Exhibit B — DV Diamond Club v. SBA (Dkt. 32-2, E.D. Mich.)

Summary

Exhibit B in DV Diamond Club of Flint, LLC v. U.S. Small Business Administration (E.D. Mich.), Case No. 4:20-cv-10899, filed April 29, 2020 as ECF No. 32-2. It is an April 29, 2020 letter from the U.S. Department of Justice, Civil Division, to Bradley J. Shafer and Matthew J. Hoffer, responding to the plaintiffs' April 23, 2020 notice of deposition. It sets out some of the grounds on which the SBA objects to the noticed topics and states that many of them are irrelevant and overly broad. It objects to Topic 1, on the meaning of "prurient sexual nature," as overly broad and as calling for a legal conclusion, calls the administration topics irrelevant to the facial challenge to 13 C.F.R. § 120.110(p), and states that SBA, not a lender, makes the final decision on eligibility. The signature block names Indraneel Sur, Trial Attorney.

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