STATUS REPORT Joint Status Conference Statement by Consolidated Plaintiffs — Bofa Ca Unemployment (Dkt. 412)

Summary

The parties' joint status conference statement in In re Bank of America California Unemployment Benefits Litigation, Case No.: 3:21-md-02992-GPC-MSB, filed 02/07/25 as Document 412 ahead of the February 14, 2025 status conference via Zoom. It sets out the parties' competing positions on whether the court can decide, on the existing briefing, to certify the breach of fiduciary duty claim for the proposed Customer Service Class. Plaintiffs say they amended the complaint on January 24, 2025 to clarify that claim, that the bank was on notice, and that further briefing would be duplicative. The statement also covers how the parties will proceed with class notice. Advocacy document; claims are each party's.

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JOINT STATUS CONFERENCE STATEMENT 
Case No. 3:21-md-02992-GPC-MSB 
 
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JOSEPH W. COTCHETT (SBN 36324) 
jcotchett@cpmlegal.com 
BRIAN DANITZ (SBN 247403) 
bdanitz@cpmlegal.com 
KARIN B. SWOPE (Pro Hac Vice) 
kswope@cpmlegal.com 
COTCHETT, PITRE & McCARTHY, LLP
840 Malcolm Road, Suite 200 
Burlingame, CA 94010 
Telephone: (650) 697-6000 
Fax: (650) 697-0577 
 
MICHAEL RUBIN (SBN 80618) 
mrubin@altber.com 
STACEY M. LEYTON (SBN 203827) 
sleyton@altber.com 
CONNIE K. CHAN (SBN 284230) 
cchan@altber.com 
ALTSHULER BERZON LLP 
177 Post Street, Suite 300 
San Francisco, CA 94108 
Telephone: (415) 421-7151 
Fax: (415) 362-8064 
 
Co-Lead Counsel for Plaintiffs and the 
Proposed Class 
JAMES W. McGARRY (pro hac vice) 
JMcGarry@goodwinlaw.com 
MICHELLE T. BRIGGS (pro hac vice) 
MBriggs@goodwinlaw.com 
GOODWIN PROCTER LLP 
100 Northern Avenue 
Boston, MA 02210 
Tel.: +1 617 570 1000 
Fax: +1 617 523 1231 
 
 
 
SABRINA M. ROSE-SMITH  
(pro hac vice) 
SRoseSmith@goodwinlaw.com 
MATTHEW L. RIFFEE (pro hac vice) 
MRiffee@goodwinlaw.com 
GOODWIN PROCTER LLP 
1900 N Street NW 
Washington, DC 20036 
Tel.: +1 202 346 4000 
Fax: +1 202 346 4444 
 
 
Attorneys for Defendant 
BANK OF AMERICA, N.A. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
IN RE BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No.: 3:21-md-02992-GPC-MSB 
 
JOINT STATUS CONFERENCE 
STATEMENT 
 
This Document Relates to All Actions 
 Date:  
February 14, 2025 
Time:  
1:30 p.m. 
Location: 
Via Zoom 
Judge: 
Hon. Gonzalo P. Curiel 
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The parties in the above-referenced matter, by and through their respective 
counsel, having met and conferred, submit this Joint Status Conference Statement to 
identify the issues the parties wish to discuss at the February 14, 2025 Status 
Conference (ECF 408, “Order Following Hearing on Class Certification”). 
I. 
Certification of Breach of Fiduciary Duty Claim as to Customer Service 
Class 
Pursuant to the Order Following Hearing on Class Certification, the parties met 
and conferred regarding whether they believe the Court may decide, based on the 
existing briefing, whether to certify the breach of fiduciary duty claim on behalf of the 
proposed Customer Service Class. The parties failed to reach agreement and set forth 
their positions as follows. 
Plaintiffs’ Position: At the hearing, Plaintiffs requested leave to amend their 
complaint to clarify that the breach of fiduciary duty claim is also brought on behalf 
of the Customer Service Class based on the allegation that the Bank “breached its 
fiduciary duty by placing its own desire to achieve greater profits ahead of the 
financial security … interests of Plaintiffs and Class Members,” ECF 304 (SAMCC) 
¶634, including by deliberately understaffing its claims call center in a manner that 
saved the Bank money at the expense of legitimate cardholders seeking to regain 
access to their unemployment insurance (UI) benefits. See 1/17/25 Hr’g Tr. 6:3-13. 
The Bank did not oppose that request, which the Court granted. On January 24, 2025, 
Plaintiffs filed the Third Amended Master Consolidated Complaint (“TAMCC”) with 
that clarification, and on February 7, 2025, Defendant filed a supplemental answer to 
respond to the few additions in the TAMCC.  
Plaintiffs respectfully request that the Court certify the breach of fiduciary duty 
claim as to the Customer Service Class without the need for further motions or briefs 
because (1) the Bank was adequately on notice that Plaintiffs sought certification of 
the breach of fiduciary duty claim for the Customer Service Class, (2) the parties’ 
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arguments in the existing briefing regarding class certification of Plaintiffs’ breach of 
fiduciary duty claim apply equally to all of the proposed Classes, and (3) any further 
briefing on this issue would be unduly duplicative and only cause unnecessary delay.  
Plaintiffs’ Notice of Motion and opening brief in support of class certification 
expressly stated that Plaintiffs were seeking certification as follows: “breach of 
fiduciary duty (all classes),” i.e., including the Customer Service Class. ECF 386-1 at 
3:7; ECF 386-2 at 17:16; see also ECF 386-2 at 28:4-7 (discussing the Breach of 
Fiduciary Duty Claim as to the following classes: “Claim Denial, Credit Rescission, 
Account Freeze, and Customer Service Classes”). As Plaintiffs explained at the class 
certification hearing, their arguments for certifying their breach of fiduciary duty claim 
for the Customer Service Class are the same as their arguments for certifying that same 
claim for the other proposed classes. Just as with respect to the Claim Denial, Credit 
Rescission, and Account Freeze Classes, the predominating common issues for the 
Customer Service Class include “whether the Bank entered into a ‘special relationship’ 
with EDD cardholders and thereby incurred fiduciary obligations,” ECF 386-2 at 26, 
and “whether the Bank breached its fiduciary duties,” including by “(2) ‘failing to take 
all adequate and necessary steps to ensure legitimate benefits recipients are not denied 
access to their Account funds without reasonable basis,’ and (3) placing its own self-
interest in achieving greater profits ahead of the interests of class members,” id. at 27-
28 (citations omitted), for example, by deliberately understaffing its Claims call center 
in a manner that impeded cardholders whose claims were denied based on the Bank’s 
CFF-1 policies from regaining access to their wrongfully withheld funds. See ECF 386-
2 at 26-27; see also id. at 17 (“Common issues include: (1) whether the Bank entered 
into a ‘special relationship’ with EDD cardholders and thereby incurred fiduciary 
obligations; and (2) whether the Bank breached its fiduciary duties by prioritizing its 
own financial self-interest above the interests of EDD cardholders.”). In addition, 
Plaintiffs’ argument for certifying the breach of fiduciary duty claim for the Customer 
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Service Class is essentially identical to the argument that Plaintiffs presented for 
certifying the breach of the implied covenant of good faith and fair dealing claim for 
that same Customer Service Class. See id. at 34 (“The Bank’s own documents and 
testimony establish a lack of good faith, as they show that the Bank’s principal 
motivation in implementing these policies and practices was to protect its own financial 
interests at the expense of class members’ rightful access to their public benefits.”). 
Because the Bank had notice of these arguments and the parties have already 
fully briefed them in nearly identical contexts, Plaintiffs submit that it would be an 
unnecessary waste of time and resources for the parties to re-brief these issues. 
Accordingly, Plaintiffs respectfully request that the Court certify the breach of 
fiduciary duty claim as to the Customer Service Class without requiring further briefing 
on that issue. 
Defendant’s Position: 
BANA agrees with the Court that Plaintiffs have not properly placed their 
request for certification of the customer service class on their breach of fiduciary duty 
claims before the Court because it (1) was not in the Second Amended Master 
Consolidated Complaint (“SAMCC”) and (2) was not briefed in their motion for class 
certification.  ECF No. 408 at 1-2.  Therefore, BANA did not have notice and has not 
had the opportunity to respond to whether this claim, for this class, may be certified.   
To assess whether Plaintiffs may still seek to certify their customer service class 
for this claim given that it was not pleaded in the SAMCC and was not briefed in 
Plaintiffs’ class certification briefs, and to preserve the record and BANA’s right to 
challenge class certification, BANA requests limited briefing on this single issue.  
BANA proposes that Plaintiffs file a 5-page brief within 14 days (February 28, 2025 
based on the upcoming Status Conference), BANA will respond with a 5-page 
opposition brief within 14 days (March 14, 2025), and Plaintiffs may file a 2-page 
reply brief within 7 days (March 21, 2025) if they so choose.  If Plaintiffs wish to 
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forego their opening brief on this issue and rest on the argument raised in this joint 
statement, then BANA would propose that it would file its 5-page opposition brief 
within 14 days (February 28, 2025 based on the upcoming Status Conference), and 
Plaintiffs may file a 2-page reply brief within 7 days (March 7, 2025) if they so choose. 
II. 
Class Notice – Joint Statement 
 
The Parties continue to meet and confer regarding the best form of Class Notice 
should it be required.  Plaintiffs believe Class Notice should be sent by e-mail (when 
available) as well as by U.S. Mail for all class members, and the Bank is considering 
the availability of class members’ email addresses. 
BANA believes that discussions regarding potential Class Notice are premature 
at this time.  However, in accordance with the Court’s Order (ECF 408), the Parties 
have engaged in discussions regarding the solicitation of potential administrators who 
may assist in providing class notice should notice be required. The Parties have an 
agreement as to how to proceed in soliciting bids for a potential class notice, and have 
begun that process.   
III. 
Apex Depositions 
Plaintiffs’ Position: On December 23, 2024, Magistrate Judge Berg held an 
informal discovery conference regarding the Bank’s objections to producing for 
deposition Chief Executive Officer Brian T. Moynihan and former Chief Operating 
Officer Thomas Montag. Judge Berg deferred ruling on the Bank’s request for a 
protective order but tentatively ordered Plaintiffs to take the Zoom depositions of six 
additional mid-level executives, each limited to two hours, and for the parties then to 
return to Judge Berg to discuss the impact of those depositions, if any, on Plaintiffs’ 
request to take the  depositions of Mssrs. Moynihan and Montag. The parties met and 
conferred and agreed to proceed with depositions of four mid-level executives, 
limited to two hours over Zoom, all of which will be completed by February 21, 2025.   
Based on the Bank’s testimony and documents produced thus far, Plaintiffs 
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feel more strongly than ever that the depositions of Messrs. Moynihan and Montag 
will be critically important to Plaintiffs’ case. The Bank maintains its objections to 
producing Moynihan and Montag for deposition. Accordingly, in the interest of 
efficiency, Plaintiffs respectfully request that the Court hear this matter without 
requiring the parties first to participate in another IDC and additional briefing before 
Judge Berg, and that it order the matter presented on the following briefing schedule, 
with a hearing date to be determined: the Bank’s motion for a protective order to be 
filed by February 28; Plaintiffs’ opposition due March 14; the Bank’s reply due 
March 21.1  
Defendant’s Position:  
The Parties have a dispute concerning Plaintiffs’ attempt to take the 
depositions of two of BANA’s most senior executives, its CEO Brian Moynihan and 
its former COO Thomas Montag.  BANA objected to both depositions, and the 
parties met and conferred.  The parties then brought the issue to Magistrate Judge 
Berg, and BANA moved for a protective order via Judge Berg’s Informal Discovery 
Conference process.  After informal letter briefing and argument, Magistrate Judge 
Berg found that Plaintiffs had not sufficiently exhausted efforts to take discovery 
through less burdensome means, and tentatively ordered Plaintiffs to take two-hour 
remote depositions of certain BANA witnesses before Plaintiffs could renew their 
request to seek apex depositions.  The parties accepted Judge Berg’s tentative ruling, 
reached an agreement as to how the remaining depositions ordered by Judge Berg 
would proceed, and have been proceeding in accordance with Judge Berg’s 
instructions.  The remaining depositions are scheduled to occur the weeks of 
February 10 and 17, and will conclude on February 21, 2025.  Thus, this issue is not 
 
1 At the February 6, 2025 Zoom discovery conference, Plaintiffs notified Judge Berg 
that, given the inevitable appeal of this Apex discovery issue to this Court, regardless 
of which side prevailed before Judge Berg, it would be most efficient for the briefing 
to proceed directly in this Court.  
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yet ripe for further consideration by Magistrate Judge Berg or this Court.   
Given Magistrate Judge Berg’s knowledge of the issue and the parties’ 
agreement to abide by his tentative ruling, BANA’s position is that it is appropriate 
for this issue to remain before and be re-raised to Magistrate Judge Berg after the 
conclusion of the remaining ordered and agreed depositions if Plaintiffs still seek 
these depositions at that time.  However, if the Court would prefer for the parties to 
bring this issue directly to the Court after the remaining depositions conclude, there 
should be a formal briefing schedule that allows for at least the minimum amount of 
time and pages permitted by the Local Rules.  Moreover, if the Court wishes to hear 
this issue, the parties have agreed that it would be raised by BANA in the form of a 
motion for a protective order.  
If this issue is to be brought directly before the Court on BANA’s motion, 
BANA proposes that it would file its motion within twenty-eight (28) days after the 
depositions conclude (on or before March 21, 2025).  Twenty-eight (28) days is 
necessary to afford BANA sufficient time to receive and review all necessary 
transcripts from the depositions that Judge Berg ordered and determined are relevant 
to this dispute, and to allow the parties the time allotted under the Stipulated 
Protective Order to make any necessary confidentiality designations that will be 
relevant to subsequent filings and motions to seal.2  BANA further proposes that 
Plaintiffs would have 14 days to respond (or 21 days if Plaintiffs prefer), and BANA 
would have 7 days for a reply (or 14 days if Plaintiffs seek 21 days for their 
opposition).  BANA would notice its motion for the Court’s next available hearing 
date at the time the motion for a protective order is filed. 
 
2 The Stipulated Protective Order provides that the parties will have twenty-one (21) 
days to designate confidentiality to transcripts.  ECF No. 82.  BANA is willing to 
request, review, and designate confidentiality of the transcripts on an expedited basis 
so that formal briefing could begin within 28 days of the conclusion of depositions 
(with BANA’s opening brief filed on or after March 21, 2025). 
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IV. 
Plaintiffs’ Supplemental Expert Designation and Expert Discovery 
Deadlines– Joint Statement 
Pursuant to the December 24, 2024 Order Modifying Case Schedule (ECF 401), 
the parties on January 27, 2025 exchanged summary expert designations that largely 
mirrored the expert reports submitted in support of and in opposition to the motion for 
class certification, with both parties designating one additional expert. Plaintiffs 
subsequently learned of the availability of a new expert, Prof. Chloe East of the 
University of Colorado, a labor economist with specialized expertise in unemployment 
insurance matters, whom Plaintiffs would also like to designate as an expert for their 
case in chief. On February 3, 2025, the parties met and conferred and Plaintiffs 
informed Defendant that they wished to disclose Prof. East. That same day, Plaintiff 
served the Bank with a Supplemental Expert Designation for Prof. East. 
The Parties further met and conferred on February 5, 2025, and the Bank 
subsequently agreed not to contest Plaintiffs’ designation of Prof. East on timeliness 
grounds provided Plaintiffs agreed to request a 14-day extension of existing expert and 
pretrial motion deadlines to allow sufficient time to locate or identify additional experts 
and prepare reports. Plaintiffs did agree. Accordingly, the parties respectfully submit 
the accompanying Joint Motion to Extend Time Re: Expert Disclosures and Pretrial 
Motions and request that the Court extend the expert and pretrial motion deadlines as 
follows: 
Event
Current Date
Proposed Date
Expert Designation 
January 27, 2025
February 10, 2025
Rebuttal Expert Designation  
February 3, 2025 
February 17, 2025 
Expert Disclosures 
February 18, 2025
March 4, 2025
Rebuttal Expert Disclosures  
March 14, 2025 
March 28, 2025 
Expert Discovery Cutoff 
April 11, 2025
April 25, 2025
Pretrial Motions Cutoff 
May 14, 2025
May 28, 2025
 
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V. 
Defendants’ Motion to Stay 
Plaintiffs’ Position: On January 28, 2025, the Bank filed a Notice of 
Supplemental Authority and stated its intent to file a motion to stay proceedings—
including issuance of the Court’s order on Plaintiffs’ motion for class certification—
based on the United States Supreme Court’s grant of certiorari in Laboratory Corp. 24-
0304 (LabCorp) (see ECF 409). Plaintiffs strongly oppose any stay of proceedings and 
will file an opposition to any formal motion the Bank files. 
 The Supreme Court’s grant of review in LabCorp does not alter controlling 
Ninth Circuit law and does not provide a basis for staying proceedings or delaying 
issuance of the Court’s order on Plaintiffs’ motion for class certification, which has 
already been fully briefed and argued and thoroughly considered by the Court. Cases 
such as Olean Wholesale Grocery Cooperative, Inc. v. Bumble Bee Foods LLC, 31 
F.4th 651 (9th Cir. 2022) (en banc) and Ruiz Torres v. Mercer Canyons Inc., 835 F.3d 
1125 (9th Cir. 2016) are the law of this Circuit, and “once a federal circuit court issues 
a decision, the district courts within that circuit are bound to follow it and have no 
authority to await a ruling by the Supreme Court before applying the circuit court’s 
decision as binding authority.” Yong v. INS, 208 F.3d 1116, 1119 n.2 (9th Cir. 2000). 
Further, there is no reason to stay proceedings because the resolution of 
LabCorp, whatever it may be, is unlikely to have any bearing on the appropriateness 
of class certification in this case. In LabCorp, the plaintiffs sought to certify a class of 
“[a]ll legally blind individuals who visited a LabCorp patient service center with a 
LabCorp Express Self-Service kiosk in California during the applicable limitations 
period and who, due to their disability, were unable to use the LabCorp Express Self-
Service kiosk.” Pet. for Cert. at 8 (quoting Pet.App.63a). As defined, the class included 
individuals who did not want to use a kiosk and preferred to use alternative check-in 
methods accessible to legally blind individuals, whom defendant argued did not suffer 
a concrete injury. Id.; see Reply to BIO at 8. Moreover, defendant presented 
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“[u]nrebutted record evidence show[ing] that nearly one-fourth of all LabCorp PSC 
visitors prefer to check in at the front desk; and another tenth preferred to do so online.” 
Pet. Cert. at 9.  
The facts of this case and the evidence in this class certification record are 
materially distinguishable at every turn. First, each proposed Class here is narrowly 
defined expressly to exclude anyone who “(i) has been disqualified by the [S]tate [of 
California] from Program eligibility” or whom the Bank has determined “(ii) has 
previously engaged in fraudulent Program conduct, such as submission of fraudulent 
claims or other abuses of the claims process.” ECF 386-1 at 2; see 1/17/25 Hr’g Tr. 
21:18-22. Second, as the Court noted at the class certification hearing, the Bank has 
not presented any evidence that there are likely to be many, if any, uninjured class 
members who are subsequently discovered. See, e.g., 1/17/25 Hr’g Tr. 21:8-18 (“[A]t 
this point, years after this fraud occurred and well into this litigation, we don’t have 
Bank of America offering something more than what is in the record. … [W]e don’t 
have any indication of … how many there are and how likely it is for … continued 
efforts to identify many more.”). Third, there is no dispute that, as defined, every class 
member was subject to the same challenged Bank policies and practices at issue, and 
thus every class member suffered a concrete injury (independent of whether they 
suffered damages) as a result of the Bank’s alleged violations of their EFTA rights to 
a reasonable and timely investigation and written findings and their due process rights 
to adequate notice and opportunity to be heard. See ECF 386-2 at 20-25; ECF 378 at 
3-9; 1/17/25 Hr’g Tr. at 43:23-44:9.  
Plaintiffs will respond fully to any arguments the Bank makes in its forthcoming 
motion to stay and as a general matter does not object to the Bank’s proposal to the 
standard briefing schedule for that motion (14 days for Plaintiffs’ opposition and 7 
days for the Bank’s reply). However, if the Court is inclined to hold issuance of the 
Court’s order on Plaintiffs’ motion for class certification pending resolution of the 
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Bank’s motion to stay, Plaintiffs respectfully request that the Court set an expedited 
briefing and (if necessary) hearing schedule in order to minimize any further delay in 
bringing resolution to the claims of Plaintiffs and the more than 109,000 UI 
beneficiaries they seek to represent, which have now already been pending for more 
than four years.  
Defendant’s Position: 
As stated in BANA’s January 28, 2025 notice to the Court (ECF No. 409), 
BANA respectfully submits that the proceedings in this action, including the issuance 
of the Court’s order on Plaintiffs’ Motion for Class Certification, should be stayed 
pending the issuance of the United State Supreme Court’s opinion in Laboratory 
Corp. of America Holdings v. Davis, No. 24-0304.  The parties have met and 
conferred, and Plaintiffs informed BANA that they oppose a stay.   
BANA will, therefore, be filing its motion to stay concurrently with this filing, 
and intends to notice the motion for the Court’s next available hearing date.  
Notwithstanding the Local Rules, BANA proposes that Plaintiffs would have 
fourteen (14) days from the date the motion is filed (not based on the hearing date) 
to file their opposition brief, and that BANA will have until seven (7) days thereafter 
to file its reply brief.   
Presently, the governing Amended Scheduling Order (ECF No. 401) sets 
expert disclosures to commence on February 18, 2025, and for dispositive motions 
be filed on May 14, 2025.  Given the proposed briefing schedule, even with the 
parties’ agreed 14-day continuance (discussed above in Section IV), the deadlines in 
the Amended Scheduling Order will begin to run while the Court is considering the 
motion to stay.  Accordingly, and for the reasons stated in BANA’s forthcoming 
motion to stay, BANA respectfully requests a brief continuance of expert and other 
pretrial deadlines while the Court is considering the motion to stay. 
 
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Dated:  February 7, 2025  
 
COTCHETT, PITRE & McCARTHY, LLP 
 
By:  /s/ Brian Danitz 
 
 
 
JOSEPH W. COTCHETT  
BRIAN DANITZ  
KARIN B. SWOPE  
BLAIR V. KITTLE 
VASTI S. MONTIEL 
 
Dated:  February 7, 2025 
ALTSHULER BERZON LLP 
 
By:  /s/ Michael Rubin  
 
 
MICHAEL RUBIN  
STACEY M. LEYTON  
CONNIE K. CHAN 
KATHERINE G. BASS 
COLIN C. JONES 
 
Co-Lead Counsel for Plaintiffs and the 
Proposed Class 
 
Dated:  February 7, 2025 
 
By:   /s/ Matthew L. Riffee 
 
 
MATTHEW L. RIFFEE (pro hac vice) 
MRiffee@goodwinlaw.com 
SABRINA M. ROSE-SMITH  
(pro hac vice) 
SRoseSmith@goodwinlaw.com 
GOODWIN PROCTER LLP 
1900 N Street NW 
Washington, DC 20036 
Tel.: +1 202 346 4000 
Fax: +1 202 346 4444 
 
JAMES McGARRY (pro hac vice) 
JMcGarry@goodwinlaw.com 
MICHELLE T. BRIGGS (pro hac vice) 
MBriggs@goodwinlaw.com 
GOODWIN PROCTER LLP 
Case 3:21-md-02992-GPC-MSB     Document 412     Filed 02/07/25     PageID.25266     Page
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JOINT STATUS CONFERENCE STATEMENT  
Case No. 3:21-md-02992-GPC-MSB 
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100 Northern Avenue 
Boston, MA 02210 
Tel.: +1 617 570 1000 
Fax: +1 617 523 1231 
 
YVONNE W. CHAN (pro hac vice) 
YChan@jonesday.com 
JONES DAY 
100 High Street 
Boston, MA 02210 
Tel.: +1 617 960 3939 
Fax: +1 617 449 6999 
 
Counsel for Defendant  
Bank of America, N.A. 
 
 
Case 3:21-md-02992-GPC-MSB     Document 412     Filed 02/07/25     PageID.25267     Page
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JOINT STATUS CONFERENCE STATEMENT  
Case No. 3:21-md-02992-GPC-MSB 
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SIGNATURE CERTIFICATION 
Pursuant to Section 2(f)(4) of this Court’s Electronic Case Filing 
Administrative Policies and Procedures Manual, I, Brian Danitz, hereby certify 
that the content of this document is acceptable to all the signatories herein and that 
I have obtained counsel’s authorization to affix their electronic signatures to this 
document. 
 
 
 
 
 
 
 
 
/s/ Brian Danitz 
 
 
 
 
 
 
 
 
         
BRIAN DANITZ 
Case 3:21-md-02992-GPC-MSB     Document 412     Filed 02/07/25     PageID.25268     Page
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