Exhibit 175 — BofA Ca Unemployment (Dkt. 378.20)

Summary

Exhibit 175, filed November 21, 2024 as Document 378-20 in Case 3:21-md-02992-GPC-MSB, is an email chain with the subject line "In re BANA California Unemployment Litig. - Call center data" between Lindsay E Hoyle of Goodwin Procter LLP and Stacey Leyton of Altshuler Berzon LLP. In a February 9, 2024 email, Hoyle writes that from June 1, 2020 through May 12, 2021 a portion of the Fraud Call Center data was housed on a vendor's platform that BANA cannot access, and that from May 13, 2021 all of it was on BANA's platform. A February 6, 2024 email says EDD Main Servicing Call Center data from before May 1, 2022 was housed on the vendors' platforms. Hoyle writes that BANA has produced the vendor reports and is under no obligation to create new documents or conduct any further analysis.

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Case 3:21-md-02992-GPC-MSB Document 378-20 Filed 11/21/24 PagelD.14424
Page 2 of 5

Monday, November 18, 20724 at 17:19:55 Pacific Standard Time

Subject: RE: In re BANA California Unemployment Litig. - Call center data

Date: Friday, February 9, 2024 at 7:25:25 PM Pacific Standard Time

From: Hoyle, Lindsay E

To: Stacey Leyton, Connie Chan, Riffee, Matthew L, Brian Danitz, Michael Rubin, Karin B. Swope, Andrew F.
Kirtley, Matthew Murray, Peter Luc, jtoomey

cc: McGarry, James W, ychan@jonesday.com, Hefferon, Thomas M, Rose-Smith, Sabrina M, Stoll, Laura A,

Haggans, Valerie A, Briggs, Michelle T, Brys, Laura, Colin Jones, Caroline Drysdale

Attachments: jimage007.png, image001.png, image002.png, image003.png, image004.png, image005.pn¢g,
image006.png

You don't often get email from Ihoyle@goodwinlaw.com. Learn why this is important

Stacey,

We write to follow up regarding the remaining questions in your January 30, 2024 letter. With respect to
your question regarding the Prepaid Fraud Call Center Data, the data produced at BANA_EDD_MDL-
00694849 reflects the data that was housed on BANA’s platform. From June 1, 2020 through May 12,
2021, a portion of the Fraud Call Center data was housed on a vendor’s platform; this data is not
included in BANA_EDD_MDL-00694849 as BANA does not have access to that platform and therefore
cannot export that data into the form you requested. Beginning on May 13, 2021, all of the Fraud Call
Center data was housed on BANA’s platform, and is reflected in BANA _EDD_MDL-00694849. As for data
between June 1, 2020 through May 12, 2021, for the portion of the Fraud Call Center housed on the
vendor’s platform, BANA received vendor reports reflecting the metrics for that portion of the Fraud Call
Center, and those reports have been produced to you, as you note. BANA’s production, taken together,
is sufficient to show the metrics Plaintiffs have requested, and BANA is under no obligation to create new
documents or conduct any further analysis.

As for data regarding “Average Abandonment Delay,” we will produce to you shortly the data that is
housed on BANA’s platform. Data that was housed on a vendor platform (for a portion of the Fraud Call
Center, as described above, and for the period prior to May 2022 for the Main Servicing Call Center) will
not be included in BANA’s report, but has been produced to you via the vendor reports BANA received,
as you note.

Best,
Lindsay

l= GOODWIN

Goodwin Procter LLP

The New York Times Building
620 Eighth Avenue

New York, NY 10018

o +1 212 459 7124

f +1212 672 1100
LHoyle@goodwinlaw.com

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Case 3:21-md-02992-GPC-MSB Document 378-20 Filed 11/21/24 PagelD.14425
Page 3 of 5

From: Hoyle, Lindsay E

Sent: Tuesday, February 6, 2024 12:38 PM

To: ‘Stacey Leyton’ <sleyton@altshulerberzon.com>; Connie Chan <cchan@altshulerberzon.com>;
Riffee, Matthew L <MRiffee@goodwinlaw.com>; Brian Danitz <BDanitz@cpmlegal.com>; Michael Rubin
<mrubin@altshulerberzon.com>; Karin B. Swope <KSwope@cpmlegal.com>; Andrew F. Kirtley
<AKirtley@cpmlegal.com>; Matthew Murray <mmurray@altshulerberzon.com>; Peter Luc
<PLuc@cpmlegal.com>; jtoomey <jtoomey@cpmlegal.com>

Cc: McGarry, James W <JMcGarry@goodwinlaw.com>; ychan@jonesday.com; Hefferon, Thomas M
<THefferon@goodwinlaw.com>; Rose-Smith, Sabrina M <SRoseSmith@goodwinlaw.com>; Stoll, Laura A
<LStoll@goodwinlaw.com>; Haggans, Valerie A <VHaggans@goodwinlaw.com>; Briggs, Michelle T
<MBriggs@goodwinlaw.com>; Brys, Laura <LBrys@goodwinlaw.com>; Colin Jones
<cjones@altshulerberzon.com>; Caroline Drysdale <cdrysdale@altshulerberzon.com>

Subject: RE: In re BANA California Unemployment Litig. - Call center data

Stacey,
We write in response to your January 30, 2024 letter regarding call center data.

With respect to your question about the EDD Main Servicing Call Center, data from prior to May 1, 2022
was housed on the vendors’ platforms. BANA does not have access to those platforms and therefore
cannot export or pull that data into a single metrics report, as we did for data from May 2022 onwards,
which is housed on BANA’s own platform. At no point did we suggest that BANA “failed to receive or
review reports” from its vendors; to the contrary, as you point out in your letter, we have produced those
reports to you. BANA is not able to generate new reports of pre-May 2022 data for the EDD Main
Servicing Call Center in any other format, nor is it under any obligation to do so.

We are looking into your remaining questions and will work to make a supplemental production, if
needed, as soon as possible.

Best,
Lindsay

| 4 GOODWIN

Goodwin Procter LLP

The New York Times Building
620 Eighth Avenue

New York, NY 10018

o +1 212 459 7124

f +1212 672 1100
LHoyle@goodwinlaw.com

From: Stacey Leyton <sleyton@altshulerberzon.com>

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Case 3:21-md-02992-GPC-MSB Document 378-20 Filed 11/21/24 PagelD.14426
Page 4 of 5

Sent: Monday, February 5, 2024 8:57 PM

To: Connie Chan <cchan@altshulerberzon.com>; Riffee, Matthew L <MRiffee@goodwinlaw.com>; Brian
Danitz <BDanitz@cpmlegal.com>; Michael Rubin <mrubin@altshulerberzon.com>; Karin B. Swope
<KSwope@cpmlegal.com>; Andrew F. Kirtley <AKirtley@cpmlegal.com>; Matthew Murray
<mmurray@altshulerberzon.com>; Peter Luc <PLuc@cpmlegal.com>; jtoomey
<jtoomey@cpmlegal.com>

Cc: McGarry, James W <JMcGarry@goodwinlaw.com>; ychan@jonesday.com; Hefferon, Thomas M
<THefferon@goodwinlaw.com>; Rose-Smith, Sabrina M <SRoseSmith@goodwinlaw.com>; Stoll, Laura A
<LStoll@goodwinlaw.com>; Haggans, Valerie A <VHaggans@goodwinlaw.com>; Hoyle, Lindsay E
<LHoyle@ goodwinlaw.com>; Briggs, Michelle T <MBriggs@goodwinlaw.com>; Brys, Laura
<LBrys@goodwinlaw.com>; Colin Jones <cjones@altshulerberzon.com>; Caroline Drysdale
<cdrysdale@altshulerberzon.com>

Subject: RE: In re BANA California Unemployment Litig. - Call center data

***EXTERNAL***
Counsel,

Our correspondence asked for a response on the discovery deficiencies identified in this letter
before today. As you know, we have a 30b6 deposition on these subjects coming up in just over two
weeks, and we need time to analyze the missing data. Can you please let us know whether you will
be producing the missing documents and if so whether you will be able to do so by February 9?

Thank you,
Stacey

From: Stacey Leyton

Sent: Wednesday, January 31, 2024 9:20 AM

To: Connie Chan <cchan@altshulerberzon.com>; Riffee, Matthew L <MRiffee@goodwinlaw.com>; Brian
Danitz <BDanitz@cpmlegal.com>; Michael Rubin <mrubin@altshulerberzon.com>; Karin B. Swope
<KSwope@cpmlegal.com>; Andrew F. Kirtley <AKirtley@cpmlegal.com>; Matthew Murray
<mmurray@altshulerberzon.com>; Peter Luc <PLuc@cpmlegal.com>; jtoomey
<jtoomey@cpmlegal.com>

Cc: McGarry, James W <JMcGarry@goodwinlaw.com>; ychan@jonesday.com; Hefferon, Thomas M
<THefferon@goodwinlaw.com>; Rose-Smith, Sabrina M <SRoseSmith@goodwinlaw.com>; Stoll, Laura A
<LStoll@goodwinlaw.com>; Haggans, Valerie A <VHaggans@goodwinlaw.com>; Hoyle, Lindsay E
<LHoyle@ goodwinlaw.com>; Briggs, Michelle T <MBriggs@goodwinlaw.com>; Brys, Laura
<LBrys@goodwinlaw.com>; Colin Jones <cjones@altshulerberzon.com>; Caroline Drysdale
<cdrysdale@altshulerberzon.com>

Subject: In re BANA California Unemployment Litig. - Call center data

Counsel,
Please see the attached correspondence.

Thank you,
Stacey

3 0f 4
Case 3:21-md-02992-GPC-MSB Document 378-20 Filed 11/21/24 PagelD.14427
Page 5o0f5

Stacey Leyton

Altshuler Berzon LLP

177 Post Street, Suite 300

San Francisco, CA 94108
Office: (415) 421-7151 ext. 304
sleyton@altber.com
Pronouns: she/her

Legal administrative assistant: Desiree Medina
dmedina@altber.com

ALTSHULER BERZON tp

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