Declaration of Valerie A. Haggans — Bofa Ca Unemployment (Dkt. 541.1)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 541-1 · 2025-08-08 · Docket on CourtListener

Summary

A declaration of Valerie A. Haggans in support of the defendant's reply brief backing its motion to stay pending resolution of its Rule 23(f) petition, in In re: Bank of America California Unemployment Benefits Litigation, Case No. 3:21-MD-02992-GPC-MSB, filed August 8, 2025 as Document 541-1 in the U.S. District Court for the Southern District of California. The declarant states that she is counsel at Goodwin Procter LLP and counsel of record for Bank of America, N.A. She states that on June 26, 2025 class counsel sent a copy of its class notice vendor request for proposal, which provided for use of the National Change of Address database, and that on July 24, 2025 the parties agreed to accept Simpluris's bid as class notice vendor. The declaration describes address verification systems and skip tracing promised in that bid, and attaches as Exhibit 1 a reply brief dated August 6, 2025.

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JAMES W. MCGARRY (pro hac vice) 
JMcGarry@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. 
 
[ADDITIONAL COUNSEL LISTED IN SIGNATURE BLOCK] 
 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA  
SAN DIEGO DIVISION 
IN RE: BANK OF AMERICA  
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 3:21-MD-02992-GPC-MSB 
DECLARATION OF VALERIE A. 
HAGGANS IN SUPPORT OF 
DEFENDANT’S REPLY BRIEF IN 
SUPPORT OF ITS MOTION TO 
STAY PENDING RESOLUTION 
OF ITS RULE 23(f) PETITION  
Date:   
September 16, 2025 
Time:   
1:30 PM 
Ctrm:   
12-A – 12th Floor  
Judge:  
Hon. Gonzalo P. Curiel 
 
 
Case 3:21-md-02992-GPC-MSB     Document 541-1     Filed 08/08/25     PageID.30226 
Page 1 of 3

 
HAGGANS DECL. ISO DEFENDANT’S 
MOT. TO STAY REPLY 
2 
CASE NO. 21-MD-02992-GPC-MSB 
  
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I, 
Valerie A. Haggans, state and declare as follows: 
1. 
I am Counsel at Goodwin Procter LLP, and counsel of record for 
Defendant Bank of America, N.A. (“BANA”) in the above-captioned lawsuit.  
2. 
I have personal knowledge of the facts set forth in this declaration, and 
if called upon to do so, I could and would competently testify thereto. 
3. 
I make this declaration in support of BANA’s Reply Brief in Support of 
its Motion to Stay Pending Resolution of its Rule 23(f) Petition.   
4. 
On June 26, 2025, Class Counsel sent BANA a copy of its class notice 
vendor Request for Proposal (“RFP”). The RFP included a provision for use of the 
National Change of Address (“NCOA”) database to be used to verify addresses in 
the event of undelivered or changed physical addresses.  
5. 
On July 24, 2025, BANA and Plaintiffs agreed to accept Simpluris’s bid 
to serve as the class notice vendor. Simpluris’s bid promised to utilize the NCOA, 
the Coding Accuracy Support System (“CASS”), a USPS system used to standardize 
and verify addresses, and the Locatable Address Conversion System (“LACS”), a 
USPS system used to update and convert addresses, and further promised to conduct 
skip tracing for undeliverable current email addresses. 
6. 
Skip tracing is an analysis undertaken when mail or email is returned as 
non-deliverable in order to locate more recent contact information for a given 
individual.  
Exhibits 
7. 
Attached hereto as Exhibit 1 is a true and correct copy of BANA’s 
Reply Brief in Support of its Petition for Leave to Appeal Under Fed. R. Civ. P. 23(f), 
dated August 6, 2025. 
Case 3:21-md-02992-GPC-MSB     Document 541-1     Filed 08/08/25     PageID.30227 
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HAGGANS DECL. ISO DEFENDANT’S 
MOT. TO STAY REPLY  
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CASE NO. 21-MD-02992-GPC-MSB 
  
  
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I declare under the penalty of perjury that the foregoing is true and correct. 
Executed August 8, 2025, in Mamaroneck, NY. 
By: s/ Valerie A. Haggans 
       VALERIE A. HAGGANS (pro hac vice) 
       VHaggans@goodwinlaw.com 
       GOODWIN PROCTER LLP 
       620 8th Avenue 
       New York, NY 10018 
       Tel.: +1 212 813 8800 
       Fax: +1 212 355 3333 
       Attorneys for Defendant 
       BANK OF AMERICA, N.A. 
Case 3:21-md-02992-GPC-MSB     Document 541-1     Filed 08/08/25     PageID.30228 
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