Joint Motion for Extension of Time to File Reply Papers in Further Support of Motion to Compel Compliance with Subpoena

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A Joint Motion for Extension of Time to File Reply Papers in Further Support of Motion to Compel Compliance with Subpoena for the Production of Documents, filed 04/06/24 as Document 259 in In re Bank of America California Unemployment Benefits Litigation, Case No. 3:21-md-02992-LAB-MSB in the Southern District of California. Plaintiffs and third party TTEC Government Solutions, LLC say meet and confer discussions have led to the production of substantial materials and seem likely to lead to a near complete resolution of the dispute. An open question concerns the types and completeness of information transferred from TTEC to Bank of America. They ask the Court to extend plaintiffs' April 5, 2024 reply deadline to April 29, 2024.

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Joint Motion for Extension of Time to File Reply Papers 
  
                                                                            Case No. 21MD2992 LAB (MSB)  
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BOTTINI & BOTTINI, INC.  
 
Francis A. Bottini, Jr. (SBN 175783) 
Albert Y. Chang (SBN 296065) 
Aaron P. Arnzen (SBN 218272) 
7817 Ivanhoe Avenue, Suite 102 
La Jolla, California 92037 
Telephone: 
(858) 914-2001 
Facsimile: 
(858) 914-2002 
E-mail: fbottini@bottinilaw.com 
achang@bottinilaw.com  
aarnzen@bottinilaw.com   
 
Counsel for Class Representative Plaintiff Lindsay 
McClure 
 
 
 
[Additional Counsel Listed Below] 
 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
 
In re BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
 
 
 
 
 
 
 
 
Case No. 3:21-md-02992-LAB-MSB 
 
The Honorable Michael S. Berg 
 
Joint Motion for Extension of Time 
to File Reply Papers in Further 
Support of Motion to Compel 
Compliance with Subpoena for the 
Production of Documents 
 
This Document Relates to All Actions 
 
 
 
 
Case 3:21-md-02992-GPC-MSB     Document 259     Filed 04/06/24     PageID.2541     Page 1
of 3

 
 
 
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Joint Motion for Extension of Time to File Reply Papers 
 
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Plaintiffs and third party TTEC Government Solutions, LLC (“TTEC”) 
respectfully and jointly move for an order extending Plaintiffs’ deadline to file reply 
papers in further support of their motion to compel compliance with subpoena for the 
production of documents.  In support of this motion, Plaintiffs and TTEC state as 
follows: 
Plaintiffs’ motion to compel third party TTEC Government Solutions, LLC’s 
(“TTEC”) to comply with a subpoena for the production of documents, and TTEC’s 
opposition brief, have led to productive meet and confer discussions between counsel.  
These discussions have led to the production of substantial materials, and the parties 
are in discussions regarding the production of additional documents.  These 
discussions seem likely to lead to a near complete resolution of the present discovery 
dispute.  One of the questions that remains outstanding, and which TTEC continues 
to review, concerns the types and completeness of information that were transferred 
from TTEC to Bank of America during the relevant time period.  The parties and 
TTEC are currently involved in discussions surrounding such transfers of information.  
The Court has granted two motions for extension of time to file a reply brief for the 
reasons cited above, and Plaintiffs and TTEC would benefit from another such 
extension.   
In light of the foregoing, good cause exists to extend Plaintiffs’ April 5, 2024 
deadline to file their reply papers to April 29, 2024.  Accordingly, the Court should 
grant this unopposed motion and issue the accompanying proposed order extending 
Plaintiffs’ April 5, 2024 deadline to file their reply papers to April 29, 2024. 
 
Dated: April 6, 2024 
Respectfully submitted, 
BOTTINI & BOTTINI, INC. 
s/ Aaron P. Arnzen 
Aaron P. Arnzen 
Francis A. Bottini, Jr. (SBN 175783) 
Albert Y. Chang (SBN 296065) 
Aaron P. Arnzen (SBN 218272) 
Case 3:21-md-02992-GPC-MSB     Document 259     Filed 04/06/24     PageID.2542     Page 2
of 3

 
 
 
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Joint Motion for Extension of Time to File Reply Papers 
 
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7817 Ivanhoe Avenue, Suite 102 
La Jolla, CA 92037 
Telephone:  858/914-2001 
Facsimile: 
858/914-2002  
Email:          fbottini@bottinilaw.com 
 
 
aarnzen@bottinilaw.com   
 
 
achang@bottinilaw.com  
Counsel for Class Representative Plaintiff Lindsay 
McClure 
 
 
 COTCHETT, PITRE & MCCARTHY, LLP 
Joseph W. Cotchett (SBN 36324) 
Brian Danitz (SBN 247403) 
Karin B. Swope (Pro Hac Vice) 
Andrew F. Kirtley (SBN 328023) 
840 Malcolm Road, Suite 200 
Burlingame, CA 94010 
Telephone:   (650) 697-6000 
Email:           jcotchett@cpmlegal.com 
bdanitz@cpmlegal.com 
kswope@cpmlegal.com 
akirtley@cpmlegal.com 
 
 
ALTSHULER BERZON LLP 
Michael Rubin (SBN 80618) 
Stacey M. Leyton (SBN 203827) 
Matthew Murray (SBN 271461) 
Connie K. Chan (SBN 284230) 
177 Post Street, Suite 300 
San Francisco, CA 94108 
Telephone: (415) 421-7151 
Email:         mrubin@altber.com 
                   sleyton@altber.com 
                   mmurray@altber.com 
                   cchan@altber.com 
 
Interim Co-Lead Counsel for Plaintiffs and the 
Proposed Class 
 
 
Dated: April 6, 2024       
    PERKINS COIE LLP 
By: /s/ Jasmine Wetherell (w/ authorization) 
Jasmine Wetherell 
1888 Century Park East Suite 1700 
Los Angeles, CA 90067-1721 
Phone: 1.310.788.3294 
Email:    JWetherell@perkinscoie.com 
 
 
Attorney for Non-Party TTEC Government Solutions, LLC 
 
Case 3:21-md-02992-GPC-MSB     Document 259     Filed 04/06/24     PageID.2543     Page 3
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