Court filing

14O — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-48, S.D. Cal. No. 3:21-md-02992)

Summary

DX 14.O, filed 10/17/25 as Document 591-48 (7 pages) in In re Bank of America California Unemployment Benefits Litigation, Case Number 21-MD-02992-GPC-MSB, U.S. District Court for the Southern District of California, contains pages of the corrected transcript of the video deposition of the plaintiffs' expert J. Daniel Kreis, taken in Washington, D.C. on Monday, May 5, 2025. Questioned by Bank of America's counsel Ms. Haggans, Kreis identifies his opening expert report of March 4 and rebuttal report of April 4. He says he was first contacted about the case in either October or November of 2023. He testifies that he has reviewed no additional materials and done no further analysis beyond the rebuttal, and has not been asked to offer other opinions.

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Filed October 17, 2025 in In re Bank of America California Unemployment Benefits Litigation; one of 1602 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of California
Filed	2025-10-17

Cite this document

“14O — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-48, S.D. Cal. No. 3:21-md-02992).” U.S. District Court for the Southern District of California, No. 3:21-md-02992-GPC-MSB, Doc. 591-48, filed 2025-10-17. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-bofa-ca-unemployment-casd-709615/2025-10-17-gov-uscourts-casd-709615-591-48-gov-uscourts-casd-709615-591-48/, SHA-256 768984f89031ea499d0e8499391378cd068233745296082aa34a2c92f7b5d204.

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Full text

DX 14.O 
Case 3:21-md-02992-GPC-MSB     Document 591-48     Filed 10/17/25     PageID.41828 
Page 1 of 7

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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 ---------------------------|
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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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Page 3 of 7

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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