Motion for Leave to File Consolidated Amended Complaint (Nunc Pro Tunc) — Shao v. Customers Bancorp (E.D. Pa., Dkt. 37)

Summary

Yang Shao, appearing pro se, filed this motion in Case Number 25-cv-02640 in the Eastern District of Pennsylvania against Customers Bancorp, Inc., Customers Bank and others. The named defendants include Chairman Jay Sidhu, Customers Bank President and CEO Sam Sidhu, SBA National Sales Manager Karl Danielian, Rosemary Dente of SBA Servicing and Liquidation, and Illinois notary Tamara R. Thompson. Shao asks leave to file her Consolidated Amended Complaint nunc pro tunc to July 15, 2025, combining her amended complaint with two additional pieces of supporting evidence. She says she was unaware that Federal Rule of Civil Procedure 15(a)(2) requires consent or leave for any amendment after the first, and that she cannot speak or understand spoken English and relies on translation tools.

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Cite this document

“Motion for Leave to File Consolidated Amended Complaint (Nunc Pro Tunc) — Shao v. Customers Bancorp (E.D. Pa., Dkt. 37).” Original at ecf.paed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/amended-complaint-shao-v-customers-bancorp-dkt-37-e-d-pa-cbfb35900e/, SHA-256 6301766e7cda5ce7902d8ccd7947babb91bb7812bb194232a61d337e48b42bed.

Full text

 Case 2:25-cv-02640-KSM                    Document 37        Filed 08/13/25   Page 1 of 4



 YANG SHAO
 524 E 14TH AVE NAPERVILLE
 IL 60563
 shaoyang_suny@163.com
 Plaintiff




                               UNITED STATES DISTRICT COURT
                             EASTERN DISTRICT OF PENNSYLVANIA


  Yang Shao

                                                               Case Number：25-cv-02640
            Plaintiff,

 vs.

Customers Bancorp, Inc.
Publicly traded holding company (NASDAQ: CUBI)
Address: 701 Reading Avenue, West Reading, PA 19611
                                                               PLAINTIFF’S MOTION FOR
Customers Bank
Pennsylvania-chartered bank, wholly owned subsidiary of        LEAVE TO FILE
Customers Bancorp                                              CONSOLIDATED AMENDED
Address: 701 Reading Avenue, West Reading, PA 19611            COMPLAINT (NUNC PRO
Jay Sidhu
                                                               TUNC)
Chairman of Customers Bancorp and Executive Chairman of
Customers Bank
Address: 701 Reading Avenue, West Reading, PA 19611
                                                               Jury Trial Demanded
Sam Sidhu
President and CEO of Customers Bank, Vice Chairman of
Customers Bancorp
Address: 701 Reading Avenue, West Reading, PA 19611

Karl Danielian
Senior Vice President of Customers Bank, SBA National Sales
Manager
Address: 40 General Warren Blvd, Malvern, PA 19355

Rosemary Dente
Vice President, SBA Servicing and Liquidation, Customers
Bank
Address: Remote office, listed business address: 521 Park
Avenue, Freehold, NJ 07728

Tamara R. Thompson
Illinois Notary Public, Owner of Tamara R. Thompson
Consulting, LLC
Address: 718 W Vermont St, Villa Park, IL 60181
  et al.,
            Defendants
   Case 2:25-cv-02640-KSM      Document 37     Filed 08/13/25   Page 2 of 4




PLAINTIFF’S MOTION FOR LEAVE TO FILE CONSOLIDATED
AMENDED COMPLAINT (NUNC PRO TUNC)


Plaintiff Yang Shao respectfully moves this Court for leave to file her
Consolidated Amended Complaint nunc pro tunc, and in support thereof
states as follows:



1. Procedural Background


On July 15, 2025, Plaintiff filed her “Plaintiff’s Amended Complaint in
Opposition to Defendant’s Motion to Dismiss or Stay.” Subsequently,
Plaintiff submitted two additional pieces of supporting evidence. For
purposes of clarity and judicial economy, Plaintiff consolidated these into a
single “Plaintiff’s Consolidated Amended Complaint.”



2. Compliance with Federal Rule of Civil Procedure 15


Plaintiff respectfully apologizes to the Court. Due to her financial hardship,
Plaintiff can only appear pro se, cannot speak or understand spoken English,
and relies solely on translation tools to read and write in English. Plaintiff
also has no knowledge of U.S. legal procedures. Therefore, she was unaware
that, under Federal Rule of Civil Procedure 15(a)(2), any amendment after
the first requires the written consent of all opposing parties or leave of the
Court. Plaintiff now respectfully requests that the Court grant leave for this
amendment nunc pro tunc to July 15, 2025, and deem the Consolidated
Amended Complaint the operative pleading in this case.



3. Good Cause for Relief
   Case 2:25-cv-02640-KSM      Document 37      Filed 08/13/25   Page 3 of 4




Plaintiff filed the consolidated pleading in good faith, without intent to cause
delay or prejudice to Defendants. The consolidation was intended to improve
efficiency and avoid confusion, and Defendants have suffered no prejudice
from the timing or manner of the filing.



4. Interests of Justice



Granting this motion will serve the interests of justice by allowing the Court
and the parties to proceed on a single, accurate, and complete operative
pleading that reflects all relevant allegations and supporting evidence.



WHEREFORE, Plaintiff respectfully requests that this Court grant leave to
file the Consolidated Amended Complaint nunc pro tunc to July 15, 2025,
deem it the operative pleading in this action, and grant such other relief as
the Court deems just and proper.



Attachments:



1. Consolidated Amended Complaint


2. Supporting Exhibits 1–64
 Case 2:25-cv-02640-KSM        Document 37      Filed 08/13/25    Page 4 of 4




        RESPECTFULLY SUBMITTED this 12th day of August 2025.
                                     /s/ Yang Shao
                                        YANG SHAO

                                                   YANG SHAO
                                                   524 E 14TH AVE
                                                   NAPERVILLE IL
                                                   60563
                                                   shaoyang_suny@163.com
                                                   Plaintiff

ORIGINAL of the foregoing e-filed
this 12th day of August, 2025, with:

Clerk of the Court–United States District Court for the Eastern District of Pennsylvania



 /s/ Yang Shao

 YANG SHAO

File and source

File: 37-amended-complaint.pdf
Size: 345,270 bytes
SHA-256: 6301766e7cda5ce7902d8ccd7947babb91bb7812bb194232a61d337e48b42bed
Our copy: 37-amended-complaint.pdf
Original: PACER (login required)