14Z — In re Bank of America California Unemployment Benefits Litigation (Dkt. 591-62, S.D. Cal. No. 3:21-md-02992)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 591-62 · 2025-10-17 · Docket on CourtListener

Full text

DX 14.Z 
REDACTED VERSION OF 
DOCUMENT SOUGHT TO 
BE SEALED PURSUANT TO 
STIPULATED 
PROTECTIVE ORDER 
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42309 
Page 1 of 9

Videotaped Deposition of
Carl Pry
May 16, 2025
In Re Bank of America CA Unemployment Benefits Litigation
Confidential
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42310 
Page 2 of 9

1  UNITED STATES DISTRICT COURT
  SOUTHERN DISTRICT OF CALIFORNIA
2  ----------------------------------------x
  IN RE BANK OF AMERICA CALIFORNIA
3  UNEMPLOYMENT BENEFITS LITIGATION
4                Case No:
                3:21-md-02992-GPC-MSB
5
  -----------------------------------------x
6
7       VIDEOTAPED DEPOSITION of CARL PRY, taken by
8  the Plaintiff, pursuant to Notice, held via ZOOM, on May
9  16, 2025, at 11:03 a.m., before a Notary Public of the
10  State of New York.
11
  *********************************************
12
13
  CONFIDENTIAL***
14
15  JOB NO. 10163120
16
17
18
19
20
21
22
23
24
25
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 1
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42311 
Page 3 of 9

1  Q.    Was there a point in your work on this case
2  where your role was anything other than serving as a
3  rebuttal expert witness?
4  A.    In this case, no.
That's been my only role.
5  Q.    You haven't provided any sort of litigation
6  support?
You make reference to that in your rebuttal
7  report.
8  A.    No, no.
I -- my only role within this
9  particular case is what we are talking about here, to
10  author and provide this rebuttal report.
11  Q.    Understood.
12      All right.
So if you turn to page 3 of you
13  report at paragraph 10, you indicate that you reserve
14  the right to revise your opinions, as stated in your
15  report.
16      Have you updated your opinions in any way, not
17  already reflected in Exhibit 2, this report?
18  A.    No, I've not.
19  Q.    Have you been provided any additional data
20  regarding potential fraudster or uninjured class
21  members?
22  A.    No, I've not been provided any additional data.
23  Q.    Sir, does Exhibit 2 contain all of the opinions
24  you intend to offer at trial in this case?
25  A.    Oh, Exhibit 2 is the report.
Yes, they do.
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 17
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42312 
Page 4 of 9

1  Q.    Sorry.
If I confuse Exhibit 2 in the report --
2  Exhibit 2 is the report?
3  A.    No.
My -- that's my confusion.
I was thinking
4  appendix 2, which has all the documents that I reviewed
5  to prepare my report.
That's my confusion.
6  Q.    We will talk about appendix 2.
7           MR. HOLLENBERG:
Now we're going to
8      mark another document as Exhibit 3, and that
9      will pop up in the chat as well.
So let me
10      know when you've had a chance to review that.
11           (Whereupon, Defendant's Rebuttal Expert
12      Designations was marked as Plaintiffs' Exhibit
13      3, for identification, as of this date.)
14           THE WITNESS:
I see:
"Defendant's
15      Rebuttal Expert Designations."
16  BY MR. HOLLENBERG:
17  Q.    Sir, have you ever seen this document before?
18  A.    Yes.
19  Q.    All right.
Direct your attention to the bottom
20  of page 4 and top of page 5 of Exhibit No. 3.
You see
21  the heading A, "Mr. Pry is expected to testify regarding
22  the following rebuttal topics"?
23  A.    I do.
24  Q.    Now, is the description of your anticipated
25  opinion or opinions previewed here on pages 4 and 5 of
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 18
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42313 
Page 5 of 9

Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42314 
Page 6 of 9

Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42315 
Page 7 of 9

Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42316 
Page 8 of 9

1   C E R T I F I C A T E
2  STATE OF NEW YORK   )
3                ) ss.:
4  COUNTY OF QUEENS )
5
6           I, BROOKE E. PERRY, a Notary Public
7      within and for the State of New York, do hereby
8      certify:
9           That CARL PRY, the witness whose
10      deposition is hereinbefore set forth, was duly
11      sworn by me and that such deposition is a true
12      record of the testimony given by such witness.
13           I further certify that I am not related
14      to any of the parties to this action by blood
15      or marriage; and that I am in no way interested
16      in the outcome of this matter.
17           IN WITNESS WHEREOF, I have hereunto set
18      my hand this 16th day of May, 2025.
19
20
  -------------------------
21  BROOKE E. PERRY
22
23
24
25
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Carl Pry
Confidential
In Re Bank of America CA Unemployment Benefits Litigation
www.aptusCR.com
Page 259
Case 3:21-md-02992-GPC-MSB     Document 591-62     Filed 10/17/25     PageID.42317 
Page 9 of 9

File and source

File

gov.uscourts.casd.709615.591.62.pdf

Size

251,427 bytes

SHA-256

4111198adeefec53a59386d57c6acc28d93430643d08adddc76c695b475a80ac

Our copy

gov.uscourts.casd.709615.591.62.pdf

Original

PACER (login required)