Court filing
14C — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-34, 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. 591-34 · 2025-10-17 · Docket on CourtListener
Full text
DX 14.C
REDACTED VERSION OF
DOCUMENT SOUGHT TO
BE SEALED PURSUANT TO
STIPULATED
PROTECTIVE ORDER
Case 3:21-md-02992-GPC-MSB Document 591-34 Filed 10/17/25 PageID.41517
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HIGHLY CONFIDENTIAL
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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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SAN DIEGO DIVISION
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IN RE BANK OF AMERICA ) Case No.
CALIFORNIA UNEMPLOYMENT ) 21-MD-02992 LAB-MSB
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BENEFITS LITIGATION )
_______________________________ )
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This Document Relates to )
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All Actions )
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)
_______________________________
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HIGHLY CONFIDENTIAL
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VIDEO-RECORDED DEPOSITION OF JANE CLONINGER
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Wednesday, June 11, 2025
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San Francisco, California
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Stenographically Reported By:
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Hanna Kim, CLR, CSR No. 13083
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Job No. 7413877
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MS. C. CHAN: Objection.
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THE WITNESS: I don't think so.
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BY MS. Y. CHAN:
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Q. Okay. Let me show you what we've
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premarked as Exhibits 1 and 2. These are your two 10:37:10
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reports in this case.
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And did you draft these reports?
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A. Yes, I drafted these reports.
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Q. Okay. Did anyone help you?
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A. Well, I drafted them and worked with my 10:37:25
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attorneys here to edit and refine and -- but
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everything is, you know, subject to my final
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approval.
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Q. Yeah. Did anyone else other than the
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attorneys help you with the report? 10:37:39
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A. No.
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Q. Okay. Did anyone rewrite any portions of
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your reports?
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A. No. I mean, my -- the edits would have
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rewritten pieces, but those I reviewed and made 10:37:49
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share I was totally comfortable with.
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Q. Did any of those edits change the
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substance of your opinion?
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A. No. They just helped it communicate
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better. 10:38:03
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HIGHLY CONFIDENTIAL
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Q. Okay. Did any of those edits change the
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nature of the opinion?
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A. No.
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Q. Okay. Did any of those edits add a new
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opinion that you had not included in a prior draft? 10:38:09
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A. I don't think so. I think we refined it
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also as we went through the process to reflect what
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we were learning through the other -- through the
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exchange of documents, so...
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Q. And you also submitted two declarations in 10:38:28
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con- -- in connection with the class certification
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briefing in this case.
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Do you recall that? Not -- not the one --
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A. I'm just looking at what you had, to see
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what you have here. 10:38:43
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Yes, there was a -- a -- a -- a report for
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class certification.
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Q. Okay. And did you draft those two
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declarations?
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A. Yes. 10:38:51
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Q. Did anyone help you with those?
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A. The same as with these.
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Q. Okay. Have you reviewed those recently?
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A. I looked at them some in the last few
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days. 10:39:00
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HIGHLY CONFIDENTIAL
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Q. Is there anything that you offered in
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those class cert declarations that you want to
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change now or that you now disagree with?
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A. I don't think so.
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Q. Okay. Have any of those opinions changed? 10:39:13
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A. I don't think so, no.
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Q. And did you review the two reports in
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front of you in pre- -- in preparation for today?
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A. Yes.
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Q. Did you see anything in there that you 10:39:25
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wanted to correct or change?
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A. No.
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Q. Okay. What else did you do in preparation
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for this deposition?
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A. Oh, I read through some of the documents 10:39:34
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that are cited. I did a prep session with the
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attorneys on Monday. And just reviewed materials.
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Q. Did you speak with anyone other than the
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attorneys in preparation for this deposition?
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A. No. 10:40:01
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Q. Did you speak with any of the other expert
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witnesses in this case?
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A. No.
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Q. Have you ever spoken with any of the other
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expert witnesses in this case? 10:40:07
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HIGHLY CONFIDENTIAL
CERTIFICATE OF REPORTER
I, Hanna Kim, a Certified Shorthand
Reporter, do hereby certify:
That prior to being examined, the witness
in the foregoing proceedings was by me duly sworn to
testify to the truth, the whole truth, and nothing
but the truth;
That said proceedings were taken before me
at the time and place therein set forth and were
taken down by me in shorthand and thereafter
transcribed into typewriting under my direction and
supervision;
I further certify that I am neither
counsel for, nor related to, any party to said
proceedings, not in anywise interested in the
outcome thereof.
Further, that if the foregoing pertains to
the original transcript of a deposition in a federal
case, before completion of the proceedings, review
of the transcript [X] was [] was not requested.
In witness whereof, I have hereunto
subscribed my name.
Dated:
June 25, 2025.
r/f
Hanna Kim CLR, CSR No. 13083
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