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JOINT RULE 26(f) CONFERENCE REPORT

Date
2025-05-02

Summary

A Joint Rule 26(f) Conference Report filed May 2, 2025 as Document 87 in United States of America ex rel. Paul Pietschner v. Kathryn Petralia, Robert Frohwein and Spencer Robinson, Civil Action No. 4:21-cv-110-SDJ, in the U.S. District Court for the Eastern District of Texas, Sherman Division. The report sets out the Government's synopsis, which alleges the defendants, executives of Kabbage, Inc., caused false claims to the Small Business Administration over Paycheck Protection Program loans under 31 U.S.C. §§ 3729–3733, and the defendants' synopsis disputing those claims. It notes pending motions to dismiss (ECF Nos. 65, 66, 67, and 68), a related bankruptcy case, No. 22-10951, and initial disclosures served April 28, 2025. The parties propose schedules with a trial date in November 2026 (defendants) or April 2027 (Government). The report closes with counsel signature blocks.

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Full text

Case 4:21-cv-00110-SDJ          Document 87        Filed 05/02/25      Page 1 of 15 PageID #: 892




                        IN THE UNITED STATES DISTRICT COURT
                         FOR THE EASTERN DISTRICT OF TEXAS
                                 SHERMAN DIVISION

  UNITED STATES OF AMERICA
  ex rel. PAUL PIETSCHNER,

  Plaintiff,
                                                       Civil Action No.: 4:21-cv-110-SDJ
  v.

  KATHRYN PETRALIA;
  ROBERT FROHWEIN; and
  SPENCER ROBINSON,

  Defendants.

                         JOINT RULE 26(f) CONFERENCE REPORT

 TO THE HONORABLE UNITED STATES DISTRICT JUDGE:

        COME NOW, Plaintiff United States of America (“United States” or the “Government”),

 Relator Paul Pietschner (“Relator”), and Defendants Kathryn Petralia, Robert Frohwein, and

 Spencer Robinson (collectively referred to as the “Parties”), and file this Joint Report pursuant to

 this Court’s Order Governing Proceedings, ECF No. 69:

        1.      A brief factual and legal synopsis of the case.

        This is an action against three executives of a former financial technology company,
 Kabbage, Inc., that participated in the Paycheck Protection Program (“PPP”) as a direct lender and
 processor of PPP loans beginning in April 2020. The United States seeks to recover treble damages
 and civil penalties under the False Claims Act, 31 U.S.C. §§ 3729–3733 (“FCA”), and to recover
 on federal common law or equitable causes of action for payment by mistake and unjust
 enrichment. Specifically, the Government’s Complaint in Intervention (“Government’s
 Complaint”) alleges that Frohwein, Petralia, and Robinson (collectively “Defendants”), violated
 the FCA by submitting, causing the submission of, and conspiring to submit false claims and
 statements to the United States Small Business Administration (“SBA”) for payment of processing
 fees and forgiveness and guaranty payments of certain PPP loans.

        The United States has intervened in this qui tam action, originally filed by Relator in 2021
 under 31 U.S.C. § 3730(b), against Kabbage, Inc. (“Kabbage”) and Defendants. See ECF Nos. 1,
 28, 34. Kabbage is no longer a part of this action, as it settled its liability with the United States
 in 2024 and was dismissed by stipulation. See ECF Nos. 30. 31. Because the Government has

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 intervened as to all claims against Defendants, “it shall have the primary responsibility for
 prosecuting the action.” 31 U.S.C. § 3730(c)(1). The Relator is not independently pursuing any
 non-intervened claims in this litigation.

          Pending before the Court are the Defendants’ joint and individual motions to dismiss. ECF
 Nos. 65, 66, 67, and 68 (the “Dismissal Motions”). Defendants argue that the Government has not
 pleaded any claim with the requisite specificity of Fed. R. Civ. P 9(b), and also seek dismissal of
 this action under Fed. R. Civ. P. 12(b)(2) and (3), contending that this Court is not a proper venue
 for this action and that this Court lacks personal jurisdiction over Defendants. The Government
 has filed its Omnibus Response in Opposition to Defendants’ motions to dismiss. ECF No. 72 (the
 “Opposition”). Briefing on these motions is due to complete by May 30, 2025. ECF No. 64.

        Government’s Factual Synopsis

         The United States alleges that Defendants knowingly directed and controlled Kabbage to
 inflate PPP loan amounts by systematically double-counting employees’ state and local taxes and
 by including annual per employee compensation in excess of $100,000 in calculating borrowers’
 average monthly payroll; to approve loans without confirming receipt of information
 demonstrating that borrowers had employees for whom the borrowers paid salaries and payroll
 taxes; and to participate in the PPP without sufficient fraud controls as required to comply with
 PPP requirements.

        At all relevant times, Frohwein, Petralia, and Robinson were, respectively, CEO, President,
 and Head of Strategy at Kabbage. Defendants caused Kabbage to participate in PPP to save the
 company from financial distress and used PPP to increase Kabbage’s value in preparation of an
 asset sale, from which Defendants earned lucrative payouts. As described in detail in the
 Government’s Complaint, each Defendant was repeatedly warned by third parties and its own
 employees that its PPP loan calculation methodology was systematically miscalculating PPP loan
 amounts, yet they chose to do nothing to investigate or fix the calculation. Additionally, each
 Defendant knew prior to PPP that its fraud controls and identity verification were insufficient, and
 each was warned by Kabbage employees that Kabbage’s review processes for PPP resulted in the
 approval of obviously fraudulent and ineligible borrowers, yet, they again chose to do nothing.
 Rather they expressly declined to pause processing of PPP loan applications. As a result of their
 conduct, Defendants knowingly submitted, caused the submission of, and conspired to submit
 thousands of false or fraudulent claims and statements to the United States, which resulted in the
 SBA’s payment of millions of dollars for processing fees and loan forgiveness and guaranty
 purchase payments on PPP loans that were ineligible for payment. The United States also alleges
 that Defendants were unjustly enriched as a result of their conduct, and the United States made
 payments by mistake for which Defendants are individually liable.

         As stated more fully in the Opposition, this Court has personal jurisdiction over defendants
 and venue lies in this district. This Court has venue and personal jurisdiction over all defendants
 in this action under Fed. R. Civ. Pro. 4(k)(1)(C) and 31 U.S.C. § 3732(a), which extends
 nationwide service of process to a federal court in “any judicial district in which . . . any one
 defendant can be found, resides, transacts business, or in which any act proscribed by section 3729
 occurred.” When Relator filed his Complaint in 2021, Kabbage, then a defendant, was transacting

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 business in this district at the time; in addition, the Complaint alleges FCA violations that occurred
 in this judicial district. See 31 U.S.C. § 3732(a). Constitutional due process is satisfied under the
 applicable national contacts analysis because all Defendants are U.S. residents.

         Contrary to the arguments in Defendants’ Synopsis, below, the Government has
 sufficiently alleged all the elements of its FCA and common law claims, for the reasons stated in
 the Opposition. Defendants’ Synopsis generally ignores allegations about the systematic loan
 calculation errors that occurred with Defendants’ knowledge and under Defendants’ direction and
 control. As to particular elements, first, the Government has sufficiently alleged materiality under
 the False Claims Act and the Supreme Court’s opinion in Universal Health Servs., Inc. v. United
 States ex rel. Escobar, 579 U.S. 176, 193 (2016), which requires a holistic analysis. Not only did
 the false statements and certifications that Defendants submitted and caused have a tendency to
 influence SBA’s payment decision, as required under the FCA, but they also satisfy Escobar’s
 materiality standard, where they are violations of a condition of payment, implicate millions of
 dollars in processing fees and inflated loan amounts, and ran contrary to the essence of the
 arrangement between SBA and PPP lenders. Second, the Government has sufficiently alleged a
 conspiracy, by alleging facts supporting a reasonable inference that Defendants agreed to commit
 FCA violations by submitting false claims to the SBA and alleging at least one act in support of
 that conspiracy. Dismissal of the FCA conspiracy claim is not appropriate because specific intent
 to defraud is not an element under the FCA, and the intra-corporate conspiracy doctrine does not
 and should not apply to FCA cases. Moreover, each Defendant had his or her own personal stake
 in Kabbage’s PPP participation and received lucrative payouts as a result of their conduct. Lastly,
 the Government has sufficiently alleged its common law claims, unjust enrichment and payment
 by mistake, as a direct benefit by the Government to Defendants is not required pursuant to those
 doctrines, and the Government has adequately alleged that the Government conferred a benefit on
 Defendants in its Complaint.

        Defendants’ Synopsis

         Defendants dispute the allegations and claims raised in the Complaint, which wrongfully
 seek to use the FCA to shift blame for the consequences of the SBA’s design and administration
 of the PPP to Defendants, each former executives of the fintech company, Kabbage, which was
 founded in 2009 to provide capital to underserved small businesses. In short, Defendants did not
 participate in any scheme or conspiracy to defraud the government, nor can they be individually
 liable for either Kabbage’s or borrowers’ purported false claims for payment. To establish liability
 under the FCA (see Counts I-III), the Government must prove by a preponderance of the evidence:
 (i) that Defendants submitted or caused to be submitted a false claim or statement to the
 government, (ii) that Defendants’ knew of its falsity, and (ii) that the claim was material to the
 Government’s payment decision. The Government cannot satisfy its burden on any element.

          Defendants did not knowingly submit or cause to be submitted any false statements or
 claims for payment. The SBA directed lenders like Kabbage to relax their underwriting standards,
 conduct no more than a “good faith review” of borrower applications, and rely on borrower
 attestations in order to get money into the hands of small business as quickly possible. Kabbage
 did that and more, using robust controls to detect and report fraud. As far as Defendants knew,
 Kabbage’s processes—which were developed by a team of highly-skilled Kabbage employees who

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 had deep experience in SBA lending, were in regular contact with the SBA, and carefully reviewed
 the SBA guidance—complied with applicable PPP regulations. At company-wide town hall
 meetings that Defendants hosted, Defendants and other members of Kabbage’s leadership team
 stressed that employees should reject and report suspected PPP fraud, and, to the extent issues or
 concerns about Kabbage’s PPP processes were raised to Defendants at town hall meetings or
 otherwise, they dealt with them appropriately.

         Moreover, Kabbage’s statements or certifications were not material to the Government’s
 payment decisions, especially considering the government’s knowledge of the widespread fraud
 in the PPP and its continued payments in spite of it. The SBA was well-aware of risks of fraud in
 the PPP and nonetheless specifically designed the program to have minimal lending requirements
 and a streamlined application process to encourage participation and distribute capital to small
 businesses as quickly as possible. By design, the SBA’s streamlined loan application and review
 process rested largely on borrower attestations regarding the accuracy of their applications, not
 lenders’ statements or certifications. As a result, the Government cannot meet the FCA’s
 “rigorous” and “demanding” materiality standard. Universal Health Servs., Inc. v. U.S. ex rel.
 Escobar, 579 U.S. 176, 192-94 (2016).

         Like its other FCA claims, the Government’s conspiracy claim (Count III) also fails. To
 state a conspiracy claim under the FCA, the Government must establish (1) the existence of an
 unlawful agreement between defendants to get a false or fraudulent claim allowed or paid, (2) at
 least one act performed in furtherance of that agreement, and (3) the Defendants shared specific
 intent to defraud the Government. Critically, however, under the intra-corporate conspiracy
 doctrine, employees who are acting within the scope of their employment cannot conspire among
 themselves. U.S. ex rel. Head v. Kane Co., 798 F. Supp. 2d 186, 201 (D.D.C. 2011) (internal
 citation omitted). Because the Defendants were all Kabbage employees and indisputably acting
 within the scope of their employment at the time of the alleged conspiracy, the Government’s
 conspiracy claim fails as a matter of law.

         Equally flawed are the Government’s common law claims for unjust enrichment and
 payment by mistake. It is beyond dispute that the SBA paid Kabbage—and not any of the
 Defendants, individually—for services Kabbage provided under the PPP. Because the Defendants
 did not, and could not have, received any direct benefit from the fees the SBA paid Kabbage, the
 Government’s claims for unjust enrichment and payment by mistake also fall flat. See, e.g., U.S.
 ex rel. Silva v. VICI Mktg., LLC, 361 F. Supp. 3d 1245, 1257-58 (M.D. Fla. 2019) (dismissing
 where defendant did not directly benefit); Gearhart v. Express Scripts, Inc., 422 F. Supp. 3d 1217,
 1226-27 (E.D. Ky. 2019) (rejecting unjust enrichment claim where “at least two steps” separated
 any benefit from plaintiff to defendant).

        2.      The jurisdictional basis for this suit.

         The Parties agree that this Court has federal question subject matter jurisdiction over this
 action arising under the FCA and federal common law pursuant to 28 U.S.C. §§ 1331 and 1345.

         Defendants Petralia, Frohwein, and Robinson have each disputed this Court’s personal
 jurisdiction over him or her, as set forth in the Dismissal Motions. As stated in its Opposition and

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 summarized above, the United States contends that this Court may exercise personal jurisdiction
 over all defendants in this action under Fed. R. Civ. Pro. 4(k)(1)(C) and 31 U.S.C. § 3732(a).

         While Defendants have separately moved to stay discovery pending the Court’s order on
 their legal jurisdictional claims, by submitting this report and/or participating in this Court-
 mandated discovery, Defendants do not waive and expressly preserve their objection to this
 Court’s personal jurisdiction over them.

        3.      A list of the correct names of the parties to this action and any anticipated
                additional or potential parties.

         The Parties’ names are correctly listed in the caption. The Plaintiff is the United States of
 America. Defendants are Kathryn Petralia, Robert Frohwein, and Spencer Robinson. The Relator
 is Paul Pietschner.

        At this time, the United States does not anticipate additional potential parties.

        4.      A list of any cases related to this case pending in any state or federal court,
                identifying the case numbers and courts along with an explanation of the status
                of those cases.

       In re: K-Servicing Wind Down Corp. et al, No. 22-10951 (D. Del. Bankr.), which is
 ongoing with an Omnibus Hearing scheduled for June 2, 2025.

        5.      Confirmation that the initial disclosures required by Rule 26(a)(1) and this
                Order have been completed.

          The parties served their initial disclosures on April 28, 2025. The United States will make
 its initial disclosure document production on May 2, 2025.

        6.      Proposed scheduling order deadlines.

         Filed as an attachment to this report is a scheduling order with each of the parties’ proposed
 schedules. The parties have deviated from the standard schedule by extending certain deadlines
 in view of the complexity of the case, the number of defendants and claims at issue in this case,
 and the anticipated fact and expert discovery. On the whole, the parties’ proposals extend the case
 schedule beyond the Court’s default schedule, with Defendants proposing a trial date in November
 2026 and the Government proposing a trial date in April 2027. The parties anticipate that
 discovery will be extensive, as reflected by the parties’ joint proposal to conduct more depositions
 than provided for by Fed. R. Civ. P. 30(a)(2)(A). To promote efficiency and avoid unnecessary
 costs in the event of an early resolution, the parties jointly propose to bifurcate fact and expert
 discovery. The parties also seek to provide sufficient time to rule on dispositive motions before




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 the parties begin final trial preparation. Finally, the parties seek to extend the Final Pretrial
 Conference and anticipated trial date to November 2026 or April 2027. 1

        7.      Description, in accordance with Rule 26(f), of the following:

                (i)     The subjects on which discovery may be needed, when discovery should
                        be completed, and whether discovery should be conducted in phases or
                        be limited to or focused on particular issues.

         The parties do not believe that fact discovery should be conducted in phases or be limited
 to or focused on particular issues. The parties have proposed to bifurcate fact and expert discovery.
 Defendants propose a January 31, 2026 deadline for the completion of fact discovery; the
 Government proposes a deadline of June 4, 2026.

 The United States’ Position

         Discovery will be needed on all issues raised in the United States’ Complaint, any
 amendments thereto, and any defenses raised in Defendants’ answers, including but not limited to
 the following subjects:

             a. All matters on which Defendants invoked their Fifth Amendment rights;

             b. Funds received directly and indirectly by Kabbage and Defendants from the United
                States;

             c. Communications between Defendants, Kabbage, and any U.S. government official
                relating to the PPP;

             d. Materials in Defendants’ custody, possession, and control which they may use to
                undercut the United States’s claims, to the extent they were not already provided to
                the Government in response to Civil Investigative Demands;

             e. The number of false or fraudulent claims, and the damages to the United States
                from any false or fraudulent claim;

             f. Each Defendant’s liability for the conduct alleged in the United States’ Complaint;

             g. Whether any Defendant knowingly submitted or caused to be submitted to the SBA
                any false or fraudulent claim;

             h. Whether any Defendant knowingly made, used, or caused to be made or used, a false
                record or statement material to a claim to the SBA relating to the PPP;


        1     If the Court grants Defendants’ motion to stay discovery, the parties will submit a
 new proposed scheduling order, if necessary, upon the Court’s ruling on Defendants’ jurisdictional
 claims.
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            i. Whether any Defendant conspired to submit or caused to be submitted any false or
               fraudulent claim to the SBA relating to the PPP;

            j.   Whether any Defendant conspired to make, use, or cause to be made or used, a false
                 record or statement material to a claim to the SBA relating to the PPP;

            k. Whether Kabbage and any Defendant submitted to the SBA claims for PPP loan
               processing fees, PPP loan payment, forgiveness, and guaranty, for miscalculated,
               inflated loan amounts, fraudulent PPP loans, or PPP loans Kabbage failed to perform
               a good faith review of supporting documentation;

            l. Communications between Defendants and Kabbage’s lender partners relating to
               PPP;

            m. Communications between Defendants and Kabbage’s consultants retained to
               review Kabbage’s processes relating to PPP;

            n. Communications between Defendants relating to American Express and American
               Express’s potential acquisition of Kabbage;

            o. Defendants’ affirmative defenses; and

            p. Expert discovery for disclosed experts.

 Discovery of these subjects may result in discovery of third parties, including KServicing Wind
 Down Corp. (formerly known as Kabbage, Inc.) and American Express, which is custodian for
 many records of Kabbage, Inc.

 Defendants’ Position

         Defendants require fact discovery on the following subjects: materials that the government
 received during the course of its investigation and that form the basis of its complaint; the alleged
 false or fraudulent claims submitted to the SBA; specific PPP applications that the government
 alleges were falsely submitted; the government’s knowledge and evaluation of the existence of
 fraud in the PPP; the SBA and other government officials’ guidance concerning PPP lender
 requirements and PPP applicant eligibility; Kabbage’s participation in the PPP; Kabbage’s
 BSA/AML program; the SBA’s use, approval, evaluation, or assessment of PPP loan applications;
 Kabbage’s communications with the SBA and other government officials.

 Defendant Robinson’s Position (in addition to Defendants’ Position)

         Documents and communications with Kabbage and within SBA and/or Treasury related to
 identifying Kabbage loan files to review or audit and the reasons for such potential reviews or
 audits;


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         Documents and communications with Kabbage and within SBA and/or Treasury related to
 whether Government employees or contractors suspected fraud or calculation errors in Kabbage
 loan files and any actions they took as a result;

        Documents and communications with Kabbage and within SBA and/or Treasury related to
 Kabbage disclosing its loan calculation and verification methodologies to the Government,
 including but not limited to in response to SBA requests for Kabbage loan files;

         Kabbage’s communications and cooperation with law enforcement related to
 investigations of PPP loan applicants, including but not limited to the FBI, SBA OIG, Treasury
 OIG, or IRS;

        Documents and communications within SBA and/or Treasury related to whether
 Government employees or contractors auditing or reviewing loan files from other lenders
 suspected fraud or calculation errors in those loan files and any actions they took as a result;

        Documents and communications within SBA and/or Treasury related to whether other
 lenders made the “SALT Error” and any actions taken as a result;

         Documents and communications within SBA and/or Treasury related to whether any other
 lenders accepted borrower representations about the number of employees making more than
 $100,000 annually without further payroll documentation review or mathematical checks or
 verifications as a result;

          Documents and communications within SBA and/or Treasury related to whether any other
 lenders did not do a “good faith review” of PPP applications or failed to maintain an acceptable
 BSA/AM system, and any actions taken as a result, including but not limited actual or threatened
 litigation against those lenders;

        All SARs or other communications from Kabbage’s partner banks reporting suspicions or
 concerns about any Kabbage PPP applicants or Kabbage’s processes for reviewing and approving
 PPP loans

        All actions taken in response to any SARs filed by Kabbage with respect to any PPP loan
 applications

        Documents and communications within SBA and/or Treasury related to whether lenders
 should approve or not approve PPP loan applications where the lenders could not confirm fraud or
 inaccuracies.

        Purpose, development, and implementation of the Paycheck Protection Program (“PPP”);

        Purpose, development, and implementation of all guidance issued pursuant to the PPP;

        Participation of non-bank lenders in the PPP, including financial technology companies;


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        Kabbage,1 including its participation in the PPP as a direct lender and service provider;

        PPP loan applications reviewed or submitted by Kabbage and/or KServicing2;

        PPP loan forgiveness applications reviewed or submitted by Kabbage and/or KServicing;

        PPP lender loan review requirements;

        The likelihood and prevalence of fraud in the PPP;

        PPP applications submitted by Celtic Bank;

        PPP applications submitted by Cross River Bank;

        The SBA’s Office of Inspector General Reports concerning the PPP;

               (ii)    Any issues relating to disclosure or discovery of electronically stored
                       information (“ESI”), including the form or forms in which it should be
                       produced (whether native or some other reasonably usable format) as
                       well as any methodologies for identifying or culling the relevant and
                       discoverable ESI. Any disputes regarding ESI that counsel for the
                       parties are unable to resolve during their conference must be identified
                       in the report.

        At the Rule 26(f) conference, counsel for each party agreed that an ESI order governing
 the production of ESI in this matter should be adopted and utilized in the litigation. On April 24,
 2025, the parties jointly moved the Court to enter an agreed-upon ESI order.

              (iii)     Any agreements or disputes relating to asserting claims of privilege or
                        preserving discoverable information, including ESI and any
                        agreements reached under Federal Rule of Evidence 502 (such as the
                        potential need for a protective order and any procedures to which the
                        parties might agree for handling inadvertent production of privileged
                        information and other privilege waiver issues). A party asserting that
                        any information is confidential should immediately apply to the Court
                        for entry of a protective order.

        At the Rule 26(f) conference, counsel for each party agreed that a protective order should
 be adopted and utilized in the litigation. Counsel also agreed that the parties’ exchange of
 discovery and other evidence would be subject to a claw-back agreement relating to the inadvertent
 disclosure of privileged or potentially privileged information. The Court has entered agreed-upon
 ESI, protective, and Rule 502(d) clawback orders.

              (iv)     Any changes that should be made in the limitations on discovery
                       imposed by the Rules, whether federal or local, and any other
                       limitations that should be imposed.

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         The Government proposes 20 fact depositions per side, excluding any depositions required
 to take discovery on any advice of counsel defense that Defendants may assert. Defendants propose
 30 fact depositions per side.

               (v)     Whether any other orders should be entered by the Court pursuant to
                       Federal Rule of Civil Procedure 26(c) or Rule 16(b), (c).

       The parties are in discussions concerning a potential additional order to govern the
 exchange of privilege logs.

        8.      Statement of the progress made toward settlement and the present status of
                settlement negotiations, including whether a demand and/or an offer has been
                made. If the parties have agreed upon a mediator, also state the name, address,
                and phone number of that mediator and a proposed deadline for mediation.
                An early date is encouraged to reduce expense. The Court will appoint a
                mediator if none is agreed upon.

         The United States received a settlement offer from Defendant Petralia on November 22,
 2024, and made a counter-offer to Defendant Petralia on the same day, but has not received a
 further response. The United States received a settlement offer from Defendant Robinson on
 February 12, 2025, and made a counter-offer on February 24, 2025. Robinson rejected that
 demand and has not made a counter. The United States has not made a settlement demand to, or
 received a settlement offer from, Defendant Frohwein. At the Rule 26(f) conference, the United
 States conveyed to counsel for Defendants that it is ready, willing, and able to discuss settlement
 at any time. Counsel for Defendants conveyed that it is premature to discuss settlement at this
 time. The parties anticipate that settlement discussions may be more productive after the Court
 has ruled on the Defendants’ motions to dismiss. The parties will agree upon a mediator by the
 deadline set forth in Appendix 1 (or advise the Court in the event they cannot reach an agreement).

        9.      The identity of persons expected to be deposed.

        The United States expects to depose Defendants and various third parties, including at least
 the former employees of Kabbage listed in the table below, and current or former employees of
 Kabbage’s lender partners, including Customers Bank, and Cross River Bank, Wells Fargo Bank,
 and Kabbage’s consultants, including Alvarez & Marsal. The Government anticipates the need
 for additional persons to be deposed as discovery proceeds.

              Name                                            Title 2
  Kate Prince                       Former Executive Assistant, Kabbage
  Syed Ashekeen                     Former New Products Analyst, Kabbage
  Nipun Goel                        Former Head of Lend Ops, Strategy, Kabbage
  Hirsh Gaikwad                     Former Strategic Analyst, Kabbage
  Rohit Bothra                      Former Data Science Analyst, Kabbage


        2       Names and titles are based on documents and information currently available to the
 United States. The United States reserves the right to amend this list as discovery proceeds.
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  Anthony Sabelli                  Former Head of Data Science, Kabbage
  James Hayes                      Former Director of FP&A, Kabbage
  Sam Taussig                      Former Head of Global Policy, Kabbage
  Kristel Adler                    Former Head of Deposits and Savings, Kabbage
  David McGowan                    Former Head of Technology, Kabbage
  Nan Siler                        Former Head of Payment Operations, Kabbage
  Deepesh Jain                     Former Head of Capital Markets, Kabbage
  Nicole Hill                      Former Head of Fraud, Kabbage
  Krishnakumar Srinivasan          Former Chief Analytics Officer, Kabbage
                                   Former Vice President, Credit Risk & Analytics; Acting
  Amit Kesarwani
                                   Head of Fraud
  Bryanna Simpson                  Former Fraud Analyst, Kabbage
  Siddharth Shah                   Former Risk Analyst, Kabbage
  Taylor Suiter                    Former SBA Loan Rep, Kabbage
  Laura Goldberg                   Former Chief Revenue Officer, Kabbage
  Paul Bernardini                  Former Head of Communications, Kabbage
  Kara Baker                       Former Payment and Finops Lead, Kabbage
  William Bowden                   Former Director of Collection & Risk Revenue, Kabbage
                                   Former Head of Tax & Treasury, Kabbage; and Former
  Daniel Eidson
                                   CFO, KServicing

        Defendants expect to depose various third parties, including at least current and former
 employees of Kabbage and the SBA, as set forth in the table below, as well as current and former
 employees of Kabbage’s bank partners, Cross River Bank and Customers Bank. Defendants
 anticipate the need for additional persons to be deposed as discovery proceeds.

            Name                                           Title 3
                                 Former Kabbage Employees
                               Former Vice President, Credit Risk & Analytics; Acting Head of
  Amit Kesarwani
                               Fraud
  Azba Habib                   Former Assistant General Counsel
  Bryanna Simpson              Former Manager, Risk Management
  Clint Hill                   Former Head of Architecture and Information Security
  David McGowan                Former Chief Technology Officer
  Elizabeth Maiellaro          Former Counsel
  Emma Blackburn               Former Customer Service Employee
  Hirsh Gaikwad                Former Product and Strategy
  Jessica Robinson             Former Risk Analyst
  Kristel Adler                Former Head of New Products
  Latinga Maxfield             Former Employee (Title Unknown)
  Laura Goldberg               Former Chief Revenue Officer



        3     Names and titles are based on documents and information currently available to
 Defendants. Defendants reserve the right to amend this list as discovery proceeds.
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  Leslie Scott Askins           Former General Counsel
  Nan Siler                     Former Head of Payments Strategy and Operations
  Nipun Goel                    Former Head of Lend Operations Strategy
  Sam Taussig                   Former Head of Policy
  Syed Ashekeen                 Former Product Lead
  Tawana Tillard                Former Risk Analyst
                                           SBA Officials
  Bill Briggs                   Nominee for Deputy Administrator
  Bill Manger                   Former Chief of Staff
  Brett Lehnert                 Special Agent
  Christopher Gray              Former Deputy Chief of Staff
  Christopher Ray               Former Special Agent, Office of Inspector General (“OIG”)
  Edward Ledford                Associate Director, Office of Credit Risk
                                Former Regional Director, Florida Small Business Development
  Eileen Rodriguez
                                Center
  Eric Benderson                Associate General Counsel for Litigation and Small Claims
  Hannibal (Mike) Ware          Inspector General
  Isabella Casillas Guzman      Former Administrator
  Janelle Jones                 Lender Relations Specialist
  Jasmin Gonzalez               Special Agent, OIG
  John Blackstock               District Director, New Jersey District
  John Miller                   Deputy Associate Administrator, Office of Capital Access
  Jon Block                     Former Loan Specialist
  Jonathan Harkless             Former Intern, Investigations Division, OIG
  Jovita Carranza               Former Administrator
  Juan Fernandez                Special Agent, OIG
  Kenneth Welch                 Certified Digital Fraud Examiner, OIG
  Michelle Blank                National Disaster Program Director, Investigations Division, OIG
  Minerva Perez                 Loan Specialist
  Miriam Gurruchaga             Special Agent
                                Former Associate Administrator for the Office of Capital Access,
  Patrick Kelley
                                from 2021-2023
  Paul Kirwin                   Supervisory Financial Analyst, Office of Credit Risk
  Ryan Kucera                   Special Agent
  Sara Oliver                   Special Agent, OIG
  Sheryl McConville             Deputy Director, Office of Performance Systems Management
  Timalyn Franklin              System Owner, Office of Performance Systems Management
  Wilbur Barras                 Title Unknown


        10.    Estimated trial time and whether a jury demand has been timely made.

        The parties jointly propose 3 weeks for a jury trial.

        All parties request trial by jury.
                                                12
Case 4:21-cv-00110-SDJ        Document 87        Filed 05/02/25     Page 13 of 15 PageID #: 904




        11.     The names of the attorneys who will appear on behalf of the parties at the
                management conference (the appearing attorney must be an attorney of
                record and have full authority to bind the client).

         For the United States: Assistant United States Attorney Betty Young of the Eastern District
 of Texas and attorneys Sarah Loucks and Kelly Phipps from the Civil Fraud Section of the United
 States Department of Justice’s Civil Division, Commercial Litigation Branch. The United States
 will be represented by the above-listed attorneys at the management conference, and this team will
 be able to negotiate any settlement that that they are willing to recommend for approval but will
 not have the “full authority to bind” the United States. See 28 C.F.R. §§ 0.160 and 0.161; 28
 U.S.C. §§ 472, 473(b)(5), (c); Fed. R. Civ. P. 16.

        For Relator: Julie Bracker and Sarah Frazier will appear in person on behalf of Relator.

        For Defendant Robert Frohwein: Miranda Hooker, Kate MacLeman, and Kara Czekai will
 appear in person on behalf of Mr. Frohwein.

        For Defendant Kathryn Petralia: George Varghese and Michaela Wilkes Klein will appear
 in person on behalf of Ms. Petralia.

        For Defendant Spencer Robinson: Henry Asbill and Chris Mead will appear in person on
 behalf of Mr. Robinson.

        12.     Whether the parties jointly consent to trial before a magistrate judge.

        The parties do not jointly consent to trial before a magistrate judge.

        13.     Any other matters that counsel deem appropriate for inclusion in the joint
                conference report or that deserve the special attention of the Court at the
                management conference.

        None at this time.




                                                 13
Case 4:21-cv-00110-SDJ      Document 87       Filed 05/02/25   Page 14 of 15 PageID #: 905




 Dated:       May 2, 2025                               Respectfully submitted,

  /s/ Melissa R. Smith__________                       /s/ Nicholas M. Mathews__________
  Melissa R. Smith                                     Nicholas M. Mathews
  Gillam & Smith LLP                                   Alexander J. Chern
  303 South Washington Ave.                            McKool Smith, PC - Dallas
  Marshall, TX 75670                                   300 Crescent Court, Suite 1500
  Telephone: (903) 934-8450                            Dallas, TX 75201
  Fax: (903) 934-9257                                  Telephone: (214) 978-4258
  melissa@gillamsmithlaw.com                           Fax: (214) 978-4044
                                                       Nmathews@mckoolsmith.com
  Anjan Sahni (pro hac vice)                           Achern@mckoolsmith.com
  Wilmer Cutler Pickering Hale and Dorr LLP
  7 World Trade Center, 250 Greenwich Street           Miranda Hooker (pro hac vice)
  New York, NY 10007                                   Kate E. MacLeman (pro hac vice)
  Tel: (212) 230-8800                                  Kara N. Czekai (pro hac vice)
  Fax: (212) 230-8888                                  Goodwin Procter LLP
  anjan.sahni@wilmerhale.com                           100 Northern Avenue
                                                       Boston, Massachusetts 02210
  Christopher E. Babbitt (pro hac vice)                Telephone: (617) 570-1000
  Michaela S. Wilkes Klein (pro hac vice)              Fax: (617) 523-1231
  Wilmer Cutler Pickering Hale and Dorr LLP            MHooker@goodwinlaw.com
  2100 Pennsylvania Avenue NW                          KMacLeman@goodwinlaw.com
  Washington, DC 20037                                 KCzekai@goodwinlaw.com
  Telephone: (202) 663-6000                            Counsel for Robert Frohwein
  Fax: (202) 663-6363
  christopher.babbitt@wilmerhale.com                   /s/ Henry W. Asbill
  michaela.wilkesklein@wilmerhale.com                  Henry W. Asbill (pro hac vice)
                                                       Christopher B. Mead (pro hac vice)
  George P. Varghese (pro hac vice)                    Lisa H. Schertler (pro hac vice)
  Wilmer Cutler Pickering Hale and Dorr LLP            Paola Pinto (pro hac vice)
  60 State Street                                      Schertler Onorato Mead & Sears
  Boston, MA 02109                                     555 13th Street NW Suite 500W
  Telephone: (617) 526-6000                            Washington DC 20004
  Fax: (617) 526-5000                                  Telephone: 202-628-4199
  george.varghese@wilmerhale.com                       Facsimile: 202-628-4177
  Counsel for Kathryn Petralia                         hasbill@schertlerlaw.com
                                                       cmead@schertlerlaw.com
                                                       lschertler@schertlerlaw.com
                                                       ppinto@schertlerlaw.com
                                                       Counsel for Spencer Robinson

  COUNSEL FOR DEFENDANTS




                                              14
Case 4:21-cv-00110-SDJ     Document 87    Filed 05/02/25   Page 15 of 15 PageID #: 906




  MICHAEL D. GRANSTON                      /s/ Julie Bracker (with permission)
  Deputy Assistant Attorney General        JULIE BRACKER
                                           Georgia Bar No. 073803
  ABE MCGLOTHIN, JR.                       Bracker & Marcus LLC
  Acting United States Attorney            3355 Lenox Road, Suite 660
  Eastern District of Texas                Atlanta, Georgia 30326
                                           E-mail: Julie@FCACounsel.com
  /s/ Betty S. Young__________             (770) 988-5035
  JAMES G. GILLINGHAM, Texas Bar #24065295 (678) 648-5544 (fax)
  BETTY S. YOUNG, Texas Bar #24102498
  Assistant U.S. Attorneys                 SARAH M. FRAZIER
  Eastern District of Texas                Texas Bar # 24027320
  110 N. College Street, Suite 700         Murphy Anderson PLLC
  Tyler, Texas 75702                       1919 Decatur Street
  E-mail: James.Gillingham@usdoj.gov       Houston, Texas 77007
  E-mail: Betty.Young@usdoj.gov            (202) 223-2620 ext. 116
  (903) 590-1400                           sfrazier@murphypllc.com
  (903) 590-1436 (facsimile)
                                           ATTORNEYS FOR RELATOR
  JAMIE A. YAVELBERG                       PAUL PIETSCHNER
  COLIN M. HUNTLEY
  SARAH E. LOUCKS
  KELLY E. PHIPPS
  Attorneys, Civil Division
  United States Department of Justice
  P.O. Box 261
  Ben Franklin Station
  Washington, D.C. 20044
  E-mail: Sarah.E.Loucks@usdoj.gov
  E-mail: Kelly.E.Phipps@usdoj.gov
  (202) 616-4203
  (202) 514-0280 (facsimile)

  ATTORNEYS FOR PLAINTIFF
  THE UNITED STATES OF AMERICA




                                         15


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