Expert Declaration of Stephen Hindle (Exhibit 5) — In re Bank of America California Unemployment Benefits Litigation (Dkt. 350-6, S.D. Cal. No. 3:21-md-02992)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 350-6 · 2024-10-24 · Docket on CourtListener

Full text

EXHIBIT 5
FILED 
PROVISIONALLY 
UNDER SEAL WITH 
REDACTIONS 
PURSUANT TO 
STIPULATED 
PROTECTIVE ORDER
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
SAN DIEGO DIVISION 
IN RE: BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
 Case No. 3:21-md-02992-GPC-MSB 
EXPERT DECLARATION OF STEPHEN HINDLE 
OCTOBER 24, 2024 
FILED PROVISIONALLY UNDER SEAL
PURSUANT TO STIPULATED PROTECTIVE ORDER
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CONFIDENTIAL  
1 
 
I. 
QUALIFICATIONS 
1. 
I have worked in the contact center industry for 30 years. Over the course of my career, I 
have held roles in direct service, operations management, and senior leadership in the contact 
center industry for several global multi-billion dollar public and private Business Process 
Outsource (BPO) organizations.  
2. 
I began my career at Royal Bank of Scotland’s support center in 1994. In 1996, I joined 
McQueen Ltd. a pioneer of offshore global Business Process Outsource (BPO) in the contact 
center industry. At McQueen Ltd., I served as an integral operations and technology leader, 
overseeing the architecture and infrastructure planning for the first global BPO organization 
in the Philippines. This initiative laid the foundation for the outsourced contact center and 
offshore customer service industry now utilized by Fortune 500 through Fortune 50 
companies. I became a Regional Manager in 2016, after McQueen Ltd. was acquired by 
Sykes Enterprises Inc., a market leader in serving financial sector clients, predominantly 
global and geographically regional banks. From 1998 to 2016 at Sykes Enterprises Inc., my 
responsibilities increased to Senior Director of Global Security Operations. In 2016, I joined 
Sitel Group and became Global Vice President. 
3. 
In 1998, I developed a specialized Training and Consultancy Solutions division at McQueen 
Ltd. that provided highly specialized training services; the two largest revenue clients for this 
contact center business unit were global banking institutions. As Senior Director of Sykes 
Enterprises Inc. in 2012, I developed and led the governance programs that ensured 
regulatory and industry compliance for, among others, global banking institutions, and their 
geographies. In 2016, I developed a client-metrics compliance program for a customer 
service, multi-million dollar line of business at Sykes Enterprises Inc. This program was 
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CONFIDENTIAL  
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considered an industry differentiator, and pioneered operational metrics compliance 
programs and adoption across the contact center industry, in monitoring call center metrics, 
reducing fraud volumes, and ensuring the highest levels of customer satisfaction. 
4. 
Throughout my contact center career, I have led technology teams to implement the strict 
requirements of financial institutions when engaging with BPOs to serve their customers, 
particularly around telephony and IT infrastructure that handles call volumes and facilitates 
omni-channel customer interactions through voice, email, and chat support. As Global Vice 
President at Sitel Group, a leading BPO serving the financial sector, I was accountable for $8 
million P&L and managing technology for client programs that generated $4 billion in 
revenue. During the pandemic, I oversaw 160,000 contact center employees (60% of which 
were impacted and worked remotely), in over 40 countries, processing over 8 million 
customer interactions every day.  
II. 
INTRODUCTION 
5. 
Plaintiffs in this matter brought a proposed class action against Defendant Bank of America, 
N.A. (“Bank of America” or “Bank”) for its alleged failures with regards to its contract with 
the California Employment Development Department (EDD) to issue and service prepaid 
debit cards to California residents who EDD determines are eligible for EDD benefits 
including, for example, benefit payments for unemployment insurance and disability 
insurance.1 Among other things, Plaintiffs allege that Bank of America implemented a Claim 
 
1  
Second Amended Master Consolidated Complaint, In re: Bank of America California Unemployment Benefits 
Litigation, No. 3:21-md-02992-GPC-MSB, United States District Court for the Southern District of California, 
July 16, 2024 (“SAMCC”), ¶¶ 38-41. 
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Fraud Filter on September 28, 20202 that deprived them of access to the benefits they allege 
they were legally entitled to.3 Plaintiffs further claim that the bank failed to provide adequate 
customer service and issued prepaid debit cards without proper security features, making the 
accounts vulnerable to fraud.4 
6. 
Plaintiffs seek certification of five classes, including a proposed “Customer Service Class” 
that is comprised of those who telephoned Bank of America’s customer service telephone 
number for its EDD prepaid debit cardholders at any time between September 13, 2020 
through November 21, 2020, and whose telephone call was routed to the Bank’s Claims call 
center.5 
 
2  
Memorandum of Points and Authorities in Support of Motion for Class Certification, In re: Bank of America 
California Unemployment Benefits Litigation, No. 3:21-md-02992-GPC-MSB, United States District Court for 
the Southern District of California, August 29, 2024 (“Motion for Class Certification”) at 2. 
3  
SAMCC, ¶¶ 93-96. 
4  
SAMCC, ¶¶ 55-69, 97-105.  
5  
The other four proposed classes are: 
• 
Claim Denial Class, defined as “[a]ll Bank of America EDD cardholders who notified the Bank that 
an unauthorized transaction had occurred on their Bank of America EDD debit card account (‘Claim’) 
at an automated teller machine (‘ATM’), and whose Claim the Bank denied or closed at any time from 
September 28, 2020 through June 8, 2021, based solely on Indicator 1 of the Bank’s CFF.” 
• 
Credit Rescission Class, defined as “[a]ll Bank of America EDD debit cardholders who received 
permanent credit from the Bank in connection with their Claim, which credit the Bank rescinded at 
any time from September 28, 2020 through June 8, 2021, based solely on Indicator 1 of the Bank’s 
CFF.”  
• 
Account Freeze Class, defined as “[a]ll Bank of America EDD cardholders whose EDD debit card 
account (“Account”) the Bank froze at any time from September 28, 2020 through March 18, 2021, 
based solely on Indicator 1 of the Bank’s CFF, and whose Account the Bank (i) subsequently unfroze, 
or (ii) subsequently converted from frozen to blocked status on or after March 18, 2021, and then 
unblocked.” 
• 
EMV Chip Class, defined as “[a]ll members of the Claim Denial Class and/or the Credit Rescission 
Class whose EDD debit card did not include an EMV chip prior to June 9, 2021.” 
 
Expert Class Certification Report of Greg J. Regan, CPA/CFF, CFE, August 29, 2024, Motion for Class 
Certification, PX 4 (“Regan Report”), ¶ 4; Expert Report of Jay Minnucci, August 29, 2024, Motion for Class 
Certification, PX 3 (“Minnucci Report”), ¶ 2. 
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CONFIDENTIAL  
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7. 
I have been retained by counsel for Defendant Bank of America, N.A. (“Bank of America” or 
“Bank”) to address certain opinions offered by Mr. Jay Minnucci and Mr. Greg J. Regan in 
their expert reports dated August 29, 2024 (the “Minnucci Report” and the “Regan Report,” 
respectively). Specifically, I have been asked to respond to:  
a. Assertions regarding customer service processes underlying Mr. Regan’s opinion that 
actual damages for members of the proposed Customer Service Class can be calculated 
on a class wide basis;6 
b. Similar assertions underlying Mr. Regan’s proposed methodology to calculate actual 
damages for members of the proposed Customer Service Class;7 and 
c. Mr. Minnucci’s opinion that the average speed to answer of 75 seconds (1.25 minutes) 
based on a survey of 214 call centers in 2020 is an appropriate industry benchmark to use 
against the wait times experienced by members of the proposed Customer Service Class.8 
8. 
This report does not respond to all of the opinions in the Minnucci or Regan Reports. This 
report only responds to those specific opinions or assumptions that counsel has asked me to 
respond to for purposes of opposing Plaintiffs’ Motion for Class Certification. I reserve the 
right to respond to additional opinions or assumptions in the Minnucci and Regan Reports if 
asked to do so by counsel in the future. 
9. 
This declaration contains my current opinions in this matter. I reserve the right to supplement 
my opinions if additional relevant information becomes available. 
10. 
The materials that I have personally reviewed and relied on in preparing this declaration are 
listed in Appendix A of this declaration. A copy of my CV is attached hereto as Appendix 
B. I have not provided any expert testimony in the past four years.   
 
6  
Regan Report, ¶ 113. 
7  
Regan Report, ¶ 114. 
8  
Minnucci Report, ¶¶ 12, 37, 46. 
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11. 
Eleven Canterbury, an expert search firm, charges $925 per hour for my time spent on this 
matter, from which I receive $695 per hour for my time on this matter. Employees of 
Analysis Group, Inc. (“Analysis Group” or “AG”) working under my direction have assisted 
me in this assignment. My fees, Eleven Canterbury’s fees, and Analysis Group’s fees do not 
depend upon the opinions I form or upon the outcome of this litigation. 
III. 
SUMMARY OF OPINIONS 
12. 
Based on my review of the facts in this case and my experience, I have formed the following 
opinions: 
• Actual damages for individual members of the proposed Customer Service Class cannot 
reliably be calculated on a class wide basis using the methodology proposed by Mr. 
Regan; and 
• 
Mr. Minnucci has not shown that his proposed industry benchmark for Average Speed to 
Answer (“ASA”) is appropriate, which further renders Mr. Regan’s proposed damages 
calculation on an aggregate level speculative and unreliable. 
IV. 
A PROPOSED CUSTOMER SERVICE CLASS SEEKING ACTUAL DAMAGES 
BASED ON “AVERAGE EXCESS” WAIT TIMES CANNOT RELIABLY 
CALCULATE DAMAGES BECAUSE WAIT TIMES VARY INDIVIDUALLY, AND 
THE METHODOLOGY WRONGFULLY ASSUMES ALL CLASS MEMBERS 
WAITED EXACTLY THE AVERAGE WAIT TIME AND THEREFORE 
NECESSARILY INCLUDES CUSTOMERS WHO DID NOT EXPERIENCE WAIT 
TIMES IN EXCESS (OR MEANINGFULLY IN EXCESS) OF THE AVERAGE 
13. 
Mr. Regan opines that actual damages for members of the proposed Customer Service Class 
can be calculated on a class wide basis.9 Specifically, Mr. Regan opines that the actual 
damages can be measured by “the value of class members’ lost time spent on hold with Bank 
of America’s Claims call center that was greater than the reasonable wait-on-hold time by 
 
9  
Regan Report, ¶ 113. 
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customers seek help with disputed transactions. In addition, in my experience, wait times for 
incoming calls that occurred at the same time can differ, depending on how the call is routed 
and the performance of Customer Service Representatives (“CSR”) teams responding to the 
calls.  
17. 
Even if one were to assume that each individual proposed Customer Service class member 
incurred commensurate harm relative to the amount of time they waited for their call to be 
answered (and I do not agree with that assumption since each individual caller’s 
circumstances and impact (if any) will vary), applying an average wait time over the 
Proposed Class Period to the class members would overstate damages for some and 
understate damages for others.  For example, callers who waited shorter than average would 
be compensated the same under Mr. Regan’s methodology as callers who waited longer than 
average.  Additionally, callers who experienced wait times below even what Mr. Minnucci 
claims were industry benchmarks at the time, which is not an appropriate benchmark for the 
reasons explained below (see Section V), would also receive the same amount of 
compensation under Mr. Regan’s methodology as callers who waited the average amount of 
time or longer.  Neither Mr. Regan nor Mr. Minnucci consider how many proposed class 
members experienced wait times either above or below the ASA. 
18. 
While Mr. Regan relies on the average wait time for his proposed damages calculation, Mr. 
Minnucci appears to claim that specific wait times for specific callers are available. 
Specifically, he proffers that 
 
 
 
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proposed and Mr. Regan intends to use as an input to his proposed aggregate damages 
calculation is appropriate.19 Specifically, Mr. Minnucci has not shown that his industry 
benchmark properly reflects the ASA experienced by other call centers comparable to Bank 
of America’s Claims call center during the Proposed Class Period. 
21. 
Mr. Minnucci considers the average ASA reported by ContactBabel based on a survey of 214 
call centers in 2020, 75 seconds (or 1.25 minutes), as the appropriate “industry” 
benchmark.20 As shown in Table 1 below,21 this average ASA was based on respondents 
across various industry verticals. Only 29 (or 13.6 percent) were from the finance industry.22  
Table 1. Survey Respondents by Industry 
 
 
19  In addition, as I discussed above, 
 
. Therefore, Mr. Regan’s proposed approach for calculating aggregate damages also relies on an 
unsupported assumption that the average ASA for CA EDD customers is the same as the average ASA for all 
prepaid card programs. Neither Mr. Regan or Mr. Minnucci raised this assumption implicit in their analysis, nor 
did they provide anything to support its reasonableness. 
20  Mr. Minnucci opines that this average ASA of 75 seconds is “consistent with (but on the higher end) of my 
understanding of the industry standard ASA generally.” Minnucci Report, ¶ 12. 
21  DX 119, The 2021 US Contact Decision-Makers’ Guide, 13th Edition, ContactBabel at 15. 
22  Minnucci Report, fn. 1. 
Vertical Market
Number of 
Call Centers 
Interviewed
%
Finance 
29
14%
Insurance 
15
7%
Manufacturing 
12
6%
Medical 
28
13%
Outsourcing 
28
13%
Public Sector 
19
9%
Retail & Distribution 
20
9%
Services 
26
12%
Technology, Media and Telecoms (TMT) 
24
11%
Transport & Travel 
11
5%
None provided / other (not included in vertical market analysis) 
2
1%
Total
214
100%
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22. 
In my experience, ASA, which measures the average amount of time that a customer waits 
before speaking with an agent, is a common performance metric used to assess call center 
performance across different industries. However, in my experience, the expectations of 
target ASAs and realized ASAs vary depending on the industry, contracts, and the nature and 
complexity of the requests handled.23 For example, in my experience, wait times can be very 
different for call centers that handle general inquiries about account balance and certain 
transactions and those that handle more complex requests such as unauthorized transactions 
and account security. In my view, there is no standard ASA applicable to all call centers. 
23. 
This is especially true in 2020 after the outbreak of the global COVID-19 pandemic, which 
had different effects on call centers depending on the industry served and requests handled. 
For example, in my experience, call volumes in the hospitality and travel industry, which 
accounts for 11 of the respondents in the ContactBabel survey,24 plummeted as travel came 
to a halt at the onset of the pandemic. In contrast, Bank of America saw a massive growth in 
the number of new EDD prepaid accounts starting in April 2020, as business shutdowns and 
layoffs surged. During the 6-month period from March 2020 to August 2020, approximately 
 were created at Bank of America, compared to only 
 in the preceding six-month period from September 2019 to February 2020.25 As 
the number of EDD prepaid accounts increased, so did the demand for customer support. 
 
23  For example, in my experience, call centers for a bank typically prioritize CSAT (Customer Satisfaction) over 
call times, while call centers serving the hospitality industry prioritize minimizing call length to reduce wait 
times. 
24  DX 119, The 2021 US Contact Decision-Makers’ Guide, 13th Edition, ContactBabel,  
25  DX 120, BANA_EDD_MDL-00884198. 
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.27 Mr. Minnucci provides no evidence, and I have no reason to believe, that any of the 
call centers surveyed by ContactBabel experienced such a significant and extended increase 
in call volume over such a short period in time.   
24. 
Further, it is unreasonable to assume that any financial institution’s call center, particularly 
one responsible for servicing complex requests like transactional fraud claims, could 
immediately respond to such a significant spike in call volume.28 In my experience, the 
remote onboarding of new CSRs during the COVID-19 pandemic, including hiring, training, 
and then moving these CSRs to live calls, posed challenges for all call centers and in 
particular those that served highly regulated industries such as banking. This is because 
regulated contact centers supporting complex requests like Bank of America’s Claims call 
center require CSRs to undergo extensive training and follow strict protocols, in order to 
ensure regulatory compliance. In my experience, changing from in-person training where 
new hires benefit from face-to-face interactions, immediate feedback, and hands-on exercise, 
to a remote setting, negatively impacted the effectiveness and speed of the training. This 
resulted in higher turnover rates among the CSRs, which in turn necessitated the hiring of 
additional CSRs, further delaying the onboarding process. Moreover, due to the complex 
 
26  Number of calls offered include the number of calls handled as well as the number of calls abandoned. 
Minnucci Report, Appendix F. See also DX 116, BANA_EDD_MDL-00719115. 
27  Minnucci Report, Appendix F. See also DX 116, BANA_EDD_MDL-00719115. 
28  Besides the challenges with onboarding new CSRs that I discuss below, I note that another staffing issue during 
the pandemic in my experience was managing unpredictable and frequent sick leave among CSRs. 
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nature of the requests handled by the Claims call center, I would expect it to be also difficult 
to reassign existing CSRs from other programs or business lines to quickly respond to the 
unprecedented spike in call volume because these existing CSRs would require cross-training 
or retraining before going live.  
25. 
Additionally, in my experience, vendors used by Bank of America are required to sign 
General Services Agreements (GSAs) 
 
 
.29 Further, the outsourced call centers for large financial institutions typically 
do not have access to the systems that generate these data, nor are they provided these data 
by the Bank. Thus, it is likely that other similarly situated contact centers used by banks 
comparable to Bank of America would not be able to share such data with ContactBabel. 
This further supports that the average ASA reported by ContactBabel is derived from call 
centers not directly comparable to Bank of America’s Claims call center. 
26. 
In summary, for reasons discussed above, Mr. Minnucci has not shown that the industry 
benchmark he proposed appropriately reflects wait times experienced by call centers for the 
finance industry generally, much less call centers that serviced unemployment programs like 
CA EDD and similarly experienced unprecedented increase in volume and claims in 2020.  
Thus, he has not shown that it is appropriate to use his industry benchmark to compare 
against the experience of members of the proposed Customer Service Class. The approach 
proposed by Mr. Regan, which calculates aggregate damages based on Mr. Minnucci’s 
industry benchmark, is speculative and unreliable.  
 
29  See DX 118, BANA_EDD_MDL-00013111, section 15.0; DX 117, BANA_EDD_MDL-00012816, section 
15.0.  
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I declare under the penalty of perjury that the foregoing is true and correct.  
Executed on this 24th day of October, 2024. 
 
By:  
________________________ 
 
 
 
 
 
 
Stephen Hindle 
 
 
 
 
 
 
 
 
 
 
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CONFIDENTIAL
Appendix A
Documents Relied Upon
Legal Documents
1. Bank of America’s Responses and Objections to Plaintiff Yick’s Fifth Set of Interrogatories, In re: Bank of America
California Unemployment Benefits Litigation,  No. 3:21-md-02992-LAB-MSB, United States District Court for the Southern
District of California, February 2, 2024.
2. Declaration of Kelly Lorenzen.
3. Memorandum of Points and Authorities in Support of Motion for Class Certification, In re: Bank of America California
Unemployment Benefits Litigation,  No. 3:21-md-02992-GPC-MSB, United States District Court for the Southern District of
California, August 29, 2024.
4. Second Amended Master Consolidated Complaint, In re: Bank of America California Unemployment Benefits Litigation,  No.
3:21-md-02992-GPC-MSB, United States District Court for the Southern District of California, July 16, 2024.
Expert Reports
1. Expert Class Certification Report of Greg J. Regan, CPA/CFF, CFE, August 29, 2024, Motion for Class Certification, PX 4.
2. Expert Report of Jay Minnucci, August 29, 2024, Motion for Class Certification, PX 3.
Bates Stamped Documents
1. BANA_EDD_MDL-00012816.
2. BANA_EDD_MDL-00013111.
3. BANA_EDD_MDL-00719115.
4. BANA_EDD_MDL-00884198.
Publicly Available Documents
1. “7 Tips for Getting Better Customer Service,” TalkDesk, available at https://www.talkdesk.com/resources/infographics/tips-
for-getting-better-customer-service/.
2. The 2021 US Contact Decision-Makers’ Guide, 13th Edition, ContactBabel.
Note:
I also reviewed the materials listed in Appendix D of the Expert Report of Jay Minnucci, August 29, 2024 and Appendix B of the 
Expert Class Certification Report of Greg J. Regan, CPA/CFF, CFE, August 29, 2024.
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Eleven Canterbury, LLC • P.O. Box 111001, Naples, FL 34108 • +1 888-330-6850 • www.elevencanterbury.com 
STEPHEN  HINDLE 
FLORIDA 
EXPERIENCE 
ACHILLES SHIELD LLC 
2007 – Present 
Founder, Board Advisor, and Vice President, Tampa, FL 
•
Founder of consulting practice advising cybersecurity startups and VC Boards in partnership with the
Israeli Economic and Trade Mission, Washington DC. VP and Operating Officer of consultancy
business across four continents; APAC, EMEA, NAMER, LATAM.
•
Board member of “The American Dog Society”, a 501(c)(3) organization aiming to prevent and reduce
dog abandonment.
•
Board appointed fractional Chief IT & Security Officer for FinTech payments startup, “Orquid
Finance” providing financial services to the immigrant labor industry.
•
Board appointed fractional Chief IT & Security Officer for Television Station subsidiary of Berkshire
Hathaway - ensuring compliance with SEC mandates for cybersecurity.
•
Strategic cybersecurity advisory for disruptive data analytics startup, “Šóta Signal Analytics”
identifying Public Co. accounting fraud. The organization was awarded Entrepreneur of the Year 2023,
by Pasco Economic Development Council
•
Board member and CISO in Residence for two global 501c3 cybersecurity community organizations.
•
“The CISO Society” (>1,500 member CISOs), and “Infosec.Live” (>12,000 member cyber
talent development).
•
Principal Security Advisor in cybersecurity incident response and resilience planning for “Abira
Security.”
•
Principal Chief Security Advisor for sensitive data discovery and loss prevention organization,
“Spirion” providing SME advisory services to their prospective customers.
•
Cybersecurity Board Advisor for Venture Capital group investing in Israeli cybersecurity startups.
MAD MOBILE INC. 
2022 – 2023 
Disruptive global FinTech payments application development organization. 
Global Chief Information Security Officer (CISO) & CIO, Tampa, FL 
•
Created and delivered a combined greenfield Cybersecurity and IT strategic plan, which transformed
the organization’s maturity to defined industry standards and defensible Board metrics reporting on
cyber, legal, and risk landscape.
•
Negotiated Cybersecurity and Tech E&O insurance with 75% increase to coverage limits and removal
of 50% ransomware co-insurance obligation. Assessments by global insurance Carriers considered
program and controls to be “Best in Class.”
•
Delivered protective controls, preventing inbound threats including 78 attempts to deploy ransomware.
•
Restored client confidence and increased trust in CI/CD pipelines through automated application/code
scanning platform.
•
Ground-up creation of Governance, Risk Management, & Compliance program, delivering
consolidation of multiple external audits for Anti Money Laundering (AML) and obtaining compliance
certifications for PCI DSS, PCI P2PE, and SOC2.
•
Undertook ownership of IT strategy development with oversight of IT Technical Operations group, as
acting CIO.
•
Established strategic partnership with leading IT solution providers, resulting in >50% reduction in
renewal/replacement costs and improved efficiency by reducing deployment timeframes from >3
months to <4 days.
•
Developed a strategy to perform Cloud consolidation, reduce complexity and overall cost-reduction of
25%.
Appendix B
CONFIDENTIAL
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Eleven Canterbury, LLC • P.O. Box 111001, Naples, FL 34108 • +1 888-330-6850 • www.elevencanterbury.com 
•
Curated an Operational Risk Management framework with Board of Directors, providing quarterly
reporting on risk and quantifiable FinOps technology metrics illustrating reduced Total Cost of
Ownership and Return on Investment (ROI).
SITEL GROUP 
2016 – 2021 
One of the world’s leading business processing outsourcing (BPO) in the Call/Contact Center industry. 
Vice President, Head of Global Security, Miami, FL 
•
Held accountability for $8MM P&L budget and managing client programs that generated $4B revenue
across 40 countries and supporting 160K employees, 60% of which work remotely. Developed and
managed diverse cyber talent in a team of 60 top performers with strategic oversight of enterprise-level
risk management strategy.
•
Championed data security for complex, internationally recognized clients in highly regulated verticals
including banking and healthcare. Constantly driving innovation, effectiveness, and resilience in the
evolving battle against cyberattacks and data breaches.
•
Developed and maintained ownership and accountability of client relationships, designing, and
promoting service offerings to grow revenue streams, building protection around vital infrastructure,
business operating models, and security frameworks.
•
Resolved cyber risk issues for clients with improved deterrence and protection of legacy systems,
adapting to cloud-native architecture and tactics with upgraded internal controls and policies based
upon NIST Cybersecurity Framework.
•
Orchestrated crisis management for 70 global business continuity events since 2018, including
cybersecurity, civil unrest, extreme weather, power outages, bomb threats, tsunamis, earthquakes,
hurricanes, and Typhoons.
•
Led incident response of three global cybersecurity incidents in 2020, including ransomware and
DDOS. Increased client trust through collaboration and partnership with leading cybersecurity
organizations, strengthening client relationships through transparency and trust, with no loss of business
or revenue.
SYKES ENTERPRISES INC. 
1998 – 2016 
$2BN public company in the BPO Call/Contact Center industry. 
Senior Director, Global Security Operations, Tampa, FL (2008 – 2016) 
•
Formulated high level, strategic plans for multi-national Fortune 100-500 clients, prioritizing roadmaps
for data security, business continuity, disaster recovery, physical safety, and compliance to cover 100
locations in 26 countries with over 33K associates. Supplied strategic leadership to seven managers and
directors with a total team of 24 personnel.
•
Brought to life a global compliance assurance program which encompassed contractual requirements
alongside industry and regulatory compliance—served as an industry differentiator and created
alignment among people, processes, and technologies to drive 20% revenue growth in the
telecommunications vertical.
•
Defined best practices based on emerging trends and aligning cyber solutions to business needs and
appetite for risk, which included anti-fraud and social-threat programs as well as protection services in
areas of political and civil unrest.
•
Commended by U.S. military 3-star general for supplying critical intelligence crucial to success of ex- 
patriot evacuation during the 2011 “Arab Spring” civilian uprising in Egypt.
Director, Global Security (2003 – 2008) 
•
Formed and later Recognized for leading one of SC Magazine’s Top Five “Best Security Teams”
(2008)
•
Championed new business development and global service delivery, offering strategic guidance on IT,
security, & compliance programs.
CONFIDENTIAL
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Eleven Canterbury, LLC • P.O. Box 111001, Naples, FL 34108 • +1 888-330-6850 • www.elevencanterbury.com 
•
Formation of the Corporate Security & Risk Management (CSRM) organization and Global Security
Operations Center.
•
Developed payment card industry (PCI) compliance program, servicing 43 clients, and yielding
$850MM annual revenue.
•
Established a robust incident response plan and managed cyber crises in coordination with government
agencies, law enforcement and external counsel, to ensure solutions met with diverse and complex
regulations.
Technical Lead, Regional Enterprise Engineering (2000 – 2003) 
•
Expert Witness in criminal trials in the UK and South Africa
•
IT Architect & lead engineer for the EMEA region
•
IT Architect & lead engineer for the EMEA region.
•
Established 24/7/365 resilient, multi-regional data centers with supporting policies, standards, and
processes to provide end-to-end service solutions related to intrusion detection, penetration testing, risk
assessment and audit.
•
Accountable for software licensing and IT standards compliance.
•
Primary point of contact for security concerns and incident response prior to formal structure.
Manager, Training & Consultancy Solutions (1998 – 2000) 
•
Developed the first channel reseller training program for Citrix new ‘Multi-user NT’ platform
•
Launched specialized IT consultancy division and developed bespoke training program for partner
alliances, gaining highest-tier partner certification from Microsoft and Citrix to expand business
opportunities.
•
Led engineering of multi-user, thin-client, enterprise architecture for multinational banking, stock- 
market, and government customers.
•
Developed bespoke technical training programs and through formation of a 5-person team, delivered to
banking, oil, and defense industry clients globally in 3 languages.
MCQUEEN LTD. 
1996 – 1998 
Pioneer of offshore global BPO in the Call/Contact Center industry and distribution centers in Europe, Asia and 
the USA. 
Manager, Customer Engineering, Edinburgh, UK 
•
Led the provision of highly technical contact center teams
•
Built and managed outsourced European Response Centre for Insignia Solutions, a cross-platform
Operating System emulation and terminal services provider.
•
Delivered architecture and infrastructure planning for the first multinational contact center in The
Philippines in 1997.
•
Developed IT infrastructure for manufacturing, printing, and fulfilment operations in Galashiels
Scotland, Shannon Ireland, and Nashville Tennessee USA, for McQueen Ltd.
•
Print and production services for NATO threat assessment targets and patented self-healing ballistic
rubber; Rand McNally maps within the USA.
ROYAL BANK OF SCOTLAND 
1996 
Analyst 
•
Online Banking platform development and support.
•
Ensured all associates were appropriately trained for the call/contact center.
•
Transition from mainframe/command-line to Windows.
CONFIDENTIAL
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Eleven Canterbury, LLC • P.O. Box 111001, Naples, FL 34108 • +1 888-330-6850 • www.elevencanterbury.com 
LAND REGISTRY OF SCOTLAND 
1995 
Technician, Edinburgh, UK 
•
Geographical digitization and land dispute resolution of contested boundaries.
•
Technology administration.
SCOTTISH NATURAL HERITAGE 
1994 
Engineer, Edinburgh, UK 
•
Scottish Government conservation and oil-company partnerships.
•
Documentation and technology management.
HM CUSTOM & EXCISE AND INLAND REVENUE 
1993 
Secretary, London, UK 
•
Treasury and collection from debtors for the British government.
•
HM Collector of Taxes and Inspector of Taxes. Documentation and initial contact triage.
EDUCATION 
MBA, The PowerMBA, Harvard Business School 
Harvard ‘ManageMentor’ Certificates, Harvard Business School, Corporate Learning 
Executive & Cloud Financial Taxonomies, Technology Business Management (TBM Council) 
Bachelor of Arts (BA), Criminal Justice: Homeland Security, Saint Leo University (with highest honors) 
CISSP – Certified Information Systems Security Professional, (ISC)2 since 2007 
Building Leadership Impact, Eckerd College 
Accelerate Leadership Development, Spencer Stuart 
Community-Led Action in Response to Violent Extremism, University of Maryland 
Advanced OSINT Tradecraft 1-4, InfraGard National Members Alliance 
Network Cyber Threat Hunting, Active Countermeasures 
Active Shooter, FEMA 
CORE Impact Certified Professional (CICP), Core Security 
Advanced Interview & Interrogation, John Reid Institute 
Internal Auditor – ISO27001, British Standards Institution (BSI) 
Fighting COVID-19 with Epidemiology, Johns Hopkins Bloomberg School 
Chinese for HSK Prep 1 – 3.1, Peking University 
Microsoft Certified Systems Engineer (MCSE), Microsoft, 1999 – 2002 
PUBLICATIONS 
Everything Starts with a Why: How to Promote Meaningfulness at Work, AuditBoard 
Journey of a CISO, Cisco Secure 
Achieving Cyber Resilience in Today’s Threat Landscape, Cyberclan 
Cybersecurity Strategies & Challenges of a Hybrid World, Cisco 
Success Stories, Sykes Enterprises Inc 
CONFIDENTIAL
Case 3:21-md-02992-GPC-MSB     Document 350-6     Filed 10/24/24     PageID.11086 
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