DECLARATION re 453 MOTION for Protective Order Declaration of Stacey Ruiz by… — Bofa Ca Unemployment (Dkt. 455)

Summary

Declaration of Stacey Ruiz, an Assistant Vice President of Bank of America, N.A., supporting the bank's motion for a protective order against deposing senior executives, in In re Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB, U.S. District Court for the Southern District of California, filed 04/11/25 as Document 455 (3 pages). She states that the parent, Bank of America Corporation, is the holding company for 57 companies with more than 213,000 employees. She says Brian Moynihan has been Chair since October 2014 and CEO since 2010, and that Thomas Montag was Chief Operating Officer until December 2021. She then lists the 2020-2021 positions of other bank employees involved in the case, such as Shane Daniels, Robert Chestnut and Michael Letson.

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JAMES W. MCGARRY (pro hac vice) 
JMcGarry_(a),zoodwinlaw.com 
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GOODWJN1>ROCTER LLP 
100 Northern Avenue 
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Boston, MA 02210 
Tel.:+ 1 617 570 1000 
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Fax:+16175231231 
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SABRINA M. ROSE-SMITH (pro hac vice) 
SRoseSmith(ci),zoodwinlaw.com 
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MATTHEWT. RIFFEE (pro hac vice) 
MRiffee(ci),g_o_odwinlaw. com 
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GOODWIN PROCTER LLP 
1900 N Street NW 
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Washing!on, DC 20036 
Tel.: + 1 202 346 4000 
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Fax:+ 1 202 346 4444 
1 o Attorneys for Defendant 
BANK OF AMERICA, N.A. 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
SAN DIEGO DIVISION 
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IN RE: BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
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BENEFITS LITIGATION 
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RUIZ DECL. ISO MOT. FOR PROTECTIVE ORDER 
Case No. 21-MD-02992-GPC-MSB 
DECLARATION OF STACEY 
RUIZ IN SUPPORT OF 
DEFENDANT'S MOTION FOR A 
PROTECTIVE ORDER 
CASE No. 21-MD-02992-GPC-MSB 
Case 3:21-md-02992-GPC-MSB     Document 455     Filed 04/11/25     PageID.26914     Page
1 of 3

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I, Stacey Ruiz, state and declare as follows: 
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1. 
I am an Assistant Vice President, for Bank of America, N.A. ("BANA") 
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in the above-captioned lawsuit. 
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2. 
In my capacity as Assistant Vice President, I have come to know 
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BANA's internal processes and procedures. I am also familiar with BANA's record 
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keeping processes and I have access to the business records maintained by BANA, 
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including those in connection with its employees (the "BANA Business Records"). 
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My testimony in this declaration is on information and belief based on my review of 
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certain BANA Business Records, my review of transcripts taken in this case, and 
1 O public news articles, which reflect the employment history of the individuals 
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described herein. If called upon to do so, I could and would competently testify 
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thereto. 
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3. 
I make this declaration in support of BANA's Motion for a Protective 
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Order. 
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4. 
Bank of America, N.A. ("BANA") is a wholly owned subsidiary of 
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Bank of America Corporation ("BAC"). BAC is the holding company for 57 
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companies, including operations in all 50 states of the U.S and more than 35 
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countries, with more than 213,000 employees. 
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5. 
Brian Moynihan has been the Chair ofBAC since October 2014 and has 
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been Chief Executive Officer ("CEO") since 2010. 
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6. 
Thomas Montag was BANA's second-in-line executive, with the title of 
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Chief Operating Officer ("COO") and President of Global Banking and Markets, 
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until December 2021, and is now the CEO of Rubicon Carbon. 
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Employment of Certain Individuals at BANA During 2020-2021 
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7. 
Shane Daniels was Head of Small Business Claims and Operations. 
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8. 
Robert Chestnut was a Regional Executive in Relationship 
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Management. 
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9. 
William Matthew Martin was a Senior Vice President in Fraud 
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RUIZ DECL. ISO MOT. FOR PROTECTIVE ORDER 
CASE No. 21-MD-02992-GPC-MSB 
Case 3:21-md-02992-GPC-MSB     Document 455     Filed 04/11/25     PageID.26915     Page
2 of 3

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Management. 
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10. 
Michael Letson was a Managing Director of Global Financial Crimes 
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("GFC"). 
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William Golden was an Operations Managing Director. 
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Jennifer Lennon was a Program Management Senior Vice President. 
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Renee Johnson led the Consumer Claims Resolution and Recovery 
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group. 
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14. 
Ryan Schwartz was a GFC specialist. In that role, Mr. Schwartz was 
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four reporting structures beneath the CEO. 
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Bradley Garfield was Head of Commercial Cards Product Management. 
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Anne Holt was Director of GFC. 
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Faiz Ahmad was 
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Melissa Ramirez was a business banking operations executive m 
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Commercial Card Fulfillment, Service, & Operations. 
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19. 
William Fox was the GFC Global Head. Prior to joining BANA, he 
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served as the former Director of the Financial Crimes Enforcement Network. 
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20. 
Jennifer Ehresman was Head of Consumer Client Protection. 
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Paul Simpson was Managing Director of Business Executive 
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Operations. 
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I declare under penalty of perjury under the laws of the United States that the 
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foregoing 
1s 
true 
and 
correct. 
Executed 
on April 
11, 
2025, 
m 
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K; a /ID 
------t:~A __ _ 
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By: ~?~ -ix r 
. 
s 
BANK OF A 
RICA, N.A. 
Name: Stacey Ruiz 
Title: Assistant Vice President 
Date: April 11, 2025 
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R UIZ D ECL. ISO MOT. FOR PROTECTIVE ORDER 
CASE No. 21-MD-02992-GPC-MSB 
Case 3:21-md-02992-GPC-MSB     Document 455     Filed 04/11/25     PageID.26916     Page
3 of 3

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