Court filing
14O — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-48, 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. 591-48 · 2025-10-17 · Docket on CourtListener
Full text
DX 14.O
Case 3:21-md-02992-GPC-MSB Document 591-48 Filed 10/17/25 PageID.41828
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CONFIDENTIAL
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IN THE UNITED STATES DISTRICT COURT
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FOR THE SOUTHERN DISTRICT OF CALIFORNIA
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SAN DIEGO DIVISION
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IN RE: BANK OF AMERICA |
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CALIFORNIA UNEMPLOYMENT | Case Number:
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BENEFITS LITIGATION | 21-MD-02992-GPC-MSB
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This document relates |
to All Actions |
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CORRECTED TRANSCRIPT
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***CONFIDENTIAL***
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Video Deposition of
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J. DANIEL KREIS
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in Washington, D.C.
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Monday, May 5, 2025
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9:31 a.m.
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Veritext 7304174
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Reported by: Laurie Donovan, RPR, CRR, CLR
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CONFIDENTIAL
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MS. HAGGANS: And this will be Kreis Exhibit
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3.
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(Exhibit 3 was marked for
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identification.)
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BY MS. HAGGANS:
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Q So Mr. Kreis, I'm just going to hand these
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to you -- both to you at once, and we'll do a little
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housekeeping that will hopefully make this more
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organized going forward.
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A Okay.
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Q So looking first at the document that's
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marked Kreis Exhibit 2, do you recognize it?
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A Yes, I do.
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Q Okay. What is it?
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A This is my expert report that I provided on
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March 4.
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Q Okay, and what about Kreis Exhibit 3; do you
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recognize that document?
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A Yes, I do.
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Q What is it?
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A It is my rebuttal report on April 4.
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Q When were you first contacted about this
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case?
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A It was either October or November of 2023.
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Q Who contacted you?
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CONFIDENTIAL
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Q Yes.
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A That's, that's the only thing that I would
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say.
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Q Okay.
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Were there any people that you wanted to
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talk to in connection with this case that you weren't
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able to speak with?
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A No.
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Q Okay. If we can look at tab -- Exhibit 2,
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which is the opening report.
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A Mm-hmm.
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Q And we can go to paragraph 7, which is on
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page 4.
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A Okay.
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Q You there?
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A I am.
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Q Okay. So you note in paragraph 7 that your
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work is "ongoing," and you "reserve the right to
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supplement, amend, and revise."
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My question is whether -- other than the
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materials reflected in your rebuttal report, have you
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reviewed additional materials in connection with this
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case?
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A Say that again.
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Q Sure.
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CONFIDENTIAL
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So this paragraph 7 that's in your, in your
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opening report where you --
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A Yeah.
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Q -- reserve your, your right to, you know,
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review additional materials or conduct further
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analysis -- and, and I understand that since you wrote
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this, you've provided the rebuttal report --
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A Right.
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Q -- that, that we just looked at, and so I'm
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just trying to understand that. Other than the
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rebuttal report, have you done -- have you reviewed
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any additional materials?
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A No, not other than the rebuttal report.
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Q Okay. Other than as reflected in the
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rebuttal report, have you conducted any further
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analyses in connection with this case?
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A No, I have not.
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Q Okay. Other than the work in the rebuttal
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report, have you supplemented your opinions in this
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case in any way?
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A I'm not sure -- you mean have I written
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something else? Supplemented how?
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Q Or, or do you intend to supplement the
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opinions that you've offered in this case other than
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as, as detailed in the rebuttal?
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CONFIDENTIAL
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A No, I haven't done anything other than
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what's in the rebuttal, but obviously retain the right
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to further add to my report should new information
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come about.
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Q Okay. That's fair.
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I'm, I'm just trying to understand, as we
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sit here today, do you intend to offer any opinions in
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this case beyond the opinions that are articulated in
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the reports that you have submitted so far?
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A As of this moment, I have not been asked to
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offer any other opinions.
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Q Okay. Mr. Kreis, where are you employed?
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A I am the head and founder of First Camden
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Consulting.
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Q Well, that's -- so I apologize.
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So you're not -- are maybe not technically
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employed. So you, you work for your own consulting
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business?
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A Correct.
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Q Okay. How long have you been working for
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yourself?
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A About three years.
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Q Okay. How many years were you doing
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consulting before you started your own company?
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A My time at Fair Isaac was mostly consulting.
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CONFIDENTIAL
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CERTIFICATE OF SHORTHAND REPORTER -- NOTARY PUBLIC
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I, Laurie Donovan, Registered Professional
Reporter, Certified Realtime Reporter, and notary
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public for the District of Columbia, the officer
before whom the foregoing deposition was taken,
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do hereby certify that the foregoing transcript
is a true and correct record of the testimony
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given; that said testimony was taken by me
stenographically and thereafter reduced to
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typewriting under my supervision; and that I am
neither counsel for, related to, nor employed by
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any of the parties to this case and have no
interest, financial or otherwise, in its outcome.
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IN WITNESS WHEREOF, I have hereunto set my
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hand and affixed my notarial seal this 24th day
of JUNE 2025.
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My commission expires: July 14, 2027
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<%12445,Signature%>
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LAURIE DONOVAN
NOTARY PUBLIC IN AND FOR
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THE DISTRICT OF COLUMBIA
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