Court filing
Declaration of Laura G. Brys by Defendant Bank of America, N.A. — In re BofA Unemployment Litigation (Dkt. 591)
Filed October 17, 2025 in In re Bank of America California Unemployment Benefits Litigation; one of 1415 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of California |
|---|---|
| Filed | 2025-10-17 |
U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 591 · 2025-10-17 · Docket on CourtListener
Full text
BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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. 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 DECLARATION OF LAURA G. BRYS IN SUPPORT OF DEFENDANT BANK OF AMERICA, N.A.’S MOTION FOR PARTIAL SUMMARY JUDGMENT Date: April 17, 2026 Time: 1:30 p.m. Ctrm: 12AD – 12th Floor Judge: Hon. Gonzalo P. Curiel Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40635 Page 1 of 23 2 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Laura Brys, hereby declare as follows: 1. I am an attorney licensed to practice before this Court. 2. I am a senior attorney at Goodwin Procter LLP, attorneys of record for Defendant BANK OF AMERICA, N.A. (BANA) in this action. 3. I make this declaration in support of BANA’s Motion for Partial Summary Judgment. I have personal knowledge of the matters set forth in this Declaration and/or upon a review of non-privileged records kept by Goodwin Procter LLP in the regular course of its business, and if called upon to do so, I could and would testify competently to same. 4. BANA’s Exhibits to this Declaration shall be referred to as “DX” in BANA’s Motion for Partial Summary Judgment and its supporting documents. Fact Declarations 5. Attached hereto as Exhibit 1 is a true and correct copy of the Declaration of Robert Chestnut in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. 6. Attached hereto as Exhibit 2 is a true and correct copy of the Declaration of William Golden in Support of Defendant’s Motion for Partial Summary Judgment dated October 15, 2025. 7. Attached hereto as Exhibit 3 is a true and correct copy of the Declaration of Jennifer Lennon in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. 8. Attached hereto as Exhibit 4 is a true and correct copy of the Declaration of Michael J. Letson in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. 9. Attached hereto as Exhibit 5 is a true and correct copy of the Declaration of William M. Martin in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. 10. Attached hereto as Exhibit 6 is a true and correct copy of the Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40636 Page 2 of 23 3 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Don Robart in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. Expert Declarations and Reports 11. Attached hereto as Exhibit 7 is a true and correct copy of the Declaration of Victor Stango in Support of Defendant’s Motion for Partial Summary Judgment dated October 16, 2025. 12. Attached hereto as Exhibit 7.A is a true and correct copy of the Expert Report of Victor Stango, and appendices thereto, dated April 4, 2025. 13. Attached hereto as Exhibit 8 is a true and correct copy of the Declaration of Justin McCrary in Support of Defendant’s Motion for Partial Summary Judgment dated October 13, 2025. 14. Attached hereto as Exhibit 8.A is a true and correct copy of the Expert Report of Professor Justin McCrary, and appendices thereto, dated April 4, 2025. 15. Attached hereto as Exhibit 9 is a true and correct copy of the Declaration of Carl Pry in Support of Defendant’s Motion for Partial Summary Judgment dated October 10, 2025. 16. Attached hereto as Exhibit 9.A is a true and correct copy of the Expert Rebuttal Report of Carl Pry, and appendices thereto, dated April 4, 2025. 17. Attached hereto as Exhibit 10 is a true and correct copy of the Declaration of Russell Cronan in Support of Defendant’s Motion for Partial Summary Judgment dated October 13, 2025. 18. Attached hereto as Exhibit 10.A is a true and correct copy of the Expert Report of Russell Cronan, and appendices thereto, dated March 4, 2025. 19. Attached hereto as Exhibit 11 is a true and correct copy of the Declaration of Teresa A. Pesce in Support of Defendant’s Motion for Partial Summary Judgment dated October 13, 2025. 20. Attached hereto as Exhibit 11.A is a true and correct copy of the Expert Rebuttal Report of Teresa A. Pesce, and appendices thereto, dated April 4, 2025. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40637 Page 3 of 23 4 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21. Attached hereto as Exhibit 11.B is a true and correct copy of the Expert Report of Teresa A. Pesce, and appendices thereto, dated March 4, 2025. 22. Attached hereto as Exhibit 12 is a true and correct copy of the Declaration of Pamela Joseph dated October 11, 2025. 23. Attached hereto as Exhibit 12.A is a true and correct copy of the Expert Report of Pamela Joseph, and appendices thereto, dated March 4, 2025. 24. Attached hereto as Exhibit 12.B is a true and correct copy of the Expert Rebuttal Report of Pamela Joseph in Support of Defendant’s Motion for Partial Summary Judgment, dated April 4, 2025. 25. Attached hereto as Exhibit 13 is a true and correct copy of the Declaration of Stephen Hindle in Support of Defendant’s Motion for Partial Summary Judgment dated October 10, 2025. 26. Attached hereto as Exhibit 13.A is a true and correct copy of the Expert Rebuttal Report of Steve Hindle dated April 4, 2025. Deposition Transcripts 27. Attached hereto as Exhibit 14.A is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Faiz A. Ahmad, taken on January 29, 2025. 28. Attached hereto as Exhibit 14.B is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Robert A. Chestnut, taken on February 8, 2024. 29. Attached hereto as Exhibit 14.C is a true and correct copy of excerpts of the official transcript of BANA’s deposition of Jane Cloninger, taken on June 11, 2025. 30. Attached hereto as Exhibit 14.C.1 is a true and correct copy of the Expert Report of Jane Cloninger, and appendices thereto, dated March 4, 2025. 31. Attached hereto as Exhibit 14.C.2 is a true and correct copy of the Expert Rebuttal Report of Jane Cloninger, and appendices thereto, dated April 4, Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40638 Page 4 of 23 5 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2025. 32. Attached hereto as Exhibit 14.D is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Russell Wayne Cronan, Sr., taken on May 1, 2025. 33. Attached hereto as Exhibit 14.E is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Shane Daniels, taken on February 6, 2024. 34. Attached hereto as Exhibit 14.F is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Chloe Noel East, Ph.D., taken on May 15, 2025. 35. Attached hereto as Exhibit 14.F.1 is a true and correct copy of the Expert Report of Chloe Noel East, and appendices thereto, dated March 4, 2025. 36. Attached hereto as Exhibit 14.G is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Jennifer Ehresman, taken on February 19, 2025. 37. Attached hereto as Exhibit 14.H is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of William Fox, taken on February 13, 2025. 38. Attached hereto as Exhibit 14.I is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Bradley Garfield, taken on December 10, 2024. 39. Attached hereto as Exhibit 14.J is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of William Golden, taken on February 22, 2024. 40. Attached hereto as Exhibit 14.K is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Stephen Hindle, taken on April 29, 2025. 41. Attached hereto as Exhibit 14.L is a true and correct copy of excerpts Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40639 Page 5 of 23 6 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of the official transcript of Plaintiffs’ deposition of Anne Holt, taken on January 8, 2025. 42. Attached hereto as Exhibit 14.M is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Renee Johnson, taken on May 7, 2024. 43. Attached hereto as Exhibit 14.N is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Pamela Ann Joseph, taken on May 12, 2025. 44. Attached hereto as Exhibit 14.O is a true and correct copy of excerpts of the official transcript of BANA’s deposition of J. Daniel Kreis, taken on May 5, 2025. 45. Attached hereto as Exhibit 14.O.1 is a true and correct copy of excerpts of the Expert Report of J. Daniel Kreis, and appendices thereto, dated March 4, 2025. 46. Attached hereto as Exhibit 14.P is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Jennifer Lennon, taken on February 23, 2024. 47. Attached hereto as Exhibit 14.Q is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition Michael Letson, taken on February 16, 2024. 48. Attached hereto as Exhibit 14.R is a true and correct copy of excerpts of the official transcript of BANA’s deposition of David I. Levine, taken on May 28, 2025. 49. Attached hereto as Exhibit 14.R.1 is a true and correct copy of excerpts of the Expert Report of David I. Levine dated March 4, 2025. 50. Attached hereto as Exhibit 14.S is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of William Matthew Martin, taken on February 14, 2024. 51. Attached hereto as Exhibit 14.T is a true and correct copy of excerpts Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40640 Page 6 of 23 7 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of the official transcript of BANA’s deposition of Lindsay McClure, taken on March 12, 2024. 52. Attached hereto as Exhibit 14.U is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Jay Minnucci, taken on April 23, 2025. 53. Attached hereto as Exhibit 14.U.1 is a true and correct copy of excerpts of the Expert Report of Jay Minnucci, and appendices thereto, dated March 4, 2025. 54. Attached hereto as Exhibit 14.V is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Thomas Montag, taken on September 24, 2025. 55. Attached hereto as Exhibit 14.W is a true and correct copy of excerpts of the official transcript of BANA’s deposition of Azuri Moon, taken on February 27, 2024. 56. Attached hereto as Exhibit 14.X is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Brian T. Moynihan, taken on October 2, 2025. 57. Attached hereto as Exhibit 14.Y is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Teresa Pesce, taken on May 8, 2025. 58. Attached hereto as Exhibit 14.Z is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Carl Pry, taken on May 16, 2025. 59. Attached hereto as Exhibit 14.AA is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Melissa Ramirez, taken on February 11, 2025. 60. Attached hereto as Exhibit 14.AB is a true and correct copy of excerpts of the official transcript of BANA’s deposition of Greg Regan, taken on May 19, 2025. 61. Attached hereto as Exhibit 14.AB.1 is a true and correct copy of the Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40641 Page 7 of 23 8 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Expert Report of Greg J. Regan, CPA/CFF, CFE, and appendices thereto, dated March 4, 2025. 62. Attached hereto as Exhibit 14.AC is a true and correct copy of excerpts of the official transcript of BANA’s deposition of Vanessa Rivera, taken on February 29, 2025. 63. Attached hereto as Exhibit 14.AD is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Ryan Schwartz, taken on December 4, 2025. 64. Attached hereto as Exhibit 14.AE is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Paul Simpson, taken on February 21, 2025. 65. Attached hereto as Exhibit 14.AF is a true and correct copy of excerpts of the official transcript of the deposition of Shameel Singh, taken on May 8, 2025. 66. Attached hereto as Exhibit 14.AG is a true and correct copy of excerpts of the official transcript of Plaintiffs’ deposition of Victor Stango, taken on May 30, 2025. Plaintiffs’ Discovery Responses 67. Attached hereto as Exhibit 15 is a true and correct copy of an excerpt from Plaintiff Kuang Ting Chong’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 68. Attached hereto as Exhibit 16 is a true and correct copy of an excerpt from Plaintiff Candace Koole’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 69. Attached hereto as Exhibit 17 is a true and correct copy of an excerpt from Plaintiff Lindsey McClure’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 70. Attached hereto as Exhibit 18 is a true and correct copy of an excerpt from Plaintiff Azuri Moon’s Supplemental Responses to BANA’s First Set of Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40642 Page 8 of 23 9 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Interrogatories Directed to Plaintiffs. 71. Attached hereto as Exhibit 19 is a true and correct copy of an excerpt from Plaintiff Stephanie Moore’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 72. Attached hereto as Exhibit 20 is a true and correct copy of an excerpt from Plaintiff Roland Oosthuizen’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 73. Attached hereto as Exhibit 21 is a true and correct copy of an excerpt from Plaintiff Vanessa Rivera’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 74. Attached hereto as Exhibit 22 is a true and correct copy of an excerpt from Plaintiff J. Michael Willrich’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. 75. Attached hereto as Exhibit 23 is a true and correct copy of an excerpt from Plaintiff Alex Yuan’s Supplemental Responses to BANA’s First Set of Interrogatories Directed to Plaintiffs. Subpoena Responses 76. Attached hereto as Exhibit 24 is a true and correct copy of the Declaration of Marc D. Keller in response to Plaintiffs’ Subpoena, dated May 14, 2024. 77. Attached hereto as Exhibit 25 is a true and correct copy of TTEC’s Response to Plaintiff Lindsay McClure’s Subpoena. BANA’s Discovery Responses 78. Attached hereto as Exhibit 26 is a true and correct copy of an excerpt from BANA’s Responses to Plaintiffs’ First Set of Requests for Admission. 79. Attached hereto as Exhibit 27 is a true and correct copy of excerpts from BANA’s Revised Second Supplemental Responses to Plaintiffs’ First Set of Interrogatories. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40643 Page 9 of 23 10 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 80. Attached hereto as Exhibit 27.A is a true and correct copy of Exhibit 1 of BANA’s Revised Second Supplemental Responses to Plaintiffs’ First Set of Interrogatories. 81. Attached hereto as Exhibit 27.B is a true and correct copy of Exhibit 3 of BANA’s Revised Second Supplemental Responses to Plaintiffs’ First Set of Interrogatories. 82. Attached hereto as Exhibit 27.C is a true and correct copy of Exhibit 4 of BANA’s Revised Second Supplemental Responses to Plaintiffs’ First Set of Interrogatories. 83. Attached hereto as Exhibit 27.D is a true and correct copy of Exhibit 5 of BANA’s Revised Second Supplemental Responses to Plaintiffs’ First Set of Interrogatories. 84. Attached hereto as Exhibit 28 is a true and correct copy of excerpts from BANA’s Responses to Plaintiffs’ Fourth Set of Interrogatories. 85. Attached hereto as Exhibit 28.A is a true and correct copy of an excerpt from BANA’s Revised Responses to Plaintiffs’ Third Set of Interrogatories. 86. Attached hereto as Exhibit 28.A.1 is a true and correct copy of an excerpt from BANA’s Revised Responses to Plaintiffs’ Third Set of Interrogatories. 87. Attached hereto as Exhibit 29 is a true and correct copy of an excerpt from BANA’s Responses to Plaintiffs’ Eighth Set of Interrogatories. 88. Attached hereto as Exhibit 30 is a true and correct copy of an excerpt from BANA’s Responses to Plaintiffs’ Fifth Set of Interrogatories. 89. Attached hereto as Exhibit 30.A is a true and correct copy of excerpts from BANA’s Responses to Plaintiffs’ Fifth Set of Interrogatories. 90. Attached hereto as Exhibit 30.B is a true and correct copy of BANA’s Supplemental Responses to Plaintiffs’ Fifth Set of Interrogatories. 91. Attached hereto as Exhibit 31 is a true and correct copy of excerpts from BANA’s Second Set of Responses to Plaintiffs’ Seventh Set of Interrogatories. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40644 Page 10 of 23 11 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 92. Attached hereto as Exhibit 31.A is a true and correct copy of excerpts from BANA’s Second Supplemental Responses to Plaintiffs’ Seventh Set of Interrogatories. 93. Attached hereto as Exhibit 31.B is a true and correct copy of an excerpt from BANA’s Revised Second Supplemental Responses to Plaintiffs’ Seventh Set of Interrogatories. 94. Attached hereto as Exhibit 31.B.1 is a true and correct copy of excerpts from BANA’s Revised Second Supplemental Responses to Plaintiffs’ Seventh Set of Interrogatories. Plaintiff Produced Documents 95. Attached hereto as Exhibit 32 is a true and correct copy of a document produced by Plaintiff Candace Koole in this action Bates stamped Koole_C_00000055. 96. Attached hereto as Exhibit 33 is a true and correct copy of a document produced by Plaintiff Candace Koole in this action Bates stamped Koole_C_00000067. 97. Attached hereto as Exhibit 34 is a true and correct copy of a document produced by Plaintiff Azuri Moon in this action Bates stamped Moon_A_00000006. 98. Attached hereto as Exhibit 35 is a true and correct copy of a document produced by Plaintiff Azuri Moon in this action Bates stamped Moon_A_00000088. 99. Attached hereto as Exhibit 36 is a true and correct copy of a document produced by Plaintiff Azuri Moon in this action Bates stamped Moon_A_00000118. 100. Attached hereto as Exhibit 37 is a true and correct copy of a document produced by Plaintiff Azuri Moon in this action Bates stamped Moon_A_00000141. 101. Exhibit 38 is intentionally omitted. BANA Documents 102. Attached hereto as Exhibit 39 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00002286. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40645 Page 11 of 23 12 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 103. Attached hereto as Exhibit 40.A is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00001500. 104. Attached hereto as Exhibit 40.B is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00086396. 105. Attached hereto as Exhibit 41 is a true and correct copy of the Consent Order of the Office of the Comptroller of the Currency (OCC). 106. Attached hereto as Exhibit 42 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00387807. 107. Attached hereto as Exhibit 43.A is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00102554. 108. Attached hereto as Exhibit 43.B is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00102520. 109. Attached hereto as Exhibit 43.C is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00102578. 110. Attached hereto as Exhibit 44 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00012816. 111. Attached hereto as Exhibit 45 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00354749. 112. Attached hereto as Exhibit 46 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00012801. 113. Attached hereto as Exhibit 47 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00013111. 114. Attached hereto as Exhibit 48 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00013107. 115. Attached hereto as Exhibit 49 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40646 Page 12 of 23 13 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00013096. 116. Attached hereto as Exhibit 50 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00002852. 117. Attached hereto as Exhibit 51 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00005509. 118. Attached hereto as Exhibit 52 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00012790. 119. Attached hereto as Exhibit 53 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014090. 120. Attached hereto as Exhibit 54 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014091. 121. Attached hereto as Exhibit 55 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014099. 122. Attached hereto as Exhibit 56 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014817. 123. Attached hereto as Exhibit 57 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014819. 124. Attached hereto as Exhibit 58 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014820. 125. Attached hereto as Exhibit 59 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00014821. 126. Attached hereto as Exhibit 60 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00015433. 127. Attached hereto as Exhibit 61 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00019602. 128. Attached hereto as Exhibit 62 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00019618. 129. Attached hereto as Exhibit 63 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40647 Page 13 of 23 14 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00019846. 130. Attached hereto as Exhibit 64 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00043600. 131. Attached hereto as Exhibit 65 is a true and correct copy of an excerpt of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00044098. 132. Attached hereto as Exhibit 66 is a true and correct copy of an excerpt of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00044180. 133. Attached hereto as Exhibit 67 is a true and correct copy of an excerpt of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00044201. 134. Attached hereto as Exhibit 68 is a true and correct copy of an excerpt of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00044202. 135. Attached hereto as Exhibit 69 is a true and correct copy of an excerpt of a document produced by BANA in this action Bates stamped BANA_EDD_MDL- 00044295. 136. Attached hereto as Exhibit 70 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00054835. 137. Attached hereto as Exhibit 71 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00057488. 138. Attached hereto as Exhibit 72 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00059677. 139. Attached hereto as Exhibit 73 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00073529. 140. Attached hereto as Exhibit 74 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00074993. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40648 Page 14 of 23 15 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 141. Attached hereto as Exhibit 75 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00076984. 142. Attached hereto as Exhibit 76 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00077224. 143. Attached hereto as Exhibit 77 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00082907. 144. Exhibit 77.A is intentionally omitted.1 145. Attached hereto as Exhibit 78 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00085548. 146. Attached hereto as Exhibit 79 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00086221. 147. Attached hereto as Exhibit 80 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00086827. 148. Attached hereto as Exhibit 81 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00086931. 149. Attached hereto as Exhibit 82 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00086932. 150. Attached hereto as Exhibit 83 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00087715. 151. Attached hereto as Exhibit 84 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00087749. 152. Attached hereto as Exhibit 85 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00087772. 153. Attached hereto as Exhibit 86 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00087776. 154. Attached hereto as Exhibit 87 is a true and correct copy of a document 1 Exhibit 77.A (BANA_EDD_MDL-00082909) is an email attachment to Exhibit 77 (BANA_EDD_MDL-00082907) and is intentionally omitted given its large file size. BANA would be happy to provide a copy of Exhibit 77.A to the Court upon request. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40649 Page 15 of 23 16 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00088501. 155. Attached hereto as Exhibit 88 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00088506. 156. Exhibit 89 is intentionally omitted. 157. Attached hereto as Exhibit 90 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00090725. 158. Attached hereto as Exhibit 91 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00107342. 159. Attached hereto as Exhibit 92 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00116204. 160. Attached hereto as Exhibit 93 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00116445. 161. Attached hereto as Exhibit 94 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00117094. 162. Attached hereto as Exhibit 95 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00117097. 163. Attached hereto as Exhibit 96 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00117903. 164. Attached hereto as Exhibit 97 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00118436. 165. Attached hereto as Exhibit 98 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00120424. 166. Attached hereto as Exhibit 99 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00123624. 167. Attached hereto as Exhibit 100 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00124522. 168. Attached hereto as Exhibit 101 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00125059. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40650 Page 16 of 23 17 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 169. Attached hereto as Exhibit 102 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00125116. 170. Exhibit 103 is intentionally omitted. 171. Attached hereto as Exhibit 104 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00125919. 172. Attached hereto as Exhibit 105 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00125920. 173. Attached hereto as Exhibit 106 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00140121. 174. Attached hereto as Exhibit 107 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00142739. 175. Attached hereto as Exhibit 108 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00143488. 176. Attached hereto as Exhibit 109 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00143629. 177. Attached hereto as Exhibit 110 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00153842. 178. Attached hereto as Exhibit 111 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00154700. 179. Attached hereto as Exhibit 112 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00163779. 180. Attached hereto as Exhibit 113 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00164188. 181. Attached hereto as Exhibit 114 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00164189. 182. Attached hereto as Exhibit 115 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00167033. 183. Attached hereto as Exhibit 116 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40651 Page 17 of 23 18 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00186897. 184. Attached hereto as Exhibit 117 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00198287. 185. Attached hereto as Exhibit 118 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00202603. 186. Attached hereto as Exhibit 119 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00206047. 187. Attached hereto as Exhibit 120 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00225375. 188. Attached hereto as Exhibit 121 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00265136. 189. Attached hereto as Exhibit 122 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00283611. 190. Attached hereto as Exhibit 123 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00287946. 191. Attached hereto as Exhibit 124 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00287970. 192. Attached hereto as Exhibit 125 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00296860. 193. Attached hereto as Exhibit 126 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00298567. 194. Attached hereto as Exhibit 127 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00353033. 195. Attached hereto as Exhibit 128 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00354508. 196. Attached hereto as Exhibit 129 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00368628. 197. Attached hereto as Exhibit 130 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40652 Page 18 of 23 19 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00370150. 198. Attached hereto as Exhibit 131 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00370151. 199. Attached hereto as Exhibit 132 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00405281. 200. Attached hereto as Exhibit 133 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00416742. 201. Attached hereto as Exhibit 134 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00422979. 202. Attached hereto as Exhibit 135 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00428994. 203. Attached hereto as Exhibit 136 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00430148. 204. Attached hereto as Exhibit 137 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00433183. 205. Attached hereto as Exhibit 138 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00433929. 206. Attached hereto as Exhibit 139 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00436910. 207. Attached hereto as Exhibit 140 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00436971. 208. Attached hereto as Exhibit 141 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00447117. 209. Attached hereto as Exhibit 142 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00448765. 210. Attached hereto as Exhibit 143 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00450462. 211. Attached hereto as Exhibit 144 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40653 Page 19 of 23 20 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00450467. 212. Attached hereto as Exhibit 145 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00450516. 213. Attached hereto as Exhibit 146 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00452826. 214. Attached hereto as Exhibit 147 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00468505. 215. Attached hereto as Exhibit 148 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00493780. 216. Attached hereto as Exhibit 149 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00497802. 217. Attached hereto as Exhibit 150 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00500173. 218. Attached hereto as Exhibit 151 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00505808. 219. Attached hereto as Exhibit 152 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00515252. 220. Attached hereto as Exhibit 153 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00531012. 221. Attached hereto as Exhibit 154 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00534403. 222. Attached hereto as Exhibit 155 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00534409. 223. Attached hereto as Exhibit 156 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00546652. 224. Attached hereto as Exhibit 157 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00570333. 225. Attached hereto as Exhibit 158 is a true and correct copy of a document Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40654 Page 20 of 23 21 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_.EDD_MDL-00580207. 226. Attached hereto as Exhibit 159 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00592324. 227. Exhibit 160 is intentionally omitted. 228. Attached hereto as Exhibit 161 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00617457. 229. Exhibit 161.A is intentionally omitted.2 230. Attached hereto as Exhibit 162 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00617463. 231. Exhibit 162.A is intentionally omitted.3 232. Attached hereto as Exhibit 163 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00624540. 233. Attached hereto as Exhibit 164 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00624542. 234. Attached hereto as Exhibit 165 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00624545. 235. Attached hereto as Exhibit 166 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00624679. 236. Attached hereto as Exhibit 167 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00637212. 237. Attached hereto as Exhibit 168 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00640771. 238. Attached hereto as Exhibit 169 is a true and correct copy of a document 2 Exhibit 161.A (BANA_EDD_MDL-00617459) is an email attachment to Exhibit 161 (BANA_EDD_MDL-00617457) and is intentionally omitted given its large file size. BANA would be happy to provide a copy of Exhibit 161.A to the Court upon request. 3 Exhibit 162.A (BANA_EDD_MDL-00617465) is an email attachment to Exhibit 162 (BANA_EDD_MDL-00617463) and is intentionally omitted given its large file size. BANA would be happy to provide a copy of Exhibit 162.A to the Court upon request. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40655 Page 21 of 23 22 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced by BANA in this action Bates stamped BANA_EDD_MDL-00678567. 239. Attached hereto as Exhibit 170 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00694846. 240. Attached hereto as Exhibit 171 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00707598. 241. Attached hereto as Exhibit 172 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00719114. 242. Attached hereto as Exhibit 173 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00719115. 243. Attached hereto as Exhibit 174 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00719116. 244. Exhibit 175 is intentionally omitted. 245. Attached hereto as Exhibit 176 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00720087. 246. Attached hereto as Exhibit 177 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00855874. 247. Attached hereto as Exhibit 178 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00871377. 248. Attached hereto as Exhibit 179 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00881851. 249. Attached hereto as Exhibit 180 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00884200. 250. Attached hereto as Exhibit 181 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00654305. 251. Attached hereto as Exhibit 182 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL_00071599. 252. Attached hereto as Exhibit 183 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00055974. Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40656 Page 22 of 23 23 BRYS DECL. ISO BANA MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 253. Attached hereto as Exhibit 184 is a true and correct copy of a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00205361. I declare under the penalty of perjury that the foregoing is true and correct. Executed on this 17th day of October, 2025. /s/ Laura G. Brys LAURA G. BRYS Case 3:21-md-02992-GPC-MSB Document 591 Filed 10/17/25 PageID.40657 Page 23 of 23
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