Court filing
14N — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-47, 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. 591-47 · 2025-10-17 · Docket on CourtListener
Full text
DX 14.N
REDACTED VERSION OF
DOCUMENT SOUGHT TO
BE SEALED PURSUANT TO
STIPULATED
PROTECTIVE ORDER
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41818
Page 1 of 10
Videotaped Deposition of
Pamela Ann Joseph
May 12, 2025
In Re Bank of America CA Unemployment Benefits Litigation
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41819
Page 2 of 10
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
IN RE:
BANK OF AMERICA Case No.
CALIFORNIA UNEMPLOYMENT 3:21-md-02992-GPC-MSB
BENEFITS LITIGATION
~~~~~~~~~~~~~~~~~~~~~~~
REMOTE VIDEOTAPED DEPOSITION OF
PAMELA ANN JOSEPH
May 12, 2025
11:11 a.m.
(All attendees appeared remotely via
teleconferencing and/or videoconferencing.)
Elizabeth R. Hollingsworth, CCR B-1319
Job No.: 10163119
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 1
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41820
Page 3 of 10
you recognize this document?
A Yes.
Q And this is a true and correct copy of
your rebuttal report in this case?
A Yes.
Q Okay.
I'll be referring throughout the
day to this Exhibit 5, your rebuttal report as --
dated April 4th, 2025, as your rebuttal report.
So Exhibit 4 is your expert report.
Exhibit 5 is
your rebuttal report.
Do the last three documents that we
just looked at, your class declaration, your
expert report, and your rebuttal report, do they
contain all the opinions that you are providing in
this case?
A Yes.
Q Are all of the opinions expressed in
your class certification declaration also
expressed in either your expert report or your
rebuttal report?
A That was very early in the process.
So
I'd have to go back and look at all of those
again.
But, again, I know that my expert report
and my rebuttal report are all my opinions.
Q Are there any opinions expressed in
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 35
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41821
Page 4 of 10
your class certification declaration that are not
expressed in either your expert report or your
rebuttal report?
A They would be my opinions, but I do not
know.
I would have to go back and look through
line by line.
Q You don't recall intentionally omitting
any declar- -- any opinions that were in your
class certification declaration from your
subsequent expert report or rebuttal report?
A No.
Q Okay.
Do you intend to offer any
opinions in this case beyond those expressed in
your expert report and rebuttal report?
A No.
Q Okay.
So if you could turn your
attention to Exhibit 4, the expert report.
Who
wrote this report?
A I wrote this report with support from
Ankura.
Q And when you say "Ankura," are you
referring to Ankura Consulting Group, LLC?
A Yes.
Q What is Ankura?
A They are the firm that hired me and
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 36
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41822
Page 5 of 10
Q I am not.
We have put together some
excerpts.
We do have a full copy of the contract
but in the interest of trying to save some paper
and some scrolling, we put together Exhibit 19,
which I will represent consists of excerpts from
the EDD bank contract.
It's 11 pages of excerpts.
A Okay.
Q Do you see the first page of this
document that's 11 pages --
A Standard agreement, yeah.
Q Standard Agreement.
And this is --
this is the EDD bank contract that you reviewed
portions of?
A Yes.
Q Great.
And on the last page of this
excerpt, so if you scroll to page 11 of the .pdf,
requirement 323 states, "The debit card shall
contain no less than an ISO 7811-compliant high
coercivity magnetic strip."
And the contractor agrees to that
requirement; correct?
A Correct.
Q It is possible for a card to have both
an ISO 7811-compliant high coercivity magnetic
strip and also an EMV chip; correct?
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 182
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41823
Page 6 of 10
A That is correct.
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
1
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 183
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41824
Page 7 of 10
Q If you could scroll to the sixth page
of this excerpt.
This is the page at the top of
it, it says "Continued support of the EDD s
central mission."
Are we on the same page?
A What does it say at the top?
Q "Continued support of the EDD's central
mission."
MS. YVONNE CHAN:
Click on the left.
Page 6.
(Inaudible.)
Q (By Ms. Connie Chan)
No.
No.
Thank
you.
I know.
Unfortunately, the page also does
not have -- this document does not have internal
page numbers.
A Okay.
I'm there.
Q And if you could look at the very
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 184
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41825
Page 8 of 10
COURT REPORTER CERTIFICATE
STATE OF GEORGIA:
COUNTY OF DEKALB:
I hereby certify that the foregoing
transcript was taken down, as stated in the
caption, and the proceedings were reduced to
typewriting under my direction and control;
that the foregoing pages represent a true,
complete, and correct transcript of the
evidence given upon said deposition; and I
further certify that I am not of kin or
counsel to the parties in the case; am not
in the employ of counsel for any of said
parties; nor am I in any way interested in
the result of said case.
This, the 28th day of May, 2025.
________________________
Elizabeth R. Hollingsworth, CCR B-1319
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 230
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41826
Page 9 of 10
DISCLOSURE OF NO CONTRACT
I, Elizabeth R. Hollingsworth, CCR, do
hereby disclose, pursuant to Article 10.B of the
Rules and Regulations of the Board of Court
Reporting of the Judicial Council of Georgia, that
Gallo Legal Services, was contacted by the party
taking the deposition to provide court reporting
services for this deposition and there is no
contract that is prohibited by O.C.G.A.
15-14-37(a) and (b) or Article 7.C. of the Rules
and Regulations of the Board for the taking of
this deposition.
There is no contract to provide court
reporting services between Gallo Legal Services,
or any person with whom Gallo Legal Services, has
a principal and agency relationship nor any
attorney at law in this action, party to this
action, party having a financial interest in this
action, or agent for an attorney at law in this
action, party to this action, or party having a
financial interest in this action.
Any and all
financial arrangements beyond our usual and
customary rates have been disclosed and offered to
all parties.
This 28th day of May, 2025.
_______________ ___
Elizabeth R. Hollingsworth, B-1319
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
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
Pamela Ann Joseph
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 231
Case 3:21-md-02992-GPC-MSB Document 591-47 Filed 10/17/25 PageID.41827
Page 10 of 10File and source
- File
- gov.uscourts.casd.709615.591.47.pdf
- Size
- 213,735 bytes
- SHA-256
- 562e204a3631593e2b65ddeb08d2d378db8c9909bfd9ead43c6329799028da10
- Original
- PACER (login required)