Exhibit 146 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 379-7, S.D. Cal. No. 3:21-md-02992)

Summary

Exhibit 146, filed 11/22/24 as Document 379-7 in Case 3:21-md-02992-GPC-MSB, is Bank of America, N.A.'s revised second supplemental responses and objections to Plaintiff Jennifer Yick's first set of interrogatories in In re Bank of America California Unemployment Benefits Litigation, dated December 1, 2023. The bank objected to identifying subclass members because no subclass had been certified, then pointed to anonymized data in exhibits. Exhibit 1 covers EDD Cardholders whose claims, submitted between January 1, 2020 and June 2, 2021, triggered the Claim Fraud Filter and were later paid; Exhibit 2 covers rescinded permanent credits; Exhibit 3 covers accounts frozen under the filter and later unfrozen or unblocked. The bank says it does not track whether a claim was reopened under the Preliminary Injunction. Jennifer Lennon, Product Management and State Liaison, verified the responses.

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Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14505
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Exhibit 146
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JAMES W. MCGARRY (admitted pro hac vice)

JMcGarr oodwinlaw.com
GOOD ROCTER LLP
100 Northern Avenue

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

YVONNE W. CHAN (admitted pro hac vice)
YChan Uyonesday. com

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.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

IN RE BANK OF AMERICA Case No. 3-21-md-02992-LAB-MSB
CALIFORNIA UNEMPLOYMENT
BENEFITS LITIGATION,

BANK OF AMERICA’S REVISED
SECOND SUPPLEMENTAL
RESPONSES AND OBJECTIONS
TO PLAINTIFF YICK’S FIRST
This Document Relates to All Actions SET OF INTERROGATORIES
(INTERROGATORIES 2-6, 14-15)

EXHIBIT

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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RESPONDING PARTY: Defendant, Bank of America, N.A.
PROPOUNDING PARTY: Plaintiff, Jennifer Yick
SET NO.: ONE

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

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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ground of inadmissibility as evidence for any purpose in any aspect of this or any
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
as 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.

2. BANA objects to Plaintiffs “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

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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information constituting trade secrets or proprietary or confidential business
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.

a 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

if BANA objects to Plaintiff's Definition No. 8 on the grounds that the

definition of “RELEVANT PERIOD” is overly broad, unduly burdensome, and seeks

information that is not relevant to this litigation.

De BANA objects to Plaintiff's Definition Nos, 17 and 19 on the grounds
that the definition of “EDD DEBIT CARD” and “EDD DEBIT CARD ACCOUNT”
are 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, and “EDD Debit
Card Account” or “Account” to have the same meaning as “Account” and
“Government Prepaid Debit Card Account” in the same agreement. See California

Employment Development Department Prepaid Debit Card Account Agreement

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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(“Account Agreement”), at 2.!

3. BANA objects to Plaintiff's Definition No. 20 on the erounds that the
definition of “CARDHOLDER” is overly broad insofar as it includes “debit card[s]
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. 21 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.

Ds BANA objects to Plaintiff's Definition No. 22 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).

6. BANA objects to Plaintiff's Definition No. 23 on the grounds that the
definition of “CLAIM INVESTIGATION” is overly broad and seeks information
not relevant to any claims or defenses in this litigation insofar as it incorporates other
broadly defined terms and defines “CLAIM INVESTIGATION” in a manner that
seeks information unrelated to the investigation of claims made by EDD Debit Card
Accountholders or the investigation of claims by means other than through the Claim

Fraud Filter.

' 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, at See ECF No. 90-5.

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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7. BANA objects to Plaintiff's Definition No. 24 on the grounds that the
definition of “CLAIM FRAUD FILTERS” is overly broad insofar as (1) the phrase
“tool or tools that DEFENDANT uses or has used to detect potentially fraudulent or
suspicious CLAIMS” 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.?

8. BANA objects to Plaintiff's Definitions Nos. 29 and 30 on the grounds
that the definition of “FREEZE” and “UNFREEZE” 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.

D, BANA objects to Plaintiff's Definitions Nos. 31 and 32 on the grounds
that the definition of “BLOCK” and “UNBLOCK” 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” and “UNBLOCK” are not limited to
blocks placed on accounts as a result of the application of the Claims Fraud Filter as
it includes all (i) “actions taken by DEFENDANT which prevent an EDD DEBIT
CARDHOLDER from accessing funds in, or otherwise using, their EDD DEBIT
CARD ACCOUNT,” and (ii) “any instance in which DEFENDANT uses the word
‘blocking,’ ‘blocked,’ or another iteration of the word “block” in connection with or
relation to an EDD DEBIT CARD, an EDD DEBIT CARD ACCOUNT, or an EDD
DEBIT CARDHOLDER’ ability or inability to access or use their EDD DEBIT
CARD or EDD DEBIT CARD ACCOUNT,” and insofar as it incorporates other
broadly defined terms.

10. BANA objects to Plaintiff's Definitions Nos. 33 and 34 on the grounds
that the definitions of “CONTRACTOR” and “CSP” are overly broad, unduly

* 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. é

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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burdensome, and seek information that is potentially not relevant to the claims and
defenses in this litigation. For these Responses, BANA construes “CONTRACTOR”
and “CSP” to include only those Contractors and CSPs performing a customer
service function for EDD Debit Cards that are relevant to the claims or defenses in
this litigation.

11. BANA objects to Plaintiff's Definition No. 35 on the grounds that the
definition of “PERSONAL INFORMATION” is overly broad and encompasses
information that would not be sufficient to effect an unauthorized transaction and
information that is not protected by any statute, regulation, or other law.

OBJECTION TO INSTRUCTIONS
1. BANA objects to Instruction Nos. 2, 4, and 6 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. 2:
IDENTIFY all CLAIM DENIAL SUBCLASS MEMBERS.
RESPONSE TO INTERROGATORY NO. 2:
BANA incorporates its General Objections, Objections to Definitions, and

Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the basis that responding to any such interrogatory is premature as
no such subclass has been certified. BANA further objects to this Interrogatory as
overly broad on the grounds that the definition of “CLAIM DENIAL SUBCLASS
MEMBER?” includes individuals who are not eligible for relief under the causes of
action asserted by Plaintiffs, including individuals whose EDD Debit Card Account

F

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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is not an “account” covered by EFTA. BANA also objects to this Interrogatory on
the grounds that the definition of “CLASS MEMBER?” in Plaintiffs’ FAMCC is not
identifiable by BANA to the extent it is based on information concerning EDD’s
reasoning that is not in BANA’s possession, custody, or control because it excludes
persons from the class definition whose benefits were revoked for failure to
establish valid identity with EDD. 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 or subclass that has been certified.

Based on these objections, BANA will not respond to Interrogatory No. 2 at
this time.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 2:

Subject to and without waiving any objections stated in BANA’s initial
response to Interrogatory No. 2, and in accordance with the Parties’ September 18,
2023 and September 22, 2023 letters and related correspondence and
communications, BANA states that Exhibit 1 to this Supplemental Response contains
BANA’s response to Interrogatories 2 and 6.

Specifically, Exhibit 1 contains responsive data anonymized for all EDD
Cardholders who submitted a claim between January 1, 2020 and June 2, 2021,
whose claim triggered the Claim Fraud Filter, and was subsequently paid by
BANA. 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. 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 (ClaimNbr) contains the Claim Number assigned by
BANA to each claim. Column C (ClaimEntryDte) contains the Claim Entry Date,
which is the date on which the claim was entered into BANA’s system of record

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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(Wadworth). Column D (CardProgramID) contains the Card Program ID for the
EDD Unemployment Insurance Benefits Program (SC384-CAEDDUE) or the EDD
Disability Insurance Benefits Program (SC384-CAEDDDI). Column E
(ClaimAmt) contains the amount of the claim. Column F (FraudFilterFileDate)
contains the date the claim triggered the Claim Fraud Filter. Column G
(Paid_Date) contains the date the claim was paid.
INTERROGATORY NO. 3:

IDENTIFY all CREDIT RESCISSION SUBCLASS MEMBERS.
RESPONSE TO INTERROGATORY NO. 3:

BANA incorporates its General Objections, Objections to Definitions, and

Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the basis that responding to any such interrogatory is premature as
no such subclass has been certified. BANA further objects to this Interrogatory as
overly broad on the grounds that the definition of “CREDIT RESCISSION
SUBCLASS MEMBER?” includes individuals who are not eligible for relief under
the causes of action asserted by Plaintiffs, including individuals whose EDD Debit
Card Account is not an “account” covered by EFTA, and individuals for whom the
recission of a credit after 45 days did not constitute an EFTA violation. BANA also
objects to this Interrogatory on the grounds that the definition of “CLASS
MEMBER?” in Plaintiffs’ FAMCC is not identifiable by BANA to the extent it is
based on information concerning EDD’s reasoning that is not in BANA’s
possession, custody, or control because it excludes persons from the class definition
whose benefits were revoked for failure to establish valid identity with EDD.
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 or subclass that
has been certified.

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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Based on these objections, BANA will not respond to Interrogatory No. 3 at
this time.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 3:

Subject to and without waiving any objections stated in BANA’s initial
response to Interrogatory No. 3, and in accordance with the Parties’ September 18,
2023 and September 22, 2023 letters and related correspondence and
communications, BANA states that Exhibit 2 to this Supplemental Response contains
BANA’s response to Interrogatory 3.

Specifically, Exhibit 2 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 was rescinded based on application
of the Claim Fraud Filter. 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. 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 (ClaimNbr) contains the Claim Number
assigned by BANA to each claim. Column C (ClaimEntryDte) contains the Claim
Entry Date, which is the date on which the claim was entered into BANA’s system
of record (Wadworth). Column D (ClaimAmt) contains the amount of the claim.
Column E (CreditDte) is the date BANA’s records indicate the claim received a
permanent credit from BANA. Column E (FraudFilterDte) contains the date the
claim triggered the Claim Fraud Filter. Column F (Paid Date) contains the date the
claim was paid or re-credited (if applicable).

INTERROGATORY NO. 4:

IDENTIFY all ACCOUNT FREEZE SUBCLASS MEMBERS.
RESPONSE TO INTERROGATORY NO. 4:

BANA incorporates its General Objections, Objections to Definitions, and

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the basis that responding to any such interrogatory is premature as
no such subclass has been certified. BANA further objects to this Interrogatory as
overly broad on the grounds that the definition of “ACCOUNT FREEZE
SUBCLASS MEMBER?” includes individuals who have no claim for relief under
the causes of action asserted by Plaintiffs. BANA also objects to this Interrogatory
on the grounds that the definition of “CLASS MEMBER?” in Plaintiffs’ FAMCC is
not identifiable by BANA to the extent it is based on information concerning
EDD’s reasoning that is not in BANA’s possession, custody, or control because it
excludes persons from the class definition whose benefits were revoked for failure
to establish valid identity with EDD. 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 or subclass that has been certified.

Based on these objections, BANA will not respond to Interrogatory No. 4 at
this time.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 4:

Subject to and without waiving any objections stated in BANA’s initial
response to Interrogatory No. 4, and in accordance with the Parties’ September 18,
2023 and September 22, 2023 letters and related correspondence and
communications, BANA states that Exhibit 3 to this Supplemental Response contains
BANA’s response to Interrogatories 4 and 5.

Specifically, Exhibit 3 contains responsive data anonymized for all EDD
Cardholders whose EDD Debit Card Account were frozen during the putative Class
Period based on application of the Claim Fraud Filter, and whose EDD Debit Card
Accounts were later unfrozen or converted from frozen to blocked status and then
unblocked. The source of this data is The W, which is BANA’s primary system of

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BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14517
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record for freeze, block, and transactional data relating to EDD prepaid debit cards.
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
(Frd_Flt_Frz_Dte) contains the date the EDD Cardholder’s prepaid debit card
account was frozen. Column C (Balance _at Freeze) contains the EDD Cardholder’s
prepaid debit card account balance at the time of the freeze. Column D
(ACTION _DT) contains the date the EDD Cardholder’s prepaid debit card account
was unfrozen. Column E (ACTION) describes the action that was taken on the action
date. Column F (ACTION RQSTR) indicates whether the unfreeze action described
in Columns D and E was requested by BANA or the State (EDD). Column G
(ACTION REASON) contains the reason for the unfreeze action, with “Claims filter
— FTB” indicating the account was unfrozen because it was converted from freeze-
to-block. Column H (Unblock_Dt) contains the date the EDD Cardholder’s prepaid
debit account was unblocked, if applicable, following the conversion of their freeze
to a block. Column I (Current Account Status) contains the current status of the
EDD Cardholder’s prepaid debit card account as of November 30, 2023. Column J
(Current_Card_Status) contains the current status of the EDD Cardholder’s prepaid
debit card as of November 30, 2023. Column K indicates whether the EDD
Cardholder’s prepaid debit card account is currently blocked.
INTERROGATORY NO. 5:

For each ACCOUNT FREEZE SUBCLASS MEMBER, state: the date(s) on
which the individual’s EDD DEBIT CARDHOLDER ACCOUNT was FROZEN
based in whole or in part on the results of YOUR CLAIM FRAUD FILTER; the
ACCOUNT balance at the time the ACCOUNT was FROZEN; and the date(s) on
which such ACCOUNT was UNFROZEN.

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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RESPONSE TO INTERROGATORY NO. 5:

BANA incorporates its General Objections, Objections to Definitions, and
Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the grounds that responding to any such interrogatory is premature
as no such subclass has been certified. BANA further objects to this Interrogatory as
overly broad on the grounds that the definition of “ACCOUNT FREEZE
SUBCLASS MEMBER” inolndes individuals who have no claim for relief under the
causes of action asserted by Plaintiffs. BANA also objects to this Interrogatory on
the grounds that the definition of “CLASS MEMBER” in Plaintiffs’ FAMCC is not
identifiable by BANA to the extent it is based on information concerning EDD’s
reasoning that is not in BANA’s possession, custody, or control because it excludes
persons from the class definition whose benefits were revoked for failure to establish
valid identity with EDD. 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 or subclass that has been certified.

Based on these objections, BANA will not respond to Interrogatory No. 5 at
this time.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 5:

Subject to and without waiving any objections stated in BANA’s initial
response to Interrogatory No. 5, and in accordance with the Parties’ September 18,
2023 and September 22, 2023 letters and related correspondence and
communications, BANA states that Exhibit 3 to this Supplemental Response contains
BANA’s response to Interrogatories 4 and 5.

Specifically, Exhibit 3 contains responsive data anonymized for all EDD
Cardholders whose EDD Debit Card Account were frozen during the putative Class
Period based on application of the Claim Fraud Filter and whose EDD Debit Card

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
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Accounts were later unfrozen or converted from frozen to blocked status and then
unblocked. The source of this data is The W, which is BANA’s primary system of
record for freeze, block, and transactional data relating to EDD prepaid debit cards.
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
(Frd_Flt_Frz Dte) contains the date the EDD Cardholder’s prepaid debit card
account was frozen. Column C (Balance_at Freeze) contains the EDD Cardholder’s
prepaid debit card account balance at the time of the freeze. Column D
(ACTION _DT) contains the date the EDD Cardholder’s prepaid debit card account
was unfrozen. Column E (ACTION) describes the action that was taken on the action
date. Column F (ACTION RQSTR) indicates whether the unfreeze action described
in Columns D and E was requested by BANA or the State (EDD). Column G
(ACTION_REASON) contains the reason for the unfreeze action, with “Claims filter
— FTB” indicating the account was unfrozen because it was converted from freeze-
to-block. Column H (Unblock Dt) contains the date the EDD Cardholder’s prepaid
debit account was unblocked, if applicable, following the conversion of their freeze
to a block. Column I (Current Account Status) contains the current status of the
EDD Cardholder’s prepaid debit card account as of November 30, 2023. Column J
(Current_Card_Status) contains the current status of the EDD Cardholder’s prepaid
debit card as of November 30, 2023. Column K indicates whether the EDD
Cardholder’s prepaid debit card account is currently blocked.
INTERROGATORY NO. 6:

For each CLAIM DENIAL SUBCLASS MEMBER, state: the amount of each
CLAIM they submitted at any time between January 1, 2020 and June 2, 2021 that
YOU initially DENIED based on the CLAIM FRAUD FILTER and that YOU
subsequently reimbursed after REOPENING the CLAIM pursuant to the

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14520
Page 16 of 24
So Oo NN DN

DT

CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER

PRELIMINARY INJUNCTION; the date they submitted each such CLAIM; and the
date YOU issued PERMANENT CREDIT on each such CLAIM.
RESPONSE TO INTERROGATORY NO. 6:

BANA incorporates its General Objections, Objections to Definitions, and
Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the grounds that responding to any such interrogatory is premature
as no such subclass has been certified. BANA further objects to this Interrogatory
on the grounds that the definition of “CLAIM DENIAL SUBCLASS MEMBER”
includes individuals who are not eligible for relief under the causes of action asserted
by Plaintiffs, including individuals whose EDD Debit Card Account is not an
“account” covered by EFTA. BANA also objects to this Interrogatory on the grounds
that the definition of “CLASS MEMBER” in Plaintiffs’ FAMCC is not identifiable
by BANA to the extent it is based on information concerning EDD’s reasoning that
is not in BANA’s possession, custody, or control because it excludes persons from
the class definition whose benefits were revoked for failure to establish valid identity
with EDD. 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
or subclass that has been certified. BANA further objects to this Interrogatory on the
grounds that it is unduly burdensome and seeks information that is not kept in the
ordinary course of business, such as whether a Claim was reopened “pursuant to” the
Preliminary Injunction.

Based on these objections, BANA will not respond to Interrogatory No. 6 at

this time.

‘EE

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14521
Page 17 of 24
ao nN BD

\o

a

CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 6:

Subject to and without waiving any objections stated in BANA’s initial
response to Interrogatory No. 6, and in accordance with the Parties’ September 18,
2023 and September 22, 2023 letters and related correspondence and
communications, BANA states that Exhibit 1 to this Supplemental Response contains
BANA’s response to Interrogatories 2 and 6.

Specifically, Exhibit 1 contains responsive data anonymized for all EDD
Cardholders who submitted a claim between January 1, 2020 and June 2, 2021,
whose claim triggered the Claim Fraud Filter, and was subsequently paid by
BANA. 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. 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 (ClaimNbr) contains the Claim Number assigned by
BANA to each claim. Column C (ClaimEntryDte) contains the Claim Entry Date,
which is the date on which the claim was entered into BANA’s system of record
(Wadworth). Column D (CardProgramID) contains the Card Program ID for the
EDD Unemployment Insurance Benefits Program (SC384-CAEDDUE) or the EDD
Disability Insurance Benefits Program (SC384-CAEDDDI). Column E
(ClaimAmt) contains the amount of the claim. Column F (FraudFilterFileDate)
contains the date the claim triggered the Claim Fraud Filter. Column G
(Paid Date) contains the date the claim was paid.

BANA is not able to determine for the purposes of this Response whether the
claims referenced in Exhibit 1 were reopened pursuant to the Preliminary Injunction
or for another reason because that is not a data point or information that BANA tracks
in its system of records. Thus, BANA is unable to respond to that portion of this
Interrogatory, and instead refers Plaintiffs to the data in Column G — which would

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14522
Page 18 of 24
CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER

indicate if the claim was paid prior to or following the entry of the Preliminary
Injunction, or prior to or following the entry of the CFPB Consent Order.
INTERROGATORY NO. 14:

IDENTIFY all CLASS MEMBERS who are also “Affected Consumers” as
defined in Paragraph 3 of the CFPB CONSENT ORDER.
RESPONSE TO INTERROGATORY NO. 14:

BANA incorporates its General Objections, Objections to Definitions, and

Objections to Instructions as if fully set forth herein. BANA objects to this
Interrogatory on the basis that responding to any such interrogatory is premature as
no such class has been certified and because it seeks information that do not yet
exist and may be subject to change as BANA’s implementation of the CFPB’s
Consent Order, dated July 14, 2022 (the “Consent Order”) is ongoing. BANA
further objects to this Interrogatory as overly broad on the grounds that the
definition of “CLASS MEMBER” includes individuals who are not eligible for
relief under the causes of action asserted by Plaintiffs, including individuals whose
EDD Debit Card Account is not an “account” covered by EFTA. BANA also
objects to this Interrogatory on the grounds that the definition of “CLASS
MEMBER” in Plaintiffs’ FAMCC is not identifiable by BANA to the extent it is
based on information concerning EDD’s reasoning that is not in BANA’s
possession, custody, or control because it excludes persons from the class definition
whose benefits were revoked for failure to establish valid identity with EDD.
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 the bank examiner, supervisory,
investigative, or other regulatory privileges.

BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14523
Page 19 of 24
CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER
1 || Dated: December 1, 2023 _—_ Respectfully Submitted,
3 By-/s/ Matthew L. Riffee
4 JAMES W. MCGARRY
JMcGarr oodwinlaw.com
5 GOODW. ROCTER LLP
100 Northern Avenue
6 Boston, MA 02210
Tel.: +1 617 570 1000
7 Fax: +1 617 523 1231
8 MATTHEW L. RIFFEE
ee oodwinlaw.com
a GOOD PROCTER LLP
1900 N Street, NW
10 Washington, DC 20036
Tel.: +1 202 346 4000
11 Fax: +1 202 204 7237
12 YVONNE W. CHAN
YChan@jonesday.com
13 JONE DAY
100 High Street
14 Boston, MA 02110
Tel.: +1 617 960 3939
15 Fax: +1 617 449 6999
16 Attorneys for Defendant BANK OF
AMERICA, N.A.
Da
a 24
BANK OF AMERICA’S REVISED SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO
PLAINTIFF YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14524
Page 20 of 24
a

NY HD vO

CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER

PROOF OF SERVICE

I am 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 1, 2023 I caused to be served the following document on the
person(s) below:

DEFENDANT BANK OF AMERICA, N.A.’S_-REVISED SECOND
SUPPLEMENTAL RESPONSES AND OBJECTIONS TO PLAINTIFF
Imad is) SET OF INTERROGATORIES (INTERROGATORIES 2-6

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
peas ae Chan LLP mrubin@altber.com
tshuler Berzon
177 Post Street, Suite 300 nhac oaaan
San Francisco, CA 94108 mmurray@altber.com

cchan@altber.com

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

ased es a court order or agreement of the parties to ace 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 1, 2023 at Washington, DC.

Matthew L. Riffee /s/ Matthew L. Riffee

(Type or print name) (Signature)

BANK OF AMERICA’S SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO PLAINTIFF
YICK’S FIRST SET OF INTERROGATORIES (INTERROGATORIES 2-6, 14-15)
Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14525
Page 21 of 24
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07 5 aalpy BAY TZ-4EW-EZ Ald - Jay sue|5 yueg = @ZBIIJUN TZ-JEIN-8T = 98 T?-uel-LZ Z8€SL008
| as 4so7 BAY TZ-4dy-ZT Ald - Jaq sue] yueg = 9ZIBAJUN TZ-IEW-8T = €G'9Z 02-980-LT €80S2008
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annoy aAIDW TZ-deI-6Z ald - Jay swle|D yueg = @ZBIJUN TZ-JEW-6Z =O TZ-4eEW-Z SS6ZZ008
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ae aAlpy aay 42410 ayeIS = 8ZBIJUN OZ-190-V SLOT 02-390-T 78E6686L
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2 anlpy AAV TZ-JEW-7Z Ald - ayy sue yueg = 9ZBAIJUN TZ-4EW-8T = LL LZ TZ-uef-0Z T8LL686L
a aay any TZ-1dy-T Ald - Jaq suue|D yueg = BZIAJUN' TZ-EWI-6Z = 8Z'Z TZ-JEW-2T LLLL686L
mp 4so7 aay 42410 a}€IS —-8ZBAIJUN OZ-190-17 67°ET 0z-das-gz LLZL686L
= aAlpy annoy TZ-INf-0Z Ald - ayy suulelD yueg = 8ZIBAJUN TZ-EWI-8T =O TZ-uel-6T 8€69686L
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Case 3:21-md-02992-GPC-MSB     Document 379-7     Filed 11/22/24     PageID.14528
Page 24 of 24
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VERIFICATION OF REVISED SECOND SUPPLEMENTAL
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 Revised Second Supplemental
Responses and Objections to Plaintiff's First Set of Interrogatories (Interrogatories
2-6 and 14-15) (“Second Supplemental Responses”), dated December 1, 2023, and
the Revised Supplemental Exhibits 1, 4 and 5, and I am informed and believe,
based on reasonable investigation, that the matters stated in the Revised Second
Supplemental 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 1. day, December 2023, in Los Angeles, California.

C J

\| JENNIFER LENNON

Verification


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