to ignore. See Ex. 1, July 1, 2022 Declaration of Edward Rodriguez; and Ex. 2,

July 14, 2022 Creation Letter.

4. Creation has been producing live entertainment shows centering on genre television

and film for more than 50 years. Creation hires actors of popular science fiction film and television

shows to put on live theatrical and musical performances through licensing agreements for which

the actors are paid handsomely by way of revenue from ticket sales.

5. The SBA improperly labelled Creation a promoter of “science cosplay

conventions.” See Ex. 3., July 7, 2022 SBA Letter (“A holistic review of the application, submitted

documentation, applicant’s website and social media pages indicates that the applicant’s principal

business activity is to organize, plan, create and promote science cosplay conventions.”). The

SBA’s conclusion appears to be based solely on the subject matter and genre of Creation’s

theatrical performances. As discussed more fully below and in the attached documents, all of

Creation’s shows are ticketed and fans sit in fixed seats. Ticket prices rise the closer a seat is to

the stage. Front row seating costs over one thousand dollars and the events consist of live musical

and theatrical performances by well-known actors. Creation earns de minimis revenue from vendor

booths and provides vendor space that is less than 5% of the overall venue. Additionally, 76% of

Creation’s total business expenses go to paying performers for their theatrical performances.

6. Thus Creation meets each of the SVOG eligibility criteria specific to a live

performing arts organization operator. The SBA’s denial of Creation’s SVOG application was

arbitrary, capricious, an abuse of discretion and otherwise unlawful.

7. In early spring 2020, the COVID-19 pandemic, as well as associated restrictions

regarding live entertainment, halted Creation’s business. As a live performing arts organization,

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the company suffered a 93 percent loss in revenue in 2020 as compared to revenues in 2019.

2019 Revenue 2020 Revenue

$23,364,955.33 $1,621,085.74

8. Creation was forced to shut down and cancel all its scheduled events after March

2020. Creation did not earn any revenue from April 2020 through December 31, 2020.

9. Creation was entitled to first priority review for its SVOG award due to the 100%

revenue decline it suffered from April 2020 December 2020.

10. Creation subsequently resumed live operations in February 2021. During the first

quarter of 2021, Creation suffered a 97% loss in revenue as compared to the first quarter of 2019.

2019 Q1 Revenue 2021 Revenue

$4,031,192.03 $392,547.02

11. Creation needs an SVOG award for precisely the reason Congress created the

SVOG Program: to help eligible live entertainment businesses like Creation recover from the

major setbacks they have experienced because of the pandemic.

12. SVOG funds are limited, and once the SBA has depleted the appropriated amount

through awards, eligible businesses may not be able to receive the emergency assistance. Thus,

even though Creation demonstrated that it is an eligible applicant, it may receive no assistance if

SVOG funds are depleted before the SBA corrects the erroneous denial of Creation’s application.

JURISDICTION AND VENUE

13. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 because it

presents federal questions under the APA.

14. Venue lies in this district under 28 U.S.C. § 1391(e)(1).

15. This Court has authority to issue declaratory and injunctive relief under 5 U.S.C.

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§ 706 and 28 U.S.C. §§ 2201 and 2202.
PARTIES

16. Plaintiff Creation is a Glendale, California based live performing arts organization

operator. Creation organizes, promotes, and produces live entertainment shows throughout the

United States for fans of genre television and film.

CREATION ENTERTAINMENT

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17. Defendant Small Business Administration is an independent agency of the federal

government. The SBA’s mission is to help Americans start, build, grow and sustain businesses.

18. Defendant Isabella Casillas Guzman is the Administrator of the SBA and oversees

its operations. Administrator Casillas Guzman is sued in her official capacity.

BACKGROUND

A. Shuttered Venue Operators Grant Program

19. The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the

“Act”), signed into law December 27, 2020, included $15 billion for grants to operators of

shuttered venues. Pub. L. No. 116-260 § 324. The American Rescue Plan, enacted March 11, 2021,

amended the Act by providing an additional $1,249,500,000 for SVOG awards. Pub. L. No.117-2

§ 5005(a).

20. SVOG awards may be used for specified business expenses, including payroll, rent

and utility payments, which are incurred between March 1, 2020, and December 31, 2021. 15 U.S.C.

§ 9009a(d)(1)(A)(i).

21. An eligible entity may receive an SVOG award in an amount equal to 45 percent

ofits gross earned revenue in 2019. 15 U.S.C. § 9009a(c).

22. Eligible businesses with 2021 first quarter revenues of no more than 30 percent of

their 2019 first quarter revenues are eligible for supplemental grants in the amount of 50 percent

of the original award amount, up to a maximum combined initial and supplemental SVOG award

amount of $10 million. 15 U.S.C. § 9009a(b)(3)(A); SBA, SBA Opens Supplemental Grant

Applications for Shuttered Venue Operators Grant Awardees (Aug. 27, 2021),

https://www.sba.gov/article/2021/aug/27/sba-opens-supplemental-grant-applications-shuttered-

venue-operators-grant-awardees. Supplemental awards can be used for costs incurred through

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June 30, 2022. 15 U.S.C. § 9009a(d)(1)(A)(i).

23. Eligible entities under the Act include live performing arts organization operators

and live venue operators, as well as promoters, theatrical producers, museum operators, motion

picture theatre operators, and talent representatives. 15 U.S.C. § 9009a(a)(1)(A).

24. In addition to falling within an eligible business category, to qualify for an SVOG

award a business must meet general eligibility criteria including, inter alia, that the business was

fully operational on February 29, 2020, suffered at least a 25 percent reduction of gross earned

revenue during at least one quarter of 2020 as compared to 2019, and has reopened or intends to

reopen. 15 U.S.C. § 9009a(a)(1)(A). The Act lists a number of characteristics that would render

an entity ineligible, including, inter alia, issuance of securities on a national securities exchange,

employing more than 500 employees, and presenting live performances of a prurient sexual nature.

Id. § 9009a(a)(1)(A)(vi), 9009a(a)(1)(B).

25. The Act defines live venue operator or promotor, theatrical producer, or live

performing arts organization operator identically. 15 U.S.C. § 9009a(a)(3)(A)(i). The definition

includes an entity that as a principal business activity organizes, promotes, produces manages or

hosts live concerts, comedy shows, theatrical production or events by performing artists for which

there is a ticketed cover charge, performers are paid in an amount set by sales or for agreement, and

not less than 70 percent of revenue is generated through ticket sales or event beverages, food or

merchandise. Id.

26. The Act specifies that for a live performing arts organization operator (as well as a

live venue operator or promotor, or theatrical producer) to be eligible, the entity must have

additional characteristics. It must put on events with defined performance and audience spaces;

use mixing equipment, a public address system and a lighting rig; engage one or more individuals

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to carry out at least two of the following roles—sound engineer, booker, promoter, stage manager,

security personnel, or box office manager; sell tickets or impose a cover charge for most

performances; fairly pay artists; and market its events including through print or electronic

publications, websites, mass email, or social media. 15 U.S.C. § 9009a(a)(1)(A)(iii).

27. On June 25, 2022, Congress rescinded $1.2 billion of the appropriations available

for the SVOG Program. Pub. L. No. 117-158 § 4(a)(3).

28. As of July 5, 2022, the SBA had distributed a total of $14.57 billion in SVOG award

funds.

29. Of the $16.25 billion originally appropriated for the SVOG Program, only

approximately $400 million remains for SVOG initial and supplemental awards as well as all SBA

contractor and staff costs for post-award administration of the SVOG program.

B. Implementation of the SVOG Program

30. The SBA implemented the SVOG program through the publication of regulations

in the Federal Register and guidance and procedural notices on its SBA website.

31. On March 26, 2021, the SBA published its only regulations in the Federal Register

pertaining to the SVOG program. The regulations stated that the SBA would begin receiving

applications on April 8, 2021 and would continue receiving submissions until SVOG funds were

exhausted.

32. On January 27, 2021, the SBA published a list of frequently asked questions with

answers (“FAQ”). The SBA published eleven subsequent versions of its FAQs (February 5, 2021;

February 12, 2021; February 28, 2021; March 5, 2021; March 12, 2021; March 22, 2021; April 6,

2021; April 8, 2021; April 23, 21; July 7, 2021; and October 10, 2021).

33. On March 5, 2021, the SBA published an application checklist to assist applicants

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with gathering documents needed to support their eligibility. The SBA published three subsequent

versions of the checklist (March 11, 2021, April, 23, 2021; and July 28, 2021).

34. On April 8, 2021, the SBA published a SVOG user guide on its website. On April

23, 21, the SBA published a second version of the user guide.

35. On July 13, 2021, the SBA published an SVOG eligibility matrix summarizing the

application requirements in table format.

36. The SBA also provided three instructional webinars for applicants (January 14,

2021; February 2, 2021; and March 31, 2021).

37. All SVOG applicants had to apply for funds through the SVOG application portal

on the SBA website.

38. The SVOG portal had size limitations, and the SBA did not accept files over 35

MBs.

39. The SVOG portal was designed to not allow an applicant to skip a required question

or fail to upload a document in a required location.

40. The SBA maintained a policy of notifying applicants of errors in their applications

and giving applicants an opportunity to correct errors and/or upload additional documents in

support of their applications.

41. The SBA maintained a policy authorizing SBA personnel to email or call applicants

and request additional evidence or documents in an effort to correct deficient applications.

42. SBA personnel regularly spoke to applicants and helped them locate and upload

necessary documents.

43. The SBA maintained a policy encouraging SBA personnel to look beyond the

application and supporting documents submitted through the SVOG portal. SBA personnel

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conducted reviews of an applicant’s website, social media sites, Google and Yelp reviews, Google

search information, Youtube videos and other publicly available information.

44. On August 20, 2021, the SBA stopped accepting new SVOG applications.

45. The SBA continues to overturn SVOG denials and to accept supplemental

documents, evidence and information from previously denied applicants.

C. Creation’s SVOG Application and the SBA’s Denial

46. Due to the significant amount of money at stake and the complexities of the SVOG

program, Creation hired the Certified Public Accounting firm, Weiss Accountancy LLP, to assist

with its SVOG application.

47. On April 28, 2021, Creation applied for a SVOG award of $9,699,500.00. In its

application, Creation demonstrated that it satisfied the criteria for eligibility as a live performing

arts organization operator. See 15 U.S.C. § 9009a(a)(3)(A) (defining the term “live venue operator

or promotor, theatrical producer, or live performing arts organization operator”). Creation

demonstrated that its losses in 2020 exceeded the 25 percent statutory threshold by submitting its

financial statements and tax returns for 2019 and 2020. Creation also submitted, among other things:

(i) documents demonstrating the performance space and defined audience space (floor plan),

lighting rig (photos of lighting), mixing equipment (photos of sound mixing equipment) and public

address system (photos of PA system); (ii) ticketing reports and box office information; (iii)

contracts with venues and theatrical personnel; and (iv) advertising and marketing documents.

Creation further provided the certifications of eligibility required by the SBA’s guidance on SVOG

applications. Additionally, Creation uploaded pictures of its shows, as well as links to publicly

available information showing the quality and nature of its shows.

48. On July 6, 2021, Creation learned from the SBA’s portal that its application was

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denied. No reason was given for its denial.

49. Creation was confused by its denial and attempted on several occasions to reach

someone from the SBA in order to obtain a more detailed explanation for why Creation was denied

the SVOG funds. Creation was never able to speak to a representative from the SBA.

50. As described in more detail below, Creation could have easily cured the SBA’s

perceived deficiencies with its application had the SBA simply notified Creation of the reason for

its denial.

51. On August 17, 2021, Creation submitted an administrative appeal of the denial to

the SBA. At the time of its appeal, Creation still did not know the reason for its denial and was

forced to guess. Creation explained in detail and with supporting documentation how it meets each

of the general eligibility requirements for an SVOG award and each of the specific eligibility

requirements for live performing arts organization operators. Creation’s supporting documentation

included: its quarterly income statements for 2019 and 2020; 2019 and 2020 federal tax returns;

advertising materials; contracts with live performing artists; box office records reflecting ticket

sales; employee records and contractor agreements reflecting engagement of a sound engineer,

stage manager, security personnel, box office manager, and bookers and promoters; photographs

and floorplans demonstrating its defined performance space, audience space, sound mixing

equipment, public address system, and lighting rig; payroll and other records reflecting its periods

of operation; web links to marketing materials and websites; and other documentation.

52. On August 25, 2021, the SBA notified Creation that its appeal was denied. No

reason was given for the denial.

53. On May 12, 2022, the SBA rescinded its denial and notified Creation that it would

be issuing a new decision.

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54. On July 1, 2022, Creation’s Chief Financial Officer, submitted a sworn declaration

to the SBA. See Ex. 1. The declaration summarized previously submitted evidence and

demonstrated (under oath) that Creation unequivocally qualifies for an SVOG award.

55. The declaration included (among other evidence) the following statements:

(i) Creation derives 100% of its revenue from the organization and
production of live theatrical events;

(ii) Creation derives 93% of its revenue directly from ticket sales;

(iii) Creation’s largest business expense is paying its talent to perform at its
shows, which accounts for 76% of its overall expenses;

(iv) Creation’s shows are ticketed and the prices for seats rise as individuals
are seated closer to the stage;

(v) All performers are paid;

(vi) A summary of the most common and representative theatrical and
musical events that take place at its shows.

56. On July 7, 2022, the SBA issued its new decision. See Ex. 3.

57. The SBA decision stated that it denied Creation’s application because: (i) Creation

failed to present adequate evidence of qualifying live performances; and (ii) Creation failed to

provide evidence that its performers are paid.

58. The SBA’s decision contradicts and ignores the application materials submitted by

Creation, including (i) pictures of its events; (ii) its ticketing information; (iii) its financial

statements; (iv) its venue contracts; and (v) copies of its talent contracts. The decision also

contradicts the available information on Creation’s website and social media accounts. Creation’s

website includes information showing the actors who are scheduled to perform at upcoming events

as well as pictures of past events. Moreover, a simple Google search of any of Creation’s shows

produces hundreds of videos of live musical and theatrical performances.

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59. The SBA decision also directly contradicts the declaration of Mr. Rodriguez. See

Ex. 1 at ¶¶ 7,14 (averring that Creation had submitted substantial evidence to the SBA conclusively

demonstrating that Creation’s performers are paid); ¶¶ 9-14 (averring to the live performances put

on by Creation).

60. On July 14, 2022, Creation submitted a letter to the SBA addressing its two

concerns in great detail. See Ex. 2. The letter provided the SBA with overwhelming evidence that

Creation does indeed qualify for the SVOG award, including videos of its past live performances

and copies of its contracts with its performers. Id. Creation further offered to provide any additional

evidence the SBA may have needed to approve Creation’s SVOG application.

61. On August 2, 2022, the SBA responded to Creation’s letter, tacitly acknowledging

that Creation appears to qualify for an SVOG award but concluding that the SBA would not fund

the award because the supporting evidence was not timely submitted to the SBA. See Ex 4, August

2, 2022 SBA letter.

62. The SBA’s August 2, 2022 denial of Creation’s application is the agency’s final

decision.

CLAIMS FOR RELIEF

63. The courts recognize a strong presumption favoring judicial review of

administrative action.

64. The APA provides that “[a] person suffering legal wrong because of agency action,

or adversely affected or aggrieved by agency action within the meaning of a relevant statute, is

entitled to judicial review thereof.” 5 U.S.C. § 702.

65. The APA provides that “final agency action for which there is no other adequate

remedy in a court” is “subject to judicial review.” 5 U.S.C. § 704.

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66. The APA provides that courts will “hold unlawful and set aside” agency action that

is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” or

“unsupported by substantial evidence.” 5 U.S.C. § 706(2)(A) and (E), respectively.

67. The SBA is an “agency” whose final actions are reviewable under the APA.

COUNT I - ARBITRARY AND CAPRICIOUS AGENCY ACTION

68. Creation realleges and incorporates by reference each of the preceding paragraphs

and allegations.

69. A basic requirement of administrative law is that an agency provide the reasons and

bases forits decisions. The SBA failed to give any reason for denying Creation’s application and

its subsequent appeal until July 7, 2022.

70. Within a matter of days, Creation was easily able to provide sufficient evidence to

overwhelmingly disprove the SBA’s factual conclusions.

71. The SBA’s failure to contact Creation, return Creation’s telephone calls, or accept

its evidentiary submissions violates the SBA’s congressionally mandated duty to implement the

SVOG program and supply emergency funds to businesses who meet the statutory criteria.

72. The SBA’s decision on Creation’s application is contrary to and ignores the

overwhelming evidence of Creation’s eligibility that Creation presented to the SBA in its

application and in its appeal.

73. The SBA’s decision to deny Creation’s application is also contrary to and ignores

the publicly available information reviewed by the SBA concerning Creation and its business.

74. The SBA further erred by treating Creation disparately from similarly situated

businesses that were granted SVOG awards. Specifically, the SBA approved the SVOG

application of the following Creation competitors:

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 Clexacon LLC

 Mischief Management LLC

 Walker Stalkers LLC

75. The SBA’s funding of the aforementioned entities has further exacerbated

Creation’s COVID-related damages. The SVOG’S disparate funding decisions have served as a

significant competitive advantage to Creation’s competitors. In fact, many of those acompanies

attract precisely the same customers as Creation and have been able to market and put on more

elaborate performances than Creation due to their receipt of SVOG funds.

76. The SBA further erred by treating Creation disparately from other applicants in that

it failed to give Creation an opportunity to be heard and to fix its allegedly deficient application

and failed to timely notify Creation of the reasons for its denial.

77. For each of these reasons, the SBA’s denial of Creation’s SVOG award request is

arbitrary and capricious.

COUNT II - AGENCY ACTION CONTRARY TO LAW

78. Creation realleges and incorporates by reference each of the preceding paragraphs

and allegations.

79. Creation meets the Act’s definition of a live performing arts organization operator

and satisfies the Act’s general eligibility criteria for a SVOG award.

80. The SBA’s denial of Creation’s SVOG award request therefore violated the Act

and is contrary to law.

COUNT III - AGENCY DECISION UNSUPPORTED BY SUBSTANTIAL EVIDENCE

81. Creation realleges and incorporates by reference each of the preceding paragraphs

and allegations.

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82. The SBA’s denial of Creation’s SVOG award request is supported by no evidence

in the record, let alone substantial evidence. Creation’s application and appeal presented evidence

that demonstrates Creation is eligible for a SVOG award.

83. The SBA’s denial of Creation’s SVOG award request is thus unsupported by
substantial evidence.

COUNT IV – DEPRIVATION OF DUE PROCESS AND EQUAL PROTECTION IN
VIOLATION OF THE FIFTH AMENDMENT TO THE U.S. CONSTITUTION

84. Creation realleges and incorporates by reference each of the preceding paragraphs

and allegations.

85. The two fundamental precepts of the rights afforded under the Due Process Clause

of the Fifth Amendment to the U.S. Constitution are notice and an opportunity to be heard.

86. The allegations set forth above demonstrate that the SBA deprived Creation of both

notice and an opportunity to be heard.

87. The SBA never provided any notice to Creation as to the alleged deficiencies in its

application, deficiencies Creation could have immediately addressed had it been afforded such

notice.

88. Nor did the SBA ever provide notice to Creation that it would not accept

supplemental information in support of Creation’s application or that there was any properly

published notice in the Federal Register or elsewhere that there existed a cut-off after which an

SVOG applicant was precluded from providing such supplemental information in support of its

application.

89. The SBA’s sudden refusal to accept supplemental information from Creation

overwhelmingly demonstrating Creation’s eligibility for an SVOG award and supplemental award

both deprived Creation of an opportunity to be heard on its application and constituted disparate

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treatment given the SBA’s repeated willingness to accept and consider supplemental information

from other SVOG applicants.

PRAYER FOR RELIEF

For the foregoing reasons, Creation respectfully requests that this Court:

90. Declare unlawful and unconstitutional Defendants’ denial of Creation’s SVOG

award request and set such denial aside.

91. Preliminarily and permanently order Defendants to consider Creation’s application

for an SVOG award consistent with applicable law and the evidence before the SBA.

92. Preliminarily and permanently order Defendants to award Creation

$9,699,500.00 in SVOG funds.

93. Preliminarily and permanently order Defendants to grant Creation a

supplemental SVOG award of $300,500.00.

94. Preliminarily and permanently order Defendants to retain appropriations from the

Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (Pub. L. No. 116-260

§ 324) and/or the American Rescue Plan (Pub. L. No. 117-2 § 5005(b)) in an amount sufficient to

fund Creation’s SVOG initial and supplemental grant awards.

95. Award Plaintiff its costs and reasonable attorney fees; and

96. Grant such other and further relief as the Court deems just and proper.

Dated: August 19, 2022

Respectfully submitted,

/s/ Jeffrey E. McFadden
Jeffrey E. McFadden
D.C. Bar No. 434234
LAW OFFICES OF JEFFEREY E.
MCFADDEN

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312 Prospect Bay Drive E.
Grasonville, MD 21638-1181
410-490-1163
jmcfadden@jmcfaddenlaw.com

Tyler W. Hudson
D.C. Bar No. 485971
Eric D. Barton
(pro hac vice application to be filed)
WAGSTAFF & CARTMELL LLP
4740 Grand Ave., Suite 300
Kansas City, MO 64112
816-701-1100
thudson@wcllp.com
ebarton@wcllp.com

Matthew S. Mokwa
(pro hac vice application to be filed)
THE MAHER LAW FIRM, PA
398 West Morse Blvd., Suite 200
Winter Park, FL 32789
407-839-0866
mmokwa@maherlawfirm.com

Counsel for Plaintiff

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