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4-25-20 Payday Loan TRO Motion
4-25-20 Payday Loan TRO Motion
Pursuant to Fed. R. Civ. P. 65 and LCvR 65.1, Plaintiff Payday Loan, LLC d/b/a Payday
Money Centers moves for an emergency Temporary Restraining Order and Preliminary Injunction
against Defendants United States Small Business Administration (“SBA”), Jovita Carranza, in her
official capacity as Administrator of the SBA, and the United States of America (collectively,
“Defendants”): (1) to enjoin them from enforcing 13 C.F.R. § 120.110(b) (“Section 120.110(b)”)
to deprive Plaintiff of the right to apply for and obtain loans under the Paycheck Protection
Program (the “PPP” or “Program”), established by the Coronavirus Aid, Relief, and Economic
Security Act, Pub. L. No. 116-136, 134 Stat. 281 (2020) (the “CARES Act”); and (2) to preserve
the status quo pending the Court’s decision on the validity of Section 120.110(b) by requiring
Defendants to set aside $644,382 (or $310 billion of additional funding appropriated on April 24,
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ECF procedures indicate that a motion for a TRO should be filed in person. Due to Covid19 issues, we are
E-Filing, emailing a copy to the emergency judge, and will follow up with the court when it opens on Monday
morning.
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2020) for the PPP loan Plaintiff has requested in the event this Court ultimately rules that Section
Under the CARES Act, small businesses may obtain PPP loans up to at least 2.5 average
monthly payroll costs in 2019 and in many cases obtain full government-paid forgiveness of the
loan, which effectively converts the loans into government grants. $349 billion was initially
appropriated to fund the Program. Due to the overwhelming popularity of the Program, this
appropriation was fully utilized in less than two weeks. As a result, Congress passed and the
President signed on April 24, 2020 an additional $310 billion of PPP funding, H.R. 266, and the
SBA announced it will begin accepting applications for the second tranche of funding on Monday,
April 27, 2020, at 10:30 am ET. Because funding is provided on a “first-come, first served” basis
and there is no assurance that the second round of funding will suffice beyond a few hours or days,
absent emergency relief, Plaintiff is threatened by a permanent loss of its right to a PPP loan and
This motion is made on the grounds specified herein and in Plaintiff’s brief in support
thereof, the Verified Complaint, the Declaration of John Blake-Zuniga, and such other and further
Pursuant to Local Rule 7(m), Plaintiff has conferred with Counsel for the SBA who stated
that he does not have authority to approve this motion in whole or in part.
WHEREFORE, Plaintiff respectfully requests that the Court either grant the foregoing
Motion or schedule a hearing on Plaintiff’s Motion on Monday morning, April 27, 2020 before
10:30 am ET, enter the proposed Temporary Restraining Order and Preliminary Injunction, and
enter such other and further relief as it deems just and appropriate.
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Respectfully submitted,
Jeremy T Rosenblum
(motion for admission pro hac vice forthcoming)
BALLARD SPAHR LLP
1735 Market Street, 51st Floor
Philadelphia, PA 19103
Telephone: 215.665.8500
Facsimile: 215.864.8999
[email protected]
Sarah T. Reise
(motion for admission pro hac vice forthcoming)
BALLARD SPAHR LLP
999 Peachtree Street, Suite 1000
Atlanta, GA 30309-3915
Telephone: 678.420.9300
Facsimile: 678.420.9301
[email protected]
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I. INTRODUCTION
COVID-19 and the government measures implemented to combat its spread have affected
nearly every business and employee nationwide. In response, Congress passed a series of measures
intended to combat the devastating effects on both employers and employees, including the
Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (2020)
(the “CARES Act”) and a successor bill signed on April 24, 2020 (“CARES II”). The CARES Act
created the Paycheck Protection Program (the “PPP” or “Program”) and appropriated $349 billion
for purchases of PPP loans by the Small Business Administration (“SBA”), the agency tasked with
administering these loans. PPP loans, available in amounts at least equal to 2.5 times average 2019
monthly payroll costs, carry annual interest rates of only 1% and, more importantly, are subject to
costs and/or other specified expenditures in the eight weeks following the initial disbursement of
funds. Among other things, CARES II appropriated an additional $310 billion for the Program.
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Plaintiff has applied for a PPP loan in the amount of $654,382 (which, if approved, is
Plaintiff on an Economic Injury Disaster Loan). However, the SBA’s PPP rules do not permit loans
to “financial businesses primarily engaged in the business of lending” and hence purport to prohibit
Plaintiff from obtaining the benefits of a PPP loan during this time of economic crisis. Plaintiff, a
financial business engaged primarily in lending, has been severely impacted by the financial
hardships that COVID-19 has inflicted on the Nation. This unjustified stance of the SBA threatens
Plaintiff has a powerful case on the merits (not merely the substantial argument
required by applicable law). The SBA rules denying Plaintiff the right to a PPP loan
directly conflict with the plain language of the CARES Act, which broadly
authorizes a PPP loan to any business concern that meets specified size
Absent emergency injunctive relief, Plaintiff and its employees will suffer severe
economic injury. This economic injury will be irreparable since lawsuits for
The balance of equities and public interest tilt heavily in favor of the requested
relief.
Accordingly, pursuant to Fed. R. Civ. P. 65 and LCvR 65.1, Plaintiff submits this
memorandum in support of its Emergency Motion for a Temporary Restraining Order and
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Preliminary Injunction against the SBA, Jovita Carranza, in her official capacity as Administrator
II. BACKGROUND
Sections 1102 and 1106 of the CARES Act establish the Paycheck Protection Program (the
“PPP” or “Program”). Sections 1102 and 1106 have been implemented by four Interim Final Rules,
As recognized by the SBA, the purpose of the Program is “to provide immediate assistance
to individuals, families, and businesses affected by the COVID-19 emergency.” SBA Interim Final
Rule, RIN 3245-AH34, Business Loan Program Temporary Changes; Paycheck Protection
Program, Exh. A to the Complaint (the “First Interim Final Rule”) 85 F.R. 20811 (April 15, 2020)
(emphasis added). Congress’ intent “is that SBA provide relief to America’s small businesses
expeditiously.” Id. at 5.
Section 1102 of the CARES Act amended Section 7(a) of the Small Business Act, 15
U.S.C. § 636(a) (“Section 7(a)”), by providing 100% SBA guarantees of PPP loans (15 U.S.C.
§ 636(a)(2)(F)) and adding a new subsection (36) (“Subsection (36)”), authorizing PPP loans to
companies previously entitled to loans under Section 7(a) and to an expanded group of for-profit
Subsection (36)(E) provides for a maximum loan amount that is normally equal to the
lesser of $10 million or 2.5 times the recipient’s average monthly payroll costs for the twelve
months preceding the loan or calendar year 2019. See 15 U.S.C. § 636(a)(36)(F); First Interim
Subsection (36)(F) and the First Interim Final Rule specify the allowable uses of PPP
loans—primarily payroll and related costs and secondarily mortgage interest, rent, utilities and
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interest on debt obligations incurred prior to February 15, 2020. See 15 U.S.C. § 636(a)(36)(F);
Section 1106 of the CARES Act provides for government-financed forgiveness of PPP
loans to the extent the proceeds are used within the eight-week period following loan origination
for payroll costs and/or, to a limited extent, specified other purposes. However, in keeping with
the goal of the CARES Act to promote employment, loan forgiveness is subject to formulaic
reductions for companies that have laid off employees or cut compensation of individual
employees more than 25%. See, also, First Interim Final Rule at 13-14.
Section 1107(a)(1) of the CARES Act appropriated $349 billion for the cost of PPP loans
and the associated SBA guarantees. The processing of PPP loan applications commenced on April
3, 2020. By April 15, 2020, the entire appropriation was fully utilized. Accordingly, Congress
passed and the President signed CARES II, providing for an additional $310 billion of PPP
funding. This second round of PPP lending is scheduled to commence on Monday, April 27, 2020.
Plaintiff was deprived of the right to participate in the first round of PPP financing. See
loan in the second round of financing—a real possibility due to the huge demand for PPP loans
and the “first-come, first-served” allocation of loan approvals, it will have lost a key tool to cope
with the economic uncertainties caused by COVID-19 and the resulting government and societal
responses, and to retain its workers and maintain their payrolls. In substantial part based on the
hope and expectation that Plaintiff could receive a PPP loan, Plaintiff has largely resisted employee
layoffs, furloughs and compensation reductions to date. However, due to governmental closures
of virtually all businesses surrounding Plaintiff’s retail locations, Plaintiff is now suffering serious
and unsustainable losses. In the event it is unable to secure a PPP loan, it will be forced to retrench
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and close a minimum of 70% of its business locations, terminating all related employees. Indeed,
Plaintiff’s majority shareholder believes that it is highly likely that Plaintiff will need to shut down
completely and wind down all operations permanently without a PPP loan. Not only is this a
III. ARGUMENT
A. Standard of Review.
demonstrates by verified complaint or affidavit that the movant’s rights are being or will be
violated by an adverse party, and the movant will suffer immediate and irreparable injury or loss.
Fed. R. Civ. P. 65(b). In determining whether to grant preliminary or temporary injunctive relief,
the Court must consider whether (1) the plaintiff has demonstrated a likelihood of success on the
merits; (2) the plaintiff will be irreparably harmed by the denial of injunctive relief; (3) the
threatened injury to the plaintiff outweighs the harm to the defendant; and (4) the issuance of an
injunction would not be averse to the public. Pursuing America’s Greatness v. FEC (PAG), 831
F.3d 500, 505 (D.C. Cir. 2016) (quoting Winter v. NRDC, 555 U.S. 7, 20, 22 (2008)).Plaintiff is
able to demonstrate each factor necessary for the entry of injunctive relief.
Agency action must be set aside when it is arbitrary, capricious, an abuse of discretion, or
otherwise not in accordance with law. 5 U.S.C. § 706(2)(A). The SBA’s determination that
financial businesses primarily engaged in the business of lending must be foreclosed from
obtaining PPP loans directly conflicts with Section 1102 of the CARES Act, which provides that
PPP loans are to be made available to “any business concern” meeting CARES Act size limitations.
This is a simple case of statutory construction. Not only does Plaintiff have a likelihood of
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* * *
In the face of this plain Congressional command that “any business concern” meeting
applicable size requirements “shall be eligible” for a PPP loan, the SBA has determined that,
among other ineligible borrowers, “financial businesses primarily engaged in the business of
lending” are categorically ineligible for PPP loans. Thus, the First Interim Final Rule answers the
by stating: “Businesses that are not eligible for PPP loans are identified in 13 CFR 120.110 ….”
In turn, 13 C.F.R. § 120.110(b) (“Section 120.110(b)”) declares ineligible for SBA business loans
“[f]inancial businesses primarily engaged in the business of lending, such as banks, finance
The SBA failed even to attempt an explanation why PPP loans should be subject to the
same pre-existing business restrictions as other kinds of loans under Section 7(a). Nor did the SBA
try to explain how its position could be harmonized with the plain language of the CARES Act.
2
Additionally, a PPP loan applicant must have been in business, paying employees and/or
independent contractors, on February 15, 2020, and must make specified certifications
concerning, among other things, its need for funds to support ongoing operations in light
of the uncertainty of current economic conditions and the use of funds to retain workers
and maintain payroll or make mortgage payments, lease payment and utility payments. 15
U.S.C. §§ 636(a)(36)(F)(ii), (G).
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lending, the closest the SBA has come to an articulation of the reasoning behind its prohibition
comes from a predecessor regulation to Section 120.110(b). That regulation listed as businesses
ineligible for SBA financial assistance “[c]oncerns primarily engaged in the business of lending
or investing.” The regulation went on to provide: “Applicants that are otherwise eligible become
ineligible where the purpose of the Financial Assistance is to finance investments that are neither
related nor essential to the enterprise ….” 13 C.F.R. § 120.101-2(e) (repealed), 1997 Code of
Federal Regulations Archive, attached as Exhibit E to the Complaint. Apparently, the SBA felt
that lending it supported should not be used to indirectly finance loans by third parties. Other
federal instrumentalities (e.g., the Federal Reserve System and Federal Home Loan Banks) serve
that role. Of course, this rationale has nothing to do with whether small lending institutions are
proper recipients of government support in the form of PPP loans. The proceeds of PPP loans are
must be spent for payroll and a limited universe of additional operating costs—not loan funding.
While the SBA has chosen to apply Section 120.110(b) to PPP loans, it has concluded that
a number of the prohibitions in Section 120.110 is inappropriate. Thus, the SBA Interim Final
Rule, RIN 3245-AH35, Business Loan Program Temporary Changes; Paycheck Protection
Program, 85 Fed. Reg. 20817 (Apr. 15, 2020) attached as Exhibit B to the Complaint (the “Second
Interim Final Rule”), that the prohibition in Section 120.110(k) for loans to businesses “principally
The SBA Interim Final Rule, RIN 3245-AH36, Business Loan Program Temporary
Certain Pledges of Loans, 85 Fed. Reg. 21747 (Apr. 20, 2020), attached as Exhibit C to the
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Complaint (the “Third Interim Final Rule”), relaxed the eligibility requirements of Section
120.110(g) with respect to lawful gaming establishments—again without explanation. Under the
Third Interim Final Rule, previously ineligible gaming establishments will qualify for PPP loans
if legal gaming revenues (net of payouts) amounted to $1 million or less of 2019 revenues and less
Finally, SBA Interim Final Rule, RIN 3245-AH37, Business Loan Program Temporary
Affiliation, and Eligibility, attached as Exhibit D to the Complaint (the “Fourth Interim Final
Rule”), overrides as to PPP loans Section 120-110(j), which otherwise precludes loans to
government-owned entities:
A hospital that is otherwise eligible to receive a PPP loan as a business concern or nonprofit
organization (described in section 501(c)(3) of the Internal Revenue Code of 1986 and
exempt from taxation under section 501(a) of such Code) shall not be rendered ineligible
for a PPP loan due to ownership by a state or local government if the hospital receives less
than 50% of its funding from state or local government sources, exclusive of Medicaid.
The Administrator, in consultation with the Secretary, determined that this exception to the
general ineligibility of government-owned entities, 13 CFR 120.110(j), is appropriate to
effectuate the purposes of the CARES Act.
While they afford limited relief to other businesses, the Third and Fourth Interim Final
Not only is the SBA determination generally to apply Section 120.110 to the PPP program
and financial institutions unjustified on policy grounds, it violates at least two bedrock principles.
First, it ignores the plain language of the governing statute. Second, it substitutes the SBA’s
unexplained judgment that specified businesses should be denied the benefits of PPP loans for
Congress’ direction that all small businesses qualify, in contravention of the separation of powers
between Congress and the Executive branch. On both these points, the Supreme Court and the
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“The starting point for interpreting a statute is the language of the statute itself.” United
States v. Jamison, 934 F.2d 371, 373 (D.C. Cir. 1991) (citing Consumer Prod. Safety Comm’n v.
GTE Sylvania, 447 U.S. 102, 108 (1980)); Aref v. Lynch, 833 F.3d 242, 263 (D.C. Cir. 2016).
“[U]nless otherwise defined, words will be interpreted as taking their ordinary, contemporary,
common meaning.” ArQule, Inc. v. Kappos, 793 F.Supp.2d 214, 220 (D.C. Cir. 2011) (quoting
Perrin v. United States, 444 U.S. 37, 42 (1979)). And a court looks beyond the plain language of
the statutory text only when there is “evidence that Congress meant something other than what it
literally said . . . .” Engine Mfrs. Ass’n. ex rel. Certain of its Members v. United States EPA, 88
Likewise, it is fundamental that Congress makes the laws and the Executive branch
executes the laws. Thus, Article I, § 1 of the Constitution provides: “All legislative Powers herein
granted shall be vested in a Congress of the United States ….” And Article II, Section III instructs
the President to “take Care that the Laws be faithfully executed ….”
Moreover, a federal agency is a “creature of statute” and as such, it has “no constitutional
or common law existence or authority, but only those authorities conferred upon it by Congress.”
Michigan v. EPA, 268 F.3d 1075, 1081 (D.C. Cir. 2001). Therefore, “[i]t is axiomatic that an
delegated by Congress.” Id. (citing Bowen v. Georgetown Univ. Hosp., 488 U.S. 204, 208, 102 L.
Because Congress makes the law, “no deference is due to agency interpretations at odds
with the plain language of the statute itself.” Public Employees Ret. Sys. v. Betts, 492 U.S. 158,
171, 109 S. Ct. 2854, 2863, 106 L. Ed. 2d 134, 151 (1989) (superseded by statute on other
grounds); see also United States v. Labonte, 520 U.S. 751, 757, 117 S. Ct. 1673, 1677, 137 L. Ed.
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2d 1001 (1997) (“If the [agency’s regulation] is at odds with [the statute’s] plain language, it must
give way.”); City of Mesa v. FERC, 993 F.2d 888, 892–93 (D.C. Cir. 1993). “The traditional
deference courts pay to agency interpretation is not to be applied to alter the clearly expressed
intent of Congress.” Bd. of Governors of Fed. Reserve Sys. v. Dimension Fin. Corp., 474 U.S. 361,
368, 106 S. Ct. 681, 685-686, 88 L. Ed. 2d 691, 698 (1986). “The court remains the final authority
on issues of statutory construction ... and cannot abdicate its ultimate responsibility to construe the
language employed by Congress.” Fed. Election Comm’n v. Dem. Senatorial Campaign Comm.,
454 U.S. 27, 102 S. Ct. 38, 42, 70 L. Ed. 2d 23 (1981); Zuber v. Allen, 396 U.S. 168, 90 S. Ct. 314,
24 L. Ed. 2d 345 (1969); NOW, Washington D.C. Chapter v. Social Sec. Admin of Dep’t of Health
& Human Services, 736 F.2d 727, 734–35 (D.C. Cir. 1984) (“While on legal inquiries, including
typically those of statutory construction, courts yield agencies varying degrees of deference, it is
the court, not the agency, that has the final say.”); City of Anaheim v. FERC, 558 F.3d 521, 522
(D.C. Cir. 2009) (Kavanaugh, J.) (“But we give no deference to an agency interpretation that fails
to comport with the plain statutory language. The precise words of the statutory text matter.”).
Chevron U.S.A., Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984), has been
criticized for the deference it accords agency interpretations of statutes but even Chevron refuses
to defer to interpretations at odds with the statutory text. “First, always, is the question whether
Congress has directly spoken to the precise question at issue. If the intent of Congress is clear, that
is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously
The CARES Act accords the SBA power to adopt regulations “to carry out” the Act. Here,
of course, there is nothing in the Small Business Act or the CARES Act giving the SBA power to
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Plaintiff will suffer irreparable harm if injunctive relief is not granted. Irreparable harm
requires the moving party to show its injury is “both certain and great”, and there must be a “clear
and present need for equitable relief to prevent irreparable harm.” Chaplaincy of Full Gospel
Churches v. England, 454 F.3d 290, 297 (D.C. Cir. 2006) (internal quotations omitted). Here,
Plaintiff’s injury is both certain and great, because SBA’s decision to misapply Section 120.110
to PPP loans bars Plaintiff’s access to PPP loans and the loan forgiveness which comes with them.
Plaintiff also has a clear and present need for equitable relief, because monetary relief is
unavailable since the SBA, as a federal agency, is immune to suit for monetary damages. See, e.g.
Woerner v. United States Small Business Admin., 739 F. Supp. 641, 650 (D. D.C. 1990) (finding
plaintiffs satisfied element of irreparable harm for injunctive relief because, inter alia, the
Solely because of the SBA’s decision to misapply Section 120.110 to PPP loans, Plaintiff
is unable to obtain a PPP loan. Declaration of John Blake-Zuniga, Exh. 1, at ¶ 11.3 Absent
immediate relief in the form of the requested TRO, Plaintiff will lose the opportunity to obtain a
PPP loan and the loan forgiveness it could claim, a loss exceeding $644,000. As observed above,
this damage is not compensable in a lawsuit against a federal agency such as the SBA. And, in any
event, the whole point of the PPP is to provide emergency financial assistance. Without this
assistance, will need to shut down most of its stores and likely its entire business. Declaration of
3
Plaintiff has under 100 employees, together with its affiliates. It was in business on
February 15, 2020 and it truthfully made the certifications required by Subsection (36)(G)
due to serious impacts of the coronavirus and the steps the federal and state governments
have taken to contain its spread. If it obtains a PPP loan, the proceeds will be used to retain
workers who might otherwise need to be furloughed or discharged and to maintain payroll.
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John Blake-Zuniga, Exh. 1 at ¶ 5. This will have exactly the adverse impact on employees the PPP
D. The Balance of the Equities and Public Interest Favor a TRO and
Preliminary Injunction.
In considering the appropriateness of injunctive relief, a court should balance the possible
harm to the plaintiff from denying the requested relief against the possible harm to the defendant
from granting it. See, e.g., Amoco Production Co. v. Village of Gambell, Alaska, 480 U.S. 531
(1987). Here, the balance of equities tilts sharply in favor of a ruling for Plaintiff.
Of course, “[p]roper administration of the laws is in the public interest.” United States v.
Bell, 238 F. Supp. 2d 696, 705 (M.D. Pa. 2003) (citing U.S. v. Knudson, 959 F. Supp. 1180, 1187
(D. Neb. 1997) (“[I]t is in the public interest that the federal courts uphold federal law and assure
the proper functioning of government.”)); see also Siembra Finca Carmen, LLC v. Sec’y of the
Dep’t of Agric. of P.R., Civil No. 18-1783, 2020 U.S. Dist. LEXIS 20452, *33-*34 (D. P.R. Jan.
23, 2020) (“Just as a government has no interest in enforcing an unconstitutional law, the public
interest is harmed by the enforcement of laws repugnant to the United States Constitution.”) (citing
Additionally, “[t]here is a great public interest in guaranteeing that those in financial need
are not unreasonably terminated from public assistance benefits.” Jones v. Lansing Hous. Comm’n,
Case No. 5:03-CV-123, 2003 U.S. Dist. LEXIS 28327, *22 (W.D. Mich. Sept. 19, 2003)
benefits to plaintiff during pendency of suit), adopted and injunction granted at Jones v. Lansing
Hous. Comm’n, 2003 U.S. Dist. LEXIS 28328 (W.D. Mich., Oct. 17, 2003). Accordingly, the
strength of Plaintiff’s case on the merits militates strongly in favor of relief on this element as well.
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immediate and profound impact on Plaintiff and its employees. By contrast, the SBA will suffer
no harm whatsoever if relief is granted. And in all of its PPP rulemaking and guidance, the SBA
has not proffered any explanation how the public interest would be impaired by PPP loans to
On April 24, 2020, Congress and the President added $310 billion of new funding to the
Program. Even more than the initial round of PPP funding, which lasted less than two weeks
despite the need for the SBA and banks to create new procedures and mechanisms on the fly, the
new funding could be dissipated in a matter of hours or days. See Kimball, Spencer, “Congress
approved $370 billion more in small business loans, but the money could run out in days — again,”
business-loans-could-run-out-in-days.html.
Accordingly, in order to protect Plaintiff’s right to a PPP loan if this Court ultimately rules
in Plaintiff’s favor, this Court should enter an immediate order, as contemplated by 5 U.S.C. § 705,
to preserve Plaintiff’s rights pending conclusion of the review proceedings by requiring the SBA
temporarily to set aside $644,382 of funding for the loan Plaintiff has requested.
IV. CONCLUSION
Plaintiff respectfully requests that this Court enter a temporary restraining order and grant
a preliminary injunction enjoining and restraining Defendants from denying PPP loans to Plaintiff
and other similarly situated small business concerns that primarily engage in the business of
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lending. Pending action on this request, Plaintiff requests that the Court preserve the status quo by
ordering the SBA to set aside $644,382 of PPP funding for Plaintiff.
Respectfully submitted,
Jeremy T Rosenblum
(motion for admission pro hac vice forthcoming)
BALLARD SPAHR LLP
1735 Market Street, 51st Floor
Philadelphia, PA 19103
Telephone: 215.665.8500
Facsimile: 215.864.8999
[email protected]
Sarah T. Reise
(motion for admission pro hac vice forthcoming)
BALLARD SPAHR LLP
999 Peachtree Street, Suite 1000
Atlanta, GA 30309-3915
Telephone: 678.420.9300
Facsimile: 678.420.9301
[email protected]
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CERTIFICATE OF SERVICE
I, Constantinos G. Panagopoulos, hereby certify that on April 25, 2020, the foregoing has
been filed via the CM/ECF system and by email to [email protected]. This
filing was also sent via electronic mail on April 25, 2020 and First Class Certified Mail on April
Chris Pilkerton
Eric Benderson
Office of General Counsel
U.S. Small Business Administration
409 3rd St, S.W.
Washington DC 20416
[email protected]
David Morrell
Deputy Assistant Attorney General
Federal Programs Branch
Civil Division
U.S. Department of Justice
Washington, DC 20530
[email protected]
James J. Gilligan
Special Litigation Counsel
Civil Division, Federal Programs Branch
U.S. Department of Justice
P.O. Box 883
Washington, D.C. 20044
Tel: 202-514-3358
[email protected]
and will be sent by First Class Certified Mail on April 27, 2020 to:
Timothy J. Shea
United States Attorney
District of Columbia
555 4th St NW,
Washington, DC 20530
202-252-7566
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