Exhibit 59 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 379-2, S.D. Cal. No. 3:21-md-02992)

Summary

Bank of America, N.A.'s responses and objections to Plaintiff Jennifer Yick's Third Set of Interrogatories, dated December 21, 2023 and filed 11/22/24 as Document 379-2 in Case 3:21-md-02992-GPC-MSB, In re Bank of America California Unemployment Benefits Litigation. BANA objects that Interrogatory No. 21 has multiple subparts and that Plaintiffs have exceeded the 25 interrogatories permitted under the Local Rules. It will not answer the fourth subpart, on cardholders whose EDD Debit Card Accounts were solely blocked by the Claim Fraud Filter without a claim denial. For the rest it points to Exhibit 6, anonymized data by Card Alias ID showing which Claim Fraud Filter indicators each claim triggered. The filing also holds a page of Revised Exhibit 6 (Part 4), a proof of service and a verification by Jennifer Lennon.

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Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14473
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1 | JAMES W. MCGARRY (admitted pro hac vice)

JMcGar oodwinlaw.com
2 | GOOD PROCTER LLP
100 Northern Avenue

3 || Boston, MA 02210
Tel.: +1 617 570 1000
4 || Fax: +1 617 523 1231

5 | YVONNE W. CHAN (admitted pro hac vice)
YChan eae com
6 || JONES DAY
100 High Street
7 || Boston, MA 02110
Tel.: +1 617 960 3939
8 || Fax: +1 617 449 6999

9 || Attorneys for Defendant
BANK OF AMERICA, N.A.

11 UNITED STATES DISTRICT COURT
2 SOUTHERN DISTRICT OF CALIFORNIA

13 | INRE BANK OF AMERICA Case No. 3-21-md-02992-LAB-MSB
CALIFORNIA UNEMPLOYMENT
14 || BENEFITS LITIGATION,

BANK OF AMERICA’S

15 RESPONSES AND OBJECTIONS
TO PLAINTIFF YICK’S THIRD
16 SET OF INTERROGATORIES

This Document Relates to All Actions

l
28 BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14474

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RESPONDING PARTY: Defendant, Bank of America, N.A.
PROPOUNDING PARTY: Plaintiff, Jennifer Yick
SET NO.:: THREE

Pursuant to Federal Rule of Civil Procedure 26(b)(1), Defendant Bank of
America, N.A. (“Defendant” or “BANA”) hereby submits the following responses
and objections (“Responses”) to Plaintiff Jennifer Yick’s (“Plaintiff”) Third Set of
Interrogatories (the “Interrogatories” or, individually, “Interrogatory”).

PRELIMINARY STATEMENT

BANA states that it is responding to the Interrogatories to the best of its present
knowledge and present investigation to date. BANA has not completed its pre-trial
research, investigation, or analysis of all the facts relating to this case and has not
completed its preparation for trial. Accordingly, while these Responses are based
upon a reasonable and appropriate investigation by BANA and its counsel, they
reflect the current state of BANA’s knowledge with respect to the matters about

which the Interrogatories are made. Thus, the information contained herein remains

subject to further review, and in making these Responses, BANA reserves the right

to amend, supplement, and/or otherwise change its Responses as further investigation
and discovery may make appropriate in accordance with BANA’s obligations under
the Federal Rules of Civil Procedure and the Local Rules for the United States
District Court for the Southern District of California (the “Southern District Local
Rules”). Furthermore, BANA has prepared these Responses based on its good faith
interpretation and understanding of each individual Interrogatory, but BANA
reserves its right to correct any errors or omissions.

BANA provides its Responses to these Interrogatories without waiving, but
rather intending to preserve: (a) any applicable right, privilege or objection; (b) the
right to object to Plaintiffs use of any information and/or documents provided on the
ground of inadmissibility as evidence for any purpose in any aspect of this or any

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14475

on A Dn nan FP W WN

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other court action or judicial or administrative proceeding or investigation; (c) the
right to object at any time to a request for any further information and/or response to
this or any other Interrogatory; and (d) the right at any time to supplement any of its
Responses to these Interrogatories.

These Responses are made solely for the purpose of this action. Nothing
herein shall be construed as an admission respecting the admissibility or the relevance
of any facts, documents, or information, as an admission that documents or
information exist, or as an admission as to the truth or accuracy of any
characterization or assertion contained in any Interrogatory. Each Response is
subject to all objections as to competence, relevance, materiality, propriety, and
admissibility, and any and all other objections on grounds that would require the
exclusion of any statement herein if any of the Interrogatories were asked of, or
statements contained herein were made by, a witness present and testifying in court,
all of which objections and grounds are reserved and may be interposed at the time
of trial.

The following responses are provided subject to this Preliminary Statement,
which BANA hereby incorporates by reference into each Response.

GENERAL OBJECTIONS
L; BANA objects to Plaintiff's “Instructions,” “Definitions,” and each and

every Interrogatory to the extent that they seek information relating to individuals
who are not putative class representatives or individual plaintiffs in this action.

om BANA objects to Plaintiff's “Instructions,” “Definitions,” and each and
every Interrogatory that purports to seek information or documents related to
accounts other than EDD Debit Card accounts or account holders other than EDD
Debit Card account holders.

3, BANA objects to each and every Interrogatory to the extent that it seeks
information constituting trade secrets or proprietary or confidential business

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14476

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information.

4. BANA objects to each and every Interrogatory to the extent that it seeks
information protected from discovery by the attorney-client privilege, the work
product doctrine, the joint defense privilege, the bank examiner privilege, or any
other privileges or reasons for non-production. Plaintiffs’ discovery requests will not
be construed to seek such information. Inadvertent disclosure of privileged
information is not intended to be, and may not be construed as, a waiver of any
applicable privilege or similar basis for non-disclosure.

5. BANA objects to each and every Interrogatory to the extent that it seeks
information not in the possession, custody, or control of BANA, and purports to
require BANA to produce information in the possession of other entities.

OBJECTIONS TO DEFINITIONS

1, BANA objects to Plaintiff's Definition No. 2 on the grounds that the

definition of “ACCOUNT BLOCK SUBCLASS MEMBERS?” is overly broad and

seeks information that is not relevant to any claims or defenses in this litigation
because the definition includes individuals who have no claim for relief under the
causes of action asserted by Plaintiffs, and insofar as it incorporates other broadly
defined terms. BANA further objects to this definition on the basis that responding
to any such interrogatory applying this definition is premature as no such subclass
has been certified.

i. BANA objects to Plaintiff's Definition No. 5 on the grounds that the
definition of “BLOCK” is overly broad, unduly burdensome, and seeks information
that is not relevant to any claims or defenses in this litigation insofar as the term
“BLOCK” is not limited to blocks placed on accounts as a result of the application
of the Claims Fraud Filter, and insofar as it incorporates other broadly defined terms.

3. BANA objects to Plaintiff's Definition No. 6 on the grounds that the
definition of “CARDHOLDER?” is overly broad insofar as it includes “debit card[s]

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14477

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or credit card[s]” that are not EDD Debit Cards, and it incorporates other broadly
defined terms.

4. BANA objects to Plaintiff's Definition No. 9 on the grounds that the
definition of “CLAIM” is overly broad and seeks information that is not relevant to
the claims and defenses in this litigation insofar as it incorporates other broadly
defined terms and defines a “CLAIM” in a manner inconsistent with unauthorized
electronic funds transfer (“EFT”) error claims subject to 12 C.F.R. § 1005.11. For
these responses, BANA construes “Claim” to mean an unauthorized EFT error claim
in relation to an EDD Debit Card account (see 12 C.F.R. § 1005.11).

a. BANA objects to Plaintiff's Definition No. 10 on the grounds that the
definition of “CLAIM DECISION?” is overly broad to the extent it seeks information
concerning claims or claims decisions that are not relevant to this litigation, because
its use of the term “grant” is vague, ambiguous, and undefined, and to the extent it
incorporates other broadly defined terms. For these Responses, BANA construes
“CLAIM DECISION” to refer to its decision to either close or deny a claim because
the claim or account is deemed likely fraudulent or suspicious, or its decision to deny
or pay a claim based on its investigation of the claim or its determination that a claim
will be paid automatically through auto-pay.

6. BANA objects to Plaintiff's Definition No. 11 on the grounds that the
definition of “CLAIM FRAUD FILTER” is overly broad insofar as (1) the phrase
“automated tool, analysis, algorithm, process, or combination thereof used by YOU”
is vague, and (2) it incorporates other broadly defined terms. For these Responses,
BANA construes “Claim Fraud Filter” to have the same meaning as it does in the
Preliminary Injunction.!

Ke BANA objects to Plaintiff's Definition Nos. 16 and 32 on the grounds

' Preliminary Injunction refers to the Corrected Preliminary Injunction ordered by Judge Vince
Chhabria in Yick v. Bank of America, N.A., No. 3:21-cv-00376 (N.D. Cal. June 2, 2021). See ECF
No. 103. ‘

BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14478

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that “DEFENDANT” and “YOU” are overly broad to the extent it encompasses
persons and/or entities not within the control of BANA.

8. BANA objects to Plaintiff's Definition No. 18 on the grounds that the
definition of “EDD BENEFITS” is overly broad and seeks information not relevant
to any claims or defenses in this litigation insofar as its definition includes benefits
distributed by EDD that are not at issue in this case, including but not limited to paid
family leave benefits.

9. BANA objects to Plaintiff's Definition No. 19 on the grounds that the
definition of “EDD DEBIT CARD” is overly broad, ambiguous, and vague. For
purposes of these Responses and Objections, BANA construes “EDD Debit Card” or
“Card” to have the same meaning as “Card” and “Government Prepaid Debit Card”
in the California Employment Development Department Prepaid Debit Card Account
Agreement. See California Employment Development Department Prepaid Debit
Card Account Agreement (“Account Agreement”), at 2.”

10. BANA objects to Plaintiff's Definition No. 20 on the grounds that the
definition of “EDD DEBIT CARDHOLDER” is overly broad insofar as it
incorporates other broadly defined terms. For purposes of these Responses and
Objections, BANA construes “EDD Debit Cardholder” or “Cardholder” as an
individual to whom BANA issued an EDD Debit Card or his or her legal
representative. See Account Agreement, at 2.

11. BANA objects to Plaintiff's Definition No. 21 on the grounds that the
definition of “ERROR” is overly broad to the extent it seeks information that is not
relevant to any claims or defenses in this litigation insofar as it seeks information
concerning types of errors included in the definition set for at 15 U.S.C. § 1693f(f)

that are not at issue in this case.

* The Account Agreement was attached as Exhibit A to the Declaration of Brian Danitz in
Support of Plaintiffs’ Opposition to Defendant’s Motion to Dismiss in Yick v. Bank of America,
N.A., No. 3:21-cv-00376 (N.D. Cal. Nov. 15, ae See ECF No. 90-5.

BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14479

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12. BANA objects to Plaintiff's Definition No. 22 on the grounds that the
definition of “FREEZE” is overly broad, unduly burdensome, and seeks information
concerning EDD Debit Card Account freezes that are not relevant to any claims or
defenses in this litigation.

13. BANA objects to Plaintiff's Definition No. 30 on the grounds that the
definition of “RELEVANT PERIOD” is overly broad, unduly burdensome, and seeks
information that is not relevant to this litigation.

OBJECTION TO INSTRUCTIONS
le BANA objects to Instruction Nos. 2, 4, and 5 to the extent that they are

inconsistent with, or impose obligations or burdens upon BANA beyond those
required and/or permitted by, the Federal Rules, the Local Rules, and/or the rulings
and individual rules of the Court. BANA will respond to the Interrogatories, and to
each individual Interrogatory, pursuant to its obligations under the Federal Rules, the

Local Rules, and/or the rulings and individual rules of the Court.

RESPONSES AND OBJECTIONS
INTERROGATORY NO. 21:

IDENTIFY by Card Alias ID all EDD DEBIT CARDHOLDERS (1) whose
CLAIM YOU DENIED based solely on application of YOUR CLAIM FRAUD
FILTER, (2) whose previously granted PERMANENT CREDIT YOU reversed
based solely on application of YOUR CLAIM FRAUD FILTER, (3) whose
ACCOUNT YOU FROZE based solely on application of YOUR CLAIM FRAUD
FILTER, or (4) whose ACCOUNT YOU BLOCKED based solely on application of
YOUR CLAIM FRAUD FILTER. With respect to each such CARDHOLDER, state
which of the four aforementioned actions YOU took, identify the CLAIM FRAUD
FILTER criteria that were the basis for YOU taking those actions (i.e., state whether

“Indicator 1,” “Indicator 2,” and/or “Indicator 3” as described in
BANA _ EDD MDL-00005524 applied; which Indicator 3 “Features” described in

BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14480

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BANA EDD MDL-00005524 applied, if applicable; and/or whether some other
criterion applied).
RESPONSE TO INTERROGATORY NO. 21:

BANA incorporates its General Objections, Objections to Definitions, and
Objections to Instructions as if fully set forth herein. BANA further objects to this
Interrogatory on the grounds that it includes multiple subparts, rendering it at least
four separate interrogatories, and therefore in violation of Local Rule 33.1, because
Plaintiffs have exceeded the 25 interrogatories permitted under the Local Rules.
BANA reserves its right to contest this and any future Interrogatories that may be
propounded on this ground. BANA also objects to this Interrogatory as unduly
burdensome, overly broad, and because it seeks information that is irrelevant to the
claims and defenses in this litigation to the extent it seeks information concerning
EDD cardholders with prepaid debit card accounts that were blocked without an
accompanying Claim denial on or after the entry of the June 2, 2021 preliminary
injunction, and therefore have no claim for relief under the causes of action asserted
by Plaintiffs. BANA further objects to this Interrogatory on the grounds that it seeks
personal identifying information for individuals who are not putative class
representatives or individual plaintiffs in this case and who are not part of any class
that has been certified. BANA also objects to this Interrogatory to the extent that it
seeks information protected from discovery by attorney-client privilege, the work
product doctrine, the joint defense privilege, and the bank examiner, supervisory,
investigative, or other regulatory privileges. BANA further objects to this
Interrogatory as unduly burdensome to the extent it seeks data or information that is
not readily available in BANA’s systems of records and/or information that cannot
be determined without a manual individual review of each EDD cardholder’s file.

Subject to and without waiving the foregoing objections, BANA states that it
will not respond to the fourth subpart of this Interrogatory insofar as it requests

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14481

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information for EDD Debit Cardholders whose EDD Debit Card Accounts were
solely blocked based on application of the Claim Fraud Filter without an
accompanying claim denial. BANA further states that Exhibit 6 to BANA’s
interrogatory responses provides its response to Plaintiffs’ Interrogatory No. 21. The
source of this data is BANA’s claims system of record, Wadworth, The W, which is
BANA’s primary system of record for transactional data received from Visa, and data
from GIS.

Specifically, the tab labelled “Part 1” of Exhibit 6 contains responsive data
anonymized for all EDD Cardholders whose claim triggered the Claim Fraud Filter.
Column A (CardAliasID) contains the Card Alias ID, which is a unique identifier
assigned by Visa to each EDD Cardholder’s prepaid debit card account. Column B
(Ind1) indicates whether the cardholder’s claim triggered Claim Fraud Filter
Indicator 1. Column C (Ind2) indicates whether the cardholder’s claim triggered
Claim Fraud Filter Indicator 2. Column D (Ind3) indicates whether the cardholder’s
claim triggered Claim Fraud Filter Indicator 3.

The tab labelled “Part 2” of Exhibit 6 contains responsive data anonymized for
all EDD Cardholders who BANA’s records indicate the claim received a permanent
credit from BANA in connection with their claim that may have been rescinded based
on application of the Claim Fraud Filter. Column A (CardAliasID) contains the Card
Alias ID, which is a unique identifier assigned by Visa to each EDD Cardholder’s
prepaid debit card account. Column B (Ind1) indicates whether the cardholder’s
claim triggered Claim Fraud Filter Indicator 1. Column C (Ind2) indicates whether
the cardholder’s claim triggered Claim Fraud Filter Indicator 2. Column D (Ind3)
indicates whether the cardholder’s claim triggered Claim Fraud Filter Indicator 3.

The tab labelled “Part 3” of Exhibit 6 contains responsive data anonymized for
all EDD Cardholders whose EDD Debit Card Accounts were frozen during the
putative Class Period based on the application of the Claim Fraud Filter. Column A

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14482

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(CardAliasID) contains the Card Alias ID, which is a unique identifier assigned by
Visa to each EDD Cardholder’s prepaid debit card account. Column B (Ind1)
indicates whether the cardholder’s claim triggered Claim Fraud Filter Indicator 1.
Column C (Ind2) indicates whether the cardholder’s claim triggered Claim Fraud
Filter Indicator 2. Column D (Ind3) indicates whether the cardholder’s claim
triggered Claim Fraud Filter Indicator 3.

The tab labelled “Part 4” of Exhibit 6 contains responsive data anonymized for
all EDD Cardholders who submitted a claim between March 18, 2021 and June
8, 2021, whose claim triggered the Claim Fraud Filter, and whose EDD Debit
Card Accounts were blocked based on application of the Claim Fraud Filter.
Column A (CardAliasID) contains the Card Alias ID, which is a unique identifier
assigned by Visa to each EDD Cardholder’s prepaid debit card account.
Column B (Ind1) indicates whether the cardholder’s claim triggered Claim
Fraud Filter Indicator 1. Column C (Ind2) indicates whether the cardholder’s
claim triggered Claim Fraud Filter Indicator 2. Column D (Ind3) indicates
whether the cardholder’s claim triggered Claim Fraud Filter Indicator 3.
INTERROGATORY NO. 22:

For each individual identified in response to Interrogatory No. 21, state

whether the individual “(i) has been disqualified by the state from Program
eligibility;” whether the individual “(ii) has previously engaged in fraudulent
Program conduct, such as submission of fraudulent claims or other abuse of the
claims process;” and whether the individual “(iii) has had their card frozen due to
legal order processes, as a result of Internal/Vendor fraud investigations, or by Global
Financial Crimes Compliance,” as referenced at page 3 of the REMEDIATION
PLAN (BANA _ EDD MDL-00102475).

RESPONSE TO INTERROGATORY NO. 22:

BANA incorporates its General Objections, Objections to Definitions, and

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14483

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Dated: December 21, 2023 Respectfully Submitted,

By-/s/ James W. McGarry

JAMES W. MCGARRY
JMcGarr oodwinlaw.com
GOODW! ROCTER LLP
100 Northern Avenue

Boston, MA 02210

Tel.: +1 617 570 1000

Fax: +1 617 523 1231

MATTHEW L. RIFFEE
GOOD PROCTER LLP
1900 N Street, NW
Washington, DC 20036

Tel.: +1 202 346 4000

Fax: +1 202 204 7237

YVONNE W. CHAN
JONES DAY

100 High Street
Boston, MA 02110
Tel.: +1 617 960 3939
Fax: +1 617 449 6999

Attorneys for Defendant BANK OF
AMERICA, N.A.

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14484

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PROOF OF SERVICE

Iam employed in Washington, DC. I am over the age of 18 and not a party
to the within action. My business address is: 1900 N Street, NW Washington, DC.

On December 21, 2023 I caused to be served the following document on the
person(s) below:

DEFENDANT BANK OF AMERICA, N.A.’°S_ RESPONSES AND
OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)

Brian Danitz Interim Co-lead Counsel for
Karin B. Swope Plaintiffs and Proposed Class
Andrew F. Kirtley Tel.: 650-697-6000
Peter Luc bdanitz@cpmlegal.com
Jeanine Toomey kswope@cpmlegal.com
Cotchett, Pitre & McCarthy, LLP akirtley@cpmlegal.com
840 Malcolm Road, Suite 200 pluc@cpmlegal.com
Burlingame, CA 940010 Jtoomey@cpmlegal.com
Michael Rubin Interim Co-lead Counsel for
Stacey M. Leyton Plaintiffs and Proposed Class
Matthew Murray Tel.: 415-421-7151
tshuler Berzon
177 Post Street, Suite 300 sais omerensal
San Francisco, CA 94108 mmurray@altber.com

cchan@altber.com

X (E-MAIL or ELECTRONIC TRANSMISSION) By electronic service.

ased ee a court order or agreement of the parties to accept electronic

service, I caused the documents to be sent to the persons at the electronic
service addresses listed

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 21, 2023 at New York, New York.

Matthew L. Riffee /s/ Matthew L. Riffee

(Type or print name) (Signature)

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BANK OF AMERICA’S RESPONSES AND OBJECTIONS TO PLAINTIFF YICK’S THIRD SET OF
INTERROGATORIES (SET THREE)
Case 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14485
Page 14 of 15

CONFIDENTIAL - ATTORNEYS' EYES ONLY
REVISED EXHIBIT 6 TO BANA's RESPONSE TO PLAINITFFS' INTERROGATORIES (INTERROGATORY 21 - Part 4) (February 15, 2024)

CardAliasiD Ind1 Ind2 Ind3 Featurel Feature2 Feature3 Feature4 FeatureS FeatureAmt
0000000000079895732
0000000000079896209
0000000000079896938
0000000000079897124
0000000000079897597
0000000000079897632
0000000000079897777
0000000000079897781
0000000000079898409
0000000000079899110
0000000000079900482
0000000000080072874
0000000000080072891
0000000000080072955
0000000000080073689
0000000000080073842
0000000000080074685
0000000000080075017
0000000000080075083
0000000000080075387
0000000000080075420
0000000000080075631
0000000000080075800
0000000000080075803
0000000000080075925
0000000000080075984
0000000000080076053
0000000000080076421
0000000000080076554
0000000000080076656
0000000000080077087
0000000000080225965
0000000000080227216
0000000000080227228
0000000000080227427
0000000000080227527
0000000000080227942
0000000000080228021
0000000000080228067
0000000000080228236
0000000000080228451
0000000000080228678
0000000000080392931
0000000000080393330
0000000000080394097
0000000000080394235
0000000000080394322
0000000000080394792
0000000000080395064
0000000000080395227
0000000000080396018
0000000000080396057
0000000000080396710
Cas

2 3:21-md-02992-GPC-MSB Document 379-2 Filed 11/22/24 PagelD.14486
Page 15 of 15

VERIFICATION OF INTERROGATORY RESPONSES

I, Jennifer Lennon, am the Product Management and State Liaison for Bank
of America, N.A. (“BANA”) and am authorized to make this verification for and on
behalf of BANA. I have reviewed BANA’s Responses and Objections to Plaintiff's
Third Set of Interrogatories (“Responses”), and I am informed and believe, based
on reasonable investigation, that the matters stated in the Responses are true and
correct. I declare under penalty of perjury that the foregoing is true and correct to
the best of my knowledge and belief.

Executed on 2 \ day, December 2023, in Los Angeles, California.

JENNIFER LENNON

ACTIVE/124741798.1

Verification


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