REQUEST FOR JUDICIAL NOTICE by Bank of America, N.A.… — Bofa Ca Unemployment (Dkt. 590)

Record facts

U.S. District Court, Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 590 · 2025-10-17 · Docket on CourtListener

Summary

Defendant Bank of America, N.A.'s request for judicial notice in support of its motion for partial summary judgment, filed October 17, 2025 as Document 590 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB, in the U.S. District Court for the Southern District of California, San Diego Division. Made under Federal Rule of Evidence 201, it asks the court to take notice of the documents in Exhibits 1-22 attached to a concurrently filed declaration of counsel. The first group is materials published by government entities, including California State Auditor Report 2020-502 dated November 19, 2020, Report 2020-628.2 dated January 2021, FinCEN press releases and advisories dated from March 16, 2020 through February 24, 2021, and a Department of Justice task force consumer guide dated September 21, 2020. The filing runs 13 pages.

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BANA’S RJN ISO MOT. FOR PARTIAL SJ 
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW 
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 
FOR THE SOUTHERN DISTRICT OF CALIFORNIA 
SAN DIEGO DIVISION 
IN RE: BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 21-MD-02992-GPC-MSB 
DEFENDANT BANK OF AMERICA, 
N.A.’S REQUEST FOR JUDICIAL 
NOTICE IN SUPPORT OF MOTION 
FOR PARTIAL SUMMARY 
JUDGMENT 
 
Date: 
April 17, 2026 
Time: 
1:30 p.m. 
Ctrm: 
12A – 12th Floor 
Judge: 
Hon. Gonzalo P. Curiel 
 
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PLEASE TAKE NOTICE that pursuant to FEDERAL RULE OF EVIDENCE 201, 
Defendant Bank of America, N.A. (BANA) hereby requests the Court take judicial 
notice of the following documents and their contents in Exhibits 1-22, true and correct 
copies of which are attached to the concurrently filed Declaration of Laura G. Brys in 
support of this Request for Judicial Notice (RJN). 
REQUEST FOR JUDICIAL NOTICE 
I. 
Materials Published by Government Entities 
RJN 
Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
1. 
 California State Auditor Report 2020-502, dated November 19, 2020: 
 California’s State Auditor discovered and reported that EDD had 
mailed at least 51 million documents to benefits claimants between 
2017 and 2020 that included their full Social Security numbers. RJN 1 
at 1-2; see SUF ¶ 52.1  
2. 
 California State Auditor Report 2020-628.2 titled Significant Weaknesses 
in EDD’s Approach to Fraud Prevention Have Led to Billions of Dollars 
in Improper Benefit Payments, dated January 2021: 
 California’s State Auditor concluded that the PUA and failings by 
agencies charged with UI benefits administration (including EDD) 
resulted in hundreds of billions of fraud losses. RJN 2 at 1-3; see SUF 
¶ 46.  
 California’s State Auditor reported that EDD failed to implement fraud 
detection or identity verification technology until October 2020, 
ignored repeated warnings from the U.S. Department of Labor’s (DOL) 
Office of Inspector General, and approved approximately $10.4 billion 
in benefits with no identity verifications. RJN 2 at 1, 8-9, 14-17, 20, 
29; see SUF ¶ 51. 
3. 
 Financial Crimes Enforcement Network (FinCEN) press releases and 
advisory notices from March 16, 2020 through February 24, 2021: 
 The Financial Crimes Enforcement Network (FinCEN) Encourages 
Financial Institutions to Communicate Concerns Related to the 
Coronavirus Disease 2019 (COVID-19) and to Remain Alert to Related 
Illicit Financial Activity, dated March 16, 2020; 
 
1 SUF refers to BANA’s Statement of Undisputed Material Facts, filed herewith. 
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RJN 
Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
 The Financial Crimes Enforcement Network Provides Further 
Information to Financial Institutions in Response to the Coronavirus 
Disease 2019 (COVID-19) Pandemic, dated April 3, 2020; 
 Advisory FIN-2020-A002 titled Advisory on Medical Scams Related to 
the Coronavirus Disease 2019 (COVID-19), dated May 18, 2020; 
 Notice Related to the Coronavirus Disease 2019 (COVID-19), dated 
May 18, 2020; 
 Advisory FIN-2020-A003 titled Advisory on Imposter Scams and 
Money Mule Schemes Related to Coronavirus Disease 2019 (COVID-
19), dated July 7, 2020; 
 Advisory FIN-2020-A005 titled Advisory on Cybercrime and Cyber-
Enabled Crime Exploiting the Coronavirus Disease 2019 (COVID-19) 
Pandemic, dated July 30, 2020; 
 Advisory FIN-2020-007 titled Advisory on Unemployment Insurance 
Fraud During the Coronavirus Disease 2019 (COVID-19) Pandemic, 
dated October 13, 2020; 
 Advisory FIN-2021-A002 titled Advisory on Financial Crimes 
Targeting COVID-19 Economic Impact Payments, dated February 24, 
2021; and 
 Notice FIN-2021-NTC1 titled Consolidated COVID-19 Suspicious 
Activity Report Key Terms and Filing Instructions, dated February 24, 
2021. 
 Throughout the pandemic, FinCEN issued alerts to BANA and others 
about rising benefits fraud, encouraging financial institutions to 
perform additional inquiries and investigations to identify red flags 
indicating fraud, including suspicious, rapid disbursements from 
benefits accounts. RJN 3; see SUF ¶ 69.  
4. 
 U.S. Department of Justice (DOJ) National Unemployment Insurance 
Fraud Task Force guide titled Unemployment Insurance Fraud Consumer 
Protection Guide, dated September 21, 2020: 
 In September 2020, the DOJ National Unemployment Insurance Fraud 
Task Force issued a warning that personal information stolen during 
past data breaches at other companies and sold on the dark web was 
being used by fraudsters to apply for PUA and other UI benefits. RJN 
4 at 1; see SUF ¶ 54.   
5. 
 U.S. Secret Service alert titled Massive Fraud Against State 
Unemployment Insurance Programs, dated May 14, 2020: 
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Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
 In May 2020, the Secret Service issued an alert stating that a Nigerian 
fraud ring was exploiting the pandemic to commit “large-scale fraud 
against state unemployment insurance programs.” RJN 5; see SUF ¶¶ 
53, 69. 
6. 
 Consumer Financial Protection Bureau (CFPB) report titled The 
Consumer Credit Card Market, dated December 2015: 
 In December 2015, the CFPB advised that EMV chips were not 
required in any type of card, and noted the “cost” and slow “merchant 
adoption” as factors that may be considered by financial institutions in 
deciding whether to include chips. RJN 6 at 270-73; SUF ¶ 232A. 
7. 
 Congress.gov report titled Unemployment Rates During the COVID-19 
Pandemic, dated August 20, 2021: 
 The U.S. unemployment rate rose from 4.4% in March 2020 to 14.8% 
in April 2020. RJN 7 at 7, SUF ¶ 34.   
8. 
 EDD news release No. 20-49 titled EDD Announces Reset in Response to 
Strike Team Recommendations to Process Claims Faster, Reduce Fraud 
and Tackle Backlog Issues, dated September 19, 2020: 
 In mid-September 2020, California’s governor shut down EDD for two 
weeks, so that EDD could implement new strategies, including identity 
verification processes (ID.me), to attempt to counter fraudulent 
applications. RJN 8; see SUF ¶ 68.  
9. 
 EDD news release No. 24-06 titled EDD benefit payments now issued on 
new Money Network prepaid debit cards, dated February 15, 2024: 
 EDD and BANA agreed that BANA would cease providing prepaid 
cards for EDD. RJN 9; see SUF ¶ 23. 
 EDD stopped funding benefits through BANA-issued cards on 
February 15, 2024. RJN 9; see SUF ¶ 24. 
 EDD reported that “April 15, 2024 is the last day individuals will be 
able to use their” BANA-issued EDD prepaid cards and accounts. RJN 
9; see SUF ¶ 25.  
10. 
 Federal Reserve 2022 Payments Study: 
 Between 2019 and 2020, approximately 65%-74% of in-person prepaid 
card transactions were completed without an EMV chip. RJN 10 at 5; 
see SUF ¶ 233.  
11. 
 Legislative Analyst’s Office report titled Legislative Oversight of Ongoing 
Challenges at EDD, dated January 26, 2021: 
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Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
 The CA Legislative Analyst’s Office attributed the “[o]verwhelming 
majority” of fraud to PUA’s “lower standard of identity and wage 
information” “due to federal policymakers’ decision to prioritize 
immediate assistance.” RJN 11 at 5; see SUF ¶ 47.  
12. 
 U.S. House Committee on Oversight and Accountability Report titled 
Examining Widespread Fraud in Pandemic Unemployment Relief 
Programs, dated September 10, 2024:  
 In March 2020, Congress passed the Coronavirus Aid, Relief, and 
Economic Security Act (CARES Act), which created the Pandemic 
Unemployment Assistance program (PUA). RJN 12 at 14-15; see SUF 
¶ 35. 
 PUA extended unemployment benefits to those not previously eligible 
under traditional unemployment systems, including self-employed 
individuals, contract workers, and gig workers. RJN 12 at 15; see SUF 
¶ 36.  
 PUA allowed claimants to file for benefits without former employer 
verification of wage or salary history. RJN 12 at 25; see SUF ¶ 37.  
 The U.S. House Committee on Oversight and Accountability reported 
that “EDD staff . . . adopted a ‘pay and chase’ model and processed 
incoming claims quickly.” RJN 12 at 28; see SUF ¶ 50, see also id. ¶ 
38.  
 The U.S. House Committee on Oversight and Accountability reported 
that “EDD staff understood that less time should be spent on checking 
eligibility of claimants as this would slow down paying out benefits. 
This led to many bad actors like international organized crime and 
individual criminals cashing in while eligible claimants were unable to 
obtain their benefits.” RJN 12 at 28; see SUF ¶ 50; see also id. ¶ 38.   
 The U.S. House Committee on Oversight and Accountability 
concluded that the PUA and failings by UI benefits administration 
agencies (including EDD) resulted in fraud losses that other agencies 
estimated reached at least nearly $200 billion. RJN 12 at 27; see SUF 
¶ 46. 
 The U.S. House Committee on Oversight and Accountability reported 
that the DOL reported that PUA had an improper payment rate of 
35.9%. RJN 12 at 6, 22, 27; see SUF ¶ 48. 
 The U.S. House Committee on Oversight and Accountability reported 
that “EDD was such a well-known target of fraud that it reached 
mainstream media and music.” RJN 12 at 45; see SUF ¶¶ 59-60.  
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RJN 
Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
 The U.S. House Committee on Oversight and Accountability reported 
that an individual from Tennessee “rapped about successfully getting 
rich from filing fraudulent UI claims in California in the music video 
‘EDD’ posted on YouTube and Instagram” featuring him waiving EDD 
envelopes “that had contained debit cards loaded with UI benefits” and 
boasting “about how he was doing ‘my swagger for EDD’ by 
exploiting the vulnerabilities in the PUA program.” RJN 12 at 45-46; 
see SUF ¶ 60.  
13. 
 EDD brochure titled Unemployment Insurance Benefits: What You Need 
to Know:  
 EDD made benefits available in two ways: via paper check or via a 
prepaid debit card. RJN 13 at 6; see SUF ¶ 2.  
 EDD benefits recipients had the ability to choose whether they wanted 
to receive their benefits via check or via a prepaid card when they 
submitted their benefits applications to EDD. RJN 13 at 6; see SUF ¶ 
3.  
14. 
 U.S. House Committee on Ways and Means article titled Ways and Means 
Votes to Claw Back Billions in Stolen Pandemic-Era Unemployment 
Benefits, Protect Taxpayer Rights, dated February 12, 2025: 
 The U.S. House Committee on Ways & Means reported in February 
2025 that improper PUA payments were estimated to be upwards of 
$400 billion nationwide. RJN 14 at 1; see SUF ¶ 49. 
15. 
 California State Auditor Report 2020-128/628.1 titled EDD’s Poor 
Planning and Ineffective Management Left It Unprepared to Assist 
Californians Unemployed by COVID-19 Shutdowns, dated January 2021: 
 The California unemployment rate rose to over 16% in April 2020. RJN 
15 at 6-7; see SUF ¶ 34. 
 PUA extended unemployment benefits to those not previously eligible 
under traditional unemployment systems, including self-employed 
individuals, and business owners. RJN 15 at 5; see SUF ¶ 36. 
 California’s State Auditor reported that “EDD responded to the claim 
surge by suspending its determinations of eligibility for most claimants, 
thereby compromising the integrity of the UI program.” RJN 15 at 1; 
see SUF ¶ 64.  
 California’s State Auditor reported that “[i]n spring of 2020, the 
secretary of the Labor and Workforce Development Agency directed 
EDD to pay certain claimants UI benefits without making key 
eligibility determinations and to temporarily stop collecting biweekly 
eligibility certifications” – “directives [which] were designed to 
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Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
provide Californians with benefit payments as quickly as possible.” 
RJN 15 at 1; see SUF ¶ 64.   
II. 
Other Publications 
RJN 
Ex. # 
Item and Fact(s) for Which Judicial Notice Is Requested 
16. 
  KCRA 3 article titled Analysis shows California EDD fraud at $32.6 
Billion and Counting, dated October 6, 2022: 
 Lexis Nexis data analysis estimated that EDD incurred approximately 
$32.6 billion in fraud losses during the pandemic. RJN 16 at 4; see SUF 
¶ 47.   
17. 
  Decipher article titled Criminals Find a Way to Clone EMV Cards, dated 
July 31, 2020, and relied upon by BANA’s expert witness Pamela Joseph: 
 “Shimming” machines allow criminals to read identifying data, 
including card numbers, from EMV chips and produce counterfeit 
cards. RJN 17; see SUF ¶ 244, DX 12.A ¶¶ 56, 83, 85, 89-90, 104, 117.  
18. 
 WQOW.com article titled Shimmers: the new credit card skimmers, dated 
June 29, 2018, and relied upon by BANA’s expert witness Pamela Joseph: 
 “Shimming” machines allow criminals to read identifying data, 
including card numbers, from EMV chips and produce counterfeit 
cards. RJN 18 at 2-3; see SUF ¶ 244, DX 12.A ¶¶ 56, 83, 85, 89-90, 
104, 117. 
19. 
 ID.me article titled Calculating the Road to Losing $400 Billion Dollars, 
dated January 20, 2022: 
 ID.me estimated $400 billion in fraudulent claims for unemployment 
insurance during the pandemic, approximately a 40% loss rate. RJN 19 
at 1, 4; see SUF ¶ 49.   
20. 
 Nilson Report, Issue 1187, dated December 2020, and relied upon by 
BANA’s expert witness Pamela Joseph: 
 EMV chip technology does not prevent account compromise through 
phishing or merchant breaches. RJN 20 at 5; see SUF ¶ 243, DX 12.A 
¶¶ 56, 83, 85, 89-90, 104, 117. 
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III. 
YouTube Videos 
RJN 
Ex. # 
Item for Which Judicial Notice Is Requested 
21. 
 YouTube video titled “EDD” by ShotOff & Nuke Bizzle: 
 Individuals posted music videos on YouTube bragging about having 
defrauded EDD and BANA. RJN 21; see SUF ¶¶ 59-60.   
22. 
 YouTube video titled “Bandemic (E.D.D.)” by Shoreline Mafia: 
 Individuals posted music videos on YouTube bragging about having 
defrauded EDD and BANA. RJN 22; see SUF ¶¶ 59-60.   
LEGAL ARGUMENT 
The court may take judicial notice of a fact “not subject to reasonable dispute 
because it: (1) is generally known within the trial court’s territorial jurisdiction; or (2) 
can be accurately and readily determined from sources whose accuracy cannot 
reasonably be questioned.” FED. R. EVID. 201(b). “[C]ourts often take judicial notice 
of the existence of documents.” Coastkeeper v. United States Int'l Boundary & Water 
Comm'n, 2025 WL 509303, *3 (S.D. Cal. Feb. 14, 2025). Beyond that, a court may 
“take notice of the factual truth of the contents, if those are [not] subject to reasonable 
dispute.” See id.  
As set forth below, BANA respectfully requests judicial notice of RJNs 1-22 
and the facts in these documents detailed above for the reasons discussed herein.  
I. 
Materials Published by Government Entities 
 The Court may take judicial notice of public records and publicly available 
government website pages. See, e.g., Jones v. Pollard, 2023 WL 4728802, *2 n.7 
(S.D. Cal. July 24, 2023) (“all five exhibits are proper for judicial notice as they are 
publicly available government website pages”); Metroflex Oceanside LLC v. Newsom, 
532 F. Supp. 3d 976, 980 (S.D. Cal. 2021) (documents “in the public record” are 
“subject to judicial notice”). Specifically, the “contents” of government records “are 
proper subjects for judicial notice.” Rowland v. Paris Las Vegas, 2014 WL 769393, 
*2 (S.D. Cal. Feb. 25, 2014); see Lopez v. Bank of America, N.A., 505 F. Supp. 3d 
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961, 969 (N.D. Cal. 2020) (“the content of records and reports of administrative 
bodies are proper subjects for judicial notice”) (quotation omitted). The deference 
given to government materials extends to materials available on “[g]overnment 
websites,” which are considered “reliable sources.” Day v. GEICO Cas. Co., 2024 
WL 251408, *2 (N.D. Cal. Jan. 23, 2024). The “information obtained” from 
government websites is also judicially noticeable. ImprimisRx, LLC v. OSRX, Inc., 
2022 WL 3371343, *6 (S.D. Cal. Aug. 15, 2022) (quotation omitted); No Cost Conf., 
Inc. v. Windstream Commc'ns, Inc., 940 F. Supp. 2d 1285, 1296 (S.D. Cal. 2013) 
(information, or facts, within a government website are judicially noticeable if they 
“cannot reasonably be disputed”).   
RJNs 1-15 consist of  government reports, press releases, and other publications 
by federal and state government agencies and officials that are “proper subjects of 
judicial notice” and cannot reasonably be disputed. See Rowland, 2014 WL 769393,  
*2. These sources convey facts relating to the COVID-19 pandemic, including such 
non-controversial facts as the adoption of federal assistance programs, unemployment 
trends during the pandemic, warnings from government agencies about increases in 
pandemic-related fraud, the findings of government agencies that a significant portion 
of assistance payments made under the PUA program were improper, and government 
findings concerning EDD’s administrative failings, as well as facts relating to EMV 
chips and EDD’s payment options for unemployment insurance (UI) beneficiaries. 
These are all facts “generally known within [this Court’s] territorial jurisdiction.” FED. 
R. EVID. 201(b). Accordingly, judicial notice of the documents and facts listed in 
RJNs 1-15 is proper. See, e.g., Jones, 2023 WL 4728802, *2 n.7 (granting request for 
judicial notice of publicly available government website pages relating to pandemic); 
see also United States v. Lopez-Valdez, 2021 WL 2453278, *1 n.2 (S.D. Cal. June 16, 
2021) (taking judicial notice of government “statistics and reports” regarding 
pandemic).   
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II. 
Other Publications 
RJNs 16-20 are publications accessible through the Internet and/or Internet 
archives. Not only is the existence of webpages judicially noticeable, but “[f]acts that 
become widely known through news or other announcements, including on websites, 
are subject to judicial notice.” Parent v. Millercoors LLC, 2016 WL 3348818, *4 (S.D. 
Cal. June 16, 2016) (finding judicial notice of fact in news article appropriate because 
fact in article was “generally known in San Diego and capable of sufficiently accurate 
and ready determination”); see D'Angelo v. FCA US, LLC, 726 F. Supp. 3d 1179, 
1191-92 (S.D. Cal. 2024) (“existence of . . . webpages [is] judicially noticeable.”). In 
addition, courts also have taken judicial notice of archived Internet content. See 
Kinnee v. TEI Biosciences Inc., 2023 WL 8191097, *3 (S.D. Cal. Nov. 27, 2023) 
(“courts have taken judicial notice of internet archives in the past”) (quotation 
omitted).  
 The facts set forth in RJNs 16-20 for which judicial notice is sought relate to 
EMV chip technology and the estimated impact of pandemic-related UI fraud. Judicial 
notice of such facts is proper for the following reasons:  (i) the limitations of EMV 
chip technology is a fact that has become “widely known” through public 
dissemination and therefore subject to judicial notice, see Parent, 2016 WL 3348818, 
*4; and (ii) the extent of UI fraud is at the heart of Plaintiffs’ claims in this action and 
“generally known within the trial court's territorial jurisdiction.” FED. R. EVID. 201(b).  
III. 
YouTube Videos 
RJNs 21 and 22 are YouTube videos. BANA requests that the Court take 
judicial notice of RJNs 21 and 22 for the limited and proper purpose of establishing 
the existence of RJNs 21 and 22 in the public domain. See Witt v. Bristol Farms, 2022 
WL 6258296, *5 (S.D. Cal. Oct. 7, 2022) (Courts may take judicial notice of 
“YouTube . . . to establish ‘the existence of the website in the public realm.’”) (quoting 
Farrell v. Boeing Emps. Credit Union, 761 F. App’x 682, 682 n.1 (9th Cir. 2019)).  
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CONCLUSION 
For the foregoing reasons, the Court should take judicial notice of the 
aforementioned documents and their contents in support of BANA’s Motion for 
Partial Summary Judgment. 
 
 
 
 
 
 
Dated: October 17, 2025 
Respectfully submitted, 
 
 
 
By:  s/ Laura G. Brys  
 
 
 
  
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 
KEITH LEVENBERG (pro hac vice) 
KLevenberg@goodwinlaw.com 
GOODWIN PROCTER LLP 
1900 N St. NW  
Washington, DC 20036  
Tel: +1 202 346 4000  
Fax: +1 202 346 4444 
 
LAURA G. BRYS (SBN 242100) 
LBrys@goodwinlaw.com 
GOODWIN PROCTER LLP 
601 S Figueroa St., Suite 4100 
Los Angeles, CA 90017 
Tel.: +1 213 426 2500 
Fax: +1 617 346 4444 
 
VALERIE A. HAGGANS (pro hac vice) 
VHaggans@goodwinlaw.com 
LINDSAY E. HOYLE (pro hac vice) 
LHoyle@goodwinlaw.com 
GOODWIN PROCTER LLP 
620 Eighth Avenue 
New York, NY 10118 
Tel.: +1 212 813-8800 
Fax: +1 212 355-3333 
 
YVONNE W. CHAN (pro hac vice) 
Case 3:21-md-02992-GPC-MSB     Document 590     Filed 10/17/25     PageID.39862     Page
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BANA’S RJN ISO MOT. FOR PARTIAL SJ 
CASE NO. 21-MD-02992-GPC-MSB 
 
 
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW 
YChan@jonesday.com 
JONES DAY 
100 High Street 
Boston, MA 02110 
Tel.: +1 617 960 3939 
Fax: +1 617 449 6999 
 
JANICE P. BROWN (SBN 114433) 
jbrown@myersnave.com 
MATTHEW B. NAZARETH (SBN 278405) 
mnazareth@myersnave.com 
MEYERS NAVE 
600 B Street, Suite 1650 
San Diego, CA 92101 
Attorneys for Defendant 
BANK OF AMERICA, N.A. 
 
 
 
Case 3:21-md-02992-GPC-MSB     Document 590     Filed 10/17/25     PageID.39863     Page
12 of 13

 
 
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BANA’S RJN ISO MOT. FOR PARTIAL SJ 
CASE NO. 21-MD-02992-GPC-MSB 
 
 
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW 
CERTIFICATE OF SERVICE 
I hereby certify that I electronically filed the foregoing with the clerk of the 
court for the United States District Court for the Southern District of California by 
using the CM/ECF system on October 17, 2025. I further certify that all participants 
in the case are registered CM/ECF users and that service will be accomplished by the 
CM/ECF system. I certify under penalty of perjury that the foregoing is true and 
correct. 
 
 
 
Dated:  October 17, 2025 
 
s/ Laura G. Brys 
 
 
 
 
 
Case 3:21-md-02992-GPC-MSB     Document 590     Filed 10/17/25     PageID.39864     Page
13 of 13

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