Court filing
14AD — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-29, S.D. Cal. No. 3:21-md-02992)
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. 591-29 · 2025-10-17 · Docket on CourtListener
Full text
DX 14.AD REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED PURSUANT TO STIPULATED PROTECTIVE ORDER Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41440 Page 1 of 17 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41441 Page 2 of 17 1 2 UNITED STATES DISTRICT COURT 3 SOUTHERN DISTRICT OF CALIFORNIA 4 CASE NO. 3:21-md-02992-LAB-MSB 5 - - - - - - - - - - - - - - - - - - - - - - - - 6 IN RE BANK OF AMERICA 7 CALIFORNIA UNEMPLOYMENT 8 BENEFITS LITIGATION 9 - - - - - - - - - - - - - - - - - - - - - - - - 10 11 TRANSCRIPT of the stenographic notes of 12 the videotaped deposition of RYAN SCHWARTZ in the 13 above-entitled matter, as taken by and before 14 LORRAINE B. ABATE, a Certified Shorthand Reporter and 15 Notary Public of the State of New York, and 16 Registered Professional Reporter, held at the offices 17 of Goodwin Procter LLP, New York Times Building, 620 18 Eighth Avenue, New York, New York 10018, on December 19 4, 2024, commencing at 9:43 a.m., pursuant to Notice. 20 21 22 23 Job No.: 10154398 24 25 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41442 Page 3 of 17 1 Schwartz - December 4, 2024 2 Q. Who's your supervisor now? 3 A. Let me think about that. It's the same 4 answer. My formal supervisor, I've never spoken to. 5 My functional supervisor is Amy Pierce. 6 Q. Who is her supervisor? 7 A. Sara Walsh. Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41443 Page 4 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41444 Page 5 of 17 14 MR. JONES: I think we can take a break 15 now. 16 THE VIDEOGRAPHER: The time is 11:01 17 a.m. We're going off the record. 18 (There was a recess taken.) 19 THE VIDEOGRAPHER: The time is 11:20 20 a.m. We're back on the record. 21 BY MR. JONES: 22 Q. Before we took a break, we had been 23 talking about various e-mails and some of your 24 colleagues on those e-mails. 25 A. Yes. Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41445 Page 6 of 17 1 Schwartz - December 4, 2024 2 Q. And so is it correct to say that Letson, 3 Holt, and Michel are the folks you were working 4 closest -- most close with -- 5 A. Yes. 6 Q. -- in this period? 7 A. My immediate colleagues, yes, that's 8 correct. 9 Q. What was Letson's background and 10 expertise? 11 A. I'm not sure I know for certain. 12 Q. What was your sense of it at the time? 13 A. He had either an auditing or accounting 14 background. I know he had been with the bank for 15 decades. I did not know Mike very well at all prior 16 to these events. He hired me, obviously, and knew 17 who I was, but I don't know Mike personally or 18 professionally. I've never actually met him in 19 person. 20 Q. And what was Holt's background? 21 A. I have the same answer. I don't know. 22 I only met her very briefly, before she was on 23 medical leave -- maternity leave. I don't think 24 she'd mind me saying that. 25 Q. You had mentioned that she had some Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41446 Page 7 of 17 1 Schwartz - December 4, 2024 2 expertise in fraud rings; is that right? 3 A. That was my understanding of her time at 4 the bank, had been primarily within either financial 5 crimes specifically or fraud group, but I can't 6 testify to her specific background or resume. I've 7 never seen it. 8 Q. Did you find her to have useful 9 contributions to this work? 10 A. Absolutely, yes. I absolutely did, yes. 11 She had a different perspective and different 12 background than mine. 19 Q. And what was Michel's background, as far 20 as you remember? 21 A. As far as I remember, prior coming -- 22 prior to coming to the bank, she had worked for a law 23 enforcement agency in an analytical capacity. I 24 don't recall which one. Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41447 Page 8 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41448 Page 9 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41449 Page 10 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41450 Page 11 of 17 1 Schwartz - December 4, 2024 3 Q. Were you the primary person on the team 4 with expertise in data analytics? 5 A. Yes. That's why they hired me. And 6 when you -- when I say team, I want to be clear I'm 7 talking about Mike's team specifically. 8 Q. Yes. 9 And Mike's team is larger than the four 10 of you; is that correct? 11 A. At the time, I can't recall specifically 12 what his team was. I'd be -- this is my best guess, 13 is that he had probably three teams of equivalent 14 size. Typically at the bank, a team would be about 15 eight or ten people reporting to a common manager. I 16 believe he had -- I believe he had three managers at 17 the time. 18 Q. And one of those three was Holt? 19 A. Again, it was -- she was on leave, so 20 there was some, you know, temporary management by 21 other people, but one of them was Anne, yes. 22 Q. And so you spent a fair amount of time 23 working with Holt, Michel, and Letson on prepaid -- 24 A. Absolutely, yes. 25 Q. -- issues? Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41451 Page 12 of 17 1 Schwartz - December 4, 2024 2 A. Absolutely. Once it became -- it came 3 to our attention that there was a pretty severe 4 problem with that product. 5 Q. And was it your experience that all of 6 you had valuable things to contribute to the work 7 that you were doing? 8 A. I think all of my colleagues are 9 valuable, yes. 10 MR. JONES: Good on-the-record answer. Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41452 Page 13 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41453 Page 14 of 17 1 Schwartz - December 4, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41454 Page 15 of 17 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41455 Page 16 of 17 1 Schwartz - December 4, 2024 2 C E R T I F I C A T I O N 3 4 STATE OF NEW YORK ) 5 ) ss: 6 COUNTY OF WESTCHESTER ) 7 8 9 I, LORRAINE B. ABATE, a Certified Shorthand 10 Reporter and Notary Public of the State of New York 11 and Registered Professional Reporter, do hereby 12 certify the foregoing to be a true and accurate 13 transcript of my original stenographic notes taken of 14 RYAN SCHWARTZ at the time and place hereinbefore set 15 forth. 16 I further certify that I am not related, by 17 blood or marriage, to any of the parties in this 18 matter and that I am in no way interested in the 19 outcome of this matter. 20 21 ____________________________________ 22 LORRAINE B. ABATE, CSR, RPR 23 License No. 000965 24 25 Dated: December 7, 2024 Case 3:21-md-02992-GPC-MSB Document 591-29 Filed 10/17/25 PageID.41456 Page 17 of 17
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