Exhibit 1 (Complaint) — Brandon Joe Williams v. SBA (C.D. Cal.)

Summary

Exhibit 1 to a notice of removal, filed November 5, 2024 as Document 1-1 in Brandon Joe Williams v. United States Small Business Administration, Case 2:24-cv-09553-RGK-SK, in the U.S. District Court for the Central District of California. It reproduces the complaint Williams filed against the SBA in Los Angeles County Superior Court, stamped September 20, 2024. The complaint states that Williams had an SBA disaster loan of $59,000 later expanded to $198,700, and alleges the SBA used his promissory notes as collateral under 12 U.S.C. § 412 so that he funded his own loan. It pleads eleven causes of action, including breach of contract, fraud, unjust enrichment and claims under California Penal Code § 496(a) and § 236.1. The 43-page exhibit also includes letters Williams sent to the SBA, among them an amended novation dated August 4, 2024.

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